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

As such, Alternative 1 would avoid the Project’s less -than-significant impacts (after M itigation Measures ARC-1 to ARCH-3) related to an adverse change in the significance of an archaeological resource. Thus, impacts related to archaeological resources would be less under Alternative 1 than the Project.

Energy
Efficient Energy Consumption
Alternative 1 would not involve any construction at the Project Site and, as such, would have no impact relative to construction -related energy resources such as diesel, gasoline, and electricity.

Construction of the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy, and, as such, energy impacts would be less than significant. Because Alternative 1 would have no impact related to construction-related energy demand, construction- related impacts would be less under Alternative 1 as compared to the Project’s less-than-significant impact.

Alternative 1 would not involve any new or additional use of the Project Site compared to existing conditions and, as such, would have no impact relative to energy resources. Operation of the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy, and, as such, energy impacts would be less than significant. Operational impacts would be less under Alternative 1 as compared to the Project’s less-than-significant impact. However, it is noted that the existing office building on the Project Site would not be as energy efficient as the proposed building under the Project.

Conflict with Plans for Renewable Energy or Energy Efficiency As no new construction is proposed under Alternative 1 and given the similar operational energy use under this a lternative, Alternative 1 would have no impact related to conflict s with plans for renewable energy and energy efficiency. The Project’s design would comply with existing energy standards and incorporate project design features to reduce energy consumption. Therefore, the Project would not conflict with energy conservation plans and impacts would be less than significant. Because Alternative 1 would have no impact related to conflict s with plans for renewable energy and energy efficiency, impacts would be less under Alternative 1 as compared to

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the Project’s less-than-significant impact. However, it is noted that the existing office building on the Project Site would not be as energy efficient as the proposed building under the Project.

Geology and Soils
Paleontological Resources
Alternative 1 would not require any construction activities; therefore, it would have no potential to encounter previously undiscovered paleontological resources. Accordingly, because Alternative 1 would involve no excavation or ground disturbance, it would have no impact on paleontological resources. As such, Alternative 1 would avoid the Project’s less -than-significant impacts (after Mitigation Measures GEO-1 to GEO-4) related to potentially destroying paleontological resources.

Thus, impacts related to paleontological resources would be less under Alternative 1 than the Project.

Greenhouse Gas Emissions
Alternative 1 would not include the construction of any new buildings or provide for any changes in on-site occupancy of office building on the Project Site. Alternative 1 represents an absence of new development and would neither generate new GHG emissions nor conflict with applicable GHG reduction plans and policies. Since Alternative 1 would not provide for any increase or new use that would generate additional GHG emissions, Alternative 1 would have no GHG emissions impact. As such, Alternative 1 would avoid the Project’s less than significant GHG impacts. Thus, impacts with regard to GHG emissions and conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs would be less under Alternative 1 than the Project.

Land Use and Planning
Alternative 1 would not change the existing land use. The existing parking lot, office use, and zoning/land use designations would remain. As no physical changes would occur on the Project Site, Alternative 1 would not conflict with any adopted plans, policies or regulations related to avoiding or reducing environmental impacts. Although Alternative 1 would not further regional and local policies applicable to the Project Site with the City of Culver City, such as providing new housing, enhancing pedestrian activity, and increasing transit use, this alternative would have no impacts with respect to conflicts with plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. As such, Alternative 1 would avoid the Project’s less-than-significant land use and planning impacts. Thus, impacts with regard to land use and planning would be less under Alternative 1 than the Project.

Noise
Substantial Temporary or Permanent Increase in Ambient Noise Levels Construction – On-Site
Alternative 1 would not involve any construction activities, and, therefore, no on-site construction noise impacts would occur. As such, Alternative 1 would avoid the Project’s potential Project-level significant and unavoidable on-site construction noise impacts at nearby noise-sensitive receptor locations should construction activities occur outside the City’s permitted hours without an Approval for Extended Hours of Construction. Thus, impacts related to construction noise would be less under Alternative 1 than the Project.

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Construction – Off-Site
Alternative 1 would not involve any construction activities, and, therefore, no off-site construction noise (via mobile sources) impacts would occur. As such, Alternative 1 would avoid the Project’s construction off -site noise less-than -significant i mpacts. Thus, impacts related to off -site construction noise would be less under Alternative 1 than the Project.

Operation – On-Site
Occupancy and activity at the Project Site would remain as under conditions with Alternative 1.

Thus, no new on-site noise impacts would occur under Alternative 1. As such, Alternative 1 would avoid the Project’s less than significant operational on-site noise impacts. Thus, impacts related to on-site operational noise would be less under Alternative 1 than the Project.

Operation – Off-Site
Occupancy at the Project Site would remain as under conditions with Alternative 1. Accordingly, off-site noise from mobile sources would remain similar to existing conditions. Thus, no new off- site noise impacts would occur under Alternative 1. As such, Alternative 1 would avoid the Project’s less than significant operational off-site noise impacts. Thus, impacts related to on-site operational noise would be less under Alternative 1 than the Project.

Vibration
Construction
Alternative 1 would not involve any new development or construction, and, therefore, no construction vibration impacts would occur. As such, Alternative 1 would avoid the Project’s less- than-significant c onstruction vibration impacts to nearby vibration sensitive receptor locations.

Thus, impacts related to construction vibration would be less under Alternative 1 than the Project.

Operation
Occupancy and activity at the Project Site would remain as under conditions with Alternative 1.

Thus, no new operational vibration impacts would occur under Alternative 1. As such, Alternative 1 would avoid the Project’s less than significant operational vibration impacts. Thus, impacts related to operational vibration would be less under Alternative 1 than the Project.

Population and Housing
Induce Substantial Unplanned Population Growth
Alternative 1 would not involve any new construction or additional occupancy or employment opportunities compared to existing conditions, would have no impact related to population and housing, and would not contribute to SCAG or City housing growth objectives. Project impacts related to unplanned population growth under the Project during long-term operation would be less than significant. However, because Alternative 1 would result in no direct or indirect population growth, impacts would be less than the Project’s less-than-significant impacts.

Public Services
Fire Protection
Under Alternative 1, no increased demand for fire protection and emergency medical services would occur compared to existing conditions and there would be no effect on emergency response

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times or emergency access, as would occur under the P roject from construction activities and project operations. While the Project would involve construction activities and intensify the use of the Project Site, impacts on fire protection and emergency access would be less than significant with incorporation of Project Design Features and compliance with applicable regulatory requirements. Further, under the Project, the addition of a new fire facility, or the expansion, consolidation, or relocation of an e xisting facility, is not foreseeably needed to maintain service and the potential for physical impacts associated with construction of fire facilities are considered less than significant. Alternative 1 would result in no impacts to fire protection and emergency access. Therefore, the impact of Alternative 1 on fire protection and emergency access would be less as compared to the Project’s less-than-significant impact.

Police Protection
Alternative 1 would not change existing conditions or increase the level of activity at the Project Site and therefore would not alter demand for police protection services or affect emergency response times. In contrast, the Project would result in construction and ope rational activities that could increase demand for police protection services. These impacts associated with the Project would be less than significant as the Project would incorporate Project Design Features POL-PDF- 1 and POL-PDF-2, which provide on-site security features for construction and operation. Further, under the Project, the addition of a new police facility, or the expansion, consolidation, or relocation of an existing facility, is not foreseeably needed to maintain service and the potential for physical impacts associated with construction of fire facilities are considered less than significant.

Alternative 1 would result in no impacts to police protection services. Therefore, the impact of Alternative 1 on police protection services would be le ss as compared to the Project’s less-than- significant impact.

Schools
Alternative 1 would not involve any new or additional occupancy or use of the Project Site compared to existing conditions and would not increase student enrollments in the area. The Project, which would increase enrollments at the serving schools, would be required to pay development fees for schools to the Culver City Unified School District (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 impa cts. Therefore, the Project’s impact on schools would be less than significant. However, because Alternative 1 would not result in any new student enrollment, impacts associated with schools would be less than the Project’s less-than-significant impact.

Parks and Recreation
Alternative 1 would not involve any new construction or additional occupancy or use of the Project Site compared to existing conditions and would not increase residential population or increase use of parks and recreational facilities. Alterative 1 would have no impact on parks and recreation facilities. Under the Project, with the provision of on-site open space and recreational facilities, in addition to the required payment of applicable fees to the City, the Project would meet CCMC open space and parkland requirements and would result in less-than -significant impacts on parks and recreational facilities. However, because Alternative 1 would not result in any changes to current parks usage, impacts would be less than the Project’s less-than-significant impact.

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Transportation
Conflict with Programs, Plans, Ordinances, or Policies Addressing the Circulation System, Transit, Roadways, Bicycle, and Pedestrian Facilities Alternative 1 would not involve any new or additional occupancy or use of the Project Site compared to existing conditions and, as such, would have no impact regarding conflicts with programs, plans, ordinances or policies addressing the circulation system, transit, roadways, bicycle and pedestrian facilities. While the Project would introduce new uses that would generate new sources of traffic and provide new transportation features within the Project Site, the Project would not result in any substantial conflicts with programs, plans, ordinances or policies addressing transportation issues and, therefore, impacts would be less than significant. However, because Alternative 1 would have no impact in this regard as it neither implements nor conflicts with any transportation plan objectives, impacts would be less than the Project’s less-than-significant impact Consistency with CEQA Guidelines Section 15064.3, Subdivision (b) Alternative 1 would not involve any new or additional occupancy or use of the Project Site compared to existing conditions. Thus, no impacts regarding vehicle miles traveled (VMT) would occur under Alternative 1. The Project’s daily per capita resident and employee VMT would be below the City’s thresholds and, therefore, impacts would be less than significant. However, because Alternative 1 would not generate any new vehicle trips or VMT, impacts would be less than the Project’s less-than-significant impact.

Design Hazards
Alternative 1 would not generate any new vehicle trips or change the transportation design features in and around the Project Site. Alternative 1 would result no impacts regarding geometric hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses . The Project would reconfigure the driveways accessing the Project Site. However, no unusual or new obstacles or features are included in the Project design that would be considered hazardous to motorized vehicles, non-mo torized vehicles, or pedestrians. The Project would have a less-than - significant i mpact regarding hazards due to geometric design features or incompatible uses.

However, because Alternative 1 would have no impact with respect to geometric design hazards, impacts would be less than the Project’s less-than-significant impact.

Emergency Access
Alternative 1 would not generate any new vehicle trips or change the transportation design features in and around the Project Site. Alternative 1 would result no impact regarding emergency access.

The Project would reconfigure the driveways accessing the Project Site. However, all driveways would be reviewed by the Culver City Fire Department to confirm adequate emergency vehicle access is provided per applicable CCMC requirements. The Project would have a less-than - significant impact regarding emergency access. However, because Alternative 1 would have no impact with respect to emergency access, impacts would be less than the Project’s less-than- significant impact.

Tribal Cultural Resources
Alternative 1 would not involve any ground disturbance or excavation activities that would potentially encounter previously undiscovered tribal cultural resources and, as such, would have no

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impact related to such resources. Excavation for the Project would be required for subterranean parking and building foundations. Potentially significant impacts related to tribal cultural resources during Project construction would be reduced to less than significant with Mitigation Measures TCR-MM-1 (Native American Monitor), TCR-MM-2 (monitoring logs), and TCR-MM-3 (halting of construction activity In the event that a prehistoric/Native American resource is unearthed). However, because Alternative 1 would have no impact related to tribal cultural resources, impacts would be less than the Project’s less-than-significant impact (with mitigation).

Utilities and Service Systems
Water Supply
Water Infrastructure
Alternative 1 would not involve any new or additional occupancy or use of the Project Site compared to existing conditions. No new impacts to water infrastructure would occur under Alternative 1. Under the Project, the existing Golde n State Water Company ( GSWC) water infrastructure has adequate capacity and pressure to meet the Project’s domestic and fire flow requirements. Only minor connections to existing water supply lines would be necessary to support the Project. 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. However, because Alternative 1 would not generate any new water demand, impacts would be less than the Project’s less-than-significant impact.

Water Supply
Alternative 1 would not involve any new or additional occupancy or use of the Project Site compared to existing conditions. No impacts to water supply would occur under Alternative 1.

Under the Project, GSWC has sufficient water supplies to serve the Project and, therefore, Project water supply impacts would be less than significant. However, because no change or increase in water demand over existing conditions would occur under Alternative 1, water supply impacts would be less than the Project’s less-than-significant impact.

Electric Power, Natural Gas, Telecommunications Facilities While Alternative 1 would not construct new buildings , under this alternative the existing office uses would continue to be fully occupied and operational . T he electric power and natural gas infrastructure needs required under this alternative would be the same as under existing conditions.

Accordingly, impacts relative to electric power and natural gas infrastructure would be less than significant. Thus, impacts with regard to electric power and natural gas infrastructure would be less under Alternative 1 than the Project.

Alternative 1 would not involve any new development that would increase existing electricity and natural gas demand or require additional energy infrastructure. Thus, no new impacts to electricity and natural gas infrastructure would occur under Alternative 1. The Project would result in an increase in operational electricity demand, but a decrease in natural gas demand. The Project’s electrical demand would be within Southern California Edison’s (SCE) projected electricity supplies. Also, the Project’s natural gas demand would be within SoCal Gas’s projected natural gas supplies. With the exception to connections to existing utility lines, the Project would not require

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the construction of new energy facilities or the expansion of existing facilities. Under Alternative 1, the Project Site’s existing on -site electrical and natural gas demands would continue. However, because Alternative 1 would not change existing conditions and would not result in any new electrical power or natural gas demand, impacts related to utility supply and infrastructur e would be less than the Project ’s less-than-significant impact with respect to the wasteful, inefficient, and unnecessary consumption of energy.

Relationship of the Alternative to Project Objectives
As described above, under Alternative 1 the Project Site would continue to operate as an office building as under existing conditions . Thus, Alternative 1 does not propose redevelopment of the Project Site and would not meet any of the eight Project objectives, which are listed below:

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

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

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

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

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

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

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

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

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

It is acknowledged that the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update includes a draft Land Use Map and Land Use designations with

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appropriate draft densities. The Project Site’s draft land use designation and density is Mixed-Use High and 100 dwelling units per acre, consistent with the City’s adopted 2021-2029 Housing Element preferred designation and density.

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

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

Environmental Impacts
Aesthetics
Applicable Zoning and Other Regulations Governing Scenic Quality CEQA Appendix G addresses whether a project in an urban area would conflict with regulations that govern scenic quality, such as those applicable to street trees, exterior lighting, signage, and compliance with applicable policies of the General Plan. Alternative 2 would be developed in accordance with all applicable regulations as part of the existing zoning designation of Commercial Regional Business Park (CRB) for the Project Site. Similar to the Project, Alternative 2 redevelop the site with a high-quality new building subject to design review by the City. Alternative 2 would implement project design features that would require mechanical, electrical, and roof top equipment (including heating, ventilation, and air conditioning (HVAC) systems ), as well as building appurtenances, to be integrated into the architectural design (e.g., placed behind parapet walls) and be screened from view from public rights-of -way. Compared to the Project, the overall massing and height of the building would be smaller and shorter, respectively. As with the Project, Alternative 2 would include a landscape and street tree program that meets City requirements along Hannum Avenue and Buckingham Parkway. However, this Alternative would not include a public plaza along Hannum Avenue, thus, the extent of streetscape, landscaping and heightened pedestrian activity would be less than the Project. Despite the aesthetic variations between the Project and Alternative 2, both would comply with applicable CCMC regulations that govern scenic character, such as building heights, setbacks, and screening. As such, neither the Project nor Alternative 2 would conflict with the policies of the CCMC that regulate scenic quality and impacts would be less than significant. When compared to the Project, impacts related to conflicting with regulations that govern scenic quality under Alternative 2 would be similar to the Project.

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Supplemental Shading Analysis
Under Alternative 2, the proposed office building would be 4-stories (56 feet) over two levels of subterranean parking as compared to the Project’s 6-story (up to a height of 78-feet) over two levels of subterranean parking mixed-use building. Under the Project, redevelopment of the Project Site would add limited incremental shadows to the Fox Hills Parkette during the winter season in the afternoon hours, and not shade any portion of the residential uses across Buckingham Parkway year around. Given the Project’s limited shading of off -site routinely usable outdoor spaces, shading would not be an adverse effect of the Project's implementation. Under Alternative 2 with a reduced building height, there would be no shading of the Fox Hills Parkette or any portion of the residential uses across Buckingham Parkway year around. The extent of shadows cast by Alternative 2 would be less than the Project , with neither the Project nor Alternative 2 substantially affecting any off- site shade sensitive uses.

Air Quality
Conflict with Air Quality Management Plan
Similar to the Project, Alternative 2 would include new development on the Project Site that would generate new criteria pollutant emissions. Similar to the Project, Alternative 2 would be consistent with the goals of SCAG’s 2016- 2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also referred to Connect SoCal, and growth projections in the 2016 AQMP, since the growth would occur in consistent with the existing zoning designation. As with the Project, Alternative 2 would be consistent with the AQMP in its incorporation of appropriate control strategies for emissions reduction during construction and operation. In addition, Alternative 2 would also be consistent with applicable goals, objectives, and policies of the City of Culver City General Plan and Mandatory Green Building Program that support and encourage reducing single occupancy vehicle trips and VMT. As with the Project, Alternative 2 would develop a TDM program to reduce the amount single-occupancy vehicle trips and encourage use of alternative transportation. For all of these reasons, impacts under Alternative 2 with respect to conflicting or obstructing with AQMPs would be less than significant. When compared to the Project, impacts related to conflicting with the AQMP under Alternative 2 would be similar to the Project.

Cumulative Increase in Criteria Pollutants/Violation of Air Quality Standards Construction
As with the Project, Alternative 2’s construction phases have the potential to generate daily emissions that would exceed the SCAQMD air quality standards through the use of heavy -duty construction equipment, such as excavators and forklifts, through vehicle trips generated by workers and haul trucks traveling to and from the Project Site, and through building activities, such as the application of paint and other surface coatings. The maximum daily regional emissions under Alternative 2 would be similar to the Project because emission levels are based on a single day in which maximum construction activity would occur. Similar to the Project, regional construction emissions under Alternative 2 would not exceed SCAQMD numerical regional construction emissions significance thresholds and impacts would be less than significant . However, Alternative 2 would reduce the scale of development (or building square footage by approximately 47 percent compared to the Project and, thus, would reduce the overall building construction phase duration by approximately 8 months. As Alternative 2 would reduce construction duration, impacts

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with respect to cumulative increases in criteria pollutants and violations of air quality standards would be less than the Project.

Operation
During operation, Alternative 2 would generate emissions associated with vehicle trips, heating, lighting, other electric requirements, and architectural coatings. Similar to the Project, Alternative 2 would incorporate Project Design Feature GHG-PDF-1 (Green Building Features) and would comply with SCAQMD Rule 1113 regarding architectural coatings. While there would be a reduction in the size of the building scale compared to the Projec t, Alternative 2 would generate more daily VMT than the Project resulting in higher mobile source emissions which is a primary factor in assessing regional emissions. W hile Alternative 2 would generate fewer daily trips compared to the Project (1,197 vs. 1,462 trips), Alternative 2’s daily VMT would be approximately 13% higher than the Project (11,874 vs. 10,504 VMT).
5 As such, mobile source regional emissions
would be greater under this Alternative. Both the Project and Alternative 2’s regional emissions would be well below the applicable SCAQMD daily impact for VOC, NO X, CO, SOX, PM10, and PM2.5, and emissions related to air quality standards would be less than significant. Overall, despite Alternative 2 being developed at a lower intensity than the Project, since its mobile source regional emissions would be higher with a higher VMT than the Project, impacts with respect to cumulative increases in criteria pollutants and violations of air quality standards would be greater under Alternative 2 than the Project.

Sensitive Receptor Exposure to Pollutant Concentrations Localized Emissions
Construction
As with the Project, Alternative 2’s construction phases have the potential to generate daily emissions that would exceed the SCAQMD air quality standards through the use of heavy-duty construction equipment, such as excavators and forklifts, through vehicle trips generated by workers and haul trucks traveling to and from the Project Site, and through building activities, such as the application of paint and other surface coatings. The maximum daily localized emissions under Alternative 2 would be similar to the Project because emission levels are based on a single day in which maximum construction activity would occur. Similar to the Project, localized construction emissions under Alternative 2 would not exceed SCAQMD numerical localized construction emissions significance thresholds and impacts would be less than significant.

However, Alternative 2 would reduce the scale of development (or building square footage by approximately 47 percent compared to the Project and, thus, would reduce the overall building construction phase duration by approximately 8 months. As Alternative 2 would reduce construction duration, impacts with respect to construction-related localized emissions would be less than the Project.

Operation
As with the Project, Alternative 2 would generate localized emissions from area sources located on-site, such as landscaping equipment, architectural coating, and use of consumer products.

Similar to the Project, Alternative 2 would incorporate Project Design Feature GHG-PDF-1 (Green

5 See Appendix K, Alternatives Documentation, of the Draft EIR for supplemental information regarding trips and VMT for the Project alternatives.

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Building Features) and would comply with SCAQMD Rule 1113 regarding architectural coatings.

Also, both the Project and Alternative 2 would comply with the Title 24 (2022) building energy efficiency standards, CALGreen Building Code, and the Culver City Mandatory Green Building Program. Both the Project and Alternative 2’s localized emissions would be well below the applicable SCAQMD daily impact for NO X, CO, PM10, and PM2.5, and emissions related to sensitive receptor exposure to pollutant concentrations would be less than significant. However, the reduction in building floor area under Alternative 2 would reduce daily operational localized emissions, such as those from consumer product usage, and architectural coatings usage. Also, it can be expected that less landscaping would be provided under Alternative 2 than the Project, so localized emissions associated with landscaping equipment would also decrease compared to the Project. Accordingly, impacts under Alternative 2 with respect to localized operational emissions would be less than the Project.

Carbon Monoxide Hotspots
Vehicle trips would be fewer under Alternative 2 than the Project. As with the Project, Alternative 2 would not cause or contribute considerably to the formation of CO hotspots, and impacts would be less than significant. However, because Alternative 2 would reduce the Project’s daily vehicle trips, impacts would be less than the Project.

Toxic Air Contaminants
Construction
Under Alternative 2, as with the Project, temporary TAC emissions associated with diesel particulate matter (DPM) emissions from heavy construction equipment would occur during construction activities. The Project Site is not located within 500 feet of a freeway, 1,000 feet from a major service and maintenance rail yard or distribution center, or 500 feet of a dry cleaner; therefore, existing sources of TAC emissions are not located within the SCAQMD’s screening distances of the future employees and visitors to the Project Site. Alternative 2 would comply with the California Air Resources Board (CARB) Air Toxics Control Measure that limits diesel powered equipment and vehicle idling to no more than 5 minutes at a location and the CARB In-Use Off - Road Diesel Vehicle Regulation; compliance with these CARB regulations would minimize emissions of TACs during construction. In addition, Alternative 2 would be required to implement Mitigation Measure AQ-MM-1, which would have co-benefits of reducing emissions of PM10 and PM2.5, which are correlated to DPM emissions, from heavy-duty diesel construction equipment.

As with the Project, Alternative 2 would not expose sensitive receptors to substantial TAC concentrations, and impacts would be less than significant. As Alternative 2 would reduce the duration of construction activities, impacts under Alternative 2 would be less than the Project.

Operation
Alternative 2, nor the Project, would include uses that generate a significant number of diesel emissions, such as a truck stop or warehouse distribution uses . As such, operations under both the Project and Alternative 2 would generate only minor amounts of diesel emissions from mobile sources, such as delivery trucks and occasional maintenance. Furthermore, trucks during operation of the Project and Alternative 2 would be required to comply with the applicable provisions of 13 California Code of Regulations (CCR), Section 2025 (Truck and Bus regulation) to minimize and reduce PM10, PM2.5, and NO X emissions from existing diesel trucks. Therefore, as with the

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Project, operation of Alternative 2 would not be considered a substantial source of DPM. With respect to the use of consumer products and architectural coatings, the office uses associated with Alternative 2 would be expected to generate minimal TAC emissions from these sources. As a result, toxic or carcinogenic air pollutants are not expected to occur in any substantial amounts in conjunction with operation of the proposed land uses within the Project Site. Based on the proposed office use, operation of A lternative 2 would not expose sensitive receptors to substantial TAC concentrations and operational impacts would be less than significant, similar to the Project. Since neither the Project or Alternative 2 would include any sources that generate substantial emissions of TACs and both would comply with applicable existing regulations to avoid or minimize TAC emissions, impacts under the Project and Alternative 2 would be similar.

Cultural Resources
Archaeological Resources
Similar to the Project, excavation associated with Alternative 2 would reach a depth of approximately 27 feet bgs. The subsurface archaeological sensitivity assessment for the Project Site indicates that the potential for encountering prehistoric archaeological resources is moderate to high based on the fact that six prehistoric archaeological resources (village sites with human remains and associated artifacts, shell midden deposits, metates, mortars, etc.), water sources (which would have provided fresh water sources to prehistoric inhabitants), and Native American villages (Saa’anga and Waachnga) are situated in the vicinity of the Project Site. Therefore, impacts to previously unknown buried prehistoric archaeological resources are considered potentially significant.

Alternative 2, as with the Project, would implement Mitigation Measures CUL -MM-1 through CUL-MM-3. With the implementation of these measures, Alternative 2, as with the Project, would provide for appropriate treatment and/or preservation of a rchaeological resources if encountered.

Under Alternative 2, as with the Project, potentially significant impacts to archaeological resources would be mitigated to a less-than-significant level. When compared to the Project, impacts related to archeological resources under Alternative 2 would be similar to the Project.

Energy
Efficient Energy Consumption
Similar to the Project, during construction of Alternative 2, energy would be consumed in the form of electricity on a limited basis for powering lights, electronic equipment, or other construction activities necessitating electrical power. Construction of the Project and Alternative 2 would also consume energy in the form of petroleum-based fuels associated with the use of off-road construction vehicles and equipment on the Project Site, construction workers travel to and from the Project Site, and delivery and haul truck trips (e.g., hauling of demolition material to off-site reuse and disposal facilities). Construction of the Project and Alternative 2 would utilize fuel -efficient equipment consistent with State and federal regulations, such as fuel efficiency regulations in accordance with the CARB Pavley Phase II standards, the anti-idling regulation in accordance with Section 2485 in 13 CCR, and fuel requirements in accordance with 17 CCR Section 93115. Alternative 2 would have reduced square footage as compared to the Project. As such, the overall duration of construction would be less than that of the Project. A shorter construction length would mean less overall electricity and transportation energy usage during construction under Alternative 2 than the Project.

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During operation of the Project and Alternative 2, energy would be consumed for multiple purposes, including, but not limited to, on-road mobile sources (i.e., transportation fuel), area sources (i.e., landscape maintenance equipment), energy (i.e., electricity), water conveyance and wastewater treatment, and solid waste. As with the Project, Alternative 2 would incorporate energy- conservation measures beyond regulatory requirements as specified in Project Design Features GHG-PDF-1, which requires achieving a LEED Certified Performance level or higher. The Project and Alternative 2 would include, but would not be limited to, water-efficient landscape design, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; electric vehicle (EV) charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star – labeled appliances, where possible; a solar photovoltaic system and active circulation. Similar to the Project, Alternative 2 would also concentrate its uses within an urban infill location in proximity to multiple public transit options. These measures would minimize operational transportation fuel demand consistent with State, regional, and City goals.

Section 4.4, Energy, of this Draft EIR concludes that the Project’s energy requirements would not substantially affect local and regional supplies or capacity during construction or operation, and that the Project would not cause wasteful, inefficient, or unnecessary consumption of energy during construction or operation and, as such, impacts related to efficient energy consumption would be less than significant. As discussed above, Alternative 2 with its energy saving features in addition to compliance with applicable regulations, would also result in less-than-significant impacts related to wasteful, inefficient, or unnecessary consumption of energy. While the floor area would be reduced under Alternative 2, the proposed office use would have a higher electrical demand than the Project’s residential and retail uses. No natural gas is assumed to be under Alternative 2, and as such, natural gas usage and demand would be greater under the Project. With respect to transportation fuels, Alternative 2 would have a higher VMT than the Project (11,874 vs. 10,504 VMT), thus, energy demand related to transportation fuels would be greater under Alternative 2. 6 Overall, because electricity would be the primary source of energy for both the Project and Alternative 2, and with electricity demand being higher for Alternative 2, in addition to a higher transportation fuel energy demand, Alternative 2 would generate a higher long-term level of energy demand than the Project. Thus, while impacts related to efficient energy consumption would be less than significant under both the Project and Alternative 2, impacts with respect to efficient energy consumption would be greater under Alternative 2 than the Project.

Conflict with Plans for Renewable Energy or Energy Efficiency As with the Project, Alternative 2 would be designed in a manner that is consistent with and not in conflict with relevant energy conservation plans that are intended to encourage development that results in the efficient use of energy resources. The Project and Alternative 2 would comply with applicable regulatory requirements for the design of new buildings, including the provisions set forth in the Title 24 standards and California Green Building Standards (CALGreen ) Building Code, which have been incorporated into Culver City’s Green Building Program. In addition, Alternative 2, as with the Project, would be designed to achieve LEED Certified Performance level

6 See Appendix K, Alternatives Documentation, of the Draft EIR for supplemental information regarding trips and VMT for the Project alternatives.

5. Alternatives

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or higher including energy performance optimization features, including, water-efficient landscape design, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; EV charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star–labeled appliances, where possible; solar photovoltaic system and active circulation. With respect to operational transportation-related fuel usage, the Project and Alternative 2 would support statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. Similar to the Project, Alternative 2 would include the implementation of a transportation demand management (TDM) Program that would encourage efficient transportation and reduce VMT.

Based on the above, similar to the Project, Alternative 2 would have a less-than-significant impact regarding the provisions of plans for renewable energy and energy efficiency. When compared to the Project, impacts related to conflicting with plans for renewable energy or energy efficiency under Alternative 2 would be similar to the Project.

Geology and Soils
Paleontological Resources
Excavation associated with Alternative 2 would reach a maximum depth of approximately 27 feet bgs, same as the Project. Geologic mapping indicates that the surface of the Project Site is underlain by Pleistocene-age older alluvium (Qoa), Holocene -age alluvium (Qa), and possibly by the Pleistocene-age Baldwin Hills Paleosol (Qop), also known as the Fox Hills Paleosol. The Pleistocene alluvium, Qoa, and Baldwin Hills Paleosol have a high potential to yield paleontological resources. Since excavation at the Project Site is estimated to reach depths of up to 27 feet bgs under the Project and Alternative 2, which is deeper than previous excavations on the Project Site, the re is the potential to impact older alluvium and possibly the Baldwin Paleosol, which have a high sensitivity for retaining paleontological resources as discussed above. Therefore, impacts on paleontological resources due to grading and excavation during constr uction are considered potentially significant for both the Project and Alternative 2. Similar to the Project, Alternative 2 would implement Mitigation Measures GEO-MM -1 to GEO-MM-4. With the implementation of these measures, impacts under the Project and A lternative 2 related to paleontological resources during Project construction would be reduced to a less -than-significant level. When compared to the Project, impacts related to paleontological resources under Alternative 2 would be similar to the Project.

Greenhouse Gas Emissions
Like the Project, construction and operation activities under Alternative 2 would increase GHG emissions. The smaller scale associated with Alternative 2 would generate lower total GHG emissions than the Project during the overall construction phase . During operation, a s with the Project, Alternative 2 would incorporate applicable project design features, including Project Design Feature GHG-PDF -1, which requires achieving LEED Certified Performance level or higher, and Project Design Feature TRAF-PDF-1, which would include implementation of a TDM Program. GHG emission impacts under Alternative 2, as with the Project, would be less than significant.

5. Alternatives

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Alternative 2, as with the Project, would be consistent with applicable strategies outlined in CARB’s Climate Change Scoping Plan, SCAG’s Socal Connect , Culver City’s Green Building Program. As such, similar to the Project, impacts under Alternative 2 related to conflicts with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs would be less than significant. However, in consideration of Alternative 2’s higher VMT (mobile source) and increased electricity ener gy demand compared to the Project, long-term GHG emissions can be expected to be higher under Alternative 2 than the Project. For this reason, impacts related to GHG emissions would be greater under Alternative 2 than the Project.

Land Use and Planning
Alternative 2 proposes the development of 190,000 sf of office use on the Project Site. The height of the building would be 4 stories or 56 feet. The size and scale of the building would be smaller than the Project. No publicly accessible space would be provided as part of Alternative 2. proposed square footage, building heights and setbacks would be consistent with the existing zoning designation of Commercial Regional Business Park (CRB) for the Project Site.

As with the Project, the density and location of Alternative 2 would not conflict with policies of regional and local land use plans adopted to avoid or mitigate environmental effects, including:

SCAG’s SoCal Connect , the Culver City General Plan, the Culver City Bicycle & Pedestrian Action Plan, the Culver City Urban Forest Master Plan, and the Culver City Municipal Code, and, as such, impacts with respect to land use would be less than significant. As no changes in zoning or land use designations would be required under Alternative 2, impacts related to land use and planning would be less than the Project.

Noise
Substantial Temporary or Permanent Increase in Ambient Noise Levels Construction
Construction activities under Alternative 2 would be similar to those of the Project and would generally include site demolition, site preparation, grading/excavation, drainage/utilities/trenching, foundations/concrete pour, building construction, architectural coating, and paving. Similar to the Project, maximum daily construction activities under Alternative 2 would increase noise levels at several sensitive receptor locations in the vicinity of the Project Site. As with the Project, because the maximum amount of construction equipment operating simultaneously within the Project Site would be constrained by the size of the property, the maximum construction noise levels under Alternative 2 would be similar to the Project. Based on a conservative impact analysis, construction noise levels would exceed the applicable noise significance thresholds at two nearby noise-sensitive receptors. Therefore, as with the Project, Mitigation Measures NOI-MM-1 and NOI-MM-2 would be implemented under Alternative 2 to reduce construction noise impacts at off-site noise-sensitive receptors. However, as with the Project, even with implementation of mitigation measures,

5. Alternatives

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potentially significant on-site construction noise impacts would remain significant and unavoidable under Alternative 2 should construction activities occur during the morning hours if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours. With regard to off-site construction noise, the increase in noise levels of construction trips along any of the studied roadway segments would not exceed the significance threshold, and impacts would be less than significant. The overall duration of construction under Alternative 2 would be less than that of the Project. Therefore, the duration of construction noise would be shorter. As such, impacts related to construction noise under Alternative 2 would be less than the Project.

Operation
Alternative 2, as with the Project, would generate on -site composite noise associated with fixed mechanical equipment noise and parking structure noise. However, under the Project, outdoor open space noise would occur from various spaces within the Project Site. No outdoor opens spaces would occur under Alternative 2. Under the Project, operational composite noise levels, with the outdoor open space areas, would not exceed the ambient noise levels by 5 dBA at the nearby noise receptor locations. Because Alternative 4 would not support outdoor activities, operational noise impacts would be less than the Project’s less-than-significant impacts.

Further, Alternative 2 would involve a smaller scale project with fewer overall off-site vehicle trips.

Therefore, operational mobile source noise impacts would be incrementally less under Alternative 2 than the Project. Overall, impacts under Alternative 2 would be less than the Project.

Vibration
Construction
Construction of Alternative 2 , as with the Project, would generate groundborne construction vibration from the operation of heavy equipment (i.e., backhoe, dozer, excavators, grader, loader, and haul trucks, etc.). As with the Project, the estimated vibration velocity levels from all construction equipment (maximum construction conditions) under Alternative 2 would be below the structural damage and human annoyance significance criteria at off-site building structures and vibration sensitive receptors. In addition, as with the Project, vibration impacts from off -site construction traffic would also be below the vibration significance criteria. Therefore, on-site and off-site vibration impacts would be less than significant. As the overall scale of development would be reduced under Alternative 2, the duration of construction and overall construction activity causing vibration would be less, and impacts under Alternative 2 would be less than the Project.

Operation
Day-to-day operations under Alternative 2, as with the Project, 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 vibration would be passenger vehicle circulation within the proposed parking area. The potential vibration levels from all Project operational sources at the closest existing sensitive receptor locations would be less than the significance threshold. Therefore, similar to the Project, operational vibration impacts under Alternative 2 would be less than significant. While Alternative 2 would increase daytime occupancy of the Project Site compared to the Project , a change in off -site

5. Alternatives

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groundborne operation vibration is not anticipated to be perceptible under Alternative 2 compared to the Project, and, as such, impacts under Alternative 2 would be similar to the Project.

Population and Housing
Induce Substantial Unplanned Population Growth
During operation, the Project would generate 733 new residents and 20 employees. Accounting for the existing 147 employees, the net decrease in employees under the Project would be 127 people.

Alternative 2 would generate 908 employees with no new residential population. Alternative 2 and the Project’s contribution to population and/or employee growth would continue an infill growth pattern that is encouraged locally. Neither Alternative 2 nor the Project would exceed projected growth SCAG forecasts for the City and region. However, Alternative 2 would not be consistent with regional and local policies that encourage mixed -use and higher density housing within the City and region. The Project’s contribution of housing would help the City’s ability to meet its housing obligation under SCAG’s RHNA and goals of the Housing Element. Alternative 2 would indirectly induce population gain through employment opportunities but would not incorporate housing. As such, Alternative 2 would be less consistent with SCAG and City objectives which seek an increase in diverse housing options. However, because Alternative 2 would result in no housing and only an increased indirect demand for housing as compared to the Project, impacts with respect to induced direct or indirect substantial unplanned population growth would be less than the Project’s less than significant population and housing impacts.

Public Services
Fire Protection
Construction
Alternative 2, as with the Project, would involve construction activities and intensify the use of the Project Site so that it would increase demand on fire protection and emergency medical services, as well as potentially reduce emergency access. As with the Project, Alternative 2 would comply with all regulatory requirements including regulations set forth in the Safety and Health Regulations for Construction established by OSHA and compliance with all applicable federal, state, and local requirements con cerning the handling, disposal, use, storage, and management of hazardous materials. In addition, the Project and Alternative 2 would implement Project Design Feature TRAF-PDF-1 to provide a Construction Management Plan to ensure that adequate and safe access remains available within and near the Project Site during construction activities. The implementation of regulatory requirements and project design features would facilitate emergency access. With such features, neither the Project nor Alternative 2 would increase fire services demand to the extent that the addition of a new fire facility, or the expansion, consolidation, or relocation of an existing facility would be required to maintain service. As such, similar to the Project, construction under Alternative 2 would result in less-than -significant impacts related to fire protection that are similar to the Project.

Operation
During operation, the Project would generate 733 new residents and 20 employees. Accounting for the existing 147 employees, the net decrease in employees under the Project would be 127 people.

As such, the overall net daytime population (residents and employees) under the Project would be

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606 people, while the nighttime population (residents only) would be 733 persons. Alternative 2 would generate 908 employees, thus, the net increase in the daytime population would be 761 persons. Alternative 2 would have no nighttime population. Alternative 2 , as with the Project, would comply with the applicable OSHA, Building Code, Fire Code, CCMC, and Culver City Fire Department (CCFD) requirements, including installation of a fire sprinkler suppression system, a fire alarm system, an Emergency Responder Radio Coverage, smoke detectors, and signage, among other fire prevention features. Compliance with applicable requirements under both the Project and Alternative 2 would reduce demand on facilities and equipment without creating the need for new or expanded fire facilities. In addition, both buildings under the Project and Alternative 2 would be required to install an automatic fire sprinkler system. As the Project Site is located within a highly urbanized area accessed via an established street system, impacts on emergency response under the Project or Alternative 2 would not be significant. Alternative 2, as with the Project, would also be consistent with CCFD fire flow requirements. As such, the Project and Alternative 2 would not result in substantial adverse physical impacts associated with the provision of or need for new or altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or ot her performance objectives. Impacts under Alternative 2, as with the Project, would be less than significant.

However, because Alternative 2 would not include a nighttime population despite its higher daytime population compared to the Project, impacts related to fire protection services under Alternative 2 would be less than the Project.

Police Protection
Construction
Alternative 2, as with the Project, would result in construction activities that could affect emergency access and increase demand for police protection services. As with the Project, Alternative 2’s construction phase, although of shorter duration than that of the Project, could increase demand for police protection services. To reduce Culver City Police Department (CCPD) demand during construction, Alternative 2, as with the Project, would implement security measures under Project Design Feature POL -PDF-1 to limit access to construction areas and provide for cameras to monitor the Project Site during off hours. Similar to the Project, construction activities under Alternative 2 may involve temporary partial lane closures or increase travel time due to flagging or stopping traffic to accommodate trucks entering and exiting the Project Site. As with the Project, Alternative 2 would implement Project Design Feature TRAF -PDF-1. Under Project Design Features TRAF-PDF-1, a Construction Management Plan would ensur e that adequate and safe access remains available at the Project Site during construction activities. Furthermore, it is not anticipated that any additional officers from CCPD would be needed to monitor the Project Site during construction outside of the e xisting officers that patrol the area. Additionally, the various safety and control features that would be implemented during construction would reduce the potential for incidents that would require police responses. With such features, neither the Project nor Alternative 2 would increase police services demand to the extent that the addition of a new fire facility, or the expansion, consolidation, or relocation of an existing facility would be required to maintain service. Therefore, impacts under Alternative 2 would be less-than-significant and similar to the Project.

5. Alternatives

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Operation
During operation, the Project would generate 733 new residents and 20 employees. Accounting for the existing 147 employees, the net decrease in employees under the Project would be 127 employees. As such, the overall net daytime population (residents and employees) under the Project would be 606 pe ople, while the nighttime population (residents only) would be 733 persons.

Alternative 2 would generate 908 employees, thus, the net increase in the daytime population would be 761 persons. Alternative 2 would have no nighttime population. Impacts to police services are based on an increase i n the ratio of officers to residential population. Consequently, since Alternative 2 would not directly increase the existing residential population in the Culver City Police Department (CCPD) service area, which has a current residential population of approximately 40,000, Alternative 2 would not directly impact officer per resident service ratios. As provided in Project Design Feature POL-PDF-2, both the Project and Alternative 2 would incorporate a security program to reduce demand for police services and to ensure the safety of occupants. The security program would reduce the potential for on-site crimes, including loitering, theft, and burglaries and would be reviewed for further suggestions by the CCPD. CCPD correspondence in response to the preparation of the Draft EIR stated that the Project would not result in the need for new or altered police facilities. 7 Given that Alternative 2 have no residential or nighttime population, the CCPD’s determination is equally applicable to Alternative 2. Thus. neither the Project nor Alternative 2 would result in substantial adverse physical impacts associated with the provision of a new or physically altered police facility, the construction of which would cause significant environmental impacts. Impacts relative to police services would be less t han significant under both the Project and Alternative 2.

However, because Alternative 2 would remove the Project’s residential population increase, impacts to police services would be less than the Project’s less-than-significant impact.

Schools
Construction
Construction under either the Project or Alternative 2 would generate employees who are anticipated to be hired from a mobile regional construction work force. Given the mobility and temporary duration of work at a particular site, construction employees not residing locally would not be expected to relocate residences (and, therefore, generate a new student population).

Therefore, construction of either the Project or Alternative 2 would not result in a notable increase in the resident population or new students needing to attend local schools. With the nearest public CCUSD school located approximately 0.7 mile northwest of the Project, no public schools would be physically affected by construction activities at the Project Site. Construction impacts on schools under both the Project and Alternative 2 would be less than significant. Impacts on schools under Alternative 2 would be similar to the Project’s less-than-significant impacts.

Operation
As shown in Table 5-2, Estimated Number of Students Generated by Alternative 2, Alternative 2 would generate a total of 157 students. In comparison, the Project would generate 162 students from just its residential uses. Another few students (less than 5) could be generated by the Project’s retail uses. Similar to the Project, under Alternative 2, El Rincon Elementary School, Culver City

7 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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Middle School, and Culver City High School are conservatively assumed that the Project or Alternative 2 have the potential to result in a new seating shortage at all three schools.

TABLE 5-2
ALTERNATIVE 2 STUDENT GENERATION
Land Use Amount a Generation Factor a
Elementary
School
Students
Middle
School
Students
High
School
Students Total
Employees 908 employees 0.1724 students/emp 86 24 47 157 NOTES:
a 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 Alternative 2 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 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, 2024.

Under either the Project or Alternative 2, pursuant to Senate Bill (SB) 50, the Project Applicant would be required to pay development fees 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 school impacts. Therefore, neither the Project nor Alternative 4 would result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities and impacts would be less than significant. Because Alternative 2 would result in a lower generation of students, operational impacts on schools would be less than the Project’s less- than-significant impact.

Parks and Recreation
Construction
Construction activities under both the Project and Alternative 2 have the potential to affect parks and recreational facilities. A small number of construction workers may visit public parks to eat lunch or for recreational activity after a workday. However, because construction workers are temporary employees with high turnover during various phases of construction, the use of public parks would be uncommon and short-term. In addition, neither the Project nor Alternative 2 directly impact public park facilities. Construction of either the Project or Alternative 2 would not include or require the construction, alteration, or expansion of recreational facilities that might have an adverse physical effect on the environment. Therefore, Alternative 2’s impacts associated with parks and recreational facilities would be similar to the Project’s less-than-significant impacts.

Operation
Alternative 2 would remove the Project’s residential component by developing only office uses.

Alternative 2’s office uses would generate a nominal demand for public recreational uses with employees primarily visiting the Fox Hills Parkette for short periods of time during the work week.

Also, Alternative 2 would result in an incremental indirect population gain through employment opportunities but would not incorporate housing. Nonetheless, because Alternative 2 would not

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result in any direct (residential) population increase, or include housing impacts to public recreational and parks facilities would be less than significant and less than the Project.

Transportation
Conflict with Programs, Plans, Ordinances, or Policies Addressing the Circulation System, Transit, Roadways, Bicycle, and Pedestrian Facilities Similar to the Project, Alternative 2 would support multimodal transportation options as well as promote transportation-related safety in the vicinity. Alternative 2, as with the Project, would not conflict with policies or procedures of 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. As with the Pr oject, Alternative 2 would implement Project Design Feature TRAF- PDF-2, which would include implementation of a TDM Program that would help to reduce volumes on nearby roadways due to employee commute and encourage transit ridership through various programs. Similar to the Project, as Alternative 2 would not conflict with any of the policies and procedures contained in the above-mentioned City of Culver City transportation-related programs, plans, ordinances, and policie s, impacts relative to plans and programs would be less than significant. When compared to the Project, impacts related to conflicting with programs, plans, ordinances, and policies, addressing the circulation system under Alternative 2 would be similar to the Project.

10.2, which is above the City’s 8.6 threshold per employee. Comparatively, the Project would generate 1,462 daily trips and 11,874 VMT. 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. It is assumed that Alternative 2 would implement TDM measures to reduce its VMT to below the employee threshold. By doing so, neither the Project nor Altern ative 2 would result in VMT impacts that exceed the City’s VMT thresholds. Impacts regarding VMT would be consistent with the City’s Transportation Study Criteria and Guidelines and, thus, consistent with CEQA Guidelines Section 15064.3(b). Therefore, VMT impacts under either the Project or Alternative 2 would be less than significant. Since Alternative 2 would have a higher daily VMT and the VMT per capita for the Project without any TDM measures would be below the City’s threshold, unlike Alternative 2 exceedance of the employee VMT threshold without any TDMs, impacts would be greater under Alternative 2 than the Project’s less than significant VMT impact.

Design Hazards
Alternative 2, as with the Project, would design driveways to comply with City of Culver City standards as outlined in the Culver City Municipal Code ( Section 17.320.040). The driveways

8 See Appendix K, Alternatives Documentation, of the Draft EIR for supplemental information regarding trips and VMT for the Project alternatives.

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would be configured to avoid or minimize potential conflicts with transit services and pedestrian traffic by providing curb and sidewalk to separate pedestrian movements from vehicular movements. The Project or Alternative 2 would not substantially increase hazards or conflicts and would contribute to overall walkability through enhancements to the Project Site. As Alternative 2 would generate fewer trips to/from the Project Site, projected queue lengths would similarly not exceed the available storage lengths under Alternative 2. Impacts under Alternative 2 would be less than significant and similar to the Project.

Emergency Access
The Project Site is located within an urbanized area with a fully developed roadway system. Similar to the Project, Alternative 2 would include temporary construction activities (e.g., temporary lane closures) and traffic that could potentially affect emergency access to the Project Site and surroundings. The Project and Alternative 2 would implement Project Design Feature TRAF-PDF- 1, which would require construction staging and construction worker parking to be accommodated on the Project Site, limiting potential conflicts with traffic on local streets. In addition, e mergency 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. In addition, future driveway and building configurations under the Project and Alternative 2 would comply with applicable fire code requirements for emergency evacuation, including proper emergency exits for visitors and employees. Furthermore, pursuant to California Vehicle Code Section 21806, the drivers of emergency vehicles are 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. Therefore, Alternative 2, as with the Project, would not impair implementation of or physically interfere with adopted emergency response or emergency evacuation plans. Impacts regarding emergency access under Alternative 2 would be less than significant and similar to the Project.

Tribal Cultural Resources
The City complied with Assembly Bill (AB) 52 in its Native American tribal consultation and records searches conducted through South Central Coastal Information Center (SCCIC) and the Native American Heritage Commission (NAHC). No known prehistoric archaeological resources were identified within or immediately adjacent to the Project Site. No known tribal cultural resources, as defined in PRC Section 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 AB 52 consultation, or as a result of the Sacred Lands File (SLF) search through the NAHC and the SCCIC. However, the Project Site appears to have a moderate to high potential for encountering previously unknown tribal cultural resources during construction. As a result, similar to the Project, Alternative 2 would implement Mitigation Measure CUL-MM-2 and Mitigation Measures TCR-MM-1 through TCR-MM-3. With implementation of mitigation measures, impacts under the Project and Alternative 2 would be reduced to less-than -significant levels. When compared to the Project, impacts related to tribal cultural resources under Alternative 2 would be similar to the Project.

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Utilities and Service Systems
Water Supply
New or Expanded Water Facilities
Under Alternative 2, while construction duration would be reduced as compared to the Project, construction water use would be similar on a daily basis. 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, the existing water infrastructure would meet the limited and temporary water demand associated with construction of the Project or Alternative 2.

Water service for the Project or Alternative 2 would be provided by Golden State Water Company (GSWC), as under existing conditions. When analyzing infrastructure capacity, although domestic water demand is the 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. The existing hydrants in the area of the Project Site would provide adequate fire flow meeting the requirements of CCFD for the Project . Given the relatively smaller size of the proposed building under Alternative 2 as compared to the Project, it can be expected that the existing hydrants serving the Project Site would also be able to provide adequate fire flow for Alternative 2. As such, operation of the Project or Alternative 2 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 and impacts would be less than significant. When compared to the Project, impacts related to new for expanded water facilities under Alternative 2 would be similar to the Project.

Water Supplies
While construction duration would be reduced under Alternative 2 as compared to the Project, the estimated construction daily 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, the existing water supplies would be available to meet the temporary water demand associated with construction of the Project.

As with the Project, Alternative 2 would not require the preparation of a WSA per SB 610 since it would not employ more than 1,000 persons or have more than 250,000 sf of office floor space.

Both the Project and Alternative 2 would increase long -term water demand for consumption, operational uses, maintenance, and other activities on the Project Site. Net domestic water demand (subtracting existing demand) for the Project would be 36,446 gpd, or 41 AFY. As shown in Table 5-3, Alternative 2 Estimated Water C onsumption, using the office water demand factor in Table

4.13.1-6, Estimated Cumulative Water Generation by Related Projects, in Section 4.13.1, Utilities and Service Systems – Water Supply, based on a rate of 120 gpd/ksf, Alternative 2’s 190,000 sf of office use would have a water demand of 2 7,360 with irrigation gpd day. Subtracting the existing 7,360 gpd, the net water demand would be approximately 20,000 gpd or 22.4 AFY.

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TABLE 5-3
ALTERNATIVE 2 ESTIMATED WATER CONSUMPTION
Proposed Use Units Water Use Rate a
Water Usage b
gpd AFY
Office 190,000 sf 120/1,000 sf 22,800 25.5
Irrigation b — — 4,560 5.1
Total Proposed Water Demand 27,360 30.6
Existing Site Demand -7,360 -8.2
Total Net Water Demand 20,000 22.4
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: ESA, 2024.

Both the Project and Alternative 2 would be consistent with the demographic projections for the City in SCAG’s SoCal Connect and, as such, the GSWC has sufficient water supplies as projected in its latest UWMP to serve the Project and Alternative 2 and the reasonably foreseeable future development during normal, dry, and multiple -dry years. Impacts regarding water supply during operation would be less than significant under both the Project and Alternative 2. However, because Alternative 2 would reduce overall water demand compared to the Project, Alternative 2’s impacts would be less than the Project’s less-than-significant water impacts.

Electric Power, Natural Gas, Telecommunications Facilities Alternative 2, as with the Project, would utilize energy infrastructure to accommodate their respective demand for energy resources. Similar to the Project, Alternative 2’s electricity and natural gas demands are expected to represent a small fraction of Southern California Edison (SCE) and Southern California Gas Company (SoCalGas) energy supplies and the service provider’s existing infrastructure. Planned electricity and natural gas supplies would be sufficient to meet the Project’s or Alternative 2’s demand for elect ricity and natural gas. As with the Project, Alternative 2 would not result in an increase in demand for electricity, or natural gas, services that exceeds available supply or distribution infrastructure capabilities that could result in the construction of new facilities or expansion of existing facilities, the construction of which could cause significant environmental ef fects. Similar to the Project, impacts with respect to the relocation or expansion of electric power or natural gas infrastructure under Alternative 2 would be less than significant. As off -site electric power and natural gas infrastructure would accommodate demand under Alternative 2, impacts would be similar to the Project.

Relationship of the Alternative to Project Objectives
As described above, with development under the Existing Zoning Alternative ( Alternative 2), the Project Site would be developed in accordance with the existing General Plan Land Use designation of Regional Center and existing zoning designation of Commercial Regional Business Park (CRB) for the Project Site. Under this Alternative, the existing 30,672 square foot two-story office building

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built in the 1970s would be replaced with a modern 190,000 square foot, 4-story (56 feet) office building. This Alternative would provide no retail uses or public open space as compared to the Project. Alternative 2 would not include a public plaza along Hannum Avenue, thus, the extent of streetscape, landscaping and heightened pedestrian activity would be than the Project. Compared to the Project, Alternative 2 would have an approximate 47 percent reduction in building square footage (362,596 sf vs 190,000 sf).

Alternative 2 would fully meet the following Project Objective similar to the Project:

Alternative 2 would partially meet the below Project Objective, but to a lesser extent than the Project since it would provide less landscape features and less active ground floor uses with open space amenities.

As described above, under Alternative 2 the Project Site would continue to operate as a larger office building as compared to existing conditions. Thus, Alternative would not meet the following Project objectives:

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

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.

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

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

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

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

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

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Project. Under Alternative 3 and similar to the Project, in order to provide an aesthetically succinct and unified development, the Alternative 3 would redevelop the Project Site under the PD zone.

Similar to the Project, Alternative 3 redevelop the site with a high -quality new building subject to design review by the City. Alternative 3 would implement project design features that would require mechanical, electrical, and roof top equipment (including heating, ventilation, and air conditioning (HVAC) systems), as well as building appurtenances, to be integrated into the architectural design (e.g., placed behind parapet walls) and be screened from view from public rights-of-way. Compared to the Project, the overall massing and height of the building would be smaller and shorter, respectively. As with the Project, Alternative 3 would include a landscape and street tree program that meets City requirements along Hannum Avenue and Buckingham Parkway. However, this Alternative would include a reduced public open space area along Hannum Avenue, and no residential units along Buckingham Parkway. A parking garage would be visible at the ground level along Buckingham Parkway under Alternative 3. Thus, the extent of streetscape, landscaping and heightened pedestrian activity would be less than the Project. Despite the aesthetic variations between the Project and Alternative 3, both would comply with applicable CCMC regulations that govern scenic character, such as building heights, setbacks, and screening. As such, neither the Project nor Alternative 3 would conflict with the policies of the CCMC that regulate scenic quality and impacts would be less than significant. When compared to the Project, impacts related to conflicting with regulations that govern scenic quality under Alternative 3 would be similar to the Project.

Supplemental Shading Analysis
Under Alternative 3, the proposed building would be 5-stories (56 feet) over 1-level of subterranean parking as compared to the Project’s 6 -story (up to a height 78- feet) building over 2 -levels of subterranean parking. Under the Project, redevelopment of the Project Site would add limited incremental shadows to the Fox Hills Parkette during the winter season in the afternoon hours, and not shade any portion of the residential uses across Buckingham Parkway year around. Given the Project’s limited shading of off-site routinely usable outdoor spaces, shading would not be an adverse effect of the Project's implementation. Under Alternative 3 with a reduced building height, there would be no shading of the Fox Hills Parkette or any portion of the residential uses across Buckingham Parkway year around. The extent of shadows cast by Alternative 3 would be less than the Project, with neither the Project nor Alternative 3 substantially affecting any off-site shade sensitive uses.

Air Quality
Conflict with Air Quality Management Plan
Similar to the Project, Alternative 3 would include new development on the Project Site that would generate new criteria pollutant emissions. Similar to the Project, Alternative 3 would be consistent with the goals of SCAG’s 2016- 2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also referred to Connect SoCal, and growth projections in the 2016 AQMP, since the growth would occur in consistent with the existing zoning designation. As with the Project, Alternative 3 would be consistent with the AQMP in its incorporation of appropriate control strategies for emissions reduction during construction and operation. In addition, Alternative 3 would also be consistent with applicable goals, objectives, and policies of the City of Culver City General Plan and Mandatory Green Building Program that support and encourage reducing single occupancy vehicle trips and VMT. As with the Project, Alternative 3 would develop a TDM program to reduce the amount single-occupancy vehicle trips and encourage use of alternative transportation. For all of these

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reasons, impacts under Alternative 3 with respect to conflicting or obstructing with AQMPs would be less than significant. When compared to the Project, impacts related to conflicting with the AQMP under Alternative 2 would be similar to the Project.

Cumulative Increase in Criteria Pollutants/Violation of Air Quality Standards Construction
As with the Project, Alternative 3’s construction phases have the potential to generate daily emissions that would exceed the SCAQMD air quality standards through the use of heavy- duty construction equipment, such as excavators and forklifts, through vehicle trips generated by workers and haul trucks traveling to and from the Project Site, and through building activities, such as the application of paint and other surface coatings. The maximum daily regional emissions under Alternative 2 would be similar to the Project because emission levels are based on a single day in which maximum construction activity would occur. Similar to the Project, regional construction emissions under Alternative 3 would not exceed SCAQMD numerical regional construction emissions significance thresholds and impacts would be less than significant. However, with an approximate 37 percent reduction in overall building square footage (362,593 sf vs 227,600 sf) and removal of one of the subterranean parking levels proposed under Alternative 3, the duration of the Project’s excavation phase would be reduced from 4 months to 2.5 months and the building construction phase would be reduced by approximately 1.5 months from 17 months to 15.5 months. Thus, overall construction under Alternative 3 would be approximately 27 months, as opposed to 30 months under the Project.

As Alternative 3 would reduce construction duration, impacts with respect to cumulative increases in criteria pollutants and violations of air quality standards would be less than the Project.

Operation
During operation, Alternative 3 would generate emissions associated with vehicle trips, heating, lighting, other electric requirements, and architectural coatings. Similar to the Project, Alternative 2 would incorporate Project Design Feature GHG-PDF-1 (Green Building Features) and would comply with SCAQMD Rule 1113 regarding architectural coatings. Not only would there be a reduction in the size of the building scale compared to the Project, Alternative 3 would generate fewer daily trips (1,094 vs. 1,462 trips), and VMT (7,883 vs. 10,504 VMT) than the Project resulting in lower mobile source emissions which is a primary factor in assessing regional emissions.
9 As such, mobile source regional emissions would be less under this Alternative. Both the Project and Alternative 3’s regional emissions would be well below the applicable SCAQMD daily impact for VOC, NO X, CO, SO X, PM10, and PM2.5, and emissions related to air quality standards would be less than significant. Overall, with Alternative 3 being developed at a lower intensity than the Project and a corresponding reduction in daily vehicle trips and VMT compared to the Project, impacts with respect to cumulative increases in criteria pollutants and violations of air quality standards would be less under Alternative 3 than the Project.

9 See Appendix K, Alternatives Documentation, of the Draft EIR for supplemental information regarding trips and VMT for the Project alternatives.

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Sensitive Receptor Exposure to Pollutant Concentrations Localized Emissions
Construction
As with the Project, Alternative 3’s construction phases have the potential to generate daily emissions that would exceed the SCAQMD air quality standards through the use of heavy -duty construction equipment, such as excavators and forklifts, through vehicle trips generated by workers and haul trucks traveling to and from the Project Site, and through building activities, such as the application of paint and other surface coatings. The maximum daily localized emissions under Alternative 3 would be similar to the Project because emission levels are based on a single day in which maximum construction activity would occur. Similar to the Project, localized construction emissions under Alternative 3 would not exceed SCAQMD numerical localized construction emissions significance thresholds and impacts would be less than significant.

However, with an approximate 37 percent reduction in overall building square footage (362,593 sf vs 227,600 sf) and removal of one of the subterranean parking levels proposed under Alternative 3, the duration of the Project’s excavation phase would be reduced from 4 months to 2.5 months and the building construction phase would be reduced by approximately 1.5 months from 17 months to

15.5 months. Thus, overall construction under Alternative 3 would be approximately 27 months, as opposed to 30 months under the Project. As Alternative 3 would reduce construction duration, impacts with respect to construction-related localized emissions would be less than the Project.

Operation
As with the Project, Alternative 3 would generate localized emissions from area sources located on- site, such as landscaping equipment, architectural coating, and use of consumer products. Similar to the Project, Alternative 2 would incorporate Project Design Feature GHG-PDF-1 (Green Building Features) and would comply with SCAQMD Rule 1113 regarding architectural coatings. Also, both the Project and Alternative 2 would comply with the Title 24 (2022) building energy efficiency standards, CALGreen Building Code, and the Culver City Mandatory Green Building Program. Both the Project and Alternative 3’s localized emissions would be well below the applicable SCAQMD daily impact for NO
X, CO, PM10, and PM2.5, and emissions related to sensitive receptor exposure to pollutant concentrations would be less than significant. However, the reduction in building floor area under Alternative 3 would reduce daily operational localized emissions, such as those from consumer product usage, and architectural coatings usage. Also, it can be expected that less landscaping would be provided under Alternative 3 than the Project, so localized emissions associated with landscaping equipment would also decrease compared to the Project. Accordingly, impacts under Alternative 3 with respect to localized operational emissions would be less than the Project.

Carbon Monoxide Hotspots
Vehicle trips would be fewer under Alternative 3 than the Project. As such, as with the Project, Alternative 3 would not cause or contribute considerably to the formation of CO hotspots, and impacts would be less than significant. However, because Alternative 3 would reduce the Project’s daily vehicle trips, impacts would be less than the Project.

Toxic Air Contaminants
Construction
Under Alternative 3, as with the Project, temporary TAC emissions associated with DPM emissions from heavy construction equipment would occur during construction activities. The Project Site is

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not located within 500 feet of a freeway, 1,000 feet from a major service and maintenance rail yard or distribution center, or 500 feet of a dry cleaner; therefore, existing sources of TAC emissions are not located within the SCAQMD’s screening distances of the future employees and visitors to the Project Site. Alternative 3 would comply with CARB’s Air Toxics Control Measure that limits diesel powered equipment and vehicle idling to no more than 5 minutes at a location and the CARB In-Use Off -Road Diesel Vehicle Regulation; compliance with these CARB regulations would minimize emissions of TACs during construction. In addition, Alternative 3 would be required to implement Mitigation Measure AQ -MM-1, which would have co- benefits of reducing emissions of PM10 and PM2.5, which are correlated to DPM emissions, from heavy-duty diesel construction equipment. As with the Project, Alternative 3 would not expose sensitive receptors to substantial TAC concentrations, and impacts would be less than significant. As Alternative 3 would reduce the duration of construction activities, impacts under Alternative 3 would be less than the Project.

Operation
Alternative 3, nor the Project, would include uses that generate a significant number of diesel emissions, such as a truck stop or warehouse distribution uses. As such, operations under both the Project and Alternative 3 would generate only minor amounts of diesel emissions from mobile sources, such as delivery trucks and occasional maintenance. Furthermore, operation of the Project and Alternative 3 would be required to comply with the applicable provisions of 13 CCR, Section 2025 (CARB Truck and Bus regulation) to minimize and reduce PM10, PM2.5, and NO X emissions from existing diesel trucks. Therefore, as with the Project, operation of Alternative 3 would not be considered a substantial source of DPM. With respect to the use of consumer products and architectural coatings, similar to the Project, the mix of residential and retail uses associated with Alternative 3 would be expected to generate minimal TAC emissions from these sources. As a result, toxic or carcinogenic air pollutants are not expected to occur in any substantial amounts in conjunction with operation of the proposed land uses within the Project Site. Based on the proposed uses, operation of Alternative 3 would not expose sensitive receptors to substantial TAC concentrations and operational impacts would be less than significant, similar to the Project. Since neither the Project or Alternative 3 would include any sources that generate substantial emissions of TACs and both would comply with applicable existing regulations to avoid or minimize T AC emissions, impacts under the Project and Alternative 3 would be similar.

Cultural Resources
Archaeological Resources
Excavation associated with Alternative 3 would reach a depth of approximately 15 feet bgs, which is 12 feet less than the Project’s excavation depth of 27 feet bgs. The subsurface archaeological sensitivity assessment for the Project Site indicates that the potential for encountering prehistoric archaeological resources is moderate to high based on the fact that six prehistoric archaeological resources (village sites with human remains and associated artifacts, shell midden deposits, metates, mortars, etc.), water sources (which would have provided fresh water sources to prehistoric inhabitants), and Native American villages (Saa’anga and Waachnga) are situated in the vicinity of the Project Site. Therefore, impacts to previously unknown buried prehistoric archaeological resources are considered potentially significant. Alternative 3, as with the Project, would implement Mitigation Measures CUL- MM-1 through CUL-MM-3. With the implementation of these measures, Alternative 3, as with the Project, would provide for appropriate treatment and/or preservation of archaeological resources if encountered.

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Under Alternative 3, as with the Project, potentially significant impacts to archaeological resources would be mitigated to a less-than-significant level. However, when compared to the Project, because the depth and extent of excavation would be less under Alternative 3, impacts related to archaeological resources under Alternative 3 would be less than the Project.

Energy
Efficient Energy Consumption
Similar to the Project, during construction of Alternative 3, energy would be consumed in the form of electricity on a limited basis for powering lights, electronic equipment, or other construction activities necessitating electrical power. Construction of the Project and Alternative 3 would also consume energy in the form of petroleum -based fuels associated with the use of off -road construction vehicles and equipment on the Project Site, construction workers travel to and from the Project Site, and deliver y and haul truck trips (e.g., hauling of demolition material to off -site reuse and disposal facilities). Construction of the Project and Alternative 3 would utilize fuel - efficient equipment consistent with State and federal regulations, such as fuel efficiency regulations in accordance with the CARB Pavley Phase II standards, the anti -idling regulation in accordance with Section 2485 in 13 CCR, and fuel requirements in accordance with 17 CCR Section 93115.

Alternative 2 would have reduced excavation, density and scale as compared to the Project. As such, the overall duration of construction would be less than that of the Project. A shorter construction length would mean less overall electricity and transportation energy usage during construction under Alternative 3 than the Project.

During operation of the Project and Alternative 3, energy would be consumed for multiple purposes, including, but not limited to, on-road mobile sources (i.e., transportation fuel), area sources (i.e., landscape maintenance equipment), energy (i.e., electricity), water conveyance and wastewater treatment, and solid waste. As with the Project, Alternative 3 would incorporate energy- conservation measures beyond regulatory requirements as specified in Project Design Features GHG-PDF-1, which requires achieving a LEED Certified Performance level or higher. The Project and Alternative 3 would include, but would not be limited to, water-efficient landscape design, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; electric vehicle (EV) charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star – labeled appliances, where possible; a solar photovoltaic system and active circulation. Similar to the Project, Alternative 3 would also concentrate its uses within an urban infill location in proximity to multiple public transit options. These measures would minimize operational transportation fuel demand consistent with State, regional, and City goals.

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Conflict with Plans for Renewable Energy or Energy Efficiency As with the Project, Alternative 3 would be designed in a manner that is consistent with and not in conflict with relevant energy conservation plans that are intended to encourage development that results in the efficient use of energy resources. The Project and Alternative 3 would comply with applicable regulatory requirements for the design of new buildings, including the provisions set forth in the Title 24 standards and California Green Building Standards (CALGreen) Building Code, which have been incorporated into Culver C ity’s Green Bu ilding Program. In addition, Alternative 3, as with the Project, would be designed to achieve LEED Certified Performance level or higher including energy performance optimization features, including, water-efficient landscape design, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; EV charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star–labeled appliances, where possible; solar photovoltaic system and active circulation. With respect to operational transportation-related fuel usage, the Project and Alternative 2 would support statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. Similar to the Project, Alternative 3 would include the implementation of a transportation demand management (TDM) Program that would encourage efficient transportation and reduce VMT.

Based on the above, similar to the Project, Alternative 3 would have a less-than-significant impact regarding the provisions of plans for renewable energy and energy efficiency. When compared to the Project, impacts related to conflicting with plans for renewable energy or energy efficiency under Alternative 3 would be similar to the Project.

Geology and Soils
Paleontological Resources
Excavation associated with Alternative 3 would reach a maximum depth of approximately 15 feet bgs, which is 12 feet less than the Project’s maximum depth of 27 feet bgs. Geologic mapping indicates that the surface of the Project Site is underlain by Pleistocene-age older alluvium (Qoa), Holocene-age alluvium (Qa), and possibly by the Pleistocene-age Baldwin Hills Paleosol (Qop), also known as the Fox Hills Paleosol. The Pleistocene alluvium, Qoa, and Baldwin Hills Paleosol have a high potential to yield paleontological resources. With excavations depths of 27 feet bgs and 15 feet bgs under the Project and Alternative 3, respectively, which are deeper than previous excavations on the Project Site, there is the potential to impact older alluvium and possibly the Baldwin Paleosol, which have a high sensitivity for retaining paleontological resources as discussed above. The refore, impacts on paleontological resources due to grading and excavation during construction are considered potentially significant for both the Project and Alternative 3. Similar to the Project, Alternative 3 would implement Mitigation Measures GEO -MM-1 to GEO -MM-4. With the implementation of these measures, impacts under the Project and Alternative 3 related to paleontological resources during Project construction would be reduced to a less -than-significant level. However, when compared to the Project, because the depth and extent of excavation would be less under Alternative 3, impacts related to paleontological resources under Alternative 3 would be less than the Project.

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Greenhouse Gas Emissions
Like the Project, construction and operation activities under Alternative 3 would increase GHG emissions. The smaller scale associated with Alternative 3 would generate lower total GHG emissions than the Project during the overall construction phase. During operation, as with the Project, Alternative 3 would incorporate applicable project design features, including Project Design Feature GHG-PDF-1, which requires achieving LEED Certified Performance level or higher, and Project Design Feature TRAF -PDF-1, which would include implementation of a TDM Program.

GHG emission impacts under Alternative 3, as with the Project, would be less than significant.

Alternative 3, as with the Project, would be consistent with applicable strategies outlined in CARB’s Climate Change Scoping Plan, SCAG’s Socal Connect, Culver City’s Green Building Program. As such, similar to the Project, impacts under Alternative 3 related to conflicts with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs would be less than significant. However, in consideration of Alternative 2’s lower VMT (mobile source) and smaller overall building scale compared to the Project, long -term GHG emissions can be expected to be lower under Alternative 3 than the Project. For this reason, impacts related to GHG emissions would be lower than the Project.

Land Use and Planning
Alternative 3 proposes the development of 223 residential units and 5,600 square feet of retail space in a 56-foot, 5-story building over 1-level of subterranean parking, as compared to 309 residential units and 5,600 square feet of retail space in a 78 -foot, 6 -story (over 2 -levels of subterranean parking) building use on the Project Site. Both the Project and Alternative 3 would include similar discretionary approvals for a General Plan Map Amendment from Regional Center to General Corridor; a Zone Change from Commercial Regional Business Park to Planned Development; and adoption of a Comprehensive Plan for the Project to develop standards for the new PD Zone District. However, Alternative 3 would not seek Density and Other Bonus Incentives (DOBI) to allow increased density with affordable units incorporated into the Project.

As with the Project, the density and location of Alternative 3 would not conflict with policies of regional and local land use plans adopted to avoid or mitigate environmental effects, including:

However, it is acknowledged that the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update includes a draft Land Use Map and Land Use designations with appropriate draft densities. The Project Site’s draft land use designation and density is Mixed-Use High and 100 dwelling units per acre, consistent with the City’s 2021-2029 Housing Element preferred designation and density. Alternative 3 would meet the base density contemplated by the 2021-2029 Housing Element’s preferred designation and density. However, w ith a fewer number of residential units, including no affordable units, Alternative 3 would not meet many of the goals of SoCal Connect and the objective/policies of City’s General Plan that encourage affordable housing and development of diverse housing types in areas that are supported by multiple transportation options to the same extent as the Project . Also, Alternative 3 with less public open

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space and no residential units fronting Buckingham Parkway, would create a less lively pedestrian and streetscape experience as would the Project. Thus, Alternative 3 would not meet pertinent policies that seek to enhance the pedestrian environment and provide the highest quality site design to the same extent as the Project.

Overall, as with the Project, Alternative 3 would not result in a substantial conflict with applicable land use plans, policies, or regulations and land use impacts. However, because Alternative 3 would not meet applicable policies to the same extent as the Project, especially housing policies the strive for increased density with affordable housing included, impacts would be greater than the Project’s less-than-significant land use impacts.

Noise
Substantial Temporary or Permanent Increase in Ambient Noise Levels Construction
Construction activities under Alternative 3 would be similar to those of the Project and would generally include site demolition, site preparation, grading/excavation, drainage/utilities/trenching, foundations/concrete pour, building construction, architectural coating, and paving. Similar to the Project, maximum daily construction activities under Alternative 3 would increase noise levels at several sensitive receptor locations in the vicinity of the Project Site. As with the Project, because the maximum amount of construction equipment operating simultaneously within the Project Site would be constrained by the size of the property, the maximum construction noise levels under Alternative 3 would be similar to the Project. Based on a conservative impact analysis, construction noise levels would exceed the applicable noise significance thresholds at two nearby noise-sensitive receptors. Therefore, as with the Project, Mitigation Measures NOI-MM-1 and NOI-MM-2 would be implemented under Alternative 3 to reduce construction noise impacts at off-site noise-sensitive receptors. However, as with the Project, even with implementation of mitigation measures, potentially significant on-site construction noise impacts would remain significant and unavoidable under Alternative 3 should construction activities occur during the morning hours if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours. With regard to off-site construction noise, the increase in noise levels of construction trips along any of the studied roadway segments would not exceed the significance threshold, and impacts would be less than significant. The overall duration of construction under Alternative 3 would be 3 months less than that of the Project. Therefore, the duration of construction noise would be shorter. As such, impacts related to construction noise under Alternative 3 would be less than the Project.

Operation
Alternative 3, as with the Project, would generate on -site composite noise associated with fixed mechanical equipment noise and parking structure noise. As with the Project, outdoor open space noise would occur from various spaces within the Project Site. Under the Project, operational composite noise levels, with the outdoor open space areas, would not exceed the ambient noise levels by 5 dBA at the nearby noise receptor locations. Because Alternative 3 would have a reduced public open space along Hannum Avenue and outdoor gathering spaces/pool deck compared to the Project, operational noise impacts would be less than the Project’s less-than-significant impacts.

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Further, Alternative 3 would involve a smaller scale project with fewer overall off-site vehicle trips.

Therefore, operational mobile source noise impacts would be incrementally less under Alternative 3 than the Project. Overall, noise impacts under Alternative 3 would be less than the Project.

Vibration
Construction
Construction of Alternative 3 , as with the Project, would generate groundborne construction vibration from the operation of heavy equipment (i.e., backhoe, dozer, excavators, grader, loader, and haul trucks, etc.). As with the Project, the estimated vibration velocity levels from all construction equipment (maximum construction conditions) under Alternative 3 would be below the structural damage and human annoyance significance criteria at off-site building structures and vibration sensitive receptors. In addition, as with the Project, vibration impacts from off -site construction traffic would also be below the vibration significance criteria. Therefore, on -site and off-site vibration impacts would be less than significant. As the overall scale of development would be reduced under Alternative 3, the duration of construction and overall construction activity causing vibration would be less, and impacts under Alternative 3 would be less than the Project.

Operation
Day-to-day operations under Alternative 3, as with the Project, 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 vibration would be passenger vehicle circulation within the proposed parking area. The potential vibration levels from all Project operational sources at the closest existing sensitive receptor locations would be less than the significance threshold. Therefore, similar to the Project, operational vibration impacts under Alternative 3 would be less than significant. While Alternative 3 would decrease occupancy of the Project Site compared to the Project, a change in off-site groundborne operation vibration is not anticipated to be perceptible under Alternative 3 compared to the Project, and, as such, impacts under Alternative 3 would be similar to the Project.

Alternative 3 would generate 529 new residents and 20 employees. Alternative 3 and the Project’s contribution to population and/or employee growth would continue an infill growth pattern that is encouraged locally. Neither Alternative 3 nor the Project would exceed projected SCAG growth forecasts for the City and region. Alternative 3 would be consistent with regional and local policies that encourage mixed-use and higher density housing within the City and region, but to a lesser extent than the Project with fewer units. The Project and Alternative 3’s contribution of housing would help the City’s ability to meet its housing obligation under SCAG’s RHNA and goals of the 2021-2029 Housing Element. Since Alternative 3 would not include any affordable housing units, Alternative 3 would be less consistent with SCAG and City objectives which seek an increase in diverse housing options. However, because Alternative 3 would result in less new residential population as compared to the Project, impacts with respect to induced direct or indirect substantial unplanned population growth would be less than the Project’s less than significant population and housing impacts.

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Public Services
Fire Protection
Construction
Alternative 3, as with the Project, would involve construction activities and intensify the use of the Project Site so that it could increase demand on fire protection and emergency medical services, as well as potentially affect emergency access. As with the Project, Alternative 3 would comply with all regulatory requirements including regulations set forth in the Safety and Health Regulations for Construction established by OSHA and compliance with all applicable federal, state, and local requirements con cerning the handling, disposal, use, storage, and management of hazardous materials. In addition, the Project and Alternative 3 would implement Project Design Feature TRAF-PDF-1 to provide a Construction Management Plan to ensure that adequate and safe access remains available within and near the Project Site during construction activities. The implementation of regulatory requirements and project design features would facilitate emergency access. With such features, neither the Project nor Alternative 3 would increase fire services demand to the extent that the addition of a new fire facility, or the expansion, consolidation, or relocation of an existing facility would be required to maintain service. As such, similar to the Project, construction under Alternative 3 would result in less-than -significant impacts related to fire protection that are similar to the Project.

Operation
During operation, the Project would generate 733 new residents and 20 employees. In comparison, Alternative 3 would generate 529 new residents and 20 employees. Alternative 2, as with the Project, would comply with the applicable OSHA, Building Code, Fire Code, CCMC, and CCFD requirements, including installation of a fire sprinkler suppression system, a fire alarm system, an Emergency Responder Radio Coverage, smoke detectors, and signage, among other fire prevention features. Compliance with applicable requirements under both the Project and Alternative 3 would reduce demand on facilities and equipment without creating the need for new or expanded fire facilities. In addition, both buildings under the Project and Alternative 3 would be required to install an automatic fire sprinkler system. As the Project Site is located within a highly urbanized area accessed via an established street system, impacts on emergency response under the Project or Alternative 3 would not be significant. Alternative 3, as with the Project, would also be consistent with CCFD fire flow requirements. As such, the Project and Alternative 3 would not result in substantial adverse physical impacts associated with the provision of or need for new or altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives.

Impacts under Alternative 3, as with the Project, would be less than significant. However, because Alternative 3 would include a reduced residential population compared to the Project, impacts related to fire protection services under Alternative 3 would be less than the Project.

Police Protection
Construction
Alternative 3, as with the Project, would result in construction activities that could affect emergency access and increase demand for police protection services. As with the Project, Alternative 3’s construction phase, although of shorter duration than that of the Project, could

5. Alternatives

City of Culver City 5-45 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
increase demand for police protection services. To reduce CCPD demand during construction, Alternative 3, as with the Project, would implement security measures under Project Design Feature POL-PDF-1 to limit access to construction areas and provide for cameras to monitor the Project Site during off hours. Similar to the Project, construction activities under Alternative 3 may involve temporary partial lane closures or increase travel time due to flagging or stopping traffic to accommodate trucks entering and exiting the Project Site. As with the Project, Alternative 3 would implement Project Design Feature TRAF-PDF-1. Under Project Design Features TRAF -PDF-1, a Construction Management Plan would ensure that adequate and safe access remains available at the Project Site during construction activities. Furthermore, 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 construction would reduce the potential for incidents that would require police responses. With such features, neither the Project nor Alternative 3 would increase police services demand to the extent that the addition of a new fire facility, or the expansion, consolidation, or relocation of an existing facility would be required to maintain service. Therefore, impacts under Alternative 3 would be less-than-significant and similar to the Project.

Operation
During operation, the Project would generate 733 new residents and 20 employees. In comparison, Alternative 3 would generate 529 new residents and 20 employees. Impacts to police services are based on an increase in the ratio of officers to residential population. Consequently, since Alternative 3 would generate a lower residential population in the CCPD service area, which has a current residential population of approximately 40,000, Alternative 3 would result in an incrementally lower change to the office r per resident service ratios as compared to the Project. As provided in Project Design Feature POL-PDF-2, both the Project and Alternative 3 would incorporate a security program to reduce demand for police services and to ensure the safety of occupants. The security program would reduce the potential for on-site crimes, including loitering, theft, and burglaries and would be reviewed for further suggestions by the CCPD. CCPD correspondence in response to the preparation of the Draft EIR stated that the Project would not result in the need for new or altered police facilities.
10 Given that Alternative 3 have a lower residential population than the Project, the CCPD’s determination is equally applicable to Alternative 3. Thus, neither the Project nor Alternative 3 would result in substantial adverse physical impacts associated with the provision of a new or physically altered police facility, the construction of which would cause significant environmental impacts. Impacts relative to police services would be less than significant under both the Project and Alternative 3. However, because Alternative 3 would reduce the Project’s residential population, impacts to police services would be less than the Project’s less-than-significant impact.

Schools
Construction
Construction under either the Project or Alternative 3 would generate employees who are anticipated to be hired from a mobile regional construction work force. Given the mobility and temporary duration of work at a particular site, construction employees not residing locally would

10 CCPD , Correspondence from Sergeant Carey Grant, Culver City Police Department Admin Sergeant, October 12, 2023. Provided in Appendix H-2 of this Draft EIR.

5. Alternatives

City of Culver City 5-46 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
not be expected to relocate residences (and, therefore, generate a new student population).

Therefore, construction of either the Project or Alternative 3 would not result in a notable increase in the resident population or new students needing to attend local schools. With the nearest public CCUSD school located approximately 0.7 mile northwest of the Project, no public schools would be physically affected by construction activities at the Project Site. Construction impacts on schools under both the Project and Alternative 3 would be less than significant. Impacts on schools under Alternative 3 would be similar to the Project’s less-than-significant impacts.

Operation
Alternative 3 would include 223 units, as compared to the Project’s 309 units. Thus, with an approximate 28 percent decrease in units, there would be similar percentage reduction in students generated under Alternative 3. That is, the Project’s 162 students would be decreased to approximately 117 students generated under Alternative 3. Similar to the Project, under Alternative 3, El Rincon Elementary School, Culver City Middle School, and Culver City High School are conservatively assumed that the Project or Alternative 3 have the potential to result in a new seating shortage at all three schools.

Under either the Project or Alternative 3, pursuant to SB 50, the Project Applicant would be required to pay development fees 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 school impacts. Therefore, neither the Project nor Alternative 3 would result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities and impacts would be less than significant. Because Alternative 3 would result in a lower generation of students, operational impacts on schools would be less than the Project’s less- than-significant impact.

Parks and Recreation
Construction
Construction activities under both the Project and Alternative 3 have the potential to affect parks and recreational facilities. A small number of construction workers may visit public parks to eat lunch or for recreational activity after a workday. However, because construction workers are temporary employees with high turnover during various phases of construction, the use of public parks would be uncommon and short-term. In addition, neither the Project nor Alternative 3 directly impact public park facilities. Construction of either the Project or Alternative 3 would not include or require the construction, alteration, or expansion of recreational facilities that might have an adverse physical effect on the environment. Therefore, Alternative 3’s impacts associated with parks and recreational facilities would be similar to the Project’s less-than-significant impacts.

Operation
Alternative 3 would reduce the Project’s residential component by developing only 223 residential units, as compared to the Project’s 309 residential units. Population increases under both the Project and Alternative 3 would increase demand for parks and recreational facilities. The Project and Alternative 3’s publicly-accessible open space and private, common recreational amenities would fulfill some of the Project and Alternative 3’s demand on park facilities. In addition, through the payment of required in-lieu fees for parks and recreational facilities, the Project and Alternative 3

5. Alternatives

City of Culver City 5-47 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
would be consistent with the CCMC parkland requirements, which require the Applicant to pay fees to offset park- and open space-related impacts of a project. With the required payment of in- lieu fees, both the Project and Alternative 3 would meet CCMC open space and parkland requirements and impacts would be less than significant. As such, similar to the Project, Alternative 3 would not result in significant impacts to parks and recreational facilities. However, since Alternative 3 would generate less resid ential population and therefore result in a lower demand for parkland than under the Project, impacts on parks and recreational facilities would be less than the Project’s less-than-significant impacts.

Transportation
Conflict with Programs, Plans, Ordinances, or Policies Addressing the Circulation System, Transit, Roadways, Bicycle, and Pedestrian Facilities Similar to the Project, Alternative 3 would support multimodal transportation options as well as promote transportation-related safety in the vicinity. Alternative 3, as with the Project, would not conflict with policies or procedures of 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. As with the Pr oject, Alternative 3 would implement Project Design Feature TRAF -PDF-2, which would include implementation of a TDM Program that would help to reduce volumes on nearby roadways due to employee commute and encourage transit ridership through various programs. Similar to the Project, as Alternative 2 would not conflict with any of the policies and procedures contained in the above-mentioned City of Culver City transportation-related programs, plans, ordinances, and policies, impacts relative to plans and programs would be less than significant.

When compared to the Project, impacts related to conflicting with programs, plans, ordinances, and policies, addressing the circulation system under Alternative 3 would be similar to the Project.

Consistency with CEQA Guidelines Section 15064.3, Subdivision (b) Utilizing the City of Culver City VMT Calculator and not accounting for any TDM measures (as was calculated the Project in Section 4.11, Transportation, of this Draft EIR), the VMT for employees under Alternative 3 was calculated.
11 According to the VMT Calculator, Alternative 3
would generate 1,904 daily trips and 7,883 daily VMT. The daily household VMT per capita would be 7.2. Comparatively, the Project would generate 1,462 daily trips and 11,874 VMT. 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. It is assumed that Alternative 3 would implement TDM measures to reduce its VMT to below the household VMT per capita threshold. By doing so, neither the Project nor Alternative 3 would result in VMT impacts that exceed the City’s VMT threshol ds.

Impacts regarding VMT would be consistent with the City’s Transportation Study Criteria and Guidelines and, thus, consistent with CEQA Guidelines Section 15064.3(b). Therefore, VMT impacts under either the Project or Alternative 3 would be less than significant. While Alternative 3 would have a lower daily VMT compared to the Project, the household daily VMT per capita for Alternative 3 would be higher than the Project (without any TDM measures ). Since the City’s transportation goals and policies seek to promote density in areas with available transit and which

11 See Appendix K, Alternatives Documentation, of the Draft EIR for supplemental information regarding trips and VMT for the Project alternatives.

5. Alternatives

City of Culver City 5-48 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
reduce VMT, Alternative 3’s higher household daily VMT per capita is considered to meet the City’s transportation goals and policies relevant to VMT reduction to a lesser extent than the Project. As such, impacts would be greater under Alternative 3 than the Project’s less than significant VMT impact.

Design Hazards
Alternative 3, as with the Project, would design driveways to comply with City of Culver City standards as outlined in the Culver City Municipal Code ( Section 17.320.040). The driveways would be configured to avoid or minimize potential conflicts with transit services and pedestrian traffic by providing curb and sidewalk to separate pedestrian movements from vehicular movements. The Project or Alternative 3 would not substantially increase hazards or conflicts and would contribute to overall walkability through enhancements to the Project Site. As Alternative 3 would generate fewer trips to/from the Project Site, projected queue lengths would similarly not exceed the available storage lengths under Alternative 3. Impacts under Alternative 3 would be less than significant and similar to the Project.

Emergency Access
The Project Site is located within an urbanized area with a fully developed roadway system. Similar to the Project, Alternative 3 would include temporary construction activities (e.g., temporary lane closures) and traffic that could potentially affect emergency access to the Project Site and surroundings. The Project and Alternative 3 would implement Project Design Feature TRAF-PDF- 1, which would require construction staging and construction worker parking to be accommodated on the Project Site, limiting potential conflicts with traffic on local streets. In addition, e mergency 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. In addition, future driveway and building configurations under the Project and Alternative 3 would comply with applicable fire code requirements for emergency evacuation, including proper emergency exits for visitors and employees. Furthermore, pursuant to California Vehicle Code Section 21806, the drivers of emergency vehicles are 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. Therefore, Alternative 3, as with the Project, would not impair implementation of or physically interfere with adopted emergency response or emergency evacuation plans. Impacts regarding emergency access under Alternative 3 would be less than significant and similar to the Project.

5. Alternatives

City of Culver City 5-49 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Mitigation Measure CUL-MM-2 and Mitigation Measures TCR-MM-1 through TCR-MM-3. With implementation of mitigation measures, potentially impacts under the Project and Alternative 3 would be reduced to less-than-significant levels. However, when compared to the Project, because the depth and extent of excavation would be less under Alternative 3, impacts related to tribal cultural resources under Alternative 3 would be less than the Project.

Utilities and Service Systems
Water Supply
New or Expanded Water Facilities
Under Alternative 3, while construction duration would be reduced as compared to the Project, construction water use would be similar on a daily basis. 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, the existing water infrastructure would meet the limited and temporary water demand associated with construction of the Project or Alternative 3.

Water service for the Project or Alternative 3 would be provided by GSWC, as under existing conditions. When analyzing infrastructure capacity, although domestic water demand is the 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. The existing hydrants in the area of the Project Site would provide adequate fire flow meeting the requirements of CCFD for the Project. Given the relatively smaller size of the propo sed building under Alternative 3 as compared to the Project, it can be expected that the existing hydrants serving the Project Site would also be able to provide adequate fire flow for Alternative 3. As such, operation of the Project or Alternative 3 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 and impacts would be less than significant. When compared to the Project, impacts related to new for expanded water facilities under Alternative 3 would be similar to the Project.

Water Supplies
While construction duration would be reduced under Alternative 3 as compared to the Project, the estimated construction daily 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, the existing water supplies would be available to meet the temporary water demand associated with construction of the Project.

Similar to the Project, Alternative 3 would not meet the minimum threshold criteria to require the preparation of a WSA per SB 610. Both the Project and Alternative 3 would increase long -term water demand for consumption, operational uses, maintenance, and other activities on the Project Site. Net domestic water demand (subtracting existing demand) for the Project would be 36,446 gpd, or 41 AFY. As shown Table 5-4, Alternative 3 Estimated Water Consumption, Alternative 3 would have a water demand of 31,674 gpd day. Subtracting the existing 7,360 gpd, the net water demand would be approximately 24,314 gpd or 27 AFY.

5. Alternatives

City of Culver City 5-50 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-4
ALTERNATIVE 3 ESTIMATED WATER CONSUMPTION
Proposed Use Units Water Use Rate a
Water Usage b
gpd AFY
Studio 29 units 75/unit 26,115 29
1 Bed 129 units 110/unit
2 Bed 65 units 150/unit
Commercial 5,600 sf 50/1,000 sf 280 0.3
Irrigation b — — 5,279 6
Total Proposed Water Demand 31,674 35
Existing Site Demand -7,360 -8
Total Net Water Demand 24,314 27
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: ESA, 2024.

Both the Project and Alternative 3 would be consistent with the demographic projections for the City in SCAG’s SoCal Connect and, as such, the GSWC has sufficient water supplies as projected in its latest UWMP to serve the Project and Alternative 3 and the reasonably foreseeable future development during normal, dry, and multiple -dry years. Impacts regarding water supply during operation would be less than significant under both the Project and Alternative 3. However, because Alternative 3 would reduce overall water demand compared to the Project, Alternative 3’s impacts would be less than the Project’s less-than-significant water impacts.

Electric Power, Natural Gas, Telecommunications Facilities Alternative 3, as with the Project, would utilize energy infrastructure to accommodate their respective demand for energy resources. Similar to the Project, Alternative 3’s electricity and natural gas demands are expected to represent a small fraction of SCE and SoCalGas energy supplies and the service provider’s existing infrastructure. Planned electricity and natural gas supplies would be sufficient to meet the Project’s or Alternative 3’s demand for electricity and natural gas. As with the Project, Alternative 3 would not result in an increase in demand for electricity, or natural gas, services that exceeds available supply or distribution infrastructure capabilities that could result in the construction of new facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Similar to the Project, impacts with respect to the relocation or expansion of electric power or natural gas infrastructure under Alternative 3 would be less than significant. As off-site electric power and natural gas infrastructure would accommodate demand under Alternative 3, impacts would be similar to the Project.

Relationship of the Alternative to Project Objectives
As described above, under Alternative 3, the Project would see a 28 percent reduction in residential units (density) by reducing the Project’s 309 units to 223 units. Under Alternative 3, there would be no affordable units provided and as such, the Project’s Density Bonus incentives related to additional units and building height would not be applicable to Alternative 3. Alternative 3 would

5. Alternatives

City of Culver City 5-51 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
include the same 5,600 square feet of retail floor space as the Project. The building height would be 5-stories (over 1 -level of subterranean parking) or 56 feet under Alternative 3. Publicly accessible open space on the ground level along Hannum would be reduced under Alternative 3 from 7,507 square feet under the Project to 2,500 square feet.

Alternative 3 would fully meet the following Project Objective similar to the Project:

Alternative 3 would meet the below Project Objectives, but to a lesser extent than the Project, since it would provide less landscape features, public open space and active ground floor uses with open space amenities, including no ground level housing units along Buckingham Parkway.

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.

While Alternative 3 would provide residential and retail uses similar the Project, it would not include affordable units and would provide these uses within a reduced building size and reduced residential occupancy. As such, Alternative 3 would partially meet the following Project Objectives:

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

Alternative 3 would not meet the following objectives:

5. Alternatives

City of Culver City 5-52 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

5.6 Environmentally Superior Alternative
CEQA Guidelines Section 15126.6(e)(2) indicates that an analysis of alternatives to a proposed project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR and that if the “no project” alternative is the environmentally superior alternative, the EIR shall identify another environmentally superior alternative among the remaining alternatives.

Selection of an environmentally superior alternative is based on comparison of the alternatives to determine which among the alternatives would reduce or eliminate the impacts associated with the Project to the greatest degree. The comparative impacts of the Project and the Project alternatives are summarized in Table 5-5, Comparison of the Impacts of the Project and Alternatives , below.

In addition, Table 5-6, Ability of Alternatives to Meet Project Objectives, is also provided to show a comparison of the ability of the analyzed alternatives to meet Project Objectives.

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

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

Alternative 2, the Existing Zoning Alternative, and Alternative 3, the Reduced Project Alternative, would both involve less development compared to the Project, and both alternatives would reduce, but not eliminate, the Project’s significant unavoidable im pacts related to Project -level on -site construction noise. As shown in Table 5-5, Alternative 2 would result in four (4) “greater” impacts (Operational regional emissions, Consumption of Energy Resources, GHG, and Transportation - VMT) for the issue areas analyzed compared to the Project, and 16 “less” impacts compared to the Project. Alternative 3 would result in two (2) “greater” impacts (Land Use and Transportation-VMT) for the issue areas analyzed compared to the Project, and 21 “less” impacts compared to the Project.

Alternative 3 is considered the environmentally superior alternative, as it would reduce the magnitude of overall impacts compared to the Project to a greater extent than Alternative 2 since it would require less building construction and result in reduced residential occupancy at the Project Site.

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

5. Alternatives

City of Culver City 5-53 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-5

COMPARISON OF IMPACTS ASSOCIATED WITH THE ALTERNATIVES AND THE PROJECT Use or Feature Project
Alternative 1:

No Project/No Build Alternative
Alternative 2:

Existing Zoning Alternative
Alternative 3:

Reduced Project Alternative
Aesthetics
Regulations Governing Scenic Quality Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Air Quality
Consistency or Conflict with Air Quality
Management Plan
Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Cumulatively Considerable Increase of
Criteria Pollutants in Nonattainment Area

Construction Less than Significant Less (No Impact) Less (Less Than Significant) Less (Less than Significant) Operation Less than Significant Less (No Impact) Greater (Less Than Significant) Less (Less than Significant) Sensitive Receptor Exposure To Pollutant
Concentrations

Construction – Localized
Emissions
Less Than Significant Less (No Impact) Less (Less Than Significant) Less (Less than Significant) Operation – Localized Emissions Less than Significant Less (No Impact) Less (Less Than Significant) Less (Less than Significant) Carbon Monoxide Hotspots Less than Significant Less (No Impact) Less (Less Than Significant) Less (Less than Significant) Construction– Toxic Air
Contaminates
Less Than Significant with
Mitigation (Project-level and
Cumulative)
Less (No Impact) Less (Less Than Significant
with Mitigation)
Less (Less Than Significant with
Mitigation)
Operation – Toxic Air
Contaminates
Less than Significant Less (No Impact) Similar (Less Than Significant) Similar (Less Than Significant) Cultural Resources
Archaeological Resources Less than Significant with
Mitigation
Less (No Impact) Similar (Less than Significant
with Mitigation)
Less (Less than Significant with
Mitigation)
Energy
Wasteful, Inefficient, and Unnecessary
Consumption of Energy Resources
Less than Significant Less (No Impact) Greater (Less than Significant) Less (Less than Significant) Conflict or Obstruct a State or Local Plan
for Renewable Energy or Energy
Efficiency
Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant)

5. Alternatives

City of Culver City 5-54 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-5

COMPARISON OF IMPACTS ASSOCIATED WITH THE ALTERNATIVES AND THE PROJECT Use or Feature Project
Alternative 1:

No Project/No Build Alternative
Alternative 2:

Existing Zoning Alternative
Alternative 3:

Reduced Project Alternative
Geology and Soils
Paleontological Resources Less than Significant with
Mitigation
Less (No Impact) Similar (Less than Significant
with Mitigation)
Less (Less than Significant with
Mitigation)
Greenhouse Gas Emissions
GHG Emissions/ Conflict with any
Applicable Plan, Policy or Regulation
Adopted for the Purpose of Reducing the
Emissions of GHGs
Less than Significant Less (No Impact) Greater (Less than Significant) Less (Less than Significant) Land Use and Planning
Conflict with any Applicable Land Use
Plan, Policy, or Regulation Adopted for
the Purpose of Avoiding or Mitigating an
Environmental Effect
Less than Significant Less (No Impact) Less (Less than Significant) Greater (Less than Significant) Noise
Substantial Temporary or Permanent
Increase in Ambient Noise Levels

Construction – On Site Significant and Unavoidable
with Mitigation
Less (No Impact) Less (Significant and
Unavoidable with Mitigation)
Less (Significant and
Unavoidable with Mitigation)
Construction – Off-Site (Mobile Source) Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Operation – On-Site Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Operation – Off-Site Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Vibration
Construction Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Operation Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less Significant) Population and Housing
Induce Substantial Unplanned Population
Growth
Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant)

5. Alternatives

City of Culver City 5-55 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-5

COMPARISON OF IMPACTS ASSOCIATED WITH THE ALTERNATIVES AND THE PROJECT Use or Feature Project
Alternative 1:

No Project/No Build Alternative
Alternative 2:

Existing Zoning Alternative
Alternative 3:

Reduced Project Alternative
Public Services
Fire Protection
Construction Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Operation Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Police Protection
Construction Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Operation Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Schools
Construction Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Operation Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Parks and Recreation
Construction Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Operation Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Transportation
Conflict with Programs, Plans,
Ordinances or Policies Addressing the
Circulation System, Transit, Roadways,
Bicycle and Pedestrian Facilities
Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Consistency with CEQA Guidelines
Section 15064.3, Subdivision (b)
Less than Significant Less (No Impact) Greater (Less than Significant) Greater (Less than Significant) Geometric Design Hazards Less than Significant Less (No Impact) Similar (Less Than Significant) Similar (Less Than Significant) Emergency Access Less than Significant Less (No Impact) Similar (Less than Significant) Less (Less than Significant) Tribal Cultural Resources
Tribal Cultural Resources Less than Significant with
Mitigation
Less (No Impact) Similar (Less than Significant
with Mitigation)
Less (Less than Significant with
Mitigation)

5. Alternatives

City of Culver City 5-56 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-5

COMPARISON OF IMPACTS ASSOCIATED WITH THE ALTERNATIVES AND THE PROJECT Use or Feature Project
Alternative 1:

No Project/No Build Alternative
Alternative 2:

Existing Zoning Alternative
Alternative 3:

Reduced Project Alternative
Utilities and Infrastructure
Water Supply
Water Infrastructure Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) Water Supply Less than Significant Less (No Impact) Less (Less than Significant) Less (Less than Significant) Electric Power, Natural Gas, and
Telecommunications Facilities

Electric Power, Natural Gas, And
Telecommunications Infrastructure
Less than Significant Less (No Impact) Similar (Less than Significant) Similar (Less than Significant) SOURCE: ESA. 2024

5. Alternatives

City of Culver City 5-57 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 5-6

ABILITY OF ALTERNATIVES TO MEET PROJECT OBJECTIVES
Project
Alternative 1:

No Project/No
Build Alternative
Alternative 2: Existing
Zoning Alternative
Alternative 3: Reduced
Project Alternative

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

Fully Meets
Objective
Does Not Meet
Objective
Does Not Meet Objective Partially Meets Objective

Fully Meets
Objective
Does Not Meet
Objective
Does Not Meet Objective Does Not Meet Objective

Fully Meets
Objective
Does Not Meet
Objective
Does Not Meet Objective Meets Objective (to a
lesser extent than the
Project)

Fully Meets
Objective
Does not Meet
Objective
Does Not Meet Objective Meets Objective (to a
lesser extent than the
Project)

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.

Fully Meets
Objective
Does not Meet
Objective
Does Not Meet Objective Meets Objective (to a
lesser extent than the
Project)

Fully Meets
Objective
Does not Meet
Objective
Does Not Meet Objective Does Not Meet Objective

Fully Meets
Objective
Does Not Meet
Objective
Partially Meets Objective
(to a lesser extent than
the Project)
Meets Objective (to a
lesser extent than the
Project)

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.

Fully Meets
Objective
Does Not Meet
Objective
Fully Meets Objective
(Similar to Project)
Fully Meets Objective
(Similar to Project)
SOURCE: ESA, 2024.

5. Alternatives

City of Culver City 5-58 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

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City of Culver City 6-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 6
Other CEQA Considerations
This section summarizes the findings of the Draft EIR with respect to : significant unavoidable environmental impacts; reasons why the Project is being proposed, notwithstanding significant unavoidable impacts; irreversible environmental changes; growth inducing impacts; potential secondary effects related to Project mitigation measures; and effects found to be less than significant.

6.1 Significant Unavoidable Impacts
CEQA Guidelines Section 15126.2(a) requires that an EIR describe significant environmental impacts of a project on the environment. Direct and indirect significant effects shall be clearly identified and described, giving due consideration to short-term and long-term effects. As evaluated in Section 4.8, Noise, of this Draft EIR, and summarized below, implementation of the Project would result in significant impacts that cannot be mitigated with respect to Project-level on-site construction noise impacts.

Implementation of Mitigation Measures MM-NOI-1 (Sound Walls) and MM-NOI-2 (Construction Practices) would reduce the Project’s on-site construction noise impacts at the off-site ground-level noise sensitive receptors, to the extent technically feasible. 1 With implementation of Mitigation
Measures MM-NOI-1 and MM-NOI-2, the construction noise levels at all receptor locations would be reduced below the 5-dBA significance threshold. Therefore, with implementation of mitigation measures MM-NOI-1 and MM-NOI-2, impacts from on-site construction noise would be less than significant with approval of an extended hours construction permit. However, construction during off-hours (between 7:00 a.m. and 8:00 a.m. Monday to Friday and 7:00 a.m. to 9:00 a.m. Saturday) 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.

6.2 Reasons Why the Project Is Being Proposed,
Notwithstanding Significant Unavoidable Impacts
In addition to identification of the Project’s significant unavoidable construction-related noise impact, Section 15126.2(c) of the State CEQA Guidelines also requires a description of the reasons why a project is being proposed, notwithstanding significant unavoidable impacts associated with a project.

1 Technical infeasibility means 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.

6. Other CEQA Considerations

City of Culver City 6-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
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 residential component would help the City meet its housing needs established in the Southern California Associate of Governments (SCAG) Regional Housing Needs Assessment (RHNA). The Project would improve 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.

The 2021-2029 Housing Element indicated that the total housing growth need for the City during the 2021-2029 planning period is 3,341 units. Under the approved Housing Element, the Project Site is designated as Mixed -Use High. Per the City’s 2021 -2029 Housing Element, Mixed -Use High land uses are permitted to develop up to 100 units per acre. The Project’s 309 residential units, including affordable housing, would be consistent with the City’s Housing Element objectives and policies that seek to expand the City’s housing supply with a diverse range of housing options.

The Project would support the growth of the City’s economic base by creating jobs during both Project construction and operation of the Project. The Project would also create commercial opportunities that could serve local employees, generate local tax revenues, and provide new permanent jobs and housing for residents in support of local businesses.

The Project would 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 s etbacks, light materiality, landscape features, and active ground floor uses with open space amenities. The Project’s mix of commercial and residential uses would activate the Hannum Avenue and Buckingham Parkway frontages by providing street -oriented retail and residential uses. The Project’s open space amenities would 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.

Furthermore, the Project’s mix of uses would support policies that aim to reduce vehicle trips and vehicle miles traveled . As described in the 4.11, Transportation, of this Draft EIR, the Project proposes a CCMC Section 7.05.015 required Transportation Demand Management ( TDM) Program as described in Project Design Feature TRAF -PDF-2. The Project’s TDM Program (TRAF-PDF-2) includes TDM measures to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The Project's TDM Program (TR AF-PDF-2) includes a comprehensive program of measures, design features, transportation services, education programs, and incentives intended to reduce the effect of Project traffic from residents, employees, and visitors to the Project Site during the most congested time periods of the day. The TDM measures include the following:

Transportation Information Center (TIC); Bicycle Parking and Amenities, which includes 92 bicycle parking spaces (11 short -term and 81 long-term spaces), as required by CMCC Section

7.05.015; Pedestrian-Friendly Environment; Employee Parking; Bus Stop Improvements.

6. Other CEQA Considerations

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Additional TDM strategies that may be offered by the Project to further reduce VMT and reliance on single-passenger vehicles, and help future residents and employees manage each TDM element and maximize program participation include: Project Transportation Coordinator; Transportation Information Packet for New Residents and Employees; and Bike Repair Station (see Section 4.11, Transportation, of this Draft EIR for a detailed explanation of all TDM measures contained in TRAF-PDF-2). Thus, the Project would implement strategies and action plans as part of a comprehensive TDM Program (TRAF -PDF-2) in compliance with the requirements set forth in CCMC Section 07.05.015 to reduce single occupancy vehicle trips while promoting the use of alternative transportation modes, thereby reducing Project VMT.

The project would also meet or exceed applicable requirements of Title 24 California Code of Regulations as well as electricity requirements in the 2022 Building Efficiency Standards which encourage efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, and strengthens ventilation s tandards.

The Project would be designed with Project Design Feature GHG-PDF-1 and be required to comply with the Culver City Green Building Program and ordinances where the Project would achieve the USGBC LEED certified performance level or higher to improve building energy efficiency, and design features would include energy conservation, water conservation, TDM and mobility measures, and pedestrian- and bicycle-friendly site design. Also, as part of Project Design Feature GHG-PDF-1, the Project would directly support building electrification as the Project will utilize only electricity and no natural gas in all land uses except for the retail space. While building electrification would result in higher electricity usage, it would greatly reduce the use of a fossil fuel and the associated GHG emissions (i.e., natural gas combustion) from building energy demand since only the retail space still uses natural gas. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready. The Project would include 92 bicycle spaces, consisting of 11 short-term and 81 long-term bicycle parking spaces. As it also relates to energy conservation, the Project would include LED lighting throughout the Project Site and would install ENERGY STAR- rated appliances. As it relates to water conservation, the Project would incorporate efficient water management through low flow fauce ts and water -efficient landscape design with weather -based controllers and drip irrigation systems.

The Project would use tree landscaping to create passive solar shading and would use cool roof/pavement coatings to reduce an urban heat island effect. The Project would also comply with applicable solar installation regulatory requirements. The Project will focus on occupant wellness by incorporating healthy materials with low -volatile organic compounds (VOCs), abundant daylight, superior interior lighting quality, and accessible thermal comfort control to prevent sick building syndrome. Other building features would include such items as installation of energy- efficient heating, ventilation, and air conditioning (HVAC) systems that utilize ozone -friendly refrigerants; and dedicated on -site recycling areas. The Project will also incorporate indoor air quality best practices to provide clean ventilation for improved breathing.

For all the reasons stated above, the Project is being proposed notwithstanding its significant unavoidable impacts. It should also be noted that the Project’s significant and unavoidable noise impacts are associated with temporary and periodic construction activities, similar to those occurring

6. Other CEQA Considerations

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at development sites in urban areas, particularly within infill locations. Furthermore, should the project’s Approval for Extended Hours of Construction be granted by the City, it can be anticipated that the Project’s significant and unavoidable construction noise impacts would not occur.

6.3 Irreversible Environmental Changes
According to CEQA Guidelines Sections 15126(c) and 15126.2(c) , an EIR is required to address any significant irreversible environmental changes that would occur should the proposed Project be implemented:

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

The Project would necessarily consume limited, slowly renewable and non -renewable resources.

This consumption would occur during the construction phase of the Project and would continue throughout its operational lifetime. Project development would require a commitment of resources that would include: (1) building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the Project Site. Project construction would require the consumption of resources that are non-replenishable or may renew so slowly as to be considered non-renewable. These resources would include the following construction supplies: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics; and water. Furthermore, nonrenewable fossil fuels such as gasoline and diesel would also be consumed in the use of construction vehicles and equipment, as well as the transportation of goods and people to and from the Project Site. As stated in Section 4. 4, Energy, of this Draft EIR, Project construction would utilize energy for necessary on-site activities and to transport construction materials, excavated fill, and demolition debris to and from the Project Site. Project construction would implement idling restrictions and the use of cleaner, energy-efficient equipment would result in less fuel combustion and energy consumption and thus reduce the Project’s construction-related energy use.

Project operation would continue to expend nonrenewable resources that are currently consumed within the City. These include energy resources such as electricity and natural gas, petroleum-based fuels required for vehicle -trips, fossil fuels, and water. Fossil fuels would represent the primary energy source associated with both construction and ongoing operation of the Project, and the existing, finite supplies of these natural resources would be incrementally reduced. As discussed in Section 4.4, Energy, of this Draft EIR, buildout of the Project would result in an increase in on-site demand for electricity, natural gas, and transportation energy (e.g., petroleum -based fuels related to vehicular travel). Electricity and natural gas usage during Project operations would be minimized through incorporation of applicable Title 24 standards, applicable CALGreen Building Code

6. Other CEQA Considerations

City of Culver City 6-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
requirements, and Culver City’s Green Building Code. Furthermore, as noted above, the Project incorporates energy-conservation measures that would achieve LEED rating system at a "certified" performance level or higher and would include all -electric development for all land uses except retail (refer to Project Design Feature GHG-PDF -1). The Project would implement PV solar in compliance with the City’s Green Building Program which, at a minimum requires 1 kW of solar for every 10,000 square feet. The Project would include, but would not be limited to, water-efficient landscape design, rainwater management systems, high-efficiency plumbing fixtures and weather- based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; EV charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star –labeled appliances, where possible; energy-efficient and water conserving HVAC systems; and active circulation. Additionally, in accordance with Chapter

17.320.035 of the Culver City Municipal Code ( CCMC), the City requires at least 20 percent EV capable parking spaces, 10 percent EV-ready parking spaces, and 10 percent EV charging stations for both new residential and retail developments. The Project would be required to and would provide a minimum of 86 EV capable spaces, 44 EV-ready spaces, and 44 spaces which would have full EV chargers and stations. Therefore, while the Project would result in a net increase in energy demand, the Project would be consistent with energy efficiency policies from the City, region, and State, and would also incorporate its own energy conservation measures to reduce energy usage.

Also, as analyzed in Section 4.3, Energy, the Project would result in a less-than-significant energy impacts due to wasteful, inefficient, and unnecessary consumption of energy resources during construction or operation. The Project’s energy requirements would not significantly affect local and r egional supplies or capacity. The Project’s electricity and natural gas usage would be consistent with future usage projections for the region. Electricity generation capacity and supplies of natural gas as well as transportation fuels would be sufficient to meet the needs of the Project construction and operational activities. Construction of the Project would utilize fuel -efficient trucks and equipment consistent with federal and State regulations, such as fuel eff iciency regulations in accordance with CARB’s Pavley Phase I and II standards (at a minimum through the model year 2020 standards depending on the outcome of the SAFE Vehicles Rule court challenge), the anti-idling regulation in accordance with CCR, Title 13, Section 2485, and fuel requirements in accordance with CCR, Title 17, Section 93115, as well as the In-Use Off-Road Diesel-Fueled Fleets regulation. The Project would also comply with Title 24 standards and applicable CALGreen Building Code requirements.

In addition, the Project would be consistent with the State’s Assembly Bill (AB) 32 GHG reduction target and would result in a less-than-significant impact with respect to consistency with applicable plans, policies, or regulations to reduce GHG emissions (see Section 4.6, Greenhouse Gas Emissions). The Project would not conflict with applicable strategies outlined in CARB’s Climate Change Scoping Plan, SCAG’s 2020–2045 RTP/SCS, and Culver City’s Green Building Program.

Continued use of such non-renewable resources would be on a relatively small scale and consistent with regional and local growth forecasts in the area, as well as State and local goals for reductions in the consumption of such resources. Furthermore, the Project would not affect access to existing resources, nor interfere with the production or delivery of such resources. The Project Site is

6. Other CEQA Considerations

City of Culver City 6-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
currently developed and contains no known energy resources that would be precluded from future use through Project implementation. Based on the above, the Project’s irreversible changes to the environment related to the consumption of nonrenewable resources would not be significant.

6.4 Growth- Inducing Impacts
CEQA Guidelines Section 15126.2(d) requires an EIR to discuss the ways a proposed project could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. Growth-inducing impacts include the removal of obstacles to population growth (e.g., the expansion of a wastewater treatment plant allowing more development in a service area) and the development and construction of new service facilities that could significantly affect the environment individually or cumulatively. In addition, pursuant to CEQA, growth must not be assumed as beneficial, detrimental, or of little significance to the environment.

The Project is located on land currently developed with office uses in a highly urbanized area that is well served by existing infrastructure. The Project would demolish the existing office uses (30,672 square feet [sf]) on the Project Site and develop 309 residential units and 5,600 sf of retail space, resulting in an increase of 497,767 sf in developed floor area on the Project Site. As discussed in Section 4.9, Population and Housing, of this Draft EIR, the Project would result in 733 new residents and 20 new employees and its contribution to population, housing, and employment compared to the growth projections for the City in SCAG’s 6
th Cycle Regional Housing Needs Assessment (RHNA)
and the 2020-2045 RTP/SCS for both the Project’s fully operational year (2027) and the 2020-2045 RTP/SCS horizon year (2045), would not result insubstantial induced population growth in the area directly thr ough new housing and employment . The Project ’s residential development would represent a portion of the City’s housing share of the RHNA approved by SCAG for the period through 2021 and 2029. Therefore, the Project would not generate growth beyond the range of development anticipated within the established SCAG regional forecast for the City . Rather than being unplanned, the Project’s growth in population, housing, and employment would align with infill development priorities near available transit options consistent with State, regional, and local policies.

As such, the potential for physical impacts on the environment due to unplanned population, housing, and employment growth would be less than significant.

The Project would develop residential and commercial uses, located in proximity to existing public transit, including proximity to the Culver City Transit Center (approximately 0.6 miles east) which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity of the site include Culver City Bus Line 5C2 – Overland/Fox Hills, which includes Stop 306 Hannum Ave/Buckingham Parkway, approximately 210 feet west of the Project Site. Therefore, the Project would concentrate employment growth in an area well -served by regional and local bus lines. As such, the Project would be consistent with SCAG’s 2020-2045 RTP/SCS policies for the concentration of growth in proximity to transit.

The Project would not have indirect effects on growth through such mechanisms as the extension of roads and infrastructure, since the infill Project is located in an urbanized area that is served by current infrastructure (e.g., roads and utilities), and community service facilities. As further

6. Other CEQA Considerations

City of Culver City 6-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
described in Section 4.11 Transportation; Section 4.13.1, Utilities and Service Systems – Water Supply in the Project’s Initial Study (see Appendix A of this Draft EIR), the Project’s off -site infrastructure improvements would consist of tie-ins to or local upgrades of the existing utility mainlines already serving the Project area. Therefore, the Project would not include the construction of off-site infrastructure that would induce substantial growth and development in new areas. In addition, as further described in Section 4.10.1, Public Services - Fire Protection; Section

4.10.2; Public Services - Police Protection; Section 4.10. 3, Public Services - Schools; Section

4.10.4, Public Services - Parks and Recreation, of this Draft EIR, the Project would not require the construction of new public services facilities that would impact the environment.

The Project’s contribution to growth would also not be cumulatively considerable. As further evaluated in Section 4.9, Population and Housing, of this Draft EIR, related projects considered in association with the Project also represent infill development that would be served by available infrastructure and would result in growth falling within projected growth forecasts for the City and the region.

Overall, based on the above, as the Project would represent infill development and growth within the range of development anticipated in regional and local plans, and as the Project Site is well served by existing infrastructure, it would not remove obstacles to growth or induce unplanned growth beyond that associated with the Project that would requir e development and construction of new service facilities that would significantly affect the environment individually or cumulatively.

6.5 Potential Secondary Effects Related to Project
Mitigation Measures
CEQA Guidelines Section 15126.4(a)(1)(D) requires that if a mitigation measure proposed to address the significant effects of the Project would cause one or more significant effects in addition to those caused by the Project, the effects of the mitigation measure shall be discussed but in less detail than the significant effects of the Project . Accordingly, the mitigation measures proposed to address significant Project impacts were evaluated to determine if significant secondary impacts associated with their implementation would occur. The following provides a discussion of the subject areas in which mitigation measures are required, as well as any potential secondary significant effects that could occur as a result of their implementation. For the reasons stated below, implementation of the Project’s mitigation measures would not result in significant secondary impacts.

6.5.1 Air Quality
Mitigation Measure AQ- MM-1 requires the Applicant to maintain construction equipment to reduce exhaust emissions and to utilize equipment that meets USEPA Tier 4 Final off -road emissions standards or equivalent for equipment . Mitigation Measure AQ-1 also requires the u se electrified tower cranes in place of diesel-fueled equipment. This mitigation measure for air quality would implement emissions control strategies that would reduce impacts to less-than -significant levels. As this mitigation measure includes control strategies for different construction equipment that the Applicant would use or install, no further impacts would occur with its implementation.

6. Other CEQA Considerations

City of Culver City 6-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Therefore, the mitigation measure for air quality would not result in significant secondary impacts on the environment.

6.5.2 Cultural Resources – Archaeological Resources
Mitigation Measures ARCH-1 through ARCH-3 establish protections for archaeological resources and tribal cultural resources through monitoring plans to identify such resources should they be uncovered during construction at the Project Site . These measures also include treatment and reporting of resources should they be encountered. The mitigation measures en sure that resources would be treated consistent with CEQA Guidelines and regulatory provisions for the protection of these resources. The actions required for monitoring and t reatment of resources if they are encountered would not require additional disturbance on the Projec t Site or cause changes in the physical environment that would result in significant secondary impacts on the environment.

6.5.3 Geology and Soils – Paleontological Resources
Mitigation Measures GEO -1 through GEO-4 establish protections for paleontological resources through identification, treatment, and preservation of such resources should they be discovered on the Project Site. These measures include treatment and reporting of resources should they be encountered.

The mitigation measures ensure that resources would be treated consistent with CEQA Guidelines and regulatory provisions for the protection of these resources. Similar to the mitigation of archaeological resources described above, the activities involved with m onitoring, treatment, and reporting would not require additional disturbance on the Project Site or cause changes in the physical environment that would result in significant secondary impacts on the environment.

6.5.4 Noise
Implementation of Mitigation Measure NOI-1 would reduce construction noise through provision of temporary 6 to 15-foot-tall construction noise barriers. The construction fence would be temporary, but would result in less than significant aesthetics impact s, which would be secondary and also temporary in nature. Once construction is completed, the construction noise barriers would be removed. As such, Mitigation Measure NOI -1 would not result in significant secondary impacts.

Implementation of Mitigation Mea sure NOI -2 includes construction practices and strategies to minimize construction noise such as ensuring equipment is operating in good operating condition according to manufacturer specifications and use of proper noise mufflers. Mitigation Measure NOI- 2 would be a control strategy for construction equipment and activities that the Applicant would implement or install, thus no further impacts would occur with this mitigation implementation.

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

6.5.5 Tribal Cultural Resources
Mitigation Measure TCR-MM-1 requires retention of a Native American Monitor, the provisions of a Tribal Cultural Resources Sensitivity Training session, and Native American monitoring.

Mitigation Measure TCR -MM-2 requires completion of daily monitoring logs and Mitigation Measure TCR-MM-3 provides for provisions in the event of a discovery of potential tribal cultural resources. The mitigation measures ensure that resources would be treated consistent with CEQA

6. Other CEQA Considerations

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Guidelines and regulatory provisions for the protection of these resources. The actions required for monitoring and treatment of resources if they are encountered would not require additional disturbance on the Project Site or cause changes in the physical environment that would result in significant secondary impacts on the environment.

6.6 Impacts Found Not to Be Significant
CEQA Guidelines Section 15128 states that an EIR shall contain a brief statement indicating reasons that various possible significant effects of a Project were determined not to be significant and were not discussed in detail in the Draft EIR. The Initial Study, provided in Appendix A -2 of the Draft EIR, supports findings that the Project would result in less than significant impacts related to Agriculture and Forestry Resources; Air Quality ( odors); B iological Resources; Cultural Resources (historic resources and human r emains); Geology and Soils ( all subtopics except for paleontological resources); Hazards and Hazardous Materials; Hydrology and Water Quality; Land Use and Planning ( physical division of an established community ); Mineral Resources; Noise (airport noise), Population and Housing (displacement); Public Services (other public facilities); Utilities and Service Systems (wastewater and solid waste); and Wildfire. As such, the Initial Study concluded that these issues would not be evaluated further in the Draft EIR in accordance with CEQA Guidelines Section 15063(c)(3)(A). For further discussion of these issues and more detailed evaluation of potential impacts found not to be significant refer to the Initia l Study provided in Appendix A-2 of this Draft EIR.

6. Other CEQA Considerations

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City of Culver City 7-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 7
References

4.1 Aesthetics
Banker’s Hill, Hillcrest, Park West Community Preservation Group v. City of San Diego, 139 Cal.App. 4th 249, 279 (2006).

California Department of Transportation (CA, California State Scenic Highway System Map – ArcGIS Online,
https://www.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f 1aacaa. Accessed July 6, 2022.

City of Los Angeles, L.A. CEQA Thresholds Guide, Exhibit A.3-1, 2006.

City of Los Angeles Department of City Planning, General Plan Conservation Element.

Originally adopted September 26, 2001.

City of Los Angeles Department of City Planning, General Plan Framework Element, originally adopted December 11, 1996 and readopted August 8, 2001.

City of Los Angeles Department of City Planning, General Plan Framework Element, Chapter 5, originally adopted December 11, 1996 and readopted August 8, 2001.

City of Los Angeles Department of City Planning, General Plan Framework, Executive Summary, originally adopted December 11, 1996 and readopted August 8, 2001.

4.2 A ir Quality
42 United States Code Section 7401 et seq. (1970).

SCAG 2016–2040 RTP/SCS Final Growth Forecast by Jurisdiction.

California Air Resources Board (CARB), Hydrogen Sulfide & Health, https://ww2.arb.ca.gov/resources/hydrogen-sulfide-and-health. Accessed on July 8, 2022.

CARB, Vinyl Chloride & Health, https://ww2.arb.ca.gov/resources/vinyl-chloride-and-health.

Accessed July 8, 2022.

CARB, Visibility-Reducing Particles & Health. Last reviewed July 8, 2022.

City of Culver City, Culver City General Plan, Circulation Element, 1995.

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

7. References

City of Culver City 7-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Los Angeles, L.A. CEQA Thresholds Guide, 2006.

City of Los Angeles, Plan for a Healthy Los Angeles, 2021.

Fehr & Peers, Crossings Campus Project Transportation Impact Study, Appendix D, July 2022.

San Joaquin Valley Air Pollution Control District (SJVAPCD), Application for Leave to File Brief of Amicus Curiae Brief of San Joaquin Valley Unified Air Pollution Control District in Support of Defendant and Respondent, County of Fresno and Real Party In Interest and Respondent, Friant Ranch, L.P. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno v. County of Fresno, Filed April 13, 2015.

SCAG, Final 2016 RTP/SCS, 2016, https://scag.ca.gov/resources-prior-plans. Accessed July 8, 2022.

SCAQMD Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, 2005.

SCAQMD, Air Quality Analysis Guidance, http://www.aqmd.gov/home/rules- compliance/ceqa/air-quality-analysis-handbook#. Accessed July 8, 2022.

SCAQMD, Air Quality Significance Thresholds, April 2019.

SCAQMD, Amicus Brief in Support of Neither Party, Sierra Club v. County of Fresno, April 6, 2015.

SCAQMD, Application of the South Coast Air Quality Management District for Leave to File Brief of Amicus Curiae in Support of Neither Party and Brief of Amicus Curiae. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno v. County of Fresno.

SCAQMD, CEQA Air Quality Handbook 1993, http://www.aqmd.gov/home/regulations/ceqa/air- quality-analysis-handbook/ceqa-air-quality-handbook-(1993). Accessed July 8, 2022.

SCAQMD, Cumulative Impacts White Paper, Appendix D.

SCAQMD, Final 2016 AQMP, March 2017. http://www.aqmd.gov/home/air-quality/clean-air- plans/air-quality-mgt-plan/final-2016-aqmp. Accessed July 8, 2022.

SCAQMD, Final Localized Significance Threshold Methodology, June 2003 (Revised July 2008).

SCAQMD, Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds, 2006.

SCAQMD, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis, August 2003.

SCAQMD, Localized Significance Thresholds. http://www.aqmd.gov/home/regulations/ceqa/air- quality-analysis-handbook/localized-significance-thresholds. Accessed July 8, 2022.

7. References

City of Culver City 7-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
SCAQMD, Map of Jurisdiction, 1999.

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

SJVAPCD, Application for Leave to File Brief of Amicus Curiae Brief of San Joaquin Valley Unified Air Pollution Control District in Support of Defendant and Respondent, County of Fresno and Real Party In Interest and Respondent, Friant Ranch, L.P. In the Supreme Court of California. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno v. County of Fresno.

South Coast Air Quality Management District (SCAQMD), Final 2016 Air Quality Management Plan, March 2017.

SCAQMD, Board Meeting, Agenda No. 30, Adopt the 2012 Lead State Implementation Plan for Los Angeles County, May 4, 2012.

Travel Model Improvement Program Time-of-Day Modeling Procedures: State-of-the-Practice, State-of-the-Art(2.0 Standard Approaches,
http://www.fhwa.dot.gov/planning/tmip/publications/other_reports/tod_modeling_procedur es/ch02.cfm).

USEPA, Clean Air Act Overview, Clean Air Act Table of Contents by Title, Last Updated January 3, 2017.

USEPA, Clean Air Act, 1963.

USEPA, NAAQS Table, https://www.epa.gov/criteria-air-pollutants/naaqs-table. Accessed July 8, 2022.

4.3 Cultural Resources
36 Code of Federal Regulations (CFR) 60.

A. L. Kroeber, Handbook of the Indians of California, Bureau of American Ethnology, Bulletin 78 (Washington, D.C.: Smithsonian Institution, 1925).

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

California Public Resources Code, Section 5024.1[b].

California Public Resources Code Section 21083.1(a).

California Public Resources Code, Section 5024.1[a].

Carole Cosgrove Terry, PhD, Frederick William Dohrmann (1842–1914), Immigrant Entrepreneurship, N.D, https://www.immigrantentrepreneurship.org/entries/frederick- william-dohrmann/. Accessed July 12, 2022.

CEQA Guidelines, Section 15064.5(b)(1).

7. References

City of Culver City 7-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CEQA Guidelines, Section 15064.5(c)(4).

CEQA Guidelines, Section 15064.5(b)(3).

Cheviot Hills History, N.D, The Spanish and Mexican Ranchos, https://www.cheviothillshistory.org/spanish-mexican-ranchos. Accessed July 12, 2022.

City of Culver City, Culver City Municipal Code, Chapter 15.05 Historic Preservation Program.

City of Los Angeles, Conservation Element of the General Plan, pp. II-3 to II-5.

City of Los Angeles, Los Angeles Administrative Code, Section 22.171.7.

City of Los Angeles, Los Angeles Municipal Code, Section 12.20.3.

City of Los Angeles, Los Angeles Municipal Code, Section 91.106.4.5.1.

Culver City Historical Society, N.D, Culver City Timeline: A Work in Progress, https://www.culvercityhistoricalsociety.org/about/culver-city-timeline/. Accessed July 11, 2022.

Dibblee, T.W., and H.E. Ehrenspeck, Geologic map of the Beverly Hills and Van Nuys (south ½) quadrangles, Los Angeles County, California. Dibblee Geological Foundation, Dibblee Foundation Map DF-31, 1:24,000; 1991, https://ngmdb.usgs.gov/mapview/?center=- 118.386,34.029&zoom=15. Accessed July 12, 2022.

Environmental Science Associates (ESA), (in progress) Archaeological and Paleontological Monitoring Report for the Culver Studios Innovation Plan Project, City of Culver City, California, 2022. Report on file with ESA, Irvine, CA.

ESA, Archaeological and Paleontological Monitoring Report for the 8777 Washington Project, City of Culver City, California, 2021. Report on file with ESA, Irvine, CA.

ESA, Ivy Station Project, City of Culver City and City of Los Angeles, County of Los Angeles California: Archaeological and Paleontological Monitoring Report. Prepared for: Culver City Triangle Investor, Inc., c/o Lowe Enterprises Real Estate Group, 8740 Washington Boulevard, Suite A, Culver City, CA 90232. Prepared by: ESA, 626 Wilshire Boulevard, Suite 1100, Los Angeles, CA 90017, 2018. ESA, Archaeological and Paleontological Monitoring Results for the Ivy Station Project, City of Culver City and City of Los Angeles, County of Los Angeles, California, 2018. Report on file with the CHRIS-SCCIC, Fullerton, CA.

Evening Vanguard, Fire Destroys Zucca’s Today, February 20, 1950.

Geotechnologies, Inc., Evaluation of Soils and Geology Issues, Proposed Commercial Office Development, 8825 National Boulevard and 8771 Washington Boulevard, Culver City, California; 8876, 8884, 8886, and 8888 National Boulevard, Culver City, California, February 2, 2022.

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

7. References

City of Culver City 7-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Los Angeles County Department of Public Works, Map TR0022-044B, Tract No. 1778.

Los Angeles Department of City Planning, West Adams–Baldwin Hills–Leimert Community Plan, June 2016, 3-107.

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.

McCawley, William, The First Angelinos: The Gabrielino Indians of Los Angeles, 1996.

Nancy Hadley, Frederick H. Meyer (1876–1961), American Institute of Architects Historical Directory, December 18, 2018,
https://aiahistoricaldirectory.atlassian.net/wiki/spaces/AHDAA/pages/35728413/ahd10302

54. Accessed July 12, 2022; Pacific Coast Architecture Database, N.D, Albert John Evers (Architect), http://pcad.lib.washington.edu/person/764/. Accessed July 12, 2022.

Pacific Coast Architecture Database, N.D, Albert John Evers (Architect), http://pcad.lib.washington.edu/person/764/. Accessed July 12, 2022.

San Francisco Examiner, Broadway-Hale Sells Unit for $10 Million, November 2, 1961.

United States Department of the Interior, National Park Service, National Historic Landmarks Frequently Asked Question, 2021.

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

United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997.

United States Department of the Interior, National Register Bulletin #21: Defining Boundaries for National Register Properties Form, 1997, p. 12.

University of California Berkeley: Environmental Design Archives, N.D, Frederick H. Meyer Collection, 1904–1962, finding aid and biography via Online Archive of California, https://oac.cdlib.org/findaid/ark:/13030/tf809nb36t/admin/. Accessed July 12, 2022.

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

Southwestern Journal of Anthropology 11:214–230, 1955.

4.4 Energy
BP Global, Oil reserves, 2018, https://www.bp.com/en/global/corporate/energy- economics/statistical-review-of-world-energy/oil.html. Accessed July 11, 2022.

California Air Pollution Control Officers Association, California Emissions Estimator Model, 2021, http://caleemod.com/. Accessed July 11, 2022.

CARB, 2017 Scoping Plan, November 2017.

7. References

City of Culver City 7-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CARB, CalEEMod User's Guide, Appendix E, Section 5, September 2016. Factors for the prior Title 24 standard are extrapolated based on the technical source documentation.

CARB, Clean Car Standards – Pavley, Assembly Bill 1493. Last reviewed January 11, 2017, https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission-standards-under- assembly-bill-1493-2002-pavley. Accessed July 11, 2022.

California Building Standards Commission, Guide to the 2016 California Green Building Standards Code Nonresidential, 2018.

California Energy Commission (CEC), Annual Power Content Labels for 2020, 2021.

CEC, 2019 Building Energy Efficiency Standards, 2019.

CEC, 2019 Building Energy Efficiency Standards for Residential and Nonresidential Buildings, 2018.

CEC, California Retail Fuel Outlet Annual Reporting (CEC-A15) Results, 2010–2020, https://www.energy.ca.gov/media/3874. Accessed July 11, 2022.

CEC, Tracking Progress – Energy Efficiency. Last updated September 2018.

California Gas and Electric Utilities, 2020 California Gas Report, 2020.

California Legislative Information, Senate Bill 100, California Renewables Portfolio Standard Program: Emissions of Greenhouse Gases, Approved by Governor on September 10, 2018, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100.

Accessed July 11, 2022.

California Public Utilities Commission, California Renewables Portfolio Standard (RPS), 2018.

California Public Utilities Commission, RPS Program Overview, 2018.

CEC, 2019 Integrated Energy Policy Report, February 2020, p. 228, https://efiling.energy.ca.gov/getdocument.aspx?tn=232922. Accessed July 11, 2022.

CEC, California Retail Fuel Outlet Annual Reporting (CEC-A15) Results, 2019, https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/california- retail-fuel-outlet-annual-reporting. Accessed July 11, 2022.

CEC, The California Energy Demand 2018–2030 Revised Forecast, 2018.

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 11, 2022.

City of Culver City, Bicycle & Pedestrian Action Plan, June 2020.

City of Culver City, Circulation Element, 1995, p. C-8.

City of Los Angeles, Sustainable City pLAn, 2015.

7. References

City of Culver City 7-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Los Angeles, VMT Calculator.

City of Los Angeles. LA’s Green New Deal, 2019.

Edison International and Southern California Edison (SCE), 2020 Annual Report, 2021.

Edison International and SCE, 2021 Annual Report, 2022, p. 2, https://www.edison.com/home/investors/financial-reports-information/annual-reports.html.

Accessed July 11, 2022.

KPFF Consulting Engineers, Crossings Campus Utility Infrastructure Technical Report: Water, Wastewater, and Energy, April 2022, Exhibits 4 and 11.

Los Angeles Department of City Planning, Mobility Plan 2035: An Element of the General Plan, approved by City Planning Commission on June 23, 2016, and adopted by City Council on September 7, 2016.

Los Angeles Department of Water and Power (LADWP), 2017 Final Power Strategic Long-Term Resource Plan, December 2017.

LADWP, Briefing Book 2020-2021, p. 59.

LADWP, Facts & Figures, https://www.ladwp.com/ladwp/faces/ladwp/aboutus/a-power/a-p- factandfigures?_adf.ctrl-
state=xk0dbq6vu_4&_afrLoop=9598324856637&_afrWindowMode=0&_ afrWindowId=null#%40%3F_afrWindowId%3Dnull%26_afrLoop%3D9598324856637%2 6_afrWindowMode%3D0%26_adf.ctrl-state%3Dfcfwtty0v_25. Accessed July 11, 2022.

National Highway Traffic Safety Administration (NHTSA), Corporate Average Fuel Economy standards.

Next 10 and Pacific Institute, The Future of California’s Water-Energy-Climate Nexus, Table 4.

SoCalGas, Company Profile, https://www.socalgas.com/about-us/company-profile. Accessed July 11, 2022.

Southern California Association of Governments, 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy, December 2020.

SCE, Who We Are, April 2022.

U. S. Environmental Protection Agency (USEPA), Fact Sheet: EPA and NHTSA Adopt First- Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, 2011.

U.S. Energy Information Administration, California Energy Profile Overview, 2021, https://www.eia.gov/state/?sid=CA#tabs-1. Accessed July 11, 2022.

U.S. Energy Information Administration, How much natural gas does the United States have, and how long will it last? Last updated April 9, 2018,
https://www.eia.gov/tools/faqs/faq.php?id=58&t=8. Accessed July 11, 2022.

7. References

City of Culver City 7-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
United States District Court for the District Court of Columbia, State of California vs. Chao, Case 1:19-cv-02826, 2019.

United States Federal Register, California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment (Document Number:
2021-08826), April 28, 2021.

USEPA, EPA and NHTSA Adopt Standards to Reduce GHG and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond, August 2016.

USEPA, Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, August 2011.

USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

USEPA, Federal Register/Vol. 81, No. 206/Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, October 25, 2016.

USEPA, Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30, 2020.

USEPA, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards: Regulatory Update, December 2021.

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

City of Culver City, Culver City General Plan – Public Safety Element, July 1975.

City of Culver City, Culver City General Plan – Seismic Safety Element, May 1974, updated January 1977.

City of Los Angeles General Plan, Conservation Element, pp. II-6 to II-9.

Department of General Services, Building Standards Commission, California Building Standards Code, https://www.dgs.ca.gov/BSC/Codes#@ViewBag.JumpTo/. Accessed January 11, 2022.

ESA, Archaeological and Paleontological Monitoring Report for the 8777 Washington Project, City of Culver City, California, 2021. Report on file with ESA, Irvine, CA.

7. References

City of Culver City 7-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
ESA, Crossings Campus, City of Culver City and City of Los Angeles, California, Paleontological Resources Assessment Report, July 2022.

Geotechnologies, Inc., Evaluation of Soils and Geology Issues, Proposed Commercial Office Development, 8825 National Boulevard and 8771 Washington Boulevard, Los Angeles, California; 8876, 8884, 8886, and 8888 National Boulevard, Culver City, California, February 2, 2022.

Los Angeles Regional Water Quality Control Board, Order No. R4-2013-0095, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties, June 6, 2013.

Society of Vertebrate Paleontology (SVP), Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010.

SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources:
standard guidelines, Society of Vertebrate Paleontology News Bulletin 163:22–27, 1995.

SVP, Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010.

SWCA Environmental Consultants, Final Paleontological Resources Monitoring and Mitigation Report for the Washington National Project, Culver City, Los Angeles County, California.

Prepared for: Greystar, 2615 Pacific Coast Highway, Suite 208, Hermosa Beach, CA 90254. Prepared by: SWCA Environmental consultants, 150 South Arroyo Parkway, Second Floor, Pasadena, CA 91105, 2016.

United States Environmental Protection Agency (USEPA), Clean Water Act, Section 402:

National Pollutant Discharge Elimination System, https://www.epa.gov/cwa-404/clean- water-act-section-402-national-pollutant-discharge-elimination-system. Accessed January 11, 2022.

USGS, 2022, Areas of Land Subsidence in California,
https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html. Accessed July 12, 2022.

ZIMAS, website check for Culver City methane zones, http://zimas.lacity.org/. Accessed July 12, 2022.

4.6 Greenhouse Gas Emissions
14 California Code of Regulations Section 15064.4(b).
84 FR 51310.

7. References

City of Culver City 7-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Anderegg, William R. L., J.W. Prall, J. Harold, S.H., Schneider, Expert Credibility in Climate Change, Proceedings of the National Academy of Sciences of the United States of America, 2010, 107:12107-12109.

SCAG 2016-2040 RTP/SCS Final Growth Forecast by Jurisdiction.

California Air Pollution Control Officers Association (CAPCOA), Quantifying Greenhouse Gas Mitigation Measures, August 2010, p. 39.

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

California Climate Change Center, Our Changing Climate: Assessing the Risks to California, 2006.

California Code of Regulations (CCR) 17, Section 95800 to 96023.

California Department of Finance, E-6 Population Estimates and Components of Change by County, December 2021, https://dof.ca.gov/forecasting/demographics/estimates/estimates- e6-2010-2021/. Accessed July 14, 2022.

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

CEC, 2019 Building Energy Efficiency Standards.

California Environmental Protection Agency (CalEPA), Climate Action Team (CAT), Climate Action Team Report to Governor Schwarzenegger and the Legislature, 2006.

California Legislative Information, SB-100 California Renewables Portfolio Standard Program:

Emissions of Greenhouse Gases.

California Natural Resources Agency (CNRA), CAT, 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008, 2009.

California Natural Resources Agency, California Climate Adaptation Strategy, https://resources.ca.gov/Initiatives/Building-Climate-Resilience/2021-State-Adaptation- Strategy-Update. Accessed July 12, 2022.

CARB, 2014 Scoping Plan, May 2014.

CARB, 2017 Scoping Plan, Appendix G, November 2017.

CARB, Advanced Clean Cars Program – About, https://ww2.arb.ca.gov/our- work/programs/advanced-clean-cars-program/about. Accessed July 12, 2022.

CARB, California’s Advanced Clean Cars Midterm Review, pp. ES-17, C-9.

7. References

City of Culver City 7-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CARB, CARB amends Low-Carbon Fuel Standard for wider impact, 2018, https://ww2.arb.ca.gov/index.php/news/carb-amends-low-carbon-fuel-standard-wider- impact. Accessed July 12, 2022.

CARB, Climate Change Scoping Plan, December 2008.

CARB, First Update to the AB 32 Scoping Plan, May 2014.

CARB, Low-Carbon Fuel Standard – About, https://ww2.arb.ca.gov/our-work/programs/low- carbon-fuel-standard/about. Accessed July 12, 2022.

CARB, OFFROAD Modeling Change Technical Memo, 2003.

CARB, SB 375 Regional Greenhouse Gas Emissions Reduction Targets (2018).

CARB, Southern California Association of Governments’ (SCAG) 2016 Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination, June 2016.

CARB, Sustainable Communities & Climate Protection Program – About, https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-climate-protection- program/about. Accessed July 12, 2022.

CARB, California Greenhouse Gas Emissions for 2000-2019, 2021. Accessed July 12, 2022.

CCR 17, Section 95100-95158.

CCR 17, Section 95811(b).

CCR 17, Section 95811, 95812(d).

CCR 17, Section 95811, 95812.

CCR 17, Section 95812.

CEC, 2019 Building Energy Efficiency Standards, Fact Sheet.

CEC, 2022 Building Energy Efficiency Standards Summary.

CEC, Scenarios of Climate Change in California: An Overview, February 2006.

City of Culver City, Bicycle & Pedestrian Action Plan, June 2020.

City of Culver City, Culver City Bicycle & Pedestrian Master Plan (BPMP), adopted by City Council, November 8, 2010.

City of Culver City, Municipal Code Chapter 15.02.1005, Solar Photovoltaic Systems.

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

City of Los Angeles, Air Quality Element, June 1991, pp. IV-1 to IV-4.

7. References

City of Culver City 7-12 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Los Angeles, Department of Public Works, LA Sanitation, Recycling, https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s-lsh-wwd-s- r?_adf.ctrl-state=kq9mn3h5a_188. Accessed July 12, 2022.

City of Los Angeles, Green New Deal/Sustainable City pLAn, 2019.

City of Los Angeles, RENEW LA, Five-Year Milestone Report, 2011.

City of Los Angeles, Sustainable City pLAn, April 2015.

CNRA, CAT, 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008.

EKI, Water Supply Assessment for Crossings Campus Building 1, March 31, 2022.

Energy and Environmental Economics (E3), Achieving Carbon Neutrality in California, PATHWAYS Scenarios Developed for the California Air Resources Board, October 2020.

E3, Deep Decarbonization in a High Renewables Future, Updated Results from the California PATHWAYS Model, June 2018.

Governor’s OPR, Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, 2008.

IPPC, Intergovernmental Panel on Climate Change, Second Assessment Report, Working Group I: The Science of Climate Change, 1995.

IPCC, Intergovernmental Panel on Climate Change, Climate Change 2014: Synthesis Report, Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, Summary for Policy Makers, 2014, p. 5, http://ipcc.ch/report/ar5/syr/. Accessed July 12, 2022.

IPCC, Intergovernmental Panel on Climate Change, Fifth Assessment Report, Summary for Policy Makers, p. 20.

IPCC, Intergovernmental Panel on Climate Change, Fourth Assessment Report, Working Group I Report: The Physical Science Basis, Table 2.14, 2007.

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

National Highway Traffic Safety Administration (NHTSA), Corporate Average Fuel Economy standards.

National Research Council, Advancing the Science of Climate Change, 2010.

OPR, Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review.

P. Friedlingstein et al.: Global Carbon Budget 2020, 2020.

7. References

City of Culver City 7-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Pacific Institute for Studies in Development, Environment and Security, Climate Change and California Water Resources: A Survey and Summary of the Literature, July 2003.

Parmesan, C. and Galbraith, H., Observed Ecological Impacts of Climate Change in North America. Arlington, VA: Pew. Cent. Glob. Clim. Change, 2004.

Parmesan, C., Ecological and Evolutionary Response to Recent Climate Change, first published on August 24, 2006.

Paul R. Epstein, et al., Urban Indicators of Climate Change, Report from the Center for Health and the Global Environment, (Harvard Medical School and the Boston Public Health Commission, August 2003), unpaginated.

Pew Center on Global Climate Change, Climate Change 101: Understanding and Responding to Global Climate Change.

SCAG, 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020-2045 RTP/SCS), May 2020.

SCAG, 2020-2045 RTP/SCS Public Health Technical Report, May 2020, p. 53.

SCAG, 2020-2045 RTP/SCS, Demographics and Growth Forecast Technical Report, May 2020.

SCAG, 2020-2045 RTP/SCS, May 2020.

SCAG, The State of the Region—Measuring Regional Progress, December 2006, p. 121.

SCAQMD, Board Meeting, December 5, 2008, Agenda No. 31, http://www3.aqmd.gov/hb/2008/December/0812ag.html. Accessed July 12, 2022.

SCAQMD, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October 2008, http://www.aqmd.gov/docs/default- source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008- 2009/ghg-meeting-6/ghg-meeting-6-guidance-document-discussion.pdf?sfvrsn=2.

Accessed July 12, 2022.
14 California Code of Regulations Sections 15064.7; 15064.4.

CNRA, Final Statement of Reasons for Regulatory Action (December 2009), pp. 11-13, 14, 16 San Joaquin Valley Air Pollution Control District (SJVAPCD), CEQA Determinations of Significance for Projects Subject to ARB’s GHG Cap-and-Trade Regulation, APR-2025, June 25, 2014
SCAQMD, Final Negative Declaration for Ultramar Inc. Wilmington Refinery Cogeneration Project, SHC No. 2012041014 (October 2014)
SCAQMD Final Negative Declaration for Phillips 99 Los Angeles Refinery Carson Plant—Crude Oil Storage Capacity Project, SCH No. 2013091029 (December 2014)

7. References

City of Culver City 7-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
SCAQMD Final Mitigated Negative Declaration for Toxic Air Contaminant Reduction for Compliance with SCAQMD Rules 1420.1 and 1402 at the Exide Technologies Facility in Vernon, CA, SCH No. 2014101040 (December 2014)
SCAQMD Final Environmental Impact Report for the Breitburn Santa Fe Springs Blocks 400/700 Upgrade Project, SCH No. 2014121014 (August 2015).

South Coast Air Quality Management District, Greenhouse Gases CEQA Significance Thresholds, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis- handbook/ghg-significance-thresholds. Accessed July 12, 2022.

Southern California Association of Governments (SCAG), Final 2020–2045 RTP/SCS, Chapter 0: Making Connections, May 7, 2020, p. 5.

State of California, Department of Justice, Office of the Attorney General, Climate Change Impacts in California, https://oag.ca.gov/environment/impact. Accessed July 12, 2022.

State of California, SB No. 375, September 30, 2008.

The Cal-Adapt website: http://cal-adapt.org. Accessed July 12, 2022.

U.S. Environmental Protection Agency (USEPA), Final Rule for Model Year 2021 - 2026 Light- Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30, 2020.

United Nations Framework Convention on Climate Change, Press Release—Vienna UN Conference Shows Consensus on Key Building Blocks for Effective International Response to Climate Change, August 31, 2007.

United States District Court for the District Court of Columbia, State of California vs. Chao, Case 1:19-cv-02826, 2019.

USEPA, Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gas, updated April 2021.

USEPA, Climate Change Indicators: Greenhouse Gases, https://www.epa.gov/climate- indicators/greenhouse-gases. Accessed July 12, 2022.

USEPA, EPA and NHTSA Adopt Standards to Reduce GHG and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond, August 2016.

USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

7. References

City of Culver City 7-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
USEPA, Global Greenhouse Gas Emissions Data, www.epa.gov/ghgemissions/global- greenhouse-gas-emissions-data. Accessed July 12, 2022.

USEPA, Mixed-Use Trip Generation Model. Accessed July 12, 20221. https://www.epa.gov/smartgrowth/mixed-use-trip-generation-model.

USEPA, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards: Regulatory Update, December 2021.

LADWP, Water Supply Assessment - for the Crossings Campus Project, February 24, 2022.

4.7 Hazards and Hazardous Materials
California Health & Safety Code, Division 20, Chapter 6.95, Article 1; California Code of Regulations, Title 19, Sections 2620–2732; California Code of Regulations, Title 24, Part 9, Section 80.115; Los Angeles Municipal Code, Article 7 of Chapter V, Section 57.120.1, and 57.120.1.4.

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

Code of Federal Regulations (CFR), Title 49, Parts 100–180, Transportation, revised as of October 1, 2010.

County of Los Angeles Department of Public Works, Disaster Routes, Los Angeles County Operational Area, https://dpw.lacounty.gov/dsg/DisasterRoutes/. Accessed July 12, 2022.

EKI, Phase I Environmental Site Assessment and Results of Subsurface Investigation, Culver Crossing, 8879–880 Venice Boulevard, 8825–8829 National Boulevard, and 8771 Washington Boulevard, Culver City, California, October 18, 2021.

Federal Emergency Management Act (FEMA), History of FEMA, https://www.fema.gov/about/history. Accessed July 12, 2022.

The CalARP program encompasses both the federal “Risk Management Program,” established in the CFR, Title 40, Part 68, and the State of California program, in accordance with the Title 19 of the California Code of Regulations, Division 2, Chapter 4.5.

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

United States Environmental Protection Agency (USEPA), Emergency Planning and Community Right-to-Know Act Fact Sheet, Fall 2020.

7. References

City of Culver City 7-16 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.8 Hydrology and Water Quality
Ballona Creek Watershed Management Group, Enhanced Watershed Management Program for the Ballona Creek Watershed, January 2016.

California State Water Resources Control Board, State Board Resolution No. 68-16, 1968.

California Water Code, Division 7, Water Quality, Section 13000 et seq.

City of Los Angeles Department of Public Works, Bureau of Sanitation (LASAN), Watershed Protection Division, Planning and Land Development for Low Impact Development (LID), Part B: Planning Activities, 5th Edition, May 2016.

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

Dudek, Groundwater Sustainability Plan for the Santa Monica Groundwater Subbasin, January 2022.

KPFF Consulting Engineers, Crossings Campus Hydrology & Water Resources Technical Report, March 2022.

Los Angeles County Department of Public Works, Hydrology Manual, 2006.

Los Angeles Regional Water Quality Control Board, Order No. R4-2018-0125, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties, 2018.

Los Angeles Regional Water Quality Control Board, Order No. R4-2013-0095, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties, 2013.

Los Angeles Regional Water Quality Control Board, Order No. R4-2021-0105, NPDES Permit No. CAS004004, Regional Phase I MS4 NPDES Permit, Waste Discharge Requirements and National Pollutant Discharge Elimination System (NPDES) Permit For Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles and Ventura Counties. September 11, 2021.

The National Flood Insurance Act of 1968, as amended, and The Flood Disaster Protection Act of 1973, 42 U.S.C. 4001 et. seq.

United States Environmental Protection Agency (USEPA), Clean Water Act, 2002.

7. References

City of Culver City 7-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
USEPA, Clean Water Act, 2016.

USEPA, Water Quality Standards Handbook - Chapter 4: Antidegradation, 2010.

USEPA, Water Quality Standards, Establishment of Numeric Criteria for Priority Toxic Pollutants for the State of California, 2001.

4.9 Land Use and Planning
California Government Code, Title 7, Division 1, Chapter 3, Article 5. Authority for and Scope of General Plans, Sections 65302 – 65303.

City of Culver City, Bicycle & Pedestrian Action Plan, June 2020.

City of Culver City, Culver City Urban Forest Master Plan, 2015.

City of Culver City, Exposition Light Rail Transit and Station Design for Development, June 6, 2005, p. 2.

City of Culver City, General Plan Open Space Element, adopted 1996, amended through 2004, https://www.culvercity.org/home/showpublisheddocument?id=796. Accessed January 17, 2022.

City of Los Angeles Department of City Planning, General Plan Framework Element, originally adopted December 11, 1996 and readopted August 8, 2001, p. 5-1, et. seq.

City of Los Angeles Department of City Planning, General Plan Overview, https://planning.lacity.org/plans-policies/general-plan-overview. Accessed July 13, 2022.

City of Los Angeles, Department of City Planning, West Adams–Baldwin Hills–Leimert Community Plan, June 2016, p. 1-12
City of Los Angeles, Los Angeles Housing Element 2021-2029, p. 242.

Los Angeles Metropolitan Transit Authority (Metro), Active Transportation Strategic Plan (ATSP), in development, https://www.metro.net/projects/active-transportation-strategic- plan-atsp/. Accessed July 13, 2022.

4.10 Noise
American Journal of Audiology (AJA), Average Speech Levels and Spectra in Various Speaking/Listening Conditions, A Summary of the Pearson, Bennett, & Fidell (1977) Report, Vol. 7 21-25. doi:10.1044/1059-0889(1998/012), October 1998, https://aja.pubs.asha.org/article.aspx?articleid=1773811. Accessed July 13, 2022.

California Department of Transportation (Caltrans), Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013.

City of Los Angeles, Municipal Code, Chapter XI, Article I, Section 111.02-(b), https://codelibrary.amlegal.com/codes/los_angeles/latest/lamc/0-0-0-193819. Accessed July 13, 2022.

7. References

City of Culver City 7-18 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Los Angeles, Noise Element of the Los Angeles City General Plan, adopted February 3, 1999, pp. 1.1-2.4.

Federal Highway Administration (FHWA), Roadway Construction Noise Model User’s Guide, 2006, p. 3.

Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Manual, FTA Report No. 0123, Prepared by John A. Volpe National Transportation Systems Center, Section 7.1.3, September 2018.

Fehr & Peers, Crossings Campus Project Transportation Impact Study, July 2022.

FHWA, Special Report – Measurement, Prediction, and Mitigation, Chapter 4 Mitigation, last updated June 28, 2017,
https://www.fhwa.dot.gov/Environment/noise/construction_noise/special_report/hcn04.cfm . Accessed July 13, 2022.

State of California Governor’s Office of Planning and Research (OPR), General Plan Guidelines, 2003.

United States Department of Labor, Occupational Safety and Health (OSH) Act of 1970, https://www.osha.gov/laws-regs/oshact/completeoshact. Accessed July 13, 2022.

United States Environmental Protection Agency (EPA), EPA Identifies Noise Levels Affecting Health and Welfare, EPA Press Release – April 2, 1974,
https://archive.epa.gov/epa/aboutepa/epa-identifies-noise-levels-affecting-health-and- welfare.html#:~:text=The%20document%20identifies%20a%2024,preventing%20activity %20interference%20and%20annoyance, last updated on September 14, 2016.

World Health Organization, Environmental Noise Guidelines for the European Region, edited by Dr. Zsuzsanna Jakab, WHO Regional Director for Europe, 2018.

4.11.1 Public Services – Fire Protection
CAL FIRE, California Fire Hazard Severity Zone Viewer, https://egis.fire.ca.gov/FHSZ/.

Accessed March 18, 2022.

California Building Code (CCR, Title 24, Part 2).

California Governor’s Office of Emergency Services, Fire and Rescue Division, California Fire Service and Rescue Emergency Mutual Aid System, Mutual Aid Plan, revised April 2019.

City of Culver City, Culver City General Plan, Public Safety Element, adopted August 25, 1975.

City of Culver City, General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, p. 26.

City of Hayward v. Board of Trustees of California State University (2015) 242 Cal.App.4th 833, 843, 847.

7. References

City of Culver City 7-19 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Los Angeles Department of City Planning, General Plan Framework Element, Chapter 9:

Infrastructure and Public Services, originally adopted December 11, 1996, and readopted August 8, 2001.

City of Los Angeles Department of Public Works, Bureau of Engineering, Newsletter No. 20-5, November 6, 2019.

City of Los Angeles, A 2002 Proposition Q Citywide Safety Bond Program Progress Report, February/March 2016.

Culver City Fire Department (CCFD), Community Risk Assessment: Standards of Cover, 2019.

Los Angeles Department of Transportation, Los Angeles Signal Synchronization Fact Sheet, February 14, 2016.

Los Angeles Fire Department, Department Overview – Our Mission, http://www.lafd.org/about/about-lafd/our-mission. Accessed March 18, 2022.

Los Angeles Fire Department, Find Your Station. https://www.lafd.org/fire-stations/station- results. Accessed March 21, 2022.

Los Angeles Fire Department, Los Angeles 2000 Prop F Fire Facilities Bond, Progress Report, February–March 2016.

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

Los Angeles Fire Department, South Bureau, https://www.lafd.org/about/south-bureau. Accessed March 18, 2022.

Los Angeles Fire Department, Training Bulletin: Traffic Signal Preemption System for Emergency Vehicles, Bulletin No. 133, October 2008.

National Fire Protection Association (NFPA), NFPA 1710 – Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments, 2020 Edition.

4.11.2 Public Services – Police Protection
Culver City Police Department (CCPD), About CCPD, https://www.culvercitypd.org/Office-of- the-Chief-of-Police/About-CCPD. Accessed March 30, 2022.

CCPD, Assistant Chief of Police Jason Sims, correspondence dated February 14, 2022.

CCPD, December 2021 Monthly Report.

CCPD, Patrol, https://www.culvercitypd.org/Bureau-Information/Patrol-Bureau/Patrol. Accessed March 30, 2022.

County of Los Angeles Chief Executive Office, Office of Emergency Management, About Emergency Management, https://ceo.lacounty.gov/emergency- management/#1509664666354-388bbaed-fcaf. Accessed March 24, 2022.

7. References

City of Culver City 7-20 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
LAPD, Andre Rainey, Lieutenant II, Office-In-Charge, Public Engagement Section, Office of Operations, correspondence dated March 13, 2022.

LAPD, COMPSTAT Citywide Profile 02/27/22–03/26/22.

LAPD, COMPSTAT, https://www.lapdonline.org/office-of-the-chief-of-police/office-of-special- operations/detective-bureau/crime-mapping-and-compstat/. Accessed March 24, 2022.

LAPD, Operations – West Bureau. Prepared by LAPD/PRD/GIS MAPPING January 2009.

LAPD, West Los Angeles Community Police Station, https://www.lapdonline.org/lapd- contact/west-bureau/west-los-angeles-community-police-station/. Accessed March 30, 2022.

4.12 Transportation
City of Culver City, General Plan Circulation Element, amended through 1995.

City of Culver City, Resolution Adopting 2022-2026 Short Range Mobility Plan, February 28, 2022.

City of Los Angeles Department of City Planning. Plan for a Healthy Los Angeles: A Health and Wellness Element of the General Plan, November 2021.

City of Los Angeles Department of Transportation, LADOT Transportation Assessments – Interim Guidance for Freeway Safety Analysis, May 2020.

Federal Transit Administration (FTA), Shared Mobility Definitions, Microtransit, https://www.transit.dot.gov/regulations-and-guidance/shared-mobility-definitions, last updated February 28, 2020.

Fehr & Peers, Crossings Campus Project Transportation Impact Study, July 2022.

Los Angeles Department of City Planning, Mobility Plan 2035: An Element of the General Plan, approved by City Planning Commission on June 23, 2016, and adopted by City Council on September 7, 2016.

Los Angeles Department of Transportation (LADOT), Vision Zero Maps, https://ladotlivablestreets.org/programs/vision-zero/maps. Accessed June 30, 2022.

Public Resources Code, Section 21155.

Public Resources Code, Section 21064.3.

SCAG, High Quality Transit Areas (HQTA) 2016 – SCAG Region, February 22, 2021, https://gisdata-
scag.opendata.arcgis.com/datasets/1f6204210fa9420b87bb2e6c147e85c3_0/explore?locati on=34.018594%2C-118.361387%2C13.12. Accessed June 30, 2022.

Sequoyah Hills Homeowners Assn. V. City of Oakland (1993) 23 Cal.App.4th 704, 717–718 [29 Cal. Rptr. 2d 182].

7. References

City of Culver City 7-21 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.13 Tribal Cultural Resources
ESA, Crossings Campus, Culver City and City of Los Angeles, California, Archaeological Resources Assessment Report, prepared for Culver Crossings Properties LLC, July 2022.

ESA, Archaeological and Paleontological Monitoring Report for the 8777 Washington Project, City of Culver City, California, 2021. Report on file with ESA, Irvine, CA.

ESA, (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.

Geotechnologies, Inc. 2021. Geotechnical Engineering Investigation, Proposed Commercial Office Development, 8876 through 8888 West Venice Boulevard, and 8829 West National Boulevard, Los Angeles, California.

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

L. Kroeber, Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78 (Washington, D.C.: Smithsonian Institution, 1925).

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.

McCawley, William. The First Angelinos: The Gabrielino Indians of Los Angeles, (Malki Museum Press, Banning, California, 1996).

Public Resources Code, Section 21080.3.1(b) and (c).

Public Resources Code, Section 21080.3.2(b).

Public Resources Code, Section 21082.3(d)(2) and (3).

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

Southwestern Journal of Anthropology 11:214-230, 1955.

4.14.1 Water Supply
California Code of Regulations, Title 20, Section 1605.3(h).

California Department of Water Resources, SGMA Groundwater Management, https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater- Management. Accessed April 2022.

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

CCFD, Battalion Chief David Rindels, correspondence dated April 25, 2022.

7. References

City of Culver City 7-22 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
City of Culver City website, Water Conservation, https://www.culvercity.org/City- Hall/Departments/Public-Works/Culver-City-Environmental-Initiatives/Water- Conservation. Accessed July 13, 2022.

City of Culver City, Municipal Code, Chapter 5.03.

City of Los Angeles Department of City Planning, Citywide General Plan Framework, An Element of the Los Angeles General Plan, originally adopted December 11, 1996, and readopted August 8, 2001.

City of Los Angeles, Office of the Mayor, Executive Directive No. 5, Emergency Drought Response - Creating a Water Wise City, October 14, 2014.

City of Los Angeles, One Water LA 2040 Plan, Volume 1, Summary Report, April 2018.

City of Los Angeles, Sustainable City pLAn, 2015.

GSWC, Culver City Service Area 2020 Urban Water Management Plan, Chapter 6, June 15, 2021.

KPFF Consulting Engineers, Culver Crossings Utility Infrastructure Technical Report: Water, Wastewater, and Energy, April 2022, p. 24.

Metropolitan Water District of Southern California, 2020 Urban Water Management Plan, June 2021.

Metropolitan Water District of Southern California, Integrated Water Resources Plan – 2015 Update, Report No. 1518, 2016.

Metropolitan Water District of Southern California, Report on Integrated Water Resources Plan (IRP) Implementation, October 8, 2019.

State Water Resources Control Board, Fact Sheet, August 2017 Statewide Conservation Data, August Urban Water Production Summary, updated October 3, 2017.

State Water Resources Control Board, Fact Sheet, February 2017 Statewide Conservation Data, February Conservation Summary, updated April 4, 2017.

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.

Sustainable Groundwater Management Act [And Related Statutory Provisions from SB1168 (Pavley), AB1739 (Dickinson), and SB1319 (Pavley) as Chaptered], 2015 Amendments, effective January 1, 2019.

Golden State Water Company,
https://www.gswater.com/southwest#:~:text=We%20currently%20serve%2054%2C994%2 0customers,Village%2C%20Lennox%20and%20Gardena%20Heights. Accessed July 13, 2022.

Water Surplus and Drought Management Plan, Report No. 1150, 1999.

7. References

City of Culver City 7-23 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
West Basin Municipal Water District, 2020 Urban Water Management Plan, June 28, 2021, p. ES-3.

4.14.2 Wastewater
California Regional Water Quality Control Board Los Angeles Region, U.S. Environmental Protection Agency Region IX, Order R4-2017-0045, NPDES No. CA0109991, Waste Discharge Requirements and National Pollutant Discharge Elimination System Permit for the City of Los Angeles, Hyperion Treatment Plant Discharge to the Pacific Ocean.

City of Los Angeles Bureau of Sanitation (LASAN), Hyperion Water Reclamation Plant, https://www.lacitysan.org/san/faces/wcnav_externalId/s-lsh-wwd-cw-p-hwrp?_adf.ctrl- state=yb7ued7kk_514&_afrLoop=1716841967525366#!. Accessed April 2022.

City of Los Angeles Department of City Planning, Citywide General Plan Framework, An Element of the Los Angeles General Plan, originally adopted December 11, 1996, and readopted August 8, 2001.

City of Los Angeles Department of Public Works Bureau of Sanitation and Department of Water and Power, Water Integrated Resources Plan 5-Year Review FINAL Documents, June 2012.

City of Los Angeles Department of Public Works, Bureau of Engineering, Project Information Report, North East Interceptor Sewer (NEIS) Phase 2A.

City of Los Angeles Department of Public Works, Bureau of Engineering, Special Order No. 006-0691, Planning Period, Flow, and Design Criteria for Gravity Sanitary Sewers and Pumping Plants, effective June 6, 1991.

City of Los Angeles, Office of the Mayor, Executive Directive No. 5, Emergency Drought Response - Creating a Water Wise City, October 14, 2014.

City of Los Angeles, One Water LA 2040 Plan, Volume 1, Summary Report, April 2018.

City of Los Angeles, Ordinance No. 180,822.

City of Los Angeles, Ordinance No. 181,480.

Culver City, Amalgamated Agreement Between the City of Los and the City of Culver City for the Conveyance, Treatment and Disposal of Wastewater, April 1999.

KPFF Consulting Engineers, Crossings Campus Utility Infrastructure Technical Report: Water, Wastewater, and Energy, April 2022, pp. 15 and 16.

LASAN, Donald C. Tillman Water Reclamation Plant,
https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-cw/s-lsh-wwd-cw- p/s-lsh-wwd-cw-p-dctwrp?_adf.ctrl-state=yb7ued7kk_5&_afrLoop=1717100937245723#!.

Accessed April 2022.

7. References

City of Culver City 7-24 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
LASAN, Los Angeles-Glendale Water Reclamation Plant,
https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-cw/s-lsh-wwd-cw- p/s-lsh-wwd-cw-p-lagwrp?_adf.ctrl-state=yb7ued7kk_5&_afrLoop=1717251119351961#!.

Accessed April 2022.

LASAN, Sewer System Management Plan Hyperion Sanitary Sewer System, January 2019.

4.14.3 Solid Waste
Building Standards Commission, CALGreen, www.dgs.ca.gov/BSC/Codes. Accessed February 24, 2022.

California Public Resources Code Section 41821.

California Public Resources Code, Sections 41730 et seq.

CalRecycle, Jurisdiction Per Capita Disposal trends – Culver City, for reporting year 2020, December 16, 2021.

CalRecycle, Jurisdiction Per Capita Disposal Trends – Los Angeles, for reporting year 2020.

CalRecycle, Mandatory Commercial Organics Recycling,
www.calrecycle.ca.gov/recycle/commercial/organics/. Accessed February 24, 2022.

CalRecycle, Senate Bill 1374 (2002), Last updated August 24, 2018, https://www.calrecycle.ca.gov/lgcentral/library/canddmodel/instruction/sb1374. Accessed February 24, 2022.

City of Culver City website, Trash & Recycling, http://www.culvercity.org/live/home- property/residential-recycling-trash-services/trash-collections. Accessed March 14, 2022.

City of Los Angeles Bureau of Sanitation (LASAN), Construction and Demolition Recycling, https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s-lsh-wwd-s-r/s- lsh-wwd-s-r-
cdr?_afrLoop=302750877623885&_afrWindowMode=0&_afrWindowId=null&_adf.ctrl- state=sc2bv57ho_155#!%40%40%3F_afrWindowId%3Dnull%26_afrLoop%3D302750877 623885%26_afrWindowMode%3D0%26_adf.ctrl-state%3Dsc2bv57ho_159. Accessed February 24, 2022.

City of Los Angeles Department of City Planning, Citywide General Plan Framework, Chapter 9, originally adopted December 11, 1996, and readopted August 8, 2001.

City of Los Angeles, Department of Public Works, LASanitation, Fact Sheet: The City’s Solid Waste Policies and Programs, 2009.

City of Los Angeles, Ordinance No. 181,519, March 5, 2010.

County of Los Angeles Department of Public Works, Countywide Integrated Waste Management Plan (CoIWMP) 2020 Annual Report, October 2021.

7. References

City of Culver City 7-25 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
LASAN, Construction and Demolition Recycling,
https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s-lsh-wwd-s-r/s- lsh-wwd-s-r-
cdr?_afrLoop=302750877623885&_afrWindowMode=0&_afrWindowId=null&_adf.ctrl- state=sc2bv57ho_155#!%40%40%3F_afrWindowId%3Dnull%26_afrLoop%3D302750877 623885%26_afrWindowMode%3D0%26_adf.ctrl-state%3Dsc2bv57ho_159. Accessed February 24, 2022.

LASAN, Recycling, https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s- lsh-wwd-s-r?_adf.ctrl
state=sc2bv57ho_78&_afrLoop=302690459702255&_afrWindowMode=0&_afrWindowId =ival6l59y#!%40%40%3F_afrWindowId%3Dival6l59y%26_afrLoop%3D3026904597022 55%26_afrWindowMode%3D0%26_adf.ctrl-state%3Dsc2bv57ho_82. Accessed February 24, 2022.

LASAN, Solid Waste Integrated Resources Plan (SWIRP) – A Zero Waste Master Plan, October 2013, adopted April 2015.

LASAN, Solid Waste Integrated Resources Plan (SWIRP) A Zero Waste Master Plan, Frequently Asked Questions (FAQs), 2013.

LASAN, Zero Waste Progress Report, March 2013.

Los Angeles Municipal Code, City Ordinance No. 184,665.

4.14.4 Electric Power, Natural Gas, and Telecommunications Facilities
CEC, 2021 Integrated Energy Policy Report, February 22, 2022.

California Gas and Electric Utilities, 2020 California Gas Report.

CEC, The California Energy Demand 2018–2030 Revised Forecast, 2018, April 19, 2018.

City of Culver City, Information Technology, https://www.culvercity.org/City- Hall/Departments/IT. Accessed July 12, 2022.

City of Los Angeles, Sustainable City pLAn, 2015.

City of Los Angeles. LA’s Green New Deal, 2019.

Edison International and SCE, 2019 Annual Report, March 2020, p. 2.

LADWP, 2017 Retail Electric Sales and Demand Forecast, September 15, 2017, p. 14.

LADWP, 2019 Power Content Label, Version: October 2020.

7. References

City of Culver City 7-26 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
LADWP, Facts & Figures, https://www.ladwp.com/ladwp/faces/ladwp/aboutus/a-power/a-p- factandfigures?_adf.ctrl-
state=xk0dbq6vu_4&_afrLoop=9598324856637&_afrWindowMode=0&_afrWindowId=n ull#%40%3F_afrWindowId%3Dnull%26_afrLoop%3D9598324856637%26_afrWindowM ode%3D0%26_adf.ctrl-state%3Dfcfwtty0v_25. Accessed July 12, 2022.

LADWP, 2017 Final Power Strategic Long-Term Resource Plan, December 31, 2017.

SCE, About Us, 2022, https://www.sce.com/about-us/reliability. Accessed July 12, 2022.

SCE, Who We Are, https://www.sce.com/about-us/who-we-are. Accessed July 12, 2022.

Southern California Gas Company (SoCalGas), Company Profile, https://www.socalgas.com/about-us/company-profile. Accessed July 12, 2022.

City of Culver City 8-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 8
List of EIR Preparers and Organizations and
Persons Contacted

8.1 Lead Agency
Culver City Current Planning Division
9770 Culver Boulevard
Culver City, CA 90232-0507
• Emily Stadnicki, Planning Manager
• Jose Mendivil, Associate Planner

8.2 Project Applicant
5700 Hannum Owner, LLC
c/o Lincoln Property Company
390 N. Pacific Coast Hwy., Suite 3100
El Segundo, CA 90245
• Geoff Maleman

8.3 Environmental Impact Report Preparation
ESA
626 Wilshire Boulevard, Suite 1100
Los Angeles, CA 90017
• Mike Harden, Director – Project Director
• Janelle Firoozi, Environmental Planner
• Rid Hollands, Environmental Planner
• Meghan Gibson, Environmental Planner
• Claudia Watts, Environmental Planner
• Alan Sako, Air Quality and Noise Director
• Elbert Hsiung, Senior Associate
• Tim Witwer, Senior Associate
• Kyle Garcia, Principal Consultant, Cultural Resources

8. List of EIR Preparers and Organizations and Persons Contacted

City of Culver City 8-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• Fatima Clark, Senior Consultant, Cultural Resources
• Denise Kaneshiro, Senior Graphics Manager
• Chance Scott, GIS
• Nicole Sanchez-Sullivan, Senior Word Processor
• Aaron Guzman, Senior Word Processor
Architect
KFA Architecture
3573 Hayden Avenue
Culver City, CA 90232
• Jonnathan Watts, AIA
• Scott Kepford, AIA
• Kristyn Cosgrove, AIA
Civil Engineering and Hydrology
Kimley-Horn and Associates, Inc.
660 South Figueroa Street, Suite 2050
Los Angeles, CA 90017
• Danh Duong, P.E., QSD
Geotechnical Engineer
Geotechnologies, Inc.
439 Western Avenue
Glendale, CA 91201
• Gregorio Varela, P.E., Principal Engineer
Hazards and Hazardous Materials
Ramboll US Consulting Inc.
350 South Grand Avenue, Suite 2800
Los Angeles, CA 90071
• Stephanie Eckelman, Senior Consultant
• Alexis Hilman, Senior Managing Consultant
Historic Resources
Architectural Resources Group
360 E. 2nd Street, Suite 225
Los Angeles, CA 90013
• Katie E. Horak, Principal

8. List of EIR Preparers and Organizations and Persons Contacted

City of Culver City 8-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Transportation and Traffic
Gibson Transportation Consulting, Inc.
555 W. 5th Street, Suite 3375
Los Angeles, CA 90013
• Richard Gibson, Principal

8.4 Agencies Consulted
Culver City Police Department
4040 Duquesne Avenue
Culver City, CA 90232
• Carey Grant, Sergeant
Culver City Fire Department
9600 Culver Boulevard
Culver City, CA 90232
• Dave Rindels, Fire Marshal
Culver City Unified School District
4034 Irving Place
Culver City, CA 90232
• Mike Reynolds
Culver City Parks and Recreation
City of Culver City - City Hall
9770 Culver Boulevard
Culver City, CA 90232
• Dani Cullens

8. List of EIR Preparers and Organizations and Persons Contacted

City of Culver City 8-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

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City of Culver City 9-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 9
Standard Terms, Acronyms, and
Abbreviations
AAI All Appropriate Inquiry
AB Assembly Bill
ACM asbestos-containing materials
ADA Americans with Disabilities Act
ADT average daily trip
AEGL Acute Exposure Guideline Levels
AFY acre-feet per year
ALUC Airport Land Use Commission
AMI Advanced Metering Infrastructure
ANSI American National Standard Institute
AP Accredited Professional
APPP Art in Public Places Program
AQI Air Quality Index
AQMP Air Quality Management Plan
AR4 Fourth Assessment Report
AR5 Fifth Assessment Report
ASHRAE American Society of Heating and Air-Conditioning Engineers AST regulatory program covering aboveground storage tanks ATCM Airborne Toxic Control Measure
ATSP Active Transportation Strategic Plan
BACT best available control technology
BAU business-as-usual
BEN Bicycle Enhanced Network
BEP Business Emergency Plan
BERD Built Environment Resources Database
BEV Battery Electric Vehicle
BLS basic life support
BMP best management practice
BSD Building Safety Division
BTEX benzene, toluene, ethylbenzene, and xylenes
C2F6 hexafluoroethane
C2H4F2 1,1-difluoroethane

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
C2H6 ethane
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
CalARP California Accidental Release Program
CalEEMod California Emissions Estimator Model
Cal-EMA California Emergency Management Agency
CalEPA California Environmental Protection Agency
CalGEM California Geologic Energy Management Division
CALGreen California Green Building Standards
CalSTA California State Transportation Agency
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAS Climate Adaptation Strategy
CAT Climate Action Team
CBC California Building Code
CCAA California Clean Air Act
CF cubic feet
CCFD Culver City Fire Department
CCMC Culver City Municipal Code
CCPD Culver City Police Department
CCR California Code of Regulations
CCTV closed-circuit television
CDFA California Department of Food and Agriculture
CDR carbon dioxide removal
CEC California Energy Commission
CEQA California Environmental Quality Act
CERFA Community Environmental Response Facilitation Act CF4 tetrafluoromethane
CFC California Fire Code
CFR Code of Federal Regulations
CGS California Geological Survey
CH2FCF3 1,1,1,2-tetrafluoroethane
CH4 methane
CHC Cultural Heritage Commission
CHF3 trifluoromethane
CHRIS California Historical Resources Information System CI compression ignition
CMP Construction Traffic Management Plan
CNEL Community Noise Equivalent Level
CNRA California Natural Resources Agency
CO carbon monoxide

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CO2 carbon dioxide
CO2e carbon dioxide equivalent
COG Council of Governments
CoIWMP Los Angeles Countywide Integrated Waste Management Plan COMPSTAT Computer Statistics Unit
CPA Clean Power Alliance
CPIO Community Plan Implementation Overlay
CPTED Crime Prevention Through Environmental Design
CPUC California Public Utilities Commission
CRA Community Risk Assessment
CRT Crisis Response Team
CTC County Transportation Commission
CUPA Certified Unified Program Agency
CVC California Vehicle Code
CWA Clean Water Act
CWC California Water Code
CY cubic yards
dB decibels
dBA A-weighted decibels
DFD Design for Development
DNL day-night average noise level
DOE United States Department of Energy
DOSH Division of Occupational Safety and Health
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
DWR California Department of Water Resources
EIA U.S. Energy Information Administration
EIR environmental impact report
EISA Energy Independence and Security Act of 2007
EMD Los Angeles Emergency Management Department
EMD Environmental Monitoring Division
EMMA Emergency Managed Mutual Aid
EMS emergency medical services
EO Executive Order
EOC Emergency Operation Center
EOO Emergency Operations Organization
EPA United States Environmental Protection Agency
EPCA Energy Policy and Conservation Act of 1975
EPCRA Emergency Planning and Community Right-to-Know Act EPO Environmental Programs and Operations
ERF Effective Response Force
ERO Electric Reliability Organization

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
ERP Emergency Response Plan
ERT Emergency Response Team
ESA Environmental Science Associates
ESA environmental site assessment
EV electric vehicle
EVSE electric vehicle supply equipment
EVSE electric vehicle charging stations
EWMP Enhanced Watershed Management Program
FAR floor area ratio
FBI Federal Bureau of Investigation
FCC Federal Communications Commission
FCMP Final Construction Management Plan
FDC Fire Department Connection
FED functional equivalent document
FEMA Federal Emergency Management Agency
FERC Federal Energy Regulatory Commission
FHWA Federal Highway Administration
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FIRM flood insurance rate map
FIS flood insurance studies
FMZ fire management zone
FPS Fire Preemption System
FTA Federal Transit Administration
FYE Fiscal Year Ending
GHG greenhouse gas
GIS geographical information system
GSA groundwater sustainability agency
GSP Groundwater Sustainability Plan
GSWC Golden State Water Company
GWh gigawatt-hours
GWP global warming potential
H2S hydrogen sulfide
HASP health and safety plan
HazMat hazardous materials
HCM Historic-Cultural Monument
HCS Historic Context Statement
HDV heavy duty vehicle
HEC historical environmental condition
HFC hydrofluorocarbon
HI hybrid industrial
HMBP Hazardous Materials Business Plan
HMGP Hazard Mitigation Grant Program

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
HMIS Hazardous Material Identification System
HMMP Hazardous Material Management Program
HMTA Hazardous Materials Transportation Act
HPAC Historic Preservation Advisory Committee
HPOZ Historic Preservation Overlay Zone
HQTA High Quality Transit Area
HSC California Health and Safety Code
HVAC heating, ventilation, and air conditioning
HWCL Hazardous Waste Control Law
HWRP Hyperion Water Reclamation Plant
IBC International Building Code
IFC International Fire Code
IFFAR Information on Fire Flow Availably Request
IG industrial general
IIPP Injury and Illness Prevention Program
IL light industrial
IPCC Intergovernmental Panel on Climate Change
IRP Integrated Water Resources Plan
IT information technology
ITA Los Angeles Information Technology Agency
IWMA Integrated Waste Management Act
kW kilowatt
kWh kilowatt-hour
LA3 Los Angeles and Equinix
LAA Los Angeles Aqueduct
LACFCD Los Angeles County Flood Control District
LADBS Los Angeles Department of Building and Safety
LADOT City of Los Angeles Department of Transportation
LADWP Los Angeles Department of Water and Power
LAFD Los Angeles Fire Department
LAGWRP Los Angeles-Glendale Water Reclamation Plant
LAMC Los Angeles Municipal Code
LAPD Los Angeles Police Department
LARWQCB Los Angeles Regional Water Quality Control Board LASAN City of Los Angeles Bureau of Sanitation
LASD Los Angeles County Sheriff’s Department
LBP lead-based paint
LDV light duty vehicle
LEED Leadership in Energy and Environmental Design
Leq equivalent sound level over a specified period of time LEV low-emissions vehicle
LID Low-Impact Development

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
LOS level of service
LRT light rail transit
LST localized significance threshold
LTCP Long‐Term Conservation Plan
LTWA Long Term Water Agreement
LUST leaking underground storage tank
MCE maximum credible earthquake
MCL maximum contaminant level
MDV medium duty vehicles
MET mental health evaluation team
MLD most likely descendant
MM mitigation measures
MMBtu million British thermal units
MMRP mitigation monitoring and reporting program
MMT million metric tons
MMTCO2e million metric tons of carbon dioxide equivalent MODRAT modified rational method
MOU Memorandum of Understanding
MPD multiple property documentation
MPO metropolitan planning organization
MPP Policies and Procedures
MS4 Municipal Separate Storm Sewer Systems
MW megawatt
MWD Metropolitan Water District of Southern California
MWh megawatt-hour
MXD mixed-use development
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NC noise criteria
NEHRP National Earthquake Hazards Reduction Program
NEN Neighborhood Enhanced Network
NERC North American Electric Reliability Corporation
NF3 nitrogen trifluoride
NFIP National Flood Insurance Program
NFPA National Fire Protection Association
NHMLAC Natural History Museum of Los Angeles County
NHTSA National Highway Traffic Safety Administration
NIBRS National Incident-Based Report System
NMA neighborhood mobility area
NO2 nitrogen dioxide
NOA Notice of Availability

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
NOC Notice of Completion
NOI Notice of Intent
NOP Notice of Preparation
NOX nitrogen oxide/oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
OEHHA California Office of Environmental Health Hazard Assessment OEM Office of Emergency Management
OHP California Office of Historic Preservation
OPR Governor’s Office of Planning and Research
OSHA Occupational Safety and Health Administration
OVA organic vapor analyzer
PCB polychlorinated biphenyls
PCE perchloroethylene
PD planned development
PDF project design feature
PED pedestrian enhanced district
PEV plug-in electric vehicle
PFC perfluorocarbons
PGA peak ground acceleration
PGA priority growth area
PHEV plug-in hybrid electric vehicle
PHMSA Pipeline and Hazardous Materials Safety Administration PIP partnership in policing
PM particulate matter
PM10 respirable particulate matter
PPV peak particle velocity
PRC California Public Resources Code
PV photovoltaic
PVC polyvinyl chloride
PWD Public Works Department
RCNM Roadway Construction Noise Model
RCRA Resource Conservation and Recovery Act
REC recognized environmental condition
RHNA Regional Housing Needs Assessment
RMS root mean square
RPS Renewables Portfolio Standard
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SAFE Safer Affordable Fuel-Efficient
SAR Second Assessment Report
SAR service advisory request
SB Senate Bill

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCAR Sewer Capacity Availability Report
SCCIC South Central Coastal Information Center
SCE Southern California Edison
SCS Sustainable Communities Strategy
SEL sound exposure level
SEMS Standard Emergency Management System
SF6 sulfur hexafluoride
SFB San Fernando Basin
SFHA special flood hazard areas
SGC Strategic Growth Council
SGF sewage generation factors
SGMA Sustainable Groundwater Management Act
SGMP soil and groundwater management plan
SIP state implementation plan
SLCP short-lived climate pollutant
SLF Sacred Lands File
SLM sound level meter
SMGSA Santa Monica Basin Groundwater Sustainability Agency SMP Stormwater Management Program
SO2 sulfur dioxide
SO42 sulfates
SoCalGas Southern California Gas Company
SOX sulfur oxides
SRA source receptor area
SRMP Short-Range Mobility Plan
SRRE Source Reduction and Recycling Element
SurveyLA City of Los Angeles Historic Resources Survey
SUSMP Standard Urban Stormwater Mitigation Plan
SVP Society of Vertebrate Paleontology
SWAT special weapons and tactics
SWIRP Solid Waste Integrated Resources Plan
SWP State Water Project
SWPPP Stormwater Pollution Prevention Plan
SWQDv stormwater quality design volume
SWQMP Culver City Stormwater Quality Master Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TAG Transportation Assessment Guidelines
TCO Temporary Certificate of Occupancy
TDM transportation demand management

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TDS total dissolved solids
TEN transit enhanced network
TeNS Technical Noise Supplement
TMDL total maximum daily load
TNM Traffic Noise Model
TOD transit-oriented development
TPA Transit Priority Area
TPH total petroleum hydrocarbons
TSCA Toxic Substances Control Act
TSCG Transportation Study Criteria and Guidelines
UFC Uniform Fire Code
UFMP Urban Forest Master Plan
ULARA Upper Los Angeles River Area
USDOT U.S. Department of Transportation
USEPA U.S. Environmental Protection Agency
USGBC United States Green Building Council
UST underground storage tank
UWMP Urban Water Management Plan
VCP verified clay pipe
VdB decibel notation
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic compound
WBMWD West Basin Municipal Water District
WDI Waiver of Dedication and Improvement
WDR waste discharge requirement
WSA water supply assessment
WSAP Water Supply Allocation Plan
WSCP Water Shortage Contingency Plan
WSV water supply verification
ZEV zero-emission vehicle
ZI zoning information
ZNE zero net energy

9. Standard Terms, Acronyms, and Abbreviations

City of Culver City 9-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

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City Council Meeting AgendaNovember 11, 2024

City Council Meeting Agenda
November 11, 2024