3. Distances between stationary point-source noise generators and surrounding sensitive receptor locations were measured using Project architectural drawings, Google Earth, and site plans;
43 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-23 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
4. Stationary point-source noise levels were then calculated for each sensitive receptor location based on the standard point source noise-distance attenuation factor of 6 dBA for each doubling of distance;
5. Noise level increases, if any, were compared to the stationary point -source noise significance thresholds identified above in Section Thresholds of Significance subsection; and
6. Outdoor mechanical equipment is assessed based on the City Municipal Code requirements and measured data, and their impacts on the nearby offsite receptors are determined based on their distance from these receptors. The noise levels determined at the offsite, noise -sensitive receptors are then compared to the stationary source noise significance thresholds identified in the City Municipal Code.
For purposes of providing a conservative noise analysis for outdoor spaces, the maximum occupant load of Project outdoor spaces was calculated based on an occupancy load factor of 15 square feet per person for an assembly area without fixed seats, accordin g to the California Building Code Table 1004.5 Maximum Floor Area Allowances Per Occupant. 44 Although this occupancy load factor provides an overestimation of the occupancy load and associated noise within passive landscaped areas, it has been applied to the square footage of the Project’s outdoor spaces to provide a conservative worst-case noise analysis. It has been assumed that up to 318 people would occupy the first-floor outdoor spaces (Hannum Plaza) at one time, 497 people would occupy the second - floor amenities (exterior courtyard) at one time, and 830 people would occupy the sixth -floor amenities (outdoor amenity deck and pool area) at one time .45 Simultaneous occupation of the outdoor spaces with this number of people is not anticipated by the Project.
Noise from female adults, male adults, and children talking at a normal level is approximately 55 dBA, 58 dBA, and 58 dBA, respectively, at a distance of 3 feet.46 As a conservative analysis, it is assumed that each outdoor space would be at full capacity and that half of the visitors would be adults (half male and half female) and half would be children. Of the adults and children, half would be talking simultaneously (assuming approximately half of the occupants talking and the other half listening). Low volume amplified sound is expected in the outdoor areas.
Parking-related noise levels were estimated using the methodology recommended by FTA for the general assessment of stationary transit noise source. Using the methodology, the Project’s peak hourly noise level that would be generated by the onsite parking levels was estimated using the following FTA equation for a parking lot:
Leq(h) = SELref + 10log(NA/1000) – 35.6, where
Leq(h) = hourly Leq noise level at 50 feet
SELref = reference noise level for stationary noise source represented in sound exposure level (SEL) at 50 feet
NA = number of automobiles per hour
44 California Building Standards Commission, 2019 Title 24, Part 2, Volume 1 – California Building Code. 45 Occupancy loads were provided by the applicant.
46 American Journal of Audiology Vol.7 21-25 October 1998. doi:10.1044/1059-0889(1998/012).
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-24 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
The Project’s loading areas are located on the north and south sides of the Project. Based on a noise survey that was conducted at a loading area and trash collection facilities by ESA, loading area activity (namely idling semi -trucks and backup alarm beeps) could generate noise levels of approximately 70 dBA Leq at a reference distance of 50 feet.47 Groundborne Vibration (Construction and Operations)
Groundborne vibration impacts due to the Project’s construction activities were evaluated by identifying potential vibration sources (i.e., construction equipment), estimating the vibration levels at the potentially affected receptor, and comparing the Project’s activities to the applicable vibration significance thresholds. Vibration levels were calculated based on the FTA published standard vibration velocities for various construction equipment operations.48 The vibration velocities were calculated based on a point source with standard distance propagation conditions, pursuant to FTA procedures. Construction of the Project would not use impact pile driving methods, and as such, impact pile driving vibration is not included in the construction vibration analysis.
Exterior-to-Interior Noise Attenuation
Exterior , interior with windows open, and interior with windows closed noise levels are calculated for on-site construction noise and on-site stationary operational noise. For buildings with windows open would provide approximately 13 dBA exterior/interior noise reduction. With windows closed, the minimum exterior -to-interior noise attenuation for typical structures in California is approximately 25 to 30 dBA or potentially more with improved noise abatement materials or techniques. For purposes of this analysis, th e exterior-to-interior noise attenuation for buildings with windows closed is assumed to be 25 dBA.49
Project Design Features
As discussed above, the City’s General Plan Noise Element includes Policy 2.A, which discusses the use of temporary sound barriers at a construction site if construction noise is impacting nearby noise sensitive land uses. Since noise sensitive land uses are located in prox imity to the Project Site, the following Project Design Features (PDF) are recommended and have been incorporated into the Project’s construction plans:
NOI-PDF-1: Project Construction Schedule . Prior to issuance of a building permit, notice of the Project construction schedule will be provided to adjacent property owners and occupants. Evidence of such notification will be provided to the City of Culver City Public Works Department. The notice will identify the commencement date and proposed timing for all construction phases (demolition, grading, excavation/shoring, foundation, rough frame, plumbing, roofing, mechanical and electrical, and exterior finish).
47 The loading dock facility noise measurements were conducted at a loading dock facility at a Wal-Mart store using the Larson-Davis 820 Precision Integrated Sound Level Meter (“SLM”) in May 2003. The Larson-Davis 820 SLM is a Type 1 standard instrument as defined in the American National Standard Institute S1.4. All instruments were calibrated and operated according to the applicable manufacturer specification. The microphone was placed at a height of approximately 5 feet above the local grade.
48 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018, Table 7-4. 49 Gordon, C.G., W.J. Galloway, B.A. Kugler, and D.L. Nelson. NCHRP Report 117: Highway Noise: A Design Guide for Highway Engineers. Washington, D.C.: Transportation Research Board, National Research Council, 1971.
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4.8. Noise
City of Culver City 4.8-25 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
NOI-PDF-2: Use of Impact Pile Driver. The Project will not require or allow the use of impact pile drivers. Lower noise- and vibration-generating shoring piles to be drilled will be used.
NOI-PDF-3: Construction Rules Sign. During all phases of construction, a “Construction Rules Sign” that includes contact names and telephone numbers, with 24-hour availability, of the Applicant, Property Owner, construction contractor(s) will be posted on the Property in a location that is visible to the public. In addition, appropriate staff person at the City of Culver City will be notified for such incidences. These names and telephone numbers will also be made available to adjacent property owners and occupants to the satisfaction of the appropriate department (Planning Manager and/or Building Official) of Culver City.
NOI-PDF-4: Neighborhood Streets. No construction haul trucks, including concrete trucks, will be allowed to travel through neighborhood streets that are primarily residential uses.
NOI-PDF-5: Mechanical Equipment Noise. All building mechanical equipment and/or ventilation systems not fully enclosed will be designed to not exceed sound level limits of the noise level requirements of the City of Culver City General Plan Noise Element Regulation of Stationary Noise Sources through the use of quiet fans, duct silencers, parapets, or similar noise attenuation methods.
NOI-PDF-6: Noise Control – Amplified Sound Systems . If the Project installs permanent outdoor amplified sound systems, the systems will be located in discrete areas of the outdoor common opens space areas courtyard such that the sound would be mostly blocked by the proposed on -site building or walls from off -site residential receivers.
Section 9.07.055(B) of the CCMC prohibits the operation of a loud speaker or sound amplifying equipment for the purposes of transmitting messages, giving instructions or providing entertainment which is audible at a distance of fifty (50) feet or beyond the subject's property line without first filing an application and obtaining a permit as set forth in Chapter 9.07, Noise Regulations, of the CCMC . The systems will at a minimum be designed so as not to result in a perceivable increase at the nearest noise sensitive residential receptor. Specifically, daytime outdoor amplified sound systems will not result in an increase of 5 dBA L eq over existing ambient noise conditions at the nearest noise sensitive residential receptor . Nighttime speaker noise, if it occurs, will comply with the exterior noise standards identified in the Regulation of Stationary Noise Sources (City of Culver City General Plan Noise Element, approved by City Council July 22, 1996) . A qualified noise consultant will provide written documentation and submitted to appropriate department of City of Culver City that the design of the system(s) complies with the maximum noise levels at the property line of the nearest off-site sensitive receivers.
In addition, see Project Design Feature TRAF-PDF-1 in Section 1.11, Transportation, of this Draft EIR which includes preparation of a Construction Management Plan.
Analysis of Project Impacts
Threshold NOISE-1: The Project would have a potentially significant impact on noise if it would result in the generation of a substantial temporary or permanent increase in ambient noise level in the vicinity of the Project in excess of the applicable standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-26 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Impact Analysis
On-Site Construction Noise
Noise impacts from construction activities are generally a function of the noise generated by construction equipment, equipment locations, the sensitivity of nearby land uses, and the timing and duration of the noise-generating activities. Project construction is anticipated to commence in the first quarter of 2025 and require up to 30 months.
Construction sequencing would include demolition; grading/excavation; foundations; building construction; architectural coating; and paving/sitework. Project construction would require the use of mobile heavy equipment with high noise-level characteristics. Individual pieces of construction equipment expected to be used during Project construction could produce maximum noise levels of 73 dBA to 85 dBA a t a reference distance of 50 feet from the noise source, as shown in Table 4.8-6, Construction Equipment N oise Levels . These maximum noise levels would occur when equipment is operating under full power conditions. The estimated usage factor for the equipment is also shown in 4.8-6. The usage factors are based on the FHWA’s Roadway Construction Noise Model User’s Guide.50
TABLE 4.8-6
CONSTRUCTION EQUIPMENT NOISE LEVELS
Equipment
Estimated Usage
Factor, %
Maximum Noise Level at 50 feet
from Equipment, dBA (Lmax)
Aerial Lift 20 75
Air Compressor 40 78
Bore/Drill Rig 20 79
Concrete Saw 20 90
Crane 16 81
Excavator 40 81
Forklift 10 75
Generator Sets 50 81
Grader 40 85
Off Highway Truck 40 76
Paver 50 77
Paving Equipment 50 85
Pumps 50 81
Rough Terrain Forklift 10 75
Rubber Tired Loader 40 79
Skid Steer Loader 40 78
Surfacing Equipment 20 90
Sweepers/Scrubbers 10 82
Tractor/Loader/Backhoe 40 78
SOURCE: FHWA Roadway Construction Noise Model User’s Guide, 2006.
50 Federal Highway Administration, Roadway Construction Noise Model User’s Guide, 2006. https://www.gsweventcenter.com/Draft_SEIR_References/2006_01_Roadway_Construction_Noise_Model_User_ Guide_FHWA.pdf
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-27 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
A summary of construction noise impacts at existing nearby sensitive receptors for different times of day and scenarios is provided in Table 4.8-7, with supporting calculations provided in Appendix G of this Draft EIR.
As shown in Table 4.8-7, exterior construction noise levels are estimated to reach a maximum of 66.4 dBA Leq at the off-site receptor locations R1, 63.6 dBA Leq at R2, 84.8 dBA Leq at R3, and 84.8 dBA Leq at R4, 65.5 dBA Leq at R5. Projected construction noise levels would exceed morning and daytime noise thresholds at R3 and R4and impacts would be potentially significant before implementation of mitigation measures. As indicated above, 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. In the event construction occurs outside of the permitted hours without approval from the City of Culver City, a significant impact would occur because of the noncompliance with existing regulations. It is anticipated that the Project would seek approval from the City to initiate construction as early as 7:00 a.m. During these extended construction hours (i.e., 7:00 a.m. to 8:00 a.m. on weekdays and 7:00 to 9:00 a.m. on Saturdays ) occurring within the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction, noise levels could still nonetheless exceed the thresholds as shown in Table 4.8-7 even if an extended hours permit is granted, and also for this reason, would be considered a potentially significant impact.
As discussed in Chapter 2, Project Description, of this Draft EIR, the extended construction hours are being requested over the course of approximately four (4) months during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction . The other construction phases would occur per the allowable standard CCMC permitted construction hours.
As Project construction would result in temporary increases in ambient noise that would meet or exceed the thresholds of significance (see NC -1, NC-2, and NC-3 in Thresholds) at nearby noise sensitive receptors, construction noise impacts would be potentially significant , and mitigation measures would be required.
On-Site Construction Noise – Commercial Land Uses
For informational purposes only, nearby commercial land uses were analyzed at locations R6 through R8. As shown in Table 4.8-8, Estimated Construction Noise Levels at Commercial Land Uses, noise levels would be 53.8 dBA Leq at R6, 59.8 dBA Leq at R7, and 46.6 dBA Leq at R8. Note that receptors R6 through R8 are commercial land uses with no exterior uses other than driveways, parking, and other similar uses, and as such, exterior noise levels were not analyzed. The maximum increase in interior noise would be 3.2 dBA Leq at receptor R7 relative to the ambient noise level.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-28 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-7
ESTIMATED CONSTRUCTION NOISE LEVELS AT EXISTING OFF-SITE SENSITIVE RECEPTORS Noise
Sensitive
Receptor
Maximum Construction Noise Levels,a
(Exterior/Interior with windows
open/Interior with windows closed)
Hourly Leq (dBA)
Morning Noise
Threshold
(Ambient + 5 dBA)
Exceeds Threshold?
(Exterior/Interior with
Windows Open/Interior
with Windows Closed)
Daytime Noise
Threshold
(Ambient + 5 dBA)
Exceeds Threshold?
(Exterior/Interior with
Windows Open/Interior
with Windows Closed)
R1 66.4 / 53.4 / 41.4 76.5 No / No / No 68.0 No / No / No R2 63.6 / 50.6 / 38.6 73.7 No / No / No 68.4 No / No / No R3 84.8 / 71.8 / 59.8 67.8 Yes / Yes / No 64.6 Yes / Yes / No R4 84.8 / 71.8 / 59.8 69.3 Yes / Yes / No 66.2 Yes / Yes / No R5 65.5 / 52.5 / 40.5 72.5 No / No / No 68.2 No / No / No a Estimated construction noise levels represent the worst-case condition when noise generators are located closest to the receptors. b Bold values indicate an exceedance of either the morning or daytime noise threshold. c Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
SOURCE: ESA, 2023.
TABLE 4.8-8
ESTIMATED CONSTRUCTION NOISE LEVELS AT COMMERCIAL LAND USES Commercial
Land Use
Maximum Construction Noise Levels,a
(Exterior / Interior) Hourly Leq (dBA)
Ambient Noise Level –
Morning (dBA Leq)
Ambient Noise Level –
Daytime (dBA Leq)
R6 NA / 53.8b,c 66.2 65.7
R7 NA / 59.8b,c 56.6 57.1
R8 NA / 46.6b,c 56.7 53.5
a Estimated construction noise levels represent the worst-case condition when noise generators are located closest to the receptors. b Noise levels account for an exterior-to-interior noise attenuation rate of 25 dBA for buildings with windows closed. c Note that locations R6 through R8 are commercial land uses and as such, exterior noise levels were not analyzed.
SOURCE: ESA, 2023.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-29 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Off-Site Construction Noise
Delivery and haul truck trips would occur throughout the construction period, including during extended hours between 7:00 a.m. and 8:00 a.m. on weekdays and 7:00 a.m. to 9:00 a.m. on Saturdays during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction. For the remainder of the construction period, no truck trips would occur between 8:00 p.m. and 8:00 a.m. Monday through Friday, before 9:00 a.m. or after 7:00 p.m. on Saturday, or before 10:00 a.m. and 7:00 p.m. on Sunday.
As shown in Table 4.8-9, Estimate of Off-Site Construction Traffic Noise Levels , the addition of 190 haul truck trips, 26 vendor truck trips, and 60 worker trips per day (24 truck trips, 4 vendor trips, and 30 worker trips per peak hour) during the grading/excavation phase would result in a less than perceptible 3 dBA noise level increase along affected roadway segments in the project vicinity and would not increase noise levels by a “ clearly noticeable” increase of 5 dBA over the ambient condition. The majority of truck trips would occur during the grading/excavation phase of construction. Trucks entering the site would arrive from State Route 90, head east on Slauson Avenue, then head south on Buckingham Parkway.
TABLE 4.8-9
ESTIMATE OF OFF-SITE CONSTRUCTION TRAFFIC NOISE LEVELS
Roadway Segment
Existing Land Uses
Located along
Roadway Segment
CNEL (dBA)
Existing
(A)
Existing
with Project
Construction
(B)
Project
Increment
(B–A)
Exceed
Threshold?
Buckingham Pkwy
between Hannum Ave and Green Valley Cir Residential/Commercial/ Open Space
66.6 67.9 1.3 No
between Slauson Ave and Hannum Ave Residential/Commercial 61.8 64.9 3.1 No Fox Hills Dr
s/o Hannum Ave Commercial 65.6 67.3 1.7 No
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.9 70.1 1.2 No between Fox Hills Dr and Bristol Pkwy Commercial 66.6 67.6 1.0 No between Slauson Ave and Fox Hills Dr Commercial 68.9 69.7 0.8 No between Uplander Wy and Buckingham Pkwy Commercial 68.8 70.0 1.2 No Marina Fwy
s/o Slauson Ave Freeway Off-Ramp 73.1 73.4 0.3 No
Slauson Ave
between Hannum Ave and Marina Fwy Residential/Commercial 70.2 70.8 0.5 No e/o Buckingham Pkwy Residential/Commercial 75.9 76.2 0.3 No w/o Hannum Ave Commercial 70.7 71.5 0.8 No
SOURCE: ESA 2023. Appendix G of this Draft EIR.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-30 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Alternatively, trucks would arrive from northbound Interstate 405, exit at Sepulveda Boulevard, head east on Green Valley Circle, head north on Fox Hills Drive, then head east on Hannum Avenue to reach the Project Site. Trucks would exit the site and head north on Buckingham Parkway, then either head west on Slauson Avenue to Interstate 405 or, head west on Hannum Aven ue, head west on Slauson Avenue, head south on Jefferson Avenue, and merge onto the Interstate 405 north or south.
As indicated in Table 4.8 -8, the Project’s vehicle trips would increase existing traffic noise levels from 61.8 dBA CNEL to 64.9 dBA CNEL (an increase of 3.1 dBA CNEL) along Buckingham Parkway between Slauson Avenue and Hannum Avenue, where noise -sensitive uses (e.g., multi - family residential uses) are located. As shown in Figure 4.8-2, noise levels are considered “normally acceptable” if they are between 50 dBA CNEL or lower and 65 dBA CNEL, “conditionally acceptable” if they are between 60 dBA CNEL and 70 dBA CNEL, “normally unacceptable” if they are between 70 dBA CNEL and 75 dBA CNEL, or “clearly unacceptable” if they are greater than 75 dBA CNEL. Since the existing noise levels along Buckingham Parkway between Slauson Avenue and Hannum Avenue are within the “normally acceptable” and “conditionally acceptable” categories, the noise threshold of a 5 dBA CNEL increase over existing noise levels applies to the street segment.
This increase does not represent an exceedance of the significance threshold of an increase of 3 dBA CNEL to or within the “normally unacceptable” or “clearly unacceptable” categories or an increase by 5 dBA CNEL or more within the “normally acceptable” or “conditionally acceptable” categories.
Therefore, based on this additional supporting evidence, noise impacts from off -site construction traffic would be less than significant and no mitigation measures are required.
On-Site Operational Noise
Fixed Mechanical Equipment
The Project would include new mechanical equipment (e.g., air ventilation equipment), which would be located at the roof level. Mechanical equipment such as air conditioning equipment and emergency generators may generate audible noise levels. Equipment such as emergency generators, would be located within enclosed mechanical rooms, which would shield the noise at off-site noise sensitive uses so as to avoid land use noise conflicts with adjacent uses and minimize audible increases in exterior noise levels at off-site noise sensitive uses. Table 4.8-10, Mechanical Equipment Noise Levels at Noise Sensitive Receptors, presents the estimated on-site mechanical equipment noise levels at the off -site receptor locations. As shown on Table 4.8 -9, the estimated noise levels from the mechanical equipment would range from 21.3 dBA (Leq) to R8 to 46.9 dBA (Leq) at receptor locations R2 and R3, which would be below the existing ambient noise levels. As such, the estimated noise levels at all off-site receptor locations would be below the significance threshold of 5 dBA (Leq) above ambient noise levels. As such, the Project would not result in the generation of a substantial permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established by the City, and impacts from mechanical equipment noise would be less than significant.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-31 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-10
MECHANICAL EQUIPMENT NOISE LEVELS AT NOISE SENSITIVE RECEPTORS Receptor
Location
Existing
Ambient Noise
Levels,a
dBA (Leq)
Estimated Noise from Project
Mechanical Equipment,b,c
(Exterior/Interior with
windows open/Interior with
windows closed) dBA (Leq)
Ambient + Project Noise
Levels (Exterior/Interior with
windows open/Interior with
windows closed), dBA (Leq)
Significance
Thresholdd
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 63.0 27.8 / 14.8 / 2.8 63.0 / 63.0 / 63.0 68.0 0.0 No R2 63.4 21.3 / 8.3 / 0.0 63.4 / 63.4 / 63.4 68.4 0.0 No R3 59.6 46.9 / 33.9 / 21.9 59.8 / 59.6 / 59.6 64.6 0.0 No R4 61.2 40.9 / 27.9 / 15.9 61.2 / 61.2 / 61.2 66.2 0.0 No R5 63.2 26.1 / 13.1 / 1.1 63.2/ 63.2 / 63.2 68.2 0.0 No NOTES:
a The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is used for the purposes of impact determination.
b Exterior reference noise levels for air condenser units, fans, and related equipment, the primary sources of noise from fixed mechanical equipment, would be
81.9 dBA Leq measured at a distance of 5 feet (based on noise data from large shopping center projects in Southern California). Refer to: City of Moreno Valley, Moreno Valley Walmart Noise Impact Analysis, Table 9-1, Page 71, February 10, 2015; and City of Pomona, Pomona Ranch Plaza Walmart Expansion Project, Table 4.4-5, Pg. 4.4-33, August 2014. Assumes mechanical equipment noise generated by the closest Project building to each sensitive receptor. c Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed. d Significance thresholds are equivalent to the measured daytime or morning ambient noise levels, whichever is lower plus 5 dBA.
SOURCE: ESA 2023
Parking Structure Noise
Ingress/egress driveways to the internal parking garage/structure would be located on the P1 Level from Hannum Avenue and on the P2 level from Buckingham Parkway. Based on the traffic data provided to ESA, the afternoon peak hour traffic volume would be 59 vehicles entering and exiting the parking structure. The vehicles could enter the Project Site from either Hannum Avenue or Buckingham Parkway.51 To provide a worse-case conservative analysis, assuming all 59 vehicles entered the parking structure from Buckingham Parkway, using FTA’s calculation for noise generated by parking lot traffic, the entering vehicles would create noise levels up to 44 dBA.52 Sources of noise within the below -grade parking structure would primarily include vehicular movements, engine noise and vehicle door opening and closing. Noise generated within the parking structure would be effectively shielded from off -site sensitive receptor locations, as the structure would be fully enclosed on all sides. However, for purposes of this analysis peak hour trips from the Project are assumed to occur at the closest parking garage driveway to each sensitive receptor.
Table 4.8-11, On-Site Parking Noise Levels at Noise Sensitive Receptors , presents the estimated noise levels from the parking garage at the off-site receptor locations. As indicated in Table 4.8-10, the estimated noise levels from the Project’s parking garage would be well below existing ambient noise levels and the significance threshold of 5 dBA (Leq) above ambient noise levels. As such, the Project would not result in the generation of a substantial permanent increase in ambient noise levels
51 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
52 FTA, Transit Noise and Vibration Impact Assessment. September, 2018, Tables 4-13 and 4-14.
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City of Culver City 4.8-32 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
in the vicinity of the Project in excess of standards established by the City, and impacts from parking facilities would be less than significant.
TABLE 4.8-11
ON-SITE PARKING NOISE LEVELS AT NOISE SENSITIVE RECEPTORS Receptor
Location
Existing Ambient
Noise Levels,a
dBA (Leq)
Estimated Noise from Project
Parking, (Exterior/Interior with
windows open/Interior with
windows closed)b
dBA (Leq)
Ambient + Project Noise
Levels (Exterior/Interior
with windows open/Interior
with windows closed)
dBA (Leq)
Significance
Thresholdc
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 63.0 25.0 / 12.0 / 0.0 63.0 / 63.0 / 63.0 68.0 0.0 No R2 63.4 18.5 / 5.5 / 0.0 63.4 / 63.4 / 63.4 68.4 0.0 No R3 59.6 44.1 / 31.1 / 19.1 59.6 / 59.6 / 59.6 64.6 0.0 No R4 61.2 44.1 / 31.1 / 19.1 61.2 / 61.2 / 61.2 66.2 0.0 No R5 63.2 23.3 / 10.3 / 0.0 63.2 / 63.2 / 63.2 68.2 0.0 No NOTES:
a The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is used for the purposes of impact determination.
b Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed. c Significance thresholds are equivalent to the measured daytime or morning ambient noise levels, whichever is lower plus 5 dBA.
SOURCE: ESA 2023
Loading Areas and Refuse Collection
Temporary loading would be provided along Buckingham Parkway and in the northwestern corner of the Project Site south of Hannum Avenue. Based on a noise survey that was conducted at a loading area and trash collection facilities by ESA, loading area activity (namely idling semi-trucks and backup alarm beeps) and trash compactors could generate noise levels of approximately 70 dBA Leq and 66 dBA Leq, respectively, at a reference distance of 50 feet.53 Delivery truck idling is restricted to no more than five consecutive minutes in the loading area pursuant to State regulation (Title 13 California Code of Regulations [CCR], Section 2485) . Pursuant to Title 13 California Code of Regulations [CCR], Section 2485 , signs would be posted in delivery loading areas specifying this idling restriction. Based on the engine idling limitation of five minutes, the hourly average noise level would be 59.2 dBA L eq at 50 feet. As shown in Table 4.8-12, Loading Areas and Refuse Collection Noise Levels, loading activity and trash compaction would be reduced to
56.3 dBA Leq or lower at the closest receptors located to the east of the Project Site. Therefore, the noise levels from the Project’s loading and refuse collection areas would not exceed by 5 dBA over the ambient noise levels captured at sensitive receptors in the Project vicinity and impacts would be less than significant.
53 The loading dock facility noise measurements were conducted at a loading dock facility at a Wal-Mart store using the Larson-Davis 820 Precision Integrated Sound Level Meter (“SLM”) in May 2003. The Larson-Davis 820 SLM is a Type 1 standard instrument as defined in the American National Standard Institute S1.4. All instruments were calibrated and operated according to the applicable manufacturer specification. The microphone was placed at a height of approximately 5 feet above the local grade.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-33 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-12
LOADING AREAS AND REFUSE COLLECTION NOISE LEVELS
Receptor
Location
Existing
Ambient
Noise
Levels,a
dBA (Leq)
Estimated Noise from Project
Parking, (Exterior/Interior with
windows open/Interior with
windows closed)b
dBA (Leq)
Ambient + Project Noise
Levels (Exterior/Interior with
windows open/Interior with
windows closed)
dBA (Leq)
Significance
Thresholdc
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 63.0 35.7 / 22.7 / 10.7 63.0 / 63.0 / 63.0 68.0 0.0 No R2 63.4 28.2 / 15.2 / 3.2 63.4 / 63.4 / 63.4 68.4 0.0 No R3 59.6 56.3 / 43.3 / 31.3 61.3 / 59.6 / 59.6 64.6 0.0 No R4 61.2 54.1 / 41.1 / 29.1 62.0 / 61.2 / 61.2 66.2 0.0 No R5 63.2 26.3 / 13.3 / 1.3 63.2 / 63.2 / 63.2 68.2 0.0 No NOTES:
a The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is used for the purposes of impact determination.
b Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed. c Significance thresholds are equivalent to the measured daytime or morning ambient noise levels, whichever is lower plus 5 dBA.
SOURCE: ESA 2023
Off-Site Operational Traffic Noise
Impacts Under Existing Traffic Baseline Conditions
Existing roadway noise levels were calculated along various roadway segments near to the Project Site.
Roadway noise attributable to Project development was calculated using the traffic noise model previously described and was compared to baseline noise levels that would occur under the “No Project” condition. Project impacts are shown in Table 4.8-13, Off-Site Traffic Noise Impacts – Existing Plus Project Conditions, with supporting calculation files provided in Appendix G of this Draft EIR.
TABLE 4.8-13
OFFSITE TRAFFIC NOISE IMPACTS – EXISTING PLUS PROJECT CONDITIONS
CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Existing
Existing +
Project Difference
Bristol Pkwy
between Hannum Ave and Green Valley Cir Commercial 71.2 71.2 0.1 between Slauson Ave and Hannum Ave Commercial 70.1 70.3 0.2 n/o Slauson Ave Cemetery 59.8 59.8 0.0
s/o Green Valley Cir Residential/Hotel/Cemetery 64.4 64.5 0.1 Buckingham Pkwy
between Hannum Ave and Green Valley Cir Residential/Commercial/ Open Space
66.6 66.8 0.2
between Slauson Ave and Hannum Ave Residential/Commercial 61.8 61.8 0.0 n/o Hannum Ave Commercial 52.7 52.7 0.0
n/o Slauson Ave Commercial 60.6 60.6 0.0
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-34 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-13
OFFSITE TRAFFIC NOISE IMPACTS – EXISTING PLUS PROJECT CONDITIONS
CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Existing
Existing +
Project Difference
Centinela Ave
e/o Green Valley Cir Residential/Commercial 74.4 74.4 0.0 w/o Green Valley Cir Cemetery 72.9 72.9 0.0
Fox Hills Dr
s/o Hannum Ave Commercial 65.6 65.6 0.0
Green Valley Cir
between Bristol Pkwy and Buckingham Pkwy Residential/Educational/ Open Space
69.6 69.7 0.1
between Buckingham Pkwy and Centinela Ave Residential 70.7 70.7 0.0 w/o Bristol Pkwy Hotel/Commercial 70.5 70.5 0.1
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.9 69.1 0.2 between Fox Hills Dr and Bristol Pkwy Commercial 66.6 66.6 0.0 between Slauson Ave and Fox Hills Dr Commercial 68.9 68.9 0.0 between Uplander Wy and Buckingham Pkwy Commercial 68.8 69.1 0.3 n/o Slauson Ave Residential/Commercial 70.6 70.6 0.0
Marina Fwy
s/o Slauson Ave Freeway Off Ramp 73.1 73.2 0.0
Slauson Ave
between Bristol Pkwy and Buckingham Pkwy Commercial/Cemetery 74.8 74.8 0.0 between Hannum Ave and Marina Fwy Residential/Commercial 70.2 70.2 0.0 between Marina Fwy and Bristol Pkwy Commercial 73.8 73.8 0.0 e/o Buckingham Pkwy Residential/Commercial 75.9 76.0 0.0 w/o Hannum Ave Residential/Commercial 70.7 70.7 0.1
Uplander Wy
n/o Hannum Ave Commercial 53.9 53.9 0.0
s/o Hannum Ave Commercial 56.3 56.6 0.3
a Calculated based on existing traffic volumes.
NOTE:
s/o: south of
e/o: east of
n/o: north of
w/o: west of
SOURCE: ESA, 2023.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-35 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
As indicated, the maximum increase in Project-related traffic noise levels over existing traffic noise levels would be 0.3 dBA CNEL, which would occur along Hannum Avenue between Uplander Way and Buckingham Parkway and along Uplander Way south of Hannum Avenue. This increase in noise level would be below a “ clearly noticeable” increase of 5 dBA CNEL in an area characterized by normally acceptable noise levels that would remain below 55 dBA CNEL or conditionally acceptable noise levels that would remain below 70 dBA CNEL. The increase in sound level would be lower at the remain ing roadway segments analyzed. Therefore, Project - related nois e increases would be less than the applicable threshold and therefore less than significant, and no mitigation measures would be required.
Impacts Under Future plus Project Conditions Traffic Noise Future off-site traffic-generated noise impacts were assessed based on a comparison of the future cumulative base traffic volumes with the Project to the future year (2027) base traffic volumes without the Project. The results of that comparison are provided in Table 4.8-14, Off-Site Traffic Noise Impacts – Future Plus Project Conditions. Table 4.8-13 shows the Project’s contribution to the cumulative noise levels. The maximum cumulative noise increase from the Project plus related Project traffic would be 0.3 dBA CNEL, which would occur along Hannum Ave nue between Uplander Way and Buckingham Parkway and along Uplander Way south of Hannum Avenue. This increase in sound level would not exceed the significance thresholds of an increase of 5 dBA CNEL in an area characterized by conditionally acceptable noise levels that would remain below 70 dBA CNEL. As a result, cumulative off -site traffic-related noise impacts would not be cumulatively considerable and impacts would be less than significant.
TABLE 4.8-14
OFFSITE TRAFFIC NOISE IMPACTS – FUTURE PLUS PROJECT CONDITIONS
CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use
Future Year
(2027)
Future +
Project Difference
Bristol Pkwy
between Hannum Ave and Green Valley Cir Commercial 71.9 71.9 0.0 between Slauson Ave and Hannum Ave Commercial 72.5 72.6 0.1 n/o Slauson Ave Cemetery 60.0 60.0 0.0
s/o Green Valley Cir Residential/Hotel/Cemetery 65.0 65.1 0.1 Buckingham Pkwy
between Hannum Ave and Green Valley Cir Residential/Commercial/ Open Space
67.1 67.2 0.2
between Slauson Ave and Hannum Ave Residential/Commercial 62.5 62.6 0.1 n/o Hannum Ave Commercial 52.9 52.9 0.0
n/o Slauson Ave Commercial 60.7 60.7 0.0
Centinela Ave
e/o Green Valley Cir Residential/Commercial 74.8 74.8 0.0 w/o Green Valley Cir Cemetery 73.1 73.1 0.0
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-36 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-14
OFFSITE TRAFFIC NOISE IMPACTS – FUTURE PLUS PROJECT CONDITIONS
CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use
Future Year
(2027)
Future +
Project Difference
Fox Hills Dr
s/o Hannum Ave Commercial 65.7 65.7 0.0
Green Valley Cir
between Bristol Pkwy and Buckingham Pkwy Residential/Educational/ Open Space
70.2 70.3 0.1
between Buckingham Pkwy and Centinela Ave Residential 71.5 71.5 0.0 w/o Bristol Pkwy Hotel/Commercial 71.7 71.7 0.0
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 70.3 70.4 0.1 between Fox Hills Dr and Bristol Pkwy Commercial 67.4 67.4 0.0 between Slauson Ave and Fox Hills Dr Commercial 69.6 69.6 0.0 between Uplander Wy and Buckingham Pkwy Commercial 69.2 69.5 0.3 n/o Slauson Ave Residential/Commercial 71.2 71.2 0.0
Marina Fwy
s/o Slauson Ave Freeway Off Ramp 73.9 73.9 0.0
Slauson Ave
between Bristol Pkwy and Buckingham Pkwy Commercial/Cemetery 75.1 75.1 0.0 between Hannum Ave and Marina Fwy Residential/Commercial 71.1 71.1 0.0 between Marina Fwy and Bristol Pkwy Commercial 74.4 74.4 0.0 e/o Buckingham Pkwy Residential/Commercial 76.3 76.3 0.0 w/o Hannum Ave Residential/Commercial 72.4 72.4 0.0
Uplander Way
n/o Hannum Ave Commercial 54.1 54.1 0.0
s/o Hannum Ave Commercial 56.4 56.7 0.3
a Calculated based on existing traffic volumes.
NOTE:
s/o: south of
e/o: east of
n/o: north of
w/o: west of
SOURCE: ESA, 2023.
Operational Outdoor Open Space Noise
As discussed in Chapter 2, Project Description , of the Draft EIR, the Project would provide approximately 54,156 sf of open space, including retail dining and sitting areas within the Hannum Plaza, as well as a centrally located courtyard and amenity/pool deck on sixth floor.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-37 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Of the total amount of open space, 19,526 square feet would be provided as private open space within balconies or private yards distributed throughout the Project’s eight levels (including the P1 and P2 levels). The Project would provide 7,507 square feet of publicly accessible open space as part of Hannum Plaza. The remaining square footage would be common ope n space for residents.
The Project would provide approximately 27,123 square feet of resident only open space. Outdoor spaces would include an 11,378 square foot centrally located courtyard on the second floor . The central courtyard on the second floor would have a variety of seating areas, BBQs, and drought tolerant landscape. Also, the Project would include a 9,610 square foot amenity deck on the sixth floor. The sixth floor/roof level pool deck would include a pool and spa enclosed by a 3.5 foot perimeter amenity deck glass enclosure.
Outdoor common spaces for residents would include lounge seating, gathering spaces, and small speakers installed in discreet areas to be used for low volume ambient sound and music , to be developed in accordance with Project Design Feature NOI-PDF-6. Occasional events for residents only would be held throughout the year within the courtyard or roof deck as an amenity for the residents. These events might include outdoor yoga, intimate food and beverage events, and/or outdoor movies.
Table 4.8-15, Estimated Daytime Outdoor Open Space Noise Levels (L eq), shows the estimated noise levels at the nearest off -site sensitive receptor locations from outdoor open space. As indicated in Table 4.8-15, the estimated noise levels from the Project’s individual outdoor open space related activities would range from 36.0 dBA Leq at receptor location R2 to 58.5 dBA Leq at receptor locations R3 and R4. As shown in Table 4.8-14, open space noise would not result in any exceedance of established thresholds and impacts would be less than significant.
TABLE 4.8-15
ESTIMATED DAYTIME OUTDOOR OPEN SPACE NOISE LEVELS (LEQ) Receptor
Distance to
Nearest
Receptor (ft)
Open Space Noise
Level (Exterior/Interior
with windows
open/Interior with
windows closed)a
(dBA Leq)
Ambientb
(dBA Leq)
Ambient + Project
(Exterior/Interior
with windows
open/Interior with
windows closed)
(dBA Leq)
Thresholdc
(dBA Leq)
Exceeds
Threshold?
R1 450 39.4 / 26.4 / 14.4 63.0 63.0 / 63.0 / 63.0 68.0 No R2 670 36.0 / 23.0 / 11.0 63.4 63.4 / 63.4 / 63.4 68.4 No R3 50 58.5 / 45.5 / 33.5 59.6 62.1 / 62.1 / 62.1 64.6 No R4 50 58.5 / 45.5 / 33.5 61.2 63.1 / 63.1 / 63.1 66.2 No R5 550 37.7 / 24.7 / 12.7 63.2 63.2 / 63.2 / 63.2 68.2 No NOTES:
a Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
b The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is used for the purposes of impact determination. c Significance thresholds are equivalent to the measured daytime or morning ambient noise levels, whichever is lower plus 5 dBA.
SOURCE: ESA 2023.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-38 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Composite Noise Level Impacts from Project Operations
An evaluation of composite noise levels, including all Project -related noise sources plus existing ambient noise levels, was conducted to identify the potential maximum Project -related noise level increase that may occur at the noise-sensitive receptor locations. The overall sound environment at the sensitive receptors surrounding the Project Site would include contributions from each on-site and off-site individual noise source associated with maximum daily operation of the Project. Principal on- site noise sources associated with the Project would include mechanical equipment, open space, and parking facilities. Table 4.8-16, Composite Noise Impacts, presents the estimated noise from Project- related noise sources in terms of CNEL. As indicated in Table 4.8-16, the Project would not result in an increase of 5.0 dBA CNEL at any receptor. Therefore, the Project would not result in the generation of a substantial permanent increase in ambient noise levels at any receptor in excess of standards established by the City, and the Project’s operational composite noise would be less than significant.
Operational Noise Levels at Commercial Land Uses.
For informational purposes only, operational noise levels at nearby commercial land uses as a result of the Project’s mechanical equipment, parking structure, loading/refuse collections areas, and open space are presented in Table 4.8-17, Operational Noise Levels at Commercial Land Uses. As shown therein, there would be no perceptible increase in interior noise relative to the ambient noise levels.
Mitigation Measures
As analyzed above, the Project’s on -site construction activities would result in significant noise impacts without the implementation of mitigation measures. Therefore, the following noise mitigation measures are recommended to reduce the Project’s constru ction-related noise impacts to sensitive uses in the vicinity of the Project Site:
MM-NOI-1: Temporary noise barriers shall be installed along the southern and eastern Project boundary to shield the sensitive receptors from construction noise. The barrier shall have a minimum height of 6 to 15 feet (from south to north, with the top of the barrie r at least 15 feet above the ground surface of the residences to the east along Buckingham Parkway) that is made of sound blanket , plywood or other solid material capable of reducing on-site construction noise levels by 17 to 19 dBA.
MM-NOI-2: Since construction equipment operates intermittently, and the types of equipment change with the stage of construction, noise emitted during construction would be mobile and highly variable. The following features shall be implemented during Project construction to reduce noise levels:
• Maintain all construction tools and equipment in good operating order according to manufacturers’ specifications.
• To the extent practicable, schedule construction activity during normal working hours between 8 a.m. and 5 p.m. on weekdays when higher sound levels are typically present and are found acceptable.
• Equip internal combustion engines with properly operating mufflers that are free from rust, holes, and leaks.
• For construction equipment that utilize internal combustion engines, ensure the engine’s housing doors are kept closed, and install noise -insulating material mounted on the engine housing consistent with manufacturers’ guidelines, if possible.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-39 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-16
ON-SITE COMPOSITE NOISE IMPACTS
Receptor
Location
Estimated Composite Noise, (Exterior / Interior with windows open/Interior with windows closed) dBA (Leq)
Project Composite
Noise Levels,
(Exterior /Interior
with windows open/
Interior with
windows closed)
(dBA (Leq)
Ambient
Noise
Levels,a
dBA (Leq)
Ambient Plus
Project
Composite Noise
Levels, dBA (Leq)
Maximum
Increase in Noise
Levels Due to
Project, dBA (Leq)
Significance
Threshold
Significant
Impact? Mechanical Parking Loading Area Open Space
R1 27.8 / 14.8 / 2.8 25.0 / 12.0 / 0.0 35.7 / 22.7 / 10.7 37.6 / 24.6 / 12.6 40.2 / 27.2 / 15.2 63.0 63.0 / 63.0 / 63.0 0.0 68.0 No R2 21.3 / 8.3 / 0 18.5 / 5.5 / 0.0 28.2 / 15.2 / 3.2 36.0 / 23.0 / 11.0 36.9 / 23.9 / 11.9 63.4 63.4 / 63.4 / 63.4 0.0 68.4 No R3 46.9 / 33.9 / 21.9 44.1 / 31.1 / 19.1 54.1 / 41.1 / 29.1 58.5 / 45.5 / 33.5 58.8 / 45.8 / 33.8 59.6 63.3 / 59.9 / 59.6 3.7 64.6 No R4 40.9 / 27.9 / 15.9 44.1 / 31.1 / 19.1 54.1 / 41.1 / 29.1 58.5 / 45.5 / 33.5 60.0 / 47.0 / 35.0 61.2 63.7 / 61.4 / 61.2 2.5 66.2 No R5 26.1 / 13.1 / 1.1 23.3 / 10.3 / 0.0 26.3 / 13.3 / 1.3 37.7 / 24.7 / 12.7 38.4 / 25.4 / 13.4 63.2 63.2 / 63.2 / 63.2 0.0 68.2 No NOTES:
a The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is used for the purposes of impact determination.
SOURCE: ESA, 2023.
TABLE 4.8-17
OPERATIONAL NOISE LEVELS AT COMMERCIAL LAND USES
Receptor
Location
Estimated Composite Noise, (Exterior/Interior) dBA (Leq) Project Composite Noise Levels, (Exterior/Interior)
dBA (Leq)
Ambient Noise
Levels,a dBA (Leq)
Ambient Plus Project
Composite Noise
Levels, dBA (Leq) Mechanical Parking Loading Area Open Space R6 b NA / 15.9 NA / 13.1 NA / 13.3 NA / 27.5 NA / 27.8 65.7 NA / 65.7 R7 b NA / 21.9 NA / 19.1 NA / 30.7 NA / 24.9 NA / 26.7 56.6 NA / 56.6 R8 b NA / 7.9 NA / 5.1 NA / 5.7 NA / 19.5 NA / 19.8 53.5 NA / 53.5 NOTES:
a The ambient noise level is based on the measured daytime and morning noise levels shown in Table 4.8-4, and the lower value (daytime or morning) is presented.
SOURCE: ESA, 2023.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-40 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Operation
Operational noise impacts would be less than significant. Therefore, no mitigation measures are required.
Level of Significance After Mitigation
Construction Noise
Implementation of Mitigation Measures MM -NOI-1 and MM-NOI-2, as described above, would reduce the Project’s on-site construction noise impacts at the off -site ground-level noise sensitive receptors, to the extent technically feasible.54 Table 4.8-18, On-Site Construction Noise Impacts – With Mitigation , presents the estimated, conservative construction noise levels at the off -site receptor locations with implementation of mitigation measures. As indicated in Table 4.8-18, the construction noise levels at all receptor locations would be reduced below the 5-dBA significance threshold. Therefore, with implementation of mitigation measures MM -NOI-1 and MM -NOI-2, impacts from on-site construction noise would be less than significant with approval of an extended hours construction permit . However, construction during off-hours (between 7:00 a.m. and 8:00 a.m. on weekdays and 7:00 a.m. to 9:00 a.m. on Saturdays ) during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction would remain significant and unavoidable if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours.
TABLE 4.8-18
ESTIMATED MITIGATED CONSTRUCTION NOISE LEVELS AT EXISTING OFF-SITE SENSITIVE RECEPTORS Noise
Sensitive
Receptor
Maximum Construction
Noise Levels, a,c
(Exterior/Interior with
windows open/Interior
with windows closed)
Hourly Leq (dBA)
Morning
Noise
Threshold
(Ambient +
5 dBA)
Exceeds Threshold?
(Exterior/Interior
with Windows
Open/Interior with
Windows Closed)
Daytime
Noise
Threshold
(Ambient +
5 dBA)
Exceeds
Threshold?
(Exterior/Interior
with Windows
Open/Interior with
Windows Closed)
R1 b 44.4 / 31.4 / 19.4 76.5 No / No / No 68.0 No / No / No R2 b 41.6 / 28.6 / 16.6 73.7 No / No / No 68.4 No / No / No R3 b 62.8 / 49.8 / 37.8 67.8 No / No / No 64.6 No / No / No R4 b 62.8 / 49.8 / 35.8 69.3 No / No / No 66.2 No / No / No R5 b 43.5 / 30.5 / 18.5 72.5 No / No / No 68.2 No / No / No a Estimated construction noise levels represent the worst-case condition when noise generators are located closest to the receptors. b Noise levels shown here included the noise attenuation effect by MM-NOI-1 and MM-NOI-2. c Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
SOURCE: ESA, 2023.
54 Technical infeasibility shall mean that said noise limitations cannot be complied with despite the use of mufflers, shields, sound barriers, and/or other noise reduction devices or techniques during the operation of the equipment.
LAMC Chapter XI, Art. 1, Section 112.05.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-41 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Threshold NOISE-2: The Project would have a potentially significant impact on noise if it would result in the generation of excessive groundborne vibration or groundborne noise levels.
Impact Analysis
Structural Damage
Construction
Construction activities can generate varying degrees of groundborne vibration, depending on the construction procedures and the construction equipment used. The operation of construction equipment generates vibrations that spread through the ground and dim inish in amplitude with distance from the source. The effect on buildings located in the vicinity of the construction site varies depending on soil type, ground strata, and construction characteristics of the receptor buildings. The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibration from construction activities rarely reaches levels that damage structures. The Caltrans guidance manual incorporates FTA standard vibration velocities for construction equipment operations (Table 18 of the Caltrans guidance manual). The PPV vibration velocities for the types of construction equipment that can generate perceptible vibration levels and that would be used for the Project are listed in Table 4.8-19, Vibration Source Levels for Construction Equipment.
Because vibration level in RMS is best for characterizing human response to building vibration and vibration level in PPV is best used to characterize potential for damage, this construction vibration impact analysis assessed the potential for building dam ages using vibration levels in PPV (inch/sec). Potential human annoyance is assessed in the next subsection using vibration levels in VdB.
TABLE 4.8-19
VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT
Equipment
Approximate PPV (in/sec) Approximate RMS (VdB)
25 Feet
50 Feet
60 Feet
75 Feet
100
Feet
25 Feet
50 Feet
60 Feet
75 Feet
100
Feet
Large Bulldozer 0.089 0.031 0.024 0.017 0.011 87 78 76 73 69 Loaded Trucks 0.076 0.027 0.020 0.015 0.010 86 77 75 72 68 Wheel Loader 0.076 0.027 0.020 0.015 0.010 86 77 75 72 68 Fork Lift 0.047 0.016 0.013 0.009 0.006 81 72 70 67 63
Jackhammer 0.035 0.012 0.009 0.007 0.004 79 70 68 65 61 Earth Mover 0.011 0.004 0.003 0.002 0.001 69 60 58 55 51 Small Bulldozer 0.003 0.001 0.0008 0.0006 0.0004 58 49 47 44 40 SOURCE: FTA, Transit Noise and Vibration Impact Assessment, September 2018; ESA, 2022.
Because vibration impacts occur normally at or within buildings, the distance to the nearest sensitive uses, for vibration impact analysis purposes, is measured between the nearest off -site
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-42 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
sensitive use buildings and the Project construction equipment area near the Project boundary. The Project would require drill rigs for the installation of drilled piles. As shown in Table 4.8-19, drill rigs generate approximately 0.089 in/sec PPV when measured at 25 feet. As shown in Table 4.8-1, the FTA guidelines indicate that a vibration level of 0.5 inch/sec PPV is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster), and would not result in any construction vi bration damage. For a non -engineered timber and masonry building, the construction vibration damage criterion is 0.2 inch/sec PPV.
Based on the vibration data provided in Table 4.8-19, vibration velocities from construction equipment would range from approximately 0.003 to 0.089 inches per second PPV at 25 feet from the source of activity. The nearest off -site buildings to the Project Site that could be subjected to Project-related vibration structural damage include the business park buildings to the west (50 feet) and commercial/office buildings to the north (150 feet) as measured from the Project Site boundary.
Pile driving would not be used at the Project Site boundary and other vib ration-generating equipment would normally operate at least 25 feet or more from the nearest off-site buildings. Thus, based on the vibration data provided in Table 4.8-19, the nearest off -site buildings would not be exposed to vibration levels that would cause structural damage and impacts would be less than significant.
Operation
The Project’s operations would include typical commercial -grade stationary mechanical and electrical equipment, such as air handling units, condenser units, and exhaust fans, which would produce vibration. In addition, the primary sources of transient vibr ation would include passenger vehicle circulation within the proposed parking area. Groundborne vibration generated by each of the above-mentioned activities would generate approximately up to 0.005 in/sec PPV adjacent to the Project Site.55 The potential vibration levels from all Project operational sources at the closest existing sensitive receptor locations would be less than the significance threshold of 0.2 in/sec PPV significance threshold for potential residential building damage. As s uch, vibration impacts associated with operation of the Project would be below the significance threshold and impacts would be less than significant.
Human Annoyance
Construction
The CEQA Thresholds Guide identifies residences, schools, motels and hotels, libraries, religious institutions, hospitals, nursing homes, and parks as sensitive uses. Off-site non-residential uses such as retail and commercial uses are not considered vibration sensitive receptors for human annoyance under CEQA. Groundborne noise specifically refers to the rumbling noise emanating from the motion of building room surfaces due to vibration of floors and walls and is perceptible only inside buildings.56 For typical buildings, groundborne vibration results in groundborne noise levels approximately 25 to 40 decibels lower than the velocity level. 57 According the FTA Noise and Vibration Manual, most of the studies of groundborne vibration in this country have focused on
55 This vibration estimate is based on data presented in the USDOT Federal Transit Administration, 2018; which is included in Appendix G of this Draft EIR.
56 Federal Transit Administration, Noise and Vibration Manual, 2018, Page 112, 57 Federal Transit Administration, Noise and Vibration Manual, 2018, Page 119.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-43 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
urban rail transit and the problems with groundborne vibration and noise that are common when there is less than 50 feet between a subway structure and building foundations. Project construction would not create on -going and continuous groundborne vibratio n and noise like that of an urban rail transit system. Groundborne noise impacts would also be less than significant.
Nearby vibration -sensitive uses for potential human annoyance in the Project vicinity include residences approximately 150 feet to east of the Project Site, with other residential structures at greater distances. At a distance of 150 feet or more, the maxi mum vibration level would be attenuated by 23 VdB to 64 VdB or less.
The Project would generate occasional transient vibrations from period construction and not generate continuous vibrations. Thus, Project construction would not exceed the FTA’s 75 VdB threshold for occasional events at the nearest noise -sensitive receiver locations during daytime hours. In addition, construction vibration -generation activities would not occur during the nighttime hours when people normally sleep. Compliance with Chapter 9.07 of the CCMC would eliminate the potential for groundborne vibration and groundborne noise human annoyance impacts at the nearby residential uses during sensitive nighttime hours. Impacts would be less than significant.
Operation
Post-construction on-site activities would be limited to residential uses, commercial retail uses, and associated mechanical equipment such HVAC units that would not be anticipated to generate excessive groundborne noise or vibration. Project operational vibration levels would be substantially less than during construction. As such, groundborne vibration and noise impact to human annoyance associated with the long-term operation of project 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 not result in the generation of excessive groundborne vibration or groundborne noise levels and impacts would be less than significant.
Cumulative Impacts
The geographic context for the analysis of cumulative noise impacts depends on the impact being analyzed. Noise is by definition a localized phenomenon, and significantly reduces in magnitude as the distance from the source increases. Noise would normally affect the areas immediately adjacent to the source, specifically areas that are less than 500 feet. On-site c umulative noise impacts could occur at receptor locations that are within 500 feet from two different sources.
Therefore, based on a 500-foot screening distance, the on-site cumulative noise impacts analysis is limited to related projects within 1,000 feet of the Project Site. The 1,000-foot distance is based on an assumption that a noise -sensitive receptor would be located halfway between the Project Site and the related project. However, the cumulative impacts on roadway noise would be affected by traffic from all cumulative projects throughout a larger vicinity.
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As discussed in Chapter 3, Environmental Setting, of this Draft EIR, there are 12 related projects identified in the vicinity of the Project Site. The related projects within approximately 1,000 feet of the Project Site are listed in Table 4.8-20, Cumulative Projects within 1,000 feet of the Project Site.
TABLE 4.8-20
RELATED PROJECTS WITHIN 1,000 FEET OF THE PROJECT SITE
No.a Location Jurisdiction Land Use Size (sf)
Distance to
Project Site (ft)
1 5800 Bristol Pkwy /
5801 Hannum Ave
City of Culver City Office 281,400 750
6 5840 Uplander Way City of Culver City Conversion from Office to School 16,128 950 a Related projects list based on information from City of Culver City (January 2023), City of Los Angeles (May 2023), and the County of Los Angeles (May 2023).
SOURCE: Gibson Transportation Consulting, 2023
The potential for noise impacts to occur are specific to the location of each related project as well as cumulative traffic on the surrounding roadway network.
Construction Noise
On-Site Construction Noise
Two of the related projects (Related Project Nos. 1 and 6) are located within approximately 1,000 feet of the Project Site and could contribute to cumulative construction noise impacts from on -site construction activities to off-site sensitive receptors if they are under construction at the same time as the Proj ect. However, construction of Related Project No. 1 has already been completed and therefore it is not considered in this cumulative construction noise analysis. R elated Project No. 6 would be required to comply with the noise standards and ordinances of the City of Culver City, as applicable. An exact construction schedule for Related Project No. 6 is not known. It is not possible to predict whether construction of th is related project would overlap with construction of the Project. Therefore, it is conservatively assumed that construction of these related projects could occur at the same time as the Project. However, Related Project No. 6 is approximately 1,000 feet from the Project Site and involves the conversion of an office building into a school and w ould likely require little to no demolition and less intensive construction activities than a traditional new project buildout. Intervening buildings between the Project Site and the Related Project No. 6 site would also attenuate on -site construction noise from the related project and the potential for construction noise on that site to combine with the Project’s construction noise. For these reasons, cumulative on -site noise from the Project and Related Project No. 6 would not result in cumulatively considerable noise levels and impacts would be less than significant.
Off-Site Construction Noise
With regard to off -site construction noise, construction traffic from all related projects would contribute to noise levels on major thoroughfares throughout the region, although the related projects are located in different areas and, to some extent, would have varied haul routes and traffic patterns associated with their construction. As shown in Table 4.8-9, the Project would not result in any significant off-site construction noise impacts due to construction trips. The street segment with
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the highest potential for cumulative impacts due to its proximity to sensitive receptors and location between related projects and the Project Site is Slauson Avenue between Hannum Avenue and Marina Freeway (State Route 90). The Project’s construction vehicle trips would increase existing traffic noise levels by a maximum of 0.5 dBA Leq along Slauson Avenue between Hannum Avenue and Marina Freeway.
If related projects contribute to an increase in construction vehicle trips along the same roadway segments and at the same time as the Project, the cumulative increase in construction traffic noise would be greater and could exceed the significance thresh old of 3 dBA L eq. While e xact construction schedules and construction truck trips for these related projects are not known, it is conservatively assumed that construction of the related projects could occur at the same time as the Project and could include the number of construction truck trips that would generate noise in excess of the significance threshold. For the purposes of this analysis, the number of construction trucks from related projects that would be needed to exceed the significance threshold is estimated to determine the potential for impacts.
The Slauson Avenue roadway segment between Hannum Avenue and Marina Freeway would have a maximum of up to 28 Project truck trips per hour (heavy-duty concrete, vendor, and haul trucks from overlapping Project construction activities), which would generate a combined Existing plus Project Construction Traffic noise level of approximately 70.7 dBA Leq (an increase of 0.5 dBA from the Existing baseline traffic noise level 70.2 dBA Leq). To create a significant roadway noise impact, the related projects would need to contribute an additional 187 heavy-duty truck trips per hour on the same roadway segment at the same time as the Project , which would generate a combined noise level of approximately 73.2 dBA Leq. This cumulative noise level would be equal to the significance threshold of (70.2 + 3 =) 73.2 dBA on Slauson Avenue between Hannum Avenue and Marina Freeway. However, based on the location of their potential haul routes to/from the 405 Freeway and/or the Marina Freeway and size/scope/characteristics of the related projects, there is not a reasonably foreseeable circumstance where the related projects could contribute an additional 187 trips to any roadway segment at the same time as the Project. Furthermore, any overlapping construction truck activity would be limited via the Project’s Construction Management Plan, whereby the City and Project contractors of the related projects and the Project would strive to minimize any overlapping truck activity. Based on these considerations, cumulative off -site construction traffic noise impacts would be less than significant.
Operation Noise
On-Site Operational Noise
City of Culver City have provisions that limit stationary -source noise from items such as roof -top mechanical equipment that would ensure noise levels would be less than significant at the property line for each related project. Further, noise from other stati onary sources, including parking structures and loading areas would be limited to areas in the immediate vicinity of each related project. With the noise attenuation of 6 dBA per doubling of distance from the noise source, receivers outside of a distance o f 200 feet from any noise source would receive a 12 dBA noise reduction compared to the noise level received at 50 feet from that noise source. Although each related project could potentially impact an adjacent sensitive use in its own vicinity, that poten tial impact would be localized to that specific area and would not contribute to cumulative noise
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conditions at or adjacent to the Project Site, which is more than 200 feet from other related projects.
As the Project’s composite stationary -source impacts would be less than significant, the Project’s cumulative on-site stationary-source noise impacts would be less than significant.
Off-Site Operational Noise
Cumulative noise impacts would occur primarily as a result of increased traffic on local roadways due to operation of the Project and related projects, as traffic is the greatest source of operational noise in the Project area. Cumulative traffic -generated noise impacts were assessed based on a comparison of the future cumulative base traffic volumes with the Project to the existing base traffic volumes without the Project. The noise levels associated with existing base traffic volumes without the Project, and future year base traffic volumes with the Project are provided in Table 4.8-13 and Table 4.8-14, above.
Tables 4.8-13 and 4.8-14 show the Project’s contribution to the cumulative noise levels during year 2027. The maximum cumulative noise increase from the Project plus cumulative project traffic would be 0.3, which would occur along Hannum Avenue between Uplander Way and Buckingham Parkway and along Uplander Way south of Hannum Avenue. This increase in sound level would be below a 3 dBA increase in areas within “normally unacceptable” zone or a 5 dBA increase in areas within a “normally acceptable” zone, and the increase in sound level would be lower at the remaining roadway segments a nalyzed. The Project -related noise increases contribution to the cumulative traffic noise impacts would be less than significant, and no mitigation measures would be required.
Construction Groundborne Vibration
On-Site Construction Vibration
Due to rapid attenuation characteristics of groundborne vibration, only related projects located adjacent to the same sensitive receptors would result in cumulatively considerable vibration impacts. None of the related projects are located adjacent to the sensitive receptors identified for the Project. Vibration attenuates at high rates with distance. Therefore, construction vibration would only affect sensitive uses located directly adjacent to the Project and related projects.
Therefore, construction of t he Project, when considered together with the related projects, would not result in a cumulatively considerable contribution and would have a less -than-significant cumulative impact with regard to on-site groundborne vibration (structural damage and human annoyance).
Off-Site Construction Vibration
Due to rapid attenuation characteristics of groundborne vibration, only related projects located adjacent to the same sensitive receptors would result in cumulatively considerable vibration impacts. It is unusual for groundborne vibration from sources such as rubber -tired trucks to be perceptible, even in locations close to major roads, unless the road surface is rough with uneven spaces. Several related projects are in locations that could potentially lead construction traffic, including truck traffic near sensitive vibration receptors. Should construction of the Project and related projects overlap, there is a potential for cumulative vibration impacts to sensitive vibration receptors. As discussed above, construction of the Project, both on -site and off -site, would not
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result in significant vibration impacts related to structural damage or human annoyance. Therefore, cumulative off-site construction vibration impacts would be less than significant.
Operational Groundborne Vibration
Due to the rapid attenuation characteristics of groundborne vibration and distance from each of the related projects to the Project Site, there is no potential for cumulative operational impacts with respect to groundborne vibration. As such, the Project’s contribution to impacts related to groundborne vibration during operation would not be cumulatively considerable. Therefore, cumulative impacts would be less than significant.
Mitigation Measures
Refer to Mitigation Measures MM -NOI-1 and MM-NOI-2 to reduce cumulative on -site construction noise impacts.
Cumulative impacts related to construction vibration impacts and operational noise and vibration would not occur.
Level of Significance After Mitigation
On-Site Construction Noise
As discussed for the Project, after implementation of mitigation, the Project would result in less than significant construction noise impacts during regularly allowable construction hours if an extended hours construction permit is obtained. However, construction during off-hours (between 7:00 a.m. and 8:00 a.m. on weekdays and 7:00 a.m. to 9:00 a.m. on Saturdays) during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction would be significant and unavoidable if an extended hours permit is not obtained because the Project would not be in compliance with appli cable construction hour regulations. Any additional construction noise from the related project that could combine with the Project’s construction noise, could further increase the extent of the Project’s noise levels and impacts. However, as mentioned above, Related Project No. 6 would not require intensive construction activity, is separated by intervening buildings from the Project Site, and is roughly 1,000 feet away from the Project Site. As such, cumulative on-site noise from the Project and the related project would not result in combined noise levels causing significant cumulative construction noise impacts at similar off -site receptors and receivers between the Project Site and the nearest related project site. Therefore, the Project’s contribution to cumulative construction noise would not be cumulatively considerable and would be less than significant.
Off-Site Construction Noise
Not Applicable. Cumulative impacts regarding o ff-site construction noise would be less than significant without mitigation. Therefore, no mitigation measures were required or included, and the impact level remains less than significant.
On-Site Operational Noise
Not Applicable. Cumulative impacts regarding operational noise would be less than significant without mitigation. Therefore, no mitigation measures were required or included, and the impact level remains less than significant.
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Off-Site Operational Noise
Not Applicable. Cumulative impacts regarding off -site operational noise would be less than significant without mitigation. Therefore, no mitigation measures were required or included, and the impact level remains less than significant.
Construction Groundborne Vibration
Not Applicable. Cumulative impacts regarding off-site construction groundborne vibration would be less than significant without mitigation.
Operational Groundborne Vibration
Not Applicable. Cumulative impacts regarding operational groundborne vibration would be less than significant without mitigation. Therefore, no mitigation measures were required or included, and the impact level remains less than significant.
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4.9 Population and Housing
4.9.1 Introduction
This section addresses potential impacts on population and housing that could occur due to construction and operation of the Project. The analysis focuses on potential effects of the Project’s contribution to population and housing growth within the geographical boundaries of the City of Culver City (City) by taking into account population and housing projections established in the Southern California Association of Governments (SCAG) Connect SoCal ( 2020-2045 Regional Transportation Plan and Sustainable Communities Strategy [2020 RTP/SCS]) and SCAG’s 6 th
Cycle Regional Housing Needs Assessment (RHNA), as well as policies established in the City’s Comprehensive General Plan (General Plan). This section analyzes the Project ’s effects on population, housing, and employment as compared to adopted growth forecasts; and relevant policies and programs regarding planning for future development. Potential growth-inducing impacts of the Project are further addressed in Chapter 6, Other CEQA Considerations.
4.9.2 Environmental Setting
Regulatory Framework
State Level
Housing Element Law: California Government Code Section 65583 and 65584(a)(1) Section 65583 of the California Government Code requires cities and counties to prepare a housing element, as one of the state-mandated elements of the General Plan, with specific direction on its content. Pursuant to Section 65584(a)(1), the California De partment of Housing and Community Development (HCD) is responsible for determining the regional housing needs assessment (segmented by income levels) for each region’s planning body known as a “council of governments” (COG), the SCAG being the COG serving the Southern California area. HCD prepares an initial housing needs assessment and then coordinates with each COG in order to arrive at the final regional housing needs assessment. The SCAG RHNA and the City’s General Plan Housing Element are discussed further below.
Housing Crisis Act of 2019 – (Senate Bill 330, Skinner) On October 9, 2019, the Governor signed into law the Housing Crisis Act of 2019 (Senate Bill [SB] 330). SB 330 seeks to speed up housing production in the next half decade by eliminating some of the most common entitlement impediments to the creation of new housing, including delays in the local permitting process and cities enacting new requirements after an application is complete and undergoing local review—both of which can exacerbate the cost and uncertainty that sponsors of housing projects face. In addition to speeding up the timeline to obtain building permits, the bill prohibits local governments from reducing the number of homes that can be built through down- planning or down-zoning or the introduction of new discretionary design guidelines. The bi ll is in effect as of January 1, 2020, but is temporary in nature. In 2021, the Governor signed into law SB 8 which provided clarifications to SB 330 and extended the bill’s provisions until January 1, 2030.
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Regional Level
Southern California Association of Governments
The Project Site is located within the jurisdiction of SCAG, a Joint Powers Agency established under California Government Code Section 6502 et seq. Pursuant to federal and state law, SCAG serves as a Council of Governments, a Regional Transportation Planning Agency, and the Metropolitan Planning Organization (MPO) for Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties. SCAG’s mandated responsibilities i nclude developing plans and policies with respect to the region’s population growth, transportation programs, air quality, housing, and economic development. Specifically, SCAG is responsible for preparing the Regional Comprehensive Plan (RCP), RTP/SCS, and RHNA, in coordination with other state and local agencies. These documents include population, employment, and housing projections for the region and its 15 subregions. Subregions play an important role as a conduit between SCAG and cities and counties of the region by participating and providing input on SCAG’s planning activiti es, which helps the Regional Council and its committees make better-informed decisions. The Project Site is located within the Westside Cities Subregion.
SCAG is tasked with providing demographic projections for use by local agencies and public service and utility agencies in determining future service demands. Projections in Connect SoCal serve as the bases for demographic estimates in this analysis of Project consistency with growth projections.
The findings regarding growth in the region are consistent with the methodologies prescribed by SCAG and reflect SCAG goals and procedures. Based on 2020 statistics for the City, SCAG has determined that the City has an average housing unit size of 2.37 persons per housing unit. 1 SCAG data is periodically updated to reflect changes in development activity and provisions of local jurisdictions (e.g. zoning changes). Through these updates, public agencies have advance information regarding changes in growth that must be addressed in planning for their provision of services. Changes in the growth rates are reflected in the new projections for service and utilities planning through the long-term time horizon.
SCAG Connect SoCal (2020 RTP/SCS)
The 2020 RTP/SCS, known as Connect SoCal, was developed through a four-year planning process that involved rigorous technical analysis, extensive stakeholder engagement and robust policy discussions with local elected leaders, who make up SCAG’s policy committees and Regi onal Council. Connect SoCal charts a path toward a more mobile, sustainable and prosperous region by making key connections: between transportation networks, between planning strategies and between the people whose collaboration can make plans a reality. Connect SoCal was completed in May 2020, approved and adopted by the Regional Council on September 3, 2020, and was approved by the California Air Resources Board on October 30, 2020.
Connect SoCal embodies a collective vision for the region’s future, through the horizon year of 2045. It is developed with input from a wide range of constituents and stakeholders within the Counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura, including
1 SCAG, 2022 Spatial & Statistical Summary, City of Culver City, May 2022, page 6, https://scag.ca.gov/sites/main/files/file-attachments/culver-city-atlas.pdf?1660027073. Accessed August 18, 2023.
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public agencies, community organizations, elected officials, tribal governments, the business community and the general public. Connect SoCal is an important planning document for the region, allowing public agencies who implement transportation projects to do so in a coordinated manner, while qualifying for federal and state funding. The plan includes robust financial analysis that considers operations and maintenance costs to ensure the existing transportation system’s reliability, longevity, resilience and cost effectiveness. In addition, Connect SoCal is supported by a combination of transportation and land use strategies that outline how the region can achieve California’s greenhouse gas emission reduction goals and federal Clean Air Act requirements. The plan also strives to achieve broader regional objectives, such as the preservation of natural lands, improvement of public health, increased roadway safety, support for the region’s vital goods movement industries and more efficient use of resources. 2 In addition, Connect SoCal establishes policies pertaining to regional growth and efficient development patterns to reduce development impacts on traffic congestion and related increases in air quality emissions. These policies are discussed in detail in Section 4.7, Land Use and Planning, of this Draft EIR.
Regional Housing Needs Assessment
The RHNA is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. The RHNA quantifies the need for housing within each jurisdiction during specified planning periods, or cycles. In prior cycles, factors such as household growth and household income distribution were the primary factors considered in determining a jurisdiction’s RHNA allocation. SCAG’s 6
th Cycle RHNA quantifies the regional need for housing
and then allocates the regional need t o each jurisdiction for a planning period between October 2021 and October 2029. The 6 th Cycle RHNA is focused on existing need (current housing shortages and overcrowding) plus projected growth, which takes into account factors beyond what was used to determine Connect SoCal’s projected growth. 3 Therefore, the 6 th 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. For the 6 th RHNA Cycle, SCAG considers other factors in addition to household growth. These factors include transit accessibility, job accessibility, and indicators that influence a community’s environmental, educational, and economic resource accessibility.
On October 15, 2019, SCAG received the Final Regional Determination from HCD. On November 7, 2019, SCAG Regional Council approved a Draft RHNA Allocation Methodology for HCD’s review. The Regional Council approved the Final RHNA Methodology on March 5, 2020 and released the Draft RHNA Allocation by jurisdictions.
4 The RHNA underwent Appeals Board
Hearings throughout January 2021. In February 2021, the RHNA Appeals Board concluded its determination of appeals and issued the proposed final RHNA Allocation Plan and recommended
2 SCAG, Connect SoCal (2020 RTP/SCS), May 2020, page 8. Accessed July 5, 2023. 3 SCAG, Final RHNA Allocation Methodology, adopted March 5, 2020, page 5, https://scag.ca.gov/sites/main/files/file-attachments/scag-final-rhna-methodology-030520.pdf?1602189316.
Accessed July 5, 2023.
4 SCAG, Regional Housing Needs Assessment (RHNA) & Housing, https://www.scag.ca.gov/programs/pages/housing.aspx. Accessed August 21, 2023.
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the Plan for approval by SCAG’s Community, Economic & Human Development (CEHD) Committee and Regional Council. 5 The final 6th Cycle RHNA methodology and allocations were adopted by the Regional Council on March 4, 2021 and approved by HCD on March 22, 2021 and modified on July 1, 2021. As part of the RHNA draft allocations, the City’s allocation of housing between October 2021 and October 2029 is 3,341 units.6
Consistent with the state housing law, the primary objectives the 6 th Cycle RHNA allocation plan are to:
• Increase the housing supply and mix of housing types, tenure and affordability within each region in an equitable manner
• Promote infill development and socioeconomic equity, the projection of environmental and agricultural resources, and the encouragement of efficient development patterns • Promote an improved interregional relationship between jobs and housing • Allocating a lower proportion of housing need in income categories in jurisdictions that have a disproportionately high share in comparison to the county distribution • Affirmatively furthering fair housing
Local jurisdictions are required to plan and zone to accommodate their respective RHNA allocation (housing units) by income categories through the process of updating the Housing Elements of their General Plans. Communities use the RHNA in land use planning, prioritizing local resource allocation, and in deciding how to address identified existing and future housing needs resulting from population, employment and housing unit growth. The RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and sub region can grow in ways that enhance quality of life, improve access to jobs, promotes transportation mobility, addresses social equity, and fair share housing needs.
Local Level
City of Culver City General Plan
The City’s adopted General Plan has a goal to provide for the physical, social and economic needs of the City and its people by protecting and building on the City’s strengths .7 The General Plan includes nine elements that have been updated at various points between 1968 and 2014 . The elements focus on: Land Use, Circulation, Housing, Open Space, Noise, Conservation, Seismic Safety, Public Safety, and Recreation . 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.
5 SCAG, 6th Cycle RHNA, https://scag.ca.gov/rhna. Accessed August 21, 2023. 6 SCAG, SCAG 6th Cycle Final RHNA Allocation Plan.
7 Culver City, Culver City General Plan, May 1994, page O-2, https://www.culvercity.org/Services/Building- Development/General-Plan. Accessed July 3, 2023.
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The General Plan established the following goals in order to achieve a balance of quality of life with the economic support necessary to sustain that quality:
• Residential neighborhoods that offer residents the qualities of a peaceful, small -town environment.
• Economic vitality that serves the community and protects the quality of life. • An urban design, urban forest, open space network that links neighborhoods and businesses, and instills civic pride.
• A community that provides recreational, historical, and cultural opportunities. • Clear and consistent guidance for balanced growth.
• Ample and efficient City services and infrastructure. • Integrated local and regional transportation systems that serve residential and business needs. • A peaceful community that minimizes noise disturbance. • Clean air that provides a healthy environment.
• A safe community.
• A community that minimizes waste and protects its natural resources (Culver City, 1995).
The following policies and goals that pertain to population and housing and are applicable to the Project are as presented below.
Land Use Element
The Land Use Element places an emphasis on quality of life issues in order to improve and enhance the development of the City. The following goals , objectives and policies are applicable to the Project and population and housing:
Goal: Residential neighborhoods that offer residents the qualities of a peaceful, small -town environment.
Objective 2. Housing Supply: Encourage the retention and creation of housing throughout the City.
Objective 3. Affordable Housing: Encourage the provision of housing opportunities for all members of the community.
Objective 4 Neighborhood Conditions: Establish and maintain quality living environments throughout the City.
Policy 1.A: Support residential planning efforts by neighborhoods. The City’s neighborhoods shall include features, design components, themes and programs (such as parks, community gathering places, streetscape amenities, signage/graphic systems, and community beautif ication and celebration programs) that reflect and focus the area’s identity.
Policy 2.B: Continue to allow and encourage multiple family housing opportunities in areas designated for such development.
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Policy 3.B: Provide housing assistance programs for moderate -, low- and very low - income groups.
Policy 4.A: Balance opportunities for additional housing with potential effects on adjacent lower density neighborhoods.
City of Culver City 2021-2029 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, a nd programs to address those needs while balancing community character, objectives, and resources. State law requires Housing Elements to be updated at least every six years to reflect a community’s changing housing needs.
The most recent update was approved 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.
Housing Element Housing Plan Chapter
The Housing Plan chapter is found within the City of Culver City’s Housing Element , discussed below. The Housing Plan is an assessment of the community’s housing needs identified through the City’s demographic, socioeconomic, and housing characteristics and the nature and extent of housing needs.
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.
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.
Policy 1.C: Assist low and moderate income and special needs households to encourage the rehabilitation and adequate maintenance of existing housing units.
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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.
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.
Policy 2.C: Promote mixed use residential development that is sensitive to adjacent residential uses and reinforce the compatible nonresidential uses of the area.
Policy 2.D: Encourage the incremental infilling of residential neighborhoods to enhance housing affordability and supply through the provision of smaller units.
Policy 2.E: Promote 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.
Policy 3.B : Actively support affordable housing development by private and non- profit housing developers.
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.
Policy 3.J: Incentivize housing development on surface parking lots on underused sites that would not displace existing residents.
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.
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.
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Existing Conditions
The Project Site is currently developed with an approximately 30,672 square foot two-story office building. The remainder of the Project Site includes surface parking and associated landscaping.
The Project Site’s current land use designation is Regional Center, which allows large- scale commercial uses and is intended to support existing and anticipated regional -serving commercial developments. The Regional Center land use designation does not support residential and/or residential mixed-use projects. Per the Culver City Zoning Code (Zoning Code), the Project Site is zoned Commercial Regional Business Park (CRB). The CRB Zoning District identifies areas appropriate for large-scale office and business park developments with shared parking, including specific light industrial uses and does not permit residential uses. Pursuant to the City’s adopted 2021-2029 Housing Element, the Property’s preferred land use designation is Mixed-Use High, which would allow for high-density residential uses including mixed-use development. The 2021- 2029 Housing Element’s preferred Mixed-Use High designation permits a residential density of 100 dwelling units per acre. In addition, the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update, includes the draft Land Use Map and Land Use designations with appropriate draft densities. The Project Site’s draft land use designation and density is Mixed-Use High and 100 dwelling units per acre, consistent with the Housing Element preferred designation and density.
SCAG’s C onnect SoCal, which was approved in September 2020, includes the most updated and available information on demographic projections for the City. Current and future projected population, housing, and employment estimates for the City are based on data included in the SCAG’s Connect SoCal .
8 The 2020 RTP/SCS is based on growth projections for population, housing, and employment prepared for regional, county, and local jurisdictional areas. Connect SoCal reports demographic data for 2016, and projections for 2045. 9 Connect SoCal forecasts
represent the likely growth scenario for the Southern California region in the future, taking into account recent and past trends, reasonable key technical assumptions, and local or regional growth policies. The 2020 baseline population and growth projections for the SCAG 2045 Horizon Year, are shown in Table 4.9-1, Projected Population, Housing, and Employment Estimates for Culver City, and discussed below.
Connect SoCal and the City’s current 2021-2029 Housing Element are based on SCAG’s 6 th Cycle
RHNA, which addresses the housing needs for the City from October 2021 to October 2029. As noted in both the Housing Element and the 6
th Cycle RHNA, the total housing growth need for the
City of Culver City during the 2021-2029 planning period is 3,341 units.
8 Southern California Association of Governments (SCAG), Connect SoCal (2020-2045 Regional Transportation Plan and Sustainable Communities Strategy [2020 RTP/SCS]), September 2020, https://scag.ca.gov/post/connect- socal-2020. Accessed July 3, 2023.
9 SCAG, 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020, page 34, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth- forecast.pdf?1606001579. Accessed July 3, 2023.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.9-1
PROJECTED POPULATION, HOUSING, AND EMPLOYMENT ESTIMATES
SCAG 2045 Horizon Year
2020
Baseline
2045 Projection
For Culver City Total Growth
Percentage Increase
as Compared to 2020
Population 40,307 41,600 1,293 3.2%
Housing 17,138 18,000 862 5.0%
Employment 59,962 64,100 4,138 6.9%
SOURCE: 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020. 2020 baseline numbers calculated by interpolating data from 2016 and 2045 projections.
4.9.3 Environmental Impacts
Thresholds of Significance
The following thresholds of significance are based on the Environmental Checklist contained in Appendix G of the CEQA Guidelines. A project would result in significant adverse impacts related to Population and Housing if it would:
• POP/H-1 Induce substantial unplanned population growth in an area, either directly (for example by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure); or
• POP/H-2 Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
Potentially significant impacts related to population and housing are discussed and analyzed further below.
The City determined in the Initial Study that POP/H-2 would result in no 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:
• Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
As detailed in the Initial Study, the Project Site is currently developed with a two-story office building and no residential uses exist on-site. As such, Project implementation would not displace existing people or housing. Therefore, no impact would occur due to displacement of people or housing that would require the construction of replacement housing. No further analysis of this issue is therefore included in this Draft EIR. This Draft EIR evaluates potential population and housing impacts that relate to threshold of significance POP/H-1.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Methodology
The analysis of population and housing impacts evaluates whether the Project’s contribution to population, housing, and employment growth are consistent with the future growth projections and related policies outlined above in order to assess the potential for impacts on the physical environment. Pursuant to the CEQA Guidelines and the thresholds used by the City to determine the significance of impacts to population and housing, as described further below, the focus of the analysis is on whether the Project would induce substantial unplanned population growth in an area either directly or indirectly, which would result in physical impacts on the environment due to the need for construction of unplanned homes, businesses, or infrastructure.
Connect SoCal is the most recently adopted regional plan that provides population, housing, and employment projections for the City for the period between 2016 and 2045. Therefore, for the purpose of the Project’s analysis, population, housing, and employment projections based on Connect SoCal for the City are analyzed with the Project and considered as part of the impact analysis. As Connect SoCal provides data and projections for 2016 and 2045 only, projections for Project Baseline Year 2020 are based on SCAG data
10. In addition to Connect SoCal, the City will
be expected to meet the household provision goals provided in the 6 th Cycle RHNA for the period between 2021 and 2029. Therefore, the Project’s provision of households is also compared to the total allocation for the City based on the 6th Cycle RHNA.
The Project’s estimated residential population was calculated based on the Citywide Person Per Household Factor for average household size provided by the 2020 SCAG City of Culver City 2022 Spatial and Statistical Summary. 11 The employment estimates for the Project are based on the employees per square foot of commercial development generation factors provided in Table 14 of the 2020 Developer Fee Justification Study for the Culver City Unified School District. 12 The
Project’s estimated contribution to population, housing, and employment are compared to projections from SCAG’s Connect SoCal and to the goals of the 6 th Cycle RHNA for the City of Culver City.
Project Design Features
No specific Project Design Features are proposed with regard to population, housing, and employment.
10 SCAG, City of Culver City 2022 Spatial and Statistical Summary, https://scag.ca.gov/sites/main/files/file- attachments/culver-city-atlas.pdf?1660027073. Accessed August 22, 2023. 11 SCAG City of Culver City 2022 Spatial and Statistical Summary, https://scag.ca.gov/sites/main/files/file- attachments/culver-city-atlas.pdf?1660027073. Accessed August 22, 2023. 12 Culver City Unified School District (CCUSD), 2020 Developer Fee Justification Study, March 2020, page 12, https://4.files.edl.io/4db8/03/17/20/192657-7c8c44c2-15f7-4980-b79e-a87920d26d89.pdf. Accessed August 28, 2023.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Analysis of Project Impacts
Induce Substantial Unplanned Population Growth
Threshold Pop/H-1: The Project could have a significant impact if it would i nduce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).
Impact Analysis
The Project would involve demolition of the existing office building on the Project Site to support a mixed-use development with residential and retail uses. As shown in Table 4.9 -2, Projected Increases in Population, Housing, And Employment, t he Project would increase the residential population of Culver City by introducing 309 residential units that would generate an estimated population of 733 residents at the Project Site.13 In addition, the Project would include approximately 5,600 sf of retail use, which would generate an estimated increase of approximately 20 employees on the Project Site.14 When taking into account the demolition of 30,672 sf of existing office uses on the Project Site and associated estimated employment based on the Employment Generation Factor identified in the Culver City Unified School District 2022 Developer Fee Justification Study, the Project would result in a net decrease of 127 employees, as shown in Table 4.9-2.
TABLE 4.9-2
PROJECTED INCREASES IN POPULATION, HOUSING, AND EMPLOYMENT Housing Units and Population
Use Amount Average Household Sizea Total Population
Residential 309 units 2.37 733
Existing Employees
Use Amount
Employment Generation Factor
(per 1,000 square feet)b
Existing Number of
Employees
Office 30,672 square feet 4.78 147
Total Existing Employees 147
Projected Employees
Use Amount
Employment Generation Factor
(per 1,000 square feet)b Number of Employees
Retail 5,600 square feet 3.62 20
Total Projected Employees 20
Net Employees -127
a SCAG, 2022 Spatial & Statistical Summary, City of Culver City, May 2022, page 6. Accessed August 22, 2023. b Culver City Unified School District, 2022 Developer Fee Justification Study, March 2020, page 12.
SOURCE: ESA, 2023.
13 As described in Table 4.9-2, the total population is estimated based on the number of units multiplied by the average household size for Culver City based on SCAG’s 2022 Spatial & Statistical Summary. Available here:
https://scag.ca.gov/sites/main/files/file-attachments/culver-city-atlas.pdf?1660027073. 14 As described in Table 4.9-2, the number of employees is based on the square footages by land use multiplied by employment generation factors provided by LAUSD’s Developer Fee Justification Study.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-12 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
As shown in Table 4.9-3, Projected Population, Housing, and Employment Increases for the City, and based on Connect SoCal projections, the City’s population, household, and employment growth is expected to increase by 879 persons, 159 households, and 17,073 jobs between 2020 and 2045, respectively. The Project’s estimated 733 person increase in population would fall within SCAG’s growth forecast for the City for the period running from 2020 to 2045.
TABLE 4.9-3
PROJECTED POPULATION, HOUSING, AND EMPLOYMENT INCREASES FOR THE CITY
Project Increasea
SCAG Forecasted Growth
Between 2020 and 2045b
Project’s Percentage
of Forecasted Growthc
Population
2020 - 2045 Projection Horizon 733 1,293 57%
Housing Units
2020 - 2045 Projection Horizon 309 862 36%
Employment
2020 - 2045 Projection Horizon -127 4,138 -0.3%
a From Table 4.9-2, Projected Increases in Population, Housing, And Employment. b From Table 4.9-1, Projected Population, Housing, and Employment Estimates for Culver City. c Percentages are rounded.
SOURCE: Compiled by ESA, 2023. Based on SCAG Connect SoCal projections.
As shown in Table 4.9-3, the Project’s residents would comprise 57 percent of SCAG’s projected population increase for the City from 2020 to 2045. The Project’s 309 units would comprise approximately 36 percent of SCAG’s Connect SoCal projected housing increase for the City from 202 to 2045. Compared to existing uses, the Project would result in a decrease of 127 employees, approximately -0.3 percent of SCAG’s projected employment increase for the City from 2020 to 2045. The Project’s increases in population and housing would be within SCAG’s Connect SoCal 2045 projections for the City.
The Project would support and not conflict with relevant goals, objectives, and policies in the City’s General Plan. Most notably, the Project would provide high -quality infill housing through the provision of 309 residential units with a diverse mix of dwelling types, containing both market-rate and 27 Very Low Income units, with a range of household sizes. These characteristics of the Project would support Land Use and Housing objectives and policies for increasing housing supply and affordable housing in the City and promoting access to affordable housing through the use of State and local incentives. The Project’s residential and retail uses would promote the General Plan’s policy for mixed-use development that would be sensitive to adjacent residential uses and reinforce the commercial use of the area.
Additionally, the Culver City October 2021-2029 Housing Element, which is based on the 6 th Cycle
RHNA allocations, indicates the total housing growth need for the City during this planning period is 3,341 units. These allocations show the City’s allocation of housing between October 2021 and October 2029 to be 3,341 units. Accordingly, the Project’s proposed housing would constitute 9.2
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
percent of the 6th Cycle RHNA allocations between 2021 and 2029. Further, the Housing Element contemplates a residential density of 100 dwelling units per acre for the Project Site. In conjunction with state density bonus law, the Project fulfills the City’s density goal for the Project site.
Therefore, the Project would promote fulfillment of the City’s future updated Housing Element goals and the 6
th Cycle RHNA allocation.
As further detailed in Section 4.7, Land Use and Planning, of the Draft EIR, SCAG established goals for development that reduces reliance on individual automobiles, with related lessening of impacts on the environment. The Project would support these goals by providing a mixed -use development with residential and retail uses, located in proximity to existing public transit, including proximity to the Westfield Culver City Transit Center (approximately 0.7 mile west) and a municipal bus line along Hannum Ave nue, which would serve to reduce vehicle miles traveled (VMT). The Project would further support Connect SoCal ’s goal of improving mobility, accessibility, reliability, and travel safety for people and goods based on the Project Site’s proximity to a transit center, multiple regional and local bus line and the provision of bicycle facilities to maximize mobility and accessibility . In addition, residents would be located within a reasonable walking distance to surrounding retail and office uses. The Project would create a pedestrian-friendly environment with internal walkways that connect the pedestrian access points to off-site pedestrian and transit facilities. Within walking distance of several bus stops, the Project would promote alternate modes of transit and promote the use of bicycles through the provision of secure bike storage location s on Levels P1, P2, and the first floor . The Project would encourage development of diverse housing types in areas that are supported by multiple transportation options.
Thus, the Project, which is infill development, would contribute to a growth pattern that is encouraged in SCAG policies for development that reduces reliance on individual automobiles, with associated environmental benefits.
The Project would link with and tie into existing infrastructure in the Project area. As described in in Section 4.13, Utilities and Service Systems, of the Draft EIR, new infrastructure for public service and utility systems that would be required, such as service connections to local water and sewer network and electricity and natural gas utilities would be sized to serve only the Project’s needs.
Project operation w ould modify access from streets that surround the Project Site as described.
However, these modifications represent improvements that would not induce substantial population growth indirectly through the extension of roads or other infrastructure into undeveloped areas. The Project would not have indirect effects on growth through such mechanisms as the extension of roads and infrastructure, since the Project would represent infill development and would utilize the existing transportation and utility infrastructure to serve the Project.
Based on the analysis above, the Project would not induce substantial population growth in the area, either directly or indirectly that cannot be reasonably accommodated, and impacts would be less than significant.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Level of Significance After Mitigation
Not applicable. Project -specific impacts related to population and housing 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 calculation of the cumulative number of housing units, population, and employees attributable to the related projects is provided in Table 4.9 -4, Related Projects Housing, Population And Employment. SCAG projections for the 2045 horizon year incorporate regional policies and are based on long-term demographic trends that average out short -term variations (e.g., foreign and domestic migration).
As shown in Table 4.9-4, the related projects within the City, along with the Project, would generate 2,539 residents, 1,071 housing units, and 3,059 employees. When accounting for related projects within the City of Los Angeles, a total of 4,241 residents, 1,789 housing units, and 3,089 employees would be generated.
Table 4.9 -5, Cumulative Population, Housing, and Employment Impacts, compares projected cumulative growth, inclusive of the Project, to Connect SoCal’s 2045 horizon year projections for the City of Culver City. As shown below, related projects that are outside of the boundaries of the City of Culver City (e.g., the projects within the City of Los Angeles) are not included as the table below presents a comparison to SCAG projected growth for the City of Culver City.
As shown below, the projected cumulative population and household growth for the related projects within the City of Culver City and the Project would exceed the 2045 SCAG projections identified in Connect SoCal for the City. Employment projections would be within those anticipated by SCAG’s 2020 RT/SCS. Despite the cumulative population and household growth exceeding the SCAG projections, they are consistent with the 6
th Cycle RHNA allocations. The increases in
population (approximately 196 percent) and households (approximately 124 percent) show that the City is actively increasing the housing stock within the City to meet the housing growth need based on the Housing Element and the 6 th Cycle RHNA allocations. The 1,071 cumulative households would constitute 32 percent of the City’s allocation of housing between October 2021 and October 2029 of 3,341 units. The increase in housing stock in the City provides opportunities to reduce the demand for development in lower -density areas and achieving greater efficiency in the provision and use of existing services and infrastructure.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.9-4
RELATED PROJECTS HOUSING, POPULATION AND EMPLOYMENT
Developmenta Use Amount
Population Generation
Factor (persons/
household)b
Employee
Generation Factor
(per 1,000 sf)c Population Housing Units Hotel Rooms Employees City of Culver City Only
5800 Bristol Parkway/
5801 Hannum Avenue
Office 281,000 sf -- 4.78 -- -- -- 1,345
6221 Bristol Parkway Residential 712 du 2.37 -- 1,687 712 -- -- Live/Work 50 du 2.37 -- 119 50 -- --
Retail 20,767 sf -- 3.62 -- -- -- 75
6101 Slauson Ave Showroom 8,046 sf -- 3.62 -- -- -- 29
6001 Centinela Ave Burial Plots -- -- -- -- -- -- 2d
5645 Sepulveda Blvd. Medical Office 38,712 sf -- 4.27 -- -- -- 165 Retail 3,193 sf -- 3.62 -- -- -- 12
5840 Uplander Way School 16,128 sf -- 2.55 -- -- -- 41
6161 Centinela Blvd. Creative Office 281,194 sf -- 4.78 -- -- -- 1,344 11469 Jefferson Blvd. Hotel 111,000 sf
(183 rms)
-- 1.55 -- -- 183 172
Culver City Totals 1,806 residents 762 du 183 rms 3,186 employees City of Los Angeles Only
5645 Sepulveda Blvd Residential 176 du 2.37 -- 417 176 -- -- 6711 Sepulveda Blvd Residential 180 du 2.37 -- 427 180 -- -- 5208 Centinela Blvd Restaurant 4,642 sf -- 3.62 -- -- -- 17 6501 Sepulveda Blvd Residential 362 du 2.37 -- 858 362 -- -- Restaurant 3,700 sf -- 3.62 -- -- 00 13
City of Los Angeles Totals 1,702 residents 718 du 0 rms 30 emp.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-16 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.9-4
RELATED PROJECTS HOUSING, POPULATION AND EMPLOYMENT
Developmenta Use Amount
Population Generation
Factor (persons/
household)b
Employee
Generation Factor
(per 1,000 sf)c Population Housing Units Hotel Rooms Employees Related Projects and Project
All Related Projects Totals 3,508 residents 1,480 du 183 rms 3,216 employees Project 733 residents 309 du -- -127 employees (net) Culver City Related Projects and Project 2,539 residents 1,071 du 183 rms 3,059 employees All Related Projects + Project Totals 4,241 residents 1,789 du 183 rms 3,089 employees a A list of the 12 related projects is provided in Table 3-1 of Chapter 3 of this Draft EIR. 8 projects are located within the City of Culver City, and 4 projects are located within the City of Los Angeles. b The City of Culver City average household size is based on SCAG's 2020 Profile of the City of Culver City: https://scag.ca.gov/sites/main/files/file-attachments/culver-city-atlas.pdf?1660027073 c The employment generation factors are based on the Culver City Unified School District, 2020 Developer Fee Justification Study, March 2020, page 12. d ESA estimated two employees for maintenance associated with the burial plots. e Schools did bot have a specific employment category in the Culver City Unified School District, 2020 Developer Fee Justification Study. Thus, ESA utilized the stated “average” employee generation factor of
2.55 employees/1,000 sf.
SOURCE: ESA, 2023.
TABLE 4.9-5
CUMULATIVE POPULATION, HOUSING AND EMPLOYMENT GROWTH FOR CITY
Cumulative Increase,
including Proposed Project
SCAG Projected Growth in
City from 2020 to 2045b
Cumulative Percentage
of Growth in City
(SCAG)
RHNA Projected Growth in
City from 2021 to 2029
Cumulative Percentage
of Growth in City
(RHNA)
Project
Population 2,539 1,293 196% -- --
Households 1,071 862 124% 3,341 32%
Employment 3,059 4,138 74% -- --
a From Table 4.9-4.
b From Table 4.9-1.
SOURCE: ESA, 2023.
4. Environmental Impacts Analysis
4.9. Population and Housing
City of Culver City 4.9-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
As discussed throughout Chapter 4 of this Draft EIR, no significant and unavoidable impacts associated with the operation of the Project have been identified associated with the Project. In addition, despite the increase over SCAG’s 2045 projection, the Pr oject would be consistent with the 6
th Cycle RHNA allocations. For these reasons, the Project would not substantially contribute to a cumulatively considerable impact.
As discussed above, the Project would result in a net increase in jobs compared to existing conditions. However, the Project’s employment opportunities would be adjacent to residential areas and public transit, which would support City and regional policies intended to reduce VMT. As such, the Project and related projects would not induce substantial unplanned population growth in an area, and cumulative impacts from related projects are considered 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 population and housing would be less than significant.
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4. Environmental Impacts Analysis
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4.10.1 Public Services – Fire Protection
4.10.1.1 Introduction
This section of the Draft EIR evaluates whether new or physically altered fire facilities would be required to provide fire protection services to the Project, the construction of which could cause significant environmental impacts. The analysis includes a description of the existing fire protection services in the vicinity of the Project Site as provided by the Culver City Fire Department (CCFD).
The analysis is based on information provided on the CCFD website and through written correspondence from CCFD, which is included in Appendix H-1 of this Draft EIR. 1 4.10.1.2 Environmental Setting
Regulatory Setting
This section provides a summary of State and local fire protection regulations and policies applicable to the Project.
Federal
Occupational Safety and Health Administration
The Federal Occupational Safety and Health Administrations (OSHA as well as California OSHA (Cal/OSHA) enforce the provisions of the federal and state Occupational Safety and Health Acts, respectively, which collectively require safety and health regulatio ns for construction under Part 1926 of Title 29 Code of Federal Regulations (CFR). The fire -related requirements of the Federal Occupational Safety and Health Act are specifically contained in Subpart F, Fire Protection and Prevention, of Part 1926. Exampl es of general requirements related to fire protection and prevention include maintaining fire suppression equipment specific to construction on- site; providing a temporary or permanent water supply of sufficient volume, duration, and pressure; properly ope rating the on -site fire -fighting equipment; and keeping storage sites free from accumulation of unnecessary combustible materials.
Federal Emergency Management Agency
The Federal Emergency Management Agency (FEMA) was established in 1979 via executive order and is an independent agency of the federal government. In March 2003, FEMA became part of the U.S. Department of Homeland Security with the mission to lead the effo rt in preparing the nation for all hazards and effectively manage federal response and recovery efforts following any national incident. FEMA also initiates proactive mitigation activities, trains first responders, and manages the National Flood Insurance Program and the U.S. Fire Administration.
Disaster Mitigation Act of 2000
Disaster Mitigation Act (42 United States Code [USC] Section 5121) provides the legal basis for FEMA mitigation planning requirements for state, local, and Indian Tribal governments as a
1 Culver City Fire Department (CCFD), Fire Marshal Dave Rindels, correspondence dated December 20, 2023.
Provided in Appendix H-1 of this Draft EIR.
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
condition of mitigation grant assistance. It amends the Robert T. Stafford Disaster Relief Act of 1988 (42 USC Sections 5121–5207) by repealing the previous mitigation planning provisions and replacing them with a new set of requirements that emphasize the need and creates incentives for state, tribal, and local agencies to closely coordinate mitigation planning and implementation efforts. This Disaster Mitigation Act reinforces the importance of pre-disaster infrastructure mitigation planning to reduce disaster losses nationwide and the streamlining of the administration of federal disaster relief and programs to promote mitigation activities. Some of the major provisions of the Disaster Mitigation Act include the following:
• Funding pre-disaster mitigation activities
• Developing experimental multi-hazard maps to better understand risk • Establishing state and local government infrastructure mitigation planning requirements • Defining how states can assume more responsibility in managing the Hazard Mitigation Grant Program (HMGP)
• Adjusting ways in which management costs for projects are funded The mitigation planning provisions outlined in Section 322 of the Disaster Mitigation Act establish performance-based standards for mitigation plans and require states to have a public assistance program (Advance Infrastructure Mitigation [AIM]) to develop county government plans. The consequence for counties that fail to develop an infrastructure mitigation plan is the chance of a reduced federal share of damage assistance from 75 percent to 25 percent if the damaged facility has been damaged on more than one occasion in the preceding 10-year period by the same type of event.
State
California Building Code and California Fire Code
The California Building Code (California Code of Regulations [CCR], Title 24, Part 2) is a compilation of building standards, including general fire safety standards for new buildings, which are presented with more detail in the California Fire Code (CCR T itle 24, Part 9). California Building Code standards are based on building standards that have been adopted by State agencies without change from a national model code, building standards based on a national model code that have been changed to address par ticular California conditions, and building standards authorized by the California legislature but not covered by the national model code. The 2022 edition of the California Building Code became effective on January 1, 2023. 2 The building standards in the
California Building Code apply to all locations in California, except where more stringent standards have been adopted by State agencies and local governing bodies. Typical fire safety requirements of the California Fire Code include: the installation of fire sprinklers in all high-rise buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures within wildfire hazard areas.
2 California Building Code (CCR, Title 24, Part 2).
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City of Culver City 4.10.1-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
California Governor’s Office of Emergency Services
In 2009, the State of California passed legislation creating the Cal OES and authorized it to prepare a Standard Emergency Management System (SEMS) program (Government Code Section 8607; Title 19 CCR Section 2401 et seq.), which sets forth measures by which a jurisdiction should handle emergency disasters. In California, SEMS provides the mechanism by which local government requests assistance. Non-compliance with SEMS could result in the State withholding disaster relief from the non-complying jurisdiction in the event of an emergency disaster. Cal OES coordinates the State’s preparation for, prevention of, and response to major disasters, such as fires, floods, earthquakes, and terrorist attacks. During an emergency, Cal OES serves as the lead state agency for emergency management in the State. It also serves as the lead agency for mobilizing the State’s resources and obtaining federal resources. Cal OES coordinates the State response to major emergencies in support of local government. The primary responsibility for emergency management resides with local government. Local jurisdictions first use their own resources and, as they are exhausted, obtain more from neighboring cities and special districts, the county in which they are located, and other counties throughout the State through the statewide mutual aid system (see discussion of Mutual Aid Agreements, above). California Emergency Management Agency (Cal-EMA) maintains oversight of the State’s mutual aid system.
California Mutual Aid System & Plan
The CCFD participates in the California Fire Service and Rescue Emergency Mutual Aid System through which the California Emergency Management Agency, Fire and Rescue Division is responsible for the development, implementation and coordination of the California Fire Service and Rescue Emergency Mutual Air Plan (Mutual Aid Plan), as managed by the Governor’s Office of Emergency Services (OES).
3 The Mutual Aid Plan outlines procedures for establishing mutual aid agreements at the local, operational, regional, and State levels, and divides the State into six mutual aid regions to facilitate the coordination of mutual aid. Culver City is located in Region 1.
Through the Mutual Aid Plan, the OES is informed of conditions in each geographic and organizational area of the state, and the occurrence or imminent threat of disaster. All OES Mutual Aid participants monitor a dedicated radio frequency for fire events that are beyond the capabilities of the responding fire department and provide aid in accordance with the management direction of the OES.
The CCFD is supported, when needed, through mutual aid agreements with fire departments in the City of Los Angeles and Los Angeles County. Under this automatic aid agreement, CCFD apparatus and personnel are deployed to portions of Los Angeles County west of the City and to the City of Los Angeles south of the City, as well as to the City’s immediate borders. As the City is within mutual aid Region 1 of the Emergency Mutual Aid Region established by OES, mutual aid assistance is also provided by the fire departments in the cities of Beverly Hills, Santa Monica, and West Hollywood. The mutual aid agreements ensure that the CCFD and the neighboring assisting agencies have shared standard operating procedures and regularly participate in joint
3 California Emergency Management Agency, Fire and Rescue Division, California Fire and Rescue Emergency Mutual Aid System, Mutual Aid Plan, revised February 2023.
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training programs. 4 In the event of major emergencies or community disasters, the City of Los Angeles and Los Angeles County fire departments would provide immediate aid to the City, with the other cities of Beverly Hills, Santa Monica, and West Hollywood following, as needed.
California Constitution Article XIII, Section 35
Section 35 of Article XIII of the California Constitution at subdivision (a)(2) provides: “The protection of public safety is the first responsibility of local government and local officials have an obligation to give priority to the provision of adequate public safety services.” Section 35 of Article XIII of the California Constitution was adopted by the voters in 1993 under Proposition 172.
Proposition 172 directed the proceeds of a 0.50-percent sales tax to be expended exclusively on local public safety services. California Government Code Sections 30051-30056 provide rules to implement Proposition 172. Public safety services include fire protection. Section 30056 mandates that cities are not allowed to spend less of their own financial resources on their combined public safety services in any given year compared to the 1992-93 fiscal year. Therefore, an agency is required to use Proposition 172 to supplement its local funds used on fire protection services, as well as other public safety services. In City of Hayward v. Board of Trustees of California State University (2015) 242 Cal.App.4th 833, the court found that Section 35 of Article XIII of the California Constitution requires local agencies to provide public safety services, including fire protection, and that it is reasonable to conclude that the city will compl y with that provision to ensure that public safety services are provided.
5 The Hayward ruling also concluded that “assuming
the city continues to perform its obligations, there is no basis to conclude that the project will cause a substantial adverse effect on human beings” and the “need for additional fire protection services is not an environmental impact that CEQA requires a project proponent to mitigate.” 6 California Vehicle Code
Section 21806 of the California Vehicle Code (CVC) pertains to emergency vehicles responding to Code 3 incident/calls. This section of the CVC states the following:
Upon the immediate approach of an authorized emergency vehicle which is sounding a siren and which has at least one lighted lamp exhibiting red light that is visible, under normal atmospheric conditions, from a distance of 1,000 feet to the front of the vehicle, the surrounding traffic shall, except as otherwise directed by a traffic officer, do the following: (a)(1) Except as required under paragraph (2), the driver of every other vehicle shall yield the right -of-way and shall immediately drive to the righ t-hand edge or curb of the highway, clear any intersection, and thereupon shall stop and remain stopped until the authorized emergency vehicle has passed. (2) A person driving a vehicle in an exclusive or preferential use lane shall exit that lane immediat ely upon determining that the exit can be accomplished with reasonable safety...(c) All pedestrian upon the highway shall proceed to the nearest curb or place of safety and remain there until the authorized emergency vehicle has passed.
4 City of Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 26.
5 City of Hayward v. Board of Trustees of California State University (2015) 242 Cal.App.4th 833, 847. 6 City of Hayward v. Board of Trustees of California State University (2015) 242 Cal.App.4th 833, 843, 847.
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Local
City of Culver City General Plan
The 1975 Public Safety Element of the Culver City General Plan contains the following fire protection policies applicable to the proposed Project:7 • Reduce fire hazards associated with older buildings.
• Encourage improved fire protection for multi-story structures and high-hazard industrial facilities. • Require all new development and selected existing development to comply with established fire safety standards.
CCFD 2019 Community Risk Assessment & Standards of Cover CCFD’s 2019 Community Risk Assessment & Standards of Cover (CRA) serves as the CCFD’s Integrated Risk Management Plan. The CRA defines the process, known as “deployment analysis,” as a written procedure which determines the distribution and concentration of fixed and mobile resources of an organization. The purpose for completing such a document is to assist the agency in ensuring a safe and effective response force for fire suppression, emergency medical services, and specialty response situations. The CRA serves as: (1) the basis for continually measuring service level performance; (2) a predictive tool for helping to determine workload and ideal unit utilization; (3) a management tool for determining apparatus type and staffing levels; (4) a descriptive tool for validating service levels; and (5) a baseline tool for defining service level objectives. Performance measures set forth in the CRA applicable to the Project include, but are not limited to, the following:
8 Response Time Goals: Response time goals for fire suppression, technical rescue and HazMat are 7:00 minutes for the first due-in unit and 8:00 minutes for the Effective Response Force (ERF), 90 percent of the time. Response time goals for emergency medical services (EMS) are 6:20 minutes for the first due-in unit and 9:50 minutes for the ERF, 90 percent of the time. It is noted that the above are goals, not standards.
Fire Flow Requirements: Fire flow requirements range from 2,000 gallons per minute (gpm) in low-density residential areas up to 12,000 gpm in commercial and industrial areas.
High/Special Risk Fire Response: High and Special Fire Risk incidents in the City represent unique critical tasking situations where there is very little historical response information to base tasking upon. These types of incidents are addressed with the region’s mutual aid agreements t o help augment City resources. For example, the minimum mutual aid request to meet the demands of a high/special risk fire is an “A Assignment,” (i.e., one truck company (5), three engine companies (12), two rescue ambulances (4), two battalion chiefs (4), and one EMS Supervisor (1), requiring 26 personnel to assist with the incident).
7 City of Culver City, Culver City General Plan, Public Safety Element, adopted August 25, 1975, https://www.culvercity.org/files/assets/public/documents/community-development/publicsafetyelement.pdf.
Accessed December 27, 2023.
8 CCFD, Community Risk Assessment: Standards of Cover 2019.
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Culver City Municipal Code
Sections of the City’s Municipal Code applicable to fire protection and EMS services at the Project Site include, but are not limited to, the following:
Section 9.02 (Fire Prevention):
Section 9.02.005 (Adoption of the 2022 CFC): Adopts the 2022 CFC with amendments as the City of Culver City Fire Code (Fire Code).
Section 9.02.035 (Locks for CCFD Access) : All noted exterior doors shall be provided with locksets and handles for Fire Department Access. Keys for required access shall be provided by the owner and made readily available in the KNOX Box.
Section 9.02.040 (Automatic Fire Sprinkler Systems) : An automatic fire-extinguishing (sprinkler) system shall be installed in every new building in the city, including any new residential building, hereinafter constructed or moved into the city, regardless of area separation or type of construction.
Section 9.02.065 (Fire Hydrant Spacing): Fire hydrant spacing in commercial/industrial / residential areas shall be 300 feet apart. The maximum distance of a fire hydrant to a Fire Department Connection (FDC) shall not exceed 100 feet.
Other sections of the CCMC applicable to fire protection services at the Project Site include, but are not limited to, the following:
Section 9.08.385 (Authority to Close Streets) : This section requires coordination with the Public Works Department to notify the Police and Fire Department prior to street closure for construction or repair work.
Section 17.540 (Site Plan Review): This section provides procedures and standards for the comprehensive review of proposed development projects to: ensure compliance with the required standards, design guidelines, and ordinances of the City; minimize potential adverse effects on surrounding properties and the environment; and protect the integrity and character of the residential, commercial, and public areas of the City. As such, this section may require new projects to be reviewed by the CCFD to ensure that fire related measures are incorporated.
Section 17.560 (Comprehensive Plans): This section provides procedures and standards for Comprehensive Plans, including required findings to ensure that the proposed development is capable of creating an environment of sustained desirability and stability and will not be substantially detrim ental to present and potential surrounding uses. As part of the Comprehensive Plan process, the Planning Department circulates project plans to other City departments for review and comment, including to the CCFD.
Existing Conditions
Fire Protection Facilities and Services
Fire protection and emergency medical services for the Project Site are provided by the CCFD, which is supported, when needed, through mutual aid agreements with fire departments in the City of Los Angeles and the Los Angeles County, with further assistance from the cities of Beverly Hills, Santa
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Monica, and West Hollywood. 9 The CCFD provides fire protection to an existing population of approximately 40,000 persons and is made up of a total of 79 employees who are housed at three fire stations and three support stations. Each fire station is equipped with unique equipment and personnel needed to serve the community, with at least 18 sworn personnel on duty at all times . The CCFD utilizes a three-shift schedule, staffing each shift for a 24-hour period, seven days a week, and 365 days a year. Other facilities that serve the CCFD include the Community Risk Reduction and Fire Administration offices in City Hall, as well as a 4,965 square-foot Fire Drill Training Facility used for teaching firefighting techniques.
10 The City is divided into three fire districts, two rescue/EMS districts, and 15 metropolitan fire management zones (FMZs), with the fire and rescue/EMS districts evenly distributed by population and centerline miles of roads served, and the FMZs defined by occupancies within a given geographical area that share common fire risk. 11 The Project Site is located within Fire District 3, FMZ 14, with first-in service to the Project Site provided by Fire Station 3, with Fire Stations 1 and 2 providing backup service.12 FMZ 14, which covers approximately 0.44 square miles, comprises exclusively of commercial buildings, industrial buildings, and businesses.13 Figure 4.10.1-1, Culver City Fire Department Stations, illustrates the Fire Districts and Fire Stations within Culver City, as well as the direct access route to the Project Site from Fire Station 3.
Table 4.10.1-1, CCFD Fire Stations Located in the Vicinity of the Project Site , provides information on the location, type of equipment/staffing, and the approximate distance/direction from the Project Site. Fire Station 3’s service boundaries cover approximately 1.75 square miles and has a service population of approximately 13,000 people. 14 Fire Station 3 houses a fire engine
(three personnel), a ladder truck (four personnel), and a paramedic rescue ambulance (two personnel). In 2023, Fire Station 3 responded to a total of 2,859 incidents, including 1,985 EMS incidents, 92 fire incidents, 20 wildland fire incidents, 40 hazardous materials incidents, 60 technical rescue incidents, and 662 other incidents.
15 9 City of Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 26,
https://static1.squarespace.com/static/5d950bfaae137b5f0cbd75f5/t/5f52a1c3f0c7ef795c8edf66/1599250917520/C CGPU_ParksPublicFacilities_2020_0805_WebCovidMemo.pdf. Accessed December 27, 2023. 10 City of Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 22.
11 CCFD, Community Risk Assessment: Standards of Cover 2019, pages 18 and 38, https://www.culvercityfd.org/files/sharedassets/fire/crasoc_website_20190618.pdf. Accessed December 27, 2023. 12 CCFD, Fire Marshal Dave Rindels, correspondence dated December 20, 2023. Provided in Appendix H-1 of this Draft EIR.
13 CCFD, Community Risk Assessment: Standards of Cover 2019, pages 178 to 180. 14 CCFD, Fire Marshal Dave Rindels, correspondence dated December 20, 2023. Provided in Appendix H-1 of this Draft EIR.
15 CCFD Performance Management Dashboard, Station 3, https://dashboards.mysidewalk.com/culver-city-ca-fire- performance-dashboard/station-3. Accessed January 11, 2024.
CCFD Fire Station 1
9600 Culver Blvd
Culver City, CA 90232
CCFD Fire Station 2
11252 Washington Blvd
Culver City, CA 90230
CCFD Fire Station 3
6030 Bristol Pkwy
Culver City, CA 90230
© OpenStreetMap (and) contributors, CC-BY-SA
Path: U:\GIS\GIS\Projects\2022xxx\D202201041_01_5700HannumAvenue_EIR\03_Project\CD EIR\CD EIR.aprx, sgeissler 2/13/2024 Project Site
CCFD Fire Station
Fire District 1
Fire District 2
Fire District 3
Direct Route from
Station 3 to Project Site
0 0.75
MilesN
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.10.1-1
Culver City Fire Department Stations
SOURCE: Mapbox, 2023; City of Los Angeles Open Data: https://da ta.lacity.org/, Accessed February 2024; ESA 2024
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.10.1-1
CCFD FIRE STATIONS LOCATED IN THE VICINITY OF THE PROJECT SITE Fire Station Address
Driving
Distance to
Project Sitea Apparatus Staff
Fire Station 3 6030 Bristol
Parkway
0.3 miles
southwest of
Project Site
Engine
Company Captain, engineer, firefighter
Paramedic
Resources
2 firefighter/ paramedics with ALS
certification
Truck
Company Captain, engineer, 2 firefighters
Fire Station 2
11252
Washington
Boulevard
2.6 miles
northwest of
Project Site
Engine
Company Captain, engineer, firefighter
Ambulance 2 EMTs
Fire Station 1
(Headquarters)
9600 Culver
Boulevard
3.7 miles north
of Project Site
Engine
Company Captain, engineer, firefighter
Paramedic
Resources
2 firefighter/ paramedics with ALS
certification
Battalion
Chief
Command
Vehicle
Battalion chief
NOTES:
ALS = Advanced Life Support
SOURCE: Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, pages 22 and 23.
With nine on -duty personnel, Fire District 3 would have an existing on-duty firefighter to population ratio of 1:1,445. 16 Based on the above, the existing on- duty firefighter to population ratios for the entire City is 1:2,000.17
According to the CCFD, no new fire stations are planned at this time. 18 However, as stated in the CCFD Strategic Plan and the 2019 CRA, improvements have been planned to increase CCFD performance regarding deployment, response time, data collection, and mutual aid. The CCFD plans to add a third rescue ambulance (2 staff) at F ire Station 2 and to augment employees by 7 additional staff.
19 The CCFD will continue to monitor response time and these improvement efforts, as well as improve data collection methods to improve CCFD’s performance.
16 With 9 on-duty personnel and a service population of 13,000 people, Fire District 3 would have 9 personnel:13,000 people, which is approximately 1 personnel:1,445 people. 17 With 20 on-duty personnel based on Table 4.10.1-1 for all three fire stations and a total City population of 40,000 people, the City would have 20 personnel:40,000 people, which is 1 personnel:2,000 people. 18 CCFD, Fire Marshal Dave Rindels, correspondence dated December 20, 2023. Provided in Appendix H-1 of this Draft EIR.
19 Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 29.
4. Environmental Impacts Analysis
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City of Culver City 4.10.1-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
In 2023, the CCFD responded to a total of 7,810 incidents, including fire, rescue, hazardous materials, and others.20 Based on these statistics, the CCFD had a 2023 Citywide fire/EMS incident to population ratio of 7,810 incidents per 40,000 persons, or approximately 195 incidents per 1,000 persons. As detailed above, in 2023, Fire Station 3 had a total of 2,859 incidents, serving a population of 13,000 people, and therefore had an incident to population ratio of approximately 220 incidents per 1,000 persons.
The CCFD’s response time standards differentiate between the type of an emergency response call (e.g., fire suppression, EMS, technical rescue, hazardous materials emergency response) and then by the type of risk (e.g., high, moderate, and low risk). The CCFD reports their response times based on the first due -in staff and the ERF. The first due -in staff is the first unit to arrive at the incident and has the responsibility of establishing command at the scene, evaluating the need for additional resources, and providing initial emergency response services. The ERF includes the total number of personnel necessary to address an emergency and/or terminate an incident. 21 Table 4.10.1-2, CCFD Response Times, shows the response time goals, for 90 percent of the time, and the five-year aggregate response times from 2019 to 2023.
While the 2019 to 2023 five-year aggregates did not completely meet CCFD’s response time goals, the total response time goal in 2023 for first due -in units for all calls for Station 3 , which would serve the Project Site, was met 76.6 percent of the time (compared to 69.9 percent of the time for all of CCFD).22 In 2023, the average first arriving response time for all incidents for Fire Station 3 was 8:08 minutes, 90 percent of the time.
Emergency Access
The Project Site is located within an urbanized area that has a fully developed roadway system.
Emergency access to the Project vicinity is provided by several arterials including Slauson Avenue and Bristol Parkway. Direct emergency access to the Project Site is provided by each of the streets bordering the Project Site, including Hannum Avenue and Buckingham Parkway.
A direct route is available from CCFD Fire Station 3, located at 6030 Bristol Parkway approximately 0.3 miles southeast of the Project Site, to the Project Site via Bristol Parkway to Hannum Avenue.
20 CCFD Performance Management Dashboard, Monthly Incident Report, https://dashboards.mysidewalk.com/culver-city-ca-fire-performance-dashboard/incident-report. Accessed January 11, 2024.
21 Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, pages 25 and 26.
22 CCFD Performance Management Dashboard, Monthly Station Benchmark Reports. https://dashboards.mysidewalk.com/culver-city-ca-fire-performance-dashboard/station-3. Accessed January 11, 2024.
4. Environmental Impacts Analysis
4.10.1. Public Services – Fire Protection
City of Culver City 4.10.1-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.10.1-2
CCFD RESPONSE TIMES
Incident Type CCFD Goala Aggregate 2019-2023 Response Timeb High Risk Fire Incident
First Due-In Unit 7:00 5:21
ERF 14:00 8:06
Moderate Risk EMS Incident
First Due-In Unit 6:20 8:07
ERF 9:50 11:40
Moderate Risk Technical Rescue Incidents
First Due-In Unit 7:30 5:09
ERF 12:00 N/A
Moderate Risk Hazardous Materials Incident
First Due-In Unit 8:00 9:45
ERF 9:00 11:12
Moderate Risk Wildland Fire Incident
First Due-In Unit 7:30 8:11
ERF 13:00 N/A
NOTES:
a Commission on Fire Accreditation International, 2019. Accreditation Report, Culver City Fire Department, pages 25 to 31. https://www.culvercityfd.org/files/sharedassets/fire/culvercityfdaccreditationr.pdf. Accessed January 2024. b CCFD Performance Management Dashboard, 5-Year Total Baseline Performance Table. https://dashboards.mysidewalk.com/culver-city-ca-fire-performance-dashboard/baseline-performance. Accessed January 11, 2024.
Water Infrastructure/Fire Flow for Firefighting Purposes Golden State Water Company (GSWC) currently provides water service to the Project Site. In general, fire flow pressure requirements are closely related to land use as the quantity of water necessary for fire protection varies with the type of development, life hazard, type of occupancy, and degree of fire hazard. Based on information provided in the Water Civil Technical Memorandum prepared for the Project by Kimley Horn (Appendix K) and as further detailed in Section 4.13.1, Utilities and Service Systems – Water Supply , fire flow to the Project Site is currently provided by 12- inch water main in Hannum Avenue. Additionally, a water meter is located along the street frontage of Hannum Avenue. There is a fire hydrant located across Hannum Avenue at the center of the Project Site, and another fire hydrant adjacent to the Project Site along Buckingham Parkway, also generally within the central portion of the Project Site.
Fire Hazard Area
The Project Site is in a highly urbanized area and is not located within an area designated by CAL FIRE or CCFD as a Very High Fire Hazard Severity Zone (VHFHSZ). 23,24 VHFHSZs are primarily
23 Culver City Fire Department (CCFD), Very High Fire Hazard Severity Zones (VHFHSZ) Map, June 13, 2012, https://www.culvercityfd.org/files/sharedassets/fire/v/1/culvercityfiredepartmentve.pdf. Accessed December 27, 2023. 24 CAL FIRE, California Fire Hazard Severity Zone Viewer, https://egis.fire.ca.gov/FHSZ/. Accessed December 27, 2023, 2022.
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City of Culver City 4.10.1-12 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
located in the hilly regions of the City of Culver City where wildland fires originating on brush - covered undeveloped hillsides can be affected by urban development and vice versa. The nearest VHFHSZ is located approximately 0.3 miles northeast of the Project Site. In addition, the Project Site is surrounded by urban development and is not adjacent to any wildlands or high fire hazard zones.
4.10.1.3 Environmental Impacts
Thresholds of Significance
The following threshold of significance is based on th e Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in a significant impact associated with fire protection if it would:
• FIRE-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection.
Methodology
Project effects on fire protection services are evaluated by CCFD on a project -by-project basis. A project’s land use designation, project size and components fire-related needs including fire flow and fire hydrant sizing, and whether the project site meets the recommended response distance and fire safety requirements, as well as project design features that would reduce or increase the demand for fire protection and emergency medical services, are taken into consideration. Further evaluation of impacts considers whether or not the development of the project would create the need for a new fire station, or expansion, relocation, or consolidation of an existing facility, to accommodate increased demand. Consultation with CCFD is also conducted to determine a project’s effects on fire protection and emergency medical services.
The need for or deficiency in adequate fire protection services in and of itself is not a CEQA impact, but rather a social and/or economic impact. Where a project causes a need for additional fire protection services resulting in the need to construct new facilities or additions to existing facilities, and the construction results in a potential impact to the environment, then the impact would need to be assessed in this EIR. The ultimate determination of whether there is a significant impact to the environment related to fire protection services resulting from a project is determined by whether the construction of new or expanded fire facilities is a reasonably foreseeable direct or indirect effect of the project.
Based on input received from CCF D, there are no current capital improvement plans for the construction or expansion of fire facilities in the local vicinity of the Project Site in the City of Culver City. Based on historical development of fire facilities, it is assumed that in the event Culver City determines that expanded or new emergency facilities are warranted, such facilities (1) would occur where allowed under the designated land use, (2) would be located on parcels that are infill opportunities on lots that are between 0.5 and 1 acre in size, and (3) could qualify for a categorical exemption or Mitigated Negative Declaration under CEQA Guidelines Section 15332.
4. Environmental Impacts Analysis
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City of Culver City 4.10.1-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
In regard to fire hydrant flow, GSWC performed a hydraulic analysis of their respective water system to determine if adequate fire flow is available to the fire hydrants surrounding the Project Site.
Project Design Features
The Project would incorporate Fire Code requirements, including those summarized in the letter from CCFD included in Appendix H -1 of this Draft EIR. No specific project design features are proposed with regard to fire protection. However, as discussed in Section 4.11, Transportation, of this Draft EIR, pursuant to Project Design Feature TRAF -PDF-1, the Project would implement a Construction Management Plan that would include measures to ensure emergency access to the Project Site and adjacent properties. Project Design Feature TRAF-PDF-1 would minimize impacts to vehicular and other forms of circulation during construction.
Analysis of Project Impacts
Threshold FIRE-1: The Project would have a significant impact on fire protection if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection.
Impact Analysis
Construction
Construction activities have the potential to result in accidental on -site fires by exposing combustible materials (e.g., wood, plastics, sawdust, coverings, and coatings) to fire risks from machinery and equipment sparks and from exposed electrical lines, chemical reactions in combustible materials and coatings, and lighted cigarettes. The Project Site is located 0. 3 miles from CCFD Fire Station 3, the first due-in fire station for CCFD. CCFD Fire Station 3 includes an engine company, a paramedic rescue am bulance, and a truck company . While the average first arriving response time for Fire Station 3 in 2023 was 8:08 minutes, the CCFD has estimated that the rough estimate response time for the first due -in unit to the Project Site would be 4 minutes. 25 The drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic pursuant to Section 21806 of the CVC. Furthermore, Project construction activities would be short-term and temporary.
Given the nature of construction activities and the work requirements of construction personnel, OSHA developed safety and health provisions for implementation during construction, which are set forth in 29 CFR Part 1926, as discussed further above in Section 4.10 .1.2, Environmental Setting. In accordance with these regulations, construction managers and personnel would be trained in emergency response and fire safety operations, which include the monitoring and management of life safety systems and facilities, such as those set forth in the Safety and Health Regulations for Construction established by OSHA. Additionally, in accordance with the
25 CCFD, Fire Marshal Dave Rindels, correspondence dated December 20, 2023. Provided in Appendix H-1 of this Draft EIR.
4. Environmental Impacts Analysis
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City of Culver City 4.10.1-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
provisions of OSHA, fire suppression equipment (e.g., fire extinguishers) specific to construction would be maintained on- site. Project construction would also occur in compliance with all applicable federal, state, and local requirements concerning the handling, disposal, use, storage, and management of hazardous materials. Thus, compliance with regulatory requirements would effectively reduce the potential for Project construction activities to expose people to the risk of fire or explosion related to hazardous materials and non-hazardous combustible materials.
Project construction could also potentially impact the provision of existing CCFD services in the vicinity of the Project Site as a result of construction impacts to the surrounding roadways. While most construction activities are expected to be primarily contained within the boundaries of the Project Site, construction could, if approved by the City of Culver City, encroach into the public rights-of-way (e.g., sidewalks and roadways) adjacent to the Project Site on Hannum Avenue or Buckingham Parkway. However, travel lanes would be maintained in each direction on all streets around the Project Site throughout the construction period, and emergency access would not be impeded. In addition, a Construction Management Plan will be implemented during Project construction pursuant to Project Design Feature TRAF-PDF-1 set forth in Section 4.12, Transportation, of this Draft EIR, to ensure that adequate and safe access remains available within and near the Project Site during construction activities. Specifically, Project Design Feature TRAF- PDF-1 requires the provision of an e mergency access plan as well as review and approval of any proposed lane closures include coordination with the fire and police departments of each city to minimize potential effects on traffic flow and emergency response. Construction activities would also generate traffic associated with the movement of construction equipment, the hauling of soil and construction materials to and from the Project Site, and construction worker traffic. Thus, although construction activities would be short -term and temporary for the area, Project construction activities could temporarily impact emergency access. However, with implementation of Project Design Feature TRAF -PDF-1, the majority of construction -related traffic, including hauling activities and construction worker trips, would occur outside the typical weekday commuter a.m. and p.m. peak periods, thereby reducing the potential for traffic-related conflicts. The Project would also employ temporary traffic controls, such as flag persons, to control traffic movement during temporary traffic flow disruptions. Traffic management personnel would be trained to assist in emergency response by restricting or controlling the movement of traffic that could interfere with emergency vehicle access. Appropriate construction traffic control measures (e.g., detour signage, delineators) would also be implemented, as necessary, to ensure emergency access to the Project Site. Traffic control measures would also ensure that traffic flow is maintained on adjacent rights-of-way and would also minimize response times. Furthermore, pursuant to Section 21806 of the CVC, the drivers of emergency vehicles are able to avoid traffic by using sirens to clear a path of travel or by driving in the lanes of opposing traffic to respond to emergencies in a timely manner.
Based on the above, construction of the Project would not result in the need for a new fire station or the expansion of an existing facility, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services. Therefore, impacts to fire protection during Project construction would be less than significant.
4. Environmental Impacts Analysis
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City of Culver City 4.10.1-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Operation
Fire Protection Facilities and Services
As discussed in Section 4.9, Population and Housing, of this Draft EIR, the elimination of the existing on-site office uses would result in an estimated net decrease in employees on the Project Site of 127 employees. The development of the Project’s 309 residential units would result in a total population of approximately 733 people. While there would be a decrease in employees on the Project Site, fire incidents are based on population or employees. Thus, without accounting for the decreased number of employees, this analysis conservatively analyzed incidents based on the residential population generated by the Project. Accordingly, b ased on the 2023 Fire Station 3 fire/EMS incident to population ratio of 220 incidents per 1,000 persons, the Project’s anticipated increase of approximately 733 people would generate the potential for an estimated 161 additional fire/EMS incidents per year requiring CCFD response. T he potential increase in the number of service calls associated with the Project would represent approximately two (2) percent of the total number of Citywide service calls. Nonetheless, as the Project would increase intensity of the Project Site, there would be an increase in the demand for fire protection services compared to existing conditions. As previously described, the Project Site is located 0.3 miles from CCFD Fire Station 3, the first due -in fire station. CCFD Fire Stations 1 and 2 would provide backup service to the Project Site.
The Project would comply with the applicable OSHA, Building Code, Fire Code, and other CCMC, and CCFD requirements, including installation of a fire sprinkler suppression system, a fire alarm system, an Emergency Responder Radio Coverage, and manual smoke evacuation systems in the underground parking structure on the Culver City Parcel; installation of Knox Boxes; provision of fire resistant doors, materials, walkways, stairwells, elevator systems (including emergency and fire control elevators), smoke detectors, and signage, among other fire prevention features.
The Project would also generate revenues to the City of Culver City (in the form of property taxes, sales revenue, etc.) that could be applied toward the provision of new fire station facilities and related staffing, as deemed appropriate by each City.
Lastly, based on the analysis and the constitutional requirement started in the California Constitution Article XIII, Section 35(a)(2) to provide these services, and the Hayward ruling, it is reasonable to conclude that: (1) Project operation would not require the addition of a new fire station or the expansion, consolidation, or relocation of an existing facility in order to maintain service; (2) such services will be provided by a local jurisdiction; and (3) the Project would not inhibit CCFD emergency re sponse. Also, as indicated previously, it is assumed that in the event Culver City determines that expanded or new emergency facilities are warranted, such facilities (1) would occur where allowed under the designated land use; (2) would be located on parcels that are infill opportunities on lots that are between 0.5 acre and 1 acre in size; and (3) could qualify for a categorical exemption under CEQA Guidelines Section 15332 or Mitigated Negative Declaration.
Compliance with applicable regulatory requirements and recommendations would ensure that adequate fire prevention features are provided that would reduce the demand on CCFD facilities and services without creating the need for new or expanded fire facilities.
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Response Distance and Emergency Access
CCFD does not have a required response distance, but does have response time goals. As discussed previously, CCFD emergency response time goals consisting of all the various incident types shown in Table 4.10.1-2 for Fire Station 3, which would serve the Project Site, were met 76.6 percent of the time. 26 The CCFD has also estimated that the rough estimate response time for the first due-in unit (CCFD Fire Station 3) to the Project Site would be 4 minutes .27 While precise response times cannot be predicted, this information suggests that the first due-in unit response goal of 7 minutes would be achieved.
The Project’s new buildings would be required to install an automatic fire sprinkler system. The installation of fire sprinklers in the proposed buildings serve to provide a quick reaction to a building fire that reduce the risk of death or injury from a fire because they dramatically reduce heat, flames, and smoke, allowing building occupants time to evacuate before the fire protection services arrive. As described in Chapter 2, Project Description, of this Draft EIR, vehicular access to the Project Site would be provided via two driveways, the Hannum Driveway and the Buckingham Driveway. Both driveways would provide access to the parking structure, while both adjacent roadways could be utilized by emergency vehicles to park or provide fire-fighting services during an emergency event. In addition, there is a fire access lane on the west side of the building, as shown on Figure 2-3, Conceptual Site Plan, in Chapter 2, Project Description, of this Draft EIR.
As part of the comprehensive plan review, the Project’s access would be reviewed and approved by CCFD to ensure that emergency vehicle access to the Project Site would not be impeded. As such, emergency access to the Project Site would be adequately maintained.
The area surrounding the Project Site includes an established street system, consisting of primary and secondary arterials, and collector and local streets that provide regional, sub-regional, and local access and circulation within the local Project vicini ty. The Project Site is located within a highly urbanized area of City of Culver City, and the streets surrounding the Project Site were designed as standard streets in terms of pavement width and thickness, curb and gutter, and horizontal and vertical curvature. Therefore, the street system surrounding the Project Site is not considered substandard. In addition, emergency response is routinely facilitated, particularly for high priority calls, through the use of sirens to clear a path of travel (including bypassing of signalized intersections), driving in the lanes of opposing traffic pursuant to Section 21806 of the CVC, and multiple station response. Furthermore, because of the grid-like pattern of the local street system, each of the fire stations that serve the Project Site have multiple routes available to respond to emergency calls at the Project Site. In addition, CCFD is looking to reduce response times via:
alarm handling improvements with its new dispatch center; use of turnout timers in stations to better monitor turnout times; and use of HAAS alerting systems in new engines that send messages to drivers and connected vehicles predicted to be in the path of the emergency vehicles preparing to
26 CCFD Performance Management Dashboard, Monthly Station Benchmark Reports. https://dashboards.mysidewalk.com/culver-city-ca-fire-performance-dashboard/station-3. Accessed January 11, 2024.
27 CCFD, Fire Marshal Dave Rindels, correspondence dated December 20, 2023. Provided in Appendix H-1 of this Draft EIR.
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approach or arrive on -scene.28 These CCFD improvements are likely to further reduce response times through increased efficiencies in turnout times and route clearing.
Based on the considerations above, despite potential increases in traffic, the Project would not significantly impair CCFD from responding to emergencies at the Project Site or the surrounding area.
Water Infrastructures/Fire Flow for Firefighting Purposes Fire flow requirements are based on building size and construction type. The Project Site is served by a 12-inch water main in Hannum Avenue. There is a fire hydrant located across Hannum Avenue at the center of the Project Site, and another fire hydrant adjacent to the Project Site along Buckingham Parkway, also generally within the central portion of the Project Site. As detailed within Section 4.13.1, Utilities and Service Systems – Water Supply, the Project would have a minimum fire flow requirement of 1,500 gpm at 20 psi residual for a duration of 2 hours, in compliance with the CCMC Section 9.02. Per the Fire Service Pressure Flow Report provided by GSWC (located within Appendix K of this Draft EIR), the existing fire hydrant connected to the 12- inch water main in Hannum Avenue can provide 4,409 gpm at 20 psi for a duration of 2 hours.
Additionally, according to correspondence with the CCFD (located within Appendix K), an additional fire hydrant would not be required as part of the Project. Therefore, the site’s existing fire hydrant infrastructure would be sufficient to meet the Project’s fire flow requirements. Furthermore, Project building plans would be submitted to the CCFD to review and approve the fire hydrant locations. All fire hydrant requirements and fire sprinkler designs would be subject to CCFD review and approval during the Project’s design and permitting phase. Therefore, operational impacts to the City’s fire water service facilities and infrastructure 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 not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, resp onse times or other performance objectives for fire protection. Impacts would be less than significant without mitigation.
Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR, identifies 12 related projects that are anticipated to be developed within a 1.0 -mile radius of the Project Site. These projects are summarized in Table S3-1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3. As shown in Table 3-1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles. Of these related projects, eight occur within Culver City and, like the Project, would create a demand for fire protection service from the CCFD. All of the Culver City related projects are located within Fire District 3 where the Project Site is located.
28 CCFD, Community Risk Assessment: Standards of Cover 2019, page 121.
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Construction
As with the Project, each related project would have the potential to result in accidental on-site fires by exposing combustible materials (e.g., wood, plastics, sawdust, coverings, and coatings) to fire risks from machinery and equipment sparks, and from exposed electrical lines, chemical reactions, in combustible materials and coatings, and lighted cigarettes. However, similar to the Project, construction managers and personnel would be trained in emergency response and fire safety operations, which include the monitoring and management of life safety systems and facilities, such as those set forth in the safety and health regulations for construction established by OSHA.
Additionally, in accordance with the provisions established by OSHA for emergency response and fire safety operations, fire suppression equipment (e.g., fire extinguishers) specific to construction would be maintained on-site. Construction of the related projects would also occur in compliance with applicable federal, state, and local requ irements concerning the handling, disposal, use, storage, and management of hazardous materials.
In the event that Project construction occurs concurrently with related projects in the local vicinity of the Project Site, specific coordination among these multiple construction sites would be required and implemented through the Project’s Construction Management Plan (refer to Project Design Feature TRAF-PDF-1), which would ensure that emergency access and traffic flow are maintained on adjacent rights-of-ways. Since the Project would not require substantial narrowing of adjacent public rights -of-ways th at may be hazardous to roadway travelers, the Project would not have significant impacts on access and safety. Each related project would implement similar design features during construction and would be subject to the applicable lead agency’s routine construction permitting process. Furthermore, construction-related traffic generated by the Project and related projects would not significantly impact CCFD response times within the Project Site vicinity as drivers of fire and emergency vehicles have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes opposing traffic, pursuant to Section 21806 of the CVC. Finally, the Project in and of itself would not cause a significant impact to fire protection services during construction.
Operation
The total amount of development and associated population from the related projects located in the City are identified in Table 4.9-4, Related Projects Housing, Population and Employment, in Section 4.9, Population and Housing, of this Draft EIR. As indicated therein, the related projects in the City would generate an estimated daytime population of approximately 4,992 people (residents + employees), which, when combined with the net increase of approximately 606 people as part of the daytime population (733 Project residents + 20 Project employees – 147 existing employees) associated with the Project, would generate a cumulative daytime population of approximately 5,598 persons requiring fire protection service from the CCFD. With regard to the nighttime population, the Project and related projects would increase the 40,000 person existing nighttime population to approximately 42,539 (for an increase of approximately 2,539 persons). 29 As CCFD incident statistics are reported based on residential population (or nighttime population), applying the 2023 Citywide fire/EMS incident to population ratio of approximately 195 incidents
29 Includes 733 Project residents plus 1,806 residents from Culver City related projects.
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per 1,000 persons , the cumulative nighttime population would result in approximately 495 additional fire/EMS incidents per year requiring CCFD response.
The estimates provided above are conservative because the population generated from related projects would not all be net new residents and non-residents (i.e., these population projections do not take into account existing development and the associated existing resident and non-resident populations to be removed due to the development of the related projects). Additionally, the projections do not account for related projects that do not proceed beyond the application phase or ultimately are not built. The commercial-related projects would also be expected to provide on-site fire protection features, such as automatic sprinklers.
The development of the Project and the related projects may result in the need for increased staffing for existing facilities, additional fire protection facilities, and relocation of present fire protection facilities. With regard to facilities and equipment, similar to the Project, the related projects would be required to implement all applicable requirements regarding structural design, building materials, site access, fire -flow, storage and management of hazardous materials, and alarm and communications systems. Compliance with applicable CCMC requirements would ensure that adequate fire prevention features would be provided and reduce demand on CCFD facilities and equipment. As with the Project, other related projects may also include the installation of automatic fire sprinklers to enhance fire safety that would further reduce the demand placed on the CCFD facilities and equipment.
The Project, as well as the related projects, would also generate revenues to the City of Culver City (in the form of property taxes, sales revenue, etc.) that could be applied toward the provision of new fire station facilities and related staffing, as deemed appropriate by the City. Furthermore, over time, CCFD would continue to monitor population growth and land development throughout its jurisdiction and identify additional resource needs, including staffing, equipment, trucks and engines, ambulances, other special apparatuses, and possibly station expansions or new station construction, which may become necessary to achieve the required level of service.
In accordance with CCMC Section 9.02.040, all related projects within Culver City would be required to include installation of an automatic sprinkler system, regardless of area separation or type of construction. With regard to response distance, given that the related projects are generally located within an urban area, each of the related projects within the geographic scope would likewise be developed within urbanized locations serviced by one or more existing fire stations. As with the Project, the related projects would be required to comply with all applicable CCMC requirements regarding site access, including providing adequate emergency vehicle access. Compliance with applicable CCMC requirements would be demonstrated as part of a site plan review.
With regard to response times, the Project and related projects would introduce new uses that would generate additional traffic in the City of Culver City. Traffic from the Project and related projects has the potential to increase emergency vehicle response times due to travel time delays caused by the additional traffic. However, as with the Project, related projects are expected to include design features and mitigation measures, as applicable, that would serve to reduce traffic impacts.
Furthermore, as previously stated, emergency response vehicles can use a variety of options for
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dealing with traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Therefore, despite the cumulative increase in traffic, the Project and related projects would not significantly impair the CCFD from res ponding to emergencies at the Project Site or the surrounding area.
With regard to cumulative impacts on fire protection, consistent with City of Hayward v. Board Trustees of California State University (2015) 242 Cal.App.4th 833 ruling and the requirements stated in the California Constitution Article XIII, Section 35(a)(2), the obligation to provide adequate fire protection service is the responsibility of a City. Through the regular budgeting efforts for the City of Culver City, CCFD resource needs, including staffing, equipment, trucks and engines, ambulances, other special apparatuses and possibly station expansions or new station construction, would be identified and allocated according to the priorities at the time, as appropriate. At this time, CCFD has not identified that it will be constructing a new station in the area impacted by this Project due to projects in the service area. As discussed above, CCFD did indicate that it plans to add a third rescue ambulance (2 staff) at Fire Station 2 and to augment employees by 7 additional staff.
30 If CCFD determines that new facilities are necessary at some point in the future, such facilities (1) would occur where allowed under the designated land use, (2) would be expected to be located on parcels that are infill opportunities on lots that are typically between approximately 0.5 to 2 acres in size (such as the five stations identified as serving the Project Site), and (3) would likely qualify for a Categorical Exemption under CEQA Guidelines Section 15332 or Mitigated Negative Declaration and would not be expected to result in significant impacts. Further analysis, including a specific location for a new fire station or expansion or alteration of the existing fire stations which would service the Project Site and the related projects’ sites, would be speculative and, therefore, beyond the scope of this Draft EIR.
Conclusion
Based on the above, the Project's contribution to cumulative impacts associated with the provision of new or physically altered fire facilities, the construction of which would result in substantial adverse environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection would not be cumulatively considerable, and cumulative impacts would be less than significant.
Based on the above, the Project would not substantially contribute to cumulatively considerable impacts regarding fire protection. Therefore, cumulative 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 related to fire protection services would be less than significant.
30 Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, p. 29.
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4.10.2 Public Services – Police Protection
4.10.2.1 Introduction
This section addresses potential impacts on police services that could occur due to construction and operation of the Project. The analysis focuses on the Culver City Police Department (CCPD) facilities that currently serve the Project Site and the ability of the CCP D to provide police protection services to the Project. The analysis is based on information provided on October 12, 2023 in correspondence from the CCPD (CCPD Correspondence), included in Appendix H-2 of this Draft EIR . This analysis is also based on information provided on the CCPD’s website and from other published sources.
4.10.2.2 Environmental Setting
Regulatory Framework
This section provides a summary of State, regional, and local police protection regulations and policies applicable to the Project Site.
State
California Constitution Article XIII, Section 35
Section 35 of Article XIII of the California Constitution at subdivision (a)(2) provides: “The protection of public safety is the first responsibility of local government and local officials have an obligation to give priority to the provision of adequate public safety services.” Section 35 of Article XIII of the California Constitution was adopted by the voters in 1993 under Proposition 172.
Proposition 172 directed the proceeds of a 0.50-percent sales tax to be expended exclusively on local public safety services. California Government Code Sections 30051-30056 provide rules to implement Proposition 172. Section 30056 mandates that cities are not allowed to spend less of their own financial resources on their combined public safety services in any given year compared to the 1992-93 fiscal year. Therefore, an agency is required to use Proposition 172 to supplement its local funds used on police protection services, as well as other public safety services. In City of Hayward v. Board of Trustee of California State University (2015) 242 Cal. App. 4th 833, the court found that Section 35 of Article XIII of the California Constitution requires local agencies to provide public safety services, including police protection services, and that it is reasonable to conclude that the Ci ty will comply with that provision to ensure that public safety services are provided.
California Vehicle Code
Section 21806 of the California Vehicle Code (CVC) pertains to emergency vehicles responding to Code 3 incident/calls. This section of the CVC states the following:
Upon the immediate approach of an authorized emergency vehicle which is sounding a siren and which has at least one lighted lamp exhibiting red light that is visible, under normal atmospheric conditions, from a distance of 1,000 feet to the front of the vehicle, the surrounding traffic shall, except as otherwise directed by a traffic officer, do the following: (a)(1) Except as required under paragraph
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(2), the driver of every other vehicle shall yield the right -of-way and shall immediately drive to the right-hand edge or curb of the highway, clear any intersection, and thereupon shall stop and remain stopped until the authorized emergency vehicle has passed. (2) A person driving a vehicle in an exclusive or preferential use lane shall exit that lane immediately upon determining that the exit can be accomplished with reasonable safety...(c) All pedestrian upon the highway shall proceed to the nearest curb or place of safety and remain there until the authorized emergency vehicle has passed.
Regional
County of Los Angeles
The Office of Emergency Management (OEM), established by Chapter 2.68 of the County Code, is responsible for organizing and directing emergency preparedness efforts, as well as the day -to- day coordination efforts, for the County’s Emergency Management Orga nization. The OEM’s broad responsibilities include, among others, planning and coordination of emergency services on a County-wide basis.
The County of Los Angeles organizes a formal mutual aid agreement between all police departments within its jurisdiction to provide police personnel and resources to assist other member agencies during emergency and/or conditions of extreme peril. Formal mutual aid requests between police departments can be made under the purview of the Los Angeles County Sheriff’s Department (LASD); however, additional informal agreements may be made directly between the police agencies. The Mutual Aid Operations Plan provides a structure of response should an emergency arise which requires immediate response by more law enforcement personnel than would be available to CCPD using all other available resources.
Local
City of Culver City General Plan
The City’s General Plan does not identify any goals, objectives, policies, standards or guidelines specifically applicable to police protection for the Project.
City of Culver City Municipal Code
The Culver City Municipal Code (CCMC) contains the City’s regulations and ordinances, which include general and traffic regulations enforced by the appropriate City departments, including, but not limited to, the CCPD, the Community Development Department (Enforcement Services and Building Divisions) and the Public Works Department (Environmental Programs and Operations Division).
Sections of the CCMC applicable to police protection services at the Project Site include, but are not limited to, the following:
Section 9.08.385 (Authority to Close Streets): This section requires coordination with the Public Works Department to notify the Police and Fire Department prior to street closure for construction or repair work.
Section 17.540 (Site Plan Review) : T his section provides procedures and standards for the comprehensive review of proposed development projects to: ensure compliance with the
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required standards, design guidelines, and ordinances of the City; minimize potential adverse effects on surrounding properties and the environment; and protect the integrity and character of the residential, commercial and public areas of the City. As such, this section may require new projects to be reviewed by the CCPD to ensure that public safety and site security measures are incorporated.
Section 17.560 (Comprehensive Plans): This section provides procedures and standards for Comprehensive Plans, including required findings to ensure that the proposed development is capable of creating an environment of sustained desirability and stability and will not be substantially detrim ental to present and potential surrounding uses. As part of the Comprehensive Plan process, the Planning Department circulates project plans to other City departments for review and comment, including to the CCPD.
Section 17.300.040 (Outdoor Lighting):
This section requires that security lighting be provided at all building entrances and exits.
Section 11.04.030 (Suspension or Revocation of an Alarm Permit): This section allows the City to access services charges to property owners for each false alarm that results in a CCPD response in excess of three false alarms in a 12-month period.
Section 11.04.065 (Police Chief Discretion) : This
section states that the Chief of Police shall
have discretion to enforce rules, regulations, policies, procedures and directives necessary to implement the provisions of Chapter 11.04, Alarm Systems. Such powers shall include, but are not limited to , the power to promulgate, execute and enforce a policy regarding dispatch of police to alarm signals, as well as the discretion to discontinue police response to alarm signals due to the user's failure to comply with the provisions of Chapter 11.04, or to properly repair alarm systems deemed to constitute runaway alarms.
Existing Conditions
Police protection for the Project Site is provided by the CCPD. The CCPD is responsible for providing visible patrol, preliminary criminal investigations, follow -up investigations, traffic accident investigations, and specialized investigations of crimes such as identify theft, vice offenses, and similar crimes. The CCPD promotes community safety through deterrence and prevention of crime, apprehension of offenders, and education of the public in self -protective measures to minimize victimization. Additionally, the CCPD collaborates with regional partners and the LASD, when needed, for large scale police-related emergencies, and contracts with the South Bay Regional Public Communications Authority for dispatch services. 1 The CCPD is staffed with two full time K -9 units, an Emergency Response Team (ERT), and a Crisis Negotiation Team (CNT). In addition, the CCPD provides neighborhood and business watch programs to prevent criminal activities and offers a Citizens Police Academy designed to educate residents and local citizens on various aspects of law enforcement. Crime patterns are routinely analyzed and dispersed to patrol officers and special crime suppression units. Quarterly reports are prepared and made public that ide ntify quarterly statistics and information related to crime and arrests, staffing, parking and traffic citations and traffic collisions.2
1 Culver City Police Department (CCPD), Correspondence from Sergeant Carey Grant, Culver City Police Department Admin Sergeant, October 12, 2023. Provided in Appendix H-2 of this Draft EIR. 2 CCPD, 2023 Mid-Year Quarterly Report, https://www.culvercitypd.org/Office-of-the-Chief-of- Police/Transparency-Reports. Accessed October 17, 2023.
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The CCPD has approximately 109 sworn officers and 52 professional staff that serve an area of approximately five square miles with a residential (nighttime) population of approximately 40,000, and a daytime population of approximately 300,000 .3,4,5 The CCPD also has approximately 12 reserve police officers and 19 volunteers in patrol.6 Based on the number of sworn officers provided by CCPD correspondence, the City has an officer to daytime population ratio of approximately 1:2,752 and a nighttime officer to population ratio of 1:367.7 The CCPD is divided into five patrol districts with a minimum staffing of six police officers per shift. The most current average response time documented in the CCPD 2023 Mid-Year Quarterly Report was 3 minutes and 40 seconds for emergency calls and 9 minutes and 22 seconds for non- emergency calls.8
The City’s only CCPD station is located at 4040 Duquesne Avenue in Culver City on the northeast corner of Culver Boulevard and Duquesne Avenue, approximately 2.4 miles northeast of the Project Site. The Project Site is located within Patrol District 5, which covers the southern portion of the City, generally east of Interstate-405 and south of Slauson Avenue.9 Table 4.10.2-1, Culver City 2022 Crime Statistics, identifies crimes reported in the City in 202 2 (the latest annual crime statistics). The crime statistics are based on the National Incident -Based Report System (NIBRS). As of January 1, 2021, the Federal Bureau of Investigation (FBI) made the nationwide implementation of NIBRS a top priority to provide a more useful statistics to promote constructive discussion, measures, and informed policing.
As indicated in Table 4.1 0.2-1, a total of 3,793 crimes were reported in the City in 202 2. No homicides were reported in the city in 2022. It should be noted that in 2022, 2,146 (or approximately 56 percent) of the reported crimes were property crimes (burglary, larceny/theft, motor vehicle theft, and arson), compared to the 538 (or approximately 15 percent) reported violent crimes (assault, kidnapping, robbery, etc.) and 1,109 Other crimes (crimes such as vandalism, financial crimes, stolen property, drugs, weapons law violations, etc) . Based on these numbers, and based on a residential nightt ime population of approximately 40,000, the City has an existing nighttime annual crime rate of approximately 94.8 crimes per 1,000 residential population. Based on the City’s daytime population of 300,000 people, the City has an existing annual daytime crime rate of approximately 12.64 crimes per 1,000 population.
3 CCPD, Correspondence from Sergeant Carey Grant, Culver City Police Department Admin Sergeant, October 12, 2023. Provided in Appendix H-2 of this Draft EIR.
4 CCPD, About CCPD, https://www.culvercitypd.org/Office-of-the-Chief-of-Police/About-CCPD. Accessed October 17, 2023.
5 Daytime population is the number of people in a city during the day, including commuters and tourists. Nighttime population is the number of people who live in a city, typically residents. 6 CCPD, About CCPD, https://www.culvercitypd.org/Office-of-the-Chief-of-Police/About-CCPD. Accessed October 17, 2023.
7 The ratio was calculated by taking the 40,000 population and dividing by 109 sworn officers. 8 CCPD, 2023 Mid-Year Quarterly Report, https://www.culvercitypd.org/Office-of-the-Chief-of- Police/Transparency-Reports. Accessed October 17, 2023. 9 CCPD, Patrol, https://www.culvercitypd.org/Bureau-Information/Operations-Bureau/Patrol. Accessed October 17, 2023.
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TABLE 4.10.2-1
CULVER CITY 2022 CRIME STATISTICS
Crime Type Number
Percent of Culver
City Crimea
Murder 0 0%
Homicide 0 0%
Rape/Sexual Assault 26 1%
Aggravated Assault 144 4%
Simple Assault 243 7%
Kidnapping 11 <1%
Robbery 114 3%
Total Violent Crime 538 15%
Burglary 280 7%
Larceny/Theft 1,590 42%
Motor Vehicle Theft 264 7%
Arson 12 <1%
Total Property Crime 2,146 56%
Other Crimes 1,109 29%
Total 3,793
a Percentages are rounded.
b Other Crimes includes crimes such as vandalism, financial crimes, stolen property, drugs, weapons law violations.
SOURCE: CCPD, 2023 Mid-Year Quarterly Report.
4.10.2.3 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 impact associated with police protection if it would:
• POL-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection.
Methodology
The analysis of impacts on police protection addresses the Project’s effects on the ability of police personnel to adequately serve existing and future population in the Project vicinity, taking into consideration the Project’s security and/or design features intended to reduce the demand for police protection services and potential need for new or expanded police facilities. The analysis is based on correspondence with the CCPD, which is provided in Appendix H-2 of this Draft EIR.
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Additionally, the analysis below presents statistical data for the City, including the ratio of crimes to population and the ratio of sworn police officers to population. For the analysis provided below related to ratios of police officers to population served, the analysis conservatively assumes that the Project’s residents and employees would occupy the Project Site as part of the daytime population, while the nighttime population would consist of the residential population only. Based on information provided by CCPD and the associated analyses provided in this section of the Draft EIR, the findings regarding police services focus on whether the CCPD would require the addition of a new or physically altered facility to maintain acceptable service levels, the construction of which could result in a potentially significant environmental impact.
The need for or deficiency in adequate police protection services in and of itself is not a CEQA impact, but rather a social and/or economic impact. Where a project causes a need for additional police protection services resulting in the need to construct new facilities or additions to existing facilities, and the construction results in a potential impact to the environment, then the impact would need to be assessed in this EIR. The ultimate determination of whether there is a significant impact to the environment related to police protection services result ing from a project is determined by whether the construction of new or expanded police facilities is a reasonably foreseeable direct or indirect effect of the project.
Based on input received of CCPD, there are no current capital improvement plans for the construction or expansion of police facilities in the local vicinity of the Project Site in the City .
Based on historical development of police facilities, it is assumed that in the event the City determines that expanded or new emergency facilities are warranted, such facilities (1) would occur where allowed under the designated land use, (2) would be located on parcels that are infill opportunities on lots that are between 0.5 and 1 acre in size, and (3) could qualify for a categorical exemption or Mitigated Negative Declaration under CEQA Guidelines Section 15332.
Project Design Features
Refer to Project Design Feature TRAF -PDF-1 (Construction Management Plan) in Section 4.11 , Transportation, of this Draft EIR. In addition, the following project design feature related to police protection services during Project construction will be implemented as part of the Project:
POL-PDF-1 (Project Site Security and Access During Construction): During construction of the Project, the Project Site will be fenced and gated with surveillance cameras to monitor the site during off hours.
POL-PDF-2 (Project Site Security and Access During Operation): During operation of the Project, access to the parking structure will be controlled through gated entries, and the entry areas will be well illuminated. Project Site security would include controlled keycard access to office spaces, security lighting within common areas and entryways, and closed- circuit TV monitoring (CCTV).
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Analysis of Project Impacts
Threshold POL-1: The Project would have a significant impact on police protection if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, resp onse times or other performance objectives for police protection.
Impact Analysis
Construction
During construction, equipment, building materials, vehicles, and temporary offices, would be temporarily located on the Project Site, which could be subject to theft or vandalism. Therefore, when not properly secured, construction sites can become a distraction for local law enforcement from more pressing matters that require their attention. This could result in an increase in demand for police protection services.
As detailed in Project Design Feature POL -PDF-1, during construction of the Project, the Project Site would be fenced and gated with surveillance cameras to monitor the site during off hours, thereby reducing the potential need for police protection services from CC PD in order to avoid potential theft. Security measures would ensure that valuable materials (e.g., building supplies and metals, such as copper wiring), as well as construction equipment, are not easily stolen or vandalized. The specific type and combination of construction site security features would depend on the phase of construction. Implementation of these security features would minimize the Project’s potential need for police protection services during the building construction phase.
Police vehicles can use a variety of options for dealing with traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Although minor traffic delays due to temporary lane closures needed to facilitate specific con struction activities could occur, particularly during the construction of utilities and street improvements, impacts to police protection services would be considered less than significant for the following reasons:
1. Emergency access would be maintained to the Project Site during construction through marked emergency access points approved by CCPD;
2. Construction impacts are temporary in nature and do not cause lasting effects; and
3. Partial lane closures, if determined to be necessary, would not significantly affect emergency vehicles, the drivers of which normally have a variety of options for avoiding traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic, in accordance with Section 21806 of the CVC. Furthermore, within the City, the Project Site would adhere to CCMC Section 9.08.385, which requires coordination with the Public Works Department to notify the Police and Fire Department prior to street closure for construction or repair work. Additionally, if there are partial closures to streets surrounding the Project Site, flagmen would be used to facilitate the traffic flow until such temporary street closures are complete.
A Construction Traffic Management Plan (CMP), subject to review and approval by the City would be incorporated into the Project as provided in Project Design Feature TRAF -PDF-1. The CMP
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would include street closure information, detour plans, haul routes, and staging plans and would formalize how construction would be carried out and identify specific actions that would be required to reduce effects on the surrounding community. The CMP would also require that review and approval of any proposed lane closures include coordination with the fire and p olice departments of each city to minimize potential effects on traffic flow and emergency response.
Any potential CCPD officers needed to patrol the Project Site would be existing officers at the CCPD police station. It is not anticipated that any additional officers from CCPD would be needed to monitor the Project Site during construction outside of the existing officers that patrol the area.
Additionally, the various safety and control features that would be implemented during Project construction would reduce the potential for incidents that would require police responses.
Based on the above, Project construction would not result in substantial adverse physical impacts associated with the provision of new or physically-altered government facilities, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection. Therefore, impacts to police protection during Project construction would be less than significant.
Operation
Operational activities associated with the Project would increase demand for police protection services. As discussed in Section 4.9, Population and Housing, the Project’s 309 residential units and 5,600 sf of retail use is anticipated to result in 733 residents and 20 employees, or 753 total persons. The existing office use on the Project Site employs approximately 147 people, and the overall anticipated net increase of 606 people would represent an approximately 0.2 percent increase
10 in the existing daytime population of the City (approximately 300,000), while the anticipated added nighttime population of 733 residents would be an approximately 1.8 percent increase11 in the existing nighttime population (approximately 40,000) of the City.
As discussed above, the Project Site would be served by CCPD, which has 109 sworn officers serving the daytime and nighttime populations. CCPD currently has an officer to daytime population ratio of approximately 1:2,752 and a nighttime officer to population ratio of 1:367. The anticipated net daytime increase in population of 606 people would reduce the existing officer to daytime population ratio of 1:2,752 to 1:2,758
12, and would reduce the existing officer to nighttime
population ratio of 1:367 to 1:3 74.13 The potential for an increase in officer to daytime and nighttime population ratios would represent increases of 0.2 and 1.9 percent, respectively. If it were determined that additional officers would be needed to maintain existing service ratios, the Project contribution would, without accounting for security features, generate an increase in demand for
10 606 new population/existing daytime population 300,000 = 0.002, or 0.2 percent increase in daytime population. 11 733 new residential population/existing nighttime population 40,000 = 0.018, or 1.8 percent increase in nighttime population.
12 300,000 existing daytime population + 606 new population = 300,606 new daytime population. The new 300,606 population/109 existing officers = one officer per 2,758 population. 13 40,000 existing nighttime population + 733 new population = 40,733 new nighttime population. The new 40,733 population/109 existing officers = one officer per 374 population.
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0.2 additional CCPD sworn officers for the daytime population, and two additional CCPD sworn officers for the nighttime population, an increase of 0.2 percent and 2.0 percent, respectively.14,15 According to the CCPD, while staffing changes of up to two officers may be required as a result of the Project, no new or expanded police facilities would be needed as a result of Project implementation.
16 Moreover, the Project’s operational demand for CCPD police protection services would be reduced as the result of the proposed security features set forth in Project Design Feature POL-PDF-2, as described further above . Implementation of these security features would help reduce the potential for on-site crimes, including loitering, theft, and burglaries, and would reduce demand for CCPD services.
In addition, the Project would contribute revenue to the General Fund for the City which could fund CCPD expenditures as necessary to offset the cumulative incremental impact on police services.
Through this process, CCPD would be able to provide adequate facilities to accommodate future growth and maintain acceptable levels of service. Additional increased demands for CCPD staffing, equipment, and facilities would be funded via existing mechanisms (e.g., property taxes and government funding), to which both the Project would contribute.
Lastly, given the (1) limited increases in demand for police services expected to be generated by the Project, (2) reduced demand for police services as the result of project design features, and (3) CCPD patrols in the local Project vicinity available to serve the Project Site, CCPD emergency response times are not expected to materially change under the Project. Although the Project would add traffic to surrounding roadways, CCPD has indicated that responses to calls to the Project Site is expected to remain within the current range of emergency response times. 17 Further, emergency
response to a site is routinely facilitated, particularly for high priority calls, through use of sirens to clear a path of travel, driving in the lanes of opposing traffic, use of alternate routes, and multiple station response. Emergency access to the Project Site and surrounding uses would be maintained at all times , and emergency vehicles would have priority and the ability to bypass signals and stopped traffic. Thus, Project-related traffic is not anticipated to impair the CCPD from responding to emergencies at the Project Site or the surrounding area. Accordingly, Project operational impacts associated with emergency response times and emergency access would be less than significant.
Based on the above analysis and with implementation of Project Design Feature POL -PDF-2, development of the Project is not anticipated to generate a demand for additional police protection services that could exceed the CCPD’s capacity to serve the Project Site. Project operation would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities, the construction of which would cause significant environmental impacts, in order to maintain acceptabl e service ratios, response times or other performance
14 606 new population X (one officer per 2,758 population) = 0.2 additional officers. (0.2 additional officers / 109 existing officers) X 100 = 0.2 percent increase in sworn officers. 15 733 new population X (one officer per 372 population) = 2 additional officers. (2 additional officers / 109 existing officers) X 100 = 2.0 percent increase in sworn officers. 16 CCPD , Correspondence from Sergeant Carey Grant, Culver City Police Department Admin Sergeant, October 12, 2023. Provided in Appendix H-2 of this Draft EIR.
17 CCPD , Correspondence from Sergeant Carey Grant, Culver City Police Department Admin Sergeant, October 12, 2023. Provided in Appendix H-2 of this Draft EIR.
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objectives for police protection. Therefore, impacts to police protection during Project operation would be less than significant.
Mitigation Measures
Impacts regarding police protection services would be less than significant. Therefore, no mitigation measures are required.
Level of Significance After Mitigation
Impacts regarding police protection services 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.
Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR, identifies 12 related projects that are anticipated to be developed within a 1 -mile radius of the Project Site. These projects are summarized in Table 3-1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3. As shown in Table 3-1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles. Of these related projects, eight occur within Culver City and, like the Project, would create a demand for police protection service from the CCPD.
Construction
In general, impacts to CCPD services and facilities during the construction of each related project would be addressed as part of each project’s respective environmental review process conducted by respective city. Similar to the Project, each related project would be required to implement a construction traffic management plan to ensure that adequate emergency access to the property and neighboring properties is maintained. Related projects would also be required to implement similar security measures as under the Project to limit access to construction areas, such as installing construction fencing and gating and including security lighting. The specific type and combination of construction site security features would depend on the phase and duration of construction. The related projects would need to coordinate emergency accessibility with CCPD to their respective sites to ensure that emergency access would be maintained through temporary lane closures or marked emergency access points. Construction -related traffic generated by the Project and related projects would not substantially adversely affect CCPD service in the Project vicinity as drivers of police and emergency vehicles normally have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic.
Operation
The total amount of development and associated population from the related projects located in the City are identified in Table 4.9-4, Related Projects Housing, Population and Employment, in Section 4.9, Population and Housing, of this Draft EIR. As indicated therein, the related projects in the City would generate an estimated daytime population of approximately 4,992 people (residents + employees), which, when combined with the net increase of 606 population associated with the Project, would generate a cumulative daytime population of 5,598 persons requiring police
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protection service from the CCPD. With regard to the nighttime population, the Project and related projects would increase the 40,000 person existing nighttime population to 42,53918.
The cumulative increase in daytime population of 5,598 people would reduce the existing officer to daytime population ratio of 1:2,752 to 1:2,804.19 The increase in residential population of 2,539 people (1,806 cumulative residential population plus 733 from the Project ) would reduce the existing officer to nighttime population ratio of 1: 367 to 1:390 .20 Applying the existing sworn police officer to daytime population ratio in the City of 1:2,752, this cumulative population would create a demand for approximately two additional CCPD sworn officers, an increase of 1.8 percent.21 Applying the existing sworn police officer to the nighttime population ratio in the City of 1:367, this cumulative population would create a demand for approximately seven additional CCPD sworn officers, an increase of 6.4 percent.22
The estimates provided above are conservative because the population generated from related projects would not all be net new residents and non-residents (i.e., these population projections do not take into account existing development and the associated existing resident and non-resident populations to be removed due to the development of the related projects). Additionally, the projections do not account for related projects that do not proceed beyond the application phase or ultimately are not built. The projections also do not consider the potential reduction in criminal activity that is likely to occur as a result of development of the related projects, which include residential, commercial, office, school, and other uses, as the related projects would seek to activate their frontages and increase the amount of activity around their respective sites. The commercial - related projects would also be expected to provide on-site security, personnel and/or design features for their visitors and patrons.
With regard to response times, the Project and related projects would introduce new uses that would generate additional traffic in the Project area. Traffic from the Project and related projects has the potential to increase emergency vehicle response times due to travel time delays caused by the additional traffic. However, related projects are anticipated to include adequate security features similar to the security features of the Project, plus any required mitigation measures that would serve to reduce cumulative impacts to police protection service, if appropriate. Furthermore, as previously stated, emergency response vehicles can use a variety of options for dealing with traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic, in accordance with Section 21806 of the CVC. Therefore, despite the cumulative increase in traffic, the Project and related projects would not significantly impair the CCPD from responding to emergencies at the Project Site or the surrounding area.
18 Includes 722 Project residents plus 1,806 residents from Culver City related projects. 19 300,000 existing daytime population + 5,598 new population = 305,598 population/109 existing officers = one officer per 2,804 population.
20 40,000 nighttime existing population + 2,539 new population = 42,539 new population. The new 42,539 population/109 existing officers = one officer per 390 population. 21 5,598 new population X (one officer per 2,752 population) = 2 additional officers. (2 additional officers / 109 existing officers) X 100 = 1.8 percent increase in sworn officers. 22 2,539 new population X (one officer per 367 population) = 7 additional officers. (7 additional officers / 109 existing officers) X 100 = 6.4 percent increase in sworn officers.
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Additionally, the Project and the related projects would contribute revenue to the General Fund for the City which could fund CCPD expenditures as necessary to offset the cumulative incremental impact on police services. Through this process, CCPD would be able to provide adequate facilities to accommodate future growth and maintain acceptable levels of service. Additional increased demands for CCPD staffing, equipment, and facilities would be funded via existing mechanisms (e.g., property taxes and government funding), to which both the Project and related projects would contribute.
With regard to cumulative impacts on police protection, consistent with City of Hayward v. Board Trustees of California State University (2015) 242 Cal.App.4th 833 ruling and the requirements stated in the California Constitution Article XIII, Section 35(a)(2), the obligation to provide adequate police protection services is the responsibility of the City. Through the regular budgeting efforts of the City, police department resource needs and possibly an expansion of the existing station or new station construction, would be identified and allocated according to the priorities at the time. At this time, CCPD has not identified that it will be constructing a new station in the area impacted by this Project due to projects in the service area. If CCPD determines that new facilities are necessary at some point in the future, such facilities (1) would occur where allowed under the designated land use, (2) would be located on parcels that are infill opportunities on lots that are typically between 0.5 and one acre in size, and (3) could qualify for a categorical exemption under CEQA Guidelines Section 15332 or Mitigated Negative Declaration and would not be expected to result in significant impacts. Further analysis, including a specific location, would be speculat ive and beyond the scope of this document. As such, cumulative impacts on police protection services would be less than significant.
Conclusion
Based on the above, the Project's contribution to impacts associated with the provision of new or physically altered police facilities, the construction of which would result in substantial adverse environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection would not be cumulatively considerable, and cumulative 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 related to population and housing would be less than significant.
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4.10.3 Public Services – Schools
4.10.3.1 Introduction
This section addresses whether new or physically altered school facilities would be required to provide school services to the Project, the construction of which could cause significant environmental impacts. The analysis estimates the number of students that would be generated by the Project and addresses whether Culver City Unified School District (CC USD) school facilities would have sufficient capacity to accommodate these students. The analysis is based, in part, on written correspondence with CCUSD dated October 12, 2023, which is included in Appendix H-3 of this Draft EIR.
4.10.3.2 Environmental Setting
Regulatory Framework
State
California Education Code
Educational services and school facilities for the Project are subject to the rules and regulations of the California Education Code, the California Department of Education (CDE) and governance of the State Board of Education (SBE) (Gov. Code Section 33000, et seq.). The CDE is the government agency responsible for public education throughout the state. With the State Superintendent of Public Instruction, the CDE is responsible for enforcing education law and regulations and for continuing to reform and improve public elementary school, secondary school, childcare programs, adult education, and preschool programs. The CDE oversees funding, student testing, and achievement levels for all state schools. A sector of the CDE, the SBE is the 11-member governing and policymaking body of the CDE that sets Kindergarten through 12th Grade (K –12) education policy in the areas of standards, instructional materials, assessment, and accountability. The State also provides funding through a combination of sales and income taxes. In addition, pursuant to Proposition 98, the State is also responsible for the allocation of educational funds that are acquired from property taxes. Further, the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities. 1 Senate Bill 50
The Leroy F. Greene School Facilities Act of 1998 (known as the Greene Act), enacted in 1998, is a program for funding school facilities largely based on matching funds. For new school construction, grants provide funding on a 50/50 State and local match basis. For school modernization, grants provide funding on a 60/40 State and local match basis. Districts that are unable to provide some, or all, of the local match requirement and are able to meet the financial hardship provisions may be eligible for additional State funding. 2 1 California Education Code Section 17620(a)(1).
2 State of California, Office of Public School Construction, School Facility Program Guide, October 24, 2012.
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The Greene Act permits the local district to levy a fee, charge, dedication, or other requirement against any development project within its boundaries, for the purpose of funding the construction or reconstruction of school facilities. The Act also sets a maximum level of fees a developer may be required to pay. Pursuant to Government Code Section 65996, the payment of these fees by a developer serves to mitigate all potential impacts on school facilities that may result from implementation of a project to a less-than-significant level. 3 Open Enrollment Policy
The Open Enrollment Policy is a state-mandated policy that enables students located in the CCUSD to apply to any regular, grade-appropriate CCUSD school with designated “open enrollment” seats.
Open enrollment seats are granted through an application process that is completed before the school year begins. Under the Open Enrollment Policy, students living in a particular school’s attendance area are not displaced by a student requesting an open enrollment transfer to that school. 4 Class Size Reduction Kindergarten–University Public Education Facilities Bond Act of 1998
Proposition 1A, the Class Size Reduction Kindergarten –University Public Education Facilities Bond Act of 1998 (Ed. Code, Section 100400– 100405) is a school construction funding measure that was approved by the voters on the November 3, 1998 ballot. This Act created the School Facility Program where eligible school districts may obtain state bond funds.
Regional
CCUSD Facilities Master Plan
CCUSD adopted its Facilities Master Plan in 2014, which outlined planned improvements to school facilities throughout its campuses. These changes were designed to increase student safety and health, familiarize students with the use of technology, and faci litate student learning and engagement. Planned improvements include asbestos and hazardous materials removal, exterior/site illumination improvements, fire alarm upgrades, security system installation, construction of shade structures, seismic retrofittin g of existing structures, and installation of technology/telecom systems and electrical infrastructure. Overall, the cost of improvements to all CCUSD facilities identified in the Facilities Master Plan, along with construction contingencies, cost escalations, general conditions, liability, and design costs was estimated at $165,300,161. 5 The
CCUSD is currently in the process of developing an updated Facility Master Plan.6
3 California Government Code Section 65996 and 65997.
4 California Education Code Sections 48350, et seq.
5 Culver City Unified School District, 2014. Facilities Master Plan. https://www.ccusd.org/CapitalProjects/CCUSD_Facilities_Master_Plan.pdf. Accessed November 2023. 6 Culver City Unified School District, 2023. Culver City USD Future-Ready Facilities Plan. https://www.ccusdfutureready.org/. Accessed November 2023.
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Local
City of Culver City General Plan
The City’s General Plan does not identify any goals, objectives, policies, standards or guidelines specifically applicable to schools for the Project.
Existing Conditions
The city is served by CCUSD, which offers public school programs from preschool and K -12, as well as adult education courses. CCUSD is comprised of five elementary schools, one middle school, one high school, one independent learning academy, and one adult education school.7 Each of the five elementary schools funnel students into Culver City Middle School for sixth grade through eighth grade, which then leads to enrollment in Culver City High School for ninth grade through twelfth grade. An alternative independent study program is available for students in grades K-12 through iAcademy (CCUSD iAcademy).
According to correspondence with CCUSD, three schools would serve the Project Site, including El Rincon Elementary School, Culver City Middle School, and Culver City High School. 8 Student
enrollment for the 2023-2024 school year for these schools is shown in Table 4.10.3-1, Enrollment of CCUSD Schools Serving the Project Site. Per correspondence with CCUSD , CCUSD does not have school capacity information available, but indicated that each of the three schools are already at or just below capacity (see Appendix H-3).
TABLE 4.10.3-1
ENROLLMENT OF CCUSD SCHOOLS SERVING THE PROJECT SITE
School Campus 2023-2024 Existing Enrollment
El Rincon Elementary School 561
Culver City Middle School 1,557
Culver City High School 2,151
Total Enrollment 4,269
SOURCE: Correspondence with CCUSD, October 2023. Included as Appendix H-3.
4.10.3.3 Environmental Impacts
Thresholds of Significance
The following threshold of significance is based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in a significant impact associated with school facilities if it would:
• SCHOOL-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered
7 Culver City Unified School District. 2023. Our Schools. https://www.ccusd.org/. Accessed November 2023. 8 CCUSD , Correspondence from Mike Reynolds, Interim Assistant Superintendent, October 12, 2023. Provided in Appendix H-3 of this Draft EIR.
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governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for school facilities.
Methodology
The analysis of enrollment effects on schools is based in part on the ability of CCUSD school facilities and services to accommodate the potential increase in students generated from development of the Project. The student generation for the proposed multi -family residential is based on the rate provided by the CCUSD in its Level I Developer Fess Study for Culver City School District (March 2020), and considers whether CCUSD school facilities that serve the Project Site would have sufficient available capacity to accommodate these students at the time of Project buildout. The analysis addresses three levels of education facilities operated by CCUSD (i.e., elementary, middle, and high schools), and is centered on those schools that serve the Project Site. It also considers state regulations (i.e., SB 50) and development fees as a mechanism for providing school facilities and addressing school impacts of the Project.
Project Design Features
No specific Project Design Features are proposed with regard to schools.
Analysis of Project Impacts
Threshold SCHOOL-1: The Project would have a significant impact on schools if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for schools.
Impact Analysis
Construction
Construction of the Project would require employees who are anticipated to be hired from a mobile regional construction work force that moves from project to project. Typically, construction workers pass through various development projects on an intermittent basis as their particular trades are required. Given the mobility and temporary durations of work at a particular site, and a large construction labor pool that can be drawn upon in the region, construction employees would not be expected to relocate r esidences (and, therefore, a student population) within this region or move from other regions as a result of their temporary work on the Project Site. Therefore, Project construction would not result in a notable increase in the resident population or generate new students needing to attend local schools.
There are no public schools located in the immediate Project vicinity that would be affected by construction activities at the Project Site. The nearest CCUSD school, El Rincon Elementary School, is located approximately 0.7 mile northwest of the Project Site. There would be no Project- related construction staging or road closures at or adjacent to this or any other school. Therefore, construction activities would not adversely affect the operations of nearby schools.
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Project construction would not result in substantial adverse physical impacts associated with the provision of new or physically altered schools, the construction of which would cause significant environmental impacts. Therefore, the Project’s construction impacts on schools would be less than significant.
Operation
The Project would develop a mixed -use development with residential and retail uses. As detailed within Chapter 4.9, Population and Housing, the Project would increase the residential population of Culver City by introducing 309 residential units that would generate an estimated population of 733 residents at the Project Site. According CCUSD’s Level I Developer Fess Study for Culver City School District, residential uses generate an average of 0.513 students per residence. Based on this generation rate, the number of students that could be generated by the Project is illustrated in Table 4.10.3-2, Estimated Number of Students Generated by the Project . As shown, the Project could generate an estimated 87 elementary school students, 25 middle school students, and 50 high school students for a total net increase of approximately 162 school students. The Level I Developer Fess Study for Culver City School District does not include a student generation factor for non- residential uses. Because the Project would include a relatively small amount of retail (5,600 sf) and corresponding number of employees (20), the Project’s employees would contribute a negligible number of students to area schools. Furthermore, it can be expected that the Project’s retail employees likely live in the local area, and the incremental number of associated students presumably already attend local schools. Regardless, any incremental increase in students would be more than offset by the existing office employees student generation, thus, the analysis of students generated by the Project is conservative in this regard.
TABLE 4.10.3-2
ESTIMATED NUMBER OF STUDENTS GENERATED BY THE PROJECT
Land Use Use
Generation
Factora, b
Elementary
School
Students
Middle
School
Students
High
School
Students Totalc
Proposed Project
Residential Multi-Family 309 units Elm: 0.28/unit
MS: 0.08/unit
HS: 0.16/unit
87 25 50 162
NOTES: ksf = 1,000 square feet
a Student generation rates for residential uses are based on a rate of 0.513 students per residence as stated in CCUSD’s Level I Developer Fess Study for Culver City School District, March 2022, P. 9. The student generation rate is multiplied by the grade level assumptions below to calculate the generation factor for elementary, middle and high school students. b Since the Developer Fee Study does not specify grade levels for the residential land uses, the students generated by the residential uses are assumed to be divided among the elementary school, middle school, and high school levels as follows: 55 percent elementary school, 15 percent middle school, and 30 percent high school. c Input totals for elementary, middle and high schools have been conservatively rounded up based on generation factors to equal total number of students.
SOURCE: ESA, 2024.
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This analysis is conservative in that it assumes that none of the future Project residents with families would already have students attending the schools that serve the Project Site. Furthermore, there is potential that a portion of the Project’s school -aged children could attend non-CCUSD schools (e.g., private or charter schools), thus reducing attendance at CCUSD schools. For these reasons, the above analysis is considered conservative and likely overestimates the Project’s actual potential to generate new students.
The projected 162 students generated by the Project would be added to the total number of students currently enrolled at CCUSD schools serving the Project Site (Table 4.10.3-1). With implementation of the Project, El Rincon Elementary School would serve 648 students, Culver City Middle School would serve 1,582 students, and Culver City High School would serve 2,201 students, for a total enrollment of 4,431 students (compared to 4,269 students currently enrolled).
Per correspondence with CCUSD, CCUSD does not have school capacity information available, but indicated that each of the three schools are already at or just below capacity. 9 Therefore, it is
conservatively assumed that the Project has the potential to result in a new seating shortage at all three schools.
As previously discussed, Project-related student generation is likely to be less than estimated in the above analysis. Additionally, CCUSD continually monitors enrollment numbers at all schools within the District. Seating shortages can be addressed through changes in attendance boundaries and new/expanded school facilities. Additionally, because actual enrollment is based on the number of students enrolled, whether they live inside or outside of the attendance boundary, actual enrollment tends to run lower than the resident enrollment, which is used in the projections above and is based on the number of students living in a school’s attendance area. Nonetheless, based on the above, Project implementation could require new or expanded school facilities. Because the location and operational characteristics of any new or expanded school facilities have not yet been identified by CCUSD to specifically serve the Project, it would be speculative to determine how school capacity shortages would be addressed, including where and what type of expanded or new facilities might be provided. Therefore, at such time as the need for expanded or new school facilities are identified by CCUSD, the environmental impacts associated with construction of those facilities would be evaluated by CCUSD under CEQA as a project independent of the Project.
Pursuant to SB 50, the Project Applicant would be required to pay development fees for schools to CCUSD prior to issuance of building permits. Under Government Code section 65995 and 65996, the payment of these fees is considered full and complete mitigation of Project -related school impacts including any school -related consideration relating to a school district’s ability to accommodate enrollment. Therefore, under state law, payment of the applicable development school fees to CCUSD would offset the potential impact of additional student enrollment at schools serving the Project Site.
9 CCUSD , Correspondence from Mike Reynolds, Interim Assistant Superintendent, October 12, 2023. Provided in Appendix H-3 of this Draft EIR.
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Project operation would not result in substantial adverse physical impacts associated with the provision of new or physically altered schools, the construction of which would cause significant environmental impacts. Therefore, operational impacts on schools 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 not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to ma intain acceptable service ratios or other performance objectives for schools. Impacts would be less than significant without mitigation.
Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR, identifies 12 related projects that are anticipated to be developed within a 1 -mile radius of the Project Site. These projects are summarized in Table 3-1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3. As shown in Table 3-1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles. Of these related projects, eight occur within Culver City and, like the Project, would create a demand for CCUSD schools.
To provide a conservative analysis of impacts, students generated by the related projects are added to the schools serving the Project Site, recognizing that students of some related projects would potentially attend other CCUSD schools.
No schools are in the immediate vicinity of the related projects , and would not be aff ected by construction of those projects. Nevertheless, each of the related projects would be required to consult with CCUSD to ensure that their respective construction activities or road/sidewalk closures and detours would not affect routes to schools or other operational aspects of nearby schools. Furthermore, these schools are located at a distance from the Project Site such that the Project would not contribute to a cumulative impact associated with those schools.
Similar to the Project, the number of students anticipated to be generated by the related projects is based on the type of development proposed. The related projects, not including the Project, would provide approximately 762 residential units and generate approximately 3,186 employees.
Table 4.10.3-3, Cumulative Student Generation, shows the number of students projected to be generated by the related projects, which are added to the number of students generated by the Project. As shown in Table 4.10.3-3, the Project in combination with related projects would potentially generate an estimated 604 elementary school students, 169 middle school students, and 337 high school students for a total of approximately 1,110 students.
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TABLE 4.10.3-3
CUMULATIVE STUDENT GENERATION
Land Use Amount a Generation Factor b, c
Elementary
School
Students
Middle
School
Students
High
School
Students Total
City of Culver City Related Projects
Residential 762 units Elm: 0.28/unit
MS: 0.08/unit
HS: 0.16/unit
214 61 122 397
Employees 3,186 employees 0.1724 students/emp 303 83 165 551 Total Students Generated by Culver City Related Projects 517 144 287 948 Project Students 87 25 50 162
Total Increase (Related Projects + Project) 604 169 337 1,110 NOTES:
a Related projects residential units and employee totals from Table 4.9-4, Total Cumulative Development, in Section 4.9, Population and Housing, of this Draft EIR.
b Student generation rates for residential uses are based on a rate of 0.513 students per residence as stated in CCUSD’s Level I Developer Fess Study for Culver City School District, March 2022, P. 9. The student generation rate is multiplied by the grade level assumptions below to calculate the generation factor for elementary, middle and high school students. c CCUSD’s Level I Developer Fess Study for Culver City School District, does not include student generation rates for non-residential uses. Thus, for the non-residential uses, the total number of employees from the related projects are used to calculate the number of students based on factors included in Table 15 of the Los Angeles Unified School District (LAUSD) 2022 Developer Fee Justification Study (March 2022). The LAUSD study identifies a student per employee rate of 0.1724 for all commercial and industrial land uses. Thus, this rate was applied to the non-residential related project land uses. Since the LAUSD Developer Fee Justification Study does not specify which grade levels students fall within for non-residential land uses, the students generated by the non-residential uses are assumed to be divided among the elementary school, middle school, and high school levels at the same distribution ratio observed for the residential generation factors (i.e., approximately 55 percent elementary school, 15 percent middle school, and 30 percent high school).
SOURCE: ESA, 2023
As shown in the Project level analysis above, per CCUSD, the three schools serving the Project are already at or just below capacity, and thus the Project has potential to contribute to a projected shortage of seats at El Rincon Elementary School, Culver City Middle School, and Culver City High School. Thus, the addition of students by the related projects would further the potential seating shortages at these schools.
Based on the analysis, the Project, in combination with the related projects, could require new or expanded school facilities. However, as exemplified by the CCUSD Facilities Master Plan, CCUSD continually monitors enrollment numbers at all schools within the District and seating shortages can be addressed through changes in attendance boundaries and new/expanded school facilities.
Provided that the location and operational characteristics of any new or expanded school facilities have not yet been identified by CCUSD to specifically serve the Project and the related projects, it would be speculative to determine how school capacity shortages would be addressed, including where and what type of expanded or new facilities may be provided. Therefore, at such time as the need for expanded or new school facilities are identified by CCUSD, the environmental impacts associated with construction of those facilities would be evaluated by CCUSD under CEQA as a project independent of the Project.
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Similar to the Project, the projected student population increase from related projects is likely to be conservative and overstated. As with the Project, projected student generation is likely to be less than estimated in the above analysis, as it assumes that none of the future residents or employees with families would already have students attending the schools listed above. A portion of the school-aged children could attend other non-CCUSD schools (e.g., private or charter schools), thus reducing attendance at CCUSD schools. This analysis also does not take into account projects that may not be constructed and occupied within the timeframe analyzed, projects that may be reduced in size, or demolition of existing housing or uses to accommodate the planned new devel opment.
For these reasons, the above analysis is considered conservative and likely overestimates the related projects’ actual potential to generate new students.
As with the Project, pursuant to Government Code Section 65995, all related projects would be required to pay developer fees under the provisions of SB 50 to address the impacts of new developments on school facilities. Payment of such fees is intended for the general purpose of addressing the construction of new school facilities, whether schools serving the Project in question are at capacity or not. Pursuant to Section 65995(h) of the California Government Code, payment of such fees is deemed full mitigation of a project’s development impacts. Therefore, with the payment of the developer fees under the provisions of SB 50, the Project and related projects would not result in a substantial adverse physical impact associated with the provision of new or physically altered government facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for schools.
Therefore, the cumulative impacts would be less than significant.
Mitigation Measures
Cumulative impacts regarding schools were determined to be less than significant. Therefore, no mitigation measures are required.
Level of Significance After Mitigation
Not applicable. Cumulative impacts to schools would be less than significant.
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4.10.4 Public Services – Parks and Recreation
4.10.4.1 Introduction
This section addresses potential impacts of the Project on public parks and recreational facilities.
The analysis focuses on physical impacts associated with the provision of new or altered facilities, the construction of which could cause significant environmental impacts and the physical deterioration of existing parks from new Project demands. The analysis is based on information provided in correspondence from the Culver City Parks, Recreation and Community Services (PRCS) Department on October 16, 2023, included in Appendix H-4 of this Draft EIR. This analysis is also based on information provided on the PRCS website and from other published sources.
4.10.4.2 Environmental Setting
Regulatory Framework
State
Quimby Act
California Government Code Section 66477, also known as the Quimby Act, was enacted by the California legislature in 1965. The Quimby Act authorizes cities and counties to enact ordinances requiring the dedication of land, or the payment of fees for park and/or recreational facilities in lieu thereof, or both, by developers of residential subdivisions as a condition to the approval of a tentative tract map or parcel map. As discussed below, the City implemented the Quimby Act in the City through the adoption of Culver City Municipal Code (CCMC) Chapters 15.01 and 15.06.
Local
City of Culver City General Plan Open Space Element
The City’s General Plan Open Space Element, approved in 1996 and amended in 2004, includes the following park, recreation, and open space goals, objectives, and policies that relate to the Project1:
• Objective 1: Open Space Protection and Acquisition. Protect and expand Culver City’s open space resources by pursuing land acquisition and encouraging private land contributions to achieve, in the long term, the standard of four acres of local park land and school playground space per 1,000 residents.
– Policy 1.A: Provide three acres of local park land per 1,000 residents. – Policy 1.B: Provide one acre of school playground space per 1,000 residents. – Policy 1.D: Require contributions of park land from new private developments and/or in- lieu fees from projects which cannot provide actual park land on site. • Objective 2: Active Recreation. Provide a wide range of active recreational opportunities accessible to all City residents.
1 Culver City General Plan Open Space Element.
https://www.culvercity.org/files/assets/public/v/1/documents/planning-amp-development/advance- planning/general-plan/openspaceelement.pdf. Accessed October 26, 2023.
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• Objective 3: Passive Recreation. Provide passive recreational open space within walking distance of all City neighborhoods.
– Policy 3.C: Seek opportunities to develop landscaped “parkettes” or urban plazas in highly visible areas adjacent to major arterials that are not feasibly developed with other uses and that can provide sitting and eating areas for public use. – Policy 3.D: Provide seating, bike racks, and drinking fountains in passive recreation areas. – Policy 3.F: Provide barrier free access to passive recreation areas. • Objective 5: Visual Open Space and Urban Design. Extend the City’s park-like qualities into neighborhoods and business districts through streetscape and urban design improvements. – Policy 5.A: Provide urban design amenities such as plazas, courtyards, and extended sidewalks as part of new developments to visually enhance public accessways in commercial areas.
City of Culver City Municipal Code
Chapter 15.10, Subdivisions, of the CCMC requires developers subdividing land for residential uses to dedicate parkland or pay an in-lieu fee. Chapter 15.10 is consistent with the Subdivision Map and Quimby Acts, which allow cities whose general plan contains policies and standards f or park and recreation facilities to adopt by ordinance a parkland dedication requirement or in- lieu fees.
Subdivisions in Culver City exempt from this requirement include those containing senior housing and/or low - or moderate- income housing. Parkland dedications and in -lieu fees are based on residential density of a proposed development. Chapter 15.10 does not establish a service radius for dedications, but states that the parkland dedication or fees "shall be used only for the purpose of developing new or rehabilitating existing neighborhood or community park or recreational facilities reasonably related to serving the subdivision."
2 The City must accept in-lieu fees for projects with 50 residential units or fewer per Chapter 15.10.
Further, Chapter 15.06 of the CCMC (Residential Development Park Dedication and In Lieu Parkland Fees Ordinance, also referred to as the Park Dedication Ordinance) requires all residential development, not just residential development that is a result of a subdivision, to dedicate parkland (three acres of parkland per 1,000 residents) or in-lieu fees. This allows the City to collect in-lieu fees from residential projects, additional units on the same property, and conversions of single-family homes to multi-family projects. Chapter 15.06 allows the City to acquire and dedicate parkland outside of the proposed residential development. For instance, if a developer owns a parcel adjacent to an existing park, and the City determines that this parcel would benefit the City's parks and recreation system, the City may allow the developer to dedicate that property instead of property within a proposed residential development.
The City, however, does not require non-residential developers to develop parkland or recreational facilities as a condition of development. Many other California cities, per the Fee Mitigation Act (Section 66000 of California Government Code), require non-residential developers to dedicate parkland or pay in-lieu fees. Park and public space dedications from non-residential development are negotiated between the City and developers on a project -to-project basis as conditions of development approval.
2 CCMS Section 15.10.785, Limitation on Use of Land and Fees.
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Existing Conditions
PRCS Facilities and Ratios
The Culver City PRCS Department is responsible for the establishment, operation, and maintenance of parks and recreational facilities in the City. These facilities include parks, recreation centers, youth camps, sports programs, and programs for senior citizens. The PRCS Department also supervises construction of new facilities and improvements to existing ones. Currently, the PRCS Department maintains 13 parks, a regional Senior Center, the Culver City Pool (also known as The Plunge), the Boneyard Dog Park, and the Culver City Skate Park.3 The City uses a classification system to divide parks and open spaces into eight types: regional parks, community parks, neighborhood parks, parkettes/mini parks, linear parks, special use areas, natural open space, and undeveloped land. These types vary in size, function, and amenities offered to residents, employees, and visitors of Culver City (see Table 4.10.4-1, Culver City Parks and Recreation Master Plan - Park and Open Space Classifications).
TABLE 4.10.4-1
CULVER CITY PARKS AND RECREATION MASTER PLAN - PARK AND OPEN SPACE CLASSIFICATIONS Type Description
Regional Parks Large recreation areas designed to serve the entire region beyond city limits. The City does not own any regional parks.
Community Parks Usually between 15 and 40 acres, community parks are designed to serve people within a two- to three-mile radius. They provide for a variety of passive and active uses.* Community parks may include sports fields (lit or unlit), basketball courts, restrooms, indoor facilities, picnic areas, and specialized facilities (such as dog parks and skateparks).
Neighborhood Parks Neighborhood parks are intended to serve neighborhood residents within a mile of the park and are usually between three and 15 acres. Neighborhood parks may have playgrounds, picnic areas, trails, open grass areas for passive use, outdoor basketball courts, and multi-use open grass areas for sports.
Parkettes/Mini Parks Less than three acres, parkettes/mini parks are typically designed for use by small children or as green oases in the middle of an urban context. Parkettes/mini parks may have open grass areas, playgrounds, and a small picnic area.
Linear Parks Linear parks are developed landscaped areas and other lands that follow linear corridors such as rivers, creeks, abandoned railroad rights-of-way, canals, powerlines, and other elongated features.
This type of park usually contains trails, landscaped areas, viewpoints, and seating areas.
Special Use Areas Special use areas are sites often occupied by a specialized recreation facility. Some uses that fall into this category include waterfront parks, boat ramps, botanical gardens, community gardens, single purpose sites used for a particular field sport, or sites occupied by recreation buildings.
Natural Open Space Natural open space is defined as undeveloped land primarily left in its natural form with recreation uses as a secondary objective. It is usually owned or managed by a governmental agency and may or may not have public access. This type of land may include wetlands, steep hillsides, or other similar spaces. In some cases, environmentally sensitive areas are considered open space and can include wildlife habitats, stream and creek corridors, or unique and/or endangered plant species.
Undeveloped Land This land is undeveloped and has not yet been designated for a specific park use. * The term “passive use” refers to recreational activities that do not require specialized park equipment and management, such as walking, biking, and picnicking. “Active uses” require the use of special facilities, courses, fields, or equipment. Examples of active uses include playing basketball, swimming, and using playground equipment.
SOURCE: Culver City, 2009. Parks and Recreation Master Plan. Chapter 3, pages 1 to 3.
3 PRCS, Parks & Recreation, https://www.culvercity.org/Explore/Parks-Recreation, accessed October 26, 2023.
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The City maintains park service standards for city parks, regional parks, and joint use facilities to evaluate park service. The park service ratio, or ratio of number of acres of parks per 1,000 residents, is a metric the City uses to measure park service and calculate park dedication requirements for new development. A higher service ratio indicates more acres of park per 1,000 residents.
The City’s current park service standard, established in the 1968 General Plan, aimed to provide 10 acres of park space per 1,000 residents.
4 One acre per 1,000 residents may be satisfied with joint use agreements with the Culver City Unified School District (CCUSD) and six acres per 1,000 residents may be satisfied by regional parks, leaving at least three acres per 1,000 residents to be satisfied by City-owned parks. According to the Culver City Parks and Recreation Master Plan, using a population of 40,000, the 10 acres per 1,000 population standard would require the City to have access to 400 acres of parkland to meet its General Plan Parkland Standard. The City’s current population is estimated at approximately 41,000.
5 Thus, based on this estimate, 410 acres of parkland are needed to meet the General Plan Parkland Standard. According to the Culver City Parks and Recreation Master Plan, 348.63 acres of parkland were available as of 2009 (consisting of 240 acres of regional parkland, 30 acres of school parkland, and 78.63 acres of City-owned parkland).6 It is acknowledged that the parkland acreage may have increased slightly since 2009, however, for purposes of this analysis, the data cited in the Parks and Recreation Master Plan is conservatively cited herein as the potential minor increase in parkland acreage is not available. Therefore, based on this conservative baseline assumption, the City has a current parkland deficit of 61.37 acres (consisting of 11 acres of school parkland, 44.37 acres of City-owned parkland, and 6 acres of regional parkland), and does not meet the City’s standards for 10 acres per 1,000 residents. 7,8,9
In addition to the General Plan park service standard, the City’s Park Dedication Ordinance (Chapter 15.06 of the CCMC) states that public interest requires three acres of community park or recreation facilities for each 1,000 residents should be provided and maintained for community parks. As the City has 41,000 residents, 123 acres of community parks or recreation facilities would be needed to meet this standard. As the City has 78.63 of City-owned parkland (or community parks, as called for in the Ordinance), the City has a deficit of 4 4.37 acres and does not meet the City’s Ordinance standard of three acres of community park per 1,000 residents.
Existing Parks in the Project Area
The Project Site is currently developed and no existing parks or recreational facilities are located on- site. According to correspondence with the PRCS Department, and as detailed in Table 4.10.4-2,
4 Culver City, 2009. Parks and Recreation Master Plan.
5 See Section 4.9, Population and Housing, of this Draft EIR, Table 4.9.1, Projected Population, Housing, And Employment Estimates, which provides population estimates for the City. 6 Culver City, 2009. Parks and Recreation Master Plan. Chapter 6, page 3. 7 The City has a School District parkland standard of 1 acre per 1,000 residents. As Culver City has 41,000 residents, 41 acres of school parkland would be needed to meet this standard. However, only 30 acres of School District parkland are available, leaving a deficit of 11 acres.
8 The City has a City-owned parkland standard of three acres per 1,000 residents. As Culver City has 41,000 residents, 123 acres of City-owned parkland would be needed to meet this standard. However, there are only 78.63 acres of City-owned parkland available, leaving a deficit of 44.37 acres. 9 The City has a regional parkland standard of 6 acres per 1,000 residents. As Culver City has 41,000 residents, 246 acres of regional parkland would be needed to meet the standard. As 240 acres of regional parkland are available, there is a regional parkland deficit of 6 acres.
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Culver City Parks in a Two-Mile Radius of the Project Site, the following parks are within a 2-mile radius of the Project Site: two regional parks, three community parks (including a dog park); six neighborhood parks; and two parkettes. These parks are shown in Figure 4.10.4-1, Culver City Parks and Recreational Facilities Located in the Vicinity of the Project Site.
TABLE 4.10.4-2
CULVER CITY PARKS IN A TWO-MILE RADIUS OF THE PROJECT SITE Facility
Miles from
Project Site Classification Amenities
Fox Hill Parkette 0.05 Parkette Benches
Fox Hill Park 0.24 Neighborhood Park Basketball court, BBQ, picnic tables, recreation hut, restrooms, playground, tennis court, volleyball court,
walking/jogging oath
Blanco Park 0.79 Neighborhood Park Basketball court, BBQ, picnic tables, recreation building, restrooms
El Marino 1 Neighborhood Park Basketball court, BBQ, handball wall, kitchen, lighting, picnic tables, playground, recreation
building, restrooms, ceramics hut with kiln
Lindberg Park 1.37 Neighborhood Park Basketball court, BBQ, kitchen, picnic tables, playground, recreation building, restrooms, tennis
courts
Kenneth Hahn State
Recreational Areaa
1.58 Regional Park Baseball fields, soccer fields, volleyball courts, picnic tables, children’s play areas, community
centers, restrooms, BBQ, basketball courts,
concession stands, fishing lake, fitness par courses,
group picnic shelters, hiking trails
Coombs Parkette 1.73 Parkette No amenities, open turf area Culver City Park 1.78 Community Park Basketball court, BBQ, dog park, picnic tables, playground pooch path, recreation hut, skate park,
walking/jogging path, restrooms, ropes course
concession, interpretive nature trail, trail access to
Baldwin Hills Overlook, rose garden
The Bone Yard 1.78 Community Park Dog park
Baldwin Hills Scenic
Overlookb
1.93 Regional Park Hiking trails
Blair Hills 1.94 Neighborhood Park Basketball court, BBQ, picnic tables, recreation hut, restrooms, playground
Veterans Memorial
Park
1.94 Community Park Basketball court, BBQ, handball wall, kitchen, picnic tables, playground pooch path, recreation building,
skate park, walking/jogging path, restrooms,
Veterans Memorial Building, Culver City Teen
Center, and Culver City Pool
Carlson Park 1.96 Neighborhood Park BBQ, picnic tables
a Kenneth Hahn State Recreational Area is located in the County of Los Angeles and is maintained by the Los Angeles County Parks & Recreation Department.
b Baldwin Hills Scenic Overlook is located in the County of Los Angeles and is maintained by the California Department of Parks and Recreation.
SOURCES: PRCS Department, Correspondence from Dani Cullens, October 16, 2023. Provided in Appendix H-4 of this Draft EIR; Los Angeles County Parks & Recreation Department, Kenneth Hahn State Recreation Area, available at https://parks.lacounty.gov/kenneth-hahn-state-recreation-area/#. Accessed November 2023; California Department of Parks and Recreation, Baldwin Hills Scenic Overlook, available at https://www.parks.ca.gov/?page_id=22790, accessed November 2023.
Project Site
Culver
City Park
Coombs
Parkette
Lindberg Park
Blanco Park
El Marino
Park
Fox Hills
Parkette
Fox Hills
Park
The Bone Yard
Blair Hills Park
Carlson Park
Veterans
Memorial Park
Baldwin Hills
Scenic Overlook
Kenneth
Hahn
State
Recreation
Area
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Neighborhood Park
Parkette
Regional Park
Project Site
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4. Environmental Impacts Analysis
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4.10.4.3 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 a significant impact associated with park and recreation facilities if it would:
• PARK-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for parks. • PARK-2 Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
• PARK-3 Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
Methodology
The analysis of parks and recreation is based on an estimate of the Project’s residential population (based on the number of units), and the potential for increased demand to result in the need for construction of new facilities with associated impacts on the physical environment, or to result in the deterioration of existing facilities. The Project’s retail uses are not considered to generate appreciable additional demand for park and recreational facilities because they would not generate permanent residential populations that would utilize the parks and recreational facilities in the area.
Therefore, the commercial uses are not considered in the analysis. In addition, the metrics and Citywide goals used by the PRCS Department are based on residential population. The analysis considers the Project’s proposed open space features and whether the provision of those facilities could reduce Project-generated demand on existing parks and recreational facilities. It should be noted that the analysis contained in this section is based on the Project’s potential demand on existing facilities and not on future facilities that are proposed and planned. However, if approved and constructed, planned, future open space and park improvements would further reduce demand for park facilities in the Project vicinity, which is noted in the analysis.
The estimated Project-generated population, as well as the Project-provided recreational facilities, are converted to a service ratio expressed as acres of parkland per 1,000 residents. The City’s current park service standard, established in the 1968 General Plan and maintained in the current General Plan, aim s to provide 10 acres of park space per 1,000 residents . However, under the authority of the Quimby Act and through the City’s Park Dedication Ordinance, the City has adopted a parkland dedication requirement of three acres of parkland per 1,000 residents for each residential development that takes place in the City; thus, this is the service ratio used in this analysis.
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Project Design Features
No specific Project Design Features are proposed with regard to parks and recreation beyond the open space and recreational amenities described in Chapter 2 , Project Description, of this Draft EIR, and the additional details provided in the following impact analysis portion of this section.
Analysis of Project Impacts
Threshold PARK-1: The Project would result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for parks.
Impact Analysis
Construction
During construction of the Project, there would be a temporary increase in construction workers on the Project Site. These construction workers would likely come from an existing local pool of construction employees within the region and would not likely r elocate their households as a consequence of working on the Project. Therefore, the increased employment of construction workers on the Project Site would not result in an increase in the residential population of the area surrounding the Project Site. Accordingly, there would not be a corresponding residential demand or use of the existing parks and recreation facilities during this time as construction workers are more likely to use parks near their places of residence. A small number of construction workers may visit the parkette or other local parks to eat lunch or for recreational activity after a workday.
However, construction workers are temporary employees with high turnover associated with the various phases of construction, so such park use would be rare and short -term. Thus, construction would not generate a substantial increase in demand for park and recreation facilities such that acceptable service ratios or performance objectives for parks would be exceeded . Therefore, impacts during construction would be less than significant.
Operation
As previously discussed, the City’s current park service standard recommends three acres of park space per 1,000 residents 10. As discussed in Chapter 4.9, Population and Housing, of this Draft EIR, the Project’s 309 residential housing units would result in 733 residents on the Project Site.
Based on the guideline of three acres of park space per 1,000 persons, the Project’s recommended park space would total approximately 2.2 acres.
As described in detail in Chapter 2, Project Description , of this Draft EIR, the Project would provide 7,507 sf (0.17 acres) of publicly-accessible open space as part of the Hannum Plaza, located along Hannum Avenue . The Hannum Plaza would feature drought tolerant landscaping and a variety of seating areas, open to the community. The Project’s 0.17 acres of publicly -accessible
10 Culver City, 2009. Parks and Recreation Master Plan. https://www.culvercity.org/files/assets/public/documents/building-development/city- documents/1_2009_parksandrecreationm.pdf. Accessed October 26, 2023.
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open space as part of the Hannum Plaza is less than the 2.2 acres required by the City’s Park Dedication Ordinance for the Project’s 733 additional residents.
However, overall, with the Hannum Plaza, plus 19,526 sf of private open space and 27,123 sf of common open space (for residents), the Project would provide a total of 54,156 sf (or 1.24 acres) of open space. Amenities provided throughout the Project’s open space areas would include shade trees, lounge seating, and gathering spaces. The Project’s residential open space and amenity features would include a centrally located courtyard and a community room on the second floor.
The courtyard would have a variety of seating areas, BBQs, and landscaping. An amenity deck and community room area and gym space would be located on the sixth floor. The sixth floor/roof level deck would include a pool and spa, open seating areas, private meeting areas, and a kitchen ette.
Occasional events for residents only would be held throughout the year within the courtyard or roof deck as an amenity for the residents. These events might include outdoor yoga, intimate food and beverage events, and/or outdoor movies. The property management team would have on-site staff, courtesy patrol, or hired service present at all times during such events.
Given the Project’s open space and recreational amenities, the Project’s recreational demand would be at least partially accommodated on the Project Site. While these privately owned open spaces are not under the jurisdiction of the PRCS Department, 7,507 sf of open space would be open to the public and, thus, has the potential to reduce Project-related recreational demand on PRCS facilities. Likewise, it can be reasonably assumed that residual off-site park usage would likely be dispersed among the neighborhood parks, community parks, and regional parks that are within a two -mile radius of the Project Site, as shown in Figure 4.10.4-1 above, as each park offers a range of different amenities.
Notwithstanding the on-site open space and recreational amenities proposed , and the private and public amenities in the Project vicinity, some Project residents would still be expected to utilize nearby public park amenities such as picnic areas, sports fields, and basketball courts. As a result, the Project could result in an incremental increase in the use of area neighborhood, community, and regional public parks.
However, compliance with regulatory requirements would ensure that the intent of the PRCS parkland guidelines would be addressed through compliance with state law (e.g., Quimby Act) as enforced through applicable CCMC requirements related to the provision and/or funding of parks and recreational spaces (e.g., provision of on-site recreational amenities and open space and payment of in-lieu fees, where applicable).
The Project would be subject to CCMC requirements intended to offset increased demand for parks and recreational facilities created by residential development projects. As previously discussed, CCMC Section 15.10 and 15.06 sets park and recreational facility dedication and/or in lieu fee requirements for new residential development.
The Project would include development of 30 9 residential units on the Project Site. The Project does not propose the dedication of any portion of the Project Site to the City for parks and recreational facilities and would be required to pay applicable in-lieu fees to satisfy CCMC requirements. As the Applicant would pay the in -lieu fees, as determined applicable, the Project would be consistent with CCMC requirements to support acquisition of new park space.
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Conclusion
Based on the above, with the proposed on-site open space and recreational amenities, in addition to the required payment of in-lieu fees, as applicable, the Project would be consistent with and meet CCMC open space and parkland requirements. Implementation of regulatory requirements would ensure that the parkland standards would be addressed through compliance with applicable CCMC requirements. Therefore, the Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which would ca use significant environmental impacts. Impacts would be less than significant.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
Level of Significance After Mitigation
Not applicable. Impacts regarding the construction of parks and recreation facilities would be less than significant.
Threshold P ARK-2: The Project would i ncrease the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
Impact Analysis
Construction
The nearest PRCS Department park to the Project Site is the Fox Hill Parkette, located to the east of the Project Site at the southeast corner of Hannum Avenue and Buckingham Parkway. A small number of construction workers may visit the parkette or other local parks to eat lunch or for recreational activity after a workday. However, construction workers are temporary employees with high turnover associated with the various phases of construction, so such park use would be rare and short-term. As a result, Project construction activities would not result in increased use of parks such that substantial deterioration would occur. The Project does not include or require the construction of recreational facilities that might have an adverse physical effect on the environment.
Operation
This analysis evaluates the Project’s proposed provision of open space and demand for parks and recreational amenities associated with new residents.
As previously stated under Threshold PARK-1, based on the Project’s residential population of 733 residents, the Project would need to provide approximately 2.2 acres of parkland to meet the required Park Dedication Ordinance standard of 3 acres of parkland per 1,000 residents. As described in detail in Chapter 2, Project Description, of this Draft EIR, the Project would provide 7,507 sf (0.17 acres) of publicly-accessible open space, consisting of the Hannum Plaza. The Project’s open space would thus not meet the recommended three acres of local parkland space per 1,000 persons (or 2.2 acres of parkland for the Project), based on the Project’s projected residential population. However,
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overall, with Hannum Plaza, plus 19,526 sf of private open space and 27,123 sf of common open space (for residents), the Project would provide a total of 54,156 sf (1.24 acres) of open space.
Although the Project would provide a considerable amount of open space and recreational features, it is assumed that some Project residents would still patronize existing public parks and recreational facilities, including use of public park amenities, such as playgrounds , nature trails, picnic areas, basketball courts, and sports fields. However, it is expected that Project resident use would be distributed across a number of recreational sites and facilities depending on the amenities offered at each location, such that substantial deterioration of facilities would not occur. Additionally, there is little potential that Project residents’ and employees’ use at any particular park or recreational facility would result in physical deterioration due to the Project’s proposed open space and recreational amenities. There is also the potential for the 7,507 square feet of publicly -accessible open space that the Project would provide to reduce the existing demand on nearby parks and recreational facilities. In addition, the Project’s private open space and amenities would reduce the Project’s resident demand on nearby parks and recreational facilities by providing active (i.e., exercise facilities and pool) and passive (i.e., seating and lounge areas) recreational opportunities.
Moreover, through the payment of required in-lieu fees for parks and recreational facilities, the Project would be consistent with the CCMC parkland requirements, which would require the Applicant to pay fees to offset park- and open space-related impacts of the Project. Therefore, the Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.
Impacts would be less than significant.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
Level of Significance After Mitigation
Not applicable. The Project would not result in an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Impacts would be less than significant.
Threshold P
ARK-3: The Project would include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.
Impact Analysis
Construction
As discussed above under Thresholds PARK-1 and PARK-2, the Project includes the construction of open space and recreational amenities. The construction of these Project components and the potential for adverse physical effects on the environment are addressed within the construction related analyses provided in the topical sections in Chapter 4, Environmental Impact Analysis , of this Draft EIR. Therefore, with implementation of mitigation measures detailed throughout Chapter 4, impacts during construction would be less than significant.
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Operation
As discussed above under Thresholds PARK-1 and PARK-2, the Project’s provision of open space and recreational amenities would help offset demand for such facilities, and it is expected that residents, guests, and employees are likely to use on-site open space and recreational facilities to a greater extent than off-site facilities. In addition, the Project would pay in-lieu park fees and comply with the CCMC, as applicable, which would help fund construction of future off -site recreational facilities when and where needed. As the Project would largely offset demand for recreational facilities through provision of its own recreational facilities, such as the gym facilities, pool deck, and other open space amenities, it would not require construction or expansion of new off-site recreational facilities. To the extent the Project would generate some incremental demand that could lead to the need for construction of new or expanded off-site recreational facilities, construction of such facilities and the potential for associated adverse effects on the physical environment are not foreseeable, particularly in light of facilities that are proposed in the area, such as potential improvements to Veterans Memorial Complex and Culver City Park 11, which are
independent projects that would be required to go through their own environmental review process.
Therefore, the Project would not include recreational facilities or require the construction or expansion of recreational facilities which would have an adverse physical effect on the environment. 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 not include recreational facilities or require the construction or expansion of recreational facilities which would have an adverse physical effect on the environment and impacts would be less than significant.
Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR, identifies 12 related projects that are anticipated to be developed within a 1-mile radius of the Project Site. These projects are summarized in Table 3-1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3. As shown in Table 3-1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles. Of these related projects, eight occur within Culver City and, like the Project, would create a demand for park space from the PRCS Department.
The PRCS Department bases its evaluations of park space on the availability of park services for residents as opposed to employees or visitors to an area. Most park visits originate from people’s homes and residents tend to prefer using local parks out of convenience. Typically, employees are engaged in their work during the day and do not contribute notable demand for parks. Given the PRCS Department methodology for evaluating park services, this cumulative analysis on parks and recreation focuses on the related projects that propose residential uses.
11 PRCS Department, Correspondence from Dani Cullens, October 16, 2023. Provided in Appendix H-4 of this Draft EIR.
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These related projects, in conjunction with the Project, would cumulatively generate the need for additional parks and recreational facilities. As analyzed in Section 4.9, Population and Housing, of this Draft EIR, the related projects containing residential components would have the potential to generate a cumulative population increase of approximately 1,806 people within the City of Culver City. The related projects, including the Project’s estimated 733 residents, would generate a total of approximately 2,539 residents.
As is the case with the Project, impacts on local parks from related projects would be reduced by the provision of on-site open space and recreational amenities. The applicable related projects would be required to pay in-lieu fees pursuant to CCMC Section 15.10 and 15.06, which is the City’s parkland dedication ordinance that ensures compliance with the Quimby Act. Moreover, the use of parks by related project residents can reasonably be expected to be distributed across the parks serving the Project and r elated projects, such that substantial physical deterioration of an individual park facility would be unlikely to occur.
The Project would introduce a new residential population to the area, which would increase demand for and use of existing recreational sites and facilities. However, all related projects with residential uses would be required to comply with CCMC Section 15.10 and 15.06, which require the provision of on-site open space and park facilities and/or payment of in-lieu fees to offset a project’s impact to off-site park and recreational facilities. Payment of the fees by each respective related project, as applicable, would ensure that such substantial physical deterioration would not occur or be accelerated and that all facilities would be maintained.
Therefore, with on -site open space and park facilities and payment of the applicable fees, the Project and related projects would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment; or result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for parks. Based on the above considerations, cumulative impacts on parks and recreational facilities 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 parks would be less than significant.
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4.11 Transportation
4.11.1 Introduction
This section analyzes potential impacts related to transportation. The analysis is based on the Transportation Study for the Project prepared by Gibson Transportation Consulting, Inc , dated August 2023, included as Appendix I of this Draft EIR. The Transportation Study was prepared in accordance with the City of Culver City’s (City) CEQA transportation thresholds of significance and the Transportation Study Criteria and Guidelines (TSCG) adopted in July 2020. 1 The base assumptions and technical methodologies to be used in the Transportation Study were established in a detailed Memorandum of Understanding (MOU) with the City, which was signed in July 2023 and provided in Appendix A of the Transportation Study.
4.11.2 Environmental Setting
Regulatory Framework
Federal
Americans with Disabilities Act of 1990
Titles I, II, III, and V of the Americans with Disabilities Act (ADA) have been codified in Title 42 of the United States Code (U.S.C.), beginning at Section 12101. Title III prohibits discrimination based on disability in “places of public accommodation” (businesses and non- profit agencies that serve the public) and “commercial facilities” (other businesses). The regulation includes Appendix A through Part 36 (Standards for Accessible Design), establishing minimum standards for ensuring accessibility when designing and constructing a new facility or altering an existing facility.
Examples of key guidelines include detectable warnings for pedestrians entering traffic where there is no curb, a clear zone of 48 inches for the pedestrian travel way, and a vibration -free zone for pedestrians.
State
Complete Streets Act
Assembly Bill (AB) 1358, the Complete Streets Act (Government Code Sections 65040.2 and 65302), was signed into law by Governor Arnold Schwarzenegger in September 2008. As of January 1, 2011, the law requires cities and counties, when updating the part of a local general plan that addresses roadways and traffic flows, to ensure that those plans account for the needs of all roadway users. Specifically, the legislation requires cities and counties to ensure that local roads and streets adequately accommodate the needs of bicyclists, pedestrians and transit riders, as well as motorists.
At the same time, the California Department of Transportation (Caltrans), which administers transportation programming for the State, unveiled a revised version of Deputy Directive 64 (DD- 64-R1 October 2008), an internal policy document that now explicitly embraces Complete Streets
1 On July 13, 2020, the Culver City Council adopted a resolution formally implementing the City’s updated transportation thresholds of significance for CEQA analyses and overall transportation study guidelines. The TSCG is the document providing the guidance for conducting both CEQA and non-CEQA transportation analyses.
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as the policy covering all phases of State highway projects, from planning to construction to maintenance and repair.
Assembly Bill 32 and Senate Bill 375
With the passage of Assembly Bill (AB 32), the Global Warming Solutions Act of 2006, the State of California committed itself to reducing Statewide greenhouse gas (GHG) emissions to 1990 levels by 2020. The California Air Resources Board (CARB) is coordinating the response to comply with AB 32.
On December 11, 2008, CARB adopted its Scoping Plan for AB 32. This scoping plan included the approval of Senate Bill (SB) 375 as the means for achieving regional transportation-related GHG targets. SB 375 provides guidance on how curbing emissions from ca rs and light trucks can help the state comply with AB 32.
There are five major components to SB 375. First, regional GHG emissions targets: California ARB’s Regional Targets Advisory Committee guides the adoption of targets to be met by 2020 andc2035 for each Metropolitan Planning Organization (MPO) in the State. These targets, which MPOs may propose themselves, are updated every eight years in conjunction with the revision schedule of housing and transportation elements.
Second, MPOs are required to prepare a Sustainable Communities Strategy (SCS) that provides a plan for meeting regional targets. The SCS and the Regional Transportation Plan (RTP) must be consistent with each other, including action items and financing decisions. If the SCS does not meet the regional target, the MPO must produce an Alternative Planning Strategy that details an alternative plan to meet the target.
Third, SB 375 requires that regional housing elements and transportation plans be synchronized on 8-year schedules. In addition, Regional Housing Needs Assessment (RHNA) allocation numbers must conform to the SCS. If local jurisdictions are required to rezone land as a result of changes in the housing element, rezoning must take place within three years.
Fourth, SB 375 provides CEQA streamlining incentives for preferred development types. Certain residential or mixed-use projects qualify if they conform to the SCS. Transit-oriented developments (TODs) also qualify if they (1) are at least 50 percent residential, (2) meet density requirements, and (3) are within 0.5 mile of a transit stop. The degree of CEQA streamlining is based on the degree of compliance with these development preferences.
Finally, MPOs must use transportation and air emissions modeling techniques consistent with guidelines prepared by the California Transportation Commission. Regional Transportation Planning Agencies, cities, and counties are encouraged, but not required, t o use travel demand models consistent with the California Transportation Commission guidelines.
California Vehicle Code
The California Vehicle Code (CVC) provides requirements for ensuring emergency vehicle access regardless of traffic conditions. Sections 21806(a)(1), 21806(a)(2), and 21806(c) define how motorists and pedestrians are required to yield the right-of-way to emergency vehicles.
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Senate Bill No. 743
On September 27, 2013, Governor Jerry Brown signed SB 743, which went into effect in January 2014. SB 743 directed the Governor’s Office of Planning and Research (OPR) to develop revisions to the CEQA Guidelines by July 1, 2014, to establish new criteria for determining the significance of transportation impacts and define alternative metrics for traffic level of service ( LOS). This started a process that changes transportation impact analysis under CEQA. These changes include elimination of auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts for land use projects and plans in California. Additionally, as part of SB 743, parking impacts for particular types of development projects in areas well served by transit are not considered significant impacts on the environment.
According to the legislative intent contained in SB 743, these changes to current practice were necessary to “more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions.”
On January 20, 2016, OPR released the Revised Proposal on Updates to the CEQA Guidelines on Evaluating Transportation Impacts in CEQA, which was an update to Updating Transportation Impacts Analysis in the CEQA Guidelines, Preliminary Discussion Draft of Updates to the CEQA Guidelines Implementing Senate Bill 743, which was released on August 6, 2014. Of particular relevance was the updated text of the proposed new CEQA Guidelines Section 15064.3 that relates to the determination of the significance of transportation impacts, alternatives, and mitigation measures. Specifically, CEQA Guidelines Section 15064.3, which is discussed further below, establishes VMT as the most appropriate measure of transportation impacts. In November 2018, the California Natural Resources Agency (CNRA) finalized the updates to the CEQA Guidelines, and the updated guidelines became effective on December 28, 2018.
Based on these changes, the City of Culver City adopted its Transportation Study Criteria and Guidelines (TSCG) in July 2020; this guidance document sets forth the revised thresholds of significance for evaluating transportation impacts as well as screening and evaluation criteria for determining impacts, pursuant to SB 743.
CEQA Guidelines Section 15064.3
As discussed above, recent changes to the CEQA Guidelines include the adoption of Section 15064.3, Determining the Significance of Transportation Impacts. CEQA Guidelines Section 15064.3 establishes VMT as the most appropriate measure of transportation impacts. Generally, land use projects within 0.5 miles of either an existing major transit stop 2 or a stop along an existing
high quality transit corridor 3 should be presumed to cause a less than significant transportation impact. Projects that decrease VMT in the project area compared to existing conditions should be presumed to have a less than significant transportation impact. A lead agency has discretio n to choose the most appropriate methodology to evaluate VMT, including whether to express the
2 “Major transit stop” is defined in Public Resources Code Section (PRC) 21064.3 as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.
3 “High-quality transit corridors” are defined in PRC Section 21155 as a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.
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change in absolute terms, per capita, per household or in any other measure. A lead agency may also use models to estimate VMT, and may revise those estimates to reflect professional judgment based on substantial evidence. As discussed further below, Culver City developed a VMT Tool to measure VMT for development projects .
4 The methodology for determining VMT based on the
VMT Tool is consistent with CEQA Guidelines Section 15064.3.
Regional
Southern California Association of Governments 2020-2045 Regional Transportation Plan / Sustainable Communities Strategy
In compliance with SB 375, on September 3, 2020, the Southern California Association of Governments (SCAG) Regional Council adopted the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020 -2045 RTP/SCS), a long -range visioning plan that incorporates land use and transportation strategies to increase mobility options and achieve a more sustainable growth pattern while meeting GHG reduction targets set by CARB. The 2020 -2045 RTP/SCS contains baseline socioeconomic projections that are used as the basis for SCAG’s transportation planning, as well as the provision of services by the six-county region of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura counties. SCAG policies are directed towards the development of regional land use patterns that contribute to reductions in vehicle miles and improvements to the transportation system.
The 2020-2045 RTP/SCS builds on the long-range vision of SCAG’s prior 2016-2040 RTP/SCS to balance future mobility and housing needs with economic, environmental and public health goals. A substantial concentration and share of growth is directed to Priority Growth Areas (PGAs), which include high quality transit areas (HQTAs), Transit Priority Areas (TPAs), job centers, Neighborhood Mobility Areas (NMAs) and Livable Corridors. These areas account for four percent of SCAG’s total land area but the majority of directed growth. HQTAs are corridor-focused PGAs within one 0.5mile of an existing or planned fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes (or less) during peak commuting hours. TPAs are PGAs that are within a 0.5 mile of a major transit stop that is existing or planned.
Job centers are defined as areas with significant higher employment density than surrounding areas which capture density peaks and locally significant job centers throughout all six counties in the region. NMAs are PGAs with robust residential to non -residential land use connections, high roadway intersection densities, and low-to -moderate traffic speeds. Livable Corridors are arterial roadways, where local jurisdictions may plan for a combination of the following elements: high- quality bus frequency; higher density residential and employment at key intersections; and increased active transportation through dedicated bikeways.
The 2020-2045 RTP/SCS’ “Core Vision” prioritizes the maintenance and management of the region’s transportation network, expanding mobility choices by co-locating housing, jobs, and transit, and increasing investment in transit and complete streets. Strategies to achieve the “Core Vision” include, but are not limited to, Smart Cities and Job Centers, Housing Supportive Infrastructure, Go Zones, and Shared Mobility. The 2020-2045 RTP/SCS intends to create benefits
4 Because the City of Culver City is the Lead Agency for the Project, the VMT analysis follows the City of Culver City’s procedures identified in the TSCG and VMT Tool.
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for the SCAG region by achieving regional goals for sustainability, transportation equity, improved public health and safety, and enhancement of the regions’ overall quality of life. These benefits include, but are not limited to, a five percent reduction in VMT per capita, nine percent reduction in vehicle hours traveled, and a two percent increase in work-related transit trips.
Local
Culver City Municipal Code
Sections of the City’s Municipal Code (CCMC) applicable to transportation include, but are not limited to, the following:
• Section 7.05.015 (Transportation Demand and Trip Reduction Measures): Prior to issuance of a certificate of occupancy of any new development of 25,000 gross square feet (sf) of floor area or more, the property owner shall make lasting provisions for a bulletin board, display, case or kiosk displaying transit route, ridesharing, bicycle route, and carpool/vanpool information. Prior to the issuance of a certificate of occupancy of any new development of 50,000 gross sf of floor area or more, not less than 10 percent of the employee parking area shall be located as close as is practical to employee entrances and be reserved for potential carpool or vanpool vehicles. Additionally, preferential parking spaces reserved for employee vanpool services shall be accessible to vanpool vehicles. Furthermore, bicycle racks or other secure bicycle parking shall also be provided at a rate of four spaces for the first 50,000 sf of new development, and once space for each additional 50,000 sf. For projects of 100,000 gross sf of floor area or more, the following shall also be provided: (1) sidewalks or other designated pedestrian pathways following direct and safe routes from the external pedestrian circulation system, vehicle and bicycle parking areas and transit facilities, to each b uilding in the development; (2) if determined necessary by the City to mitigate impacts, bus stop improvements; and (3) a safe and convenient zone in which vanpool and carpool vehicles may deliver or board their passengers.
• Section 17.320.020 (Number of Parking Spaces Required): This section identifies that there are no minimum required parking spaces for any use, except as may be determined through a Comprehensive Plan. Any parking provided voluntarily or otherwise, shall comply with the development standards outlined in Chapter 17.320 Off-Street Parking and Loading, or other applicable section of this Title.
• Section 17.320.030 (Accessible Parking): Parking spaces for persons with disabilities shall be provided in compliance with the Uniform Building Code and the Federal Accessibility Guidelines. For each dwelling unit required to be designed to accommodate the persons with disabilities, or required to be made adaptable for the persons with disabilities, the required parking shall be provided in compliance with Cal. Admin. Code, Title 24, Part 2. • Section 17.320.045 (Bicycle Parking): This section includes bicycle parking spaces requirements for residential and non-residential buildings. For residential buildings with more than 201 units, this section requires one (1) short-term space per 40 units and one (1) long-term space per four (4) units. For non-residential buildings, this section requires one (1) short-term space per 2,000 sf of retail/restaurant use and one (1) long-term space per 2,000 sf of retail/restaurant use. A minimum of two (2) short-term spaces is required for residential buildings and a minimum of two (2) short- term spaces and two (2) long term spaces is required for non-residential buildings. • Section 17.320.050.B (Loading Area Requirements): Per this section, non-residential buildings with floor area between 2,501 and 7,500 sf shall be required to provide one (1) medium loading space. Loading area sizes are to meet the minimum dimensions in Section 17.320.050.B.
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City of Culver City General Plan Circulation Element5
The Circulation Element, amended through 2004, includes the following traffic and parking designations, goals, objectives and policies that relate to the Project:6 • Policy 1.A: Facilitate movement of vehicles at intersections and along roadway links by increasing capacity, improving operation, and reducing volumes as appropriate and feasible. • Policy 1.F: Reduce driveways and curb cuts on arterials in favor of side street and alley access, where appropriate, considering potential impacts on the neighborhoods served by the side streets.
• Policy 2.C: Maintain levels of transit service that are adequate to meet and encourage ridership demand.
• Policy 2.H: Encourage public transit links to sites of high trip-generating uses to maximize transit use by patrons and employees.
• Policy 3.D: Seek public and private contributions to provide support facilities for bicycle users (such as racks, secure storage, drinking fountains, etc.) where bikeways connect to turnouts, parks, and other open space areas, as appropriate.
• Policy 3.G: Encourage large business to include bike lockers or other secure bicycle storage and related facilities to support bicycle commuting by employees. • Policy 4.C: Provide safe and attractive pedestrian walkways/sidewalks which link streets and parking areas to the entrances of major developments.
• Policy 4.D: Enhance the aesthetic qualities of pedestrian access routes by increasing amenities, such as trees, awnings, lighting, street furniture, and drinking fountains, etc. • Policy 6.B: Reduce pressure on on-street parking through provision of private and public off - street parking facilities.
Culver City Short Range Transit Plan
The Culver City Short -Range Transit Plan (Culver CityBus, FY 2019-2020) provides a strategic blueprint designed to maintain a forward-thinking focus on improved mobility services with a continued dedication to customer service and fiscal responsibility. The plan provides an overview of the City’s existing mobility services and policies that further improve mobility in the City, such as transit-oriented development and complete streets projects. Further, the plan proposes a variety of measures to improve mobility services, implement physical changes to transit facilities and roadways, and upgrade existing buses with fully electric vehicles.
In the Project area, the Plan identifies Culver CityBus system’s Line 3 (Overland Avenue). Line 3 (Overland Ave.) serves Century City, Palms, West Los Angeles College, Fox Hills, and the Corporate Pointe area of Culver City. The Line 3 route operates 20.6 miles round trip. A more detailed description of Line 3 is discussed under Public Transit in the Existing Conditions section below.
5 The TSCG requires that the Transportation Impact Study must study the Circulation and Land Use Elements of the General Plan. However, the Land Use Element does not include transportation-related measures, objectives, or policies. 6 City of Culver City, General Plan Circulation Element, amended through 1995, https://www.culvercity.org/files/assets/public/documents/planning-amp-development/advance-planning/general- plan/circulationelement.pdf. Accessed July 5, 2023.
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Culver City Bicycle & Pedestrian Action Plan
The City of Culver City Bicycle and Pedestrian Action Plan (Action Plan) establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Plan aims to provide a safe, convenient, and accessible active transportation network, accessible by users of all ages and abilities. The Plan uses Caltrans’ four bicycle facility designations as follows:
• Class I (Shared -Use Paths): Shared-use paths, or paved trails, are facilities that provide completely separated, exclusive right-of-way for bicycling, walking, and other non-motorized uses.
• Class II (Bicycle Lanes): Bicycle lanes are striped lanes on roadways for one-way bicycle travel.
• Class III (Bicycle Routes and Bike Boulevards): Bicycle routes are signed routes where people riding bicycles share a travel lane with people driving motor vehicles. • Class IV (Separated Bikeways): A separated bikeway, also known as a cycletrack, is an on - street facility that is physically separated from motor vehicle traffic by a vertical element or barrier, such as a curb, bollards, or vehicle parking aisle.
The Action Plan was adopted by City Council in June 2020, and supersedes the 2010 City’s Bicycle and Pedestrian Master Plan. The Action Plan shows that Buckingham Parkway (from Hannum Ave. to Green Valley Circle), immediately adjacent to the Project Site, is planned as a Class IV Separated Bikeway. Additionally, Green Valley Circle (from Sepulveda Blvd. to Centinela Ave.) is planned to have a Class II Bicycle Lane within the Project study area. The following actions in the Action Plan are applicable to the Project:
• Action AC-1.2: Prioritize projects that create safe welcoming spaces for all people, with an added focus on ways to serve those who have the least access to financial and social resources. • Action HS-3.2: Use current design guidelines to encourage development patterns that promote active transportation and allow for short trips between destinations. • Action HS-4.1: Build an active transportation network that encourages Culver City residents to use means of transportation other than driving by providing safer, more comfortable biking and walking facilities.
Complete Streets Policy
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 Complete Streets 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 ROW. The following policies provided in the Complete Streets Policy are applicable to the Project:
• Policy 5a.i: The City will plan, design, operate, and maintain a transportation system that provides a connected network of streets and facilities that accommodate all modes of travel.
The City will actively seek opportunities to repurpose or enhance rights -of-way to improve connectivity for pedestrians, bicyclists, and transit users.
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• Policy 5a.ii: The City will pursue enhancements to the bicycle and pedestrian connectivity to public transit services, as well as to schools, parks, service retail, public facilities, regional connections, and business districts.
• Policy 5b.ii: The City will emphasize pedestrian access along and across City streets by, for example, providing convenient and protected crossing locations, shortening crossing distances through the use of curb extensions and tight curb radii, and enhancing signage and pavement markings.
• Policy 5d.ii: The City will coordinate street improvements with business owners along retail and commercial corridors to develop or enhance vibrant business districts.
Neighborhood Traffic Management Program (NTMP) Procedures Manual The City adopted a series of procedures for the implementation of NTMPs, as defined in its Neighborhood Traffic Management Program (NTMP) Procedures Manual (November 22, 2004).
The program requires a series of actions by the neighborhood and City/Engineering Division to determine the traffic issues, study them, develop a plan, test proposed improvements, and finalize the plan.
Gateway Neighborhood Design Guidelines
The City’s Multi-Family Neighborhood Residential Design Guidelines – Gateway Neighborhood (Adopted March 24, 2010) is intended to encourage new residential projects to be compatible with, maintain the integrity of, and preserve the unique character and bes t features of the Gateway Neighborhood by promoting desirable design qualities, guiding change in ways that are compatible with the existing neighborhood development pattern, and respecting the diversity and vitality of the neighborhood. The Project is not located within the Gateway Neighborhood and, therefore, Multi- Family Neighborhood Residential Design Guidelines – Gateway Neighborhood does not apply to the Project.
Gateway Adjacent Neighborhood Design Guidelines
The City’s Multi-Family Neighborhood Residential Design Guidelines – Gateway Adjacent Neighborhood (July 13, 2011) is intended to encourage new residential projects to be compatible with, maintain the integrity of, and preserve the unique character and best features of the Gateway Adjacent Neighborhood by promoting desirable design qualities, guiding change in wa ys that are compatible with the existing neighborhood development pattern, and respecting the diversity and vitality of the neighborhood. The Project is not located within the Gateway Adjacent Neighborhood and, therefore, Multi-Family Neighborhood Resident ial Design Guidelines – Gateway Adjacent Neighborhood does not apply to the Project.
Residential Parkway Guidelines
The City’s Culver City Residential Parkway Guidelines (2016) informs the general public about parkway regulations and provides guidance on planning, creating, and maintaining a parkway landscape. Property owners are expected to maintain the parkway space adjacent to their properties, with the exception of street trees, which are maintained by the City. Sidewalk access and step -out strips are to be installed and maintained along all residential parkways in the City. The Project would comply with any applicable Culver City Residential Parkway Guidelines as determined appropriate in consultation with the City.
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Upper Culver Crest Hillside Design Standards
Culver Crest: Recommendations for R-1 Neighborhood Hillside Development Standards (January 4, 2017) specifies a zoning code overlay for the Culver Crest residential community to ensure that the unique planning and development concerns of this hillside neighborhood are addressed. The Project is not located within the Upper Culver Crest community and, therefore, Culver Crest: Recommendations for R-1 Neighborhood Hillside Development Standards does not apply to the Project.
Local Road Safety Plan
The City’s Local Roadway Safety Plan (November 2021) (LRSP) is a document that enables the City to determine potential traffic safety projects on roadways and intersections within the City. In an effort to eliminate fatal and severe injury collisions, the document provides a comprehensive collisions analysis through the LRSP to identify high -risk corridors and intersections with the highest collision frequency and severity.
Vision Zero
The City adopted the Vision Zero initiative in 2016 and has incorporated policies and infrastructure improvements into Culver City Bicycle & Pedestrian Action Plan. None of the streets located on the City’s High Injury Network (HIN) are located adjacent to the Project Site and no Vision Zero improvements have been proposed adjacent to the Project Stie, as of June 2023.
Existing Conditions
Existing Street System
As described below, the Project Site and the transportation study area is well-served by a network of freeways and streets. The streets in the S tudy Area are under the jurisdiction of the City.
Freeways are under the jurisdiction of the California Department of Transportation (Caltrans).
The existing street system in the Study Area consists of a regional roadway system including arterials and local streets that provide regional, sub-regional, or local access and circulation within the Study Area. These transportation facilities generally p rovide two to six travel lanes and left - turn lanes and usually allow parking on one or both sides of the street. Hannum Avenue provides Class II bicycle lanes. Typically, the speed limits range between 25 and 35 miles per hour (mph) on the streets and 55 mph on the freeways.
Street classifications for City roadways are designated in Culver City General Plan Circulation Element (adopted May 24, 2004) (Circulation Element). The Circulation Element defines specific street standards in an effort to effectively link and serve local and regional transportation systems.
Per the Circulation Element, street classifications are defined as follows:
• Freeways are specialized arterials with limited access and are grade-separated from the City’s street system. Their primary function is to carry large volumes of traffic at high speed throughout the region.
• Primary Arterials are major cross-town thoroughfares with desired ROW widths of 95 feet or more. Traffic flow on Primary Arterials is characterized as high volume and fast-moving. Direct access onto Primary Arterials from private driveways should be limited or prohibited. Where private driveways are prohibited, Primary Arterials are designed as controlled access streets.
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• Secondary Arterials provide links between Collectors and Primary Arterials with desired ROW widths of 80 to 94 feet.
• Collectors provide a means for the movement of traffic from Local Streets to larger streets with desired ROW widths between 60 to 79 feet.
• Neighborhood Feeders are generally located within residential neighborhoods and provide direct routes between Local Streets and the adjacent arterials. • Local Streets provide access for vehicles to travel between private parking and driveways to larger, non-Local Streets. Generally, Local Streets do not exceed 60 feet of ROW widths and are mostly in residential neighborhoods.
Primary regional access to the Project Site is provided by I -405 and SR 90. In proximity to the Project Site, the Study Area is served by arterial streets such as Hannum Avenue, Bristol Parkway and Slauson Avenue. The following is a brief description of the roadways in the Study Area, including their classifications under the Circulation Element:
Freeways
• Interstate 405 (San Diego Freeway): The San Diego Freeway runs north/south and is approximately 0.8 miles west of the Project Site. Access to the San Diego Freeway is available via interchanges at SR 90 and La Cienega Boulevard.
• State Route 90 (Marina Freeway): The Marina Freeway runs east/west and is approximately
0.5 miles west of the Project Site and links Marina Del Rey to Culver City. Access to the Marina Freeway is available via Slauson Avenue and Centinela Avenue.
Roadways
• Hannum Avenue: Hannum Avenue is a designated Secondary Arterial that runs in the east-west direction and is located adjacent to the northern boundary of the Project Site. It provides four travel lanes, two in each direction. On -street parking is generally prohibited with in the Study Area. Travel lanes are typically 10 feet wide, and the total paved width is generally 75 feet. • Slauson Avenue: Slauson Avenue is a designated Primary Arterial that runs in the east-west direction and is located north of the Project Site. It provides six travel lanes, three in each direction. On-street parking is generally prohibited within the Study Area. Travel la nes are typically 10 feet wide and the total paved width ranges from 80 to 100 feet. • Bristol Parkway: Bristol Parkway is a designated Secondary Arterial that runs in the north- south direction and is located west of the Project Site. It provides four travel lanes, two in each direction, with a left-turn lane in the middle. On-street parking is generally pr ohibited within the Study Area. The total paved width ranges from 65 to 80 feet. • Buckingham Parkway: Buckingham Parkway is a designated Secondary Arterial that runs in the north-south direction and is located at the eastern boundary of the Project Site. It provides four travel lanes, two in each direction. Unmetered on -street parking is generally provided on both sides of the street south of Hannum Avenue with restrictions. The total paved width is generally 60 feet.
• Fox Hills Drive: Fox Hills Drive is a designated Local Street that runs in the north -south direction and is located southwest of the Project Site. It provides two travel lanes, one in each direction as well as left -turn lanes at intersections. On -street parking is general ly prohibited within the Study Area. The total paved width is generally 40 feet.
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• Uplander Way: Uplander Avenue is a designated Local Street that runs in the north -south direction and is located to the southwest of the Project Site. It provides two travel lanes, one in each direction. Metered on-street parking is generally provided on both sides of the street. The total paved width is generally 50 feet.
• Green Valley Circle: Green Valley Circle is a designated Secondary Arterial that runs in the east-west direction and is located south of the Project Site. It provides four travel lanes, two in each direction with left -turn lanes. Limited unmetered on -street parking is provide d on both sides of the street. The total paved width is generally 60 feet. • Centinela Avenue: Centinela Avenue is a designated Primary Arterial that runs in the east - west direction and is located west of the Project Site. It provides four travel lanes, two in each direction with left-turn lanes. A Class II bike lane follows both sides of the street from Green Valley Circle to Bristol Parkway. Limited unmetered on-street parking is provided on the south side of the street. The total paved width is generally 50 feet.
Public Transit
The Project Site and Study Area is served by five bus lines. These bus lines are listed below and identified in Figure 4.11-1, Existing Transit Service:
• Culver City Bus Line 2: Line 2 is a local east/west line weekday community circulator connecting Washington and Lincoln Boulevards with the Westfield Culver City Mall and Corporate Pointe. It also intersects with Metro lines and Santa Monica’s Big Blue Bus lines. • Culver City Bus Line 3: Line 3 is a local north/south route travel from Culver City Fox Hills to Century City. It runs adjacent to the Project Site along Buckingham Parkway/Hannum Avenue on both weekdays and weekends. Line 3 also provide s connection to Culver City Transit Center, the Culver Center , and the P alms neighborhood. The route intersects with six Metro bus lines, two Santa Monica’s Big Blue Bus lines and the five other Culver CityBus lines. It serves two major regional shopping centers: the Westfield Culver City Mall and the Century City Mall.
• Culver City Bus Line 5C2: Line 5 C2 i s a local weekday circulator route that connects Overland Ave and Fox Hills to Washington Blvd via Braddock Drive. Primary destinations include Culver City Middle School, Culver City High School, Downtown Culver City, the Hayden Industrial Tract and La Cienega Boulevard. This service only operates on weekdays and when school is in session.
• Los Angeles Metro Bus Local Line 108: Line 108 is an east/west line from Venice to Pico Riviera on weekdays and weekends, running predominantly along Slauson Avenue. Bus 108 also provides service to the Metro Rail A Line at Slauson Station, to the Metro Bus J Line at Slauson Harbor Transitway Station, Hyde Park K Line Station, Culver City Transit Center/Westfield Mall and Venice Pier. This service operates on weekdays and weekends. • Los Angeles Metro Bus Local Line 110: Line 110 is an east/west line from Playa Vista to Bell Gardens via Jefferson Boulevard and Gage Avenue. This service operates on weekdays and weekends.
The Culver City Transit Center is also located approximately 0. 6 miles west of the Project Site.
The Transit Center is not only serviced by Culver City Bus Lines 4, 6, and Rapid 6, but also Metro Lines 108/358 and 110.
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.11-1
Existing Transit Service
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Bicycle and Pedestrian Facilities
The City adopted the Culver City Bicycle & Pedestrian Action Plan in June 2020, which is comprised of a network of streets identified to prioritize bicyclists. and the Plan identifies Class I Shared-Use Paths, Class II Bicycle Lanes, Class III Bicycle Routes and Bike Boulevards, which provide sharrows and signage, and Class IV Separated Bikeways.
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.
Pedestrian access is provided via sidewalks located along Hannum Avenue, Buckingham Parkway, and Uplander Way.
Marked crosswalks, including traverse lines and continental crosswalks, are provided at most major intersections throughout the City, and are present at junctions within the study area. The sidewalks that serve as routes to the Project Site provide proper connectivity and adequate widths for a comfortable and safe pedestrian environment. The sidewalks provide connectivity to pedestrian crossings at signalized intersections within the study area.
Existing Project Site Vehicular Access
There is currently one driveway to access the Project Site along Hannum Avenue. Access is also available via Uplander Way via an easement across the adjacent property.
4.11.3 Environmental Impacts
Thresholds of Significance
The following significance thresholds below are based on the Environmental Checklist contained in Appendix G of the CEQA Guidelines. A project would result in a significant adverse impact related to transportation if it would:
• TRAF-1 Conflict with a program, plan, ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities; • TRAF-2 Conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b); • TRAF-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or • TRAF-4 Result in inadequate emergency access.
Methodology
The analysis of potential transportation impacts considers potential Project effects related to: 1) potential conflicts with transportation-related plans, ordinances or policies; 2) a substantial increase in VMT; 3) increased hazards due to a geometric design feature or incompatible use; and 4) emergency access.
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.11-2
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The scope of the analysis in the Transportation Study was developed in consultation with the City.
The base assumptions and technical methodologies (i.e., trip generation, study locations, analysis methodology, etc.) were identified as part of the study approach and were outlined in a MOU with the City and signed in July 2023 (see Appendix A of the Transportation Study). The subsections below describe the methodologies to evaluate each significance threshold.
Review for Conflicts with Plans, Programs, Ordinances, or Policies As noted in Section 4, CEQA Transportation Analysis Requirements of the TSCG, the TSCG requires review of whether a Project conflicts with transportation -related programs, plans, ordinances, and policies. The analysis addresses whether the Project would conflict with a program, policy, plan, or ordinance addressing the circulation system, including transit, roadways, bicycle, and pedestrian facilities. The focus is on policies or standards adopted to protect the environment and those that support multimodal transportation options and a reduction in VMT. If the Project does not implement a particular program, plan, policy, or ordinance, it would not necessarily result in a conflict as many of these programs must be implemented by the City itself over time, and over a broad area. Rather, the Project would result in a conflict if it would preclude the City from implementing adopted transportation-related programs, plans and policies. Furthermore, if a conflict is identified in association with the Project, under CEQA, it would only equate to a significant impact if precluding implementation of a given program, plan and policy would foreseeably result in a physical impact on the environment. 7 Regarding cumulative impacts, each of the plans, ordinances, and policies are reviewed to assess potential conflicts that may result from the Project in combination with other development projects in the Project’s study area. The analysis considers whether there would be a significant impact to the environment to which both the Project and related projects contribute. For instance, a cumulative impact could occur if the Project, as well as other future development projects located in the same project area, were to preclude the City’s ability to serve transportation user needs.
VMT Analysis
The City of Culver City developed a VMT Tool to assess the VMT impacts of proposed development projects within the City. The VMT Tool also assesses the effectiveness of selected TDM measures proposed for a project based on available research. With the City of Culver City as the lead agency, the VMT analysis follows the City of Culver City’s VMT procedures identified in the TSCG and VMT Tool.
The TSCG specifies Culver City’s VMT screening criteria for development projects. Per the criteria, if a development project meets any of the below VMT screening thresholds, it would be exempted from having to conduct VMT impact analysis to comply with CEQ A, and a less than significant impact is presumed.
1. Small projects that result in less than 250 daily or 25 peak hour trips.
7 The rule of general plan consistency is that the project must at least be compatible with the objectives and policies of the general plan. (Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 717–718 [29 Cal. Rptr. 2d 182].
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2. Projects within one -half mile from these key Transit Priority Areas (TPAs): Metro “E” Line Culver City Station, Metro “E” Line La Cienega Station, Westfield-Culver City Transit Center, or Sepulveda/Venice Boulevard intersection.
3. Projects located within any TPA where at least 15% of the on-site residential units are affordable.
4. Affordable housing projects where 100% of the dwelling units are affordable.
5. Local serving retail projects having less than 50,000 sf in size at a single store.
Since the Project does not meet any of the criteria, the Guidelines provide guidance for the further analysis of VMT, as discussed below.
The following details the methodology that vehicle trips and VMT are calculated in Culver City VMT Tool (October 2021) (VMT Calculator), as detailed in the Guidelines. The VMT Calculator estimates the project-specific daily number of trips as well as the daily household VMT per capita and daily work VMT per employee for developments within City limits.
As noted in Section 4B of the Guidelines, small-scale retail/restaurant components less than 50,000 sf of larger mixed -use development projects are not considered for the purposes of identifying significant work VMT per employee impacts, as those trips are assumed to be local serving and would have a negligible effect on VMT.
Table 2 of the Guidelines, as presented below, shows the citywide VMT thresholds by type of land use. Note that the table was modified to include the current threshold values for the City.
Use Metric Threshold Threshold Value
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VMT/capita
15% below existing levels
(Existing level = 8.3)
7.1 Work Daily home-based-work
VMT/employee
15% below existing levels
(Existing level = 10.1)
8.6 Regional Retail Total VMT Any net positive change in citywide VMT
N/A
The Project consists of residential and neighborhood serving retail uses, under 50,000 sf in size.
Transportation Demand Management
A TDM Program consists of strategies that are aimed at discouraging single-occupancy vehicle trips and encouraging alternative modes of transportation, such as carpooling, taking transit, walking, and biking. Strategies included in a typical TDM Program address a wide range of transportation factors, including parking, transit, commute trips, shared mobility, bicycle infrastructure, site design, education and encouragement, and management.
Geometric Design Feature or Incompatible Use Hazards
For vehicle, bicycle and pedestrian safety impacts, a review is conducted for all Project access points, internal circulation, and parking access from an operational and safety perspective (e.g., turning radii, driveway queuing, line-of-sight for turns into and out of project driveway[s]). Where
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Project driveways would cross pedestrian facilities or bicycle facilities (bike lanes or bike paths), the analysis considers operational and safety issues related to the potential for auto/pedestrian and auto/bicycle conflicts and the severity of consequences that could result.
Emergency Access
For emergency access impacts, a review is conducted for Project access points, internal circulation, and parking access to determine if adequate emergency access is provided. The analysis considers the physical conditions of the Project Site and surrounding area, such as curves, slopes, walls, landscaping or other barriers. Also, a determination is made as to whether the Project would preclude adequate emergency access within the adjacent roadway network.
Project Design Features
The following project design features are applicable to the Project:
TRAF-PDF-1: Construction Management Plan. A Final Construction Management Plan (FCMP) will be prepared by the Project contractor in consultation with the Project's traffic and/or civil engineer. The F CMP will define the scope and scheduling of construction activities covering the entire Project Site as well as the Applicant's proposed construction site management responsibilities in order to ensure that disturbance of nearby land uses or interruption of pedestrian, vehicle, bicycle and public transit are minimized to the extent feasible. The FCMP will be subject to review and approval by appropriate building officials, city traffic engineers, civil engineers, and planning managers for the City of Culver City, as required, prior to issuance of any Project demolition, grading or excavation permit. The FCMP will also be reviewed and approved by the respective fire and police departments.
Prior to commencement of construction, the contractor will advise the City’s public works inspector and building inspector (inspectors) of the construction schedule . As-needed construction management meetings shall be convened with appropriate Culver City staff and representatives of surrounding developments that may have overlapping construction schedules with the Project, to ensure that concurrent construction projects are managed in collaboration with one another. The FCMP will consider potential project construction disruptions to transportation facilities near the Project Site and provide effective strategies to limit the Project’s use of the public right -of-way (streets and sidewalks) during peak traffic periods and will be subject to adjustment by City staff as deemed necessary and appropriate to preserve the general public safety and welfare.
Prior to approval of the FCMP and grading permits, the Applicant will conduct one (1) community meeting, to discuss and provide the following information to the surrounding community:
1. Construction schedule and hours.
2. Framework for construction phases.
3. Identify traffic diversion plan by phase and activity.
4. Potential location of construction parking and office trailers.
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5. Truck hauling routes and material deliveries (i.e., identify the potential routes and restrictions. Discuss the types and number of trucks anticipated and for what construction activity).
6. Emergency access plan.
7. Demolition plan.
8. Staging plan for the concrete pours, material loading and removal.
9. Crane location(s).
10. Accessible Applicant and contractor contacts during construction activity and during off hours (relevant email address and phone numbers).
11. Community notification procedures.
The FCMP will at a minimum include the following:
1. The name and telephone number of a contact person who can be reached 24 hours a day via telephone regarding construction or construction traffic complaints or emergency situations.
2. An up-to-date list of local police, fire, and emergency response organizations and procedures for the coordination of construction activity, potential delays, and any alerts related to unanticipated road conditions or delays, with local police, fire, and emergency response agencies. Maps showing access to and within the site and to adjacent properties will be provided.
3. Construction plans and procedures to address community concerns the City of Culver City personnel notification of key construction activities; temporary construction fencing and maintenance of construction areas within public view; noise and vibration controls; dust management and control; and worker education on required mitigation measures included in the Project’s Mitigation Monitoring Program and best practices to reduce disturbances to adjacent and nearby land uses.
4. Procedures for the training and certification of flag persons.
5. To the extent known, identification of the location, times, and estimated duration of any roadway closures; procedures for traffic detours, pedestrian protection, reducing effects on public transit and alternate transportation modes; and plans for use of protective devices, warning signs, and staging or queuing areas.
6. The location of temporary power, portable toilet and trash and materials storage locations.
7. The timing and duration of any street, sidewalk and/or lane closures will be approved in advance by ethe City of Culver City. As traffic lane, parking lane, and/or sidewalk closures are anticipated, worksite traffic control plan(s), approved by the City of Culver City, will be developed and implemented to route vehicular traffic, bicyclists, and pedestrians around any such closures. As applicable at the time of construction, such notices will be made available in digital format for posting on each City website and distribution via email alerts on electronic platforms such as the County of Los Angeles’ "Gov Delivery" system. The FCMP will be updated weekly during the duration of project construction, as determined necessary by the City. The FCMP will require that review and approval of any proposed lane closures include coordination
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with the Culver City Fire and Police Departments to minimize potential effects on traffic flow and emergency response.
8. Provisions that staging of construction equipment and materials will be accommodated within the Project Site and that construction worker parking will be accommodated on the Project Site and/or at off-site locations to be determined and disclosed, potentially with shuttles to and from the Project Site.
In addition, the Project proposes voluntary measures to reduce drive-alone vehicle trips to/from the Project Site as part of a TDM Program. The TDM Program would offer a wide variety of options to support employees who choose to use a commute alternative to reach their destination. This program is designed to make non-automobile commutes attractive and viable options by providing employees with mobility once they arrive at work, access to needed services during the day, or financial incentives to participate. The Project will implement the following project design feature:
TRAF-PDF-2: Transportation Demand Management (TDM) Program. The Project will implement TDM measures that include, but are not limited to, those listed below subject to Culver City Transportation Department review and approval prior to issuance of the first Temporary Certificate of Occupancy (TCO) for the Project in order to reduce drive-alone vehicle trips to/from the Project Site by residents, visitors and employees, as well peak hour traffic. The TDM strategies necessary comply with the TDM and trip reduction requirements of City Municipal Code Section 07.05.015, as well as City’s design requirements for the Project:
On-
Site Enhancements - The Project design will incorporate mobility features to encourage alternative transportation modes. The features will be designed in accordance with the City Municipal Code requirements and standards. • Pedestrian Connections. The Project will p rovide exclusive pedestrian access separate from vehicular driveways. The Project will provide internal walkways that connect the pedestrian access points to off-site pedestrian facilities, rideshare, and transit. • Bicycle Parking and Amenities. The Project wi l l provide both short -term and long- term bicycle parking spaces on -site in accordance with the City Municipal Code requirements. Short -term bicycle parking, which will include bicycle racks, will be located near the pedestrian entrance. Long -term bicycle parking, which will include bicycle lockers or secure bicycle enclosures, will be placed in an accessible weather protected location.
Electric Vehicle (EV) Parking . In
accordance with City Municipal Code Section
17.320.035.O.3, at least 40% of the onsite parking supply will have EV capability, including EV Capable spaces (20%), EV Ready spaces (10%), and Full EV Charger/Charging Stations (10%).
Off-Site Enhancements - T
he Project will improve and contribute toward improvements to off-site mobility facilities to encourage alternative transportation modes. • Mobility Fees. I n accordance with City Municipal Code Section 05.06.015, the Project will be subject to contributing its fair share toward funding the City's mobility infrastructure and improvement projects intended to reduce VMT and support housing and job growth. Pursuant to Resolution No. 2021-R055, the total mobility fee for th e Project will be based on a rate of $3,394 per multi -family unit and $14.92 per sf of commercial space.
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Other TDM Strategies - The Project will implement TDM strategies to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The following details the minimum TDM strategies necessary to comply with the TDM and trip reduction requirements of City Municipal Code Section 07.05.015, as well as City’s design requirements for the Project:
• Transportation Information Center (TIC). Th
e Project will provide a TIC, a commuter
information center where residents, employees, and visitors can obtain information regarding commute programs and individuals can obtain real -time information for planning travel without using an automobile. A TIC provides information about transit schedules, commute planning, rideshare, telecommuting, bicycle routes and facilities, and facilities and resources for carpoolers, vanpoolers, bicyclists, transit riders, and pedestrians. The TIC can be provided via a bulletin board, display case, or kiosk, as well as virtually, providing every resident, employee, and visitor access to commuter information through a website portal.
• Bicycle Parking and Amenities. The Project will support bicycling to work through the provision of bike storage facilities throughout the Project site. Bicycle parking will be provided in accordance with the City Municipal Code requirements for the Project and will include short-term fa cilities (e.g., bicycle racks) and secure long -term bicycle parking (e.g., fully enclosed rooms or bicycle lockers that protect the bicycle from inclement weather and accessible only to the owner).
• Pedestrian-Friendly Environment . The Project is designed to be pedestrian-friendly and accessible to the local neighborhood. The Project’s pedestrian access points will be located separate from vehicular access points. To promote walkability within and around the Project site, internal pedestrian pathways will provide a safe and direct connection to external public pedestrian facilities. Safety measures will also be implemented at the Project driveway to ensure safe crossings to limit potential vehicular-pedestrian conflicts.
• Employee Parking. At least 10% of employee parking will be reserved, as signed on the spaces, for use by potential carpool or vanpool vehicles and located as close as practical to employee entrances. This preferential parking will be identified on the site plan accompanying the application for a building permit. Vanpool spaces will have a minimum parking space dimension of nine feet wide by 18 feet in length and provide a minimum interior vertical clearance of eight feet two inches. A safe and convenient zone in which vanpool and carpool vehicles may deliver or board their passengers will also be provided.
• Bus Stop Improvements. If deemed necessary by the City, bus stop improvements will be provided to the satisfaction of the City Director of Transportation.
Plan/Program Management - T he Project will take appropriate measures to help future residents and employees manage each TDM Plan element and maximize program participation through consolidation of information and proactive engagement. The following will be provided as part of the TDM Plan:
• Project Transportation Coordinator. A Transportation Coordinator will be designated for the site and will be responsible for implementing, coordinating, and maintaining the elements of the TDM Plan. The identity and contact information for the Transportation Coordinator will be supplied to the City and kept current.
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• Transportation Information Packet for New Residents and Employees . Each new resident and employee will receive an information packet summarizing the transit and transportation alternatives available to Project tenants. The packet will emphasize the location of the TIC and include the contact information of the Transportation Coordinator.
Mobility Hub Support and Alternative Transportation - Th e Project will incorporate measures and design elements to support first-mile/last-mile service connection for transit users and reduce reliance on personal automobiles. The following will be provided as part of the TDM Plan:
• Bike Repair Station. The Project will provide an on-site bike parking station for use by Project residents and employees that has a space and basic tool set for bike repairs. • Subsidized Shared- Ride/Uber/Lift Service. Employees who arrive to work via a means other than a single -passenger vehicle or utilize the carpool matching service will automatically be registered in a Subsidized Shared -Ride/Uber/Lift Service by which, upon request to the Transportation Coordinator, the employee will be given a voucher to travel home or Uber/Lyft (or similar shared ride service) in case of illness or emergency. The Project will provide up to $750 in total for this program every year.
The subsidy will be for two years after Certificate of Occupancy over a two -year period.
• Transit Passes. The Project will provide up to $500 per pass per year of subsidies for up to five Transit Access Passes (TAP) cards for a period of three years for employees who opt to take Metro instead of personal vehicles and will not be provided on-site parking accommodations and not receive a car share subsidy.
Analysis of Project Impacts
Threshold TRAF-1: The Project would have a potentially significant impact on transportation if it would conflict with a program, plan, ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities.
Impact Analysis
As previously noted, the TSCG includes a list of transportation-related programs, plans, ordinances, and policies that should be consulted to identify the potential for conflicts with the Project. Upon review of the listed plans, the following were determined relevant to the Project and are analyzed in the Transportation Study and this Draft EIR: the City’s General Plan Circulation Element, the Culver City Short Range Transit Plan, the Bicycle and Pedestrian Action Plan, the Complete Streets Policy, the NTMP Procedures Manual , Residential Parkway Guidelines, the Local Road Safety Plan and Vision Zero.
The analysis below includes a consistency analysis with the plans, policies and programs determined to be applicable to the Project.
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General Plan Circulation Element
The Circulation Element includes numerous policies that are applicable to the Project. Table 4.11-1, Consistency of the Project with Applicable Policies of the Circulation Element, provides determinations of whether the Project would conflict with any of the applicable policies in the Circulation Element. As shown therein, the Project would not conflict with any of the applicable policies.
TABLE 4.11-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE POLICIES OF THE CIRCULATION ELEMENT Policy Would the Project Conflict?
1.A. Facilitate movement of vehicles at intersections and along roadway links by increasing capacity, improving
operation, and reducing volumes as appropriate and
feasible.
No Conflict. The Project would provide a mixed-use
development, allowing residents within the Project Site and in nearby areas to access retail services in the Project Site by walking or reducing the need to drive longer distances.
1.F. Reduce driveways and curb cuts on arterials in favor of side street and alley access, where appropriate,
considering potential impacts on the neighborhoods
served by the side streets.
No Conflict. The Project Site is bordered by Hannum
Avenue and Buckingham Parkway, which are both
Secondary Arterials, not Primary Arterials. Only one
ingress/egress driveway would be provided along each
roadway. With two driveways, vehicle traffic and queuing would be minimized as Project traffic would be dispersed among the two driveways. Regardless, the driveways and
associated Project traffic would not substantially impede traffic for neighboring land uses.
2.C. Maintain levels of transit service that are adequate to meet and encourage ridership demand.
No Conflict. The Project includes a mix of commercial and residential land uses adjacent to frequently running transit lines, which would encourage ridership. The proposed TDM Program, would also encourage ridership through provision of a TIC, a commuter information center where residents, employees, and visitors can obtain information regarding commute programs and individuals can obtain real-time
information for planning travel without using an automobile.
2.H. Encourage public transit links to sites of high trip- generating uses to maximize transit use by patrons and
employees.
No Conflict. The Project includes a mix of commercial and residential land uses adjacent to frequently running transit lines, which would encourage ridership. The proposed TDM Program would also encourage ridership through provision of a TIC, a commuter information center where residents, employees, and visitors can obtain information regarding commute programs and individuals can obtain real-time
information for planning travel without using an automobile.
3.D. Seek public and private contributions to provide
support facilities for bicycle users (such as racks, secure storage, drinking fountains, etc.) where bikeways connect to turnouts, parks, and other open space areas, as
appropriate.
No Conflict. The Project would provide a total of 92 bicycle spaces, consisting of 11 short-term and 81 long-term
bicycle parking spaces in compliance with CCMC
requirements. Additionally, bicycle rooms or lockers would be provided for residents and employees.
3.G. Encourage large business, commercial centers, and
industrial parks to include bicycle lockers, or other secure bicycle storage and related facilities, to support bicycle commuting by employees.
No Conflict. The Project would provide a total of 92 bicycle spaces, consisting of 11 short-term and 81 long-term
bicycle parking spaces in compliance with CCMC
requirements. Additionally, bicycle rooms or lockers would be provided for residents and employees.
4.C. Provide safe and attractive pedestrian
walkways/sidewalks which link streets and parking areas to the entrances of major developments.
No Conflict. The Project would provide new sidewalk and pedestrian facilities around and through the Project Site, as well as the Hannum Plaza which entails the first level
outdoor area with seating outside the retail area at the intersection of Buckingham Parkway/ Hannum Avenue. The
pedestrian facilities would be beautified by high quality architecture and ample landscaping and open space.
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TABLE 4.11-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE POLICIES OF THE CIRCULATION ELEMENT Policy Would the Project Conflict?
4.D. Enhance the aesthetic qualities of pedestrian access routes by increasing amenities, such as trees, awnings, lighting, street furniture, and drinking fountains, etc.
No Conflict. The Project would enhance the Project
frontage sidewalks with street trees, lighting, and aesthetic treatments on building facades. Proposed signage would be designed to be aesthetically compatible with the existing and proposed architecture of the Project Site and would comply with the requirements of the CCMC. Hannum Plaza, the first level outdoor area with seating along Hannum
Avenue and outside the retail area at the intersection of Buckingham Parkway/Hannum Avenue would be open to
the public, with the site’s other first level areas available to Project residents. Seating areas would be placed
throughout Hannum Plaza to create spaces for rest, open to the community. Outdoor spaces would include lounge
seating, gathering spaces, and small speakers installed in discreet areas to be used for low volume ambient sound
and music.
6.B. Reduce pressure on on-street parking through
provision of private and public off-street parking facilities.
No Conflict. The Project would provide an adequate
amount of parking according to the CCMC and California
Government Code. The Project would provide 428 vehicular parking spaces on the Project Site with 405 spaces for
residential uses and 23 spaces for commercial uses. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready. Forty- four (44) total spaces (41 residential + 3 commercial) would have EV charging stations.
SOURCE: ESA, 2023.
Culver City Short Range Transit Plan
The SRTP provides a service analysis of the current fixed route service and the impact of local and regional transit projects, and evaluation of main corridors and the on-demand services offered, such as Dial-A-Ride and microtransit. The SRTP focuses on public transportation services, enhancing fixed route and paratransit services, expanding micro mobility with scooters and bikes, and offering microtransit services. While the implementation of the SRTP is largely within the purview of the City rather than private developers, the Project would not preclude the implementation of the SRTP, and improvements made in the plan would likely enhance transit alternatives for residents and visitors to the site. Therefore, the Project would not conflict with the SRTP.
Culver City Bicycle & Pedestrian Action Plan
The Action Plan establishes 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, accessible by users of all ages and abilities. Table 4.11-2, Consistency of the Project with Applicable Actions of the Culver City Bicycle & Pedestrian Action Plan, provides determinations of whether the Project would conflict with any of the applicable actions of the Action Pla n. As shown therein, the Project would not conflict with any of the applicable actions.
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TABLE 4.11-2
CONSISTENCY OF THE PROJECT WITH APPLICABLE ACTION OF THE CULVER CITY BICYCLE &
PEDESTRIAN ACTION PLAN
Action Would the Project Conflict?
AC-1.2. Increase the supply of bicycle parking at
neighborhood destinations like schools, medical centers, grocery stores, transit stations, and government offices No Conflict. The Project would provide both short-term
visitor and long-term tenant bicycle parking for the proposed residential and retail uses.
HS-3.2. Use current design guidelines to encourage
development patterns that promote active transportation and allow for short trips between destinations.
No Conflict. The Project would develop a mixed-use
building that encourages pedestrian trips and shorter trips between destinations. It also provides local serving retail to shorten trips for other residents of the area. Additionally, the proposed Buckingham Parkway driveway would intersect
with the proposed southbound bicycle lane on Buckingham Parkway based on the proposed project design. However,
the Project would meet City guidelines for driveway design and visibility, ensuring maximum visibility would be provided for all road users, including bicycles, pedestrians, and motorized vehicles. Furthermore, the Project would not
preclude the installation of a bicycle lane on Buckingham Parkway or any other street within the Study Area that has been identified for bicycle and/or pedestrian improvements.
The Project would also support active modes of
transportation by providing bicycle parking and improving the pedestrian facilities adjacent to the Project frontage.
Action HS-4.1: Build an active transportation network
that encourages Culver City residents to use means of
transportation other than driving by providing safer, more comfortable biking and walking facilities.
The Project supports this action by implementing 92 bicycle parking spaces, including spaces for employees and
visitors, short-term spaces, and long-term spaces. The
Project Site frontage designs and access points would not preclude the implementation of the planned Class IV
separated bikeway planned along Buckingham Parkway
fronting the Project Site, or any other planned high-quality bicycle facilities. During the design of a new bicycle facility, planners and engineers will take into account existing and planned site access needs and accommodate those needs
by employing best practices to alert all road users to the potential mixing zones and conflict areas with geometric design, signage and striping. The Project would also
enhance pedestrian circulation and promote an active
streetscape on both Hannum Avenue and Buckingham
Parkway, featuring the Hannum Plaza, through increased
sidewalk widths, enhanced parkway landscape and street
trees along the site frontage.
SOURCE: ESA, 2023.
Complete Streets Policy
The City’s adopted Complete Streets Policy includes numerous policies that are applicable to the Project. Table 4.11-3, Consistency of the Project with Applicable Policies of the Complete Streets Policy, provides determinations of whether the Project would conflict with any of the applicable policies in the Complete Streets Policy. As shown therein, the Project would not conflict with any of the applicable policies and programs.
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TABLE 4.11-3
CONSISTENCY OF THE PROJECT WITH APPLICABLE POLICIES OF THE COMPLETE STREETS POLICY Policy Would the Project Conflict?
5.a.i. The City will plan, design, operate, and maintain a transportation system that provides a connected network of streets and facilities that accommodate all modes of travel.
The City will actively seek opportunities to repurpose or enhance rights-of-way to improve connectivity for
pedestrians, bicyclists, and transit users.
No Conflict. The Project supports this policy by
introducing 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.
5.a.ii. The City will pursue enhancements to the bicycle and pedestrian connectivity to public transit services, as well as to schools, parks, service retail, public facilities, regional connections, and business districts.
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.
5.a.iii. The City will require larger-scale developments and redevelopment projects to maintain or enhance connectivity, such as through interconnected street networks with small blocks, walkways and bikeways. The City will require smaller projects to maintain or enhance walkways and bikeways
when practical.
No Conflict. The Project Site is one contiguous parcel
not separated smaller, blocks, walkways or parkways.
The Project would provide internal walkways available to Project residents and sidewalks along the Project street frontages, with enhanced streetscape, landscape and
street trees.
5.b.viii. The City will promote strong community identity through the implementation of streetscape plans, including street trees, pedestrian-scale lighting, street furniture, and other streetscape elements.
No Conflict. The Project supports this policy by
introducing development that is conducive to walking.
The Project would enhance pedestrian rights-of-way by
introducing increased sidewalk widths, publicly available open space as part of the Hannum Plaza, and enhanced
streetscape, pedestrian-scale lighting, landscape and
street trees along Hannum Avenue and Buckingham
Parkway.
5.b.xi. The City will require appropriate accommodations for pedestrians and bicyclists during construction activities in the public right-of-way. Whenever feasible, the City will not permit the closure of sidewalks or bikeways.
No Conflict. The Project will implement a Construction
Management Plan (CMP) per Project Design Feature
TRAF-PDF-1. Consistent with this policy, the CMP will
provide appropriate accommodations to ensure
pedestrians and bicyclists can safely navigate around
the Project Site. Any temporary closure of sidewalks
closure or traffic lanes would be minimized by the CMP.
5.d.ii. The City will coordinate street improvements with business owners along retail and commercial corridors to develop or enhance vibrant business districts.
No Conflict. The Project would provide a development
that is conducive to walking, biking, and taking transit.
The Project would enhance pedestrian rights-of-way by
introducing street facing retail and landscaping along the sidewalks. Pedestrian connectivity throughout the
Project Site would be enhanced with internal walkways
connecting to existing sidewalks.
SOURCE: ESA, 2023
Residential Parkway Guidelines
Consistent with the City’s Culver City Residential Parkway Guidelines (2016), the Project would maintain applicable parkway space adjacent to on-site properties, with the exception of street trees, which are maintained by the City. As applicable and determined necessary in consultation with
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the City, sidewalk access and step -out strips would to be installed and maintained along Buckingham Parkway.
Neighborhood Traffic Management Program (NTMP) Procedures Manual The City adopted a series of procedures for the implementation of NTMPs, as defined in its NTMP Procedures Manual (November 22, 2004). The program requires a series of actions by the neighborhood and City/Engineering Division to determine the traffic issues, study them, develop a plan, test proposed improvements, and finalize the plan. No streets would be considered significantly affected with the addition of Project-related traffic. Furthermore, the Project is not projected to lead to trip diversion along residential Local Streets, nor is the Project projected to add a substantial amount of automobile traffic to congested Arterial Streets that could potentially cause a shift to residential Local Streets. Therefore, the Project would not be required to propo se an NTMP for the surrounding residential neighborhoods. In addition, the Project would not conflict with the Fox Hills NTMP or preclude any measures identified therein from being installed.
Local Road Safety Plan
The City’s Local Roadway Safety Plan (November 2021 ) enables the City to determine potential traffic safety projects on roadways and intersections within the City. In an effort to eliminate fatal and severe injury collisions, the document provides a comprehensive collisions analysis through the LRSP to identify high-risk corridors and intersections with the highest collision frequency and severity. Of the several high-risk intersections and street segments identified in the plan, none are located adjacent t o the Project Site. Thus, the Project would not preclude the City from implementing improvements to eliminate fatal and severe injury collisions as part of the LRSP.
Vision Zero
The City adopted the Vision Zero initiative in 2016 and has incorporated policies and infrastructure improvements into Culver City Bicycle & Pedestrian Action Plan. None of the streets located on the City’s HIN are located adjacent to the Project Site and no Vision Zero improvements have been proposed adjacent to the Project Site, as of June 2023. Nevertheless, the Project would not preclude future Vision Zero Safety Improvements by the City. Thus, the Project does not conflict with Vision Zero.
Based on the above, the Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.
Therefore, 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. Project -specific impacts related to conflict s with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities would be less than significant.
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Threshold TRAF-2: The Project would have a potentially significant impact on transportation if it would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b).
Impact Analysis
The Project is estimated to generate a total of 1,462 daily vehicle trips and a total daily VMT of 10,504. Additional details regarding the VMT analysis are available in Appendix C of the Transportation Study, which is provided in Appendix I of this Draft EIR. As noted above under the Methodology section, small-scale retail/restaurant components less than 50,000 sf of larger mixed- use development projects are not considered for the purposes of identifying significant work VMT per employee impacts, as those trips are assumed to be local serving and would have a negligible effect on VMT. The Project consists of residential and neighborhood serving retail uses, under 50,000 sf in size which meant no further analysis was required for the retail component as it is neighborhood serving.
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. This figure does not account for any project design features. Nonetheless, as previously detailed, the Project would implement strategies and action plans as part of a comprehensive TDM program (See Project Design Feature 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. Thus, the Project would have a less than significant impact on household VMT per capita as estimated by the VMT Calculator. Although mitigation measures would not be required due to the Project falling below Citywide VMT thresholds, this impact would be further reduced through implementation of TRAF-PDF-2.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
Level of Significance After Mitigation
Not applicable. The Project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) and impacts would be less than significant.
Threshold TRAF-3: T he Project would have a potentially significant impact on transportation if it would substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).
Impact Analysis
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. T he Buckingham Driveway would be restricted to residential vehicles only on levels P1 and P2. Pedestrian access to the Project would be provided via separate lobby and retail entrances along Hannum Avenue.
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The section of Hannum Avenue along which the Hannum Driveway is situated provides four travel lanes, two in each direction, and metered parking on the south side of the street. With development of the Project, a few on -street parking spaces adjacent to the Project may be removed to accommodate the Hannum Driveway. Sidewalks are provided along the northern boundary of the Project Site. 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.
The section of Buckingham Parkway along which the Buckingham Driveway is situated provides two travel lanes, one in each direction, and a two -way left-turn median. Unmetered parking is generally available on both sides of the street; however, a few spaces may be lost to accommodate the Buckingham Driveway and loading area on Buckingham Driveway adjacent to the entry driveway. Sidewalks are provided along the eastern boundary of the Project Site. 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. As previously mentioned, the design for this bicycle lane has not been finalized. However, the Buckingham Driveway would intersect the southbound bicycle lane on the west side of Buckingham Parkway. Similar to the Hannum Driveway, the Buckingham Driveway would ensure maximum visibility by meeting all of the City’s driveway 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.
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. The Buckingham Driveway would be restricted to residential access only.
No unusual or new obstacles are presented in the Project design that would be considered hazardous to motorized vehicles, non -motorized vehicles, or pedestrians. Access to the Project would be consolidated to two driveways in order to minimize potential hazards to pedestrians, bicyclists, and motorists along Buckingham Parkway and Hannum Avenue. All driveways will be subject to review by the City.
Furthermore, based on the trip generation estimates detailed in Appendix I , the Project would generate fewer than two vehicles per minute at either driveway. Thus, pedestrians and bicyclists would have adequate gaps in vehicular traffic at the driveways to safely cross and the Project is unlikely to result in an increase in vehicle -pedestrian and vehicle-bicycle conflicts. Additionally, Metro Line 108 has a bus stop located adjacent to the Project Site along Buckingham Parkway. As neither proposed driveway would interfere with the bus stop operation and adequate sight distance would be provided to ensure visibility between buses and vehicles at the driveway, no impact to transit activity or access would occur.
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In addition, the Project Site is located on a sloping parcel that is generally level with some grade, along the Buckingham frontage with only slight changes in vertical elevation. Therefore, no line - of-sight issues would be caused by changes in elevation, and drivers would be able to safely identify approaching vehicles, pedestrians, and bicycles at both driveways. The driveways are designed to intersect the public ROW at right angles to the extent possible, with adequate building setback to allow pedestrians and bicyclists to observe vehicles within either driveway. Finally, the Project would be compatible with the surrounding residential uses to the east and south. Furthermore, no elements of the Project’s uses or design would be considered incompatible.
Based on the above, the Project would have a less than significant impact regarding hazards due to geometric design features or incompatible uses.
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 design hazards and incompatible uses would be less than significant.
Threshold TRAF-4: T he Project would have a potentially significant impact on transportation if it would result in inadequate emergency access.
Impact Analysis
The Project Site is located within an urbanized area with a fully developed roadway system. Direct emergency access is provided by each of the two streets bordering the Project Site, including Hannum Avenue and Buckingham Parkway. Emergency access is also available from Uplander Way through a shared access easement adjacent to the western boundary of the Project Site.
Construction of the Project is not anticipated to require road closures in public right-of-way; and it is feasible that construction staging would be within the Project Site. Construction traffic would be temporary and short -term and would cease after construction is completed. If required, the Project’s contractor would implement construction traffic management measures to ensure that access for all road users is maintained near the Project Site and limit potential conflicts with traffic on local streets. In addition, emergency vehicle access to the Project Site and neighboring land uses would be maintained, and worker and construction equipment delivery would be scheduled to avoid peak traffic hours. Furthermore, Project construction contractors would coordinate with the Culver City Police Department (CCPD) and Culver City Fire Department (CCFD) concerning any planned temporary lane closures and other construction activities that could affect emergency access and emergency response times and arrange for traffic control devices and detours to minimize any potential impacts to traffic. Because of the short -term nature of the construction activities, the Project’s construction activities would not require a new, or significantly interfere with an existing risk management, emergency response, or evacuation plan. The Project would not resul t in inadequate emergency access during construction.
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Regarding Project operation, CCMC Chapter 17.540 requires that new projects be reviewed by the CCPD to ensure that public safety and site security measures are incorporated. Furthermore, as a condition of approval, CCFD would review and approve plans for the building, fire lanes, fire hydrant locations, and associated equipment, to ensure adequate access to and within the Project Site for emergency vehicles. Furthermore, pursuant to California Vehicle Code Section 21806, the drivers of emergency vehicles ar e generally able to avoid traffic in the event of an emergency by using sirens to clear a path of travel or by driving in the lanes of opposing traffic. Accordingly, emergency access would be maintained during operation of the Project. Therefore, Project operation would result in a less than significant impact in this regard.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
Level of Significance After Mitigation
Not applicable. The Project would not result in inadequate emergency access and impacts would be less than significant.
Cumulative Impacts
Chapter 3, Environmental Setting, of this Draft EIR provides a list of 12 related projects (eight in the City and four in the City of Los Angeles) that are planned or are under construction within an approximately 1.5-mile radius of the Project Site . These projects are summarized in Table 3 -1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3. As shown in Figure 3-1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles.
As discussed under Threshold TRAF -1, the Project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities, which have been adopted to protect the environment and reduce VMT. Each of the related projects considered in this cumulative analysis of consistency with programs, plans, policies, and ordinances would be separately reviewed and approved by the City, including a check for their consistency with applicable policies. Collectively, the Project and the related projects would add development and density in an area with robust transit accessibility and high levels of pedestrian activity. As with the Project, related projects would be expected to support, incl ude and/or enhance pedestrian, bicycle, and/or other alternative transportation facilities, thus, increasing access to the City’s multi-modal transportation network. Thus, the Project and the related projects would not preclude the City’s ability to serve transportation needs as defined by the City’s transportation policy framework. Therefore, the Project, in combination with the related projects, would not create inconsistencies or result in cumulative impacts with respect to the identified programs, plans, policies, and ordinances.
As the Project would generate per capita and per employee VMT that are below the City’s thresholds of significance resulting in a less-than -significant impact on VMT a nd would consequently be consistent with the 2020-2045 RTP/SCS VMT reduction goals, the Project would
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similarly result in a less -than-significant impact on VMT in cumulative conditions, and further analysis is not necessary.
With regard to design hazards, the Project would result in a less than significant impact for geometric hazards. Each related project would be reviewed by the City to ensure compliance with the City’s requirements relative to the provision of safe access for vehicles, pedestrian, and bicyclists, which would incorporate standa rds for adequate sight distance, sidewalks, crosswalks, and pedestrian movement controls to protect pedestrian and enhance bicycle safety. Furthermore, since modifications to access and circulation plans are largely confined to a project site and immediate surrounding area, a combination of impacts with other related projects that could potentially lead to cumulative impacts is not expected. Therefore, the Project’s contribution to cumulative impacts associated with hazardous design conditions would not be considerable.
With regard to emergency access, the Project would not result in a significant impact. The Project Site and the surrounding area are located in an established urban area that is well -served by the surrounding roadway network, and multiple routes exist in t he area for emergency vehicles and evacuation. Drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic. Similar to the Project, relate d projects would likely also implement a Construction Management Plan to ensure adequate emergency access is maintained in and around the related project sites throughout all construction activities. Coordination of these plans would ensure construction activities of the concurrent related projects and associated hauling activities are managed in collaboration with one another and the Project. Furthermore, each of the related projects would be required to coordinate with CCFD and CCPD for site plan reviews and to ensure that emergency access is maintained at all times.
As such, cumulative impacts on transportation 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 population and housing would be less than significant.
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4.12 Tribal Cultural Resources
4.12.1 Introduction
This section evaluates potential impacts on tribal cultural resources. The analysis is based on a Sacred Lands File (SLF) search conducted by the California Native American Heritage Commission (NAHC), consultations between the City and Native American tribes, as well as the 5700 Hannum Avenue Mixed-Use Residential and Commercial Project – Archaeological Resources Assessment Report (Archaeological Report) prepared by ESA, 1 that is provided in
Appendix D of this Draft EIR. Confidential Native American consultation documentation materials provided by the Gabrieleño Band of Mission Indians –Kizh Nation is maintained by the City in a confidential appendix, which is referenced in this section, but not included.
4.12.2 Environmental Setting
Regulatory Framework
The following describes the primary State regulatory requirements (Assembly Bill 52 and Senate Bill 18) applicable to the Project.
Assembly Bill 52
Assembly Bill (AB) 52 was approved on September 25, 2014. The act amended California Public Resources Code (PRC) Section 5097.94, and added PRC Sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, and 21084.3. The primary intent of AB 52 is to involve California Native American Tribes early in the environmental review process and to establish a category of resources related to Native Americans, known as tribal cultural resources, that require consideration under CEQA. PRC Section 21074(a )(1) and (2) defines tribal cultural resources as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American Tribe” that are either included or determined to be eligible for inclusion in the California Register or included in a local register of historical resources, or a resource that is determined to be a tribal cultural resource by a lead agency, in its discretion and supported by substantial evidence. A tribal cultural resource is further defined by PRC Section 20174(b) as a cultural landscape that meets the criteria of subdivision (a) to the extent that the landscape is geographically defined in terms of the size and scope of the landscape. PRC Section 20174(c) provides that a historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource” as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if i t conforms with the criteria of subdivision (a).
PRC Section 21080.3.1 requires that, within 14 days of a lead agency determining that an application for a project is complete, or a decision by a public agency to undertake a project, the lead agency provide formal notification to the designated contact, or a tribal representative, of California Native American Tribes that are traditionally and culturally affiliated with the
1 Environmental Science Associates, 5700 Hannum Avenue Mixed-Use Residential and Commercial Project, Culver City, California, Archaeological Resources Assessment Report, prepared for Lincoln Property Company West, October 2023. Provided in Appendix D of this Draft EIR.
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geographic area of the project (as defined in PRC Section 21073) and who have requested in writing to be informed by the lead agency of projects within their geographic area of concern. 2 Tribes interested in consultation must respond in writing within 30 days from receipt of the lead agency’s formal notification and the lead agency must begin consultation within 30 days of receiving the tribe’s request for consultation.
3 PRC Section 21080.3.2(a) identifies the following as potential consultation discussion topics: the type of environmental review necessary; the significance of tribal cultural resources; the significance of the project’s impacts on the tribal cultural resources; project alternatives or appropriate measures for preservation; and mitigation measures. Consultation is considered concluded when either: (1) the parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on a tribal cultural resource; or (2) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. 4 In addition to other CEQA provisions, the lead agency may certify an EIR or adopt a mitigated negative declaration for a project with a significant impact on an identified tribal cultural resource, only if a California Native American tribe has requested consultation pursuant to Section 21080.3.1 and has failed to provide comments to the lead agency, or requested a co nsultation but failed to engage in the consultation process, or the consultation process occurred and was concluded as described above, or if the California Native American tribe did not request consultation within 30 days.
5 PRC Section 21082.3(c)(1) states that any information, including, but not limited to, the location, description, and use of the tribal cultural resources, that is submitted by a California Native American tribe during the environmental review process shall not be included in the environmental document or otherwise disclosed by the lead agency or any other public agency to the public without the prior consent of the tribe that provided the information. If the lead agency publishes any information submitted by a California Native American tribe during the consultation or environmental review process, that information shall be published in a confidential appendix to the environmental document unless the tribe that provided the information consents, in writing, to the disclosure of some or all of the information to the public.
Confidentiality does not apply to data or information that are, or become , publicly available, are already in lawful possession of the applicant before the provision of the information by the California Native American tribe, are independently developed by the applicant or the applicant’s agents, or are lawfully obtained by the applicant from a third party that is not the lead agency, a California Native American tribe, or another public agency. 6 2 Public Resources Code, Section 21080.3.1(b) and (c). 3 Public Resources Code, Sections 21080.3.1(d) and 21080.3.1(e) 4 Public Resources Code, Section 21080.3.2(b)
5 Public Resources Code, Section 21082.3(d)(2) and (3)
6 Public Resources Code, Section 21082.3(c)(2)(B).
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Senate Bill 18
Senate Bill (SB ) 18 (Statutes of 2004, Chapter 905), which went into effect January 1, 2005, requires local governments (city and county) to consult with Native American tribes before making certain planning decisions and to provide notice to tribes at certain key points in the planning process. The intent is to “provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places.”
7 The purpose of involving tribes at these early planning stages is to allow consideration of cultural places in the context of broad local land use policy, before individual site -specific, project-level, land use designations are made by a local government. The consultation requirements of SB 18 apply to general plan or specific plan processes proposed on or after March 1, 2005. 8 According to the Tribal Consultation Guidelines: Supplement to General Plan Guidelines, the following are the contact and notification responsibilities of local governments:
9 • Prior to the adoption or any amendment of a general plan or specific plan, a local government must notify the appropriate tribes (on the contact list maintained by the NAHC) of the opportunity to conduct consultations for the purpose of preserving, or miti gating impacts to, cultural places located on land within the local government’s jurisdiction that is affected by the proposed plan adoption or amendment. Tribes have 90 days from the date on which they receive notification to request consultation, unless a shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3).
• Prior to the adoption or substantial amendment of a general plan or specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county’s jurisdicti on. The referral must allow a 45 -day comment period (Government Code Section 65352). Notice must be sent regardless of whether prior consultation has taken place. Such notice does not initiate a new consultation process.
• Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes who have filed a written request for such notice (Government Code Section 65092).
Existing Conditions
Project Site
The Project Site is currently improved with an office building and associated surface parking. No subterranean parking exists on the Project Site. There is disagreement over the geologic mapping of the Project Site by geologists. Poland et al.10 show the Project Site geology as the San Pedro Sand Formation from the lower or early Pleistocene. This geologic unit is a nearshore marine deposit.
7 Governor’s Office of Planning and Research, Tribal Consultation Guidelines: Supplement to General Plan Guidelines, 2005.
8 As noted under Subsection 4.12.3, Environmental Setting, under Native American Consultation, the City submitted a request for consultation pursuant to SB 18 on October 9, 2020. As a General Plan Amendment is not requested as part of the Project, no further consultation is required pursuant to SB 18. 9 Governor’s Office of Planning and Research, Tribal Consultation Guidelines: Supplement to General Plan Guidelines, 2005.
10 Poland, J.F., A. A. Garrett, and A. Sinnot, 1959, Geology, hydrology, and chemical character of ground waters in the Torrance-Santa Monica area, California: U.S. Geological Survey Water Supply Paper 1461, 425 p.
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Dibblee and Minch11 map the Project Site as Qop (Fox Hills paleosol), Qoa (older alluvium), and Qa (Holocene-age alluvium). Qa is surficial alluvium of Holocene age, “derived mostly from Santa Monica Mountains”. Dibblee and Minch 12 assign a late Pleistocene age to the Qoa and the Qop.
Geotechnologies, Inc.13 reproduced the mapping of Poland et al. 14, but describe the soils in the northern portion of the Project Site as (marine) terrace deposits. That could be compatible with the San Pedro Sand Formation. Geotechnologies, Inc. (2022) also mention that during geotechnical exploration (consisting of placing two borings within the Project Site; one in the northern portion and another in the southern portion), fill materials were encountered from the surface down to depths of 1 and 3 feet bgs. Under the fill soils, marine terrace deposits (as mentioned above) were found, followed by bedrock (siltstone).
Ethnographic Setting
The Project Site is located in a region traditionally occupied by the Gabrielino. The term “Gabrielino” is a general term that refers to those Native Americans who were administered by the Spanish at the Mission San Gabriel Arcángel. Prior to European colonization, the Gabrielino occupied a diverse area that included: the watersheds of the Los Angeles, San Gabriel, and Santa Ana rivers; the Los Angeles basin; and the islands of San Clemente, San Nicolas, and Santa Catalina
15. Their neighbors included the Chumash and Tataviam to the north, the Juañeno to the south, and the Serrano and Cahuilla to the east. The Gabrielino language was part of the Takic branch of the Uto-Aztecan language family.
The Gabrielino Indians were hunter-gatherers and lived in permanent communities located near the presence of a stable food supply. Subsistence consisted of hunting, fishing, and gathering. Small terrestrial game was hunted with deadfalls, rabbit drives, and by burning undergrowth, while larger game such as deer were hunted using bows and arrows. Fish were taken by hook and line, nets, traps, spears, and poison .
16 The primary plant resources were the acorn, gathered in the fall and processed in mortars and pestles, and various seeds that were harvested in late spring and summer and ground with manos and metates. The seeds included chia and other sages, various grasses, and islay or holly-leafed cherry. Community populations generally ranged from 50 to 100 inhabitants,
11 Dibblee and Minch, 2007, Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 12 Dibblee and Minch, 2007, Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 13 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.
14 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. 15 A. L. Kroeber, Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78 (Washington, D.C.: Smithsonian Institution, 1925).
16 Lowell J. Bean and Charles R. Smith. “Gabrielino, in California,” edited by R.F. Heizer, Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor (Washington, D.C. Smithsonian Institution, 1978), 538- 549.
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although larger settlements may have existed. The Gabrielino are estimated to have had a population numbering around 5,000 in the pre-contact period.17 The Late Prehistoric period, spanning from approximately 1,500 years B.P. to the mission era, is the period associated with the florescence of the Gabrielino. 18 Coming ashore near Malibu Lagoon
or Mugu Lagoon in October of 1542, Juan Rodriguez Cabrillo was the first European to make contact with the Gabrielino Indians. The Gabrielino are reported to have been second only to their Chumash neighbors in terms of population size, regional influence, and degree of sedentism. 19 Maps produced by early explorers indicate that at least 26 Gabrielino villages were within proximity to known Los Angeles River courses, while an additional 18 villages were reasonably close to the river.
20 The closest named settlements to the Project Site are Saa’anga and Waachnga.
Review of a map titled Gabrielino Communities Located on the Los Angeles -Santa Ana Plain by William McCawley21 indicates that the settlement of Saa’anga was located approximately 1 mile north of the Project Site, while the settlement of Waachnga was situated approximately 1.25 miles south. Both of these settlements are depicted as located close to Ballona Creek.
South Central Coastal Information Center Records Search and Other Archival Research
As noted in the Archaeological Report, archival research was conducted for the Project, which included a records search at the California Historical Resources Information System ( CHRIS) South Central Coastal Information Center ( SCCIC). The records search included a review of all recorded cultural resources and previous cultural resource studies within the Project Site and a 0.50- mile radius. The records search results indicate that seven cultural resources studies have been conducted within a 0.50-mile radius of the Project Site. Approximately 15 percent of the 0.50-mile records search radius has been included in previous cultural resources assessments. Of the eight previous studies, none overlap the Project Site. The records search results indicate that no cultural resources have been recorded within the 0.50-mile radius of Project Site. However, a total of six prehistoric archaeological resources have been recorded in the immediate vicinity of the 0.50-mile radius ( see Table 4.3-1, Previously Recorded Cultural Resources, in Section 4.3, Cultural Resources, of this Draft EIR).
Additional archaeological resources (the report for which has not yet been archived at the CHRIS- SCCIC, as it is still in progress) were identified approximately 2.5 miles from the Project Site during ground disturbing activities in connection with a development project in Downtown Culver
17 A. L. Kroeber, Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78 (Washington, D.C.: Smithsonian Institution, 1925).
18 Wallace, William J. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11:214-230, 1955.
19 Lowell J. Bean and Charles R. Smith. “Gabrielino, in California,” edited by R.F. Heizer, Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor (Washington, D.C. Smithsonian Institution, 1978), 538- 549.
20 Gumprecht, Blake, Los Angeles River: Its Life, and Possible Rebirth, The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
21 McCawley, William, The First Angelinos: The Gabrielino Indians of Los Angeles, (Malki Museum Press, Banning, California, 1996).
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City.22 These include two isolated prehistoric metates that were recovered in the upper six feet of disturbed fill sediments in an area of the property that had been previously developed with a large warehouse building. This property had a similar land use history as the Project Site.
Sacred Lands File Search
The Native American Heritage Commission (NAHC) maintains a confidential Sacred Lands File (SLF) which contains sites of traditional, cultural, or religious value to the Native American community. The NAHC was contacted on July 11, 2023, to request a search of the SLF. The NAHC responded to the request in a letter dated August 11, 2023, indicating that the results were negative.
However, the NAHC noted that the absence of site information does not mean the absence of cultural resources in a project area.
Tribal Consultation
The City submitted notification and request to consult letters to the individuals and organizations listed below on January 5, 2024. In particular, tribal consultation letters were sent to the following California Native American tribes and individuals:
• Sandonne Goad and Samuel Dunlap, Gabrielino/Tongva Nation • Charles Alvarez, Gabrielino-Tongva Tribe
• Andrew Salas and Christina Swindall, Gabrieleño Band of Mission Indians—Kizh Nation • Robert Dorame and Christina Conley, Gabrielino Tongva Indians of California Tribal Council • Anthony Morales, Gabrielino/Tongva San Gabriel Band of Mission Indians • Joseph Ontiveros and Jessica Valdez, Soboba Band of Luiseño Indians • Lovina Redner, Santa Rosa Band of Cahuilla Indians
The City received a consultation request from the Gabrieleño Band of Mission Indians–Kizh Nation (Tribe). The City has not received any other responses from the Native American community. The City had a conference call with the Tribe on February 20, 2024. During this meeting, the Tribe indicated that the Project Site has potential to encounter buried and previously unknown tribal cultural resources, because trade routes and villages existed in the vicinity of the Project area, such as the sacred community of Huachongna, which once was formerly loc ated in Culver City. Based on this consultation, the City on February 22, 2024 provided the Tribe with proposed mitigation measures for addressing potential tribal cultural resources. The Tribe reviewed the mitigation and provided a single comment back to the City on March 6, 2024. The Tribe indicated that they are in acceptance of the proposed mitigation measures with the revision included based on their comment.
On March 6, 2024 the City made the revision per the Tribe’s comment and provided the Tribe with the final revised mitigation measures.
On March 14, 2024, the Tribe submitted an email to the City with digital materials including screenshots of maps and electronic documents (some of which also include screenshots), artifact photographs, and the Tribe reiterated the high potential to encounter tribal cultural resources during
22 ESA. 2022. (in progress) Archaeological and Paleontological Monitoring Report for the Culver Studios Innovation Plan Project, City of Culver City, California. Report on file with ESA, Irvine, CA.
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construction of the project. Many of the maps, electronics documents, and photographs were referenced during the aforementioned conference call with the City . The maps are from 1881 and 1898 depicting the general location of the Project Site (unknown source), and the Kirkman - Harriman Pictorial and Historical M ap of Los Angeles County (1938). The electronic documents included: screenshots of California’s Gabrielino Indians (1962) book identifying general information on La Ballona in Culver City and the term Gaucho (also referred to as Huacho); a screenshot of information (source unknown) on where villages were located (coast, valleys, and desert); and a screenshot of information on Rancho La Ballona (source unknown). The photographs depict prehistoric artifacts that were recovered during construction of another development project in Culver City in 2019.
The City did not receive any other responses from the Native American community.
4.12.3 Project Impacts
Thresholds of Significance
The significance thresholds below are derived from the Environmental Checklist questions in Appendix G of the CEQA Guidelines. Accordingly, a significant impact to tribal cultural resources would occur if:
• TCR-1: The Project would cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
Methodology
The analysis is based on a SLF search conducted by the NAHC, consultations between the City and Native American tribes, as well as the Archaeological Report prepared by ESA. Specifically, the City submitted notification and request to consult letters to Native American individuals and organizations and conducted follow -up Native American consultation. ESA also reviewed maps , photographs, and materials (confidential) provided by Gabrieleño Band of Mission Indians –Kizh Nation as part of their consultations with the City.
Project Design Features
There are no project design features relative to tribal cultural resources.
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Analysis of Project Impacts
Threshold TCR-1: The Project would result in a significant tribal cultural resources impact if it would cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Lis
ted or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k); or ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
Impact Analysis
As discussed in the Archaeological Report, no known prehistoric archaeological resources were identified within or immediately adjacent to the Project Site. However, a total of six prehistoric archaeological resources have been recorded in the immediate vicinity of the 0.50 -mile radius records search. The SLF search conducted through the NAHC indicated that the Project Site was negative for known resources in the SLF database. The results of several geotechnical investigations at the Project Site revealed that fill was found from the surface down to approximately 1 to 3 feet below existing grade. The fill was underlain by various marine terrace deposits (as discussed above) and followed by bedrock (siltstone).
Per review of Kirkman’s 1938 map that was provided to the City from Kizh Nation, the Project Site is depicted as located in the vicinity of old/ancient roads south of Baldwin Hills; however, no Native American villages are observed as located within the Project Site. The closest unnamed village to the Project Site is shown in the 1938 map as located approximately 2.2 miles north of the Project Site in Culver City and 2.5 miles east of the Project Site in Inglewood. Additionally, no villages with the name of Huachongna were observed in the 1938 map. A screenshot of a book titled California’s Gabrielino Indians (1962) identifies the term Gaucho/Huacho (possibly in reference to Huachongna), which according to the text it is a Native American term for the cliffs of Ballona’s easterly boundary. However, no additional information is provided in the text as to the exact location of Gaucho/Huacho. As a result, specific evidence of village locations located within or overlapping the Project Site was not provided.
Therefore, no known tribal cultural resources, as
defined in PRC Sections 21074(a)(1), or resources determined by the City in its discretion and supported by substantial evidence to be significant pursuant to PRC Section 5024.1 have been identified within the Project Site as a result of tribal consultation, or as a result of the SLF search through the NAHC and the SCCIC.
However, due to the Project Site being located in the vicinity of old/ancient roads (that could have been possibly used as prehistoric trade routes) and Ballona Creek , recent discoveries during other
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construction projects in the vicinity, and the tribal consultation efforts, the Project Site appears to have a moderate to high potential for encountering previously unknown tribal cultural resources during construction. As a result, there is potential that the Project could cause a substantial adverse change in the significance of a tribal cultural resource as described in PRC Section 21084.2.
Accordingly, impacts on tribal cultural resources are considered potentially significant, and mitigation measures are provided below.
Mitigation Measures
Refer to Mitigation Measure CUL-MM-2. The following mitigation measures are also required to address potentially significant impacts to tribal cultural resources during Project construction:
TCR-MM-1: Prior to the issuance of a demolition permit for the Project, the Applicant shall retain a Native American Monitor from the Gabrieliño Band of Mission Indians – Kizh Nation (Kizh Nation or Tribe). The Native American Monitor shall be present during the following construction activities that have the potential for encountering tribal cultural resources: demolition, pavement removal, clearing/grubbing, drilling/augering, potholing, grading, trenching, excavation, tree removal or other ground disturbing activity associated with the Project, whether on the Project Site or in connection with Project off -site improvements (collectively “ground disturbing activities”). Notwithstanding the foregoing, Native American monitoring shall not be required for any moving of soils that have been monitored or observed prior to their disturbance and subsequently disturbed or displaced by Project-related construction. The Applicant shall prepare a monitoring agreement with the Kizh Nation that outlines the roles and responsibilities of the Native American Monitor and shall submit this agreement to the City of Culver City (City) prior to the issuance of demolition permit for the Project.
Prior to commencement ground disturbing activities, a Tribal Cultural Resources Sensitivity Training session shall be held for those construction personnel who will be directly involved in the ground disturbing activities. The training session shall be car ried out by the Native American Monitor and shall focus on how to identify tribal cultural resources that may be encountered during ground disturbing activities and the procedures to be followed in such an event. If the Native American Monitor is not present at the Project Site on any given workday, the ground disturbing activities may continue if the workers involved in such activities attended the training session.
Full-time monitoring may be reduced to part -time inspections, or ceased entirely, if determined appropriate by the Native American Monitor in the event there appears to be little to no potential for impacting tribal cultural resources. Native American monitoring shall conclude no later than conclusion of ground disturbing activities.
TCR-MM-2: The Native American Monitor shall complete daily monitoring logs that provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs shall identify and describe any discovered tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the Applicant and the City upon written request to the Tribe. The Applicant shall not be deemed to be out of
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compliance with this measure if the Native American Monitor fails to complete or submit any such monitoring logs.
TCR-MM-3: In the event of a discovery of potential tribal cultural resources at the Project Site, the Qualified Archaeologist identified in Mitigation Measure CUL-MM-1 (after consultation with the Native American Monitor) shall have the authority to temporarily divert, redirect, or halt ground-disturbance activities to allow identification, evaluation, and potential recovery of such potential resources. After consulting with the Native American Monitor and the Applicant, the Qualified Archaeologist s hall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety considerations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where ground-disturbing activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area.
Within three (3) business days of such discovery, a meeting shall take place between the Applicant, the Qualified Archaeologist, the Tribe, and the City to discuss the significance of the find and whether it qualifies as a tribal cultural resource pursuant to Public Resources Code Section 21074(a). If, as a result of the meeting and after consultation with the Tribe, the Applicant, and the Qualified Archaeologist, the City determines, based on substantial evidence, that the resource is in fact a tribal cultural resource, the Qualified Archaeologist shall develop a reasonable and feasible treatment plan, with input from the Tribe as necessary, and with the concurrence of the City’s Planning Director. The treatment measures in the treatment plan shall be in compliance with any applicable federal, State, or local laws, rules or regulations. The treatment plan shall also include measures regarding the curation of the recovered resources.
If the Applicant does not accept a particular recommendation determined to be reasonable and feasible by the Qualified Archaeologist (including, but not limited to, the size of the buffer set forth above), the Applicant, or its successor, may request mediation by a mediator agreed to by the Applicant and the City. The mediator must have the requisite professional qualifications and experience to mediate such a dispute. The City shall make the determination as to whether the mediator is at least minimally qu alified to mediate the dispute. After making a reasonable effort to mediate this particular dispute, the City may:
(1) require the recommendation be implemented as originally proposed by the Archaeologist; (2) require the recommendation, as modified by the City, be implemented as it is at least as equally effective to mitigate a potentially significant impact; (3) require a substitute recommendation be implemented that is at least as equally effective to mitigate a potentially significant impact to a tribal cultural resource; or (4) not require the recommendation be implemented because it is not necessary to mitigate any significant impacts to tribal cultural resources. The Applicant shall pay all costs and fees associated with the mediator.
The Applicant may recommence ground disturbance activities inside of the specified radius of the discovery site only after it has complied with all of the recommendations developed and approved pursuant to the process set forth in the above paragraphs.
The recovered Native American resources may be placed in the custody of the Tribe, who may choose to use them for their educational purposes or they may be curated at a public, non-profit institution with a research interest in the materials. If neither th e Tribe nor an
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institution accepts the resources, they may be donated to a local school or historical society in the area for educational purposes.
Notwithstanding the above paragraph, any information determined to be confidential in nature by the City Attorney’s office, shall be excluded from submission to the SCCIC or the general public under the applicable provisions of the California Public Records Act, California Public Resources Code Section 6254(r).
Level of Significance after Mitigation
In the event unknown tribal cultural resources are unearthed during construction of the Project, with implementation of the above mitigation measures, potentially significant impacts on tribal cultural resources would be reduced to a less than significant level.
Cumulative Impacts
As demonstrated above, prior to mitigation, the Project would have a potentially significant impact on tribal cultural resources even though there are no resources listed or determined eligible for listing, on the national, State, or local register of historical resources, and the Lead Agency determined that no resources were identified during tribal consultation that are eligible for listing under the criteria in PRC Section 5024.1(c). This significant impact finding is due to the potential to encounter tribal cultural resources at depth during construction. This potential exists due to the Project Site being located in the vicinity of old/ancient roads (that c ould have been possibly used as prehistoric trade routes) and proximity to Ballona Creek, given recent discoveries during other construction projects in the vicinity, and Native American consultation efforts.
As with the Project, e ach related project would also be required to engage in tribal consultation with Native American tribes in order to identify any tribal cultural resources that could potentially be impacted by the related project and to address potentially significant impacts, if identified. The related projects may require mitigation similar to that applicable to the Project, especially if those related projects are in areas of heightened sensitivity similar to the Project Site.
Accordingly, in light of the Project’s mitigation measures and similar anticipated mitigation requirements for Projects in areas of heightened sensitivity, the Project’s contribution to cumulative impacts regarding tribal cultural resources would not be cumulatively considerable and cumulative impacts would be less than significant.
Mitigation Measures
Cumulative impacts regarding tribal cultural resources were determined to be less than significant with mitigation. Therefore, no additional mitigation measures to address cumulative impacts are required.
Level of Significance after Mitigation
Cumulative impacts regarding tribal cultural resources would be less than significant with mitigation.
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4.13.1 Utilities and Service Systems – Water Supply
4.13.1.1 Introduction
This section evaluates potential Project impacts on water supply and whether the Project would require or result in the construction of new water treatment facilities, including conveyance infrastructure, the construction of which would cause significant environmental effects. The Golden State Water Company (GSWC) supplies water within its Service Area of the City of Culver City (City) and the Project Site. This section describes GSWC’s available water supplies, current and projected regional water demand, municipal water infrastructure serving the Project Site, and the adequacy of water supplies and infrastructure to meet Project demand.
4.13.1.2 Environmental Setting
Regulatory Framework
State
California Urban Water Management Planning Act
The California Urban Water Management Planning Act (Water Code, Section 10610, et seq.) addresses several State policies regarding water conservation and the development of water management plans to ensure the efficient use of available supplies. The California Urban Water Management Planning Act also requires Urban Water Suppliers to develop Urban Water Management Plans (UWMPs) every five years to identify short-term and long-term demand management measures to meet growing water demands during normal, dry, and multiple-dry years.
Urban Water Suppliers are defined as water suppliers that either serve more than 3,000 customers or provide more than 3,000 acre-feet per year (AFY) of water to customers.
Senate Bill 610, Senate Bill 221, and Senate Bill 7
Two of the State laws addressing the assessment of water supply necessary to serve large-scale development projects, Senate Bill (SB) 610 and SB 221, became effective January 1, 2002. SB 610, codified in Water Code Sections 10910–10915, specifies the requi rements for Water Supply Assessments (WSAs) and their role in the California Environmental Quality Act (CEQA) process, and defines the role UWMPs play in the WSA process. SB 610 requires that, for projects subject to CEQA that meet specific size criteria, the water supplier prepare WSAs that determine whether the water supplier has sufficient water resources to serve the projected water demands associated with the projects. SB 610 provides specific guidance regarding how future supplies are to be calculated in the WSAs where an applicable UWMP has been prepared. Specifically, a WSA must identify existing water supply entitlements, water rights, or water service contracts held by the public water system, and prior years’ actual water deliveries received by the public water system.
In addition, the WSA must address water supplies over a 20 -year period and consider normal, single-dry, and multiple-dry year conditions. In accordance with SB 610, projects for which a WSA must be prepared are those subject to CEQA that meet any of the following criteria:
• Residential developments of more than 500 dwelling units; • Shopping centers or business establishments employing more than 1,000 persons or having more than 500,000 sf of floor space;
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• Commercial office buildings employing more than 1,000 persons or having more than 250,000 sf of floor space;
• Hotels, motels, or both, having more than 500 rooms;
• Industrial, manufacturing, or processing plants, or industrial parks planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 sf of floor area
• Mixed-use projects that include one or more of the projects specified in this subdivision; or • Projects that would demand an amount of water equivalent to or greater than the amount of water required by a 500 -dwelling-unit project. (Water Code Section 912, CEQA Guidelines Section 15155(a)).
The Project does not meet the above criteria, and, therefore, a WSA is not required.
In addition, under SB 610, a water supplier responsible for the preparation and periodic updating of an UWMP must describe the water supply projects and programs that may be undertaken to meet the total project water use of the service area. If groundwater is identified as a source of water available to the supplier, the following additional information must be included in the UWMP: (1) a groundwater management plan; (2) a description of the groundwater basin(s) to be used and the water use adjudication rights, if any; (3) a description and analysis of groundwater use in the past five years; and (4) a discussion of the sufficiency of the groundwater that is projected to be pumped by the supplier.
SB 221 also addresses water supply in the land use approval process for large residential subdivision projects. However, unlike SB 610 WSAs, which are prepared at the beginning of a planning process, SB 221-required Water Supply Verification (WSV) is prepared at the end of the planning process for such projects. Under SB 221, a water supplier must prepare and adopt a WSV indicating sufficient water supply is available to serve a proposed subdivision, or the local agency must make a specific finding that suf ficient water supplies are or will be available prior to completion of a project, as part of the conditions for the approval of a final subdivision map. SB 221 specifically applies to residential subdivisions of 500 units or more. However, Government Code Section 66473.7(i) exempts “…any residential project proposed for a site that is within an urbanized area and has been previously developed for urban uses; or where the immediate contiguous properties surrounding the residential project site are, or previously have been, developed for urban uses; or housing projects that are exclusively for very low and low -income households.”
SB 7, enacted on November 10, 2009, mandates new water conservation goals for UWMPs, requiring Urban Water Suppliers to achieve a 20 percent per capita water consumption reduction by the year 2020 statewide, as described in the “20 x 2020” State Water Conservation Plan. 1 As
such, each updated UWMP must now incorporate a description of how each respective urban water supplier will quantitatively implement this water conservation mandate, which requirements in turn must be taken into consideration in preparing and adopting WSAs under SB 610.
1 California State Water Resources Control Board, 20 x 2020 Water Conservation Plan, February 2010.
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Senate Bill X7-7 – Water Conservation Act
SB X7-7 (Water Conservation Act of 2009), codified in California Water Code Section 10608, requires all water suppliers to increase water use efficiency. Enacted in 2009, this legislation sets an overall goal of reducing per capita urban water use, compared to 2009 use, by 20 percent by December 31, 2020. The State of California was required to make incremental progress towards this goal by reducing per capita water use by at least 10 percent on or before December 31, 2015.
Monthly statewide potable water savings reached 25.1 percent in February 2017 as compared to that in February 2013.
2 Cumulative statewide savings from June 2015 through February 2017 were estimated at 22.5 percent. 3 Following a multi- year drought and improvements to hydrologic conditions, statewide potable water savings reached 14.7 percent in August 2017 as compared to August 2013 potable water production.
4 As provided in GSWC’s 2020 Urban Water Management
Plan, in accordance with SB X7-7, GSWC developed a final reported 2020 target of 142 gallons per capita per day (GPCD). GSWC’s actual GPCD in 2020 was 116 GPCD, less than the 2020 target.5 Sustainable Groundwater Management Act of 2014
The Sustainable Groundwater Management Act (SGMA) of 2014, passed in September 2014, is a comprehensive three-bill package that provides a framework for the sustainable management of groundwater supplies by local authorities.
6 The SGMA requires the formation of local groundwater
sustainability agencies to assess local water basin conditions and adopt locally based management plans. Local groundwater sustainability agencies were required to be formed by June 30, 2017. The SGMA provides 20 years for groundwater sustainability agencies to implement plans and achieve long-term groundwater sustainability, and protect existing surface water and groundwater rights.
The SGMA provides local groundwater sustainability agencies with the au thority to require registration of groundwater wells, measure and manage extractions, require reports and assess fees, and request revisions of basin boundaries, including establishing new subbasins. Furthermore, SGMA requires governments and water agencie s of high and medium priority basins to stop overdraft and bring groundwater basins into balanced levels of pumping and recharge. Under SGMA, these basins should reach sustainability within 20 years of implementing their sustainability plans. For the basins that are critically over-drafted, the timeline is 2040. For the remaining high and medium priority basins, the deadline is 2042.
California Code of Regulations
Title 20
Title 20, Sections 1605.3 (h) and 1505(i) of the California Code of Regulations (CCR) establishes applicable State efficiency standards (i.e., maximum flow rates) for plumbing fittings and fixtures, including fixtures such as showerheads, lavatory faucets, and water closets (toilets). Among the
2 State Water Resources Control Board, Fact Sheet, February 2017 Statewide Conservation Data, February Conservation Summary, updated April 4, 2017.
3 State Water Resources Control Board, Media Release, “Statewide Water Savings Exceed 25 Percent in February; Conservation to Remain a California Way of Life,” April 4, 2017. 4 State Water Resources Control Board, Fact Sheet, August 2017 Statewide Conservation Data, August Urban Water Production Summary, updated October 3, 2017.
5 Golde State Water Company. Culver City Service Area 2020 Urban Water Management Plan, page 4-2. 6 California Department of Water Resources, SGMA Groundwater Management, https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater-Management. Accessed October 2023.
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standards, the maximum flow rate for showerheads manufactured on or after July 1, 2018 , is 1.8 gallons per minute (gpm) at 80 pounds per square inch (psi); and lavatory faucets manufactured after July 1, 2016, is 1.2 gpm at 60 psi. The standard for toilets sold or offered for sale on or after January 1, 2016, is 1.28 gallons per flush.7
CALGreen Code
Part 11 of Title 24, the title that regulates the design and construction of buildings, establishes the California Green Building Standards (CALGreen) Code. The purpose of the CALGreen Code is to improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact or a positive environmental impact and encouraging sustainable construction practices in the following categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental quality. The CALGreen Code includes both mandatory measures as well as voluntary measures. The mandatory measures establish minimum baselines that must be met in order for a building to be approved. The mandatory measures for water conservation provide limits for fixture flow rates, which are the same as those for the Title 20 efficiency standards listed above. The voluntary measures can be adopted by local jurisdictions for greater efficiency.
Plumbing Code
Title 24, Part 5 of the CCR establishes the California Plumbing Code. The California Plumbing Code sets forth efficiency standards (i.e., maximum flow rates) for all new federally-regulated plumbing fittings and fixtures, including showerheads and lavatory faucets and outlines minimum requirements for plumbing fixture quantities based on proposed use and occupant load. The 2022 California Plumbing Code, which is based on the 2021 Uniform Plumbing Code, has been published by the California Building Standards Commission and went into effect on January 1, 2023.
Executive Order B-37-16
In 2018 the California State Legislature enacted two policy bills: SB 606 and Assembly Bill (AB) 1668 to establish a new foundation for long-term improvements in water conservation goals and drought planning to adapt to the longer and more intense droughts climate change is causing in California.
The 2018 legislation applies to the actions of the California Department of Water Resources (DWR), the California State Water Resources Control Board (SWRCB), and water suppliers. DWR and the SWRCB will work closely together to develop new standards for:
• Indoor residential water use standard will be 55 gallons per capita daily until January 2025; the standard will become stronger over time, decreasing to 50 gallons per capita daily in January 2030. For the water use objective, the indoor use is aggregated across population in an urban water supplier’s service area, not each household;
• Outdoor residential water use standard will be based on land cover (landscaping), climate, and other factors, i.e., geography, pastures and other irrigated lands, or open space determined by the DWR and the SWRCB.
7 California Code of Regulations, Title 20, Section 1605.3(h).
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• Commercial, industrial, and institutional water use for landscape irrigation with dedicated meters; and
• System water losses, formerly known as unaccounted for water.
In October 2022, DWR provided recommendations to the SWRCB to support the development of these standards. Urban water suppliers must stay within annual water budgets based on these standards for their service areas. The 2018 legislation also supports drought planning. In urban areas, drought plans will be primarily led by local water suppliers. DWR and the SWRCB will develop recommendations to strengthen drought planning in rural are as and areas served by small water systems by coordinating with counties and other stakeholders.
Executive Order B-40-17
Executive Order B -40-17 was issued on April 7, 2017. Cities and water districts throughout the State are required to report their water use each month and bans wasteful practices, including hosing off sidewalks and running sprinklers when it rains.
Executive Order N-10-21
On July 8, 2021, Executive Order N-10-21 was issued calling for voluntary cutbacks of water usage by 15% from 2020 usage levels. The Order lists common sense measures Californians can undertake to achieve water usage reduction goals and identifies the SWRCB for tracking of monthly reporting on the State’s progress.
Executive Order 7-77
On March 28, 2022, Governor Newsom issued Executive Order No. 7-77, meant to provide guidance on emergency drought relief. The Order states that the “21st century to date has been characterized by record warmth and predominantly dry conditions, and the 2021 meteorological summer in California and the rest of the western United States was the hottest on record” and “the ongoing drought will have significant, immediate impacts on communities with vulnerable water supplies, farms that rely on irrigation to grow food and fiber, and fish and wildlife that rely on stream flows and cool water.”
Within the Order, the Governor ordered the SWRCB to evaluate the adoption of regulations and the relaxations of permitting for drought positive measures. These regulations include banning irrigation of “non-functional” turf (or grass), such as decorative grass adjacent to large industrial and commercial buildings. The ban would not include residential lawns or grass used for recreation, such as school fields, sports fields and parks. Further, the Order asks the SWRCB to prepare municipal water agencies for drought restrictive measures. More specifically, the SWRCB asks these urban water suppliers to prepare to activate, at a minimum, Level 2 of their customized Water Shortage Contingency Plans. These plans are developed by local water agencies to navigate extreme drought and each plan is customized based on an agency’s unique infrastructure and management. Triggering Level 2 of these plans involves implementing water conservation actions to prepare for a water shortage level of up to 20 percent.
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Regional
Metropolitan Water District 2020 Urban Water Management Plan As discussed in detail below, the Metropolitan Water District of Southern California (MWD) is a primary source of water supply within Southern California. Based on the water supply planning requirements imposed on its member agencies and ultimate customers, MWD has adopted a series of official reports on the state of its water supplies. As described in further detail below, in response to recent developments in the Sacramento Delta, the MWD has developed plans intended to provide solutions that, when combined with the rest of its supply portfolio, will ensure a reliable long-term water supply for its member agencies, including the City.
MWD’s 2020 UWMP (MWD UWMP) addresses the future of MWD’s water supplies and demand through the year 2045.
8 Evaluations are prepared for average year conditions, single dry- year conditions, and multiple dry-year conditions. The analysis for multiple -dry year conditions, i.e. under the most challenging weather conditions such as drought and service interruptions caused by natural disasters, is presented in Table 2-5 of the 2020 UWMP. 9 The analysis in the 2020 UWMP
concluded that reliable water resources would be available to continuously meet demand through 2045.
10 In the 2020 UWMP, the projected 2045 demand water during multiple-dry year conditions is 1,564,000 AFY, whereas the expected and projected 2045 supply is 2,239,000 AFY based on current programs, for a potential surplus in 2045 of 675,000 AFY. 11 MWD has comprehensive plans for stages of actions it would undertake to address up to a 50 - percent reduction in its water supplies and a catastrophic interruption in water supplies through its Water Surplus and Drought Management and Water Supply Allocation Plans. MWD has also developed an Emergency Storage Requirement to mitigate against potential interruption in water supplies resulting from catastrophic occurrences within the Southern California region and is working with the State to implement a comprehensive improvement plan to address catastrophic occurrences that could occur outside of the Southern California region. MWD is also working with the State on the Delta Risk Management Strategy to reduce the impacts of a seismic event in the Delta that would cause levee failure and disruption of State Water Project (SWP) deliveries. In addition, MWD has plans for supply implementation and continued development of a diversified resource mix, including programs in the Colorado River Aqueduct, SWP, Central Valley transfers, local resource projects, and in-region storage that enables the region to meet its water supply needs. 2015 Integrated Resources Plan
The MWD prepares an Integrated Water Resources Plan (IRP) that provides a water management framework with plans and programs for meeting future water needs. It addresses issues that can affect future water supply such as water quality, climate change, and regulatory and operational changes. The most recent IRP (2015 IRP) was adopted in January 2016. 12 It establishes a water
supply reliability mission of providing its service area with an adequate and reliable supply of high-
8 Metropolitan Water District of Southern California, 2020 Urban Water Management Plan, June 2021. 9 Metropolitan Water District of Southern California, 2020 Urban Water Management Plan, June 2021, p. 2-19. 10 Metropolitan Water District of Southern California, 2020 Urban Water Management Plan, June 2021, p. 2-19. 11 Metropolitan Water District of Southern California, 2020 Urban Water Management Plan, June 2021, p. 2-19. 12 Metropolitan Water District of Southern California, Integrated Water Resources Plan – 2015 Update, Report No. 1518, 2016.
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quality water to meet present and future needs in an environmentally and economically responsible way. Among other topics, the 2015 IRP discusses water conservation, local and imported water supplies, storage and transfers, water demand, and adaptation to drought conditions.
The 2015 IRP reliability targets identify developments in imported and local water supply, and in water conservation that, if successful, would provide a future without water shortages and mandatory restrictions under planned conditions. For imported suppl ies, MWD would make investments to maximize Colorado River Aqueduct deliveries in dry years. MWD would make ecologically-sound infrastructure investments to the SWP so that the water system can capture sufficient supplies to help meet average year demands and to refill the MWD storage network in above-average and wet years.
Planned actions to keep supplies and demands in balance include, among others, lowering regional residential per capita demand by 20 percent by the year 2020 (compared to a baseline established in 2009 state legislation), reducing water use from outdoor landscapes and advancing additional local supplies. IRP Table ES-1, 2015 IRP Update Total Level of Average -Year Supply Targeted (Acre-Feet), of the 2015 IRP, shows the supply reliability and conservation targets. As presented in the IRP, the total supply reliability target for each five -year increase between 2016 and 2040 would exceed the retail demand after conservation. In 2040, retail demand after conservation is estimated to be 4,273,000 acre-feet and the total supply reliability target is approximately 4,539,000 acre-feet, representing an excess of 266,000 acre-feet. 13 As of October 2023, the 2020 IRP preparation process is underway . The 2020 IRP analyzes multiple scenarios that could plausibly unfold in the future due to climate change, economic growth, legislation and regulations affecting water sources and demands, and other variables. With the variability of these impacts in mind, MWD is developing four scenarios to help understand the challenges of the future and effectively plan to ensure water reliability in the face of those challenges. These four scenarios include (A) low demand, stable imports; (B) high demand, stable imports; (C) low demand, reduced imports; and (D) high demand, reduced imports . Refer to the Existing Conditions subsection below for additional information on the scenarios being evaluated as part of the 2020 IRP.
Water Surplus and Drought Management Plan
In 1999, MWD incorporated the water storage contingency analysis that is required as part of any UWMP into a separate, more detailed plan, called the Water Surplus and Drought Management Plan (WSDM Plan). The overall objective of the WSDM Plan is to ensure that shortage allocation of MWD’s imported water supplies is not required. The WSDM Plan provides policy guidance to manage MWD’s supplies and achieve the goals laid out in the agency’s IRP. The WSDM Plan separates resource actions into two major categories: Surplus Actions and Shortage Actions. The WSDM Plan considers the region to be in surplus only after MWD has met all demands for water, including replenishment deliveries. The Surplus Actions store surplus water, first inside then outside of the region. The Shortage Actions of the WSDM are separated into three subcategories:
Shortage, Severe Shortage, and Extreme Shortage. Each category has associated actions that could
13 Metropolitan Water District of Southern California, Integrated Water Resources Plan – 2015 Update, Report No. 1518, 2016, p. VIII.
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be taken as part of the response to prevailing shortage conditions. Conservation and water efficiency programs are part of MWD’s resource management strategy through all categories.14 Long-Term Conservation Plan
The Long‐Term Conservation Plan (LTCP) provides a framework of goals and strategies to reduce per capita water use through conservation and water use efficiency. The plan recognizes the challenges and uncertainties to achieving the IRP target. As a result, the LTCP uses adaptive management and strategies to adjust implementation approaches.
Water Supply Allocation Plan
While the WSDM Plan included a set of general actions and considerations for MWD staff to address during shortage conditions, it did not include a detailed water supply allocation plan or implementation approach. Therefore, in February 2008, MWD adopted a water supply plan called the Water Supply Allocation Plan (WSAP). The WSAP includes a formula for determining equitable, needs-based reductions of water deliveries, with the potential application of a surcharge, to member agencies during extreme water shortages in MWD's service area conditions (i.e., drought conditions or unforeseen interruptions in water supplies).
The WSAP allows member agencies the flexibility to choose among various local supply and conservation strategies to help ensure that demands on MWD stay in balance with limited supplies.
The WSAP formula addresses shortages of MWD supplies, by taking into account growth, local investments, changes in supply conditions and the demand hardening aspects of non-potable recycled water use and the implementation of conservation savings programs. The allocation period covers 12 consecutive months from July of a given year through the following June.
West Basin Municipal Water District 2020 Urban Water Management Plan The West Basin Municipal Water District (WBMWD) was established in 1947 to mitigate over - pumping in the West Coast Subbasin. WBMWD is the fourth-largest member agency of the MWD and undertakes actions to protect groundwater supplies from seawater intrusion and augment the West Coast Subbasin supplies. The WBMWD imports water from MWD and delivers these supplies to investor -owned utilities, municipalities, a county waterworks district, and a groundwater agency to supplement locally available supplies.
As described in its most recent 2020 UWMP, WBMWD has an approximately 185 -square-mile service area and provides wholesale potable water to 17 cities through three investor -owned utilities, four municipal water departments and one county waterworks district , in southwest Los Angeles County. WBMWD supplies recycled water to over 450 metered connections for municipal, commercial, and industrial use as well as for injection into the West Coast Basin Seawater Barrier to halt seawater intrusion and replenish the WCGB aquifers. 15 WBMWD has been able to support the diversification of supplies available to its customer agencies by providing access to imported water supplies from MWD, as well as primarily through the development of recycled water supplies and conservation. These supplies are served directly to its
14 Water Surplus and Drought Management Plan, Report No. 1150, 1999. 15 West Basin Municipal Water District, 2020 Urban Water Management Plan, June 28, 2021, p. ES-3.
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customer agencies and indirectly as the replenishment supplies necessary to maintain groundwater production. WBMWD is projected to increase current recycled water supplies as well as invest in ocean water desalination supply.
Local
Culver City General Plan
The General Plan Conservation Element (1972) does not address water supply or further water conservation measures.
Culver City Municipal Code
The City’s policies regarding water supply are set forth in CCMC Chapter 5.03, Water Conservation and Water Supply Shortage Program. The purpose of this chapter is to adopt and enforce a conservation and supply shortage program as necessary to manage the C ity’s potable water supply in the short - and long-term, and to avoid or minimize the effects of drought and shortage within the City. According to Chapter 5.03.010.C, careful water management that includes active water conservation measures not only in times of drought, but at all times, is essential to ensure a reliable minimum supply of water to meet current and future water supply needs. 16 The water conservation and supply shortage program established under Chapter 5.03, is intended to reduce water consumption through conservation, and to enable effective water supply planning, assure reasonable and beneficial use of water, prevent waste of water, and maximize the efficient use of water within the City to avoid and minimize the effect and hardship of water shortage to the greatest extent possible.
Under Section 5.03.030, permanent water conservation requirements and prohibition against waste include limits on watering hours (Section 5.03.030.A), which prohibit watering or irrigating of lawn, landscape or other vegetated area with potable water between the hours of 8:00 A.M. and 7:00
P.M.; limit on watering duration (Section 5.03.030.B), which limit watering to no more than 10 minutes of watering per day, per station; prevention of excessive water flow or runoff (Section
5.03.030.C); and prohibition of washing down hard or paved surfaces (Section 5.03.030.D). Other measures (Section 5.03.030.E through O) include the obligation to fix leaks, breaks or malfunctions (Section 5.03.030.E); required re-circulation of water for decorative water fountains and decorative water features (Section 5.0 3.030.F), and prohibition of single -pass cooling systems (Section
5.03.030.J). The Code also requires that all pools and spas be covered in a manner to reduce evaporation (Section 5.03.030.N) , and it prohibits irrigation of ornamental turf on public street medians Section 5.03.030.O).
Sections 5.03.035, 5.03.040, and 5.03.045, respectively, pertain to Level 1, Level 2, and Level 3 water supply shortage emergency conditions. The stages are cumulative and include permanent measures as well as measures from the preceding level. Level 1 wat er supply shortage requires additional water conservation measures including limits on water days; a 72 -hour time limit on repairs of leak, breaks or malfunctions. Level 2 requires more stringent limits on watering days, a 48-hour time limit on repairs of leak, breaks or malfunction; prohibition on filling ornamental lakes
16 City of Culver City, Municipal Code, Chapter 5.03.010.C.
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or ponds (except under specified conditions); and limits on washing vehicles at commercial car washing facilities. The use of potable water to wash or clean a vehicle, whether motorized or not, is prohibited at a commercial car washing facility that does not utilize a re-circulating water system.
Level 3 prohibits watering or irrigating, unless maintenance of vegetation, including trees and shrubs, are watered with a hand-held bucket or similar container or a hand-held hose equipped with a positive, self -closing, water -shut-off nozzle or device. Maintenance of existing landscape necessary for fire protection, erosion control, or protection of protected species or certain other landscaped areas, such as public parks and playing fields, is allowed provided tha t such irrigation does not exceed two days per week and is conducted in accordance with the time restrictions. Level 3 also requires that all leaks, breaks, or other malfunctions in the water user's plumbing or distribution system be repaired within 24 hours of notification. At present, there are no City water restrictions beyond GSWC’s Stage 1 restrictions, further detailed below.
Culver City Service Area Urban Water Management Plan
In accordance with the California Urban Water Management Planning Act, UWMPs are updated at 5-year intervals. GSWC approved the Culver City Service Area 2020 UWMP (UWMP -Culver City) on June 15, 2021. The UWMP-Culver City describe GSWC’s water supply reliability under single dry-year, multiple dry -year, and average year conditions, with projected information in 5- year increments for a minimum of 20 years.
It is also acknowledged that GSWC service areas are in Stage 1 of the Water Shortage Contingency and Staged Mandatory Water Conservation and Rationing plan. 17 In Stage 1, customers are
encouraged to voluntarily reduce usage and to use water wisely, only using what is needed and not one drop more. G SWC may additionally charge customers who exceed their baseline drought allocation. Outdoor irrigation/watering is limited to no more than three days per week between the hours of 5 PM–9 AM. Outdoor irrigation/watering is limited to eight minutes per controller station/valve. Addresses ending in an even number must water only on: Sunday, Wednesday, or Friday. Addresses ending in an odd number must water only on: Tuesday, Thursday, or Saturday.
Existing Conditions
Water Infrastructure
GSWC currently provides potable water service to the Project Site. Based on information provided in the Water Civil Technical Memorandum prepared for the Project by Kimley Horn (Appendix J of this Draft EIR), there is an existing 12-inch water line in Hannum Avenue. Additionally, a water meter is located along the street frontage of Hannum Avenue. There is a fire hydrant located across Hannum Avenue at the center of the P roject Site, and another fire hydrant adjacent to the Project Site along Buckingham Parkway, also generally within the central portion of the Project Site.
Water Demand
The Project Site is currently occupied by an approximately 30,672 square foot two-story office building. The remainder of the Project Site includes surface parking and associated landscaping.
Based on information provided in the Water Civil Technical Memorandum (Appendix J of this
17 City of Culver City website, Water Conservation, https://www.culvercity.org/City-Hall/Departments/Public- Works/Culver-City-Environmental-Initiatives/Water-Conservation. Accessed October 24, 2023.
4. Environmental Impacts Analysis
4.13.1. Utilities and Service Systems – Water Supply
City of Culver City 4.13.1-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Draft EIR), existing water usage on the Project Site is approximately 7,36 1 gallons per day (gpd), or approximately 8.3 AFY, as shown in Table 4.13.1-1.
TABLE 4.13.1-1
EXISTING ESTIMATED WATER CONSUMPTION
Existing Use Units Water Use Ratea
Water Usage
gpd AFY
Commercial Office 30,672 sf 200/1,000 sf 6,134 6.9
Irrigationb - - 1,227 1.4
Total Existing Water Use - - 7,361 8.3
NOTES: gpd = gallons per day; sf = square feet, AFY = acre-feet per year. a Estimated water usage is estimated as being equivalent to the estimated sewage generation for the Project.
These rates are assessed using LA County Sanitation’s Estimated Wastewater Generation Tables. b 20% factor included to account for landscaping and irrigation consumption.
SOURCE: Kimley Horn, Water Civil Technical Memorandum, 2023 (Appendix J of this Draft EIR)
Water Supply
Golden S tate Water Company – Culver City Service Area
The water supply for the Culver City service area is mostly imported water purchased from the WBMWD, which is a member agency of MWD. While approximately 0.1 AF of groundwater was pumped from the Santa Monica Subbasin (DWR Basin No. 4-011.01) in 2020 by the GSWC, no groundwater was used in 2021 nor is groundwater projected for use within the City’s service area through the 2045 planning horizon.
18 As such, further discussion of groundwater supplies are not included in this Draft EIR section.
Per the GSWC Culver City Service Area 2020 UWMP, the WBMWD provided GSWC’s Culver City service area a total of 4,707 acre-feet in 2020, which sufficiently met the City service area total water demand.
The water purchased from WBMWD may be managed and moved between the GSWC Culver City service area and GSWC Southwest service area, depending upon the circumstances for supply availability in each particular service area.
19 GSWC entered into a five -year purchase agreement between GSWC and WBMWD, effective January 1, 2008, through December 31, 2012. The agreement was extended an additional two years to December 31, 2014. This agreement provided GSWC with an annual maximum allocation of
18 GSWC 2020 Urban Water Management Plan, June 15, 2021. 19 The Southwest Service Area currently includes 54,994 customers in Southwest Los Angeles County, including all of Gardena and Lawndale, and portions of Carson, Compton, El Segundo, Hawthorne, Inglewood, Redondo Beach, and unincorporated Athens, Del Aire, El Camino Village, Lennox and Gardena Heights. Source: Golden State Water Company,
https://www.gswater.com/southwest#:~:text=We%20currently%20serve%2054%2C994%20customers,Village%2C%20 Lennox%20and%20Gardena%20Heights. Accessed October 24, 2023.
4. Environmental Impacts Analysis
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30,651 AFY with a total purchase commitment of 91,953 AF over the five-year term of the agreement, shared by all of GSWC’s systems served by WBMWD.
WBMWD entered into a new 10-year term purchase order with MWD effective January 1, 2015, through December 31, 2024. For the first five years of the new purchase order term, MWD staff recommended to not enter into agreements with its customer agencies.
WBMWD acts as secondary wholesale water agency, purchasing water from MWD and reselling it to GSWC. MWD supplies imported water sourced from the SWP and the Colorado River via a series of pipelines and aqueducts.
The Colorado River was MWD’s original source of water following its establishment in 1928.
MWD has a legal entitlement to receive water from the Colorado River under a permanent service contract with the United States Secretary of the Interior. The Colorado River Aqueduct, which has a capacity of 1.25 million AFY, is owned and operated by MWD. It transports water from Lake Havasu, at the border of California and Arizona, approximately 242 miles west to its terminus at Lake Mathews in Riverside County and MWD’s service area.
MWD also imports water from the SWP, which is owned by the State of California and operated by DWR. This project transports Feather River water stored in and released from Oroville Dam and conveyed through the Bay-Delta, as well as unregulated flows diverted directly from the Bay- Delta, south via the California Aqueduct to four delivery points: one from the California Aqueduct’s West Branch at Castaic Lake and three from the East Branch along the northeastern portion of MWD’s service area between Devil’s Canyon Power Plant and Lake Perris.
MWD’s 2015 IRP details a series of reliability goals, approaches, and targets for each of their water resource areas, with some focus on maintaining existing capabilities and increasing net quantities over the 25-year planning horizon. The goals identified are:
• Maintain Colorado River Aqueduct supplies;
• Stabilize state Water Project supplies;
• Achieve additional conservation savings; and
• Develop and protect local water supplies.
MWD published annual implementation reports on its progress towards the 2015 IRP goals. The most recent Implementation Report (2019)
20 highlights the progress on achieving the above
resource and reliability goals established in the 2015 IRP as follows:
• MWD has worked closely with other agencies to improve reliability of its imported water supplies. MWD led efforts in crafting the Lower Colorado River Basin Drought Contingency Plan and supported efforts to make the Delta more resilient and support Governor Newsom’s new direction to advance a single tunnel solution in the Delta.
20 Metropolitan Water District of Southern California, Report on Integrated Water Resources Plan (IRP) Implementation, October 8, 2019.
4. Environmental Impacts Analysis
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City of Culver City 4.13.1-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• MWD continues to support and encourage local supply development through the Local Resources Program. MWD’s board approved three projects with a total contract yield of 3,660 acre-feet per year from January 2019 to date. Seven additional applications for a total of 116,580 acre-feet per year are under consideration. MWD is also assessing the water supply benefits from stormwater through pilot programs.
• MWD continues to inform residents of water use efficiency through ongoing advertising campaigns and education. In addition to rebates for water efficient fixtures, MWD also implements programs targeting outdoor conservation with its landscape education and turf replacement programs. In 2019, MWD’s board approved a conservation initiative that focuses on reaching disadvantaged communities.
The 2020 IRP is a two-phase process including a Regional Needs Assessment (Phase 1) and a One Water Implementation phase (Phase 2). The Draft Regional Needs Assessment was completed in April 2022, and includes the analysis of regional needs under a range of scenarios: (1) Scenario A, low demand and stable imports, (2) Scenario B, high demand and stable imports, (3) Scenario C, low demand and reduced imports, and (4) Scenario D, high demand and reduced imports . 21 The
Draft Regional Needs Assessment found plausible reliability outcomes by the year 2045, with potential shortages ranging from no net shortage at all under Scenario A to as high as 1.2 million acre-feet under Scenario D, and identifies needs and opportunities related to five focus areas: (1) SWP dependent areas, (2) storage, (3) retail demand/ demand management, (4) MWD imported supplies, and (5) local supply. The Draft Regional Needs Assessment concludes that “[c]ollectively, these findings instill a sense of optimism about Southern California’s water future. Metropolitan has identified the tools necessary to adapt to a variety of plausible futures successfully. It is also well within Southern California’s control to avoid a fate with increased per - capita water use and higher demands that would prove unsustainable.” It further notes that through the One Water Phase of the process, “the precise combination of actions will emerge as more is known about the future that we actually face. Southern California is poised to be agile enough to adjust its portfolio of water actions to keep up with our changing times.”
As an additional acknowledgment, recycled water is not served to customers within the City service area and is not expected to supply the Project. It is noted, however, that wastewater generated within the service area is treated by the City of Los Angeles, and a portion of that treated wastewater is sold to WBMWD for further treatment for recycled water uses throughout the WBMWD service area. Although the City service area does not directly utilize recycled water, its customers contribute to the regional water supply reliability benefit achieved through WBMWD’s distribution of recycled water.
21 Metropolitan Water District of Southern California, 2020 IRP Regional Needs Assessment, April 12, 2022.
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4.13.1.3 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 water supply if it would:
• WS-1: Require or result in the relocation or construction of new or expanded water facilities, the construction of which would cause significant environmental effects. • WS-2: Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.
Methodology
Water Infrastructure
The analysis of impacts to water infrastructure is based on the analysis in the Water Civil Technical Memorandum prepared for the Project by Kimley Horn (included as Appendix J of this Draft EIR).
The analysis: (1) identifies the domestic water mains and fire hydrants that would serve the Project; (2) identifies the capacity and water pressures in the main s and associated fire hydrant s based on flow; and (3) determines whether the subject water main s and fire hydrant s have the capacity to serve the Project.
Based on the results of the Fire Service Pressure Flow Report provided by GSWC and correspondence with the Culver City Fire Department (CCFD), the Water Civil Technical Memorandum determines whether the Project has sufficient water flow and pressure. 22 Water Supply
As previously detailed, SB 610 requires a discussion regarding the availability of water to meet projected water demands of large-scale projects. As defined in SB 610, large-scale projects include residential development projects of more than 500 residential units or shopping centers employing more than 1,000 persons or having more than 500,000 sf of floor space. The Project would include the development of 309 multi-family dwelling units and 5,600 sf of commercial floor area. As the Project proposes less than 500 dwelling units and less than 500,000 sf of commercial floor space, the Project does not meet the CEQA significance threshold of SB 610, and therefore, a water supply assessment and verification is not required for the Project.
Estimated water use for the Project was provided in the Water Civil Technical Memorandum (Appendix J of this Draft EIR). The Project’s demand for domestic water was assessed in relation to GSWC’s ability to supply water pursuant to the 2020 UWMP. The water demand was calculated based on wastewater generation factors provided by the Los Angeles County Sanitation District.
This method of calculating future water demand for new development is a common practice in the Los Angeles region , including for Culver Ci ty. Additionally, the GSWC provided a Will Serve
22 See Appendix J – Water Civil Memorandum, of this Draft EIR for correspondence provided by GSWC and CCFD.
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Letter dated April 26, 2023 (located in Appendix J of this Draft EIR ), stating that the Project Site would be supplied with water from the existing municipal system.
Project Design Features
The following project design features are applicable to the Project:
WATER-PDF-1 (Water Conservation): The Project will implement water conservation measures that include, but are not limited to, the following:
• Landscape and Irrigation
o California Friendly® plants or native plants
o Drip/ Subsurface Irrigation (Micro-Irrigation)
o Proper Hydro-zoning/Zoned Irrigation (groups plants with similar water requirements together)
Analysis of Project Impacts
Threshold WS-1: The Project w ould have a potentially significant impact if it would require or result in the relocation or construction of new or expanded water facilities, the construction of which would cause significant environmental effects.
Impact Analysis
Construction
Water, such as soil watering for soil compacting and fugitive dust control, masonry, painting, clean- up, and other related activities, would be required during construction. Project construction is projected to begin in early 2025 and is expected to take approximately 30 months to complete. Full build-out is expected as early as the fourth quarter of 2027. Water for construction would be required for activities such as dust control, cleaning of equipment, excavation/export, removal and re-compaction. Non-potable water could be used for soil compacting and dust control purposes, if required, and would represent the majority of the water used during construction. Such practices are implemented by the contractor and use non-potable water trucked to a construction site. Project construction activities would create a demand for some potable water, such as drinking, cleaning of brushes and other items, and lavatories. According to the Water Civil Technical Memorandum, based on contractor estimates, construction wat er usage is estimated to be approximately 75 gpd for the Project Site. The estimated construction water use would be less than the existing domestic water use of approximately 7,360 gpd for the Project Site (as shown in Table 4.13.1-1). As such, it is anticipated that the existing water infrastructure would meet the limited and temporary water demand associated with construction of the Project.
The Project would also require construction of new, on-site water distribution lines to serve the Project. According to the Water Civil Technical Memorandum, the Project would include a proposed 8-inch domestic water line and an 8-inch fire water line connection to tie into the existing 12-inch water main in Hannum Avenue. Construction impacts associated with the installation of water distribution lines would primarily involve trenching in order to place the water distribution
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lines below surface and would be limited to on-site water distribution, and minor off -site work associated with connections to the public main. No upgrades to existing water mains are anticipated at this time. As detailed in Chapter 4.11, Transportation, TRAF-PDF -1 would require implementation of a Construction Management Plan that would reduce any temporary pedestrian and traffic impacts. The contractor would implement the Construction Management Plan, which would ensure safe pedestrian access and vehicle travel and emergency vehicle access throughout the construction phase. Prior to ground disturbance, Project contractors would coordinate with GSWC to identify the locations and depth of all lines. Further, GSWC would be notified in advance of proposed ground disturbance activities to avoid water lines and disruption of water service and would be responsible for the installation of new meters and main connection, as well as work on water mains within the public right-of -way. Therefore, Project impacts on water associated with construction activities would be less than significant.
Operation
Water service to the Project Site would continue to be provided by GSWC, as under existing conditions. When analyzing the Project for infrastructure capacity, although domestic water demand is the Project’s main contributor to water consumption, fire flow demands have a much greater instantaneous impact on infrastructure and are, therefore, the primary means for analyzing infrastructure capacity.
According to the Water Civil Technical Memorandum (Appendix J of this Draft EIR), the Project would have a minimum fire flow requirement of 1,500 gpm at 20 psi residual for a duration of 2 hours, in compliance with the CCMC Section 9.02. Per the Fire Service Pressure Flow Report provided by GSWC (located within Appendix J), the existing fire hydrant connected to the 12-inch water main in Hannum Avenue can provide 4,409 gpm at 20 psi for a duration of 2 hours.
Additionally, a ccording to correspondence with t he CCFD (located within Appendix J), an additional fire hydrant would not be required as part of the Project. Therefore , the site’s existing fire hydrant infrastructure would be sufficient to meet the Project’s fire flow requirements..
Based on the above, the existing GSWC water infrastructure has adequate capacity and pressure to meet the Project’s domestic and fire flow requirements. As such, Project operation would not require or result in the relocation or construction of new or expanded water facilities, the construction of which would cause significant environmental effects. Project operational impacts related to water infrastructure 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 not require the relocation or construction of new or expanded water facilities and impacts would be less than significant.
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Threshold WS-2: T he Project would have potentially significant impact if it would not have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.
Impact Analysis
Construction
As stated under Threshold WS-1, water would be required for Project construction activities, such as dust control, cleaning of equipment, excavation/export, removal and re -compaction, and other related activities. Construction activities would be intermittent, with demand for water consumption variable but generally temporary in nature.
As stated above and in the Water Civil Technical Memorandum, an estimate of potable construction water demand would be approximately 75 gpd for the Project. The estimated construction water use would be less than the existing domestic water use of approximately 7,360 gpd for the Project Site. As such, it is anticipated that the existing water supply would meet the limited and temporary water demand associated with construction of the Project. Water use during construction would be temporary given that proje ct construction activities would be temporary (approximately 30 months). It is, therefore, expected that Project construction activities would generate minimal potable water demand and would be met with existing water supplies provided by GSWC.
As analyzed below under Operational impacts, sufficient water supplies exist to meet the Project’s projected operational water demand, in addition to the existing and planned future demands for normal, single-dry, and multiple-dry years on GSWC water supplies. As Project construction would require a nominal amount of water compared to Project operation, the Project’s intermittent construction-related water demand would be met by GSWC ’s available water supplies. For these reasons, adequate water supplies would be available from existing entitlements and resources for Project construction activities.
Therefore, GSWC would have sufficient water supplies to serve the Project during construction and reasonably foreseeable future development during normal, dry, and multiple -dry years, and impacts on water supply during construction would be less than significant.
Operation
Project Water Demand
Estimated domestic water demand for the Project is shown in Table 4.13.1-2, Project’s Estimated Water Consumption, which shows the net increase in potable water that would be required for the Project. As shown in Table 4.13.1-2, the net water demand for the Project would be 36,446 gpd, or 41 AFY.
Golden State Water Company Culver City Service Area Water Demand and Reliability Assessment
As discussed above, water purchased from WBMWD constitutes the primary source of supply for the GSWC Culver City service area, and is expected to be the sole source of supply within the 2045 planning horizon. The total projected potable supplies for the GS WC Culver City service area for normal, single dry, and multiple dry years are presented in Table 4.13.1-3, Projected Normal Year Water Supply and Demand for Culver City Service Area , Table 4.13.1-4, Single Dry Year Water
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Supply and Demand for Culver City Service Area, and Table 4.13.1-5, Five Consecutive Dry Years Water Supply and Demand through 2045 for Culver City Service Area , respectively. As shown in the tables, GSWC has sufficient supplies to meet demand in normal, single dry, and multiple dry years without shortages.
TABLE 4.13.1-2
PROJECT’S ESTIMATED WATER CONSUMPTION
Proposed Use Units Water Use Ratea
Water Usageb
gpd AFY
Residential
Studio
1 Bed
2 Bed
39 units
180 units
90 units
75/unit
110/unit
150/unit
36,225
41 Commercial 5,600 sf 50/1,000 sf 280 0.3
Irrigation b - - 7,301 8
Total Proposed Water Demand 43,806 49
Existing Site Demand -7,360 -8
Total Net Water Demand 36,446 41
NOTES: gpd = gallons per day; sf = square feet, AFY = acre-feet per year. a Estimated water usage is estimated as being equivalent to the estimated sewage generation for the Project.
These rates are assessed using LA County Sanitation’s Estimated Wastewater Generation Tables. b 20% factor included to account for landscaping and irrigation consumption.
SOURCE: Kimley Horn, Water Civil Technical Memorandum, 2023 (Appendix J of this Draft EIR)
TABLE 4.13.1-3
PROJECTED NORMAL YEAR WATER SUPPLY AND DEMAND FOR CULVER CITY SERVICE AREA 2025 2030 2035 2040 2045
Normal Year Supply 5,002 5,086 5,175 5,269 5,370
Normal Year Demand 5,002 5,086 5,175 5,269 5,370
Difference 0 0 0 0 0
NOTE: All values in acre-feet.
SOURCE: GSWC, Culver City Service Area 2020 Urban Water Management Plan, June 15, 2021.
TABLE 4.13.1-4
SINGLE DRY YEAR WATER SUPPLY AND DEMAND FOR CULVER CITY SERVICE AREA 2025 2030 2035 2040 2045
Single Dry Year Supply 5,502 5,594 5,692 5,796 5,907
Single Dry Year Demand 5,502 5,594 5,692 5,796 5,907
Difference 0 0 0 0 0
NOTE: All values in acre-feet.
SOURCE: GSWC, Culver City Service Area 2020 Urban Water Management Plan, June 15, 2021.
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TABLE 4.13.1-5
MULTIPLE (FIVE) CONSECUTIVE DRY YEARS WATER SUPPLY AND DEMAND THROUGH 2045 FOR
CULVER CITY SERVICE AREA
Year 2025 2030 2035 2040 2045
1 Dry Year Supply 5,502 5,594 5,692 5,796 5,907
Dry Year Demand 5,502 5,594 5,692 5,796 5,907
Difference 0 0 0 0 0
2 Dry Year Supply 5,520 5,613 5,712 5,817 5,907
Dry Year Demand 5,520 5,613 5,712 5,817 5,907
Difference 0 0 0 0 0
3 Dry Year Supply 5,538 5,633 5,733 5,839 5,907
Dry Year Demand 5,538 5,633 5,733 5,839 5,907
Difference 0 0 0 0 0
4 Dry Year Supply 5,557 5,652 5,754 5,862 5,907
Dry Year Demand 5,557 5,652 5,754 5,862 5,907
Difference 0 0 0 0 0
5 Dry Year Supply 5,575 5,672 5,775 5,884 5,907
Dry Year Demand 5,575 5,672 5,775 5,884 5,907
Difference 0 0 0 0 0
NOTE: All values in acre-feet.
SOURCE: GSWC, Culver City Service Area 2020 Urban Water Management Plan, June 15, 2021.
The WBMWD 2020 UWMP states that it will be able to serve 100 percent of projected demands in normal, single-dry and multiple-dry years. Because of this, GSWC expects that under all hydrologic conditions purchased water supplies will fully meet future purch ased water demands. Therefore, consistent with the City service area 2020 UWMP, the available supplies to the GSWC Culver City service area are considered to be equal to demands under all conditions (i.e., current and projected, and for normal, single dry, and multiple dry years including a 5-year drought period).
Table 4.13.1-3, Table 4.13.1-4, and Table 4.13.1-5 show sufficient water supplies in all hydrologic years; however, in the event of a water supply shortage as described in the GSWC 2020 UWMP, GSWC can implement its Water Shortage Contingency Plan (WSCP). 23 The WSCP requires water
response actions to six water shortage stages, which correspond to progressively severe water shortage conditions (up to 10 percent, 20 percent, 30 percent, 40 percent, 50 percent, and greater than 50 percent shortage) as compared to the normal reliability condition. The following six (6) Stages list the shortage response actions:
• Stage 1 (0 to 10% shortage) – Stage 1 is a “Water Alert” where voluntary conservation is encouraged.
23 GSWC, Culver City Service Area 2020 Urban Water Management Plan, Chapter 6, June 15, 2021.
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• Stage 2 (10% to 20% shortage) – Stage 2 is a “Moderate Shortage” and will be implemented if the Stage 1 restrictions are deemed insufficient to achieve necessary demand reductions due to water supply shortages.
• Stage 3 (20% to 30% shortage) – Stage 3 is a “Severe Shortage” that requires water allocations and mandatory conservation.
• Stage 4 (30% to 40% shortage) – Stage 4 is a “Critical Shortage” that includes all steps taken in prior stages regarding allocations and mandatory conservation. • Stage 5 (40% to 50% shortage) – Stage 5 is a “Shortage Crisis” that includes all steps taken in prior stages regarding allotments and mandatory conservation. This stage will be implemented in the event that the source of supply is severely curtailed to the level that requires each customer to restrict their water use for only human health and safety purposes. • Stage 6 (50% or greater shortage) – Stage 6 is an “Emergency Shortage” condition that includes all steps taken in prior stages regarding allotments and mandatory conservation.
Project Water Supply Availability
The water demand projections in GSWC’s 2020 UWMP were developed based on SCAG’s 2020– 2045 RTP/SCS demographic projections. GSWC’s 2020 UWMP identified water supplies to meet projected water demands through 2045. GSWC’s water supply projections in their 2020 UWMP are sufficient to meet the water demand for projects that are determined by the CEQA lead agency to be consistent with the 2020 RTP/SCS by SCAG.
The analysis included in this Draft EIR indicates that the Project would conform with the use and intensity of development permitted by the City’s General Plan. The Project is also consistent with the demographic projections in the 2020 RTP/SCS. Thus, the anticipated water demand for the Project would be within GSWC’s 2020 UWMP projected water supplies for normal, single -dry, and multiple-dry years through the year 2045 and is also within the GSWC 2020 UWMP’s 25-year water demand growth projections. Table 4.13.1-3 to Table 4.13.1-5 show sufficient water supplies in all hydrologic years would be available by GSWC, as applicable.
Therefore, given that (1) the 2020 GSWC UWMP projections are inclusive of the Project and do not identify supply shortfalls under any hydrologic conditions evaluated; (2) the GSWC has the ability to implement a WSCP in the case of supply shortages, and demonstrated its effectiveness during the historic 2013 –2017 drought; and (3) the increasing efficiency and drought planning requirements from the State, sufficient water supply is estimated to be available to GSWC to meet all future demands within the Culver City service area and those associated with the Project.
Additionally, GSWC provided a Will Serve Letter dated April 26, 2023 (located in Appendix J of this Draft EIR) stating that the Project Site would be supplied with water from the existing municipal system.
Based on the above, there would be sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years. Water supply impacts would be less than significant.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
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Level of Significance After Mitigation
Not applicable. Impacts regarding water supply would be less than significant.
Cumulative Impacts
Impact Analysis
The geographic context for the cumulative impact analyses on water infrastructure and water supply is the vicinity of the Project Site (i.e., the water infrastructure that would serve the Project and the GSWC service areas). Chapter 3, Environmental Setting , of this Draft EIR, identifies 12 related projects that are anticipated to be developed within a 1 -mile radius of the Project Site. These projects are summarized in Table 3 -1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapt er 3. As shown in Table 3 -1, these related Projects occur in two separate jurisdictions, the City of Culver City and the City of Los Angeles. Of these related projects, eight occur within Culver City and, like the Project, would create a demand for water service from the GSWC.
Water Infrastructure
Development of the Project, in conjunction with the related projects, would cumulatively increase service demand on the existing water infrastructure system. However, each related project would be subject to the applicable city review, as applicable, to en sure that the existing public utility facilities would be adequate to meet the domestic and fire water demands of each project. All projects are required to perform a hydraulic analysis, based on flow testing of facilities, to verify that there is available service. Individual projects are required to improve facilities where appropriate and development cannot proceed without appropriate verification and approval.
Furthermore, GSWC and the City’s Department of Public Works conduct ongoing evaluations to ensure facilities are adequate and requires infrastructure system improvements as needed. Based on these facts and the above analysis relating to the Project’s construction and operational impacts on the water infrastructure system, the Project’s incremental effects on the water infrastructure system would not be cumulatively considerable. Cumulative impacts on water infrastructure would be less than significant.
Water Supply
As discussed above, as a public water service provider , GSWC is required to prepare and periodically update its UWMPs to plan and provide for water supplies to serve existing and projected demands. GSWC’s 2020 UWMP account s for existing development within its s ervice area, as well as projected growth through the year 2045. Additionally, under the provisions of SB 610, GSWC is required to prepare a comprehensive WSA for every new development “project” (as defined by Section 10912 of the Water Code) that meets certain criteria, as required . The WSAs for such projects, in conformance with the UWMP, would evaluate the reliability of existing and projected water supplies, as well as alternative sources of water supply and measures to secure alternative sources if needed, on a project-by-project basis.
The related projects would contribute, in conjunction with the Project, to overall water demand on GSWC. As shown in Table 4.13.1-6, Estimated Cumulative Water Generation, the related projects are anticipated to generate a total water demand of approximately 242 AFY in the GSWC Culver
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City service area. With the Project, the cumulative demand would be approximately 283 AFY in the GSWC Culver City service area. For purposes of this analysis and to provide a conservative estimate of the related projects’ water demand, the related projects’ wastewater generation is assumed for the related projects water demand. This estimate is conservative (i.e., high) since the wastewater generation rates do not quantify code -required conservation or applicant conservation commitments that would reduce water demand by the related projects or deduct for existing uses and assumes all the related projects would be fully built out.
TABLE 4.13.1-6
ESTIMATED CUMULATIVE WATER GENERATION BY RELATED PROJECTS Land Use Quantity Generation Factora
Water Demand
(gpd)
Residential b 762 du 150/du 114,300
Office 562.59 ksf 120/ksf 67,511
Medical Office 38.71 ksf 250/ksf 9,678
Retail 32.01 ksf 25/ksf 800
Hotel 183 rooms 130/room 23,790
Subtotal -- -- 216,079 (242 AFY)
Proposed Project Net -- -- 36,446 (41 AFY)
Total -- -- 250,695 (283 AFY)
du = dwelling units, ksf = 1,000 square feet , gpd = gallons per day, AFY = acre-feet per year a Water demand is based on the wastewater generation factors from the City of Los Angeles Sewage Generation Factor for Residential and Commercial Categories, April 6, 2012. b Assumes all two-bedroom units.
SOURCE: ESA, 2023.
The 283 AF water demand of the Project and related projects would represent approximately 6.0 percent of GSWC’s 2020 Culver City service area water supply of 4,707 AF, with the Project’s share of 41 AF representing approximately 0.8 percent of GSWC’s 2020 Culver City service area water supply.
As previously stated, GSWC would be able to meet the water demand of the Project together with the existing and forecasted growth in the service area through 2045. Additionally, based on water demand projections through 2045 in the 2020 UWMP, GSWC has determined that they would be able to reliably provide water to its customers through the year 2045, based on demographic growth projections in SCAG’s 2020– 2045 RTP/SCS which includes the Project and likely the related projects. In addition, compliance of the Project and other future development projects with the numerous regulatory requirements that promote water conservation described above would also reduce water demand on a cumulative basis. For example, any related projects meeting the size criteria under SB 610 would be required to prepare and obtain GSWC approval of a WSA, as applicable, that demonstrates how the water demand associated with these projects would be met.
Overall, as discussed above, the 2020 GSWC UWMP demonstrate that the City will meet all new water demands from projected population growth, through a combination of water conservation
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and water recycling. The 2020 UWMP outline sources of water and measures to ensure adequate supplies of water are available to meet the needs of the service area. Furthermore, GSWC will continue to update their UWMP every five years to ensure that sufficient water supply continues to be available.
Based on the above, it is anticipated that GSWC would be able to meet the water demands of the Project and future growth within its service area through at least 2045. Therefore, the Project together with the related projects would not result in a significant cumulative impact related to water supply, nor would the Project contribute considerably to significant cumulative water demand impacts. As such, cumulative water supply 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 water infrastructure and water supply would be less than significant.
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4.13.2 Utilities and Service Systems – Electric Power,
Natural Gas, and Telecommunications Facilities
4.13.2.1 Introduction
The following section analyzes the Project’s potential impacts upon electric power, natural gas and telecommunications facilities. This section focuses on the existing facilities serving the project area and the potential for environmental impact to occur as a result of any physical improvements that may be necessary to accommodate the Project. Potential impacts associated with energy demand and energy conservation policies are discussed in Section 4.4, Energy, of this Draft EIR.
4.13.2.2 Environmental Setting
Regulatory Framework
Federal
United States Department of Energy (Energy Policy Act of 2005) The United States Department of Energy (DOE) is the federal agency responsible for establishing policies regarding energy conservation, domestic energy production and infrastructure. The Federal Energy Regulatory Commission (FERC) is an independent federal agency, officially organized as part of the DOE which is responsible for regulating interstate transmission of natural gas, oil and electricity, reliability of the electric grid and approving of construction of interstate natural gas pipelines and storage facilities. The Energy Policy Act of 2005 has also granted FERC with additional responsibilities of overseeing the reliability of the nation’s electricity transmission grid and supplementing state transmission siting efforts in national interest electric transmission corridors.
FERC has authority to oversee mandatory reliability standards governing the nation’s electricity grid. FERC has established rules on certification of an Electric Reliability Organization (ERO) which establishes, approves and enforces mandatory electricity reliability standards. The North American Electric Reliability Corporation (NERC) has been certified as the nation’s ERO by FERC to enforce reliability standards in all interconnected jurisdictions in North America. Although FERC regulates the bulk energy transmission and reliability throughout the United States, the areas outside of FERC’s jurisdictional responsibility include state-level regulations and retail electricity and natural gas sales to consumers which falls under the jurisdiction of state regulatory agencies.
Federal Communications Commission
The Federal Communications Commission (FCC) requires all new cellular tower construction to be approved by the state or local authority for the proposed site and comply with FCC rules involving environmental review. Additionally, the Telecommunications Act of 1996 requires construction of new cellular towers to comply with the local zoning authority.
State
California energy infrastructure policy is governed by three institutions: the California Independent System Operator (California ISO), the California Public Utilities Commission (CPUC), and the California Energy Commission (CEC). These three agencies share similar goals but have different
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roles and responsibilities in managing the State’s energy needs. The majority of State regulations with respect to electricity and natural gas pertain to energy conservation. For a discussion of these regulations, refer to Section 4.4, Energy, of this Draft EIR. Regulations pertaining to infrastructure are discussed below.
California ISO
The California ISO is an independent public benefit corporation responsible for operating California’s long-distance electric transmission lines. The California ISO is led by a five -member board appointment by the Governor and is also regulated by FERC. While transmission owners and private electric utilities own their lines, the California ISO operates the transmission system independently to ensure that electricity flows comply with federal operational standards. The California ISO analyzes current and future electrical demand and plans for any needed expansion or upgrade of the electric transmission system.
California Public Utilities Commission
The CPUC establishes policies and rules for electricity and natural gas rates provided by private utilities in California such as Southern California Edison (SCE) and Southern California Gas Company (SoCalGas). Public owned utilities such as the Los Angeles Department of Water and Power (LADWP) do not fall under the CPUC’s jurisdiction.
The CPUC is overseen by five commissioners appointed by the Governor and confirmed by the State senate. The CPUC’s responsibilities include regulating electric power procurement and generation, infrastructure oversight for electric transmission lines and natural gas pipelines and permitting of electrical transmission and substation facilities.
California Energy Commission
The CEC is a planning agency that provides guidance on setting the State’s energy policy. The CEC’s responsibilities include forecasting electricity and natural gas demand, promoting and setting energy efficiency standards throughout the State, developing renewable energy resources and permitting thermal power plants 50 megawatts and larger. The CEC also has specific regulatory authority over publicly owned utilities to certify, monitor , and verify eligible renewable energy resources procured.
Senate Bill 1389
Senate Bill (SB) 1389 (Public Resources Code Sections 25300 –25323), adopted in 2002, requires the development of an integrated plan for electricity, natural gas, and transportation fuels. Under the bill, the CEC must adopt and transmit to the Governor and Legislature an Integrated Energy Policy Report every two years. The 2021 Integrated Energy Policy Report, the latest report published by the CEC, provides the results of the CEC’s assessments related to energy sector trends, building decarbonization and energy efficiency, zero -emission vehicles, energy equity, climate change adaptation, electricity reliability in Southern California, natural gas assessment, and electricity, natural gas, and transportation energy demand forecasts. 1 1 California Energy Commission (CEC), 2021 Integrated Energy Policy Report, February 22, 2022.
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Local
City of Culver City
Culver City Municipal Code
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. 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 photovoltaic (PV) power installed per 10,000 square feet (sf) of new development. The CCMC includes an option to pay an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code. Under Chapter 17.320.035 of the CCMC, the City goes beyond California Green Building Standards (CALGreen) Building Code standards and requires at least 20 percent electric vehicle (EV) capable parking spaces, 10 percent EV ready parking spaces, and 10 percent EV charging stations for both new residential and retail developments. 2 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 Program 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 has to be either fluorescent, light-emitting diode ( LED) or other type of high-efficiency lighting, and specific features for parking garages would require all new lighting to be motion sensor controlled and the minimum base level lighting would use high efficiency lighting.
Culver City Municipal Code Section 11.20
Section 11.20 of the CCMC outlines rules and regulations related to telecommunications installation within Culver City. The intent of the CCMC is:
1. To enable the City to discharge its public trusts in a manner consistent with rapidly evolving federal and state regulatory policies, industry competition, and technology development.
2. To authorize and to manage reasonable access to the City's public right-of-way and public property for telecommunications purposes on a competitively neutral and nondiscriminatory basis.
3. To obtain fair and reasonable compensation for the City and its residents for authorizing the private use of the public rights-of-way and public property, which are recognized to be valuable public assets, held in trust by the City.
4. To foster and to promote competition in telecommunications services, minimize unnecessary local regulation of telecommunications service providers, and encourage the delivery of advanced and competitive telecommunications services on the broadest possible basis to local government and to the businesses, institutions and residents of the City.
2 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 July 12, 2022.
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5. To establish clear local guidelines, standards and time frames for the exercise of local authority with respect to the regulation of telecommunication service providers, including establishment and enforcement of consumer service standards and technical standards.
6. To encourage the profitable deployment of advanced telecommunications infrastructures that satisfy local needs, deliver enhanced government services, and provide informed consumer choices in an evolving telecommunication market.
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 the City of Culver City. With this change, CPA purchases the renewable energy resources for electricit y and SCE delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent or opt out of the CPA to remain with SCE as their provider. 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.
3 Culver City Information Technology Department
The City of Culver City Information Technology Department (IT) is responsible for providing computing, telecommunications, and network service to all departments and divisions within the City. IT provides project management, systems planning, design, and programming support for the enhancement of existing and new systems.
4 IT also provides high-speed fiber -optic internet cables for Culver City businesses to promote economic development. Culver City's municipal fiber network, known as Culver Connect, has a
21.7-mile network backbone in three geographical network rings interconnected by “ring ties” of approximately 3.1 route miles of fiber. The network backbone is comprised of 576 strands of entirely undergrounded fiber. There are three hub facilities located in the City that house City- owned network electronics. The City leases two fiber connections to carrier hotels at One Wilshire in Los Angeles and Equinix (LA3) in El Segundo.
3 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. 4 City of Culver City, Information Technology, https://www.culvercity.org/City-Hall/Departments/IT. Accessed July 12, 2022.
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Existing Conditions
Electric Power
Electric Supplies
SCE provides electrical services to approximately 15 million people, 15 counties, and 180 incorporated cities, including the City of Culver City and a portion of the Project Site. It also provides services to approximately 5,000 large businesses, and 280,000 businesses throughout a 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 Bernardino County to the East, and Orange County to the South.
5 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 megawatts), coal, gas, nuclear sources, and renewable resources, such as wind, solar, small hydropower (less than 30 megawatts), and geothermal sources. The annual electricity sale to customers in 2022 was approximately 84,218,000 megawatt-hours.6 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 the City of Culver City. With this change, CPA procures and purchases the 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. As of 2023, CPA serves over 3 million residents and businesses over 32 communities within Southern California.
7 In 2022, CPA procured over 1,700 MW of renewable energy and provided its customers with over 2,186,367 MWh of electricity. 8 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.
Electricity Distribution System
The power supplied to SCE consumers is distributed through a network of approximately 104,000 miles of circuits, 700 substations, and approximately 1.5 million power poles. 9 5 Southern California Edison (SCE), Who We Are, https://www.sce.com/about-us/who-we-are. Accessed October 2023. 6 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.
7 CPA, 2022 Annual Impact Report, https://cleanpoweralliance.org/wp- content/uploads/2023/06/ImpactReport2022.pdf. Accessed October 2023. 8 CPA, 2022 Annual Impact Report, https://cleanpoweralliance.org/wp- content/uploads/2023/06/ImpactReport2022.pdf. Accessed October 2023. 9 SCE, About Us, 2022, https://www.sce.com/about-us/reliability. Accessed October 2023.
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Natural Gas
Natural Gas Supplies
As discussed in Section 4.4, Energy, of this Draft EIR, SoCalGas provides natural gas resources to the City and most of Southern California and Central California from the City of Visalia to the U.S./Mexican border.
10 The availability of natural gas is based upon present conditions of gas supply and regulatory policies as SoCalGas is under the jurisdiction of the CPUC and other federal regulatory agencies. In addition, SoCalGas makes available to its customers energy-e fficiency programs with rebates and incentives for the purpose of reducing natural gas consumption.
Natural Gas Distribution Systems
Interstate Distribution Systems
Natural gas is supplied to the Southern California region through a system of interstate pipelines.
The 2020 California Gas Report projects that California natural gas demand is expected to decline at an annual rate of 1.5 percent per year from 2020 to 2035 in the SoCalGas service area. 11 Gas
supply available to SoCalGas from California sources averaged 3, 435 million cubic feet ( cf) per day per day in 2022. This equates to an annual average of 1,253,775 million cf per year per year.12 Local Distribution System
SoCalGas provides natural gas resources to the City of Culver City through existing gas mains located under the streets and public rights-of-way. Natural gas services are provided in accordance with SoCalGas’ policies and extension rules of the CPUC at the time contractual agreements are made. Natural gas is delivered to the Project Site through natural gas underground facilities within Buckingham Parkway.
4.13.2.3 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 impact related to electric power, natural gas, or telecommunications facilities if it would:
• INF-1 Require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
13 Methodology
The analysis evaluates the potential impacts of the Project on existing energy infrastructure by comparing the estimated Project energy demand with available capacity. Project energy usage,
10 Southern California Gas Company (SoCalGas), Company Profile, https://www.socalgas.com/about-us/company- profile. Accessed October 2023.
11 California Gas and Electric Utilities, 2022 California Gas Report, 2022, p. 115. 12 California Gas and Electric Utilities, 2022 California Gas Report. 13 Refer to Section 4.13.1, Utilities and Service Systems – Water Supply, of this Draft EIR for a discussion of water infrastructure; Section 4.13.2, Utilities and Service Systems – Wastewater, of this Draft EIR for a discussion of wastewater infrastructure; and Section 4.8, Hydrology and Water Quality, of this Draft EIR for a discussion of storm water infrastructure. Also refer to the Initial Study provided in Appendix A of this Draft EIR for a discussion of telecommunication systems.
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including electricity and natural gas, was calculated using CalEEMod Version 2022.1.1. During construction, energy would be consumed in the form of electricity associated with conveyance of water, lighting, and other construction activities necessitating electrical power. Construction activities typically do not involve the consumption of n atural gas. Operational energy consumption would include electricity and natural gas from uses such as heating/ventilation/air conditioning (HVAC); water heating, cooking, lighting, and use of electronics/appliances. Additional details regarding Project energy usage are provided in Section 4.4, Energy, and Appendix E of this Draft EIR.
For consistency with the emissions modeling provided in Section 4.2, Air Quality , Section 4.4, Energy, and Section 4.6, Greenhouse Gas Emissions, the Project’s energy use was calculated assuming buildout would occur in 2027. This analysis assumes that the Project would comply with the same Title 24 Building Energy Efficiency Standards (currently the 2022 version). While the Title 24 standards are typically revised every 3 years with more stringent energy efficiency requirements, it is not known to what extent future revisions to the Title 24 standards would reduce the Project’s energy demand. Therefore, it is not possible to accurately quantify the effects of future revisions to the Title 24 standards on the Project’s energy demand.
The Project’s estimated energy demands were analyzed relative to existing and planned energy supplies of SCE and SoCalGas in 2027 (i.e., the first full Project buildout year) to determine if these energy utility companies would be able to meet the Project’s energy demands.
The Project’s need for expanded telecommunication services was analyzed previously in the Initial Study and deemed to be less than significant. Therefore, no further analysis of telecommunications services is included within this Draft EIR. Please refer to Appendix A-2 of this Draft EIR for a copy of the Initial Study and additional information regarding telecommunication services.
Project Design Features
No specific project design features are proposed with regard to electric power and natural gas facilities. However, the Project includes project design features to improve energy efficiency, as set forth in Section 4.6, Greenhouse Gas Emissions, of this Draft EIR.
Analysis of Project Impacts
Impact INF-1: The Project could have a potentially significant impact if it would require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
Impact Analysis
Electric Power
Construction
Construction activities at the Project Site would require limited and minor quantities of electricity for watering, lighting, power tools and other support equipment. Heavy construction equipment would be powered with diesel fuel. Construction electricity usage would be offset by the reduction
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in the existing electricity usage at the Project Site from the removal of the existing buildings. As existing power lines are located in the vicinity of the Project Site, temporary power poles would be installed to provide electricity during Project construction. 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 approximately
1.9 percent of the Project’s net annual operational electricity consumption, of which would be within the supply and infrastructure capabilities of SCE.
14 Therefore, construction of the Project 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 energy facilities or expansion of existing facilities, the construction of which could cause significant environmental effects.
With regard to existing electrical distribution lines, the Applicant would be required to coordinate electrical infrastructure removals or relocations with SCE and comply with site -specific requirements set forth by SCE, which would ensure that service disruptions and potential impacts associated with grading, construction, and development within SCE easements are minimized.
Therefore, construction of the Project is not anticipated to adversely affect the electric power facilities serving the surrounding uses or utility system capacity and would not require the construction of new energy facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects.
Operation
As reported in Table 4.4 -5, Summary of Annual Energy Use During Project Operation , in Section 4.4, Energy, of this Draft EIR, the Project’s annual net increase in operational electricity usage would be approximately 1,794 megawatt-hours (MWh) for the Project. The Project-related increase in annual electricity consumption would represent 0.002 percent of SCE’s projected sales in 2027. During peak conditions, the Project would represent 0.002 percent of the SCE estimated system-wide peak load.
The CEC estimates energy forecasts for SCE using socioeconomic and environmental indicators including geographical and climatic factors, population growth, employments rates, transportation electrification, advances in efficiency and conservation, and demand response programs. 15 The
CEC estimates that SCE would record system sales of approximately 101,171 GWh in 2027.16 The CEC California Energy Demand 2018 –2030 Revised Forecast identif ies adequate energy resources to support future generation capacity. The Project would not require additional infrastructure (i.e., a substation) beyond proposed utilities installed on-site during construction.
Based on the required load forecast projections by SCE, the utility would be expected to meet the Project’s demand, and the Project’s operational electricity services and supply and infrastructure impacts would be less than significant and would not require the construction of new energy
14 The percentage is derived by taking the annual average amount of electricity usage during the construction period (43,767 kWh) and dividing that number by the annual amount of net electricity usage during operation (2,319,787 kWh).
15 CEC, The California Energy Demand 2021–2035.
16 CEC, The California Energy Demand 2018–2030, p. 97.
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facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects.
Natural Gas
Construction
Construction activities, including the construction of new buildings and hardscape, typically do not involve the consumption of natural gas. Accordingly, natural gas would not be expected to be supplied to support Project construction activities; thus, the re would be no expected demand generated by construction.
The Project would involve installation of new natural gas connections to serve the retail uses of the Project Site.
17 Given that 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. Construction impacts associated with the installation of natural gas connections are expected to be confined to grading/trenching activities in order to place the lines below surface. In addition, prior to ground disturbance, Project contractors would notify and coordinate with SoCalGas to identify the locations and depth of all existing gas lines and avoid disruption of gas service to other properties. Therefore, construction of the Project would not result in an increase in demand for, or an interruption in the delivery of, nat ural gas that would affect available supply or distribution infrastructure capabilities and would not result in the construction of new energy facilities or expansion of existing facilities. Further, the construction of the Project would reduce the consumption of natural gas at the Project Site during construction activities due to the removal of existing on-site uses and the inclusion of all-electric development except for the retail uses.
Therefore, the construction of the Project is not anticipated to adversely affect the natural gas facilities serving the surrounding uses or utility system capacity and would not require the construction of new energy facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects.
Operation
As reported in Table 4.4-5, in Section 4.4, Energy, of this Draft EIR, the Project would result in a net decrease of approximately 272,201 cf of natural gas per year. Based on the Project’s reduction in the total natural gas consumption for the region, ongoing SoCalGas long-range planning efforts to provide natural gas for this service region, and sufficient existing infrastructure, it is expected that SoCalGas’ existing and planned natural gas supplies and infrastructure would be sufficient to meet the Project’s demand for natural gas. Based on the required load forecast projections by SoCalGas, the utility would be expected to meet the Project’s demand and natural gas services, and the Project’s operation would not significantly affect the available natural gas supply or distribution infrastructure and would not require the construction of new energy facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects.
17 All other land uses would utilize all-electric appliances and infrastructure.
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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. Impacts regarding electric power or natural gas facilities were determined to be less than significant.
Cumulative Impacts
Impact Analysis
Cumulative impacts occur when the incremental effects of a project are significant when combined with similar impacts from other related projects in a similar geographic area. As presented in Chapter 3, Environmental Setting, of this Draft EIR, Table 3 -1, the City has identified 12 related projects located within the vicinity of the Project Site. Of the 12 related projects, eight ( 8) are located within the City of Culver City and 4 are located within the City of Los Angeles. The geographic context for the a nalysis of cumulative impacts on electricity is SCE’s and LADWP’s 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 ser vice boundaries of SCE, LADWP, and SoCalGas.
Electric Power
Construction
With regard to existing electrical distribution lines, related projects, as with the Project, would be required to coordinate electrical infrastructure removals or relocations with SCE and LADWP and comply with site -specific requirements set forth by SCE and LADWP, which would ensure that service disruptions and potential impacts associated with grading, construction, and development within their respective utilities’ easements are minimized.
Therefore, construction of the Project and related projects is not anticipated to adversely affect the electric power facilities serving the surrounding uses or utility system capacity and would not require the construction of new energy facilities or the expansion of existing facilities, the construction of which could cause significant cumulative environmental effects.
Operation
Electricity infrastructure is typically expanded in response to increasing demand, and system expansion and improvements by SCE and LADWP. As described in CEC’s California Energy Demand 2018–2030 Revised Forecast and LADWP’s 2017 Power Strategic Long-Term Resource Plan, SCE and 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 SCE’s and LADWP’s environmental priorities and reliability standards. The 2017 Power Strategic Long-Term Resource Plan and California Energy Demand 2018–2030 Revised Forecast take into account future energy demand, advances in renewable energy resources and technology, energy efficiency, conservation, and forecast changes in regulatory requirements. In addition, LADWP considers projected Los Angeles County building permit amounts when determining its load forecast and would therefore account for the Project’s and the related project’s electricity demand within its projections.
4. Environmental Impacts Analysis
4.13.2. Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities City of Culver City 4.13.2-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Development projects within the SCE and LADWP service areas would also be anticipated to incorporate site-specific infrastructure improvements, as necessary. Thus, SCE and LADWP consider growth from related projects within their service areas for the need for energy infrastructure, such as new or expanded energy facilities.
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. In addition, the local utility provider would provide service letters for each related project confirming availability of adequate electricity supplies as part of the total load growth of the regional power system. Project applicants would be required to provide for the needs of their individual projects, thereby contributing to the electrical infrastructure in the Project Site area. Related projects would also be required to evaluate electricity demands and coordinate with the local utility provider for providing adequate service, in accordance with future projected supplies, to each of the related project sites.
Related projects would be required to obtain evidence of service from SCE and LADWP, or the appropriate utility provider, to ensure that electric 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 the relocation or construction of new or expanded electric power facilities, the construction or relocation of which could cause significant environmental effects, would not be cumulatively considerable, and cumulative impacts would be less than significant.
Natural Gas
Construction
As stated above, construction activities, including the construction of new buildings and hardscape, typically do not involve the consumption of natural gas. Accordingly, natural gas would not be expected to be supplied to support related projects or Proje ct construction activities; thus, there would be no expected cumulative demand generated by construction.
Operation
Natural gas infrastructure is typically expanded in response to increasing demand and system expansion and improvements by SoCalGas, as needed. Development projects within SoCalGas’ service area, including the Project and related projects, would also be anticipated to incorporate site-specific infrastructure improvements, as appropriate.
Each of the related projects would be reviewed by SoCalGas to identify necessary natural gas service connections to meet the needs of their respective projects. In addition, SoCalGas would provide service letters for each related project confirming availab ility of adequate natural gas supplies as part of the total load growth of the regional natural gas system. Project applicants would be required to provide for the needs of their individual projects, thereby contributing to the natural gas infrastructure in the Project area. Related projects would also be required to evaluate natural gas demands and coordinate with the local utility provider for providing adequate service, in accordance with future projected supplies, to each of the related project sites. Related projects
4. Environmental Impacts Analysis
4.13.2. Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities City of Culver City 4.13.2-12 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
would also be required to obtain evidence of service from SoCalGas, or the appropriate utility provider, to ensure that natural gas service would be available and provided to meet related project demands. Furthermore, the related projects are generally inf ill 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 the relocation or construction of new or expanded natural gas facilities, the construction or relocation of which could cause significant environmental effects, would not be cumulatively cons iderable. Therefore, cumulative 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 electric power or natural gas facilities were determined to be less than significant.
City of Culver City 5-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 5
Alternatives
5.1 Introduction
Under the California Environmental Quality Act ( CEQA), and as indicated in California Public Resources Code (PRC) Section 21002.1(a), the identification and analysis of alternatives to a project is a fundamental aspect of the environmental review process intended to consider ways to mitigate or avoid the significant environmental effects of a project.
Guidance regarding the definition of Project alternatives is provided in CEQA Guidelines Section 15126.6(a) as follows:
[a]n EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.
The CEQA Guidelines indicate that the selection of project alternatives should be based primarily on the ability of the alternative to avoid or substantially lessen significant impacts relative to the proposed project, “even if these alternatives would impede to some degree the attain ment of the project objectives, or would be more costly.”
1 The CEQA Guidelines further direct that the range
of alternatives be guided by a “rule of reason,” such that only those alternatives necessary to permit a reasoned choice are analyzed.
2 The project alternatives selected for analysis in an EIR, must be feasible. CEQA Guidelines Section 15126.6(f)(1) states that:
Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent).
CEQA Guidelines Section 15626.6(e) requires the analysis of a “no project” alternative and, depending on the circumstances, evaluation of alternative location(s) for the project, if feasible. 3 Based on the alternatives analysis, an environmentally superior alternative is to be designated. In
1 CEQA Guidelines Section 15126.6(b).
2 CEQA Guidelines Section 15126.6(f).
3 CEQA Guidelines Sections 15126.6(e), 15126.6(f)(1).
5. Alternatives
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general, the environmentally superior alternative is the alternative with the least adverse impacts on the environment. If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify another environmentally superior alternative among the other alternatives. 4 CEQA Guidelines Section 15126.6(d) states that the EIR is required to provide sufficient information about each alternative to allow meaningful evaluation, analysis and comparison with the proposed project. It further states that, if an alternative would cause one or more significant effects in addition to those that would be caused by the proposed project, the alternatives analysis need not discuss those effects in the same level of detail as the significant effects of the project are discussed.
5.2 Objectives of the Project
Chapter 2, Project Description, of this Draft EIR, sets forth the Project Objectives defined by the Applicant and the Lead Agency. The underlying purpose of the Project is to redevelop the underutilized Project Site with a high -quality mixed-use development that includes new multi - family housing at varying income levels, and retail uses, as well as publicly accessible open spaces, to revitalize the Project Site, promote walkability, and enhance the City’s economic base. The Project’s specific objectives are as follows:
1. Develop new, high -quality infill housing with a diverse mix of residential dwelling types, containing both market-rate and affordable units.
2. Fulfill the City’s housing goals by improving access to quality housing for all members of the community through the provision of affordable housing in proximity to open space and public transportation, while maintaining access to a wide range of services and goods.
3. Provide open space amenities that will enhance existing site conditions through publicly accessible open space (Hannum Plaza), as well as a unified landscape design with common open space areas for Project residents.
4. Provide for a mix of commercial and residential uses to promote pedestrian activity, reduce vehicle trips and vehicle miles traveled, and encourage active transportation while maintaining appropriate levels of vehicle parking.
5. Activate the Hannum Avenue and Buckingham Parkway frontages by providing street-oriented retail and residential uses, and a landscaping program that further enhances the pedestrian experience.
6. Utilize the state’s Density Bonus laws to increase the permitted density at the Project Site in order to provide housing at a variety of income levels that will assist the City in meeting its Regional Housing Needs goals.
7. Provide a development that complements and improves the visual character of the area by connecting with the surrounding urban environment through a high level of architectural design, including a building form with vertical and horizontal breaks, generous setbacks, light materiality, landscape features, and active ground floor uses with open space amenities.
8. Create a development with high quality design that supports environmental sustainability through energy efficiency, water conservation, and the reduction of greenhouse gas emissions through such features as electric vehicle charging stations, energy -efficient appliances, water efficient plumbing fixtures and fittings, and water-efficient landscaping.
4 CEQA Guidelines Section 15126.6(e)(2).
5. Alternatives
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5.3 Overview of Alternatives Selected for Analysis
As stated above, the intent of the alternatives analysis is to determine if there are feasible alternatives that would avoid or substantially reduce the significant impacts of a proposed project. Based on the analysis in Chapter 4, Environmental Impacts Analysis, of this Draft EIR, implementation of the Project would result in significant construction impacts that cannot be feasibly mitigated to a less- than-significant level with regard to Project-level on-site construction noise if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours . The Project would not result in any significant operational impacts. The following alternatives to the Project have been selected to inform evaluation of the Project in light of the significant environmental impacts of the Project, the objectives establish ed for the Project (listed above), the feasibility of the alternatives considered, public input received during the scoping period, and the existing zoning designation on the Project Site:
• Alternative 1: No Project/No Build Alternative
• Alternative 2: Existing Zoning/Office Alternative
• Alternative 3: Reduced Project Alternative
Alternative 1 is a No Project/No Build Alternative pursuant to CEQA Guidelines Section 15126.6(e). Under the No Project/No Build Alternative, the Project would not be developed and existing on-site uses would remain as under the existing conditions.
In addition to the No Project/No Build Alternative, t wo development alternatives are included for analysis in this Draft EIR. Two alternatives (Alternatives 2 and 3) would reduce the amount of development and density that would reduce the total square footage (sf) of the proposed new uses as compared to the Project. The three alternatives, including the No Project/No Build Alternative, are listed below and described in more detail in this chapter. The alternatives considered for evaluation are compared to t he Project, as summarized in Table 5-1, Overview of the Project Alternatives.
5.4 Alternatives Considered and Rejected
CEQA Guidelines Section 15126.6(c) describes that an EIR should identify alternatives that were considered for analysis but rejected as infeasible and briefly explain the reasons for their rejection.
According to the CEQA Guidelines, the following factors may be used to eliminate alternatives from detailed consideration: the alternative’s failure to meet most of the basic project objectives, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts. Alternatives that have been considered and rejected from detailed consideration are discussed below.
5. Alternatives
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TABLE 5-1
OVERVIEW OF THE PROJECT ALTERNATIVES
Use or Feature Project
Alternative 1:
No Project/
No Build
Alternative 2:
Existing Zoning/
Office Alternative
Alternative 3:
Reduced Density
Alternative
Retail Use 5,600 sf — — 5,600 sf
Affordable Units 27 Units — — —
Total Residential Units 309 Units — — 223
Residential Square
Footage
356,996 sf — — 222,000
Office Use — 30,672 sf (existing) 190,000 sf —
Total Square Footage 362,593 sf 30,672 sf (existing) 190,000 sf 227,600 sf Maximum
Building Height
78 feet (6-stories) Same as existing
(~20 ft, 2-stories)
56 feet (4-stories) 56 feet (5-stories)
Publicly Accessible
Amenity Area
7,507 sf — — 2,500 sf
Excavation Depth 27 feet bgs (2 levels of
subterranean parking)
N/A 27 feet bgs (2 levels of
subterranean parking)
15 feet bgs (1 level of
subterranean parking)
Parking Spaces 428 spaces Same as existing 380 spaces 212 spaces NOTE: bgs = below ground surface
SOURCE: ESA, 2024.
5.4.1 Alternative Off-Site Location
CEQA does not require that analysis of alternative sites always be included in an EIR. However, if all the surrounding circumstances make it reasonable to consider an alternative site, then an alternative location should be considered and analyzed in the EIR. Per CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternative site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.” If no feasible alternative locations exist, the EIR must disclose the reasons for this conclusion. According to CEQA Guidelines Sections 15126.6(f)(1) and (f)(2), among the factors that may be considered when addressing the feasibility of an alternative site are general suitability, economic viability, availability of infrastructure, general plan consistency, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site. The above is in light of the fact that, per CEQA Section 15126.6(a), “An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.”
The Project’s significant and unavoidable impacts, including Project-level on-site construction noise if an extended hours permit was not obtained by the Project, would be expected to occur if the Project were developed at other available locations in the area as the noise generation would be similar to the Project and would impact potential nearby sensitive receptors similarly. Therefore, moving the
5. Alternatives
City of Culver City 5-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
location of the Project to another site would not necessarily reduce the nature and extent of such impacts. Accordingly, given the nature of the Project’s significant unavoidable impacts, evaluation of an alternate location was not pursued as it would be likely to shift these impacts to another location rather than helping to avoid or substantially lessen the significant effects of the Project.
In addition, the Applicant does not have ownership or control of any other suitable site within Culver City designated for mixed-use development by the City’s adopted 2021-2029 Housing Element and draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update, which would permit and support the Project’s proposed mix of uses . Therefore, the flexibility to develop a similar project on the same or similar scale at another location is not feasible.
For the reasons stated above, an off-site location alternative is not expected to meaningfully reduce the significant and unavoidable impacts of the Project, would likely not meet key Project objectives related providing housing at a variety of income levels that will assist the City in meeting its Regional Housing Needs goals , and a feasible alternate location for the Project has not been identified. Accordingly, an off-site alternative has not been carried forward for further analysis.
5.4.2 Alternative s to Further Reduce or Avoid Significant Noise Impacts during Construction
As discussed in Section 4.8, Noise, of this Draft EIR, the Project would result in significant and unavoidable impacts related to Project -level on -site construction noise impacts. No additional mitigation measures are available to reduce these impacts to a less-than-significant level.
Alternatives, including those that would reduce construction duration or Project scale/intensity, were considered to further reduce or avoid these significant and unavoidable impacts. Based on the thresholds upon which the construction noise analysis is based, a substantial reduction in the intensity and duration of the peak daily construction activities would be necessary to further reduce construction-related impacts. It is noted that the Project’s significant and unavoidable impacts would only occur during construction activities between 7:00 a.m. and 8:00 a.m. Monday to Friday and 7:00 a.m. to 9:00 a.m. on Saturdays if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours. Thus, significant construction noise impacts within the Project Site would be expected to occur with most reduced development scenarios because construction activities are inherently disturbing , and the peak construction activity would be similar as the Project during the requested extended construction working hours, assuming similar extended construction hours would occur. The Project’s proposed extended hours would allow for a 7:00 a.m. 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 during construction. The other construction phases would occur per the allowable standard Culver Cit y Municipal Code ( CCMC) permitted construction hours. Should the extended hours not be granted, any reduction in the intensity and duration of daily construction activities would increase the overall duration of the construction period. Also, the early start time for the listed construction activities will reduce the impacts of traffic during peak hours from heavy trucking.
5. Alternatives
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Furthermore, a large contributor to the need for extended construction hours is related to the concrete trucks needed for building foundations. To construct portions of a building foundation, concrete must be continuously poured in a strategic manner over a short period of time considering its drying time and need to properly cure without cracking and provide proper building support.
Breaking up the concrete pours for specific sections over multiple days in a given area is not a feasible option to properly construct a building foundation, as such breaks in the concrete pours would not provide a stable foundation built to applicable building code and regulatory requirements. Thus, reducing or eliminating the number of concrete trucks in a given construction phase is not a feasible alternative to avoid the need for extended construction hours.
Therefore, additional alternatives to further reduce or avoid the Project’s short-term noise impacts during construction were rejected as infeasible based on the inability to avoid significant environmental impacts under a reasonable construction schedule.
5.5 Analysis Format
In accordance with CEQA Guidelines Section 15126.6(d), three feasible alternatives to the Project are evaluated in sufficient detail to determine whether the overall environmental impacts would be less than, similar to, or greater than the corresponding impacts of the Project. Furthermore, each alternative is evaluated to determine whether the Project objectives, identified in Chapter 2, Project Description, of this Draft EIR would be substantially attained by the alternative. The evaluation of each of the alternatives follows the format described below:
• A description of the alternative.
• The environmental impacts of the alternative before and after implementation of reasonable mitigation measures for each environmental issue area analyzed in the EIR are described. Where applicable, the evaluation is divided between temporary impacts that would occur during the Project’s construction phase and impacts that would occur during the Project’s operational phase. • Environmental impacts of the alternative and the Project are compared for each environmental issue area evaluated in Chapter 4, Environmental Impacts Analysis, the Draft EIR. Where the impact of the alternative would be less adverse than the impact of the Project, the comparative impact is said to be “less.” Where the alternative’s net impact would be more adverse than the Project, the comparative impact is said to be “greater.” Where the impacts of the alternative and Project would be roughly equivalent, t he comparative impact is said to be “similar.” The evaluation also documents whether compared to the Project, an impact would be entirely avoided, whether a significant impact under the Project could be reduced to a less-than- significant level in the alternative, or whether a significant unavoidable impact under the alternative would be feasible to be mitigated to a less-than-significant level. • The comparative analysis of the impacts is followed by a general discussion of the extent to which the underlying purpose and Project Objectives would be attained by the alternative.
At the end of the section, a comparison of the alternative’s impacts and consistency with Project Objectives is provided. Pursuant to CEQA Guidelines Section 15126.6(e)(2) an Environmentally Superior Alternative is identified. The comparative impacts of the Project and the alternatives are summarized in Table 5-5 below.
5. Alternatives
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5.5.1 Alternative 1 : No Project/No Build Alternative
Description of the Alternative
In accordance with the CEQA Guidelines, the No Project/No Build Alternative (Alternative 1) for a development project on an identifiable property consists of the circumstance under which the project does not proceed. CEQA Guidelines Section 15126.6(e)(3)(B) states that, “in certain instances, Alternative 1 means ‘no build’ wherein the existing environmental setting is maintained.” Accordingly, for purposes of this analysis, Alternative 1 assumes that no new development would occur within the Project Site. As mentioned in Chapter 2, Project Description, of this Draft EIR, the Project Site is currently improved with an approximately 30,672 square foot, two-story office building built in the late 1970s. Under this alternative, the Project Site would continue to operate as an office building under existing conditions.
Environmental Impacts
Aesthetics
Applicable Zoning and Other Regulations Governing Scenic Quality No new development would occur under Alternative 1 and, as such, no conflict with regulations that govern scenic quality would occur. Accordingly, because Alternative 1 would not change any conditions at the Project Site, no impacts would occur. As such, impacts under Alternative 1 would be less than the Project.
Supplemental Shading Analysis
Under Alternative 1, no new development would occur and, as such, no new shading would occur beyond existing conditions. No shading currently occurs on any adjacent shade sensitive uses, such as the Fox Hills Parkette. Accordingly, because Alternative 1 would not change any shading conditions at the Project Site, no impacts would occur. As such, impacts under Alternative 1 would be less than the Project.
Air Quality
Conflict with Air Quality Management Plan
While Alternative 1 would not involve any new construction, under this alternative, the existing office building is assumed to be fully occupied with office uses as it is currently fully leased. Since new development would not occur, Alternative 1 would not generate new construction emissions, and operational emissions from the existing office uses would continue to be nominal. As such, Alternative 1 would not cause the Air Basin’s criteria pollutant emissions to worsen so as to impede the objectives of the Air Quality Management Plan (AQMP ). As such, Alternative 1 would avoid the Project’s less-than-significant impacts. Thus, impacts with regard to conflict with an Air Quality Management Plan would be less under Alternative 1 than the Project.
Cumulative Considerable Increase in Criteria Pollutants/Violation of Air Quality Standards
Construction
Alternative 1 would not involve construction or generate any new criteria pollutants related to construction. Accordingly, because Alternative 1 would not result in any new emissions generation,
5. Alternatives
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no construction-related air quality impacts would occur. As such, Alternative 1 would avoid the Project’s less-than-significant impacts. Thus, impacts with regard to air quality thresholds during construction would be less under Alternative 1 than the Project.
Operation
As Alternative 1 would include the continued operation of the existing office building, no increased emissions could occur over existing conditions. As such, Alternative 1 would avoid the Project’s less-than-significant impacts. Thus, impacts with regard to a cumulatively considerable increase in criteria pollutants and violations of air quality standards would be less under Alternative 1 than the Project.
Sensitive Receptor Exposure to Pollutant Concentrations Localized Emissions
Construction
Alternative 1 would not involve any construction at the Project Site. Accordingly, Alternative 1 would not generate any localized emissions and is considered to have no impact related to localized emissions during construction. As such, Alternative 1 would avoid the Project’s less-than - significant i mpacts. Thus, impacts with regard to s ensitive receptor exposure to p ollutant concentrations during construction would be less under Alternative 1 than the Project.
Operation
As Alternative 1 would include the continued operation of the existing office building, no increased emissions could occur over existing conditions . As such, Alternative 1 would avoid the Project’s less-than-significant impacts. Thus, impacts with regard to sensitive receptor exposure to pollutant concentrations during operation would be less under Alternative 1 than the Project.
Carbon Monoxide Hotspots
As Alternative 1 would include the continued operation of the existing office building, traffic would be similar to existing conditions. Alternative 1 would not generate new emissions that would contribute to carbon monoxide ( CO) hotspots and is considered to have no impact related to CO hotspots. As such, Alternative 1 would avoid the Project’s less-than -significant impacts. Thus, impacts with regard to CO hotspots would be less under Alternative 1 than the Project.
Toxic Air Contaminants
Construction
Alternative 1 would not involve any construction or new development at the Project Site compared to existing conditions. Accordingly, Alternative 1 would not generate any toxic air contaminant (TAC) emissions during construction and is considered to have no impact related to TAC emissions.
The Project would result in potentially significant impacts related to TAC during construction activities. That is, maximum unmitigated health risk impacts to sensitive residential receptors would exceed the applicable South Coast Air Quality Management District ( SCAQMD) cancer risk significance threshold of 10 per million. However, with implementation of Mitigation Measure AQ- 1 (Tier 4 Construction Equipment), the maximum cancer risk and hazard index for sensitive receptors would be below the SCAQMD significance thresholds. As such Project impacts would be less than significant with mitigation. Because Alternative 1 would involve no construction activities,
5. Alternatives
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Alternative 1 would avoid the Project’s less-than-significant impacts with mitigation. Thus, impacts with regard to TACs during construction would be less under Alternative 1 than the Project.
Operation
As Alternative 1 would include the continued operation of the existing office building, no increased TAC emissions could occur over existing conditions . As such, Alternative 1 would avoid the Project’s less-than-significant impacts. Thus, impacts with regard to TACs during operation would be less under Alternative 1 than the Project.
Cultural Resources
Archaeological Resources
Alternative 1 would not require any excavation activities that would potentially encounter previously undiscovered archaeological resources. Accordingly, because Alternative 1 would involve no excavation or ground disturbance, it would have no impact on archaeological resources.