• Threshold TR-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); o Impact conclusion: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) and impacts would be less than significant.
• Threshold TR-4: Result in inadequate emergency access. o Impact conclusion: The Project would not result in inadequate emergency access and impacts would be less than significant.
Proposed Project Expected Transportation Impacts
The Proposed Project involves the inclusion of the following subdivision ordinance amendments:
• Streamline approval for Parcel Maps, Tract Maps, Final Maps, Lot Mergers and Lot Line Adjustments, through allowing Director approval for Parcel Maps that are for four (4) or fewer parcels, creation of clear objective standards and requirements for Parcel Maps and provide definitions and a procedural process for reversion to acreage map, lot line adjustments, and lot mergers.
• In order to comply with SB 9 and SB 684, adopt new sections for Urban Lot Splits and Multi-Family Zone Lot Splits, which would allow for subdivision of R1 zoned lot into two individual parcels ministerially approve, without discretionary review or a hearing, a Parcel Map or a Tentative and Final Map for a housing development project that fulfills certain density requirements.
• Incorporate objective design standards for subdivisions and small lot subdivisions, which would create specific and enforceable rules regarding design for all subdivisions and small lot projects, including building orientation, primary entryways, façade articulation, roofline variation, building modulation, pedestrian pathways, landscaping, and common open space areas.
With these amendments, the Proposed Project seeks to make the process for development of subdivisions more straightforward, resulting in system that is simpler for the City to administer and for developers to follow, as well as more compliant with state standards.
These changes outlined in the Proposed Project are not anticipated to result in different transportation impact results. A discussion of some specific aspects follows:
• Threshold TR-1: The Proposed Project is not at odds with existing programs, plans, ordinances or policies. It aligns with the City’s goals from the General Plan 2045 Housing Element, such as:
Culver City Subdivision Ordinance Update Transportation Impacts October 2, 2024
o Policy 2.D: Encourage the incremental infilling of residential neighborhoods to enhance housing affordability and supply through the provision of smaller units. o Policy 6.E: Continue to evaluate and reduce regulatory and procedural barriers to housing production, such as streamlining the entitlement, environmental, and building permit processes for households of all income levels and those with special needs.
Furthermore, the Proposed Project is consistent with SB9, which requires ministerial approval of specific types of two-unit and subdivision developments as well as imposing objective zoning, subdivision, and design review standards, and with SB684, which requires a local government to ministerially approve, without discretionary review or a hearing, a Parcel Map or a Tentative and Final Map for a housing development project that meets certain requirements. As there is no change to the circulation system assumptions, the impact conclusions from the General Plan 2045 EIR would remain the same.
• Threshold TR-2: The Proposed Project seeks to allow for different types of subdivisions, which will result in different types of home access and ownership availability. It is not a change to the zone definitions. Moreover, the City already has several items in place to reduce VMT where possible, such as Culver City Municipal Code Section 7.05.015, which requires a TDM program, including measures that aim to reduce the number of vehicle trips that would occur in the City as a result of new development of 25,000 gross square feet or more.
For the General Plan 2045, VMT assessment of the entire City was completed using the Culver City Citywide Travel Demand Forecasting Model to obtain daily vehicle trips, daily VMT, and VMT per capita metrics. The buildout the development resulting from the General Plan 2045 would result in decreases in average daily VMT per capita and VMT per employee; however, neither of these metrics would be below the established 15 percent threshold required. Total VMT per service population would not decrease compared to the baseline scenario. Even with implementation of all goals and policies contained in the Mobility Element that would promote transit priority lanes, multimodal connectivity, integrated public transportation services, and prioritize public transit and mobility service such as Policies M-2.3, M-2.5, M-4.1, and M-4.8, the proposed General Plan 2045 would not meet the 15 percent VMT reduction threshold.
As such, VMT per capita, VMT per employee, and VMT per service population would likely not change or may slightly improve by condensing the housing assumptions into these more streamlined locations. With no increase in the total number of units and marginally Culver City Subdivision Ordinance Update Transportation Impacts October 2, 2024
increased housing density, the impact conclusions from the General Plan 2045 EIR would remain the same.
• Threshold TR-3: The General Plan 2045 EIR emphasizes safety through policies that promote transition and buffer areas between land uses that vary in intensity, adequate sight distance at conflict points, and improve safety through related infrastructure design recommendations. The Proposed Project does not diverge from any of these policies or aims. As such, impact conclusions from the General Plan 2045 EIR would remain the same.
• Threshold TR-4: Development based on the program from the General Plan 2045 is compliant with the City’s design guidelines that incorporate safety and emergency access needs, where applicable, and individual developments would need prove consistency as well through the development review process. The Proposed Project does not make changes that would alter this assertion. The Proposed Project is not expected to increase housing density in areas that would be more difficult for emergency services to access, nor does it increase the total amount of housing significantly as such, impact conclusions from the General Plan 2045 EIR would remain the same.
!t
Appendix D
Final Initial Study - Negative Declaration
Culver City Subdivision Ordinance Update
Final Initial Study – Negative Declaration
prepared by
City of Culver City
Planning and Development Department
9770 Culver Boulevard
Culver City, California 90232
Contact: Jose Mendivil, Associate Planner
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
February 2025
Culver City Subdivision Ordinance Update
Final Initial Study – Negative Declaration
prepared by
City of Culver City
Planning and Development Department
9770 Culver Boulevard
Culver City, California 90232
Contact: Jose Mendivil, Associate Planner
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
February 2025
This report prepared on 50% recycled paper with 50% post-consumer content.
Table of Contents
Final Initial Study – Negative Declaration i
Table of Contents
1 Introduction ................................................................................................................................ 1-1
1.1 Format of the Final IS-ND ................................................................................................ 1-1
1.2 Summary of the Project .................................................................................................. 1-1
1.2.1 Summary of Proposed Subdivision Ordinance Amendments ......................... 1-2 2 Responses to Comments ............................................................................................................ 2-1
City of Culver City
Culver City Subdivision Ordinance Update
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Introduction
Final Initial Study-Negative Declaration 1-1
Introduction
This Final Initial Study – Negative Declaration (IS-ND) has been prepared for the City of Culver City (hereafter referred to as “City” or “Culver City”) for the Subdivision Ordinance Update Project (hereafter referred to as “proposed project” or “project”). This Final IS-ND has been prepared in conformance with the California Environmental Quality Act (CEQA) of 1970 statues (California Public Resources Code, Section 21000 et. seq., as amended) and implementing guidelines (California Code Regulations, Title 14, Section 15000 et. seq.).
The IS-ND was circulated for a 30-day public review period that began on December 19, 2024 and ended on January 21, 2025. The City has the principal responsibility for approval of the project and is therefore considered the lead agency under CEQA Section 21067.
1.1 Format of the Final IS-ND
The Final IS-ND consists of the following sections:
Introduction. This section summarizes the contents of the Final IS-ND, the environmental review process, and provides a summary of the project characteristics. Response to Comments. During the public review period for the IS-ND, two written comment letters were received. This section contains the comment letters for the IS-ND and the City’s responses to the comments.
1.2 Summary of the Project
The following is a summary of the full project description, which can be found in Section 6, Description of Project, of the IS-ND.
The proposed project involves amendments to the Culver City Municipal Code (CCMC), which includes Chapter 15.10, Subdivisions, and Section 17.400.040, Condominium Conversions, to facilitate streamlined review of qualifying parcels or tract maps for housing and mixed-use developments. The proposed amendments would also allow ministerial approvals of subdivisions when in compliance with State law. Specifically, Culver City would incorporate: Senate Bill (SB) 9 requirements and regulations for the subdivision of Single-Family Residential District (R1) zoned lots into two individual parcels; SB 684 requirements to ministerially approve a parcel map or a tentative and final map for a housing development project that contains 10 or fewer lots, 10 or fewer residential units, and located on a site that is no larger than five acres and is substantially surrounded by qualified urban uses; and other provisions required by State Law. In addition, the proposed project would amend map standards specific to small lot subdivisions and include specific procedures for certificates of compliance, lot mergers, and lot line adjustments consistent with the State Subdivision Map Act. Lastly, the proposed project would add objective subdivision design standards and new processes for small lot subdivisions. No construction activities are included under the proposed project.
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Culver City Subdivision Ordinance Update
1-2
1.2.1 Summary of Proposed Subdivision Ordinance
Amendments
1.2.1.1 Streamline Approval for Parcel Maps, Tract Maps, Final Maps, Lot Mergers and Lot Line Adjustments
California Government Code Section 66415 defines the "Advisory Agency" as “a designated official or an official body charged with the duty of making investigations and reports on the design and improvement of proposed divisions of real property, the imposing of requirements or conditions thereon, or having the authority by local ordinance to approve, conditionally approve, or disapprove maps.” The Advisory Agencies presiding over subdivisions include the City’s Planning and Development Director, City Engineer, the Planning Commission, and City Council. As part of regulating such developments as small lot subdivisions, the Advisory Agency can issue decisions, based on standards that regulate the design and improvements of a parcel or tract map such as access, utility easements, maintenance agreements, guest parking, trash enclosures, and open space. While design standards govern the three-dimensional structures on the site, the map standards govern the design and improvements on the two-dimensional parcel and tract map.
The City’s Subdivision Code currently provides procedures for parcel maps (four or fewer parcels), tentative maps, vesting tentative maps, and final maps. The Subdivision Code does not specifically mention tract maps (five or more parcels), however Sections 15.10.200 through 15.10.285, Tentative Maps, were used to process tract maps. In addition to requirements and procedures for the applications, the Subdivision Code provides design standards and off-site improvement requirements.
The Subdivision Code does not provide definitions, or a procedural process for reversion to acreage map, lot line adjustments, or lot mergers. A clear procedural process for these maps can provide better guidance for developers. Additionally, the 2021-2029 Housing Element includes lot consolidation (mergers) and lot line adjustments as ways to address housing development constraints. Table 1-1 below is a summary of the types of applications and role of the current review authorities.
Table 1-1 Existing Subdivision Review Authorities
Type of Application
Role of Review Authority
Director City Engineer Commission Council
Parcel Map Review Review Approve Appeal
Tentative Map Review Review Recommend Approve
Vesting Tentative Map Review Review Recommend Approve
Final Map Review Review - Approve
The proposed project would also include sections for tract maps, lot mergers, and lot line adjustments to streamline approval for these types of subdivisions that meet specific criteria.
Establishing a procedure for lot mergers would also assist in the development of multifamily housing on small lots. Final maps would be reviewed by the Director and City Engineer for further streamlining. Additionally, the City would streamline the review process for parcel maps and tract maps that have less than 25 units by allowing Director approval for these subdivisions. The proposed project also includes the creation of clear objective standards and requirements for subdivisions. The proposed review authorities are outlined in Table 1-2 below.
Introduction
Final Initial Study-Negative Declaration 1-3
Table 1-2 Proposed Subdivision Review Authorities
Type of Application
Role of Review Authority
Director1 City Engineer Commission Council
Lot Line Adjustments2 Review Approve - -
Lot Mergers2 Review Approve - -
Urban Lot Splits (SB 9)2 Approve Review - -
Multi-Family Lot Splits (SB 684)2 Approve Review - -
Parcel Map3 Approve Review Appeal Appeal
Tentative Tract Map3, 4 Approve Review Appeal Appeal
Tentative Tract Map3, 5 Review Review Approve Appeal
Vesting Tentative Map3 Review Review Approve Appeal
Final Map2 - Approve - -
Certificates of Compliance2, 6 - Approve - -
1 Planning Director or Designee (Current Planning Staff) 2 Non-discretionary with no appeal process
3 Including Small Lot Subdivisions
4 When processed in conjunction with an Administrative Site Plan Review 5 When processed in conjunction with a Site Plan Review 6 Including Conditional Certificates of Compliance
Additionally, the ordinance amendment would require that small lot subdivision projects conform with the small lot design standards through a ministerial administrative clearance process if processing 25 or less lots, or a Site Plan Review if processing more than 25 lots. The establishment of an administrative clearance process for certain projects through an ordinance amendment would enable the City, by local ordinance, to regulate the design of subdivisions and small lot subdivision projects based on the new standards. This enables the design review of the buildings and structures that are proposed with a subdivision project. The application for the administrative clearance could be filed concurrently with the filing of the parcel or tract map application and the environmental clearance. Compliance with the design standards would be a non-appealable administrative process that would be determined prior to the required hearing for the map. Small lot architectural plans found in compliance with all the required design standards would be approved as Exhibit A and included in the subject case file.
1.2.1.2 Small Lot Subdivision Design Standards
Currently, the CCMC does not have standards for small lot subdivisions. The City is in the process of developing objective design standards throughout Culver City. The City has processed small lot subdivisions by utilizing the Exception section of the City’s Subdivision Ordinance (CCMC Section
15.10.085) to allow multiple land lots one behind the other on one multi-family zoned lot without requiring the stem of a flag lot or lots (CCMC Section 15.10.700). The Exception section allows each land lot without the required street frontage; however, the subdivision map requires an access easement for all lots along a common driveway. A subdivision code amendment in addition to small lot design standards would allow small lot development without having to utilize the Exception section. The Small Lot Subdivision would be permitted in the Low Density Multiple-Family Residential (RLD), Medium Density Multiple-Family Residential (RMD), and Two-Family Residential District (R2) zones pursuant to an approved tract or parcel map.
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Culver City Subdivision Ordinance Update
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The proposed project would incorporate objective design standards for subdivisions and small lot subdivisions, which would create specific and enforceable rules regarding design for all subdivisions and small lot projects, including building orientation, primary entryways, façade articulation, roofline variation, building modulation, pedestrian pathways, landscaping, and common open space areas. A complete overview of the small lot subdivision design standards can be found in Appendix B.
Table 1-3 outlines the various elements that regulate subdivision projects and where they would be addressed through modifications to the CCMC, design standards, and map standards.
Table 1-3 Subdivision Regulations
Proposed Items Ordinance Design Standards Map Standards (All Subdivisions and Small Lot Subdivisions)
Minimum Lot Width x
Access Easement x
Lot Coverage x
Front, Side, Rear Yards x
Fences and Walls x x
Building Orientation x
Primary Entryways x
Façade Articulation x
Varied Roofline x
Roof Terraces and Decks x
Building Modulation x
Pedestrian Pathways x
Open Area Landscaping x
Front Yard Landscaping x
Trash Enclosures x
Common Access Driveway x
Common Access Walkway x
Utility Easement x
Maintenance Agreement x
On-Site Trash Collection x
Open Space Easement x
1.2.1.3 Urban Lot Splits and Multi-Family Zone Lot Splits To comply with SB 9 and SB 684, Culver City proposes to adopt new sections under Chapter 15.10 of the CCMC for urban lot splits and multi-family zone lot subdivisions. These new sections would incorporate SB 9 requirements and regulations for the subdivision of R1 zoned lot into two individual parcels, as well as incorporate SB 684 requirements to ministerially approve, without discretionary review or a hearing, a parcel map or a tentative and final map for a housing development project that contains 10 or fewer lots, 10 or fewer residential units, that is located on a lot that is zoned multifamily residential (Low-Density Multiple-Family Residential District [RLD], Medium-Density Multiple-Family Residential District [RMD], and High-Density Multiple-Family Residential District [RHD]), is no larger than five acres, and substantially surrounded by qualified urban uses.
City of Culver City
Culver City Subdivision Ordinance Update Responses to Comments Final Initial Study-Negative Declaration
2 Responses to Comments
This section includes comments received during public circulation of the IS-ND prepared for the Culver City Subdivision Ordinance Update Project.
The IS-ND was circulated for a 30-day public review period that began on December 19, 2024, and ended on January 21, 2025. The City of Culver City Planning and Development Department received two comment letters on the IS-ND. The commenters and the page number on which each commenter’s letter appears are listed below.
Letter No. and Commenter Page No.
1 Andrew Flores 2-2
2 P
eter Stern 2-4
The comment letters and responses follow. The comment letters are numbered sequentially, and each separate issue raised by the commenter, if more than one, has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in Comment Letter 1).
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1-1
Letter 1
2-2
City of Culver City
Culver City Subdivision Ordinance Update Responses to Comments
Final Initial Study-Negative Declaration
Letter 1
COMMENTER: Andrew Flores
DATE: December 19, 2024
Response 1.1
The commenter asks what CRQA stands for which refers to a typological error in the subject line of the email which was meant to say CEQA.
The commentor also states that the Notice of Intent to Adopt a Negative Declaration form used by the City is outdated as it refers to the “Governor’s Office of Planning and Research” which has since changed to the “Governor’s Office of Land Use and Climate Innovation” The City has noted the comment and will update their NOI forms accordingly to refer to “Governor’s Office of Land Use and Climate Innovation.”
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Letter 2
2-1
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City of Culver City
Culver City Subdivision Ordinance Update Responses to Comments
Final Initial Study-Negative Declaration
Letter 2
COMMENTER: Peter Stern
DATE: December 20, 2024
Response 2.1
The commenter expresses concern about the potential environmental impacts from increased housing density such as increased automobile traffic that would result in increased exhaust emissions; increased use of utilities such as electricity, gas, sewer, and water; and increased water use could result in impacts to wildlife and the aquatic biome.
Each of the potential impacts mentioned by the commenter were addressed in the following sections of the IS-ND: Section 3, Air Quality, Section 2, Biological Resources, Section 8, Greenhouse Gas Emission, Section 6, Energy, Section Section 17, Transportation, and Section 19, Utilities and Service Systems. The proposed project involves amending the City’s Subdivision Code to streamline the review and approval of qualifying developments when in compliance with State law, so future development facilitated by the proposed project would not increase the overall development density or scale beyond what is already permitted under existing regulations. Consequently, the project would not have a significant effect on the City’s population growth, density, or demographics. As a result, no impacts associated with air emissions, biological resources, transportation, energy, or utilities and service systems impacts would occur and no mitigation measures are required.
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City of Culver City
Culver City Subdivision Ordinance Update Responses to Comments
Final Initial Study-Negative Declaration
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