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Attachment 12 - CEQA Clearance Documentation (including attachments)

City Council Meeting Agenda
February 9, 2026

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Attachment 12 - CEQA Clearance Documentation (including attachments)
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5757 UPLANDER PROJECT
CEQA Guidelines Section 15168(c) Clearance

Prepared for October 2025
City of Culver City

Attachment 12 - CEQA Clearance Documentation

5757 UPLANDER PROJECT
CEQA Guidelines Sections 15168(c) Clearance

Prepared for October 2025
City of Culver City

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Los Angeles, CA 90071
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5757 Uplander Project i City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

CONTENTS
5757 Uplander Project
Page
Chapter 1. Introduction .................................................................................................................. 1-1

1.1 Statutory Authority and Regulations .............................................................................. 1-2

1.2 Previous Environmental Documents Incorporated by Reference ................................... 1-5 Chapter 2. Project Description ...................................................................................................... 2-1

2.1 Project Location and Surrounding Land Uses ................................................................ 2-1

2.2 Existing Project Site Conditions ..................................................................................... 2-4

2.3 General Plan Land Use and Zoning ............................................................................... 2-4

2.4 Description of the Proposed Project .............................................................................. 2-5

2.4.1 Proposed Land Uses ........................................................................................... 2-5

2.4.2 Landscaping and Open Space .......................................................................... 2-16

2.4.3 Height, Density, and Setbacks .......................................................................... 2-17

2.4.4 Architectural Design .......................................................................................... 2-24

2.4.5 Access, Circulation, and Parking ....................................................................... 2-27

2.4.6 Lighting and Signage ........................................................................................ 2-31

2.4.7 Site Security ...................................................................................................... 2-31

2.4.8 Sustainability Features ...................................................................................... 2-31

2.4.9 Project Construction and Phasing ..................................................................... 2-32

2.4.10 Necessary Approvals ........................................................................................ 2-33

2.4.11 Project Design Features (PDFs) ....................................................................... 2-33 Chapter 3. Comparative Analysis of Project Impacts ................................................................. 3-1

3.1 Aesthetics ...................................................................................................................... 3-3

3.2 Air Quality .................................................................................................................... 3-10

3.3 Biological Resources ................................................................................................... 3-29

3.4 Cultural Resources ...................................................................................................... 3-36

3.5 Energy ......................................................................................................................... 3-42

3.6 Geology and Soils ........................................................................................................ 3-49

3.7 Greenhouse Gas Emissions ........................................................................................ 3-61

3.8 Hazards and Hazardous Materials ............................................................................... 3-75

3.9 Hydrology and Water Quality ....................................................................................... 3-84

3.10 Land Use and Planning ................................................................................................ 3-99

3.11 Mineral Resources ..................................................................................................... 3-107

3.12 Noise .......................................................................................................................... 3-109

3.13 Population and Housing ............................................................................................. 3-136

3.14 Public Services .......................................................................................................... 3-140

3.15 Recreation ................................................................................................................. 3-153

3.16 Transportation ............................................................................................................ 3-157

3.17 Tribal Cultural Resources .......................................................................................... 3-168

3.18 Utilities and Service Systems ..................................................................................... 3-172

3.19 Wildfire ....................................................................................................................... 3-190

3.20 Cumulative Impacts ................................................................................................... 3-195

3.21 Mandatory Findings of Significance ........................................................................... 3-197 Contents
5757 Uplander Project ii City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Chapter 4. Conclusion ................................................................................................................... 4-1

Figures
Figure 1 Regional and Project Vicinity Location ........................................................................... 2-2 Figure 2 Project Location – Aerial Photograph ............................................................................ 2-3 Figure 3 Conceptual Site Plan ..................................................................................................... 2-6 Figure 4 Building 1 Level 1, Buildings 2 & 3 Level P1 .................................................................. 2-8 Figure 5 Building 1 Level 2, Buildings 2 & 3 Level 1 .................................................................... 2-9 Figure 6 Building 1 Level 3, Buildings 2 & 3 Level 2 .................................................................. 2-10 Figure 7 Building 1 Level 4, Buildings 2 & 3 Level 3 .................................................................. 2-11 Figure 8 Building 1 Level 5, Buildings 2 & 3 Level 4 .................................................................. 2-12 Figure 9 Building 1 Level 6, Buildings 2 & 3 Level 5 .................................................................. 2-13 Figure 10 Building 1 Level 7, Buildings 2 & 3 Level 6 .................................................................. 2-14 Figure 11 Buildings 2 & 3 Level 7 ................................................................................................ 2-15 Figure 12 Elevation – Building 1 .................................................................................................. 2-18 Figure 13 Elevation – Building 2 .................................................................................................. 2-19 Figure 14 Elevation – Building 3 .................................................................................................. 2-20 Figure 15 Overall Elevation – Uplander Way ............................................................................... 2-21 Figure 16 Building Sections East–West ....................................................................................... 2-22 Figure 17 Building Sections North–South .................................................................................... 2-23 Figure 18 Conceptual Project Rendering – Public Plaza on Hannum Avenue ............................. 2-25 Figure 19 Conceptual Project Rendering – Hannum/Bristol Southeasterly View ......................... 2-26 Figure 20 Conceptual Project Rendering – Uplander Way East .................................................. 2-28 Figure 21 Conceptual Project Rendering – Uplander Way South ................................................ 2-29 Figure 22 Noise Measurement Locations .................................................................................. 3-111 Figure 23 Proposed Noise Barrier Mitigation Scenarios ............................................................ 3-129

Tables
Table 1 Project Development Summary ..................................................................................... 2-6 Table 2 Open Space Summary................................................................................................. 2-17 Table 3 Summary of Project Design Features .......................................................................... 2-33 Table 4 Estimated Maximum Unmitigated Localized Construction Emissions (pounds per day) .......................................................................................................... 3-11 Table 5 Estimated Maximum Unmitigated Localized Operational Emissions (pounds per day) .......................................................................................................... 3-13 Table 6 Estimated Maximum Unmitigated Regional Construction Emissions (pounds per day) .......................................................................................................... 3-18 Table 7 Estimated Maximum Unmitigated Regional Emissions from Interim Operations and Concurrent Construction (pounds per day) ........................................................... 3-20 Table 8 Estimated Maximum Unmitigated Regional Full Buildout Operational Emissions (pounds per day) .......................................................................................................... 3-20

Table 9 Maximum Health Risk Impacts for Off-Site Sensitive and Commercial Receptors ...... 3-24 Table 10 Project Construction Energy Usage ............................................................................. 3-43 Table 11 Summary of Annual Energy Use During Project Operation ......................................... 3-44 Table 12 Construction Greenhouse Gas Emissions (tons per year) ........................................... 3-62 Table 13 Estimated Annualized Project Greenhouse Gas Emissions ......................................... 3-63 Table 14 Project Compliance with the 2022 Climate Change Scoping Plan: Appendix D Local Actions ............................................................................................................... 3-65 Table 15 Consistency with Applicable Connect SoCal 2024 Goals ............................................ 3-68 Contents

5757 Uplander Project iii City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Table 16 Project Consistency with Applicable Culver City Green Building Program Requirements .............................................................................................................. 3-73 Table 17 Summary of Ambient Noise Measurements ............................................................... 3-112 Table 18 Predicted Existing Vehicular Traffic Noise Levels ...................................................... 3-113 Table 19 Construction Equipment Noise Levels ....................................................................... 3-115 Table 20 Estimated Construction Noise Levels at Existing Off-Site Sensitive Receptors ......... 3-116 Table 21 Estimate of Off-Site Construction Traffic Noise Levels .............................................. 3-117 Table 22 Mechanical Equipment Noise Levels at Noise Sensitive Receptors .......................... 3-118 Table 23 On-Site Parking Noise Levels at Noise Sensitive Receptors ..................................... 3-119 Table 24 Loading Areas and Refuse Collection Noise Levels .................................................. 3-120 Table 25 Composite Noise Impacts .......................................................................................... 3-122 Table 26 Offsite Traffic Noise Impacts – Existing Plus Project Conditions ............................... 3-123 Table 27 Offsite Traffic Noise Impacts – Future Plus Project Conditions .................................. 3-124 Table 28 Vibration Source Levels for Construction Equipment ................................................. 3-131 Table 29 Projected Increases in Population, Housing, and Employment .................................. 3-137 Table 30 General Plan 2045 Population, Household, and Job Growth Projections .................. 3-138 Table 31 Estimated Number of Students Generated by the Project ......................................... 3-149 Table 32 Estimated Operational Wastewater Generation ......................................................... 3-177 Table 33 Project’s Estimated Annual Water Consumption ....................................................... 3-182 Table 34 Projected Normal Year Water Supply and Demand for Culver City Service Area ...... 3-183 Table 35 Single Dry Year Water Supply and Demand for Culver City Service Area ................. 3-183 Table 36 Multiple (Five) Consecutive Dry Years Water Supply and Demand through 2045 for Culver City Service Area ...................................................................................... 3-183

Table 37 Projected Solid Waste Generated during Operation .................................................. 3-188

Appendices
A. Air Quality, Health Risk Assessment, Greenhouse Gas Emissions, and Energy Data B. Tree Inventory Report
C. Historic Resources Memorandum
D. Archaeological Resources Assessment
E. Preliminary Geotechnical Engineering Investigation
F. Paleontological Resources Assessment
G. P hase I Environmental Site Assessment
H. Hydrology and Water Quality Technical Memorandum
I. Noise Data
J. Water Civil Technical Memorandum
K. Transportation Impact Study
L. Wastewater Civil Technical Memorandum
M. Water Supply Assessment

Contents
5757 Uplander Project iv City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

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5757 Uplander Project 1-1 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

CHAPTER 1
Introduction
This document addresses the environmental effects of the proposed 5757 Uplander Project (Project) under Section 15168(c) of the California Environmental Quality Act (CEQA) Guidelines. Section 15168(c) of the CEQA Guidelines sets forth criteria to utilize a program Env ironmental Impact Report ( EIR) for “later activities” within the scope of a program EIR. The City certified a programmatic EIR to evaluate the potential environmental impacts of approving the Culver City General Plan 2045 and Zoning Code Update Project in September 2024. The General Plan 2045 and Zoning Code Update Program EIR (State Clearinghouse No. 2022030144) (Programmatic EIR or Certified PEIR) evaluated the anticipated development within the City of Culver City (City), including the anticipated development on the Project Site.1 The Project proposes to develop a mixed-use residential and commercial project on an approximately 8.34- acre (363,199 square feet [sf]) site (Project Site) located on four Assessor Parcel Numbers (APN) 4134 - 005-021 (5800 Hannum Avenue), 4134 -005-004 (6031 Uplander Way), 4134- 005-003 (5821 Uplander Way) and 4134-005 -002 (5835 Sumner Way, Bldg E), within the Fox Hills neighborhood of the City of Culver City (City). The Project Site is currently developed with four existing one - to two-story business park buildings totaling approximately 146,414 sf and associated surface parking, all of which would be removed to accommodate development of the Project.

The Project would develop three new seven-story mid-rise buildings with a maximum height of 93 feet and six inches. The three buildings, referred to herein as Buildings 1, 2 and 3, would generally be situated in the northern, central and southern portions of the Project Site, respectively. Building 1 would contain 382 residential units and a ground-level, approximately 5,772 sf retail space fronting Hannum Avenue.

Buildings 2 and 3 would include 349 and 346 units, respectively, with no retail use, and would be located south of Building 1. Overall, the Project’s proposed uses include 5,772 square feet of retail space and 1,077 residential units. At this density, there would be 129.14 units per acre. The Project is proposing to include 78 Very -Low Income affordable housing units to allow an a dditional 243 density bonus units to be developed as part of the Project, which are included within the Project’s 1,077 total units.

Each of the Project’s three buildings would have a contiguous retail/lobby/parking level at grade with upper buildings (structural components) on the east and west sides of the Project Site separated by a planted, publicly-accessible central pedestrian passage at the Project’s ground/lower levels. The centrally located paseo would span across the entirety of the Project Site from north to south connecting Hannum Avenue to Uplander Way and would be privately owned.

1 A copy of the certified programmatic Final EIR for the General Plan 2045 can be found at https://www.culvercity.org/files/content/public/v/7/city-hall/city-departments/planning-and-development/advance-planning- division/zz.-general-plan-2045-environmental-review/final-peir.pdf.

1. Introduction
5757 Uplander Project 1-2 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Each of the three buildings would have its own dedicated parking areas located within a combination of subterranean (up to two levels) and podium parking levels. Overall, the Project would include a total of 1,303 vehicular parking spaces ( 1,283 residential and 21 commercial). Four points of vehicular access would be provided to the Project Site, including three driveways along Uplander Way (two on the east and one on the south) and a driveway connecting to Bristol Parkway. One of the points of access along Uplander Way (to the east of the Project Site) between Buildings 2 and 3 would provide access only for emergency vehicles (fire lane). The Project would also provide a total of 305 commercial and residential bicycle spaces to comply with Culver City Municipal Code (CCMC) requirements The Project proposes to maintain the site’s Mixed Use High General Plan land use and zoning designations.

The Project is seeking a Density and Other Bonus Incentives (DOBI) approval to allow increased density with affordable units incorporated into the Project as well as a height incentive, and approval for Extended Hours of Construction per CCMC Section 9.07.035.C.1. The Project is requesting a Vesting Tentative Parcel Map to consolidate the existing four Project Site parcels and subsequently divide the P roject Site into three parcels, each of which will contain one of the three Project buildings. Finally, the Project will require Site Plan Review to construct a new residential project with more than 26 units. (CCMC Section 17.540).

Based on the Certified PEIR’s analysis and pursuant to CEQA Guidelines Section 15168(c), the City has prepared this written checklist to evaluate the Project -specific environmental impacts and determine whether the Project -specific environmental effects would be within the scope of the Certified P EIR. As analyzed herein and demonstrated below, the Project is “within the scope” of the Certified P EIR pursuant to CEQA Guidelines Section 15168(c)(2), and no further environmental analysis is required.

For each impact area addressed under CEQA, this document describes and relies on the analysis in the Certified PEIR. This document relies on and incorporates the applicable and feasible mitigation measures from the Certified PEIR.
2 1.1 Statutory Authority and Regulations
CEQA Guidelines Section 15168(c) permits the lead agency to approve a subsequent activity or project if it is found to be “within the scope” of a certified Program EIR, provided that no subsequent EIR would be required pursuant to CEQA Guidelines Section 15162. Whether a later activity is within the scope of the Program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that the lead agency may consider in making that determination include, but are not limited to, consistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts and covered infrastructure as described in the Program EIR.
3 2 The mitigation measures incorporated herein were taken from the General Plan 2045 and the Zoning Code Update Project PEIR Mitigation Monitoring Program (MMP), dated July 2024, https://www.culvercity.org/files/content/public/v/7/city- hall/city-departments/planning-and-development/advance-planning-division/zz.-general-plan-2045-environmental- review/final-peir.pdf.
3 CEQA Guidelines Section 15168(c)(2).

1. Introduction

5757 Uplander Project 1-3 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

CEQA Guidelines Section 15168(a) defines a program EIR as:
[A]n EIR which may be prepared on a series of actions that can be characterized as one large project and are related either:
(1) Geographically,
(2) As logical parts in the chain of contemplated actions, (3) In connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program, or
(4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

CEQA Guidelines Section 15168(c) sets forth criteria to use a program EIR for “later activities.” Specifically, CEQA Guidelines Section 15168(c) states the following:
(c) Use with Later Activities. Later activities in the program must be examined in the light of the program EIR to determine whether an additional environmental document must be prepared. (1) If a later activity would have effects that were not examined in the program EIR, a new Initial Study would need to be prepared leading to either an EIR or a Negative Declaration. That later analysis may tier from the program EIR as provided in Section 15152. (2) If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required. Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record. Factors that an agency may consider in making that determination include, but are not limited to, co nsistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure, as described in the program EIR. (3) An agency shall incorporate feasible mitigation measures and alternatives developed in the program EIR into later activities in the program.
(4) Where the later activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR. (5) A program EIR will be most helpful in dealing with later activities if it provides a description of planned activities that would implement the program and deals with the effects of the program as specifically and comprehensively as possible. With a good and detailed project description and analysis of the program, many later activities could be found to be within the scope of the project described in the program EIR, and no further environmental documents would be required.

1. Introduction
5757 Uplander Project 1-4 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Section 15162 of the CEQA Guidelines requires the preparation of a Subsequent EIR when an EIR has been certified or a negative declaration has been adopted for a project and one or more of the following circumstances exist:

1. Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:
a. The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
b. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or d. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

There is no basis to find that any of the criteria in Section 15162 have been met such that a major revision to the Certified PEIR is required. As an initial matter, the analysis provided below shows the Project would not result in a change to the Project analyzed in the Programmatic EIR that would result in any new significant impacts or more severe significant impacts than those identified in th e Certified PEIR as the Project is within the scope of and is consistent with the City’s General Plan 2045. Additionally, there have been no changes to the General Plan 2045 since its adoption that resulted in or will foreseeably result in new significant impacts or more severe significant impacts. Based on the number of projects that have been approved so far by the City, the increase in the number of residential dwelling units analyzed in the Certified PEIR has not been met for the General Plan 2045 buildout. There is no basis to find there has been a change to the project analyzed in the Certified PEIR such that there will be new or more severe significant impacts.

Additionally, there have been no substantial changes with respect to the circumstances under which the project was undertaken that are expected to result in new or more severe significant impacts. There is no new information of substantial importance that was not known or could not have been known when the Programmatic EIR was certified and the General Plan 2045 adopted by the City. Finally, no mitigation measures were identified that were previously found not to be feasible that would in fact be feasible to substantially reduce the Project’s significant impacts but that the Project applicant declined to adopt. Also, there are no mitigation measures that are considerably different from those analyzed in the Certified PEIR that would substantially reduce the Project’s significant effects on the environment but that the Project applicant declined to adopt.

1. Introduction

5757 Uplander Project 1-5 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

1.2 Previous Environmental Documents Incorporated by
Reference
Consistent with Section 15150 of the CEQA Guidelines, the following documents were used in preparation of this document and are incorporated herein by reference:
• General Plan 2045 and Zoning Code Update Program EIR, State Clearinghouse (SCH) No. 2022030144, 2024; and
• City of Culver City, General Plan 2045, 2024.

Pursuant to CEQA Guidelines Section 15150(b), the above documents are available for review at the following location during the hours of 7:30
A.M. and 5:30 P.M.

Culver City Hall
9770 Culver Boulevard, 2nd Floor
Culver City, CA 90232
The above documents are also available for review at the Planning and Development Department’s webpage at:

General Plan 2045 Environmental Review - City of Culver City (https://www.culvercity.org/City- Hall/City-Departments/Planning-and-Development/Advance-Planning-Division/ZZ.-General-Plan-2045- Environmental-Review ) and Advance Planning Division - City of Culver City (https://www.culvercity.org/City-Hall/City-Departments/Planning-and-Development/Advance-Planning- Division ), respectively.

1. Introduction
5757 Uplander Project 1-6 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

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5757 Uplander Project 2-1 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

CHAPTER 2
Project Description

2.1 Project Location and Surrounding Land Uses
The Project Site is located in an urbanized area of the southeastern portion of the City with regional access provided by the San Diego Freeway (I -405) and California State Route 90 (SR -90), each located approximately 0.5 miles west of the Project Site. Local access to the Project Site is provided via Hannum Avenue, Bristol Parkway, and Uplander Way. The Project Site is located 0.4 mile east of the Culver City Transit Center. A northwest portion of the Project Site is located in one of four Transit Priority Areas (TPA) identified in the July 13, 2020, Transportation Study Criteria and Guidelines. A project in one of these four TPAs is not required to conduct a Vehicles Miles Travelled (VMT) analysis. However, since most of the Project Site falls outside a TPA, this Project will conduct a VMT study. See Figure 1, Regional and Project Vicinity Location, for the location of the Project Site. See Figure 2, Project Location – Aerial Photograph, for an aerial image of the Project Site and surrounding development.

The area surrounding the Project Site is developed primarily with business park and office uses, with multiple- family residential uses occurring further to the east. Specifically, the surrounding land uses include:
• North – Land uses to the north across Hannum Avenue have a General Plan land use designation of Mixed Use Medium. Office uses directly north of the site are part of the larger office complex knows as Corporate Pointe, which is bounded by Hannum Avenue to the west and south, Bristol Parkway to the south and east, and Slauson Avenue to the north. Within Corporate Pointe, between Bristol Parkway and Buckingham Parkway, there are six office buildings (up to 12 stories) and three parking structures (up to eight stories).

Beyond Corporate Pointe is the Holy Cross Cemetery, with a General Plan land use designation of Cemetery. • West – Because of the irregular shape of the Project Site, land uses to the west of the Project Site are located on both sides of Bristol Parkway. Immediately adjacent to the central portion of the Project Site is Culver City Fire Department Station No. 3. Directly south of the Fire Station at the northeast corner of Bristol Parkway and Uplander Way is a two-story medical office building. Across Bristol Parkway is a two-story office building complex. Land uses to the west have a General Plan land use designation of Mixed Use High. • East – Low-rise one- to two- story business park buildings are located across Uplander Way to the east of the Project Site. These buildings have a General Plan land use designation of Mixed Use High. Beyond the intervening business park buildings are multi-family residential uses on the east side of Buckingham Parkway located approximately 400 feet from the Project Site at their nearest point. • South – Because of the curved nature of Uplander Way, Uplander Way4 also borders the Project Site to the south. On the south side of Uplander Way are low -rise one- to two- story business park buildings, which have a General Plan land use designation of Mixed Use High. Beyond the business park buildings is Fox Hills Park, with a land use designation of Open Space.

4 The portion of Uplander Way on the south side of the Project Site is also known as Sumner Way. For purposes of this document, “Uplander Way” is used to describe the Project’s southern boundary. "' N
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5757 Uplander Project
Figure 1
Regional and Project Vicinity Location
SOURCE : ESA, 2025 5757 Uplander Project
Figure 2
Project Location - Aerial Photograph

2. Project Description
5757 Uplander Project 2-4 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

2.2 Existing Project Site Conditions
The Project Site is currently developed with four one - to two -story business park/office buildings, constructed between 1978-1980, which total approximately 146,414 sf. The remainder of the Project Site includes associated surface parking and landscaping. There are sidewalks along each of the roadways surrounding the Project Site, none of which contain street trees. The buildings and surface parking uses are on slightly graded land, with a change in topography of less than approximately 16 feet along Upland er Way and Bristol Parkway generally sloping up from northwest to southeast.

Existing vehicle access to the Project Site is provided via eight ingress and egress points, four of which are located along the east side of Uplander Way, three along the south side of Uplander Way and one on Bristol Parkway. Hannum Avenue, an east–west roadway adjacent to the Project Site, abuts the northern boundary of the Project Site and includes on -street parking on its shoulder side adjacent to the Project Site only and bicycle lanes in both directions, but provides no direct vehicular access to the Project Site. Bristol Parkway abuts the northwestern boundary of the Project Site and contains no curbside parking due to the presence of the nearby Fire Station, and no bicycle lanes, but provides one direct access driveway to the Project Site.

Uplander Way to the south provides on-street parking on both sides, but no bicycle lanes.

In addition to the existing building and associated surface parking, there is a mix of ornamental landscaping and trees are scattered throughout interior and perimeters of the Project Site. There are 334 trees on the Project Site including Canary Island pines, lemon-scented eucalyptus, African fern pines, Brazilian pepper, California pepper, Callery pear, Canary Island date palm, carrotwood, Chinese elm, evergreen pear, London plane, Mexican fan palm, purple leaf plum, red ironbark, and silver dollar gum. No native or heritage trees were observed during the tree survey prepared for the Project.

2.3 General Plan Land Use and Zoning
Effective as of October 9, 2024, as part of a City -wide update of its General Plan and Zoning Code, the Project Site’s General Plan designation changed from Commercial Regional Center to Mixed Use High, and the Project Site’s zoning changed from Commercial Regional Business Park to Mixed-Use High (MU- HD). The General Plan Land Use designation Mixed Use High allows large-scale mixed use, residential, and commercial projects. The Mixed Use High designation allows densities up to 100 units per acre. The MU-HD Zoning District identifies areas appropriate for large-scale residential, office, and commercial uses emphasizing a variety of retail uses, including anchor tenants, entertainment, and restaurant uses that may share parking and serve a regional market area per CCMC Section 17.220.010. It also allows densities up to 100 units per acre per Table 2-8 in CCMC Section 17.220.020. The City adopted its 2021–2029 Housing Element on January 24, 2022 (2022 Housing Element). Pursuant to the adopted Housing Element, the Property is indicated on the Housing Element Sites Inventory as Mixed-Use High, which allows for high - density residential uses, including mixed-use developments. The 2022 Housing Element’s Mixed-Use High designation also anticipates a residential density of 100 dwelling units per acre, consistent with the General Plan Mixed Use High land use designation for the Project Site.

Pursuant to State Density Bonus Law (Government Code Section 65915 et al.) and the City’s Density Bonus and Other Bonus Initiatives program (CCMC Section 17.580 et al.), the Project proposes a density increase and height incentive in return for reserving 78 of the Project units as affordable for Very Low Income (VLI) households for a period of 55 years . Specifically, the Project seeks a 20% density increase on Parcel 1, a

2. Project Description

5757 Uplander Project 2-5 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

50% density increase on Parcel 2, and a 30% density increase on Parcel 3.5 Consistent with State Density Bonus Law, setting aside 78 units (17 units on Parcel 1, 36 units on Parcel 2, and 25 units on Parcel 3) for VLI households allows the Project more units than permitted under the General Plan and zoning designation density of 100 dwelling units per acre. Setting aside 78 units also provide s the Project development incentives and waivers; the Project is therefore seeking a building height of up to 93 feet and six inches, which exceeds the current zoning limit on the Property of 56 feet. The Project is requesting a waiver of any dedication requirements imposed as part of the Safer Fox Hills program, including along Hannum Avenue.

It is also requesting a waiver from CCMC Section 17.320.050 to allow overhead clearance of 12 feet, 9 inches instead of the required 14 feet. The Project’s proposed unit count and height would be consistent with State Density Bonus Law that permits the Project to exceed 100 dwelling units per acre and 56 -foot height with the inclusion of the Project’s affordable housing component.

2.4 Description of the Proposed Project

2.4.1 Proposed Land Uses
The Project would demolish the existing surface parking, landscaping and four, one - to two-story office buildings and construct three new seven-story mid-rise buildings with a maximum height of 93 feet and six inches. Buildings 1, 2, and 3 would generally be situated in the northern, central and southern portions of the Project Site, respectively. The Project entitlements include a Vesting Tentative Parcel Map and Final Map to consolidate the existing four Project Site parcels and subsequently divide the Project Site into three parcels – referred to Parcel 1, Parcel 2, and Parcel 3. Each of the new parcels will contain one of the three Project buildings. On Parcel 1, Building 1 would contain 382 residential units and a ground-level, approximately 5,772 sf re tail space fronting Hannum Avenue. On Parcel 2 and Parcel 3, respectively, Buildings 2 and 3 would include 349 and 346 units, respectively, with no retail use. Overall, the Project’s proposed uses include 5,772 sf of retail space and 1,077 residential units. The Project’s total net residential floor area would be 1,100,386 sf consisting of 145 studio units, 644 1-bedroom units, and 288 2-bedroom units. At this density, there would be approximately 129 units per acre. The Project is proposing to include 78 VLI affordable housing units (17, 36, and 25 on the new Project Site parcels, respectively), which would allow an additional 243 density bonus units to be developed as part of the Project and are included within the Project’s 1,077 total units. A summary of the Project’s proposed land uses is provided in Table 1, Project Development Summary.

Figure 3, Conceptual Site Plan, provides an illustration of the conceptual site plan for the Project. Figures 4 to 11 illustrate the floor plans for the Project’s proposed uses. As shown on Figure 4, Building 1 Level 1, Buildings 2 & 3 Level P1 , 1 2 residential units would be situated along the northwestern and northern boundaries of the Project Site, along with the 5,772 sf retail space and residential lobbies and amenities, including mail rooms and a fitness center. The figure also illustrates the available vehicular parking spaces for Buildings 1, 2, and 3, including the Project’s retail parking spaces.

Figure 5, Building 1 Level 2, Buildings 2 & 3 Level 1 , illustrates the residential units, parking spaces, and amenity spaces at each of the buildings. Figure 6, Building 1 Level 3, Buildings 2 & 3 Level 2, similarly illustrates the residential units and parking spaces, as well as amenity spaces, occurring on the next level. Figure 7, Building 1 Level 4, Buildings 2 & 3 Level 3, Figure 8, Building 1 Level 5, Buildings

5 “Parcels” are defined under Subsection 2.5, Development Program, below.

2. Project Description
5757 Uplander Project 2-6 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

2 & 3 Level 4 , Figure 9, Building 1 Level 6, Buildings 2 & 3 Level 5 , Figure 10, Building 1 Level 7, Buildings 2 & 3 Level 6 , and Figure 11, Buildings 2 & 3 Level 7 , illustrate the layouts of each of the buildings’ Levels 3-7, respectively, with their respective residential units, amenity areas, and trash rooms shown therein.

TABLE 1

PROJECT DEVELOPMENT SUMMARY
Building 1 Building 2 Building 3 Project Total
Studio Units 42 42 61 145
1-BR Units 221 224 199 644
2-BR Units 119 83 86 288
Total Units 382 349 346 1,077
Net Residential Floor Areaa 404,021 sf 349,217 sf 347,148 sf 1,100,386 sf Retail Square Footagea 5,772 sf — — 5,772 sf
Total Floor Areaa 409,793 sf 349,217 sf 347,148 sf 1,106,158 sf Affordable (VLI Units): Included in total units above 17 36 25 78 Private Open Space (Resident Only) 4,590 sf 4,200 sf 4,140 sf 12,930 sf Common Open Space (Resident only) 29,213 sf 27,373 sf 25,802 sf 82,388 sf Public Open Space 11,479 sf 10,945 sf 14,092 sf 36,516 sf Total Open Space 45,282 sf 42,518 sf 44,034 sf 131,834 sf Commercial Vehicle Parking Spaces 21 — — 21
Residential Parking Spaces 460 414 409 1,283
Total Vehicle Parking Spaces 481 414 409 1,303
Short-Term Bicycle Parking Spaces 13 9 9 31
Long-Term Bicycle Parking Spaces 99 88 87 274
Total Bicycle Parking Spaces 112 97 96 305
Heightb 7 stories
(83′-6″)
7 stories
(93′-6″)
7 stories
(88′-6″)
—
a. Net residential square footage is the area in square feet confined within the exterior walls of a building, but not including the area of the following: exterior walls stairways shafts rooms housing building operating equipment or machinery, parking areas with associated driveways and ramps, space dedicated to bicycle parking, space for the landing and storage of space dedicated to bicycle parking, space for the landing and storage of helicopters, and basement storage areas. b. Stories include rooftop floors that include indoor structures (i.e., amenity rooms). The number of stories does not include subterranean parking levels.

SOURCE: KFA, 2025.

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Figure 3
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Figure 5
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SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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Figure 6
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SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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5757 Uplander Project
Figure 7
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SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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Figure 8
Building 1 Level 5, Buildings 2 & 3 Level 4
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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5757 Uplander Project
Figure 9
Building 1 Level 6, Buildings 2 & 3 Level 5
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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5757 Uplander Project
Figure 10
Building 1 Level 7, Buildings 2 & 3 Level 6
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
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2 BR
1 BR
STUDIO
2 BR
PLAZA
PASEO
BRIDGE
PASEO
BRIDGE
5757 Uplander Project
Figure 11
Buildings 2 & 3 Level 7
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE 01 20
Feet
N

ONE BEDROOM

TWO BEDROO

THREE BEDRO

UTILITY

AMENITY
RETAIL

ONE BEDROOM

TWO BEDROO

THREE BEDRO

UTILITY

AMENITY
RETAIL
STUDIO
1 BEDROOM
2 BEDROOM

UTILITY

AMENITY

COMMERCIAL
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2. Project Description
5757 Uplander Project 2-16 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

2.4.2 Landscaping and Open Space
Open space and landscaping would be provided in accordance with CCMC requirements. The Project’s landscaping and open space design is highlighted by a centrally-located landscaped pedestrian paseo, neighborhood nodes, and public plazas distributed along the periphery. Through these greenspaces, the Project would provide numerous connections to its surroundings and improve walkability of the neighborhood. Figure 2-3 illustrates the central paseo and green spaces throughout the Project Site. As shown on Figur e 2-3, a pedestrian bridge between Buildings 1 and 2 would span over the driveway separating these two buildings. Likewise, there would be another pedestrian bridge that would span over a landscaped area separating Buildings 2 and 3. The paseo would separate t he east and west structural components of each of the Project’s three buildings. Distributed along the paseo are various gardens and seating areas. P rivate courtyards associated with each of the residential buildings abut the paseo . These courtyards would have their own distinct character and contain various amenities for residents, including thematic gardens, outdoor grilling and dining areas, flexible seating, pergolas, and activity lawns and decks.

Both ends of the pedestrian paseo would be accessible via stairs and American with Disabilities Act (ADA)- compliant access ramps that frame the neighborhood nodes on Hannum Avenue and Uplander Way. These multipurpose spaces would serve as gateways to the Project and create social gathering spots. Open plazas at the base of each set of stairs are designed to create neighborhood-scaled gathering places. The neighborhood node on Hannum Avenue would provide an urban feel, engaging the busier streetscape and the activity across the street. Shade, seating, small commercial activity, and open site lines would activate the space. On the southern side of the Project Site, another neighborhood node would have a softer, intimate quality, offering a park-like experience for residents and neighbors. Other defining landscape and open space features would include private elevated pool decks, unit patios, planted terraces and green roofs, entry porches for street facing units, and streetscape plantings. Irrigation would be p rovided by high efficiency drip systems on weather-based smart controllers. Landscaping would emphasize native and drought tolerant plants (e.g., ornamental grasses, leafy groundcovers, colorful shrubs, and soft textured vegetation). Along Hannum Avenue and Bristol Parkway, screening shrubs will provide privacy between the patios and the street. Uplander Way will have low shrubs and ornamental grasses framing front doors and stoops open to the street. In addition, wider sidewalks with street trees will be incorporated along Hannum Avenue, Bristol Parkway, and Uplander Way.

Overall, as shown in Table 2, Open Space Summary, the Project would include a total of 131,834 sf of open space. The Project’s centrally-located paseo, neighborhood nodes and landscaped spaces would provide a total of approximately 36,516 sf of publicly-accessible open space. Approximately 95,318 sf would be provided as open space for Project residents within common outdoor and indoor amenity areas (82,388 sf) and as part of private patios and balconies (12,930 sf). As shown in Table 2, the Project’s amenity spaces would include gyms, recreation rooms, pools, decks and roof areas that would be available to Project residents only.

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

2. Project Description

5757 Uplander Project 2-17 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 2

OPEN SPACE SUMMARY
Open Space Area Size
Publicly Accessible Open Space
Central Paseo and Street Frontage 36,516 sf
Subtotal Publicly Accessible Open Space 36,516 sf
Open Space (for Residents)
Common Open Space (for Residents)
Courtyards 31,574 sf
Amenities (Community Room, Fitness, etc.) (Various floors) 40,076 sf Roof Deck (7th Floor) 10,738 sf
Private Open Space (Balconies) 12,930 sf
Subtotal Open Space (for Residents) 95,318 sf
Total Open Space Provided 131,834 sf
sf = square feet
SOURCE: KFA, 2025.

Streetscape choices would reflect the character of the surrounding streets: Hannum Avenue, Uplander Way and Bristol Parkway. Along Hannum Avenue and Bristol Parkway, screening shrubs w ould be planted to provide privacy between the private residential patios and the street. Uplander Way would have a “townhome” aesthetic, with low shrubs and ornamental grasses framing front doors and stoops open to the street. Street trees would be planted along Bristol Parkway, Hannum Avenue, and Uplander Way to provide shade and reflect the existing trees in the area. Final species selection would be implemented during permitting and construction based on the proposed palette and the Urban Forest Master Plan.

2.4.3 Height, Density, and Setbacks
Per CCMC Section 17.220.020, Table 2-8, Mixed-Use Development Standards, the maximum allowable height for the Project is 56 feet. However, the Project is proposing to include 78 units of its residential units as VLI affordable units. These VLI units will be distributed across each of the three proposed Project Site parcels (17, 36, and 25, respectively). By doing so, consistent with the CCMC and State Density Bonus Law (Gov’t Code § 65915), the Project is entitled to receive development incentives and waivers including a height increase. The Project is requesting a height increase of 37 feet and six inches beyond the maximum allowable height as a development incentive for providing affordable units. With this incentive, the Project would have a maximum height of 93 feet and 6 inches.

Figure 12, Elevation – Building 1, provides an illustration of the elevations of Building 1 from the north (Hannum Ave), south, and west (Bristol Parkway). Figure 13, Elevation – Building 2, provides an illustration elevation from the north, south, and west. Figure 14, Elevation – Building 3, provides an illustration of the north, south (Uplander Way), and west elevations. Figure 15, Overall Elevation – Uplander Way , illustrates the overall Project elevations from Uplander Way. Lastly, Figure 16, Building Sections East –West and Figure 17 Building Sections North –South, illustrate the Project’s proposed uses and heights by floor/level.

LEVEL 01 -P1
+103' - 0"
LEVEL 02 -P1
+118' - 0"
LEVEL 03 -P1
+129' - 8"
LEVEL 04 -P1
+140' - 0"
LEVEL 05 -P1
+150' - 4"
LEVEL 06 -P1
+160' - 8"
LEVEL 07 -P1
+171' - 0"
LEVEL 08 -P1
+181' - 4"
FC 1
BR 1
FC 1
PL 1
FC 3
FC 3
LP
TOWNHOME - P1
+107' - 0"
BR 2 BR 1 ST ST
ML 2 PL 1
BR 1 ST BR 3BR 3 BR 1
PL 1 ML 2VW
88' - 6"
88' - 6"
LEVEL 01 -P1
+103' - 0"
LEVEL 02 -P1
+118' - 0"
LEVEL 03 -P1
+129' - 8"
LEVEL 04 -P1
+140' - 0"
LEVEL 05 -P1
+150' - 4"
LEVEL 06 -P1
+160' - 8"
LEVEL 07 -P1
+171' - 0"
LEVEL 08 -P1
+181' - 4"
PL 2
PL 3
BR 3
PL 1
LP
FC 1
BR 1
PL 2
PL 3
FC 1
PL 2
PL 3
FC 1
ML 2
ML 2
ST
ML 2
88' - 6"
LEVEL 02 -P1
+118' - 0"
LEVEL 03 -P1
+129' - 8"
LEVEL 04 -P1
+140' - 0"
LEVEL 05 -P1
+150' - 4"
LEVEL 06 -P1
+160' - 8"
LEVEL 07 -P1
+171' - 0"
LEVEL 08 -P1
+181' - 4"
PL 3
FC 1
LP
TOWNHOME - P1
+107' - 0"
ML 2 VW
BR 3 BR 1 BR 2 ML 1
PL 2 PL 1
88' - 6"
LEVEL 01 -P1
+103' - 0"
LEVEL 02 -P1
+118' - 0"
LEVEL 03 -P1
+129' - 8"
LEVEL 04 -P1
+140' - 0"
LEVEL 05 -P1
+150' - 4"
LEVEL 06 -P1
+160' - 8"
LEVEL 07 -P1
+171' - 0"
LEVEL 08 -P1
+181' - 4"
FC 1
LP
TOWNHOME - P1
+107' - 0"
PL 1 ML 2PL 1
ST BR 3 PL 3BR 1
VW
BR 1
ST
88' - 6"
1/16" = 1'-0" 3PARCEL 1 - NORTH ELEVATION (HANNUM AVE)
1/16" = 1'-0" 2PARCEL 1 - SOUTH ELEVATION
1/16" = 1'-0" 13
PARCEL 1 - EAST ELEVATION (UPLANDER
WAY)
1/16" = 1'-0" 1
PARCEL 1 - WEST ELEVATION (BRISTOL
PKWY)
82'-9"
80'-6"
71'-0"
72'-9"
82'-0"
83'-6"
78'-6"
5757 Uplander Project
Figure 12
Elevation - Building 1
SOURCE: KFA, 2025D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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LEVEL 01 -P2
+116' - 0"
LEVEL 02 -P2
+128' - 0"
LEVEL 03 -P2
+139' - 8"
LEVEL 04 -P2
+150' - 0"
LEVEL 05 -P2
+160' - 4"
LEVEL 06 -P2
+170' - 8"
LEVEL 07 -P2
+181' - 0"
LEVEL P1 -P2
+103' - 0"
LEVEL 08 -P2
+191' - 4"
LP LP
PL 1
FC 3
FC 1
PL 2
FC 1
PL 3
VWML 2
ST
88' - 6"
88' - 6"

FINISHED GRADE
LEVEL 01 -P2
+116' - 0"
LEVEL 02 -P2
+128' - 0"
LEVEL 03 -P2
+139' - 8"
LEVEL 04 -P2
+150' - 0"
LEVEL 05 -P2
+160' - 4"
LEVEL 06 -P2
+170' - 8"
LEVEL 07 -P2
+181' - 0"
LEVEL 08 -P2
+191' - 4"
LP LP
TOWNHOMES -P2
+118' - 0"
PL 3
PL 2
FC 1
BR 2
88' - 6"
LEVEL 01 -P2
+116' - 0"
LEVEL 02 -P2
+128' - 0"
LEVEL 03 -P2
+139' - 8"
LEVEL 04 -P2
+150' - 0"
LEVEL 05 -P2
+160' - 4"
LEVEL 06 -P2
+170' - 8"
LEVEL 07 -P2
+181' - 0"
LEVEL 08 -P2
+191' - 4"
TOWNHOMES -P2
+118' - 0"
BR 3 BR 1BR 4BR 1 FC 3
FC 1PL 1
ST
ML 2
88' - 6"
LEVEL 01 -P2
+116' - 0"
LEVEL 02 -P2
+128' - 0"
LEVEL 03 -P2
+139' - 8"
LEVEL 04 -P2
+150' - 0"
LEVEL 05 -P2
+160' - 4"
LEVEL 06 -P2
+170' - 8"
LEVEL 07 -P2
+181' - 0"
LEVEL 08 -P2
+191' - 4"
LP LP
PL 2 PL 3FC 1 ML 2
88' - 6"
1/16" = 1'-0" 3PARCEL 2 - NORTH ELEVATION
1/16" = 1'-0" 2PARCEL 2 - SOUTH ELEVATION
1/16" = 1'-0" 13
PARCEL 2 - EAST ELEVATION (UPLANDER
WAY)
1/16" = 1'-0" 1PARCEL 2 - WEST ELEVATION93'-6"
84'-0"
80'-3"
81'-6"
84'-0"
81'-6"
5757 Uplander Project
Figure 13
Elevation - Building 2
SOURCE: KFA, 2025D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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LEVEL 08 - P3
+189' - 4"
LEVEL 07 - P3
+179' - 0"
LEVEL 06 - P3
+168' - 8"
LEVEL 05 - P3
+158' - 4"
LEVEL 04 - P3
+148' - 0"
LEVEL 02 - P3
+126' - 0"
LEVEL 03 - P3
+137' - 8"
LEVEL 01 - P3
+112' - 0"
PL 3
PL 2
PL 1
VW
ML 2ML 2
ML 1
88' - 6"
LP LP
LEVEL 08 - P3
+189' - 4"
LEVEL 07 - P3
+179' - 0"
LEVEL 06 - P3
+168' - 8"
LEVEL 05 - P3
+158' - 4"
LEVEL 04 - P3
+148' - 0"
LEVEL 02 - P3
+126' - 0"
LEVEL 03 - P3
+137' - 8"
LEVEL 01 - P3
+112' - 0"
FC 1
FC 2 FC 3 ST
FC 1
PL 1
ML 2
ML 1
88' - 6"
LEVEL 08 - P3
+189' - 4"
LEVEL 07 - P3
+179' - 0"
LEVEL 06 - P3
+168' - 8"
LEVEL 05 - P3
+158' - 4"
LEVEL 04 - P3
+148' - 0"
LEVEL 02 - P3
+126' - 0"
LEVEL 03 - P3
+137' - 8"
LEVEL 01 - P3
+112' - 0"
FC 2
FC 3
PL 1
FC 1
ST
88' - 6"
LP
LEVEL 08 - P3
+189' - 4"
LEVEL 07 - P3
+179' - 0"
LEVEL 06 - P3
+168' - 8"
LEVEL 05 - P3
+158' - 4"
LEVEL 04 - P3
+148' - 0"
LEVEL 02 - P3
+126' - 0"
LEVEL 03 - P3
+137' - 8"
LEVEL 01 - P3
+112' - 0"
PL 3
FC 1 PL 2 ML 2 VW
FC 2
88' - 6"
1/16" = 1'-0" 3PARCEL 3 - NORTH ELEVATION
1/16" = 1'-0" 2
PARCEL 3 - SOUTH ELEVATION (UPLANDER
WAY)
1/16" = 1'-0" 13
PARCEL 3 - EAST ELEVATION (UPLANDER
WAY)
1/16" = 1'-0" 1PARCEL 3 - WEST ELEVATION
81'-6"
86'-3"
86'-6"
81'-5"
5757 Uplander Project
Figure 14
Elevation - Building 3
SOURCE: KFA, 2025D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE ----➔
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LEVEL 01 -P1
+103' - 0"
LEVEL 02 -P1
+118' - 0"
LEVEL 03 -P1
+129' - 8"
LEVEL 04 -P1
+140' - 0"
LEVEL 05 -P1
+150' - 4"
LEVEL 06 -P1
+160' - 8"
LEVEL 07 -P1
+171' - 0"
LEVEL 08 -P1
+181' - 4"

LP LPLP LPLP LP
Level 08-P2
+190' - 4"
Level 07-P2
+180' - 0"
Level 06-P2
+169' - 8"
Level 05-P2
+159' - 4"
Level 04-P2
+149' - 0"
Level 03-P2
+138' - 8"
Level 02-P2
+127' - 0"
Level 01-P2
+114' - 0"
LEVEL 08 - P3
+189' - 4"
LEVEL 07 - P3
+179' - 0"
LEVEL 06 - P3
+168' - 8"
LEVEL 05 - P3
+158' - 4"
LEVEL 04 - P3
+148' - 0"
LEVEL 02 - P3
+126' - 0"
LEVEL 03 - P3
+137' - 8"
LEVEL 01 - P3
+112' - 0"
88' - 6"
88'-6" MAXIMUM HEIGHT LIMIT

FROM GRADE
NTS 1SOUTH ELEVATION (UPLANDER WAY)
78'-6"
82'-6"
80'-9"
EAST
5757 Uplander Project
Figure 15
Overall Elevation - Uplander Way
SOURCE: KFA, 2025D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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Figure 16
Building Sections East-West
SOURCE: KFA, 2025D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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2. Project Description
5757 Uplander Project 2-24 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

In addition to a height incentive due to its inclusion of affordable units, the Project would receive a density bonus. The Project Site’s General Plan Land Use designation of Mixed Use High allows densities up to 100 units per acre, as does its MU-HD Zoning District. As the Project Site is 8.34 acres, up to 834 units could be developed without a density bonus. The Project includes 78 VLI affordable units split up as 17, 36, and 25 units on the proposed Project Site parcels 1, 2 and 3, respectively. Providing this amount permits a 20%, 50%, and 30% density increase, or 243 additional units total, on the three respective proposed Project Site parcels.

As such, the Project’s 1,077 total units would be within the allowed number of units with the density bonus.

CCMC Section 17.220.020, Table 2-8, Mixed-Use District Development Standards, provides development standards for development of MU -HD sites, including setback requirements. The applicable standards include providing a minimum front and side street setback of 10 feet for residential uses. The applicable standards also include a zero -foot minimum f ront and street side setback requirement for n on-residential ground floor uses with up to a 10-foot or greater maximum setback permitted under certain conditions. 6 The Project’s setbacks would be consistent with the applicable MU-HD setback development standards.

2.4.4 Architectural Design
The Project is proposing a contemporary architectural design defined by a collection of smaller buildings on shared podiums drawing from the neighboring residential community to the east and commercial buildings to the north. The Project design also features a publicly -accessible central paseo amenity that connects the overall Project with the outside community.

Hannum Avenue: The Project design presents itself, along Hannum Ave, as two separate buildings with a public plaza leading to a public paseo that meanders throughout the overall Project Site. Figure 18, Conceptual Project Rendering – Public Plaza on Hannum Avenue, is a rendering of the Project’s entrance along Hannum Avenue that illustrates outdoor areas for the public in the plaza (Hannum Plaza), which contains landscaping and a variety of seating that is open to the community. Figure 19, Conceptual Project Rendering – Hannum/Bristol Southeasterly View , is a rendering of the Project from the intersection of Hannum Avenue and Bristol Parkway. The height and bulk of the building is compatible with the scale of the buildings on the north side of Hannum Avenue. Additionally, the building would be set back 20 to 30 feet along Hannum Avenue to create Hannum Plaza, which breaks up the Project’s massing and serves as an entrance to the central paseo. A large double-height lobby to the east and a retail space to the west would frame the two sides of the Hannum Plaza. The public-facing uses would anchor and activate the plaza and Hannum streetscape. The ground level of Hannum Avenue contains a mix of different materials, storefront glazing and covered outdoor spaces. Above the double -height space, the horizontal expression along the Hannum Avenue elevation would be accomplished through a series of horizontal bands and planes, punctuated by a framed opening. The horizontal bands would include a mix of materials and accen ts in muted tones, which reflect the commercial nature of Hannum Avenue. The large, framed openings would include balconies.

6 If a development provides a covered arcade, publicly-accessible plazas or forecourts, public art, fountains, or outdoor dining, and there is clear visibility between the sidewalk and building entrance, the maximum setback on the ground floor shall be 10 feet, or a greater setback may be allowed with Director approval. 5757 Uplander Project
Figure 18
Conceptual Project Rendering – Public Plaza on Hannum Avenue SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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5757 Uplander Project
Figure 19
Conceptual Project Rendering – Hannum/Bristol Southeasterly View SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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2. Project Description

5757 Uplander Project 2-27 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Uplander Way: The multi-building development would result in three separate buildings along Uplander Way, which breaks down the massing along the longer lengths of the Project Site. Each building would have its own design that is rooted in the unifying character of the overall development yet would be distinct from the neighboring buildings. Breezeways and driveways would divide the buildings along Uplander Way into three separate masses, allowing light and air into the Project Site. Direct access to residences along the driveways would enhance the residential character of the street. The buildings would be set back 10 to 15 feet from the sidewalks, and the buildings would each step-back again at the second, fourth, and fifth levels, resulting in a terracing effect to reduce the perceived massing and size of each building. Additionally, material and color changes at each step-back would further accentuate the effort to reduce the massing along the street. The tops of the buildings would have varying depths, creating recessed balconies with undulating tops that change from building to building. Continuing with the neutral palette and local materials, the pedestrian-scaled two-story base would be designed with high-quality materials and accents, including privacy walls, private patios and stoops. Designed to appear as multiple townhomes, the two-story base of the Uplander Way elevations would incorporate large windows to facilitate a pedestrian friendly environment. Interrupting the enhanced base material would be a pavilion-like double-height lobby at each building’s primary entry point, with the modern design creating a focal point and wayfinding element along Uplander Way. Figure 20, Conceptual Project Rendering – Uplander Way East, provides a rendering of the Project as viewed from Uplander Way.

Paseo: The building massing would further be broken down by a central paseo that links the three buildings to the public domain. The paseo runs north/south through the Project Site, connecting Hannum Plaza to another public plaza located at the southeast corner of Uplander Way. Figure 21, Conceptual Project Rendering – Uplander Way South, provides a rendering of the Project ’s paseo entrance from the south as viewed from Uplander Way. The Uplander Way corner would be framed by two separate parts of Building

3. The paseo would be a central amenity feature shared by residents and the public, and that would create distinct buildings that reflect the existing neighborhood character.

2.4.5 Access, Circulation, and Parking
Vehicular and Pedestrian Access and Parking
Vehicular access to the Project’s parking levels, as well as loading and trash areas, would be provided via four points of ingress/egress: three along Uplander Way, and one on Bristol Parkway. One of the points of access along Uplander Way (to the east of the Project Site) between Buildings 2 and 3 would provide access only for emergency vehicles (fire lane). See Figure 5 for an illustration of the Project’s proposed vehicular driveways.

Each of the three buildings would have its own residential parking area, which would be accessible via key fobs or RFID tags to residents who choose to purchase parking spaces. Parking spaces will be offered separately from residential units as required under state law.
7 Designated future resident/leasing parking would be located in the residential section of the Building 1 garage, and the leasing office would provide access to those visitors.

The parking for the retail use in Building 1 would be physically separated from the residential parking area.

7 California Civil Code Section 1947.1 requires that residential parking be unbundled from the price of rent for projects of 16 or more dwelling units in Los Angeles County (among others) that receive a certificate of occupancy on or after January 1, 2025. The 5757 Uplander Project is subject to this requirement. Therefore, parking will not be included in the price of rent for the residential units, but will be offered separately and as available to renters who want to lease parking spaces, at a price to be determined by the property owner to appropriately balance on-site supply and demand. 5757 Uplander Project
Figure 20
Conceptual Project Rendering – Uplander Way East
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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5757 Uplander Project
Figure 21
Conceptual Project Rendering – Uplander Way South
SOURCE: KFA, 2024D202300668.00 - Link Culver City EIR - Culver City\05 Graphics-GIS-Modeling-USE AZURE r ESA
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2. Project Description
5757 Uplander Project 2-30 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

The residential parking areas would be accessed from either the fire lane between Parcels 1 and 2 accessible from the west on Bristol Parkway or the east from Uplander Way, or from the fire lane accessible from the south on Uplander Way for Parcel 3. Parking levels are connected by ramps, with the exception for Parcel 2 Level 1 parking, which has a dedicated entrance from the fire lane off Uplander Way.

Retail loading w ould be provided from the fire lane between Parcels 1 and 2. Residential loading w ould take place at Levels 1 and P1 for Parcels 1 and 2, respectively, and Level 1 for Parcel 3. Rideshare pickup and drop-off will occur within the residential loading zone and street pull -off areas located along Hannum Ave and Uplander Way.

Rideshare pickup and drop -off would occur within the residential loading zone and street pull -off areas located along Hannum Ave and Uplander Way.

Pedestrian access to the Project would be available via various entrances along all sides of the Project Site.

Additionally, the paseo provides pedestrian access through the Project Site and connects it to existing walking routes in the neighborhood. In addition, pedestrian walkways will be provided along the fire lanes in between each building. Widened sidewalks will be provided on the perimeters of the Project Site.

As shown in Table 1, the Project would provide a total of 1,30 3 vehicular parking spaces, including 21 commercial and 1,283 residential parking spaces within Level P1, Level 1 and Level 2. The Project would provide electric vehicle (EV) ready and Full EV charging stations per the EV requirements of the California Green (CALGreen) Building Standards Code and CCMC Section 17.320.035, which would be forty percent of parking spaces provided for EV ready ( 522 spaces) and ten percent of the parking spaces as Full EV charging stations ( 131 spaces). The Project would also provide a total of 305 bicycle parking spaces, including 31 short-term bicycle parking spaces and 274 long-term bicycle parking spaces, in compliance with CCMC bicycle requirements.

An existing Class II bike lane is provided on Hannum Avenue adjacent to the Project Site. The Project proposes to convert two unrestricted on street parking spaces on Hannum Avenue in front of the Building 1 entrance to passenger loading only. This would include the re-striping of the existing Class II bicycle lane to include green conflict markers similar to the existing condition on the opposite side of the street that would alert drivers and bicyclists.

Public Transit
The Project Site is served by a variety of public transit options along Hannum Avenue and Bristol Parkway provided by the Culver City Department of Transportation. T he Project Site is located approximately

0.4 miles east of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity include, to the north, Culver City Bus Line 3–Crosstown, which includes Stop 305 Hannum Ave/Bristol Pkwy, and to the we st, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway.

2. Project Description

5757 Uplander Project 2-31 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

2.4.6 Lighting and Signage
Exterior lighting would incorporate low-level exterior lights on the buildings and along pathways for egress, security and wayfinding purposes. In addition, low -level lighting to accent signage, architectural features, and landscaping elements would be inc orporated throughout the Project Site. Project lighting would be designed to minimize light trespass from the Project Site and would comply with CCMC requirements.

New street and pedestrian lighting within the public right -of-way would comply with applicable city regulations and would require approval from the City to maintain appropriate and safe lighting levels on sidewalks and roadways while minimizing light and glare on adjacent properties.

Proposed signage would be designed to be aesthetically compatible with the existing and proposed architecture of the Project Site and would comply with the requirements of the CCMC. Proposed signage would include identity signage, building and retail tenant signage, residential address numbers and parking entry signage, and general ground level and wayfinding pedestrian signage. No off-site advertising signage is proposed. New signage would be architecturally integrated into the design of the proposed building and would establish appropriate identification for the proposed uses. Exterior lighting for signage would be designed to avoid creating off -site glare. Illumination used for Project signage would comply with light standards set forth in the CCMC Section 17.330.030, including that sign lighting shall not be of an intensity or brightness that will create a nuisance for residential properties in a direct line of sight to the sign.

2.4.7 Site Security
The Project would incorporate various security measures, including a 24-hour/seven-day video surveillance security program for the safety of employees, residents, and visitors to the Project Site. The cameras will be located to capture views at publicly accessible areas; at main pedestrian an d vehicular entries; outdoor amenity spaces; at secure package and bicycle storage rooms; at stair/elevator lobbies; and at other sensitive locations as appropriate. During construction of the Project, the Project Site would be fenced and gated with surveillance cameras to monitor the site during off hours. During operation of the Project, access to the parking structure would be controlled through gated entries, and the entry areas would be well illuminated. Project Site security would include controlled keycard access, and perimeter lighting of entryways and public areas. Project management would reserve the right to close off the paseo after hours.

2.4.8 Sustainability Features
Energy saving and sustainable design features would be incorporated into the Project and the proposed buildings would comply with the applicable Title 24 California Code of Regulations. Design features would include energy efficiency measures such as a 15 percent reduction over the ASHRAE 90.1 (2010) Baseline energy standard for buildings, installation of ENERGY STAR-rated appliances, and application of design to LEED Silver standards or better. The Project’s construction would use 100 percent l ow- or no-Volatile Organic Compound ( VOC) paint, sealants and adhesives. W ater efficient fixtures would be installed to reduce indoor water use, and the Project would incorporate water-efficient landscape design with weather- based controllers and drip irrigation systems. EV parking and charging would be available for residential and commercial use. The Project would include 305 bicycle spaces, consisting of 31 short -term and 274 long-term bicycle parking spaces.

2. Project Description
5757 Uplander Project 2-32 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Transportation Design Management (TDM) Program
The Project would implement TDM features to reduce vehicle trips generated by Project residents, guests, employees, and customers , as well as reduce associated greenhouse gas emissions. Some specific TDM features in the Project are bicycle parking, pedestrian-oriented design, electric vehicle parking, employee parking, bus stop improvements, and ride hail/ curbside pickup and drop- off areas. In accordance with the CCMC, the Project would contribut e a fair share toward funding the City’s mobility infrastructure and improvement projects intended to reduce VMT and support housing and job growth. The Project would implement additional TDM strategies to further reduce vehicle trips as part of the long -term TDM Plan to provide flexibility in addressing future transportation and mobility needs.

2.4.9 Project Construction and Phasing
A preliminary Construction Management and Traffic Plan (CMTP) will be prepared as part of the entitlement processing phase of the Project that would define the scope and scheduling of planned construction activities. Additionally, the CMTP would detail the Applicant’s proposed construction site management responsibilities to ensure minimal impacts to neighboring land uses and to avoid interruption of pedestrian, vehicle, and alternative transportation modes and public transit. The CMTP would require regular City oversight and would facilitate communication and coordination with residents and others in the neighborhood. A final comprehensive CMTP would be subject to City review and approval prior to starting any construction activity. The CMTP would include but not necessarily be limited to: name and telephone number of a contact person regarding traffic complaints or emergency situations; community notification procedures; contact information for local police, fire, and emergency response orga nizations and procedures for the continuous coordination of construction activity; procedures for training the flag person(s) used in implementing the plan; the location, times, and estimated duration of any temporary lane closures; managing the approved haul route plan; and a construction parking management plan.

The Project Site would be fenced during construction for security purposes. The Project would require excavation to accommodate two levels of subterranean parking, footings, and foundations. Earthwork would require export of approximately 225,600 cubic yar ds (CY) of soil. Construction staging would be mostly internal to the Project Site. Vehicles w ould stage on streets adjacent to the Project Site, consistent with the CTMP. The Project would excavate to a maximum depth of 22 feet below ground surface (bgs) for the P1 parking level, although building footings could extend to approximately 28 feet bgs.

Project construction would occur in three phases and is anticipated to commence as early as the first quarter of 2027. As the Project is built out, construction activities of the three phases may overlap, with the start of Phases 2 and 3 staggered by approximately 15 months following Phases 1 and 2, respectively. Full buildout is expected to occur as early as the end of 2031. Active construction during Project buildout would occur over approximately 57 months, accounting for some overlapping of the construction phasing.

The CCMC prohibits construction between the hours of 8:00 p.m. and 8:00 a.m. Monday through Friday, 7:00 p.m. and 9:00 a.m. on Saturday, and 7:00 p.m. and 10:00 a.m. on Sunday. As part of its requested entitlements, the Project is requesting an approval for Extended Hours of Construction, as allowed by CCMC Section 9.07.035.C.1, to allow for a 7:00 a.m. daily start, Monday through Friday as well as a 8:00 a.m. start on Saturdays. The extended construction hours are being requested for the entire construction duration.

2. Project Description

5757 Uplander Project 2-33 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

2.4.10 Necessary Approvals
Discretionary entitlements, reviews, and approvals required or requested for the Project may include, but would not necessarily be limited to, the following:
• Site Plan Review to construct a new residential project with more than 26 units. (CCMC Section

17.540.)
• Density and Other Bonus Incentives (DOBI) to allow increased density with affordable units incorporated into the Project, as well as a height incentive; • Approval for Extended Hours of Construction per CCMC Section 9.07.035.C.1; and • Vesting Tentative Parcel Map to consolidate the existing four Project Site parcels and subsequently divide the Project Site into three parcels, each to contain one of the three Project buildings.

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

2.4.11 Project Design Features (PDFs)
The Project proposes to voluntarily incorporate several PDFs into the Project that would serve to minimize or avoid significant environmental effects. The PDFs will be included in the Mitigation Monitoring and Reporting Program (MMRP) required in association with certification of the this CEQA document . The PDFs are summarized in Table 3, Summary of Project Design Features, and are discussed in detail in the technical sections indicated in the table. The PDFs are incorporated in the analyses of potential Pr oject impacts.

TABLE 3

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

GHG-PDF-1: Green Building
Features
The Project will include the following green building features:
• The Project buildings will be designed to meet the United States Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) rating system at a "Silver" performance level or higher and will be designed and operated to meet or exceed the applicable requirements of the State of California Green Building Standards Code and the City’s Green Building Program Requirements. • Energy Efficiency: 15% reduction over ASHRAE 90.1 (2010) Baseline • The Project will incorporate renewable energy features in the form of 1 kW solar photovoltaic panels per 10,000 sf in order to achieve compliance with the City’s solar photovoltaic requirement, per the City’s Green Building Ordinance and CALGreen standards.
• The Project will provide EV parking and charging for residential and commercial use.

A total of 522 parking spaces (514 residential + 8 commercial) would be electric vehicle ready. One-hundred and thirty one (131) total spaces (129 residential + 2 commercial) would have EV charging stations.
• The Project will include LED lighting throughout the Project Site and would install ENERGY STAR-rated appliances.

2. Project Description
5757 Uplander Project 2-34 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 3

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary NOI-PDF-1: Project Construction
Schedule
Prior to issuance of a building permit, notice of the Project construction schedule will be provided to adjacent property owners and occupants. Evidence of such notification will be provided to the City’s Public Works Department. The notice will identify the commencement date and proposed timing for all construction phases (demolition, grading, excavation/shoring, foundation, rough frame, plumbing, roofing, mechanical and electrical, and exterior finish).

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

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

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

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

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

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

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

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

2. Project Description

5757 Uplander Project 2-35 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 3

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary during peak traffic periods and will be subject to adjustment by City staff as deemed necessary and appropriate to preserve the general public safety and welfare.

Prior to approval of the CMTP and grading permits, the Applicant will conduct one community meeting pursuant to the City’s notification requirements for community meeting guidelines, to discuss and provide the following information to the surrounding community:

1. Construction schedule and hours.

2. Framework for construction phases.

3. Identify traffic diversion plan by phase and activity.

4. Potential location of construction parking and office trailers.

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

6. Emergency access plan.

7. Demolition plan.

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

9. Crane location(s).

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

11. Community notification procedures.

The CMTP will at a minimum include the following:

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

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

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

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

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

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

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

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

2. Project Description
5757 Uplander Project 2-36 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 3

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

On-Site Enhancements - The Project design will incorporate mobility features to encourage alternative transportation modes. The features will be designed in accordance with CCMC requirements and standards.
• Pedestrian Oriented Design. The Project will provide pedestrian plazas along the north frontage on Hannum Avenue and the southeastern frontage on uplander way period the site design encourages pedestrian circulation through and around the Project Site.
• Bicycle Parking and Amenities. The Project will provide both short-term and long-term bicycle parking spaces on-site in accordance with CCMC requirements. Short-term bicycle parking, which will include bicycle racks, will be located near the pedestrian entrance. Long-term bicycle parking, which will include bicycle lockers or secure bicycle enclosures, will be placed in an accessible weather protected location.

Electric Vehicle (EV) Parking. The project would provide 522 EV ready, and 131 Full EV charger/charging station spaces in the on-site parking garages, in accordance with city code requirements.
• Ride Hail/Curbside Pickup and Drop Off. Dedicated passenger loading areas would be designated on Hannum Avenue and Uplander Way to minimize conflicts with the existing Class II bicycle lane on Hannum Avenue and avoid double parking.

Off-Site Enhancements - The Project will improve and contribute toward improvements to off-site mobility facilities to encourage alternative transportation modes. • Mobility Fees. In accordance with CCMC Section 05.06.015, the Project would be subject to contributing its fair share toward funding the City's mobility infrastructure and improvement projects intended to reduce VMT and support housing and job growth.

Other TDM Strategies - The Project will implement TDM strategies to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The following details the minimum TDM strategies necessary to comply with the TDM and trip reduction requirements of CCMC Section 07.05.015, as well as City’s design requirements for the Project:
• Promotions and Marketing. The Project would provide a promotions and marketing program, to include a kiosk, designated coordinator, pamphlets, and/or website to inform travelers about different transportation options and the effects of their travel choices. This program's information would help inform travelers how to use non- vehicular travel modes to access the Project Site.
• Pedestrian-Friendly Environment. The project would feature pedestrian plazas along the north frontage on Hannum Avenue and the southeastern frontage on Uplander Way. The Project Site design encourages pedestrian circulation through and around the site.
• Employee Parking. At least 10% of employee parking will be reserved, as signed on the spaces, for use by potential carpool or vanpool vehicles and located as close as practical to employee entrances. This preferential parking will be identified on the site plan accompanying the application for a building permit. Vanpool spaces will have a minimum parking space dimension of nine feet wide by 18 feet in length and provide a minimum interior vertical clearance of eight feet two inches. A safe and convenient zone in which vanpool and carpool vehicles may deliver or board their passengers will also be provided.
• Bus Stop Improvements. If deemed necessary by the City, bus stop improvements will be provided to the satisfaction of the City Director of Transportation.

2. Project Description

5757 Uplander Project 2-37 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 3

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

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

WATER-PDF-1: Water Conservation The Project will implement water conservation measures that include, but are not limited to, the following landscape and irrigation strategies:
• Planting native and drought tolerant plants
• Using drip/subsurface irrigation (micro-irrigation), weather based timers, and proper hydro-zoning/zoned irrigation (groups plants with similar water requirements together) • Low flow faucets.

SOURCE: ESA, 2025.

2. Project Description
5757 Uplander Project 2-38 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

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5757 Uplander Project 3-1 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

CHAPTER 3
Comparative Analysis of Project Impacts
This section provides an impact assessment of the Project. A Modified State CEQA Guidelines Appendix G Environmental Checklist Form was used to compare the anticipated environmental effects of the Project with those disclosed in the Certified PEIR to evaluate whether the Project’s environmental effects would be within the scope of effects identified in the Culver City General Plan 2045 and Zoning Code Update PEIR in accordance with Section 15168 and to review whether any of the conditions set forth in Publi c Resources Code Section 21166 or CEQA Guidelines Section 15162 requiring preparation of a Supplemental or Subsequent EIR have been triggered. Note, that to the extent that a Project impact does not trigger the need for a supplemental or subsequent EIR pursuant to Section 15162, it is found to be within the scope of the impact analyzed in the Programmatic EIR pursuant to Section 15168(c)(4). The environmental effects for each of the following impact areas were evaluated:
• Aesthetics
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
The Certified PEIR evaluated impacts within the “Planning Area”, which includes the City’s jurisdictional boundaries and its Sphere of Influence (SOI), through the planning horizon year of 2045. Agricultural and Forestry Resources was scoped out of the Certified PEIR since the Planning Area evaluated therein does not contain agricultural uses or related operations and no areas are designated for farmland or forestry uses.

Therefore, the Project would result in no impact to agricultural and forestry resource s and has not been included in the analysis below.

The Environmental Checklist Form and evaluation below provides the following information for each of the environmental impact categories listed above:

Impact Determination in the Certified PEIR —This section lists the impact determination made in the Certified PEIR for each impact category evaluated in the PEIR.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-2 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Does the Project Involve New Significant Impacts or Substantially More Severe Impacts?—Pursuant to Section 15162(a)(1) of the CEQA Guidelines, this section indicates whether the Project would result in new significant impacts that have not already been considered and mitigated by the prior environmental review or a substantial increase in t he severity of a previously identified impact. This question also addresses whether the impact is within the scope of the impact analyzed in the EIR pursuant to Section 15168(c)(4). To the extent that the Project does not have an impact that triggers the need for a subsequent or supplemental EIR due to the involvement of a new significant impact or more severe significant impact, the impact is considered within the scope of the Certified PEIR.

Impact Determination for Project —This section lists the impact determination made for the Project, which is analyzed in detail for each impact category.

Mitigation Measures Addressing Impacts —This section indicates whether the prior environmental document provides mitigation measures to address effects in the related impact category. In some cases, the mitigations have already been implemented. If “None” is indicated, a significant impact was not identified and mitigation was not required. Applicable mitigation measures from the Certified PEIR MMP that are being imposed on the Project are included after the analysis. In addition, for some topic issues, the Certified PEIR mitigation measures require site-specific analysis to determine and refine the appropriate mitigation for a development Project at a more refined level (i.e., air quality, cultural resources and noise/vibration) than that included in the Certified PEIR . In these instances, Project -specific mitigation measures are listed after the applicable Certified PEIR mitigation measures, as applicable.

Conclusion—For each environmental topic, a discussion of the conclusion relating to the analysis is provided.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-3 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.1 Aesthetics
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Aesthetics: Except as provided in Public Resources Code Section 21099, would the project:

(a) Have a substantial adverse effect on a scenic vista? Less than Significant
No Less than
Significant
N/A
(b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
No Impact No Less than
Significant
N/A
(c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less than
Significant
No Less than
Significant
N/A
(d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than
Significant
No Less than
Significant
N/A

a) Would the Project have a substantial adverse effect on a scenic vista? Impact Determination in the Certified PEIR
The Certified PEIR determined that impacts to scenic vistas would be less than significant. As discussed in the Certified PEIR, due to the highly urbanized nature of the Planning Area, the majority of the future development under the General Plan 2045 and Zoning Code Update would primarily occur on parcels that already contain existing development, and compliance with the applicable policies and development standards designed to minimize effects to scenic vistas would ensure that impacts would be less than significant. The City does not have any designated scenic vistas and is mainly characterized by urban environments, and as a result, scenic vistas are mostly limited to open space, vacant natural areas, and parks.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to scenic vistas, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Consistent with the aesthetics analysis included in the Certified PEIR which identified the Planning Area as mostly a highly urbanized environment, the Project Site is located in an urbanized area, with a mix of office, business park, and residential uses in the nearby vicinity . The topography in the surrounding area has mild topographical variations with uses to the north of Hannum Avenue at a slightly higher elevation than the Project Site, while the office and business park uses surrounding the Project Site generally follow similar minor topographical variations as the Project Site. There are no ocean or notable mountain or other

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-4 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

scenic vistas that would be affected by the Project. More specifically, the Pacific Ocean is approximately

4.2 miles to the southwest across relatively flat topography with intervening development . Further, the Project Site is not located in a scenic resource area or an area with protected views designated by the City .

Consistent with the Certified PEIR, the Project would be subject to development and planning review and would be required to comply with other applicable regulations regarding aesthetic quali ties that are established to protect visual resources, such as building heights, building setbacks, lighting, landscaping, and signage. Therefore, development of the Project would not have a substantial adverse effect on a scenic vista. Impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Impact Determination in the Certified PEIR
Impacts to scenic resources within a state scenic highway were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that impacts would be less than significant in this regard because the Planning Area does not have any City- or State-designated scenic highways.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to scenic resources within a state scenic highway , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urbanized area and is currently occupied by four one- to two-story business park/office buildings, areas of asphalt-paved surface parking, and ornamental landscaping. The Project Site is not located in the vicinity of a City of Culver City or State-designated scenic highway. The nearest scenic highway to the Project Site is an eligible but not officially designated portion of State Highway 1 (CA-1) in Venice, which is approximately 4 miles west of the Project Site. In addition, the Project Site does not contain any unique or locally recognized natural (i.e., rock outcroppings and trees) features or designated historic buildings.8 Therefore, development of the Project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

Impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

8 City of Culver City, Historic Preservation, accessed April 20, 2024, https://www.culvercity.org/Explore/Arts- Culture/Preservation#section-2.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-5 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
c) In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality? Impact Determination in the Certified PEIR
The Certified PEIR determined that impacts related to conflicts with applicable zoning and other regulations governing scenic quality would be less than significant. The General Plan 2045 policies intend to complement and improve the existing scenic quality and resources in the City as well as to implement the City’s vision for the future character of the City. The Zoning Code Update provides development standards, including setbacks, floor area ratio, building heights and lot coverage that establish the form and mass of future buildings that will occur under General Plan 2045. Future development would be reviewed by the City for compliance with applicable requirements prior to project approval and issuance of a building permit.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to conflicts with applicable zoning and other regulations governing scenic quality, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project is located within an urbanized area and, as such, the concern of this threshold is whether the Project would conflict with regulations that govern scenic quality. Such regulations pertinent to the Project Site are set forth in the Culver City General Plan, the Culver City Urban Forest Master Plan (UFMP), the Culver City Residential Parkways Standards and Guidelines, and in the CCMC. Section 3.10, Land Use and Planning, includes further analysis of the Project’s consistency with applicable plans and specific relevant policies governing scenic quality, which are summarized herein. Generally, the four existing business park/office buildings and associated surface parking lots within the Project Site have low aesthetic value.

Element 4, Land Use and Community Design, of the Culver City General Plan 2045 includes various policies that are relevant to development of the Project. Policy LU-4.3: Mixed use development, states that on large nonresidential sites, study relaxing of development standards and raising of height limits to allow concentrated, new vertical residential development to maintain existing commercial, industrial, and studio uses, and to create horizontal mixed use development on the site. Consistent with this policy, the Project would introduce high-density vertical residential development at up to heights of approximately 93 feet, six inches through its incorporation of a density bonus incentive due to the Project’ s inclusion of affordable housing as allowed by State Density Bonus Law. By doing so, the Project would help meet the City’s need for additional housing in a concentrated area, which will allow other areas within the City to maintain existing commercial, industrial, and studio uses.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-6 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Policy LU-14.2: Create an attractive pedestrian environment , seeks to facilitate a diverse and attractive pedestrian environment through the provision of street furniture, lighting, and other amenities. Policy LU-

14.5: Plazas and gathering places, seeks to improve existing and create new plazas and public gathering places throughout the city. Consistent with these policies, the Project’s landscaping and open space design is highlighted by a centrally -located landscaped pedestrian paseo, neighborhood nodes, and public plazas distributed along the periphery. Through these greens paces, the Project would provide numerous connections to its surroundings and improve walkability of the neighborhood , while also creat ing an attractive pedestrian environment . Both ends of the pedestrian paseo would be accessible via stairs and ADA-compliant access ramps that frame the neighborhood nodes on Hannum Avenue and Uplander Way.

These multipurpose spaces would serve as gateways to the Project and create social gathering spots. Open plazas at the base of each set of stairs are designed to create neighborhood-scaled gathering places. Outdoor spaces would include lounge seating, gathering spaces, and small speakers installed in discreet areas to be used for low -volume ambient sound and music. Streetscape choices would reflect the character of the surrounding streets: Hannum Avenue, Uplander Way and Bristol Parkway. Along Hannum Avenue and Bristol Parkway, screening shrubs w ould be planted to provide privacy between the private residential patios and the street. Uplander Way would have a “townhome” aesthetic, with low shrubs and ornamental grasses framing front doors and stoops open to the street. Street trees would be planted along Bristol Parkway, Hannum Avenue, and Uplander Way to provide shade and reflect the existing trees in the area.

Policy LU-15.1: Walkable and inviting buildings and spaces, requires building design that creates walkable and inviting spaces, such as locating parking behind buildings, allowing for outdoor plazas and dining, and locating building frontages in close proximity to the sidewalk edge, where appropriate. As discussed above, the Project would include a variety of walkable spaces via the centrally-located paseo and plazas. Also, the Project would include ground floor commercial spaces fronting Hannum Avenue, with all parking located within subterranean parking garages out of view from the public. Additionally, vehicular ingress/egress is limited to three driveways on the perimeters of the Project Site (excluding the fire lane), thereby emphasizing the pedestrian nature of the Project and activating the streetscape near the Project Site.

Policy LU-15.3: Architectural and visual interest in new development , encourages distinctive architecture and elements that add visual interest to buildings to enhance people’s perceptions of Culver City as an interesting and inviting place. As shown in renderings of the future buildings, including Figure 18 , Conceptual Project Rendering – Public Plaza on Hannum Avenue, Figure 19, Conceptual Project Rendering – Hannum/Bristol Southeasterly View, Figure 20, Conceptual Project Rendering – Uplander Way East; and Figure 21, Conceptual Project Rendering – Uplander Way South, in Chapter 2, Project Description, of this document, the Project would change the character and quality of the existing office buildings and parking lot site with a new, modern high-quality architecturally design building. The Project is proposing a contemporary architectural design defined by a collection of smaller buildings on shared podiums drawing from the neighboring residential community to the east and commercial buildings to the north.

The architectural design reflects the residential typologies of the apartment and condominium buildings east of Buckingham Parkway. The terraced nature of existing nearby residential buildings is incorporated into the design as vertical steps with balconies and material changes. The different materials and textures provide visual interest, such as the brick veneer employed at the base in a townhome aesthetic with stoops and patios facing the sidewalks along Uplander Way and Hannum Ave. Additionally, this townhome-style design form supports pedestrian walkability and community safety. The mid -level building architecture would be somewhat restrained with a plaster finish , while the top levels would provide contrasting shapes

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-7 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

and texture with gabled roof forms clad in fiber cement paneling. Balconies integrated throughout the design at the upper levels, as well as top floor amenity decks, provide solar access and views for residents.

Shade fins and a trellis structure would be provided at southern and western exposures to mitigate afternoon solar glare with passive sustainable design methods.

The angular shapes of the retail space and residential lobbies would be clad in a multi-colored paneling and feature large expanses of storefront glazing that serve as an invitation for the public, guests and future residents to enter. At Hannum Ave, the design includes a retail plaza flanked by a two -story residential lobby and a retail space, inclusive of an overhanging roof at a double -height space to cover a patio and support the opportunity for outdoor eating. The retail space would be located directly across the street from the TikTok building (5800 Bristol Parkway) and immediately adjacent to the entrance of the public paseo, activating the sidewalk and orienting the design for pedestrians.

The City’s Culver City Residential Parkway Guidelines (2016) informs the general public about parkway regulations and provides guidance on planning, creating, and maintaining a parkway landscape. Property owners are expected to maintain the parkway space adjacent to their properties, with the exception of street trees, which are maintained by the City. Sidewalk access and step -out strips are to be installed and maintained along all residential parkways in the City. The Project would comply with any applicable Culver City Residential Parkway Guidelines as determined appropriate in consultation with the City.

As discussed in Section 3.10, Land Use and Planning, the Project would not conflict with the policies of the UFMP. The Project’s centrally -located paseo, neighborhood nodes and landscaped spaces would provide a total of approximately 36,516 sf of publicly-accessible open space. In addition, new replacement trees would be planted on the Project Site per Section 9.08.215 of the CCMC. The selected street tree species would meet the UFMP Tree Palette and meet the UFMP’s performance criteria.

CCMC Section 17.220.020, Table 2-8, Mixed-Use District Development Standards, provides development standards such as setback, open space, parking frontage, height and other development standards. The Project would be consistent with the applicable development standards, with the exception of the incentives and waivers that the Project is requesting in connection with its Density and Other Bonus Incentives (DOBI) application. The Project is requesting a height increase of 37 feet 6 inches beyond the maximum allowable height of 56 feet as a development incentive for providing affordable units. With these incentives, the Project would have maximum building heights of up to 93 feet and six inches to the top of the roof to accommodate grade changes. However, given the Property’s grade change, the actual height from grade for each proposed building ranges from 71 feet to 93 feet and 6 inches. Further, even with this height increase, given that no views of scenic vistas or scenic resources occur across or through the Project Site, the Project would not substantially alter scenic views from surrounding areas.

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

17.300.035.C.2 requires the method of screening to be architecturally compatible with other on-site development in terms of colors, materials, and architectural style as determined by the Director. The Project would screen all utilities from public view. Any utilities located on the building roof would be screened by fencing, the design of which would be coordinated with the building’s architectural materials, color, and design. This regulation would be further implemented under Project Design Feature AES-PDF-1, which requires mechanical, electrical, and

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-8 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

roof top equipment [including heating, ventilation, and air conditioning (HVAC) systems], as well as building appurtenances, to be integrated into the Project’s architectural design (e.g., placed behind parapet walls) and will be screened from view from public rights-of-way. Plans related to rooftop screening would be submitted to the current Planning Division for review. Other utility areas, such as refuse and recyclable storage loading areas would be located in the parking garage and would not be visible from the public streets and highways.

CCMC Section 15.06.100.A (Art in Public Places) requires the inclusion of visual artwork, performing and architectural resources to enhance the quality of life for individuals living in, working in, and visiting the City. The Project would feature high qua lity architecture, proposing a contemporary architectural design defined by a collection of smaller buildings on shared podiums drawing from the neighboring residential community to the east and commercial buildings to the north; street-accessible and inviting main entrances; coordinated use of building materials and structural design; and neutral and unified color palette with large windows for the units , thus, resulting in distinctive and creative building exteriors. The Project would provide public art or pay in lieu fees for public art to the City’s requirements. With compliance with CCMC regulations that govern scenic character, such as applicable development standards, screening, public art, the Project would not conflict with the policies of the CCMC that regulate scenic quality.

Based on the above, the Project would not conflict with zoning and other regulations governing scenic quality. Therefore, impacts would be less than significant and would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
d) Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Impact Determination in the Certified PEIR
The Certified PEIR determined that impacts related to light and glare would be less than significant, as new development will primarily occur on parcels that already contain some development since the primary approach to accommodating growth is through infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. Future development will be required to comply with applicable lighting regulations and standards, which includes directing light to be oriented downward and to avoid any light spillover to adjacent properties; requiring that permanently installed lighting shall not blink, flash, or be of unusually high intensity or brightness; requiring landscaping and pedestrian walkway lights to be low profile; and limiting the height of freestanding light poles and luminaires.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to light and glare, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-9 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
The Project Site is located within an urbanized area, characterized by moderate ambient nighttime lighting levels due to the developed nature of the area, existing buildings and parking lot on-site, as well as from adjacent properties. Artificial light sources from the on -site uses and other surrounding properties include interior and exterior lighting for security, parking, architectural highlighting, incidental landscape lighting, and illuminated signage. Automobile headlights, streetlights and stoplights for visibility and safety purposes along the adjacent streets contribute to overall ambient lighting levels as well.

Similar to the existing site and surrounding uses, the Project would include low to moderate levels of interior and exterior lighting for security, parking, wayfinding, signage and architectural highlighting. Soft accent lighting used for signage and architectural highlighting would be directed to permit visibility of the highlighted elements but would not be so bright as to cause substantial light spillover. All proposed signage and outdoor lighting would be subject to applicable regulations contained within the CCMC. Additionally, the Project would be reviewed by the City for compliance with applicable requirements prior to P roject approval and issuance of a building per mit. Compliance with these regulations would ensure that impacts regarding Project lighting are less than significant, consistent with the impact findings of the Certified PEIR.

Glare occurs from sunlight reflected from reflective materials utilized in existing buildings along the adjacent roadways and from vehicle windows and surfaces. Glare-sensitive receptors include the residential uses to the west, south, and east and motorists on the roadways surrounding the Project Site. As glare is a temporary phenomenon that changes with the movement of the sun, receptors other than motorists are generally less sensitive to glare impacts than to light impacts. Any glass fenestration incorp orated into the Project’s residential or retail components, in particular on the ground level, would be designed with low - reflectivity values (no mirror -like tints or films), minimizing off -site glare. To the extent glare is experienced by adjacent uses or the occupants of vehicles on nearby streets, it would be minimal and temporary, changing with the movement of the sun throughout the course of the day and the seasons of the year. Additionally, the Project would comply with all applicable regulations in t he CCMC. Based on the above, glare impacts would be less than significant and would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to aesthetics would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-10 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.2 Air Quality
Thresholds (and Supporting Information Sources):

Impact
Determination in
the Certified PEIR
Does the Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Air Quality: Would the project:
(a) Conflict with or obstruct implementation of the applicable air quality plan?
Significant and
Unavoidable No Less than
Significant Yes
(b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment under an applicable federal or state ambient air quality standard?
Significant and
Unavoidable No Less than
Significant Yes
(c) Expose sensitive receptors to substantial pollutant concentrations?
Significant and
Unavoidable No
Less than
Significant
with Mitigation
Yes
(d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people? Less than
Significant No Less than
Significant N/A

a) Would the Project conflict with or obstruct implementation of the applicable air quality plan? Impact Determination in the Certified PEIR
The South Coast Air Basin (Basin) is designated nonattainment by the United States Environmental Project Agency (USEPA) and California Air Resources Board (CARB) for Ozone (O3) and particulate matter that are 2.5 microns or less in diameter (PM2.5) under the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS), nonattainment for lead (Los Angeles County only) under the NAAQS, and nonattainment for PM10 under the CAAQS. Long-term growth associated with buildout under the General Plan 2045 and Zoning Code Update could result in the emissions of criteria pollutants that exceed South Coast Air Quality Management District ( SCAQMD) thresholds for criteria pollutants. The Certified PEIR determined that impacts related to a conflict with or obstructing implementation of the applicable air quality plan would be significant and unavoidable due to population, housing, and employment growth that could exceed demographic assumptions for the City made by the Southern California Association of Governments (SCAG) . Mitigation Measures PEIR MM AQ-1 through PEIR MM AQ-5 serve to reduce the severity of the impacts to emissions of criteria pollutants associated with future development and projected growth from future development. However, while implementation of Mitigation Measures PEIR MM AQ-1 through PEIR MM AQ-5 would serve to reduce the severity of the effects, impacts would nonetheless remain significant and unavoidable.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to conflicting or obstructing implementation of an air quality plan, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-11 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
The Project’s Nitrous Oxides (NOX), Carbon Monoxide (CO), particulate matter that are 10 microns or less in diameter (PM10 ), and particulate matter that are 2.5 microns or less (PM2.5 ) emissions during construction and operations were analyzed: (1) to ascertain potential effects on localized concentrations; and (2) to determine if there is a potential for such emissions to cause or effect a violation of the ambient air quality standards for NO
2, CO, PM10, PM2.5 . Due to the Project’s proximity to sensitive receptors, including medical uses at the Pacific Interventional Vascular Access Center located 50 feet to the southwest of the Project Site, multifamily residential uses located 420 feet to the east of the Project Site, proposed future multi-family residential uses located 75 feet to the south of the Project Site, future school uses located 75 feet to the south of the Project Site, proposed future multi-family residential uses located 390 feet to the northeast, and multifamily residential uses located 850 feet to the south of the Project Site. Consistent with Mitigation Measure PEIR MM AQ-6, a localized Project construction -related air quality analysis was conducted for the Project in conformance with SCAQMD methodology for assessing localized significance thresholds (LST) air quality impacts.
9 As shown in Table 4, Estimated Maximum Unmitigated Localized Construction Emissions, localized Project-related construction emissions would not exceed the SCAQMD localized significance thresholds.

TABLE 4

ESTIMATED MAXIMUM UNMITIGATED LOCALIZED CONSTRUCTION EMISSIONS (POUNDS PER DAY) Source NOX CO PM10a PM2.5a
Parcel 1
Demolition - 2027 4.85 7.06 4.57 0.80
Grading/Excavation - 2027 10.54 18.53 0.31 0.26
Subterranean Work/Concrete Structure - 2027 10.16 10.38 0.39 0.36 Framing/Building Enclosure - 2028 1.85 2.69 0.05 0.05
Finishes - 2028 1.08 1.49 0.02 0.02
Finishes - 2029 1.06 1.48 0.02 0.02
Paving/Site Work – 2028 7.39 11.32 0.24 0.22
Paving/Site Work – 2029 7.18 11.33 0.22 0.20
SCAQMD Localized Significance Threshold for Parcel 1 158.9 1,317.9 11.0 6.3 Parcel 2
Demolition - 2028 4.77 7.07 0.12 0.25
Grading/Excavation - 2028 10.37 18.55 0.23 0.24
Subterranean Work/Concrete Structure - 2028 9.50 10.33 0.33 0.33 Subterranean Work/Concrete Structure - 2029 8.94 10.21 0.32 0.32 Framing/Building Enclosure - 2029 1.84 2.69 0.05 0.05
Finishes - 2029 1.06 1.48 0.02 0.02

9 The Project Site is located within SCAQMD SRA 3 is approximately 8.34 acres in size, where the Project Site is comprised of three proposed parcels: Parcel 1 (3.27 acres), Parcel 2 (2.38 acres), and Parcel 3 (2.69 acres). If the average of a site was between one acre and two acres or between two acres and five acres, the thresholds were interpolated to match the specific acreage of each individual site. The nearest off-site air quality sensitive receptors include the residences located within 25 meters of Parcel 1, Parcel 2 and Parcel 3 to the east. The acreages of Parcels 1 and 2 (5.65 acres) and acreage of Parcels 2 and 3 (5.07 acres), was also conservatively evaluated using the thresholds for a 5-acre site and for a sensitive receptor assumed to be located 25 meters from the Project Site.

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3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-12 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 4

ESTIMATED MAXIMUM UNMITIGATED LOCALIZED CONSTRUCTION EMISSIONS (POUNDS PER DAY) Source NOX CO PM10a PM2.5a
Finishes - 2030 1.05 1.48 0.01 0.01
Paving/Site Work – 2030 7.05 11.27 0.19 0.19
SCAQMD Localized Significance Threshold for Parcel 2 139.4 1,072.0 8.9 5.4 Parcel 3
Demolition – 2029 4.72 7.07 2.01 0.40
Grading/Excavation – 2029 10.23 18.54 0.28 0.23
Subterranean Work/Concrete Structure – 2030 8.61 10.19 0.33 0.31 Framing/Building Enclosure – 2030 1.82 2.68 0.05 0.04
Finishes – 2031 1.04 1.47 0.01 0.01
Paving/Site Work – 2031 6.83 11.21 0.19 0.18
SCAQMD Localized Significance Threshold for Parcel 3 146.2 1,157.7 9.6 5.7 Parcel 1 – Finishes 2028 and Parcel 1 – Paving/Site Work 2028 8.47 12.81 0.26 0.24 Parcel 1 – Finishes 2029 and Parcel 1 – Paving/Site Work 2029 8.24 12.81 0.24 0.22 Parcel 2 – Demolition 2028 and Parcel 1 – Framing/Building Enclosure 2028

6.62 9.76 1.04 0.30
Parcel 2 – Excavation 2028 and Parcel 1 – Finishes 2028 11.45 20.05 0.29 0.25 Parcel 2 – Subterranean Work/Concrete Structure 2028 and Parcel 1 - Finishes 2028 and Parcel 1 Paving/Site Work 2028

17.97 23.14 0.63 0.58
Parcel 2 – Subterranean Work/Concrete Structure 2029 and Parcel 1 - Finishes 2029 and Parcel 1 Paving/Site Work 2029

17.18 23.02 0.58 0.54
Parcel 2 – Framing/Building Enclosure 2029 and Parcel 3 – Demolition 2029

6.55 9.75 2.06 0.44
Parcel 2 - Finishes 2029 and Parcel 3 – Excavation 2029 11.29 20.02 0.29 0.24 Parcel 2 – Finishes 2030 and Parcel 2 – Paving/Site Work 2030 and Parcel 3 – Subterranean Work/Concrete Structure 2030

16.71 22.93 0.56 0.51
Parcel 3 – Finishes 2031 and Parcel 3 – Paving/Site Work 2031 7.87 12.68 0.20 0.19 Maximum Daily Construction Emissionsa 17.97 23.14 4.57 0.80 SCAQMD Localized Significance Thresholdc 197.0 1796.0 15.0 8.0 Exceed Threshold? No No No No
NOTE:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A. b. Emissions include fugitive dust control measures consistent with SCAQMD Rule 403. c. The Project Site is located within SCAQMD SRA 3 is approximately 8.34 acres in size, where the Project Site is comprised of three proposed parcels: Parcel 1 (3.27 acres), Parcel 2 (2.38 acres), and Parcel 3 (2.69 acres). If the average of a site was between one acre and two acres or between two acres and five acres, the thresholds were interpolated to match the specific acreage of each individual site. The nearest off-site air quality sensitive receptors include the residences located within 25 meters of Parcel 1, Parcel 2 and Parcel 3 to the east. The acreages of Parcels 1 and 2 (5.65 acres) and acreage of Parcels 2 and 3 (5.07 acres), was also conservatively evaluated using the thresholds for a 5-acre site and for a sensitive receptor assumed to be located 25 meters to the construction area.

SOURCE: ESA, 2025.

As shown in Table 5, Estimated Maximum Unmitigated Localized Operational Emissions, the increases in localized emissions of NO X, CO, PM10, and PM2.5 emissions during operation of the Project would not exceed the SCAQMD -recommended localized significance thresholds at sensitive receptors in proximity to the Project Site.

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3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-13 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 5
ESTIMATED MAXIMUM UNMITIGATED LOCALIZED OPERATIONAL EMISSIONS (POUNDS PER DAY)a Source NOX CO PM10 PM2.5
Area 0.79 87.16 0.07 0.06
Energy 3.17 1.54 0.25 0.25
Restaurant Charbroilers 0.0 0.0 0.19 0.12
Total Localized Project Operational Emissions 3.95 88.71 0.52 0.42 SCAQMD Localized Significance Thresholdb 197.0 1796.0 4.0 2.0 Exceeds Thresholds? No No No No
NOTE:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A. b. The SCAQMD LSTs are based on Source Receptor Area 3 (Southwest Los Angeles County Coastal) for a 5-acre site with sensitive receptors conservatively assumed to be 25 meters to the Project Site. c. Conservatively, existing site emissions were not estimated and subtracted from Project operational emissions for this analysis. Therefore, the net Project operational emissions would be lower than those presented in this table.

SOURCE: ESA, 2025

As shown in Tables 4 and 5, above, the Project would have localized emissions below the applicable SCAQMD thresholds for both construction and operation. Therefore, the P roject would not increase the frequency or severity of an existing violation or cause or contribute to new violations for ozone. Impacts regarding the timely attainment of air quality standards or interim emission reductions specified in the SCAQMD 2022 Air Quality Management Plan (AQMP) and impacts would be less than significant.

The Project’s construction and operations would not obstruct implementation of the 2022 AQMP as the Project would comply with CARB’s requirements to minimize short-term emissions from on-road and off- road diesel equipment, and with SCAQMD’s regulations such as Rule 403 for controlling fugitive dust and Rule 1113 for controlling volatile organic compounds (VOC) emissions from architectural coatings. Thus, the Project’s criteria pollutant emissions would not cause the Air Basin’s criteria pollutant emissions to worsen so as to impede the SCAQMD’s efforts to achieve attainment with respect to any criteria pollutant for which it is currently not in attainment of the NAAQS and the CAAQS (e.g., ozone, PM10, and PM2.5), or to cause the Air Basin to deteriorate from its current attainment status with respect to any other criteria pollutant emissions.

The Project would generate short -term construction jobs, but these jobs would not necessarily bring new construction workers or their families into the region. Therefore, the Project’s construction jobs would not conflict with the long -term employment or population projections upon which the 2022 AQMP is based, which incorporates regional demographic projections and integrated regional land use and transportation strategies from SCAG’s 2020 -2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS).

The Project Site is located in the Fox Hills neighborhood within Culver City and is currently designated for MU-HD use in the General Plan 2045. The Project would demolish the four one - and two-story office buildings total ing approximately 146,414 sf and associated surface parking to construct a mixed-use residential and commercial project within an approximate 8.34 acre property that would be consistent with the Land Use and Community Design Element of the City’s General Plan 2045 (see Section 3.10, Land Use and Planning, of this document). The Project is committed to providing pedestrian connections to nearby

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-14 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

neighborhood uses and transit options. The Project’s location, design, and land use planning aim to reduce vehicle trips by increasing the density of residential and commercial uses in proximity to public transit.

Several public transit stops operated by Los Angeles County Metro, and Culver City Bus are located in close proximity to the Project S ite. As such, the Project would not conflict with Connect SoCal 2020 policies for the concentration of growth in proximity to transit.

Furthermore, the Project’s growth would be in excess of the population and household growth projections, but within the employment growth projections contained in Connect SoCal 2020, which served as the basis for the 2022 AQMP .10 Based on Connect SoCal 2020 growth projections in the City of SCAG’s year 2045 relative to 2016, the Project’s proposed 1,077 residential units would comprise approximately 108 percent of an estimated increase of 1,000 households within the City, the Project’s projected 2,693 resident population would comprise approximately 179 percent of the estimated increase of 1,500 population, and a decrease in the number of employees on the Project Site of approximately 679 net employees, compared to existing uses which would comprise a decrease of 14 percent of SCAG’s year 2045 estimated increase of 4,800 employees.11 However, as discussed in Section 3.13, Population and Housing, of this document , the City ’s October 2021- 2029 Housing Element, which is based on the SCAG’s 6th Cycle Regional Housing Needs Assessment (RHNA) 12 allocations, indicates the total housing growth need for the City during the planning period through 2029 is 3,341 housing units. Accordingly, the Project’s proposed housing would constitute 32 percent of the 6th Cycle RHNA allocations between 2021 and 2029 (refer to Section 3.13, Population and Housing, of this document for additional details). Therefore, the Project would be consistent with City’s 6th Cycle RHNA allocations.

Also, as discussed in Section 3.13, Population and Housing, of this document, the Project would be well within the household, population and employment projections of the City’s General Plan 2045. The population, housing, and employment projections assumed for the General Plan are higher than SCAG’s Connect SoCal 2020-2045 and 2024-2050 estimates since the General Plan 2045 provides for additional population, housing, and employment capacity not anticipated by SCAG, including housing needs to meet the City’s RHNA allocations. However, since SCAG projections are based on the prior General Plan land uses, future SCAG planning documents would be updated to reflect the City’s General Plan 2045 projections.

In addition, the Project would be consistent with the General Plan Mixed Use High designation, MU -HD Zoning District, and Land Use and Community Design Element Policies, within the Fox Hills

10 While the 2024–2050 RTP/SCS (Connect SoCal 2024) has been released, it has not been incorporated into the AQMP and, therefore, the 2020–2045 RTP/SCS (Connect SoCal 2020) remains applicable for purposes of addressing air quality impacts.
11 SCAG, 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth-forecast.pdf?1606001579.

Accessed April 2025.
12 SCAG’s 6th Cycle Regional Housing Needs Assessment focused on existing need (current housing shortages and overcrowding) plus projected growth, which takes into account factors beyond what was used to determine the Connect SoCal projected growth. Therefore, the 6th Cycle RHNA allocation for the City results in a higher allocation of housing than what is represented in Connect SoCal, which is focused solely on projected or future growth (see Section 3.13, Population and Housing, of this document, for additional details).

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-15 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

neighborhood. The City is anticipating new growth in the Fox Hills neighborhood, and therefore, the Project would not induce substantial unplanned population growth.13 Furthermore, as discussed in Section 3.13, Population and Housing , of this document, the Project would support and not conflict with relevant goals, objectives , and policies in the City’s General Plan. Most notably, the Project would provide high-quality infill housing through the provision of 1,077 residential units with a diverse mix of dwelling types, containing both market -rate and 78 Very Low Income units , with a range of household sizes. These characteristics of the Project would support Land Use and Housing objectives and policies for increasing mixed-use development on large development sites within Fox Hills and near transit, increasing housing supply and affordable housing in the City, and promoting access to affordable housing through the use of State and local incentives. 14 Therefore, based on the above analysis, the Project would not spur additional growth other than that already anticipated for Culver City and captured within the Certified PEIR, nor would the Project eliminate impediments to growth. Therefore, impacts would be less than significant, and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
Mitigation Measures PEIR MM AQ-1 to PEIR MM AQ-5 listed below are set forth in the Certified PEIR and the associated MMP to address air quality impacts under Threshold a) and are applicable to the General Plan 2045 Project. However, Mitigation Measures PEIR MM AQ-1 to PEIR MM AQ -5 are not applicable to the Project. Although not identified in the Certified PEIR for addressing impacts under Threshold a), Mitigation Measures PEIR MM AQ-6 (below under Threshold c) is relevant to addressing Project-specific air quality impacts for the Project. In accordance with Mitigation Measure PEIR MM AQ-6, a Project - specific air quality impact analysis was conducted for the Project to determine emissions of criteria pollutants, which are shown in Tables 4 and 5, above.

PEIR MM AQ-1: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of NOX, CO, PM10 and/or PM2.5 shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off -Road New Diesel Engine Emission Standards for construction equipment with more than 50 horsepower, unless it can be demonstrated to the Culver City Department of Building and Safety that such equipment is not available. Project sponsor s should also consider including zero emissions (ZE) or zero net emissions (ZNE) technologies where appropriate and feasible or higher tier standard diesel equipment as it becomes developed and feasible. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine, as defined by CARB regulations.

Prior to construction, the project engineer shall ensure that all plans for construction phases (e.g., demolition, grading) that would exceed the SCAQMD significance thresholds clearly show the requirement for USEPA and/or CARB Tier 4 or higher emissions s tandards for construction

13 Refer to Section 3.10, Land Use and Planning, and 3.13, Population and Housing, of this document, for additional information regarding consistency with the City’s General Plan goals with respect to population and housing. 14 Refer to Section 3.10, Land Use and Planning, and 3.13, Population and Housing, of this document, for additional information regarding consistency with Connect SoCal 2024.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-16 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

equipment over 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the construction site for verification by the Culver City Department of Building and Safety. The construction equipment list shall state the makes, models, and numbers of construction equipment on-site. Equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with Section 2449 of the California Code of Regulations, Title 13, Article

4.8, Chapter 9.

PEIR MM AQ-2: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of volatile organic compounds (VOCs) as a result of VOC off - gassing emissions from architectural coatings and industrial maintenance coatings shall require the construction contractor to use SCAQMD Low -VOC and/or Super Compliant VOC architectural coatings and industrial maintenance coatings such that daily volume of coatings applied would not result in emissions that exceed the SCAQMD significance threshold for VOC, unless it can be demonstrated to t he City Department of Building and Safety that such coatings for a required application are not available. During construction, the construction contractor shall maintain a list of all architectural coatings and industrial maintenance coatings in use on the construction site and the daily volumes of coatings applied for verification by the Culver City Department of Building and Safety.

PEIR MM AQ-3: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and that exceed the South Coast Air Quality Management District significance threshol ds during operations shall, prior to issuance of a building permit, show on the building plans that all major appliances (dishwashers, refrigerators, clothes washers, and dryers) to be provided/installed are Energy Star – certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star or equivalent appliances shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.

PEIR MM AQ-4: Applicants for new residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the feature below has been incorporated into the d esign of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• For multifamily dwellings, electric vehicle charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the CALGreen Code (or its successor code).

PEIR MM AQ -5: Applicants for new non-residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the features below have been incorporated into the design of the building(s). Proper

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-17 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
• Facilities shall be installed to support future electric vehicle charging at each nonresidential building with 30 or more parking spaces. Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).

Mitigation Measures PEIR MM AQ-1 through AQ-5 are not applicable to the Project because, as noted above, the Project does not exceed the SCAQMD significance thresholds. b) Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non -attainment under an applicable federal or state ambient air quality standard?
Impact Determination in the Certified PEIR
The Certified PEIR determined that impacts related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment during construction and operation would be significant and unavoidable due to regional emissions that could exceed the SCAQMD significance thresholds. While implementation of Mitigation Measures PEIR MM AQ-1 through PEIR MM AQ-5 serve to reduce the severity of the impacts, impacts remain significant and unavoidable.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment during construction and operation, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Project construction activities that would have the potential to create regional air quality impacts include use of heavy -duty off -road construction equipment, on-road vehicle trips generated by construction workers, vendor trucks, and haul trucks traveling to and from the Project Site, fugitive dust emissions from material and soil handling, and building activities, such as the application of paint and other surface coatings. The Project’s daily regional criteria pollutant emissions during construction have been estimated by assuming a conservative scenario for construction activities (i.e., assuming all construction occurs at the earliest feasible date, given that regulatory requirements will improve future emissions associated with fleet, vehicle, and equ ipment mixes) and applying the mobile source and fugitive dust emissions factors.

The emissions have been estimated using the CalEEMod software (Version 2022.1), an emissions inventory software program recommended by the SCAQMD. Emissions from off -road equ ipment and on-road vehicles were estimated through CalEEMod since CalEEMod is based on outputs from the CARB off-road emissions factor (OFFROAD), which is the emissions estimation model developed by CARB and used to

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-18 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

calculate emissions from construction activities, including off -road vehicles, and incorporates CARB’s latest on-road vehicle EMissions FACtor (EMFAC) model, EMFAC2021 . The input values used in this analysis were adjusted to be Project-specific based on equipment types and the construction schedule. When information was unknown, CalEEMod defaults were used. Project construction would be separated into three phases of development. Phase 1 would consist of the development of Parcel 1 and is anticipated to commence in January 2027 and require approximately 27 months. Phase 2 would consist of the development of Parcel 2 and is anticipated to commence in April 2028 and require approximately 27 months. Phase 3 would consist of the development of Parcel 3 and is anticipated to commence in July 2029 and require approximately 27 months. Overall, Project construction is expected to occur over 57 months .

If construction or operation commences at a later date, emissions would be lower than those estimated below due to the use of a more energy -efficient and cleaner burning vehicle fleet mix, pursuant to State regulations that require vehicle fleet operators to phase-in less polluting trucks . As shown in Table 6, Estimated Maximum Unmitigated Regional Construction Emissions , regional Project-related construction emissions would not exceed the SCAQMD significance thresholds during construction. Therefore, the Project would not result in new significant construction air quality impacts and would not result in a substantial increase in the severity of impacts compared to those identified in the Certified PEIR.

TABLE 6
ESTIMATED MAXIMUM UNMITIGATED REGIONAL CONSTRUCTION EMISSIONS (POUNDS PER DAY)a Source VOC NOX CO SO2 PM10b PM2.5b
Parcel 1
Demolition - 2027 0.54 7.28 9.03 0.03 5.28 1.00
Grading/Excavation - 2027 1.26 21.70 25.78 0.11 3.04 1.06 Subterranean Work/Concrete Structure - 2027 2.14 19.64 31.11 0.12 6.28 1.89 Framing/Building Enclosure - 2028 0.53 6.64 18.45 0.07 5.44 1.43 Finishes - 2028 13.81 1.42 6.56 0.02 1.92 0.50
Finishes - 2029 13.80 1.37 6.27 0.02 1.91 0.49
Paving/Site Work – 2028 0.88 7.44 12.02 0.03 0.50 0.29
Paving/Site Work – 2029 0.85 7.23 11.98 0.02 0.48 0.27
Parcel 2
Demolition - 2028 0.51 6.39 8.57 0.02 1.54 0.40
Grading/Excavation - 2028 1.24 21.13 25.64 0.11 3.00 1.04 Subterranean Work/Concrete Structure - 2028 2.08 18.56 29.34 0.12 5.87 1.77 Subterranean Work/Concrete Structure - 2029 1.77 13.10 24.04 0.10 5.31 1.59 Framing/Building Enclosure - 2029 0.47 6.00 16.51 0.06 5.02 1.32 Finishes - 2029 12.03 1.34 5.88 0.02 1.76 0.45
Finishes - 2030 12.01 1.30 5.64 0.02 1.75 0.45
Paving/Site Work – 2030 0.82 7.09 11.89 0.02 0.47 0.26
Parcel 3
Demolition – 2029 0.52 6.92 8.89 0.03 2.71 0.60
Grading/Excavation – 2029 1.22 20.60 25.46 0.10 3.01 1.03 Subterranean Work/Concrete Structure – 2030 1.95 16.38 27.05 0.11 5.69 1.70 Framing/Building Enclosure – 2030 0.45 5.66 15.61 0.06 4.92 1.29 I I
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3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-19 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 6
ESTIMATED MAXIMUM UNMITIGATED REGIONAL CONSTRUCTION EMISSIONS (POUNDS PER DAY)a Source VOC NOX CO SO2 PM10b PM2.5b
Finishes – 2031 12.05 1.27 5.36 0.02 1.73 0.44
Paving/Site Work – 2031 0.78 6.87 11.80 0.02 0.45 0.24
Overlapping Phases
Parcel 1 – Finishes 2028 and Parcel 1 – Paving/Site Work 2028 14.69 8.86 18.58 0.04 2.42 0.78 Parcel 1 – Finishes 2029 and Parcel 1 – Paving/Site Work 2029 14.65 8.60 18.26 0.04 2.39 0.76 Parcel 2 – Demolition 2028 and Parcel 1 – Framing/Building Enclosure 2028

1.03 13.02 27.02 0.09 6.98 1.83
Parcel 2 – Excavation 2028 and Parcel 1 – Finishes 2028 15.06 22.55 32.20 0.12 4.92 1.54 Parcel 2 – Subterranean Work/Concrete Structure 2028 and Parcel 1 - Finishes 2028 and Parcel 1-Paving/Site Work 2028

16.77 27.41 47.92 0.16 8.29 2.56
Parcel 2 – Subterranean Work/Concrete Structure 2029 and Parcel 1 - Finishes 2029 and Parcel 1 Paving/Site Work 2029

16.43 21.70 42.30 0.14 7.71 2.35
Parcel 2 – Framing/Building Enclosure 2029 and Parcel 3 – Demolition 2029

0.99 12.92 25.41 0.09 7.73 1.92
Parcel 2 - Finishes 2029 and Parcel 3 – Excavation 2029 13.25 21.94 31.34 0.12 4.77 1.49 Parcel 2 – Finishes 2030 and Parcel 2 – Paving/Site Work 2030 and Parcel 3 – Subterranean Work/Concrete Structure 2030

14.79 24.78 44.58 0.15 7.91 2.41
Parcel 3 – Finishes 2031 and Parcel 3 – Paving/Site Work 2031 12.83 8.14 17.17 0.04 2.18 0.68 Maximum Daily Regional Emissions 16.77 27.41 47.92 0.16 8.29 2.56 SCAQMD Regional Significance Threshold 75 100 550 150 150 55 Exceed Threshold? No No No No No No
NOTES:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A of this document.
b. Emissions include fugitive dust control measures consistent with SCAQMD Rule 403.

SOURCE: ESA, 2025.

Project operational emissions were also estimated using CalEEMod Version 2022.1 to forecast the daily regional criteria pollutant emissions from on-site area and stationary sources and off-site mobile emissions that would occur during long-term Project operations. CalEEMod n atural gas usage factors are based on recreational and retail data from the C EC, and landscape equipment emissions are based on off -road emission factors from CARB. Emissions from the use of consumer products and the reapplication of architectural coatings are based on data provided in CalEEMod. Operational criteria pollutant emissions were calculated for area, energy, and mobile sources for a Proposed Project Interim Year (20 29) where it is assumed Parcel 1 would be built and operational with concurrent remaining construction on the remaining parcels and the Project’s full buildout operational year (2031) . Operational mobile trips and water usage factors were provided by the Project’s Transportation Study and Water Supply Assessment. 15,16. Results of
the criteria pollutant calculations are presented in Table 7, Estimated Maximum Unmitigated Regional Emissions from Interim Operations and Concurrent Construction and Table 8, Estimated Maximum

15 Fehr & Peers, 5757 Uplander Project Transportation Impact Study, June 2025. (Appendix K). 16 Golden State Water Company. Water Supply Assessment and Verification for 5757 Uplander Way. July 2025. (Appendix M).

I I I I I I
I I

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-20 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Unmitigated Regional Full Buildout Operational Emissions (pounds per day) , along with the regional significance thresholds. The operational -related daily emissions for the criteria and precursor pollutants (VOC, NOX, CO, sulfur dioxide ( SO2), PM10, and PM2.5) would be substantially below the SCAQMD thresholds of significance. Therefore, the Project would not result in new significant operational air quality impacts and would not result in a substantial increase in the severity of impacts compared to those identified in the Certified PEIR.

TABLE 7

ESTIMATED MAXIMUM UNMITIGATED REGIONAL EMISSIONS FROM INTERIM OPERATIONS AND CONCURRENT CONSTRUCTION (POUNDS PER DAY)a
Source VOC NOX CO SO2 PM10 PM2.5
Mobile Vehicles 3.33 4.41 30.60 0.09 9.15 2.33
Area (Coating, Consumer Products, Landscaping) 13.02 0.28 30.83 0.00 0.03 0.02 Energy (Natural Gas) 0.07 1.22 0.63 0.01 0.10 0.10
Restaurant charbroilers 0.06 0.00 0.00 0.00 0.19 0.12
Parcel 1 Maximum Daily Operational Emissions 16.48 5.92 62.07 0.10 9.47 2.57 Project Overlapping Construction 14.47 24.78 44.58 0.15 7.28 2.41 Total Project (Interim Conditions) 31.26 30.69 106.64 0.26 17.38 4.97 SCAQMD Regional Significance Threshold 55 55 550 150 150 55 Exceeds Thresholds? No No No No No No
NOTE:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A of this document.
b. Operational impacts were assessed for a Proposed Project Interim Year (2029) where it is assumed Parcel 1 would be built and operational with concurrent remaining construction on the remaining parcels and the Proposed Project full buildout year (2031). c. Conservatively, existing site emissions were not estimated and subtracted from Project operational emissions for this analysis. Therefore, the net Project operational emissions would be lower than those presented in this table.

SOURCE: ESA, 2025.

TABLE 8
ESTIMATED MAXIMUM UNMITIGATED REGIONAL FULL BUILDOUT OPERATIONAL EMISSIONS (POUNDS PER DAY)a Source VOC NOX CO SO2 PM10 PM2.5
Mobile Vehicles 7.92 10.46 72.64 0.23 23.59 6.01
Area (Coating, Consumer Products, Landscaping) 35.60 0.79 87.16 0.00 0.07 0.06 Energy (Natural Gas) 0.18 3.17 1.54 0.02 0.25 0.25
Restaurant charbroilers 0.06 0.00 0.00 0.00 0.19 0.12
Project Maximum Daily Operational Emissions 43.77 14.41 161.35 0.26 24.11 6.43 SCAQMD Regional Significance Threshold 55 55 550 150 150 55 Exceeds Thresholds? No No No No No No
NOTE:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A of this document. b. Conservatively, existing site emissions were not estimated and subtracted from Project operational emissions for this analysis. Therefore, the net Project operational emissions would be lower than those presented in this table.

SOURCE: ESA, 2025.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-21 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

For purposes of the cumulative air quality analysis with respect to CEQA Guidelines Section 15064(h)(3), the Project’s incremental contribution to cumulative air quality impacts is determined based on compliance with the SCAQMD adopted AQMP. As discussed above under Threshold a), the Project would not conflict with or obstruct implementation of AQMP and would be consistent with the growth projections in the AQMP and the Certified PEIR . In addition, the SCAQMD recommends that project-specific air quality impacts be used to determine the potential cumulative impacts to regional air quality. As shown in Table 6 Table 7 and Table 8 , all pollutants would be below the SCAQMD significance thresholds for regional emissions. Therefore, the P roject’s incremental contribution to long-term emissions of non -attainment pollutants and ozone precursors, considered together with cumulative projects, would not be cumulatively considerable and, therefore, the cumulative impact of the Project would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
Mitigation Measures PEIR MM AQ-1 to PEIR MM AQ-5 (listed above) are set forth in the Certified PEIR and the associated MMP to address air quality impacts under Threshold b) and are applicable to the General Plan 2045 and Zoning Code Update Project. However, Mitigation Measures PEIR MM AQ-1 to PEIR MM AQ-5 are not applicable to the Project because, as explained above, the Project does not exceed the SCAQMD significance thresholds. Although not identified in the Certified PEIR for addressing impacts under Threshold b), Mitigation Measure PEIR MM AQ-6 (discussed below under Threshold c) is relevant to addressing Project -specific air quality impacts for the Project. In accordance with Mitigation Measure PEIR MM AQ-6, a Project-specific air quality impact analysis was conducted for the Project to determine regional emissions, which is shown in Tables 6,7, and 8 above. c) Would the Project expose sensitive receptors to substantial pollutant concentrations? Impact Determination in the Certified PEIR
Potential new development that would occur as a result of the General Plan 2045 and Zoning Code Update will likely occur close to existing sensitive receptors , and thus future development has the potential to expose sensitive receptors to substantial pollutant concentrations. The Certified PEIR determined that impacts related to exposure of sensitive receptors to substantial pollutant concentrations during construction and operation would be significant and unavoidable due to l ocalized emissions and toxic air contaminant emissions that could exceed the applicable significance thresholds. Implementation of PEIR MM AQ-1, PEIR MM AQ-3, PEIR MM AQ-6, and PEIR MM AQ-7 serves to reduce the severity of the impacts to exposure of sensitive receptors to substantial pollutant concentrations. However, while the implementation of these measures would help to reduce the severity of the impacts , the impacts could nonetheless exceed the significance thresholds, and thus impacts would be significant and unavoidable.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to an exposure of sensitive receptors to substantial pollutant concentrations during construction and operation, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-22 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
Localized Emissions
The nearest existing sensitive receptors include medical uses at the Pacific Interventional Vascular Access Center located 50 feet to the southwest of the Project Site, multifamily residential uses located 420 feet to the east of the Project Site, proposed future multi-family residential uses located 75 feet to the south of the Project Site, future school uses located 75 feet to the south of the Project Site, proposed future multi-family residential uses located 390 feet to the northeast, and multifamily residential uses located 850 feet to the south of the Project Site . Consistent with Mitigation Measure PEIR MM AQ -6, a localized Project construction-related air quality analysis was conducted for the Project in conformance with SCAQMD methodology for assessing localized significance thresholds (LST) air quality impacts. The maximum daily localized emissions for each of the construction phases and the localized significance thresholds are presented in Table 4 above. Localized P roject-related construction emissions would not exceed the SCAQMD localized significance thresholds. Therefore, Project impacts would be significantly below the SCAQMD significance thresholds and would not result in a substantial increase in the severity of impacts and would be within the scope of impacts analyzed in the Certified PEIR.

The maximum daily operational localized emissions and the localized significance thresholds for P roject operations are presented in Table 5 above. As presented in Table 5, the localized operation emission levels for the P roject would not exceed the SCAQMD localized significance thresholds. T he Project emissions would not result in a significant localized operation air quality impact and would be within the scope of impacts analyzed in the Certified PEIR.

Carbon Monoxide Hotspots
As stated in the Certified PEIR, the potential for the Project to cause or contribute to CO hotspots was evaluated by comparing Project intersections (both intersection geometry and traffic volumes) with prior studies conducted by SCAQMD in support of thei r AQMPs and considering existing background CO concentrations. The SCAQMD conducted CO modeling for the 2003 AQMP for the four worst -case intersections in the Air Basin. The SCAQMD notes that the intersection of Wilshire Boulevard and Veteran Avenue is the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. The evidence provided in Table 4-10 of Appendix V of the 2003 AQMP shows that the peak modeled CO concentration due to vehicle emissions (i.e., excluding background concentrations) at these four intersections was 4.6 ppm (one-hour average) and 3.2 ppm (eight -hour average) at Wilshire Boulevard and Veteran Avenue. Therefore, projects that result in traffic at any intersection of less than 100,000 vehicles per day would be considered to be less than significant. Based on the Project’s Tra nsportation Study,
17 under the Future with Project Conditions (2031 ), the segment of Slauson Avenue between the Buckingham Parkway and Shenandoah Avenue would have a traffic volume of approximately 48,040 average daily trips 18. As a result, the Project would not result in daily traffic volumes exceeding 100,000 vehicles per day, and therefore CO concentrations would be less than those

17 Fehr & Peers, 5757 Uplander Project Transportation Impact Study, June 2025. (Appendix K). 18 The traffic volume of approximately 48,040 ADT was estimated based on the peak hour intersection volumes under Future plus Project conditions and the general assumption that peak hour trips represent approximately 10 percent of daily trip volumes (the Federal Highway Administration considers 10 percent to be a standard assumption; see Travel Model Improvement Program Time-of-Day Modeling Procedures: State-of-the-Practice, State-of-the-Art (2.0 Standard Approaches,
http://www.fhwa.dot.gov/planning/tmip/publications/other_reports/tod_modeling_procedures/ch02.cfm).

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-23 City of Culver City
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estimated in the 2003 AQMP, which would not exceed the SCAQMD significance thresholds. Therefore, the Project would not contribute to the formation of CO hotspots nor result in a new CO hotspot impact and would be within the scope of impacts analyzed in the Certified PEIR.

Toxic Air Contaminants
The greatest potential for TAC emissions during Project construction would be related to diesel particulate matter (DPM) emissions associated with heavy-duty equipment during construction activities. Construction activities associated with the Project would be sporadic, transitory, and short term in nature (approximately 57 months). Due to the Project’s proximity to sensitive receptors, consistent with PEIR MM AQ -7, a construction-related air quality study was conducted for the Project in conformance with SCAQMD methodology for assessing potential health risk impacts. As noted by SCAQ MD, the Office of Environmental Health Hazard Assessment (OEHHA) is responsible for developing and revising guidelines for performing health risk assessments (HRAs) under the State’s Air Toxics Hot Spots Program Risk Assessment (AB 2588) regulation. In March 2015, OEHHA adopted revised guidelines that update the previous guidance by incorporating advances in risk assessment with consideration of infants and children using Age Sensitivity Factors (ASF). The construction HRA for the Project was performed in accordance with the revised OEHHA Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (OEHHA Guidance). The analysis incorporates the estimated construction emissions, as previously discussed, and dispersion modeling using the USEPA AERMOD model with meteorological data from the closest SCAQMD monitoring station.

The maximum daily construction regional and localized emissions were estimated for each construction phase of the Project. However, t hese emissions would not represent the emissions that would occur for every day of construction. The refore, to account for the average construction usage, the average daily equipment usage hours and average daily emissions of each construction phase were applied in the Project’s construction HRA. Detailed assumptions, modeling and calculations can be found in Appendix A of this document.

The Project’s health risk calculations were performed using a spreadsheet tool consistent with the OEHHA guidance, which incorporates the algorithms, equations, and a variable described above as well as in the OEHHA guidance and incorporates the results of the AERMOD dispersion model.

As shown in Tabl e 9, Maximum Health Risk Impacts for Off -Site Sensitive and Commercial Receptors, unmitigated results of the HRA cancer risk for residential land uses exceed the SCAQMD significance threshold of 10 per million; therefore, this impact is potentially significant, and mitigation would be required. Also, as shown in Table 9, the unmitigated cancer risk for school and medical/commercial land uses does not exceed the SCAQMD significance threshold of 10 per million , and hazard index values for all receptor types were below the SCAQMD significance threshold of 1.0; therefore, chronic impacts would be less than significant.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-24 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 9

MAXIMUM HEALTH RISK IMPACTS FOR OFF-SITE SENSITIVE AND COMMERCIAL RECEPTORS Sensitive Receptor
Without Certified PEIR MM AQ-1 and
Project MM AQ-1
With Certified PEIR MM AQ-1 and
Project MM AQ-1
Maximum
Cancer Risk
(# in one million) Hazard Index
Maximum
Cancer Risk
(# in one million) Hazard Index
Residential Land Use 46.43 0.08 8.99 0.02
School Land Use 2.72 0.01 0.53 <0.01
Medical/Commercial (Worker) 2.43 0.08 0.48 0.02
Maximum Health Impact Thresholds 10 1.0 10 1.0
Exceeds Threshold? Yes No No No
SOURCE: ESA, 2025.

As Project unmitigated results of the HRA cancer risk for residential land use would exceed the SCAQMD significance threshold, the Project would implement Mitigation Measure PEIR MM AQ-1 , as described below. In addition, the Project would implement Mitigation Measure Project MM AQ-1, which is based off Mitigation Measure PEIR MM AQ -1, and includes the use of off -road diesel -powered construction equipment that meets or exceeds the CARB USEPA Tier 4 Final off-road emissions standards or equivalent for construction equipment rated at 25 horsepower or greater during Project construction where available within the Air Basin (Mitigation Measure Project MM AQ -1 is listed below). Note that the primary difference between Mitigation Measure PEIR MM AQ-1 and Project MM AQ- 1 is that the latter requires Tier 4 equipment on equipment over 24 horsepower, while the former only requires Tier 4 equipment on equipment over 50 horsepower. Therefore, the Project’s impact related to health risks would be less than significant with implementation of Mitigation Measures PEIR MM AQ -1 and Project MM -AQ-1. The calculated cancer risk was estimated for outdoor exposure and assumes that sensitive receptors (residential uses) would not have any mitigation such as mechanical filtration and that residential uses would have continuously open windows. As shown in Table 9, maximum cancer risk and hazard index for school and medical/commercial receptors would be below the SCAQMD significance thresholds without mitigation, but would be further reduced with the implementation of Mitigation Measures PEIR MM AQ-1 and Project MM AQ -1. As the mitigated maximum cancer risk and non -cancer impacts would be less than the SCAQMD significance thresholds, impacts would be less than significant with mitigation.

The process of assessing health risks and impacts includes a degree of uncertainty, which is dependent on the availability of data and the extent to which assumptions are relied upon in cases where the data are incomplete or unknown. All HRAs rely upon scientific studies to reduce the level of uncertainty; however, it is not possible to completely eliminate uncertainty from the analysis. Where assumptions are used to substitute for incomplete or unknown data, it is standard practice in performing HRAs to err on the side of health protection to avoid underestimating or underreporting the risk to the public by assessing risk on the most sensitive populations, such as children and the elderly. As shown in Table 9, cancer risk and hazard index on nearby sensitive receptors would be below significance thresholds with the incorporation of Mitigation Measures PEIR MM AQ-1 and Project MM AQ-1 . These short -term emissions would not substantially contribute to a significant construction health risk. No residual emission s and corresponding individual cancer risk are anticipated after Project construction. Thus, construction activities would not

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-25 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

expose sensitive residential, school, and medical/commercial receptors to substantial toxic air contaminant concentrations, and construction-related health impacts would be mitigated to less than significant levels.

Thus, construction activities would not expose sensitive receptors to substantial toxic air contaminant concentrations, and construction-related health impacts would be within the scope of impacts analyzed in the Certified PEIR.

The SCAQMD recommends that operational health risk assessments be conducted for substantial sources of operational diesel particulate matter (e.g., truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has provided guidance for analyzing mobile source diesel emissions.19 Project operations would generate only minor amounts of diesel emissions from mobile sources, such as delivery trucks and occasional maintenance activities that would not exceed 100 trucks per day or more than 40 trucks with operating transport refrigeration units. Furthermore, Project trucks would be required to comply with the applicable provisions of the CARB 13 California Code of Regulations ( CCR), Section 2025 (Truck and Bus regulation) to minimize and reduce PM and NOX emissions from existing diesel trucks. Therefore, Project operations would not be considered a substantial source of diesel particulates. Typical sources of hazardous TACs include industrial manufacturing processes and automotive repair facilities. The Project would not include any of these potential sources, although minimal emissions may result from the use of consumer products (e.g., aeros ol sprays). The Project’s land uses would not include installation of industrial -sized paint booths or require extensive use of commercial or household cleaning products. Based on this, operation of the Project is not expected to release substantial amounts of TACs. Documentation from CARB indicates that DPM exhaust consists of 92 percent PM 2.5 and 100 percent PM 10 (PM2.5 is a subset of PM10). Therefore, localized DPM emissions strongly correlate with localized PM10 emissions. 20 As
presented in Table 5 above, localized PM 10 operation emissions are less than significant. Although the localized analysis does not directly measure health risk impacts, it does provide data that can be used to evaluate the potential to cause health risk impacts. Thus, operation of the Project would not expose sensitive receptors to substantial toxic air contaminant concentrations, and operation -related health impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
Mitigation Measures PEIR MM AQ-1, PEIR MM AQ -3, PEIR MM AQ -6, and PEIR MM AQ -7, are set forth in the Certified PEIR and the associated MMP to address air quality impacts under Threshold c) and are applicable to the General Plan 2045 and Zoning Code Update Project . As discussed above, PEIR MM AQ-3 are not applicable to the Project because the Project does not exceed the SCAQMD significant thresholds. In contrast, Mitigation Measures PEIR MM AQ-1, PEIR MM AQ-6 and PEIR MM AQ-7 are applicable to the Project and will be implemented, as discussed above.

PEIR MM AQ-6: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building

19 SCAQMD, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis, August 2003, http://www.aqmd.gov/docs/default-source/ceqa/handbook/mobile-source-toxics- analysis.doc?sfvrsn=2.
20 CARB. Speciation Profiles Used in ARB Modeling, PMSIZE – Particle size fraction data for source categories, PM Profile Number 425 (Diesel Vehicle Exhaust) [Excel data], 2024, https://www.arb.ca.gov/ei/speciate/speciate.htm.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-26 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

permit, submit a construction -related air quality study that evaluates potential localized project construction-related air quality impacts to the City Planning Department for review and approval.

The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing localized significance thresholds (LST) air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD-adopted threshol ds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the Planning Department.

PEIR MM AQ-7: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction -related air quality study that evaluates potential health risk impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coas t Air Quality Management District (SCAQMD) methodology for assessing health risk impacts. If health risk impacts are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City’s Planning Department.

Mitigation Measures MM AQ-6 and MM AQ-7 are applicable to the Project. As discussed in the following section, a Project-specific air quality study was conducted in compliance with MM AQ-6 and MM AQ-7.

Project-Specific Mitigation Measures Addressing Impact
The Project-specific air quality analysis conducted per Mitigation Measures PEIR MM AQ -6 and PEIR MM AQ-7 has resulted in the below Project-specific mitigation measure.

Project MM-AQ-1: The Applicant shall implement the following requirements for construction equipment operating at the Project site. These requirements shall be included in applicable bid documents and contractor(s) must demonstrate the ability to supply such equipment. Construction equipment shall include the following:
• The Project shall utilize off-road diesel-powered construction equipment that meets or exceeds the California Air Resources Board (CARB) and United States Environmental Protection Agency (USEPA) Tier 4 Final off-road emissions standards or equivalent for equipment rated at 25 horsepower (hp) or greater during Project construction where available within the Air Basin. Such equipment shall be outfitted with Best Available Control Technology (BACT), which means a CARB certified Level 3 Diesel Particulate Filter or equivalent. A copy of each unit’s certified tier specification, BACT documentation, and CARB or Southern California Air Quality Management District (SCAQMD) operating permit at the time of mobilization of each applicable unit of equipment shall be provided.

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5757 Uplander Project 3-27 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

d) Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Impact Determination in the Certified PEIR
Impacts that would result in other emissions (such as those leading to odors) adversely affecting a substantial number of people were evaluated in the Initial Study prepared as part of the Certified PEIR. The Initial Study determined that impacts would be less than significant because development allowed under the General Plan 2045 and Zoning Code Update would comply with SCAQMD Rule 1113 (Architectural Coatings) and SCAQMD Rule 402 (Nuisance), meaning that the construction activities and materials and operational activities would not result in other emissions that create objectionable odors.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to other emissions (such as those leading to odors), nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Potential activities that may emit odors during construction activities include the use of architectural coatings and solvents, as well as the combustion of diesel fuel in on - and off-road equipment. SCAQMD Rule 1113 (Architectural Coatings) limits the amount of volatile organic compounds from architectural coatings and solvents. According to the SCAQMD CEQA Air Quality Handbook, construction equipment is not a typical source of odors. Through mandatory compliance with SCAQMD Rules and CARB’s Air Toxics Control Measure regarding idling limitations for diesel trucks, no construction activities or materials are expected to create objectionable odors affecting a substantial number of people. Odors from the combustion of diesel fuel would be minimized by complying with the CARB Airborne Toxic Control Measures (ATCM) that limits diesel-fueled commercial vehicle idling to five minutes at any given location, which was adopted in 2004. The Project would also comply with SCAQMD Rule 402 (Nuisance), which prohibits the emissions of nuisance air contaminants or odorous compounds. Furthermore, as shown in Table 4 and Table 6, construction emissions would not exceed the SCAQMD significance thresholds for attainment, maintenance, or unclassifiable criteria air pollutants (i.e., CO and SO 2). Therefore, construction
activities would result in less than significant impacts with respect to other emissions, including those leading to odors, and thus the Project would not result in new significant construction air quality impacts and would be within the scope of impacts analyzed in the Certified PEIR.

According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fibergla ss molding. The Project includes residential and commercial uses and would not involve the types of uses typically associated with odor complaints. The Project would include various enclosed trash receptacles associated with the proposed development. On - site trash receptacles used by the Project would be covered and properly maintained to prevent adverse odors. With proper housekeeping practices, trash receptacles would be maintained in a manner that promotes odor control, and no adverse odor impacts are anticipated from the Project uses. Furthermore, as shown in Table 5, Table 7, and Table 9 , daily operational emissions would not exceed the SCAQMD

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-28 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

significance thresholds for attainment, maintenance, or unclassifiable criteria air pollutants (i.e., CO and SO2). Therefore, operation of the Project would result in less than significant impacts with respect to other emissions, including those leading to odors , and thus the Project would not result in new significant odor impact and would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to air quality would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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5757 Uplander Project 3-29 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.3 Biological Resources
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Biological Resources: Would the project:
(a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Less than
Significant
with
Mitigation
No No Impact Yes
(b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
No Impact No No Impact N/A
(c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Less than
Significant No No Impact N/A
(d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less than
Significant
with
Mitigation
No
Less than
Significant
with Mitigation
Yes
(e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less than
Significant No Less than
Significant N/A
(f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
No Impact No No Impact N/A

a) Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
Impact Determination in the Certified PEIR
As discussed in the Certified PEIR, the vast majority of the Planning Area is heavily developed and contains minimal biological resources; however, fragmented, isolated swathes of coastal scrub and chaparral vegetation remain throughout portions of the Inglewood Oil Field (IOF) and Kenneth Hahn State Recreation Area. While the majority of special -status biological resources have a low potential to occur within the Planning Area as result of the largely developed nature of the Planning Area, new development projects have the potential to impact existing habitats and associated special -status species. The Certified PEIR determined that impacts related to candidate, sensitive, or special status species would be less than significant with implementation of PEIR MM BIO-1 and PEIR MM BIO-2.

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CEQA Guidelines Sections 15168(c) Clearance October 2025

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to candidate, sensitive, or special status species, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urbanized area and is currently developed with four one - to two-story business park/office buildings and associated surface parking . No suitable habitat for candidate, sensitive, or special status species exists, and for this reason and because of the density of development and high levels of human activity in the Project area, there is a negligible potential for the Project Site to support candidate, sensitive, or special status species. In the unlikely circumstance that a sensitive bird species nested on the Project Site, the Project would implement Mitigation Measure PEIR BIO -2 to ensure that potentially significant impacts to nesting birds are reduced to a less than significant level. With implementation of PEIR MM BIO -2, impacts would be less than significant, and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
Mitigation Measures PEIR MM BIO -1 and PEIR MM BIO -2 are set forth in the Certified PEIR and the associated MMP to address biological resources impacts under Threshold a) and are applicable to the General Plan 2045 and Zoning Code Update Project. As discussed below, Mitigation Measures PEIR MM BIO-1 is not applicable to the Project, whereas Mitigation Measure PEIR BIO-2 is applicable to the Project.

PEIR MM BIO -1: Baseline Biological Assessment. The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats. The impact analysis will aid in determining any direct, indirect, and cumulative biological impacts from construction and operations, as well as specific mitigation or avoidance measures necessary to offset significant impacts associated with future projects. The Biological Assessment shall include the following information:
a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region [State CEQA Guidelines, § 15125(c)].
b. A thorough, recent, floristic-based assessment of special status plants and natural communities, following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018);
c. Floristic, alliance - and/or association -based mapping and vegetation impact assessments conducted at the project site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment (Sawyer et al, 2008). Adjoining habitat areas shall be included in this assessment where site activities could lead to direct or indirect impacts off-site. Habitat mapping at the alliance level will help establish baseline vegetation conditions;

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d. A complete, recent assessment of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species (Fish & Game Code, §§ 351 1, 4700, 5050 and 5515).

Species to be addressed should include all those which meet the CEQA definition of endangered, rare or threatened species (State CEQA Guidelines, § 15380); and, e. Identification of focused surveys for special-status plants and/or wildlife that could be directly or indirectly impacted by the project, which shall be conducted in the appropriate season prior to any habitat disturbance.
f. Identification of any aquatic habitats such as rivers, streams, and lakes and their associated natural plant communities/habitats. This includes any culverts, ditches, storm channels that may transport water, sediment, pollutants, and discharge into rivers, streams, and lakes. g. Avoidance and minimization measures (such as preconstruction wildlife clearance surveys) to fully avoid and otherwise protect sensitive biological resources from Project - related construction and operational impacts shall be identified and implemented. If impacts cannot be avoided, appropriate mitigation measures to offset potential special -status species and habitat impacts shall be identified and implemented.

Since the Project Site is not located within or adjacent to a natural plant or wildlife habitat (see Figure 34, Vegetation, of the Conservation Element), PEIR MM BIO-1 is not applicable to the Project.

PEIR MM BIO-2: Nesting Bird Surveys. Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any tree and/or vegetation removal with in the Project site. The nesting bird surveys shall be conducted at appropriate nesting times and concentrate on potential roosting or perch sites. Pre -construction surveys shall be conducted by a qualified biologist no more than 7 days prior to the beginning of any Project -related activity likely to impact raptors and migratory songbirds. If construction activities are delayed or suspended for more than 7 days during the breeding season, the surveys shall be repeated. If nesting raptors and migratory songbirds are identified, the following minimum no disturbance buffers shall be implemented: 100 feet around active passerine (perching birds and songbirds) nests, 300 feet around active raptor nests. These buffers should be maintained until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival.

Mitigation Measure PEIR MM BIO-2 would be applicable to the Project if construction activities take place during nesting season. If that is the case, the Project will comply with PEIR MM BIO-2. b) Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? Impact Determination in the Certified PEIR
Given the lack of any riparian habitat or sensitive natural community within the Planning Area, the Certified PEIR determined that no impacts to riparian habitat or other sensitive natural community would occur with implementation of the General Plan 2045 and Zoning Code Update Project.

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Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to riparian habitat or other sensitive natural community, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urbanized area and is currently developed with four one - to two-story business park/office buildings and associated surface parking . No designated riparian habitat or natural communities exist on the Project Site or in the surrounding area. The Project Site currently supports a limited amount of ornamental landscaping. Thus, the Project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community and no impact would occur , consistent with the impact findings of the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
c) Would the Project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Impact Determination in the Certified PEIR
Based on the habitats present within the Planning Area and review of the National Wetlands Inventory, there are no wetlands present within the Planning Area. Therefore, the General Plan 2045 and Zoning Code Update Project would have no impact on these resources. The Certified PEIR does recognize that the Ballona Creek Revitalization Project would enhance the restoration and use of Ballona Creek , which may require applicable future biological permitting within the Ballona Creek. However, the permit conditions would ensure that impacts to Ballona Creek are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to state or federally protected wetlands or waters, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urban area and is currently developed with four one- to two-story office buildings and associated surface parking. The Project Site does not contain any state or federally protected wetlands. Additionally, the Project Site is not located near Ballona Creek. As such, the Project would not have a substantial adverse effect on state or federally protected wetlands and no impact would occur , consistent with the impact findings in the Certified PEIR.

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
d) Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Impact Determination in the Certified PEIR
The Certified PEIR determined that General Plan 2045 and Zoning Code Update Project would not substantially interfere with the movement of native resident or migratory fish or wildlife species or with established wildlife corridors due to the lack of wildlife movement corridors within the Planning Area. In addition, the General Plan 2045 and Zoning Code Update Project would not impede the use of wildlife nursery sites with implementation of PEIR MM BIO-2 for migratory birds. Therefore, impacts would be less than significant with mitigation incorporated.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to interfering with wildlife corridors or wildlife nursery sites, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is currently developed and located in an urbanized area. No wildlife corridors or native wildlife nursery sites are present on the Project Site or in the immediate surrounding area. Further, due to the urbanized nature of the Project area, the potential for native resident or migratory wildlife species movement through the Project Site is negligible. Hannum Avenue, Uplander Way and Bristol Parkway are moderately to highly utilized streets with moderate levels of ambient noise and human dist urbance associated with pedestrian and vehicular traffic.

Nonetheless, the Project Site currently contains ornamental trees and landscaping, and there are adjacent street trees, all of which could support raptor and/or songbird nests for native species tolerant of human disturbance. Migratory nongame native bird species are protected by international treaty under the Federal Migratory Bird Treaty Act (MBTA) of 1918 (50 Code of Federal Regulations [CFR] Section 10.13).

Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit take of all birds a nd their active nests, including raptors and other migratory nongame birds (as listed under the Federal MBTA). As the Project would include the removal of existing trees on the Project Site and potentially the removal of adjacent street trees, the removal of vegetation with nesting birds during the breeding season is considered a potentially significant impact. However, Mitigation Measure PEIR MM -BIO-2 (as discussed above) would reduce potential impacts to protected nesting birds consistent with the Federal MBTA. Impacts would be less than significant with mitigation incorporated, and would be within the scope of impacts analyzed in the Certified PEIR.

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Certified PEIR’s Mitigation Measures Addressing Impact
Mitigation Measure PEIR MM-BIO-2, provided above, is set forth in the Certified PEIR and the associated MMRP to address biological resources impacts under Threshold b) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM BIO -2 is also applicable to the Project and will be implemented if applicable.
e) Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Impact Determination in the Certified PEIR
The Certified PEIR determined that implementation of the General Plan 2045 and Zoning Code Update Project would not introduce any potential conflicts with the existing Culver City Tree Removal Ordinance No. 2013-007 (Tree Removal), Los Angeles County Oak Tree Protection Ordinance, or the Los Angeles County Oak Woodlands Conservation Management Plan. As such, impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to a conflict with any local policies or ordinances protecting biological resources , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As contemplated in the Certified PEIR, the Project would be subject to, and would comply with, the City and County’s tree preservation ordinances, and the County’s oak woodland management policies, as applicable. As such, the Project will not create any conflicts with any local policies or ordinances protecting biological resources.

A Tree Inventory Report was prepared for the Project and is included in Appendix B of this document. No native or heritage trees, nor any street trees, were observed during the tree survey. A total of 334 trees were located within the Project Site, including Canary Island pines, lemon -scented eucalyptus, African fern pines, Brazilian pepper, California pepper, Callery pear, Canary Island date palm, carrotwood, Chinese elm, evergreen pear, London plane, Mexican fan palm, purple leaf plum, red ironbark, and s ilver dollar gum.

None of these are California native trees or City street trees, and none are considered protected. As such, the Project Site does not include any notable habitat that supports protected biological resources as part of local policies or ordinances. Nonetheless, it is noted that the Project would implement construction activities consistent with Mitigation Measure PEIR MM BIO -2 to protect nesting birds, as discussed above. T he Project would also comply with applicable landscaping requirements of the CCMC.

Therefore, since the Project will comply will all applicable regulations, the Project’s impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
f) Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Impact Determination in the Certified PEIR
Impacts related to a conflict with adopted habitat conservation plans or natural community conservation plans were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that no impacts would occur because there is no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plans in place for the Planning Area.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to a conflict with adopted habitat conservation plans or natural community conservation plans , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As discussed under Threshold b), no designated riparian habitat or natural communities exist on the Project Site or in the surrounding area. Additionally, there is no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan in place for the Project Site. The Project would thus have no impact with respect to these plans, consistent with the impact findings of the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to biological resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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3.4 Cultural Resources
Thresholds (and Supporting Information Sources):

Impact
Determination in
the Certified
PEIR
Does the Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Cultural Resources: Would the project:
(a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Significant and
Unavoidable No No Impact Yes
(b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines
§15064.5?
Less than
Significant with
Mitigation
No
Less Than
Significant With
Mitigation
Yes
(c) Disturb any human remains, including those interred outside of formal cemeteries?
Less than
Significant No Less than
Significant N/A

a) Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Impact Determination in the Certified PEIR
The Certified PEIR determined that future development facilitated under the General Plan 2045 and Zoning Code Update Project may include construction, demolition, or alteration of historic buildings/structures/objects/landscape features that have the potential to cause a substantial adverse change to historical resources as defined by CEQA Guidelines Section 15064.5, especially within the three designated historic districts of Culver City. Implementation of Mitigation Measure PEIR MM CUL-1 would help to reduce the severity of the impacts. However, even with implementation of this mitigation measure, impacts remain significant and unavoidable.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts to historic resources, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Consistent with Mitigation Measure PEIR MM CUL-1 (discussed below), a historic resource memorandum was prepared by Architectural Resources Group (ARG) in February 2024 for the Project (provided in Appendix C of this document) to determine if the existing buildings on the Project Site qualify for listing in the National Register of Historic Places, California Register of Historical Resources, or locally in the City of Culver City, and would therefore be considered a historical resource under CEQA. The Project Site was not identified through Culver City’s 1987 Historic Structures Field Survey, or any other historical resources survey, and it is not listed in the California Built Environment Resource Directory (BERD). It has not been formally designated under any federal, state, or local registration program. Per Section

15.05.020 of the CCMC, in order to be considered for local historic designation, a structure must be at least 50 years old or have special importance to the City. Unlike the National Register’s and Culver City’s 50-

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year age requirement, there is no prescribed age limit for listing in the California Register. However, California Office of Historic Preservation guidelines state that sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with a resource.21 The existing office buildings were completed between 1979 and 1980 (i.e., they are less than 50 years old) and do not have any historical associations with significant events or individuals that would render it of exceptional or special importance in Culver City, the greater Southern California region, or the nation. Based on the investigation included in Appendix C, the Project Site is not eligible for listing in the National Register of Historic Places or California Register of Historical Resources, or under Culver City’s Historic Preservation Program (Chapter 15.05 of the CCMC) . Therefore, no impacts under the Project would occur related to the significance of a historical resource and the Project’s impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The following mitigation measure is set forth in the Certified PEIR and the associated MMP to address historical resource impacts under Threshold a) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM CUL-1 is also applicable to the Project.

PEIR MM CUL-1. Prior to development of individual projects that are subject to CEQA within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Pro fessional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center or Built Environment Resources Directory (BERD) search; a review of pertinen t archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified potentially eligible historic resources will be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be fully evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mi tigation for affected historical resources to be implemented prior to their demolition or alteration. Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.

Mitigation Measure PEIR MM CUL -1 is applicable to the Project, and the Project is in compliance with MM CUL-1 given that, as discussed above, the Project obtained a historic resource assessment for the Project Site.
b) Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Impact Determination in the Certified PEIR
The archival research conducted within the Certified PEIR indicates that 18 known archaeological resources have been previously identified within the City. Current or prior existence of development throughout the

21 California Office of Historic Preservation, Technical Assistance Series #6: California Register and National Register: A Comparison (Sacramento, CA: California Department of Parks and Recreation, 2001), 3.

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City does not preclude the presence of archaeological resources located underneath existing development.

In addition, the City would have been a highly suitable area for the inhabitance of indigenous people in light of Ballona Creek flowing through the are a. Individual project -related demolition, construction, maintenance, and/or improvement activities have the potential to cause a potentially significant impact to archaeological resources. However, implementation of PEIR MM CUL-2, along with the City’s sta ndard conditions of approval and applicable General Plan policies, will reduce impacts to previously unknown archaeological resources to a less than significant level.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts to archeological resources, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Consistent with Mitigation Measure PEIR MM CUL-2 (see below), an archaeological resources assessment (including archival research and an archaeological sensitivity assessment) was prepared by ESA in March 2025 for the Project (provided in Appendix D of this document) to determine if the Project has the potential to encounter buried archaeological resources during construction. The archaeological sensitivity assessment indicates that the potential for encountering precontact archaeological resources is moderate to high based on the fact that six precontact 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 precontact inhabitants), and Native American villages ( Saa’anga and Waachnga) are situated in the vicinity (between 0.50 to approximately 1.65 miles away) of the Project Site. Additionally, fill soils occur within the Project Site (from surface down to 5 feet below ground surface) and a previous development project in Downtown Culver City yielded two precontact metates in disturbed fill sediments.

The subsurface archaeological sensitivity assessment for historic archaeology indicates that no previous historic uses have existed within the Project Site and that no historic -period archaeological resources have been previously recorded within the Project Site or 0.50-mile radius. Based on these results, the potential to encounter historic-period archaeological resources within the Project Site is considered low.

Based on the above, Project excavations, which are anticipated to reach depths of 25 feet bgs and footings to a depth of approximately 28 feet bgs, have potential for encountering buried precontact archaeological resources. Therefore, construction activities associated with the Project could potentially cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 and impacts would be potentially significant. This impact finding is consistent with the impact findings of the Certified PEIR. Accordingly, the site-specific archeological resources assessment conducted per Mitigation Measure PEIR MM CUL -2 resulted in foreseeable supplemental site-specific mitigation include d as Mitigation Measures Project MM CUL-1 to Project MM CUL-3. Implementation of Mitigation Measures Project MM CUL-1 to Project MM CUL-3 would reduce potentially significant impacts to a less than significant level , consistent with the impact findings of the Certified PEIR.

Operation of the new facilities and uses on the Project Site would not result in any further ground disturbing activities such as grading or excavation; therefore, there is no potential to encounter, alter, or disturb

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archaeological resources. No operational impacts would occur. Project impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The following mitigation measure is set forth in the Certified PEIR and the associated MMP to address archeological resources impacts under Threshold b) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM CUL-2 is also applicable to the Project.

PEIR MM CUL-2: Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a qualified archaeologist, defined as an individual meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology, to conduct an archaeological resources assessment. This assessment shall include a records search at the South Central Coastal Information Center; a Sacred Lands File search at the Native American Heritage Co mmission; and a pedestrian field survey of the project site. If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for eligibility in the California Register and local register. If a resour ce is determined to be eligible and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, archaeological construction monitoring shall be prescribed as a mitigation measure.

The methods and results of the archaeological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.

Mitigation Measure PEIR MM CUL -2 is applicable to the Project, and the Project is in compliance with MM CUL-2 given that, as discussed above, the Project obtained an archaeological resources assessment.

Based on the results of the assessment and in accordance with PEIR MM CUL-2, the Project will implement Project-specific mitigation measures, as discussed below.

Project-Specific Mitigation Measures Addressing Impact
The Project archeological resources analysis conducted per Mitigation Measure PEIR MM CUL -2 has resulted in the below listed Project-specific mitigation measures.

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

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ARCH-2: Prior to commencement of excavation activities, an Archaeological and Cultural Resources Sensitivity Training shall be given for construction personnel. The training session shall be carried out by the Qualified Archaeologist and shall focus on how to ide ntify archaeological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event.

ARCH-3: In the event that historic or precontact archaeological resources (e.g., bottles, foundations, refuse dumps, etc.) are unearthed, ground-disturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluated. After consulting with the Applicant, the Qualified Archeologist shall establish an appropriate buffer in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety cons iderations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where construction activities shall not be allowed to continue. Work within the buffer area shall only be allowed to continue after the evaluation and recovery efforts are completed. Work shall be allowed to continue outside of the buffer area.

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

ARCH-4: The Qualified Archaeologist shall prepare a final report and appropriate California Department of Parks and Recreation Site Forms at the conclusion of archaeological monitoring.

The report shall include a description of resources unearthed, if any, treatment of the resources, results of the artifact processing, analysis, and research, and evaluation of the resources with respect to the California Register of Historical Resources and CEQA. The report and the Site Forms shall be submitted by the Appli cant to the City, the South Central Coastal Information Center, and representatives of other appropriate or concerned agencies to signify the satisfactory completion of the Project and required mitigation measures.
c) Would the Project disturb any human remains, including those interred outside of dedicated cemeteries?
Impact Determination in the Certified PEIR
Impacts to human remains were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that impacts would be less than significant. Various regulatory provisions address how to handle human remains that could be inadvertently uncovered during excavation activities. These include

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State Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and State CEQA Guidelines Section 15064.5(e). Under these codes, if unrecorded human remains are discovered during construction within the Planning Area, excavation w ould be halted and the County Coroner would be notified. If the human remains are determined to be Native American, the California Native American Heritage Commission (NAHC) would be notified within 24 hours and the guidelines of the NAHC would be adhered to in the treatment and disposition of the remains. Compliance with these regulatory protocols would ensure that impacts on human remains would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts to human remains, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As previously indicated, the Project Site is fully developed. Nevertheless, the Project would require excavation that could extend into native soils, with the potential to encounter previously unknown human remains. As noted above, a number of regulatory provisions address the handling of human remains inadvertently uncovered during excavation activities. These include State Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and State CEQA Guidelines S ection 15064.5(e).

Pursuant to these codes, in the event of the discovery of unrecorded human remains during construction, excavations shall be halted and the County Coroner shall be notified. If the human remains are determined to be Native American, the California NAHC would b e notified within 24-hours and the guidelines of the NAHC would be adhered to in the treatment and disposition of the remains. Since the Project would comply with these regulatory protocols, if applicable, the Project’s impacts on human remains would be le ss than significant, and Project impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to cultural resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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3.5 Energy
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Energy: Would the project:
(a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than
Significant No Less than
Significant N/A
(b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less than
Significant No Less than
Significant N/A

a) Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation?
Impact Determination in the Certified PEIR
The Certified PEIR found that implementation of the General Plan 2045 and Zoning Code Update would increase the demand for electricity , natural gas and transportation fuel consumption in the region during construction and operation, but that the extent of the projected increased consumption would not be considered inefficient or wasteful. As such, the General Plan 2045 and Zoning Code Update would result in a less-than-significant impact under CEQA for this category.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to wasteful, inefficient or unnecessary consumption of energy resources, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The amounts of construction fuel anticipated for Project construction are presented below in Table 10, Project Construction Energy Usage. Construction of the P roject would utilize fuel-efficient trucks and equipment consistent with federal and State regulations, such as fuel efficiency regulations in accordance with USEPA and National Highway Traffic Safety Administration fuel -efficiency standards for medium - and heavy-duty trucks and CARB’s Pavley Phase I and II standards, 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. Therefore, the construction of the P roject would not result in the wasteful, inefficient, and unnecessary consumption of energy, and thus impacts associated with construction would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

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TABLE 10
PROJECT CONSTRUCTION ENERGY USAGEa
Energy Type Total Quantity
Annual Average Quantity
During Construction
Electricity
Temporary Construction Trailer 194,363 kWh 40,936 kWh
Electricity from Water (Dust Control) 105,065 kWh 22,129 kWh Electric Construction Equipment 101,572 kWh 21,393 kWh
Total Electricity 401,000 kWh 84,458 kWh
Gasoline
On-Road Construction Equipment 258,853 gallons 54,519 gallons Total Gasoline 258,853 gallons 54,519 gallons
Diesel
On-Road Construction Equipment 151,464 gallons 31,901 gallons Off-Road Construction Equipment 152,256 gallons 32,068 gallons Total Diesel 303,720 gallons 63,969 gallons
NOTES:

MWh = megawatt-hours
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A of this document.

SOURCE: ESA, 2025.

The Project includes residential and commercial uses. Operation of the Project would require energy in the form of electricity and natural gas for building heating, cooling, cooking, lighting, water demand and wastewater treatment, consumer electronics, and other energy needs; as well as transportation -fuels, primarily gasoline, for vehicles traveling to and from the Project. Since the trip generation of the P roject would increase, additional mobile emissions were based on the Transportation Study. 22 Operational water usage factors were provided by the Project’s Water Supply Assessment. 23 Table 11, Summary of Annual Energy Use During Project Operation , provides a summary of the annual electricity, natural gas, and transportation fuel usage required for Project operations. These usages are consistent with the scope of impacts analyzed in the Certified PEIR.

22 Fehr and Peers, June 2025. Transportation Study for 5757 Uplander Drive Project. (Appendix K) 23 Golden State Water Company, July 2025. Water Supply Assessment and Verification for 5757 Uplander Way. (Appendix M).

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TABLE 11

SUMMARY OF ANNUAL ENERGY USE DURING PROJECT OPERATION
Energy Typea Annual Quantity
Electricity
Building 6,660 MWh
EV Charging 225 MWh
Water Conveyance 5,460 MWh
Total Electricity 12,344 MWh
Natural Gas
Building 12,018,318 cf
Mobile Sources 5,163,240 cf
Total Natural Gas 17,181,557 cf
Transportation Fuel
Gasoline 357,896 gallons
Diesel 198,706 gallons
Total Gasoline 357,896 gallons
Total Diesel 198,706 gallons
NOTES:

MWh = megawatt hours; cf = cubic feet.
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A. b. Conservatively, existing site energy consumption was not estimated and subtracted from Project operational energy consumption for this analysis. Therefore, the Project operational energy consumption would actually be lower than those presented in this table.

SOURCE: ESA, 2025.

As shown in Table 11, the Project would result in a total of 12,344 megawatt hours (MWh), which includes electricity usage for building lighting and equipment as well as electricity consumed for the conveyance and treatment of water and wastewater. The Project would install renewable energy features in the form of 1 kW solar photovoltaic panels per 10,000 sf in accordance with City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG- PDF-1 (see Project Design Feature GHG-PDF -1). 24 Based on the CEC’s 2024–2040 Energy Demand Forecast, Southern California Edison’s (SCE) total system sales for 2031 are estimated to be 103,217,000 MWh of electricity. 25 As such, the Project-related annual electricity consumption of 12,344 MWh per year would represent approximately 0.012 percent of SCE’s total energy sales. In addition, as shown in Table 11, Project consumption of natural gas would total 17.182 million cubic feet (cf). The SoCal Gas 2024 California Gas Report estimates that natural gas supplies within SoCalGas’s planning area will be 754,090 million cf in 2031.26 Thus, the Project’s increase of 17.182 million cf of natural gas would account for approximately 0.002 percent of the 2031 forecasted annual consumption in SoCalGas’s planning area. Therefore, the Project would fall within SoCalGas’s projected consumption for the area and would be consistent with SoCalGas’ s anticipated regional demand from

24 The exact size of the Project’s solar electric PV system has not yet been determined, so the analysis conservatively does not account for electricity reductions due to the Project’s solar electric PV system. 25 CEC, The California Energy Demand 2024–2040, Mid-Demand Case. https://www.energy.ca.gov/data- reports/reports/integrated-energy-policy-report-iepr/2024-integrated-energy-policy-report-0. Accessed March 2025. 26 California Gas and Electric Utilities, 2024 California Gas Report, https://www.socalgas.com/sites/default/files/2024-08/2024- California-Gas-Report-Final.pdf.

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population or economic growth. Table 11 also provides the Project’s total gasoline and diesel fuel usage per year during operation of the Project. Per Table 1 1, the Project’s gasoline fuel usage is estimated to be 357,896 gallons per year and the Project diesel fuel usage is estimated to be 198,706 gallons per year. This would be approximately 0.012 percent and 0.045 percent of the Los Angeles County gasoline and diesel fuel usage in 2023 (the most recent year for which data is available). 27 The Project would support statewide efforts, as well as local General Plan 2045 Land Use and Community Design Element Goals LU-1 and LU -14, Infrastructure Element Goal INF -7, and Greenhouse Gas Reduction Element GHG- 2 and GHG-4, which include planning for growth around transit corridors; supporting multi-family housing development for short trips/around neighborhood amenities; support ing climate-friendly, renewable and efficient use of energy resources; and supporting decarbonization of buildings, including zero emission vehicles and expanding vehicle charging stations to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. The Project achieves this by locating residential and commercial uses at an infill location in close proximity to existing off-site commercial, residential, and retail destinations and by being accessible to and well served by public transit , including various public transit stops operated by Metro, and Culver City Bus that are located in proximity to the Project Site.28 Furthermore, the Project would source its energy from SCE, which will be required by Senate Bill 100 ( SB 100, codified in part at Public Utilities Code § 339.30) to integrate renewable energy sources in its energy portfolio. With regard to on -site renewables, the Project would comply with CCMC Chapter 15.02.1005 by either installing a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code or paying an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code . To support vehicle electrification , the Project would include 522 EV ready spaces, and 131 Full EV charging stations spaces. In addition, the Project would be consistent with SCAG’s 2024–2050 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal 2024) strategies, and the City’s General Plan 2045 Mobility Element Goals M -2, M-3, M-4, M-5, and M -8, to promote active transportation and support improvements in local bike networks as the Project would provide a total of 305 bicycle parking spaces (31 short-term and 274 long-term spaces) in compliance with CCMC requirements (see Project Design Feature GHG-PDF-1). The Project would therefore be consistent with the Connect SoCal 2024 and relevant General Plan 2045 goals and benefits intended to improve mobility and accessibility, provide more transportation choices, and reduce vehicular demand and associated emissions. Based on the above, operation of the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy and would not increase the need for new energy infrastructure. Thus, as with the Certified PEIR, the Project would not result in the wasteful, inefficient, and unnecessary consumption of e nergy and impacts associated with operations would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

27 CEC, 2024. California Retail Fuel Outlet Annual Reporting (CEC-A15) Results. Available at:
https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/california-retail-fuel-outlet-annual-reporting.

Accessed April 2025.
28 Fehr and Peers, June 2025. Transportation Study for 5757 Uplander Drive Project. (Appendix K).

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Impact Determination in the Certified PEIR
As discussed in the Certified PEIR, the future development facilitated under the General Plan 2045 and Zoning Code Update would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, including the City’s plans to reduce energy consumption; therefore, impacts during construction and operation of future development under the General Plan 2045 and Zoning Code Update would be less than significant and no mitigation is required.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to a conflict with or obstruction of a state or local plan for renewable energy or energy efficiency, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As discussed above, construction of the Project would utilize fuel-efficient trucks and equipment consistent with federal and State regulations, such as fuel efficiency regulations in accordance with USEPA and National Highway Traffic Safety Administration fuel -efficiency standards for medium - and heavy-duty trucks and CARB’s Pavley Phase I and II standards, the anti -idling regulation in accordance with CCR, Title 13, Section 2485, and fuel requirements in accordance with CCR, Title 17, Section 93115, as we ll as the In-Use Off-Road Diesel-Fueled Fleets regulation.

During Project operations, the Project would comply with applicable regulatory requirements for the design of new buildings, including the provisions set forth in the Title 24 standards and CALGreen Building Code, which have been incorporated into the Culver City’s Green Building Program, and support local General Plan 2045 relevant goals, including Land Use and Community Design Goals LU -1 and LU -14, Infrastructure Element Goal INF -7, and Greenhouse Gas Reduction Element GHG-2 and GHG-4, which are designed to encourage development that results in the efficient use of energy resources. The Project will incorporate Project Design Feature GHG-PDF-1, which includes sustainable design features equivalent to LEED Silver standards or better that provide opportunities for improved energy efficiency that would exceed the regulatory standards. Energy saving and sustainable design features would be incorporated into the Pr oject as the proposed buildings would comply with the applicable Title 24 California Code of Regulations. Design features would include energy conservation, TDM and mobility measures, and pedestrian- and bicycle-friendly site design (see Project Design Features GHG-PDF-1 and TRAF-PDF-2 in Table 3 for additional details). The Applicant would also comply with CCMC Chapter 15.02.1005 by either installing a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code or paying an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with

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Section 117.2 Exceptions of the California Building Code. EV parking and charging would be available for residential and commercial use, as described above. As it relates to energy conservation, the Project would include LED lighting throughout the Project Site and would install ENERGY STAR -rated appliances. As it relates to water conservation, the Project would incorporate efficient water management through low flow faucets and water-efficient landscape design with weather-based controllers and drip irrigation systems (see Water-PDF-1 in Table 3). Overall, the Project’s features would support and promote the use of renewable energy and energy efficiency and would not conflict with or obstruct any applicable renewable energy or energy efficiency plan. In addition, as described above, during Project operations, the Project would install a solar electric PV system in accordance with the City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG-PDF-1.

Furthermore, as discussed above, the Project would support statewide efforts, as well as local General Plan 2045 Land Use and Community Design Element Goal LU-1 and LU-14, Infrastructure Element Goal INF- 7, and Greenhouse Gas Reduction Element GHG-2 and GHG-4, which include planning for growth around transit corridors; supporting multi -family housing development for short trips/around neighborhood amenities; supporting climate-friendly, renewable and efficient use of energy resources; and supporting decarbonization of buildings, including zero emission vehicles and expanding vehicle charging stations to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. The Project achieves this by locating residential and commercial uses at an infill location in close proximity to existing off -site commercial, residential, and retail destinations and in close proximity to many public transit options, including various public transit stops operated by Met ro, and Culver City Bus are located in proximity to the Project Site. The Project Site is served by a variety of public transit options along Hannum Avenue and Bristol Parkway provided by the Culver City Department of Transportation. The Project Site is located approximately 0.4 miles east of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 –Crosstown, which includes Stop 305 Hannum Ave/Bristol Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway. Additionally, the Project would implement Project Design Feature TRAF -PDF-2 (Transportation Demand Management (TDM) Program), which would reduce single occupancy trips and VMT. The Project would include 522 EV ready spaces, and 1 31 Full EV charging stations spaces. Furthermore, the Project would be consistent with the Connect SoCal 2024 strategies to promote active transportation and the City’s General Plan 2045 goals promoting active transportation by improving bicycle and pedestrian infrastructure and support improvements in local bike networks and would provide 305 bicycle parking spaces to meet the CMCC Section 7.05.015 bicycle parking space requirements.

Additionally, Infrastructure Element Goal INF -7 aims to support climate -friendly buildings and support renewable energy resources. As previously discussed, SCE would supply the energy provided to the Project Site. The Project’s consumption of energy resources would not conflict with the General Plan’s goals to increase carbon free and renewable energy usage amongst residents and businesses. Under SB 100, SCE will be required to demonstrate compliance with the requirements including providing 60 percent of its energy portfolio from renewable sources by December 31, 2030 and ultimately planning for 100 percent eligible renewable energy resources and zero-carbon resources by December 31, 2045. This represents the available off-site renewable sources of energy that would meet the Project’s energy demand. As previously

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mentioned, the Project would meet the applicable requirements of the CALGreen Building Code requiring a solar electric PV system . Therefore, the Project’s design would comply with existing energy standards and incorporate project design features to reduce energy consumption. All of these features have the potential to reduce the Project’s fuel consumption, criteria pollutant, and GHG emissions. Given that the Project Site is located in a transit-rich area such that vehicle trips and VMT would be minimized, the Project would be consistent with and support the applicable General Plan 2045 goals and the goals of Connect SoCal 2024, which has a core vision centered on a “future where transportation is efficient, multimodal and accessible to all . The density of housing, restaurants, shopping, and recreation amenities in the area, combined with the public transportation options surrounding the Project , supports the expectation that projects located in the area would have a substantially greater level of transportat ion efficiency when compared to the Citywide and statewide averages.

Based on the discussion above , the construction and operations of the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would thus be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to energy would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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3.6 Geology and Soils
Thresholds (and Supporting Information Sources):

Impact
Determination
in the Certified
PEIR
Does the Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Geology and Soils: Would the project:
(a) Directly or indirectly cause potential substantial adverse effects, including the risk or loss, injury or death involving:
(i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on other substantial evidence of a known fault?
Less than
Significant No Less than
Significant N/A
(ii) Strong seismic ground shaking? Less than
Significant No Less than
Significant N/A
(iii) Seismic-related ground failure, including liquefaction? Less than Significant No Less than
Significant N/A
(iv) Landslides? Less than
Significant No Less than
Significant N/A
(b) Result in substantial soil erosion or the loss of topsoil? Less than Significant No Less than
Significant N/A
(c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Less than
Significant No Less than
Significant N/A
(d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Less than
Significant No Less than
Significant N/A
(e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? No Impact No No Impact N/A
(f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than
Significant
with Mitigation
No
Less than
Significant
with Mitigation
Yes

a) Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Spec ial Publication 42.

Impact Determination in the Certified PEIR
The Newport-Inglewood Fault and the corresponding Alquist -Priolo Earthquake Fault Zones run through the northeastern part of the City, including the Hayden Tract. There are no other known faults that traverse the City that have the potential to result in s urface fault rupture. The Certified PEIR determined that new development under the General Plan 2045 and Zoning Code Update would comply with the California Building Code (CBC), the Los Angeles County Municipal Code , and the Culver City Municipal Code ’s

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engineering design and construction requirements and standards to minimize potential impacts associated with surface fault rupture, including the Alquist-Priolo Earthquake Fault Zones, and thus impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to rupture of known earthquake faults, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The seismically active region of Southern California is crossed by numerous faults that are both active and inactive. Fault rupture is the displacement that occurs along the sides of a fault during an earthquake. Based on criteria established by the California Geological Survey (CGS), faults can be classified as active if they have shown evidence of movement within the past 11,700 years (i.e., during the Holocene Epoch). The criteria for defining an active fault is based on standards developed by the CGS for the Alquist -Priolo Earthquake Fault Zoning Program.
29 Faults that have not moved in the last 11,700 years are not considered active.

The CGS has identified earthquake fault zones known as Alquist-Priolo Earthquake Fault Zones around the surface traces of active faults to assist cities and counties in planning, zoning, and building regulation functions. These zones, which extend from 200 to 500 feet on each side of a known active fault, identify areas where potential surface rupture along an active fault could prove hazardous and identify where special studies are required to characterize hazards to habitable structures.

As the Project Site is located in the seismically active Southern California region, it could be subject to moderate to strong ground shaking in the event of an earthquake on one of the many active Southern California faults. The Project’s Preliminary Geotechnical Engineering Investigation prepared by Geotechnologies Inc, dated May 24, 2024, included as Appendix E to this document, indicates that no known Holocene active faults underlie the Project Site, and the Project Site is not located within a designated Alquist -Priolo Earthquake Fault overland Zone. Furthermore, Project buildings would be designed and constructed to resist the effects of seismic ground motions as provided in the Culver City Building Code and the 2022 California Building Code. Therefore, the Project would not directly or indirectly cause potential substantial adverse impacts associated with the rupture of a known earthquake fault. As such, impacts in this regard would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

29 Bryant, W.A., and Hart, E.W., Fault-Rupture Hazard Zones in California – Alquist-Priolo Earthquake Fault Zoning Act with Index to Earthquake Fault Zones Maps: California Geological Survey Special Publication 42, page 42, 2017.

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ii) Strong seismic ground shaking?
Impact Determination in the Certified PEIR
The Certified PEIR determined that new development under the General Plan 2045 and Zoning Code Update could expose people and property to strong seismic ground shaking, but future development would comply with the CBC, the Los Angeles County Municipal Code, and the Culver City Municipal Code’s engineering design and construction requirements and standards to minimize potential impacts associated with ground shaking, and thus impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to strong seismic ground shaking, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site, as with all of Southern California, is subject to moderate to strong ground shaking. As such, the Project Site is located in a seismically active region. Earthquakes are unavoidable hazards, although the resultant damage can be minimized through appropriate seismic design and engineering.

As discussed in the Certified PEIR, the City requires that all new construction meet or exceed the Culver City Building Code and the latest standards of the CBC for construction, which requires structural design that can accommodate maximum ground accelerations expected from known faults. Furthermore, the Project would comply with the CGS Special Publications 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California, which provides guidance for evaluation and mitigation of earthquake-related hazards. As outlined in the Certified PEIR, the Project would be required to comply with applicable seismic- related regulatory requirements. In addition, a final design-level geotechnical report must ultimately be prepared and approved by the City prior to issuance of building permits and would be ba sed on the final construction and building plans prepared by the Applicant. Implementation of the site -specific structural and seismic design parameters and recommendations for foundations and retaining walls/shoring of the final design-level geotechnical report would further ensure that seismic-related ground shaking impacts would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death. As such, i mpacts in this regard would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

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iii) Seismic-related ground failure, including liquefaction? Impact Determination in the Certified PEIR
The Certified PEIR determined new development under the General Plan 2045 and Zoning Code Update could expose people and property to liquefaction and other seismic -related ground failure, as the majority of the City is located within a liquefaction hazard area, but that future development would comply with the CBC, the Los Angeles County Municipal Code, and the Culver City Municipal Code’s engineering design and construction requirements and standards to minimize potential impacts associated with liquefacti on, and thus impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to liquefaction , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Liquefaction is a phenomenon in which saturated silty to cohesionless soils below the groundwater table are subject to a temporary loss of strength due to the buildup of excess pore pressure during cyclic loading conditions, such as those induced by an earthquake. Liquefaction effects include loss of bearing strength, amplified ground oscillations, lateral spreading, and flow failures. Liquefaction typically occurs in areas where groundwater is less than 50 feet from the surf ace and where the soils are comp osed of poorly consolidated, fine - to medium -grained sand. In addition to the necessary soil conditions, the ground acceleration and duration of the earthquake must also be of a sufficient level to initiate liquefaction.

According to the State of California Seismic Hazard Zone Map of the Venice Quadrangle, 30,31 the Project
Site is not located within a liquefaction hazard zone. The Preliminary Geotechnical Engineering Investigation performed a liquefaction analysis for the Project Site based on the soil conditions encountered at the Project Site, earthquake hazar d mapping, and the groundwater level at the Project Site (which was determined to be on the order of 40 feet below ground surface). The Preliminary Geotechnical Engineering Investigation determined that the soils underlying the Project Site are not capable of liquefaction during ground motion associated with seismic movement. In addition, as outlined in the Certified PEIR, the Project would be required to comply with applicable seismic -related regulatory requirements of the Culver City Building Code and the CBC. Therefore, seismic-related ground failure impacts, including liquefaction, would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death. Thus, impacts in this regard would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

30 Department of Conservation, Division of Mines and Geology, Seismic Hazard Zone Report for the Venice 7.5-Minute Quadrangle, Los Angeles County, California, 1998.
31 The Venice Quadrangle covers about 34 square miles of land adjacent to Santa Monica Bay. Coastal cities, from north to south, are Venice (part of Los Angeles), Marina Del Rey (Los Angeles County land), Playa del Rey, the Los Angeles International Airport, the City of El Segundo, and the City of Manhattan Beach. Inland are parts of Culver City and Westchester (part of Los Angeles).

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
iv) Landslides?
Impact Determination in the Certified PEIR
The Certified PEIR determined that, while the Planning Area is relatively flat, the eastern portion of the City around Baldwin Hills is designated as a potential landslide zone. However, because future development would comply with the CBC, the Los Angeles County Municipal Code, and the Culver City Municipal Code’s engineering design and construction requirements and standards to minimize potential impacts associated with landslides, impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to landslides, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site elevation ranges from approximately 100 feet above mean sea level (AMSL) along Hannum Avenue at the northwestern corner of the Project Site to approximately 117 feet AMSL at the east- central portion of the Project Site. Since the grade cha nge along the Project Site is only approximately 17 feet, this makes it unlikely for a landslide to occur on the Project Site. Additionally, according to the State of California Seismic Hazard Zone Map, the Project Site is located outside the areas identified as susceptible to earthquake-induced landslides. Based on this information, impacts from landslides would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project result in substantial soil erosion or the loss of topsoil? Impact Determination in the Certified PEIR
The Certified PEIR found that development under the General Plan 2045 and Zoning Code Update could expose soils to the effects of erosion or loss of topsoil. However, construction activities that disturb one or more acres of land surface are subject to the National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022-0057-DWQ) adopted by the State Water Resources Control Board (SWRCB). Permit compliance includes implementation of a storm water pollution prevention plan (SWPPP). In addition, the

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General Plan 2045 includes goals and policies that require the use of best management practices (BMPs) to control soil erosion during and after ground- disturbing activities and geotechnical reports for projects requiring grading permits. Therefore, compliance with applicable regulations would ensure that impacts related to soil erosion and topsoil loss are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts to soil erosion or the loss of topsoil, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Soil erosion refers to the process by which soil or earth material is loosened or dissolved and removed from its original location. Erosion can occur by varying processes and may occur in a Project area where bare soil is exposed to wind or moving water (both rainfall and surface runoff). The processes of erosion are generally a function of material type, terrain steepness, rainfall or irrigation levels, surface drainage conditions, and general land uses. Topsoil is used to cover surface areas for the estab lishment and maintenance of vegetation due to its high concentrations of organic matter and microorganisms.

The Project Site is located in an urbanized area of Culver City. Negligible, if any, native topsoil is likely to occur on the Project Site as it is currently developed with four one- to two-story business park/office buildings and associated surface parking. Project construction would result in ground surface disruption during site preparation, excavation, grading, and trenching that would create the potential for erosion to occur. Wind erosion would be minimized through soil stabilization measures required by SCAQMD Rule 403 (Fugitive Dust), such as daily watering. Potential for water erosion would be reduced by implementation of standard erosion control measures imposed during site preparation and grading activities. Specifically, construction activities would be carried out in accordance with applicable City standard erosion control practices required pursuant to the California Building Code and the requirements of the National Pollutant Discharge Elimination System (NPDES) General Construction Permit issued by the Los Angeles Regional Water Quality Control Board (LARWQCB), as applicable. Consistent with these requirements, a Stormwater Pollution Prevention Plan (SWPPP) would be prepared that incorporates Best Management Practices (BMPs) to control water erosion during the Project’s construction period. Following Project construction, the Project Site would be covered completely by paving, structures, and landscaping, and would generate little , if any, soil erosion.

Thus, impacts due to erosion of topsoil would be less than significant as the Project would comply with applicable regulatory requirements and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

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c) Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Impact Determination in the Certified PEIR
As determined in the Certified PEIR, certain geologic units present in the City have the potential for landslides, slope instability, liquefaction, and liquefaction-induced lateral spreading. Development allowed under the General Plan 2045 and Zoning Code Update could be located on geologic units or soils that are unstable, or that could become unstable, and result in geologic hazards if not addressed appropriately. The potential hazards of unstable soil or geologic units will be addressed largely through t he integration of geotechnical information in the planning and design process for future development to determine the local soil suitability for specific projects in accordance with standard industry practices and state-provided requirements. In addition, future projects will comply with applicable requirements related to unstable geologic units or soils. As such, implementation of the General Plan 2045 and Zoning Code Update will result in a less than significant impact related to unstable geologic units or soils.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to unstable geologic units, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As shown in the Preliminary Geotechnical Engineering Investigation, the Project Site is not located on a geologic unit or soil that is unstable. Fill materials were encountered in all exploratory excavations to depths between two and five feet. Based on soil boring tests, the fill soils are underlain by native soils composed of interlayered granular (sandy) soil layers and fine soil layers. The granular soil layers are composed of sand, silty sand and clayey sand, while the fine layers are composed of sandy to silty clay and sandy to clayey silt. The observed native soils are slightly moist to moist, range from yellowish brown to orange brown to dark brown to gray in color, and are medium dense to very dense, stiff to very stiff, and fine to coarse grained, with occasional gravel. Based on the soils encountered, the potential for the Project to result in or be affected by landslides and liquefaction is low.

Additionally, the Project is not expected to make the soil unstable or cause lateral spreading, subsidence, or collapse (impacts related to liquefaction and landslides are discussed above Thresholds a.iii) and a.iv).

Lateral spreading is the downslope movement of surface sediment due to liquefaction in a subsurface layer.

The downslope movement is due to the combination of gravity and earthquake shaking. Such movement can occur on slope gradients of as little as one d egree. Lateral spreading typically damag es pipelines, utilities, bridges, and structures. Lateral spreading of the ground surface during a seismic activity usually occurs along the weak shear zones within a liquefiable soil layer and has been observed to generally take place toward a free face ( i.e. retaining wall, slope, or channel) and to a lesser extent on ground surfaces with a very gentle slope. As stated under Threshold a.iii), according to the site-specific liquefaction analysis within the Geotechnical Investigation , the soils underlying t he Project Site would not be prone to liquefaction. Also, due to the absence of any channel, slope, or river within or near the Project Site, the

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potential for lateral spreading occurring on or off the site is considered to be negligible. Furthermore, no large-scale extraction of groundwater, gas, oil, or geothermal energy is occurring or planned at the Project Site. Thus, there appears to be little or no potential for ground subsidence due to withdrawal of fluids or gases at the Project Site. In addition, the final design -level geotechnical report would provide site-specific recommendations for Project Site preparation, excavation, foundation design, and shoring/retaining wall specifications to minimize the effects of liquefaction, which would in turn minimize any potential for lateral spreading.

Consistent with the Certified PEIR, the Project construction and design would be required to comply with the CBC, which is designed to assure safe construction, and implementation of the site-specific design measures including foundation design recommendations of the final design-level geotechnical report would further ensure that ground and soil stability hazards w ould not become unstable as a result of the Project.

Thus, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
d) Would the Project be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Impact Determination in the Certified PEIR
The Certified PEIR determined that e xpansive soils within the City are generally located around Baldwin Hills due to the high clay content. Future development under the General Plan 2045 and Zoning Code Update will be required to comply with all appliable design, engineering, and construction standards and requirements of the CBC within the CCMC, including the Grading Ordinance. Therefore, future development under the General Plan 2045 and Zoning Code Update will not result in geologic hazards associated wi th expansive soils. As such, implementation of the General Plan 2045 and Zoning Code Update will result in a less than significant impact related to unstable expansive soils.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to expansive soils, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Soils with shrink-swell or expansive properties typically occur in fine-grained sediments and cause damage through volume changes as a result of a wetting and drying process. Structural damage may occur over a long period of time, usually the result of ina dequate soil and foundation engineering or the placement of structures directly on expansive soils. As discussed in the Geotechnical Investigation (Appendix E), the Expansion Index was found to be between 54 and 128 for representative bulk samples . The Preliminary Geotechnical Engineering Investigation includes reinforcement beneath foundations and soil compaction

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recommendations to ensure expansive soils do not create hazards to the Project . Thus, w ith the incorporation of the recommendations provided in the final design -level geotechnical report, the Project would not create a substantial direct or indirect risk to life for property due to expansive soil . As such, impacts in this regard would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
e) Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Impact Determination in the Certified PEIR
Impacts related to septic tanks and alternative waste water disposal systems were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that no impacts would occur given that future development under the General Plan 2045 and Zoning Code Update would connect to existing mainlines and services lines and thus would not use septic tanks or alternative wastewater disposal systems.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to septic tanks and alternative waste water disposal systems, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urbanized area where municipal wastewater infrastructure already exists.

The Project would be required to connect to the existing infrastructure and would not use septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur , consistent with the impact findings of the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
f) Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Impact Determination in the Certified PEIR
Based on the records search conducted in the Certified P EIR from the Natural History Museum of Los Angeles County (LACM), four fossil localities have been recorded within the City boundaries and eight

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other localities located outside the city but from the same sedimentary deposits (older Quaternary alluvium deposits and the San Pedro Sand) that occur within and throughout the city. The fossil localities have yielded multiple specimens of plants and animals including mammoth, mastodon, camel, human, horses, saber - toothed cat, duck, and multiple invertebrates (e.g., clam shells, gastropods, etc.) that have been recovered in previously undisturbed sediments between 6 and 55 feet bgs and unknown depths. Thus, f uture development implemented under the General Plan 2045 and Zoning Code Update that includes construction-related ground disturbance (e.g., grubbing/clearing, grading, excavation, trenching, and boring/drilling) into previously undisturbed sediments are activities has the potential to directly or indirectly destroy paleontological resources. In addition, certain infrastructure and other improvements requiring ground disturbance into undisturbed sediments could result in damage to or destruction of pale ontological resources buried below the ground surface. Therefore, impacts to paleontological resources are considered potentially significant. However, implementation of Mitigation Measure PEIR MM GEO-1 would reduce impacts to paleontological resources to a less than significant level.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to paleontological resources or unique geologic features, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Consistent with Mitigation Measure PEIR MM-GEO-1 (see below), a paleontological resources assessment was prepared by ESA in March 2025 for the Project (provided in Appendix F of this document) to determine if the Project has the potential to encounter buried paleontological resources during construction. As indicated previously, the Project Site is completely developed with surface parking, landscaping and four, one- to two -story office buildings with no visible soil/sediment or rock outcrops to examine for paleontological resources or fossiliferous geological formations. Geologic mapping indicates that the surface of the Project Site is underlain by two to five feet of fill material, which has n o potential for paleontological resources. Possibly beneath that is paleosol of Baldwin Hills ( Qop) which has a high potential to retain paleontological resources because the SVP guidelines 32 specifically call out paleosols as
sensitive. The remainder of the sediments that are anticipated to be encountered are o lder alluvium (Qoa) which also has a high potential for paleontological resources because many significant fossils have been recovered from older alluvium in the City. Excavations at the Project Site are estimated to reach depths of up to 25 feet bgs, with building footings potentially extending to approximately 28 feet bgs. Because these planned excavations are deeper than previous excavations on the Project Site, they have the potential to impact older alluvium (Qoa) and the Baldwin Hills paleosol (Qop), which have a high sensitivity for retaining paleontological resources as discussed above. Therefore, impacts on paleontological resources due to grading and excavation during construction are considered potentially significant . This impact finding is consistent with the impact findings of the Certified PEIR. Accordingly, the site -specific paleontological resources assessment conducted per Mitigation Measure PEIR MM GEO-1 resulted in the foreseeable supplemental site-specific mitigation measures included below as Mitigation Measures Project

32 SVP, Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010, https://vertpaleo.org/wp-content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines.pdf, accessed April 9, 2025.

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MM GEO-1 to Project MM GEO-4. Implementation of Mitigation Measures Project MM GEO-1 to Project MM GEO-3 would reduce potentially significant impacts to a less than significant level, consistent with the impact findings of the Certified PEIR.

Operation of the new facilities on the Project Site would not result in any further ground disturbing activities such as grading or excavation; therefore, there is no potential to encounter, alter, or disturb paleontological resources after construction is complete. No operational impacts would thus occur.

Certified PEIR’s Mitigation Measures Addressing Impact
The following mitigation measure is set forth in the Certified PEIR and the associated MMP to address paleontological resources impacts under Threshold (f ) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM GEO-1 is also applicable to the Project.

PEIR MM-GEO-1. Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a Qualified Paleontologist, defined as an individual meeting the Society of Vertebrate Paleontology (SVP) Standar d, to conduct a site-specific paleontological resources assessment. This assessment shall include a records search at the Natural History Museum of Los Angeles County and/or other appropriate facilities, geologic map and scientific literatur e review, and a pedestrian field survey (if deemed appropriate by the Qualified Paleontologist). If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for significance pursuant to CEQA, SVP, and/or a local register. If a resource is determined to be significant and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, paleontological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the paleontological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.

Mitigation Measure PEIR MM GEO -1 is applicable to the Project, and, a s noted above, the Project has complied with PEIR MM-GEO-1 by preparing a paleontological resources assessment for the Project and by implementing the below Project-specific supplemental mitigation measures.

Project-Specific Mitigation Measures Addressing Impact
The Project paleontological resources analysis conducted per Mitigation Measure PEIR MM GEO -1 has resulted in the below listed Project-specific mitigation measures.

Project MM-GEO-1: Prior to the issuance of demolition and grading permits, the Applicant shall retain a Qualified Paleontologist meeting the Society of Vertebrate Paleontology (SVP) standards for a p rofessional paleontologist. The Qualified Paleontologist shall provide technical and compliance oversight of all work as it relates to paleontological resources. The Qualified Paleontologist shall examine construction plans and oversee the prepar ation of a Paleontological Resources Impact Mitigation Plan (Plan). This Plan shall include geological and paleontological contextual information, methods for paleontological construction monitoring, protocols for inadvertent discoveries, methods for sediment sampling and screening, including requirements for the radiocar bon dating of specimens or other materials, and final reporting requirements. The Qualified Paleontologist or his or her designee shall attend a pre-construction meeting to discuss

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the monitoring requirements to construction personnel and shall be responsible for overseeing paleontological monitors (meeting SVP standards) that will observe grading and excavation activities.

Project MM -GEO-2: Paleontological monitoring shall be conducted during construction excavations into undisturbed older alluvial sediments, undisturbed Baldwin Hills Paleosol materials, and undisturbed Pleistocene marine sediments. Monitoring shall consist of visually inspecting fresh exposures of rock for larger fossil remains and, where appropriate, collecting and wet screening sediment samples of promising horizons for smaller fossil remains. The Qualified Paleontologist or his or her designee will regularly inspect the concentrate samples via microscope or other appropriate means. If significant vertebrate fossils are found, the Qualified Paleontologist or his or her designee will collect and process additional samples for screening per Society of Vertebrate Paleontology guidelines from each geologic unit producing significant fossils. The Qualified Paleontologist shall determine the frequency of monitoring inspections based on the rate of excavation and grading activities, the materials being excavated, and the depth of excavation, and/or if found, the abundance and type of fossils encountered. Full-time monitoring can be reduced to part-time inspections, or ceased entirely, if determined adequate by the Qualified Paleontologist.

If a potential fossil is found, the Qualified Paleontologist shall have authority to temporarily stop excavation activity or to temporarily divert or redirect grading and excavation activities in the area of the exposed fossil to facilitate evaluation of the discovery. The Qualifie d Paleontologist or his or her designee shall establish an appropriate buffer area around the find where construction activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area. At the Qualified Paleontologist’s discretion, and to reduce any construction delay, the grading and excavation contractor shall assist in removing rock/sediment samples for initial processing and evaluation. If preservation in place is not feasible, the Qualified Paleontologist shall im plement a paleontological salvage program to remove the resources from their location.

Project MM-GEO-3: Any fossils recovered during Project -related excavations shall be prepared to the point of identification if possible. The residue from sediment samples shall be dried and sorted with a binocular dissecting microscope or other appropriate means . Both macrofossils and vertebrate microfossils shall be prepared to the point of identification if possible, identified, and curated into an accredited repository , or processed in another appropriate manner . The Qualified Paleontologist shall oversee the prepar ation of a final report summarizing the results of the monitoring and salvaging efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall accompany any specimens to the accredited repository. The report shall also be submitted by the Applicant to the City of Culver City to signify the satisfactory completion of the Project and required mitigation measures.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to geology and soils would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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3.7 Greenhouse Gas Emissions
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Greenhouse Gas Emissions: Would the project:
(a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
Less than
Significant No Less than
Significant N/A
(b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less than
Significant No Less than
Significant N/A

a) Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Impact Determination in the Certified PEIR
The Certified PEIR presented a qualitative assessment of construction GHG emissions associated with development of the General Plan 2045 and Zoning Code Update, indicating that due to a lack of project - specific information , the effectiveness in estimating construction emissions could not be accurately quantified. The Certified PEIR described that operation of the development under the General Plan 2045 and Zoning Code Update would generate GHG emissions from area sources, energy usage, motor vehicles, solid waste generation, water usage and wastewater generation, and that GHG emissions would be approximately 406,023 MT CO 2e in year 2045 . The Certified P EIR determined the net change in operational emissions from existing development (2019) to existing plus buildout at 2045 under General Plan 2045 would be negative compared to existing (2019) development primarily due to the focus of the proposed General Plan 2045 on infill development and development along transportation corridors to achieve an integrated land use mix that accommodates growth while reducing VMT and associated emissions, improvements in vehicle emissions standards and, to a lesser extent, improvements in building energy efficiency standards. The Certified PEIR determined that impacts related to the generation of greenhouse gas emissions, either directly or indirectly, would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to the generation of greenhouse gas emissions, either directly or indirectly, nor would it result in a substantial increase in a previously identified impact as analyzed in the Certified PEIR.

Impact Determination for Project
Construction
GHG quantification methods rely on guidance from State and regional agencies with scientific expertise in quantifying GHG emissions, including CARB and SCAQMD. As with the air quality emissions and as

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detailed above under subsection 3.2, Air Quality, GHG emissions from construction were estimated using CalEEMod Version 2022.1 for off -road construction equipment and on-road vehicles. The Project’s construction estimated GHG emissions are shown in Table 12, Construction Greenhouse Gas Emissions.

The SCAQMD recommends that a project’s construction -related GHG emissions be amortized over the project’s 30-year lifetime in order to include these emissions as part of the project’s annualized lifetime total emissions, so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies. As indicated in Table 1 2, Project construction emissions during the 37-month construction period would generate an estimated 5,351 MTCO2e, or 178 MTCO2e amortized over a 30-year period. Thus, the amortized construction GHG emissions would only represent 2.9 percent of the Project’s annual operational GHG emissions, which, as discussed below, is well within the estimated total emissions of the Plan.

TABLE 12
CONSTRUCTION GREENHOUSE GAS EMISSIONS (TONS PER YEAR)a
Construction Year MTCO2e (Metric Tons)a
2027 1,143
2028 1,261
2029 1,380
2030 1,284
283
Total GHG Emissions 5,351
Annual (Amortized over 30 years) 178
NOTES:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A.

SOURCE: ESA, 2025.

Operation
Operation of the Project would generate GHG emissions from area sources, energy usage, motor vehicles, solid waste generation, water usage and wastewater generation . CalEEMod Version 2022.1 was used to estimate operational GHG emissions. Operational mobile trips and water usage factors were provided by the Project’s Transportation Study and Water Supply Assessment. 33,34 Maximum annual GHG emissions resulting from mobile, area, energy (i.e., electricity , natural gas ), water conveyance, waste, EV charging stations sources, as well as amortized construction emissions, were calculated for the Project buildout year of 2031. The maximum first operating year GHG emissions from operation of the P roject are shown in Table 13, Estimated Annualized Project Greenhouse Gas Emissions.

33 Fehr & Peers, 5757 Uplander Project Transportation Impact Study, June 2025. (Appendix K). 34 Golden State Water Company. Water Supply Assessment and Verification for 5757 Uplander Way. July 2025. (Appendix M).

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TABLE 13

ESTIMATED ANNUALIZED PROJECT GREENHOUSE GAS EMISSIONS
Emissions Sources
Operational Emissions CO2e
(Metric Tons per Year)a
Project
Project
Mobile 4,055
Area 31
Energy (Electricity and Natural Gas) 1,456
Water 173
Waste 295
EV Charging 54
Construction - Amortized 178
Project Total GHG Emissionsb 6,245
General Plan 2045 GHG Emissionsb 406,023
NOTES:
a. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A. b. Note, PEIR General Plan 2045 GHG Emissions are reported for year 2045.

SOURCE: ESA, 2025.

As demonstrated in Table 13, the Project operations would be approximately 6,245 MTCO2e, which would be well within the Certified PEIR estimated total annual emissions for implementation of the Plan of 406,023 MTCO2e.35 With the implementation of the P roject’s sustainable features, as discussed above, as well as providing the CMCC required number of bicycle parking spaces, and the Project infill design next to public transit where the Project locates residential and commercial uses in close proximity to existing off-site commercial, residential, and retail destinations and in close proximity to many public transit options, including various public transit stops operated by Metro, and Culver City Bus , the Project would achieve GHG reductions for electricity, water and mobile emissions, as compared to a scenario without GHG reducing features and measures.

In addition, Project operational -related GHG emissions would decline in future years as emissions reductions from the State’s Cap -and-Trade program are fully realized. Emissions reductions from the Project’s two highest GHG-emitting sources, mobile and electricity, would occur over the next decade, and beyond, ensuring that the Project’s total GHG emissions would be further reduced. Emissions from electricity would decline as utility providers, including SCE, meet their Renewables Portfolio Standard obligations to provide 60 percent of their electricity from renewable electricity sources by 2030 consistent with SB 100, which would achieve additional reductions in emissions from electricity demand, although the actual reduction will depend on the mix of fossil fuels that SCE will replace with renewables and the relative CO
2 intensities of those fossil fuels. Project emissions from mobile sources would also decline in future years as older vehicles are replaced with newer vehicles, resulting in a greater percentage of the vehicle fleet meeting more stringent combustion emissions standards, such as CARB’s Advanced Clean

35 PEIR General Plan 2045 GHG Emissions are reported for year 2045.

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Cars II and Advanced Clean Truck Regulation, which aims to increase zero-emission truck sales annually.

By 2035, all new passenger cars, trucks and SUVs sold in California will be zero-emissions.

Based on the above, the Project’s construction and operational GHG impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project generate conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Impact Determination in the Certified PEIR
The Certified PEIR determined that the General Plan 2045 and Zoning Code Update was consistent with the applicable GHG emission reduction plans and policies within CARB’s 2022 Scoping Plan, SCAG’s Connect SoCal 2020 and the City’s Green Building Program. As such, the General Plan 2045 and Zoning Code Update would result in a less than significant impact related to conflicts with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to conflicts with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs, nor would it result in a substantial increase in a previously identified impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project would generate an incremental contribution to and a cumulative increase in GHG emissions.

In the absence of any adopted quantitative threshold, the significance of the Project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b)(2) by considering whether the Project complies with applicable plans, policies, regulations, and requirements adopted for the purpose of reducing the emissions of GHGs. The Project would be consistent with the applicable GHG emission reduction plans and policies included within the Certified PEIR, including the 2022 Scoping Plan, SCAG’s Connect SoCal 2024, the City of Culver City’s Green Building Program and General Plan 2045, as discussed below.

Consistency with Climate Change Scoping Plan
At the State level, Executive Orders S-3-05 and B-30-15 are orders from the State’s Executive Branch for the purpose of reducing GHG emissions. Executive Order S-3-05’s goal to reduce GHG emissions to 1990 levels by 2020 was adopted by the Legislature as the 2006 Global Warming Solutions Act (AB 32) and codified into law in Health and Safety Code (HSC) Division 25.5. Executive Order B-30-15’s goal to reduce GHG emissions to 40 percent below 1990 levels by 2030 was adopted by the Legislature in SB 32 and also codified into law in HSC Division 25.5.

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In support of HSC Division 25.5, the State has promulgated specific laws and strategies aimed at GHG reductions that are applicable to the Project. The primary focus of many of the Statewide and regional plans, policies, and regulations is to address world wide climate change. Due to the complex physical, chemical , and atmospheric mechanisms involved in global climate change, there is no basis for concluding that the Project’s increase in annual GHG emissions would cause a measurable change in global GHG emi ssions necessary to influence global climate change. Newer construction materials and practices, energy efficiency requirements, and newer appliances tend to emit lower levels of air pollutant emissions, including GHGs, as compared to those built years ago ; however, the net effect is difficult to quantify. The GHG emissions of the Project alone would not likely cause a direct physical change in the environment. According to CAPCOA, “GHG impacts are exclusively cumulative impacts; there are no non-cumulative GHG emission impacts from a climate change perspective.”
36 It is global GHG emissions in their aggregate that contribute to climate change, not any single source of GHG emissions alone. The Climate Change Scoping Plan outlines a framework that relies on a broad array of GHG reduction actions, which include direct regulations, alternative compliance mechanisms, incentives, voluntary actions, and market -based mechanisms such as the Cap-and-Trade program.

Table 14, Project Compliance with the 2022 Climate Change Scoping Plan: Appendix D Local Actions , contains a list of GHG-reducing strategies applicable to the Project. The analysis shows that the Project is consistent with the Climate Change Scoping Plan, which presents a non -exhaustive list of impactful GHG reduction strategies that local governments can implement within the three priority areas: (1) Transportation Electrification, (2) VMT Reduction, and (3) Building Decarbonization.37 Specifically, Table 3 of Appendix D in the Scoping Plan discusses attributes for residential and mixed-use projects that accommodate growth in a manner consistent with State GHG reduction goals.38 A detailed assessment of the Project’s consistency with applicable goals, plans, and policies implemented by the City that support the GHG reduction strategies in the three priority areas is provided below.39 In addition, further details are provided regarding the correlation between these reduction strategies and applicable actions included in Table 2-1 (page 72) of the Climate Change Scoping Plan (Actions for the Scoping Plan Scenario). As discussed below, the Project would implement sustainable features to reduce energy use, conserve water, reduce waste generation, and reduce vehicle travel consistent with Statewide strategies and regulations. As a result, the Project would not conflict with applicable Climate Change Scoping Plan strategies and regulations to reduce GHG emissions.

TABLE 14
PROJECT COMPLIANCE WITH THE 2022 CLIMATE CHANGE SCOPING PLAN: APPENDIX D LOCAL ACTIONS Priority Areas Key Project Attribute Compliance Analysis Transportation
Electrification
Provides EV charging infrastructure
that, at minimum, meets the most
ambitious voluntary standard in the
California Green Building Standards
Code at the time of project approval.

No Conflict. Consistent with the 2022 California Green Building Standards Code and CCMC Section 17.320.035, the Project would include 522 EV ready spaces, and 131 Full EV charging stations (see Project Design Feature GHG-PDF-1). Therefore, the Project would not conflict with this key project attribute.

36 California Air Pollution Control Officers Association, CEQA & Climate change: Evaluating and Addressing Greenhous Gas Emissions from Projects Subject to the California Environmental Quality Act, (2008). 37 Table 1 of Appendix D, 2022 Scoping Plan Update, November 2022. 38 Table 3 of Appendix D, 2022 Scoping Plan Update, November 2022. 39 Table 1 and 3 of Appendix D, 2022 Scoping Plan Update, November 2022.

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TABLE 14
PROJECT COMPLIANCE WITH THE 2022 CLIMATE CHANGE SCOPING PLAN: APPENDIX D LOCAL ACTIONS Priority Areas Key Project Attribute Compliance Analysis VMT Reduction Is located on infill sites that are
surrounded by existing urban uses
and reuses or redevelops previously
undeveloped or underutilized land
that is presently served by existing
utilities and essential public services
(e.g., transit, streets, water, sewer).

No Conflict. The Project would result in the infill development of residential and commercial uses that would be surrounded by similar residential and commercial uses. The Project is presently served by existing utilities and essential public services. In addition, the Project’s location, design, and land use planning aim to reduce vehicle trips by increasing the density of residential and commercial uses in proximity to public transit. The Project Site is located near frequent and comprehensive public transit services.

Consequently, both residential and employment growth resulting from the Project will be concentrated near transit stops. Several public transit stops operated by Metro, and Culver City Bus are located in close proximity to the Project site. Furthermore, the Project is consistent with the CCMC since the Project would include Project Design Feature TRAF-PDF-2, where the Project would implement strategies and action plans as part of a comprehensive TDM program 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 further reducing Project VMT (see Section 3.16, Transportation, of this document for a detailed explanation of all TDM measures contained in TRAF- PDF-2). Thus, the Project would not conflict with this key project attribute.

Does not result in the loss or
conversion of natural and working
lands.
a
No Conflict. The Project proposes to redevelop an approximately

8.34-acre site, which does not contain natural and working lands.

The Project would not interfere, impede, or conflict with natural and working lands (NWL) strategies for all NWL actions under the 2022 Scoping Plan. Therefore, the Project would not conflict with this key project attribute.

Consists of transit-supportive
densities (minimum of 20 residential
dwelling units per acre), or is in
proximity to existing transit stops
(within a half mile), or satisfies more
detailed and stringent criteria
specified in the region’s SCS.

No Conflict. The Project would result in a density increase from existing conditions. Under the General Plan 2045, Mixed-Use High land uses are allowed to develop 100 units per acre. The Project would include 1,077 residential units and 5,772 sf of commercial uses. The Project includes 78 units (7 percent of base density) as Very Low Income affordable units. Providing this amount permits a 20% density increase on Parcel 1, a 50% density increase on Parcel 2, and a 30% density increase on Parcel 3 under AB 2345. At 1,077 units, the Project would be within the allowed number of units with the density bonus incentives included (see Section 3.10, Land Use and Planning, of this document for additional details). Furthermore, as discussed above, the Project Site is well served by public transit, including various public transit stops operated by Metro, and Culver City Bus that are located in proximity to the Project Site. Specifically, the Project Site is located approximately 0.4 miles east of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6.

Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 – Crosstown, which includes Stop 305 Hannum Ave/Bristol Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also, within 0.2 mile east of the Project Site is Metro Bus Line 5C2 –
Overland/Fox Hills, which includes Stop 307 Hannum
Ave/Buckingham Parkway. Thus, the Project would be not conflict with this key project attribute.

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TABLE 14
PROJECT COMPLIANCE WITH THE 2022 CLIMATE CHANGE SCOPING PLAN: APPENDIX D LOCAL ACTIONS Priority Areas Key Project Attribute Compliance Analysis Reduces parking requirements by:
eliminating parking requirements or
including maximum allowable
parking ratios (i.e., the ratio of
parking spaces to residential units or
square feet); or providing residential
parking supply at a ratio of less than
one parking space per dwelling unit;
or for multifamily residential
development, requiring parking costs
to be unbundled from costs to rent or
own a residential unit.

No Conflict. The Project reduces parking requirements by providing as little residential parking as is operationally feasible.

Additionally, residential parking will be unbundled from rent, meaning that parking spaces will be able to be efficiently dispersed amongst all tenants. Thus, the Project would not conflict with this key project attribute.

Results in no net loss of existing
affordable units.

No Conflict. There are no existing residential units on the Project Site, including affordable units. As such, the Project would result in a net gain of 78 affordable housing units. Thus, the Project would not conflict with this key project attribute.

NOTES:
a. California’s natural and working lands (NWL) cover approximately 90 percent of the state’s 105 million acres, and include forests, grasslands, shrublands and chaparral, croplands, wetlands, sparsely vegetated lands, and the green spaces in urban and built environments (p. 241 – 2022 Scoping Plan).

SOURCE: CARB, 2022; ESA, 2025

Consistency with Connect SoCal 2024
SCAG’s 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) was applicable to the Certified PEIR at the time the analysis was conducted. Since then, SCAG’s Connect SoCal 2024 (2024-2050) Regional Transportation Plan/Sustainable Communities Strategy was adopted, which is an update to the previous 2020-2045 RTP/SCS. Generally, projects are consistent SCAG’s Connect SoCal 2024 if they are compatible with the general intent of the plans and would not preclude the attainment of their primary goals . As shown in Table 1 3, above, transportation related GHG emissions would be the largest source of emissions from the Project. This finding is consistent with the findings in regional plans, including the Connect SoCal 2024, which recognizes that the transportation sector is the largest contributor to the state’s GHG emissions. At the regional level, the Connect SoCal 2024 is an applicable plan adopted for the purpose of reducing GHGs.

The purpose of Connect SoCal 2024 is to achieve the regional per capita GHG reduction targets for the passenger vehicle and light-duty truck sector established by CARB pursuant to SB 375. SCAG’s Program EIR for Connect SoCal 2024, certified on April 4, 2024, “requires MPOs to include a SCS element as part of their RTP updates, with the purpose of identifying policies and strategies to reduce per capita automobile and light-duty truck GHG emissions .” Connect SoCal 2024 seeks future growth in Priority Development Areas (PDAs) to help the region reach mobility and environmental goals. Development in PDAs would provide people with access to multiple modes of transportation or where trip origins and destinations are closer together allowing for shorter trips. Connect SoCal 2024 also seeks to protect Green Region Resource Areas (GRRAs), resource areas and farmland, which can reduce risks from climate change and promote future resilience. Furthermore, Connect SoCal 2024 includes transportation improvements to be integrated and coordinated with land use patterns that support reduced congestion, reduced VMT, and increased

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transit, walking, and biking options. Connect SoCal 2024 shows that SCAG would meet the GHG emissions reduction target of 19 percent below 2005 levels by 2035, compared to the 2005 level.40 In order to assess the Project’s potential to conflict with Connect SoCal 2024, this section analyzes the Project’s consistency with the goals set forth in Connect SoCal 2024 to meet GHG emission -reduction targets set by CARB. Generally, projects are considered to not conflict with applicable County and regional land use plans and regulations, such as SCAG’s Connect SoCal 2024, if they are compatible with the general intent of the plans and would not preclude the attainment of their primary goals. The Proje ct would not conflict with the Connect SoCal 2024 goals as detailed in Table 15, Consistency with Applicable Connect SoCal 2024 Goals.

TABLE 15
CONSISTENCY WITH APPLICABLE CONNECT SOCAL 2024 GOALS
Goals
Responsible
Party(ies) Consistency Analysis
Support investments that are well-
maintained and operated,
coordinated, resilient and result in
improved safety, improved air
quality and minimized greenhouse
gas emissions.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project’s mixed-use development would locate high-density residential and commercial uses in an infill location within an urban area. Residents would benefit from nearby shopping and employment opportunities and would be within short walking distance of several bus stops, which include service from the Metro bus lines and Culver City bus lines. The features of the Project would not conflict with SCAG goals to increase transit-oriented development. Additionally, the Project Site would include sustainable design features such as providing bicycle parking and EV-ready charging spaces, energy efficient lighting, HVAC systems and plumbing fixtures.

The Project would also include solar-ready infrastructure. As such, elements of the Project integrate the region’s development pattern and transportation network in a way that is well-maintained and operated, coordinated, and resilient, which improves air quality and reduces GHG emissions. As such, the Project would be consistent with this Connect SoCal 2024 goal.

Ensure that reliable, accessible,
affordable and appealing travel
options are readily available, while
striving to enhance equity in the
offerings in high-need communities.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project’s land use characteristics, including its location near transit, housing, and bicycle/pedestrian facilities, would encourage non-automotive forms of transportation. As previously discussed, the Project would locate a mixed- use development in close proximity to various public transit stops operated by Metro and Culver City Bus located in close proximity to the Project Site.

In addition, the Project promotes active transportation by improving bicycle and pedestrian infrastructure where the Project would provide 36,516 sf of publicly accessible open space, which would provide open space for both residents and visitors. In addition, the Project would include 305 bicycle parking spaces, as required by CMCC Section 7.05.015, as well as bicycle amenities. The Project’s bicycle parking spaces and facilities would be provided at various locations throughout the Project Site, which include short-term facilities (e.g., bicycle racks) and secure long-term bicycle parking (e.g., fully enclosed rooms or bicycle lockers that protect the bicycle from inclement weather and accessible only to the owner).Thus, the Project would be consistent with this Connect SoCal 2024 goal.

40 Southern California Association of Governments (SCAG), 2024. Connect SoCal, The Southern California Association of Governments’ 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy Final Program Environmental Report, Certified April 4, 2024.

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TABLE 15
CONSISTENCY WITH APPLICABLE CONNECT SOCAL 2024 GOALS
Goals
Responsible
Party(ies) Consistency Analysis
Support planning for people of all
ages, abilities, and backgrounds.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. As stated above, the Project development would co-locate high-density residential and commercial uses near surrounding educational, employment, and commercial uses to enhance the mixed-use environment in which residents benefit from nearby shopping and employment opportunities and would be within walking distance of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 – Crosstown, which includes Stop 305 Hannum Ave/Bristol Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway. Additionally, the Project will include 78 affordable units, as well as a variety of studio, one bedroom, and two bedroom units, meaning the Project will support the housing of persons of a variety of socioeconomic levels and backgrounds.

Similarly, the Project’s diversity of amenities will likewise provide resources for people of all ages, abilities, and backgrounds. This includes the Project’s provision of bicycle amenities and inclusion of open space amenities such as the paseo, which features various gardens and seating areas. In addition, private courtyards associated with each of the residential buildings abut the paseo. These courtyards would have their own distinct character and contain various amenities for residents, including thematic gardens, outdoor grilling and dining areas, flexible seating, pergolas, and activity lawns and decks. Therefore, the Project would be consistent with this Connect SoCal 2024 goal.

Create human-centered
communities in urban, suburban
and rural settings to increase
mobility options and reduce travel
distances.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. As stated above, the Project development would co-locate high-density residential and commercial uses near existing educational, employment, and commercial uses to enhance the mixed-use environment in which residents benefit from nearby shopping and employment opportunities and would be within walking distance of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 –
Crosstown, which includes Stop 305 Hannum Ave/Bristol
Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway. Furthermore, the Project includes much needed affordable housing, without displacing any existing residential units. In addition, the Project also includes open space amenities such as the paseo, which features various gardens and seating areas. In addition, private courtyards associated with each of the residential buildings abut the paseo. These courtyards would have their own distinct character and contain various amenities for residents, including thematic gardens, outdoor grilling and dining areas, flexible seating, pergolas, and activity lawns and decks. In addition, the Project would support active modes of transportation by improving bicycle and pedestrian infrastructure, as described above, and supporting improvements in local bike networks since the Project is located close to many Culver City bike paths and would meet the CMCC required number of bicycle parking spaces. Thus, the Project would be consistent with this Connect SoCal 2024 goal.

Produce and preserve diverse
housing types in an effort to improve
affordability, accessibility and
opportunities for all households.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project would develop three new 7-story mixed-use buildings with 1,077 residential units, including 78 units as Low Income affordable units. The Project also provides a mix of unit types, including studio, one bedroom, and two bedroom units. As such, the Project supports housing for persons of a variety of socioeconomic levels and backgrounds. Additionally, the Project includes accessibility and opportunity for the commuting needs for

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TABLE 15
CONSISTENCY WITH APPLICABLE CONNECT SOCAL 2024 GOALS
Goals
Responsible
Party(ies) Consistency Analysis
all households by providing EV parking spaces, bicycle parking and storage facilities, and access to various public transit stops operated by Metro and Culver City Bus located in close proximity to the Project Site. In addition, the Project would support active modes of transportation by improving bicycle and pedestrian infrastructure and supporting improvements in local bike networks since the Project is located close to many Culver City bike paths, and would meet the CMCC required number of bicycle parking spaces. Thus, the Project would be consistent with this Connect SoCal 2024 goal.

Develop communities that are
resilient and can mitigate, adapt to,
and respond to chronic and acute
stresses and disruptions, such as
climate change.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project’s infill location and its numerous sustainability features will help develop a resilient community that can adapt to climate change. The Project is located in a highly urban area in close proximity to other residential and commercial uses with major employers nearby. In addition, the Project’s sustainable design features include Project Design Feature GHG-PDF-1 and comply with CALGreen and Title 24 requirements to reduce energy consumption by incorporating sustainable design features equivalent to USGBC LEED rating system at a Silver performance level or higher, achieving energy efficiency with a 15% reduction over ASHRAE 90.1 (2010) Baseline, implementing energy efficient building designs, and installing ENERGY STAR®-rated appliances and LED lighting throughout the Project Site (see Project Design Feature GHG-PDF-1). Further, the Project would install a solar electric PV system in accordance with the City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG-PDF-1. Additionally, the Project would incorporate efficient water management through low flow faucets and water-efficient landscape design with weather-based controllers and drip irrigation systems (see WATER-PDF-1). These sustainable features and mitigation measures assist in developing resilient communities. Moreover, the Project Site is in close proximity to many public transit options, including various public transit stops operated by Metro, and Culver City Bus. With all of these factors, the Project would achieve GHG reductions for electricity, water and mobile emissions, as compared to a scenario without GHG reducing features and measures. Thus, the Project would be consistent with this Connect SoCal 2024 goal.

Integrate the region’s development
pattern and transportation network
to improve air quality, reduce
greenhouse gas emissions and
enable more sustainable use of
energy and water.

Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project would develop three new 7-story mixed-use buildings that would include Project Design Feature GHG-PDF-1 and comply with CALGreen and Title 24 requirements to reduce energy consumption by incorporating sustainable design features equivalent to USGBC LEED
rating system at a
Silver performance level or higher, achieving energy efficiency with a 15% reduction over ASHRAE 90.1 (2010) Baseline, implementing energy efficient building designs, and installing ENERGY STAR®-rated appliances and LED lighting throughout the Project Site (see Project Design Feature GHG-PDF-1 in Table 3 for additional details). Further, the Project would install a solar electric PV system in accordance with the City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG-PDF-1. Additionally, the Project would incorporate efficient water management through low flow faucets and water-efficient landscape design with weather-based controllers and drip irrigation systems (see WATER-PDF-1). In addition, the Project would provide 522 EV ready, and 131 full EV charging stations and would provide 305 bicycle parking spaces for residents, employees and visitors, including 31 short-term and 274 long-term spaces, in compliance with City codes. Furthermore, the Project’s location, design, and land use planning aim to reduce vehicle trips by increasing the density of residential and commercial uses in proximity to public transit. The Project Site is located near frequent and comprehensive public transit services. Consequently, both residential and employment growth resulting from the Project will be concentrated near transit stops. Specifically, the Project Site is located approximately 0.4 miles east of the Culver City Transit Center, which serves Los Angeles

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TABLE 15
CONSISTENCY WITH APPLICABLE CONNECT SOCAL 2024 GOALS
Goals
Responsible
Party(ies) Consistency Analysis
County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6.

Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 – Crosstown, which includes Stop 305 Hannum Ave/Bristol Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway. As such, all of these elements of the Project serve to integrate the region’s development pattern and transportation network in a way that reduces VMT, which improves air quality and reduces GHG emissions, and enables sustainable use of energy and water. Thus, the Project would be consistent with this Connect SoCal 2024 goal.

Conserve the region’s resources. Local
Jurisdictions,
SCAG
No Conflict. The Project would not conflict with this goal. The Project would include strategies to conserve the region’s resources through compliance of federal, state, and local regulations and the implementation of sustainable building practices that consume less energy, water, and, other non-renewable resources. As described above, the Project will incorporate Project Design Feature GHG-PDF-1 and comply with CALGreen and Title 24 requirements to reduce energy consumption by incorporating sustainable design features equivalent to USGBC LEED rating system at a Silver performance level or higher, achieving energy efficiency with a 15% reduction over ASHRAE 90.1 (2010) Baseline, implementing energy efficient building designs and installing ENERGY STAR®-rated appliances and LED lighting throughout the Project Site (see Project Design Feature GHG-PDF-1). Further, the Project would install a solar electric PV system in accordance with the City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG- PDF-1. Additionally, the Project would incorporate efficient water management through low flow faucets and water-efficient landscape design with weather-based controllers and drip irrigation systems (see WATER-PDF-1). In addition, the Project would provide 522EV ready, and 131 full EV charging stations and would provide 305 bicycle parking spaces for residents, employees and visitors, including 31 short-term and 274 long-term spaces, in compliance with City codes. Furthermore, the Project’s location, design, and land use planning aim to reduce vehicle trips by increasing the density of residential and commercial uses in proximity to public transit. The Project Site is located near frequent and comprehensive public transit services. Consequently, both residential and employment growth resulting from the Project will be concentrated near transit stops. As such, the Project would be consistent with this Connect SoCal 2024 goal.

Improve access to jobs and
educational resources.

Local
Jurisdictions
No Conflict. The Project would not conflict with this goal. As stated above, the Project development would co-locate high-density residential and commercial uses near existing educational, employment, and commercial uses where both existing nearby residents and the Project’s future residents would benefit from nearby educational and employment opportunities and would be within walking distance several bus lines.

Therefore, the Project improves access to jobs and educational resources within an already built environment. Therefore, the Project would be consistent with the strategies in Connect SoCal 2024.

Advance a resilient and efficient
goods movement system that
supports the economic vitality of the
region, attainment of clean air and
quality of life for our communities.

Local
Jurisdictions
No Conflict. The Project would not conflict with this goal. The Project would enhance and improve infrastructure and circulation surrounding the Project Site to support commercial and residential uses. The Project is utilizing the goods movement systems of the existing commercial and residential area, as well as include site improvements that allow for vehicular access and circulation. Therefore, the Project would be consistent with the goods movements strategies in Connect SoCal 2024.

SOURCE: ESA, 2025.

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As shown in Table 1 5, the Project would not conflict with SCAG’s Connect SoCal 2024 and would be supportive of the actions and strategies contained therein. Therefore, GHG impacts would be less than significant with respect to Connect SoCal 2024 and within the scope of impacts analyzed in the Certified PEIR.

Consistency with Culver City’s General Plan 2045 Greenhouse Gas Reduction Element and Green Building Program
The significance of the Project’s GHG emissions is also evaluated based on whether they would be generated in connection with a design that is consistent with relevant City of Culver City goals and actions designed to encourage development that results in a reduction of GHGs. The Project would support statewide efforts, as well as local General Plan 2045 Greenhouse Gas Reduction Element Goals GHG-1, GHG-2, and GHG-4. As described under subsections Sustainability Features and Project Design Features in this Environmental Checklist, the Project will incorporate Project Design Feature GHG- PDF-1 where the Project would include sustainable design features equivalent to LEED Silver standards or better that provide opportunities for improved energy efficiency that would exceed the regulatory standards and achieve energy efficiency with a 15% reduction over ASHRAE 90.1 (2010) Baseline . Energy saving and sustainable design features would be incorporated into the Project as the proposed buildings would comply with the applicable Title 24 California Code of Regulations. Design features would include energy conservation, water conservation , TDM and mobility measures, and pedestrian - and bicycle-friendly site design. As it relates to energy conservation, the Project would include LED lighting throughout the Project Site and would install ENERGY STAR -rated appliances. As i t relates to water conservation, the Project would incorporate efficient water management through low flow faucets and water -efficient landscape design with weather -based controllers and drip irrigation systems (see WATER-PDF-1). In addition, as described above, during Project operations, the Project would install a solar electric PV system, in accordance with the City’s Green Building Code Solar Ordinance as part of Project Design Feature GHG- PDF-1.
41 Furthermore, the Project supports the transition to zero-emission v ehicles by expanding vehicle charging stations, and the Project supports improving transportation efficiency and reducing transportation GHG emissions with respect to private automobiles by locating residential and commercial uses at an infill location in close proximity to existing off -site commercial, residential, and retail destinations as well as numerous public transit stops operated by Metro, and Culver City Bus. The Project would include 522 EV ready spaces, and 131 Full EV charging stations spaces, further supporting sustainable transportation practices. Therefore, the Project would achieve GHG reductions for electricity, water and mobile emissions, as compared to a scenario without GHG reducing features and measures.

Table 16, Project Consistency with Applicable Culver City Green Building Program Requirements, describes features the Project would implement to increase energy efficiency and reduce energy consumption, thus reducing Project GHG emissions. As discussed in Table 16, the Project would not conflict with the applicable requirements of the City’s Green Building Program . Therefore, the Project’s GHG emissions would be generated in connection with a development located and designed to be consistent with the applicable City goals and actions for GHG emission reductions.

41 The exact size of the Project’s solar electric PV system has not yet been determined, so the analyses conservatively do not account for electricity reductions due to the Project’s solar electric PV system.

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TABLE 16
PROJECT CONSISTENCY WITH APPLICABLE CULVER CITY GREEN BUILDING PROGRAM REQUIREMENTSa Source Category / Description Consistency Analysis
Culver City Green
Building Program
Requires all new buildings of 10,000 or more of
gross floor area to install 1kW of solar
photovoltaic systems per 10,000 square feet of
gross floor area
No Conflict. The Project would consist of
approximately 1,106,158 sf of new floor area
construction and would install a solar electric
PV system in accordance with the City’s Green
Building Code Solar Ordinance as part of
Project Design Feature GHG-PDF-1.
42 Category 2 Qualifying Projects: Requires all new
construction, additions, and major renovations of
50,000 square feet and greater of affected area
to comply with Category 2 requirements (USGBC
and LEED Requirements), excluding single family
and two family structures, where prior to the
issuance of a construction permit, the permit
applicant shall submit the following:

1. Evidence that a LEED-AP (Leadership in
Energy and Environmental Design Accredited
Professional) is one of the members of the
project design team.

2. Evidence that the project has been registered
with the appropriate USGBC (United States
Green Building Council) LEED program.

3. A copy of the appropriate LEED checklist,
which demonstrates that the project meets the
appropriate LEED rating system at a
"Certified" performance level or higher.

4. A signed declaration from the LEED- AP
member of the project design team, stating
that the plans and details have been reviewed
for conformance with the appropriate LEED
program and that the project meets the intent
of the criteria for certification of the selected
LEED program at the "Certified" performance
level or higher.

5. Qualifying projects shall comply with a
USGBC "3 point margin of error" for a
minimum LEED "Certified" performance level.

6. The construction permit applicant shall submit
to the Building Safety Division copies of all
submissions and correspondence between the
project team and the USGBC regarding the
qualifying project.

No Conflict. The Project would provide
evidence that a LEED-AP (Leadership in
Energy and Environmental Design Accredited
Professional) is one of the members of the
Project design team.

The Project would provide evidence that the
project has been registered with the
appropriate USGBC LEED program.

The Project would be designed to meet criteria
for the LEED Silver or equivalent certified
level.

The Project would provide a signed declaration
from the LEED-AP member of the Project
design team, stating that the plans and details
have been reviewed for conformance with the
appropriate LEED program and that the project
meets the intent of the criteria LEED Silver or
equivalent certified level.

The Project applicant will submit to the
Building Safety Division copies of all
submissions and correspondence between the
Project team and the USGBC.

NOTE:
a. This table lists applicable City of Culver City requirements for Category 2 projects.

SOURCE: ESA, 2025.

Therefore, as shown in Tables 14, 15, and 16, the Project would not conflict with applicable GHG plans, policies and regulations adopted for the purpose of reducing GHG emissions, and as such, impacts regarding GHG emissions and reduction plans would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

42 The exact size of the Project’s solar electric PV system has not yet been determined, so the analyses conservatively do not /account for electricity reductions due to the Project’s solar electric PV system.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-74 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to greenhouse gas emissions would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-75 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.8 Hazards and Hazardous Materials
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Hazards and Hazardous Materials: Would the project:
(a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less than
Significant No Less than
Significant N/A
(b) Create a significant hazard to the public or the environment through the reasonably foreseeable upset and accident
conditions involving the likely release of hazardous materials into the environment?
Less than
Significant No Less than
Significant N/A
(c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Less than
Significant No Less than
Significant N/A
(d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code
§65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less than
Significant No Less than
Significant N/A
(e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
No Impact No No Impact N/A
(f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than
Significant No Less than
Significant N/A
(g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? Less than
Significant No Less than
Significant N/A

a) Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Impact Determination in the Certified PEIR
The Certified PEIR determined that future development that will occur under the General Plan 2045 and Zoning Code Update could involve demolition of older buildings that contain asbestos containing materials and lead based paint. In addition, operation of future development could increase the amount of hazardous materials being transported, used, and stored in the city. However, the construction and operation of future development will comply with applicable regulations set forth by Culver City, USEPA, Occupational Safety and Health Administration (OSHA), Department of Toxic Substances Control (DTSC), Caltrans, SCQAMD, and other agencies. The City will review development applications for subsequent development under the Project for compliance with the applicable regulations, policies of the General Plan 2045, and the City’s Municipal code. Therefore, the General Plan 2045 and Zoning Code Update will result in a less than significant impact related to the routine use, transport, or disposal of hazardous materials.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-76 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to creating a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Construction of the Project would not involve the routine transport of hazardous materials to and from the Project Site. During demolition, excavation, on-site grading, and building construction, hazardous materials such as paint, petroleum, adhesives, surface coatings, solvents and other finishing materials, and cleaning agents, fuels, and oils could be routinely used on the Project Site. While some hazardous materials used during construction could require disposal, such activity would occur only for the duration of construction and would cease upon completion of the Project. As such, construction of the Project would not involve the routine transport or disposal of hazardous materials. Notwithstanding, all potentially hazardous materials used during construction of the Project would be used and disposed of in accordance with manufacturers’ specifications and instructions, thereby reducing the risk of hazardous materials use. In addition, there are regulations aimed at establishing specific guidelines regar ding risk planning and accident prevention, protection from exposure to specific chemicals, and the proper storage of hazardous materials. The Project would be in full compliance with all applicable federal, state, and local requirements concerning the use, storage, and management of hazardous materials, including but not limited to the Resource Conservation and Recovery Act (RCRA), Hazardous Materials Transportation Act (HMTA), California Hazardous Waste Control Law, federal and state Occupational Safety and Health Acts, SCAQMD rules, and permits and associated conditions issued by the Culver City Building and Safety Division. Such requirements include obtaining material safety data sheets from chemical manufacturers, making these data sheets available to employees, labeling chemical containers in the workplace, developing and maintaining a written hazard communication program, and developing and implementing programs to train employees about hazardous materials. Consequently, Project construction activities would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Operation of the Project would involve the routine use of small quantities of potentially hazardous materials typical of those used in commercial and residential uses including cleaning products, paints, and those used for maintenance of landscaping. Such uses would be consistent with the uses currently occurring on the Project Site and other nearby developments. As a mixed -use commercial and residential development, the Project would not involve the routine transport, use, and disposal of large quantities of hazardous materials.

The Project’s limited use of common hazardous materials can typically be disposed of at Class II or III landfills, which accept most common waste materials, such as those identified above. In addition, all hazardous materials used o n the Project Site during operation would be used, stored, and disposed of in accordance with all applicable federal, state, and local requirements.

Based on the above, with compliance with all applicable local, state, and federal laws and regulations relating to environmental protection and the management of hazardous materials, the Project’s impact associated with the routine transport, use, or disposal of hazardous materials during construction and operation of the Project would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-77 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Impact Determination in the Certified PEIR
Future development under the General Plan 2045 and Zoning Code Update will be required to comply with applicable regulations and General Plan 2045 policies during construction activities, which will ensure that future development will not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment.

In addition, all new development will be required to comply with applicable regulations for hazardous materials adopted by USEPA, OSHA, DTSC, Caltrans, California Highway Patrol (CHP), SCAQMD, and other agencies. Therefore, the General Plan 2045 and Zoning Code Update will result in a less than significant impact related to accident and upset conditions.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to creating a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
During Project construction, hazardous materials in the form of paint, petroleum, adhesives, surface coatings, solvents and other finishing materials, could be used, and therefore, would require proper handling and management and, in some cases, disposal. The use, handling, storage, and disposal of these materials could increase the opportunity for hazardous materials releases and, subsequently, the exposure of people and the environment to hazardous materials. However, as previously discussed in Threshold a), all potentially hazardous materials used during construction of the Project would be used and disposed of in accordance with manufacturers’ specifications and instructions, thereby reducing the risk of hazardous materials use. In addition, as outlined in the Certified PEIR, the Project would comply with all applicable federal, State, and local requirements concerning the use, storage, and management of hazardous materials.

The Phase I ESA prepared for the Project Site in 2022 and included as Appendix G of this document revealed no evidence of Recognized Environmental Conditions (RECs) in connection with the site.

However, the Phase I ESA, which included a survey and samples to identify the presence of asbestos, found that there is a possibility of encountering asbestos -containing materials (ACM) during construction of the Project due to the age of the existing buildings on the Project Site

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-78 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

State-level agencies, in conjunction with the United Stated Environmental Protection Agency (USEPA) and California Occupational Safety and Health Administration (Cal/OSHA), regulate removal, abatement, and transport procedures for ACM. ACM is regulated under state regulations including the California Code of Regulations (CCR), Title 8, Division 1, Chapter 4, Article 4, Sections 1529 and 5208. The Project would also comply with the requirements of SCAQMD Rule 1403 if ACM is found during the renovation and construction activities. Releases of asbestos from industrial, demolition, or construction activities are prohibited by these regulations and medical evaluation and monitoring is required for employees performing activities that could expose them to asbestos . Additionally, the regulations include warnings that must be heeded and practices that must be followed to reduce the risk for asbestos emissions and exposure. Finally, federal, state, and local agencies must be notified prior to the onset of demolition or construction activities with the potential to release asbestos.

In the event that ACM is discovered during construction, remediation or abatement of these materials would take place in accordance with all applicable regulations and standards before building demolition commences. Therefore, since the Project would compl y with all applicable regulations, impacts would be less than significant.

Overall, based on the above factors, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
c) Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Impact Determination in the Certified PEIR
The Certified PEIR determined that, while future development under the General Plan 2045 and Zoning Code Update may involve hazardous emissions or the handling of hazardous materials and wastes within one-quarter mile of an existing or future school , any such development will be required to comply with existing federal, State, and local regulations related to hazardous materials, which will ensure that hazardous materials requirements are met prior to construction and that hazardous materials would be properly stored, managed, and disposed of. Therefore, impacts would be less than significant related to emitting hazardous materials within one-quarter mile of a school.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts by emitting hazardous emissions or handling hazardous materials, substance or waste within a quarter mile of an existing or proposed school, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-79 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
The nearest school is Montessori Academy of Culver City, approximately 0.2 miles southwest of the Project Site. Construction of the Project could involve the temporary use of hazardous substances such as paint, petroleum, adhesives, surface coatings, solvents and other finishing materials, and cleaning agents, fuels, and oils. All materials would be used, stored, and disposed of in accordance with applicable laws and regulations and manufacturers’ instructions, as discussed in Threshold a). Similarly, the types and amounts of hazardous materials used during operation of the Project would be typical of such developments and would include cleaning solvents, pesticides for landscaping, painting supplies, and petroleum products. As a residential and retail mixed-use project, the Project by its nature would not include sources of significant hazardous emissions or handle hazardous or acutely hazardous materials in a manner that would adversely affect any surrounding uses. Moreover, as discussed in Threshold a), all materials used during both the construction and operation of the Project would be used, stored, and disposed of in accordance with all applicable federal, state, and local requirements. Furthermore, all materials used during both the construction and operation of the Project would be used in accordance with manufacturers’ instructions and handled in compliance with applicable standards and regulations including, but not limited to, federal and State OSHA requirements. As such, the use of such materials would not create a significant hazard to any nearby existing or proposed schools. Thus, impacts would be less than significant in this regard and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
d) Would the Project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Impact Determination in the Certified PEIR
The Certified PEIR acknowledged that within the Planning Area there are known contaminated properties, some of which have been remediated and some that are undergoing remediation, and other properties could be added if contamination is discovered. Thus, future development allowed under the General Plan 2045 and Zoning Code Update could occur on a contaminated site. However, any development on a contaminated site will be required to comply with applicable mandatory regulations, which will ensure that the development does not create a significant hazard to the public or the environment. Therefore, impacts related to hazardous materials sites would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts due to hazardous materials sites, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-80 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
Government Code Section 65962.5, amended in 1992, requires the California Environmental Protection Agency (CalEPA) to develop and update annually the Cortese List, which is a list of hazardous waste sites and other contaminated sites. While Government Code Section 65962.5 makes reference to the preparation of a list, many changes have occurred related to web-based information access since 1992 and information regarding the Cortese List is now compiled on the websites of the DTSC, the State Water Board, and CalEPA. The DTSC maintains the EnviroStor database, which includes sites on the Cortese List and also identifies potentially hazardous sites where cleanup actions (such as a removal action) or extensive investigations are planned or have occurred. The data base provides a listing of Federal Superfund sites [National Priorities List (NPL)]; State Response sites; Voluntary Cleanup sites; and School Cleanup sites.

Geotracker is the State Water Resources Control Board’s data management system for managing sites that impact groundwater, especially those that require groundwater cleanup [USTs, Department of Defense, Site Cleanup Program] as well as permitted facilities such as operating USTs and land disposal sites. CalEPA’s database includes lists of sites with active Cease and Desist Orders (CDO) or Cleanup and Abatement Orders (CAO) from the State Water Board.

The Phase I ESA prepared for the Project Site obtained a database search report, which is included in Appendix C of the Phase I ESA (Appendix G of this document). The report documents findings of various federal, state, and local regulatory database searches regarding properties with known or suspected releases of hazardous materials or petroleum hydrocarbons. As shown in the report, the Project Site was not listed on any of the databases searched. Thus, impacts regarding this threshold would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? Impact Determination in the Certified PEIR
Impacts related to airport safety hazards were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that no impacts would occur given that there are no airport land use plans or public airports within the Planning Area.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to airport safety hazards, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-81 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Impact Determination for Project
The Project Site is not located within the vicinity of a private airstrip, heliport, or helistop or within an airport land use plan or within 2 miles of a public or private airport. The nearest airports are the Los Angeles International Airport (LAX) and t he Santa Monica Municipal Airport, located approximately 2.4 miles southwest and 4.2 miles northwest of the Project Site, respectively. The Project Site is not located within the airport land use plan areas for either LAX or the Santa Monica Municipal Airport. Therefore, the Project is not located within an airport land use plan area and would not result in airport -related safety hazards or excessive noise for people residing or working in the Project area. Thus, the Project would have no impact in this regard, consistent with the impact findings of the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
f) Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Impact Determination in the Certified PEIR
The Certified PEIR determined that continued growth and development associated with implementation of the General Plan 2045 and Zoning Code Update has the potential to strain the emergency response and recovery capabilities of federal, State, and local governments. However, the Los Angeles County Operational Area Emergency Response Plan provides the framework for responding to major emergencies or di sasters. In addition, the City’s Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) provides a strategy for reducing the City's vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The General Plan 2045 contains policies that aim to continually strengthen emergency response and would not interfere with implementation of the MJHMP or of agencies that respond in the event of a disaster or major emergency in Culver City. Therefore, impacts related to impairment or interference with an emergency response plan would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts that would impair or interfere with an emergency response plan , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an established urban area that is well served by a roadway network. While it is expected that the majority of construction activities for the Project would be confined on-site, construction activities may temporarily affect access on portions of adjacent streets during certain periods of the day. However, through-access for drivers, including emergency personnel, along all roads would be maintained. In these instances, the Project would implement traffic control measures (e.g. , construction flagmen, signage, etc.) to maintain flow and access. Furthermore, in accordance with Culver City

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-82 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

requirements, the Project would develop a Construction Traffic Management Plan, which includes designation of a haul route, to ensure that adequate emergency access is maintained during construction.

Therefore, construction is not expected to result in ina dequate emergency access or impair the implementation of or physically interfere with the City’s emergency response plan. As such, the Project’s impact related to the implementation of the City’s emergency response plan during construction would be less than significant.

Project operation would generate traffic in the Project vicinity and would result in some modifications to access (i.e., new curb cuts for Project driveways) from the streets that surround the Project Site. However, emergency access to the Project Site and surrounding area would continue to be provided similar to existing conditions. Direct emergency access would continue to be provided by each of the three streets bordering the Project Site, including Hannum Avenue, Bristol Parkway, and Uplander Way. Futur e driveway and building configurations would comply with applicable fire code requirements for emergency evacuation, including proper emergency exits for visitors and employees. The Project would not include features that would inhibit emergency vehicle ac cess to the Project Site. The Project would include features to support the existing fire station access from Bristol Parkway, including restricting the Project driveway on Bristol Parkway to right-turn in and right -turn out only to reduce the likelihood of inbound or outbound vehicles turning left and obstructing the northbound travel lanes on Bristol Parkway. Subject to review and approval of Project Site access and circulation plans by the CCFD, as necessary, the Project would not result in inadequate em ergency access. California Vehicle Code section 21806 requires that all non -emergency vehicles yield right-of-way to emergency vehicles, so general traffic congestion in the vicinity of the project site would not result in substantial delay to emergency vehicle response. Therefore, emergency vehicles would continue to be able to access the Project Site and the Project would not interfere with accessibility for emergency services
Overall, since the Project would not cause significant impediments along any designated emergency evacuation routes, and the proposed mix of uses would not impair implementation of an emergency response plan, the Project would have a less than significant impact with respect to these issues, and the impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
g) Would the Project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires? Impact Determination in the Certified PEIR
The Certified PEIR found that the majority of the Planning Area is not within a Very High Fire Hazard Severity Zone (VHFSZ) but that the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within West Los Angeles College and the IOF are within a VHFHSZ.

However, future development that will occur under the General Plan 2045 and Zoning Code Update will be required to adhere to building and fire codes and review by the CCFD to reduce fire hazards. Compliance with applicable requirements and review by CCFD will ensure that people or structures are not exposed,

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-83 City of Culver City
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either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. Therefore, impacts would be less than significant related to wildland fire hazards.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to wildfire, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is not located in an area of moderate or very high fire hazard. 43 As stated in the Certified PEIR, the nearest VHFHSZ is located in Baldwin Hills extending down into Holy Cross Cemetery, approximately 0.3 miles north of the Project Site. In addition, the Project Site is not located in or near a State Responsibility Area. 44,45 As the Project would involve redevelopment of an infill site within an urbanized area that is not proximate to wildlands or high fire hazard areas, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to hazards and hazardous materials would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

43 Culver City Fire Department, Very High Fire Hazard Severity Zones (VHFHSZ) Map, prepared by CAL FIRE, dated June 13, 2012.
44 California Board of Forestry and Fire Prevention, State Responsibility Area Viewer, https://calfire- forestry.maps.arcgis.com/apps/webappviewer/index.html?id=468717e399fa4238ad86861638765ce1. Accessed April 25, 2025.
45 The State Responsibility Area (SRA) is an area where the state has financial responsibility for wildland fire protection and prevention. All of the land within the State Responsibility Area is classified as being in a Moderate, High or Very High Fire Hazard Severity Zone. Information provided by CAL FIRE 2024 FAQ Page, dated December 18, 2024. Cal Fire, https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/what-we-do/community- wildfire-preparedness-and-mitigation/fire-hazard-severity-zones/2024-fhsz- faqs_english.pdf?rev=538374a27bb44bbab4c2786ff2eafb39&hash=AD4DB78. Accessed April 25, 2025.

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3.9 Hydrology and Water Quality
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Hydrology and Water Quality: Would the project:
(a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less than
Significant No
Less than
Significant N/A
(b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the
basin?
Less than
Significant No
Less than
Significant N/A
(c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:

(i) result in substantial erosion or siltation on- or off-site; Less than Significant No Less than
Significant
N/A
(ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; Less than
Significant No Less than
Significant
N/A
(iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or Less than
Significant No
Less than
Significant
N/A
(iv) impede or redirect flood flows? Less than
Significant No Less than
Significant
N/A
(d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less than
Significant No Less than
Significant
N/A
(e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Less than
Significant No Less than
Significant
N/A

a) Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? Impact Determination in the Certified PEIR
The Certified PEIR indicated that the City is generally a developed, urban environment with limited vacant parcels, where the sources and types of stormwater pollutants are typical of an urban setting. Under the General Plan 2045 and Zoning Code Update, an increase in impervious surfaces could occur, which could increase the amount of urban pollution in storm water runoff. In addition, other pollutant sources from past uses and disposal practices as well as chemicals and fertilizers applied to landscaping could result.

Construction and operation of future development will comply with applicable laws, regulations, and standards related to water quality and waste discharge, including the General NPDES Permit for Discharges of Groundwater from Construction and Project Dewatering Permit No. CAG994004, the Permit Order No.

R4-2018-0125 issued by LARWQCB, and the Los Angeles MS4 Permit No. Order No. R4- 2021-0105/ NPDES Permit No. CAS004004, as may be updated over time. In addition, future projects will comply with policies in the General Plan 2045 and requirements related to water quality of the CCMC. Therefore, impacts related to violating water quality standards or waste discharge requirements are less than significant.

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Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to violating water quality standards or waste discharge requirements, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Surface Water Quality
Construction
In California, the NPDES stormwater permitting program is administered by the SWRCB through its nine Regional Water Quality Control Boards (RWQCBs). This NPDES permit, referred to as General Permit for Stormwater Discharges from Construction Activities by the SWRCB, establishes a risk -based approach to stormwater control requirements for construction projects.

The SWRCB adopted this General Permit for Stormwater Discharges from Construction Activities on September 8, 2022 (Order No. 2022-0057-DWQ, General NPDES Permit No. CAS000002). The Construction General Permit regulates construction activity, including clearing, grading, and excavation of areas one acre or more in size, and prohibits the discharge of materials other than stormwater, authorized non-stormwater discharges, and all discharges that contain a hazardous substance, unless a separate NPDES permit has been issued for those discharges. For all construction activities disturbing one acre of land or more, California also mandates the development and implementation of SWPPP. The SWPPP documents the selection and implementation of BMPs to prevent discharges of water pollutants to surface or groundwater. The SWPPP also charges owners with stormwater quality management responsibilities. The developer or contractor for a construction site subject to the General Permit must prepare and implement a SWPPP that meets the requirements of the General Permit.

During construction of the Project, per the NPDES Construction General Permit, the Project would be required to implement a SWPPP that includes BMPs to reduce pollutants in stormwater runoff from the Project Site. The BMPs would adhere to the California Stormwater Quality Association BMP Handbook and would include, but not be limited to, use of sandbags, storm drain inlets protection, stabilized construction entrance, wind erosion control, and stockpile management to minimize the discharge of pollutants in stormwater during construction. All construction activities would occur in accordance with City grading permit regulations contained in the CCMC.

With the implementation of site -specific BMPs included as part of the SWPPP and implementation of standard construction practices, construction of the Project would not result in discharges that would violate any surface water quality standard or waste discharge requirements. Therefore, construction-related impacts on any surface water quality would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Operations
Stormwater discharge is generated by rainfall that runs off the land and impervious surfaces, such as paved streets, parking lots, and rooftops. If s tormwater discharge includes pollutants of concern (which could be generated by the Project ), stormwater quality can be affected . During Project operation, pollutants of

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concern within stormwater runoff may include, but are not limited to, pollutants such as sediment, nutrients, pesticides, metals, pathogens, oil and grease, and trash. This stormwater runoff can flow directly into storm drains and continue untreated. Untre ated stormwater runoff degrades water quality in surface waters and groundwater and can affect drinking water, human health, plant and animal habitats, and the water quality in off-site drainages and surface water bodies such as Ballona Creek.

CCMC Section 5.05.040.A requires the implementation of Low impact Development (LID) and Standard Urban Stormwater Mitigation Plan (SUSMP) strategies outlining pollution prevention control requirements during operation for projects meeting specified size and/or redevelopment criteria to mimic predevelopment hydrology through infiltration, evapotranspiration and rainfall harvest and use.

The Project is also required to comply with County and City LID requirements, which require implementation of a stormwater treatment system that captures the 85 th percentile runoff volume for
treatment. The Hydrology and Water Quality Technical Memorandum prepared for the Project by Kimley Horn, dated July 31, 2024 (included as Appendix H), concluded that based on the available geotechnical investigation, infiltration is feasible for the Project Site due to high infiltration rate and low groundwater table relative to the subterranean parking garage. The Memorandum noted an infiltration rate of 26.9 inches per hour and groundwater was not detected at a maximum exploration depth of 80-feet at the nearby 5700 Hannum Avenue property. According to the Project’s Preliminary Geotechnical Engineering Investigation prepared by Geotechnologies Inc., dated May 24, 2024, included as Appendix E to this document, the historic groundwater depth for the Project Site is on the order of 40 feet below ground surface. Therefore, the Project proposes to implement a drywell system, along with an underground detention tank system for added storage to allow the drywell to infiltrate the required treatment volume. Additionally, it is preliminarily proposed to use drywell systems with added detention to treat and infiltrate the 85th percentile storm runoff. All site and building runoff will be captured and directed to the drywell system, where the 85th percentile storm event runoff will be captured, treated and infiltrated. If future si te-specific soils investigation results in unfavorable conditions for implementing a drywell system, the Project would still provide the required stormwater treatment compliance by implementing a rainwater harvesting/reuse or alternative treatment system i n coordination with the City. Any overflow stormwater runoff beyond the required treated volume will be discharged into the surrounding streets including Uplander Way, Bristol Parkway, and Hannum Avenue. The final design and location of the drywell system will be subject to review and approval by the City of Culver City Department of Public Works Source control measures per the City’s LID requirements, including good housekeeping, removal of trash and maintenance of driveways and parking areas, and proper use and storage of pesticides, would also reduce surface water quality impacts and would prevent pollutants from entering the surface water flow system, as well as to groundwater by percolation within landscaped areas. Any on -site use of hazardous materials in association with operation of the Project, such as small quantities of potentially hazard ous materials in the form of cleaning solvents, painting supplies, and pesticides for landscaping, as well as fuel storage associated with maintenance and/or emergency equipment, would be contained, stored, and used in accordance with manufacturers’ instru ctions and handled in compliance with applicable standards and regulations, such that no hazardous materials would be exposed to or otherwise would adversely impact groundwater quality.

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Due to the incorporation of the required LID system and BMPs, operation of the Project would not result in discharges that would cause (1) pollution which would alter the quality of the waters of the State (e.g., Ballona Creek) to a degree which unreasonab ly affects beneficial uses of the waters; (2) contamination of the quality of the waters of the State by waste to a degree which creates a hazard to the public health through poisoning or through the spread of diseases; or (3) nuisance that would be injuri ous to health, affect an entire community or neighborhood, or any considerable number of persons, and occurs during or as a result of the treatment or disposal of wastes.

Furthermore, the existing Project Site was developed prior to the enforcement of storm water quality BMP design, implementation, and maintenance requirements. The existing Project Site currently does not implement BMPs and has no significant means for use or treatment of stormwater runoff. Therefore, with implementation of the LID BMPs, the Project would substantially improve the quality of stormwater runoff discharged from the Project Site. Accordingly, operation of the Project would not result in discharges that violate any water quality standards or waste discharge requirements. Therefore, impacts resulting from Project operation would be less than significant with respect to surface water quality and groundwater quality and within the scope of impacts analyzed in the Certified PEIR.

Groundwater Quality
Construction
Excavation could occur to a depth of approximately 28 feet below ground surface (bgs) for the lowest foundations. As described in the Preliminary Geotechnical Investigation report prepared for the Project, the highest historical groundwater level is approx imately 40 feet below grade and no groundwater was encountered in the borings, drilled to a maximum depth of 80 feet below the existing ground surface. Based on historic groundwater levels in the Project Site vicinity and the depth of proposed construction, groundwater is not expected to be encountered during construction. However, in the unanticipated event that groundwater seepage were to occur within any of the deeper excavations, dewatering would be conducted in accordance with General NPDES Permit No. CAG994004, in which the developer must submit a Notice of Intent (NOI) to discharge groundwater generated from dewatering operations during construction in accordance with the requirements of the NPDES permit. Dewatering operations are practices that discharge groundwater that must be removed from a work location into the storm drain system to proceed with construction. Discharges from dewatering operations can contain high levels of fine sediments, which, if not properly treated, could lead to exceedance of the NPDES requirements. Temporary pumps and filtration would be utilized in compliance with the NPDES permit. If dewatering is required, the treatment and disposal of the dewatered water would, therefore, occur in accordance with the requirements of LARWQCB’s Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties.

Although not anticipated, if contaminated soil is encountered during grading and excavation, there could be a potential to impact groundwater quality. In the event that contaminated soils were to be encountered during construction, soils would be tested to determine the nature and extent of the contamination and appropriate handling, disposal, and/or treatment would be implemented in accordance with applicable regulations. In addition, Project construction activities would occur in accordance with City grading permit regulations. Furthermore, as part of standard construction practices, soil is routinely tested for contaminants to ensure removed soils meet the disposal requirements of the receiving construction and demolition (C&D) facility or construction site. With the removal of any potential contaminated soils and/or materials, grading

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and excavation activities would not pose a significant hazard to groundwater quality. Therefore, construction-related impacts on groundwater quality would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Operation
The Project does not include the installation or operation of water wells or any extraction or recharge system that is in the vicinity of the coast, within an area of known groundwater contamination or seawater intrusion, in proximity to a municipal supply well, or within a spreading ground facility.

Operational activities that typically affect groundwater quality include spills of hazardous materials and leaking underground storage tanks (USTs). Surface spills from the handling of hazardous materials at non- industrial sites like the Project Site most often involve small quantities that are removed in a timely manner, thereby resulting in little to no effect on groundwater. Other types of risks such as leaking USTs have a greater potential to affect groundwater. However, no USTs would be installed as part of the Project.

Therefore, operation of the Project would not result in discharges that would violate any groundwater quality standard or waste discharge requirement. Operation-related impacts on groundwater quality would be less than significant . As such, o peration-related impacts on groundwater quality would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update would increase the demand for water, which in turn could lead to groundwater pumping. The City’s water service is provided by the Los Angeles Department of Water and Power (LADWP) and the Golden State Water Company (GSWC). Since the groundwater supply used by the City’s water providers is regulated, there are limits on the amount of groundwater each provider can pump for potable use , and for this reason, the potential for overdraft is limited. Additionally, neither of the water providers rely solely on groundwater to service the Planning Area and would be able to utlize other sources of potable water to supplement a decrease in the amount of available groundwater, if needed. Therefore, implementation of the General Plan 2045 is not aniticipated to substnatially deplete groundwater supplies.

In regard to groundwater recharge, a substantial increase in impervious surfaces would limit future groundwater recharge. The General Plan 2045 and Zoning Code Update establishes land use designations that would encourage mixed uses and infill development, while maintaining existing parks and open space resources and expanding these resources. Therefore, future development under the General Plan 2045 and Zoning Code Update would not result in substantial increases of impervious surfaces such that groundwater recharge would be substantially hindered. Furthermore, the CBC regulates any development that requires

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grading to submit an engineering geology report, which would include information about existing groundwater supplies and potential impacts to groundwater supplies. Therefore, any future development under the General Plan 2045 subject to the CBC would be required to account for its potential groundwater use and implement appropriate water conservation measures (or other mitigating actions) if the potential demand is projected to exceed the available supply . For these reasons, impacts were determined to be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to groundwater supplies, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is located in an urbanized area of the City and is currently developed with four one- to two-story office buildings, areas of asphalt -paved surface parking, and ornamental landscaping. As stated in the Hydrology and Water Quality Technical Memorandum, 87 percent (7.2 acres) of the Project Site is currently impervious. 46 The Project Site does not currently provide a substantial opportunity for recharge of groundwater. Furthermore, the Project does not propose to use groundwater or to develop long- term groundwater production wells, which would lead to decreased groundwater supplies. While some dewatering could be necessary during construction activities (although unlikely), such dewatering activities would not substantially alter groundwater supplies because construction would be temporary, the planned excavation depths are shallower than the lower groundwater levels, and any necessary treatment and disposal of the dewatered water would occur in accordance with the requirements of LARWQCB’s Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles County. With development of the Project, the impervious area on the Project Site would remain substantially similar at 7.2 acres (86 percent). In addition, stormwater runoff captured and treated onsite for water treatment purposes via the Project’s drywell system would allow for infiltration into the underlying soils for groundwater recharge.

Therefore, with the Project’s LID stormwater system in place, there would not be a substantial ch ange to groundwater recharge conditions. Furthermore, the Project would not include the installation of water supply wells on the Project Site .

Based on the above, the Project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin. Thus, impacts would be less than significant and within the scope o f impacts analyzed in the Certified PEIR.

46 Kimley Horn and Associates, Inc., Hydrology and Water Quality Technical Memorandum, dated April 24, 2024, page 1.

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
c) Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on or off site; Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update could impact existing drainage systems. However, the Certified PEIR notes that the majority of the City is currently developed and new housing would primarily consist of infill development. Furthermore, future development would be required to comply with a ll applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No. CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Therefore, compliance with applicable regulations would ensure that impacts are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to altering the drainage pattern that would result in substantial erosion or siltation on or off site, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
No streams or rivers occur on or near the Project Site. As discussed above, the amount of impermeable surface areas on the Project Site would remain substantially similar at 7.2 acres (86 percent)), meaning that the Project’s use of impermeable surface would not substantially alter the existing drainage pattern of the area. In addition, the Project would include a drywell system that captures the 85th percentile runoff volume for treatment and provides infiltration consistent with the City’s SUSMP and LID r equirements and preferred stormwater management system priorities. As discussed in the Hydrology and Water Quality Technical Memorandum, with the drywells system in place, the combined storage capacity volume of the system would meet or exceed the required capacity of approximate 27,321 cubic feet (CF). If future site - specific soils investigation results in unfavorable conditions for implementing a drywell system, the Project would still provide the required stormwater treatment compliance by implementing a rainwater harvesting/reuse or alternative treatment system in coordination with the City. Under existing conditions, during a 50-year storm event, runoff is 16 cubic feet per second (cfs). With the drywell system, runoff from the Project Site during the 50-year storm event would likewise be 16 cfs. Thus, no increase in offsite runoff would occur under the proposed Project conditions, consistent with City LID and SUSMP requirements, further showing that the Project would not substantially alter the existing drainage pattern of the area.

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Under existing conditions, the existing site gradient and stormwater runoff generally flows northerly/westerly for the northern half of the site and southerly/westerly for the southern half of the site.

The onsite stormwater flows into shared access driveway drains located throughout the site, and is conveyed offsite to the gutter within surrounding streets. Once the stormwater runoff has left the site and is in the public right-of-way, it is directed west and south via concrete gutters along either Hannum Avenue, Bristol Parkway or Uplander Way, respectively, until it enters the Culver City storm drain system through curb opening catch basins downstream (see Figures 1 and 2 of the Hydrology and Water Quality Technical Memorandum). The storm drain system ultimately discharges into Centinela Creek Lower, which leads to Ballona Creek.

Under the Project conditions, stormwater runoff from the Project Site would be captured and treated by an LID drywell system as described above. Any overflow stormwater runoff beyond the required treated volume that is not infiltrated would be discharged into the surrounding streets, like under the current Project Site conditions. As discussed above, once the stormwater runoff has left the site and is in the public right - of-way, it would be directed west and south via concrete gutters along either Hannum Av enue, Bristol Parkway or Uplander Way, respectively, until it enters the Culver City storm drain system through curb opening catch basins downstream. Because the overall amount of offsite stormwater runoff from the Project would be less than under existing conditions and any such runoff would continue to flow into the City’s municipal storm drain system, which would continue to accommodate the runoff, the Project would not substantially alter the existing drainage pattern of the Project Site or area, includ ing through the alteration of the course of a stream or river or through the addition of impervious surfaces. As such, the Project would not result in substantial erosion or siltation on - or off-site, and impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on or off site;
Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update could impact existing drainage systems. However, the Certified PEIR notes that the majority of the City is currently developed, and new development would primarily consist of infill development.

Furthermore, future development would be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No.

CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Therefore, compliance to applicable regulations would ensure that impacts are less than significant.

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Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to altering the drainage pattern that would substantially increase the rate or amount of surface runoff , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As previously discussed, construction activities have the potential to temporarily alter existing drainage patterns and flows on the Project Site by exposing the underlying soils, modifying flow direction, and making the Project Site temporarily more permeable. As discussed above in Threshold a), the Project would implement a SWPPP that specifies BMPs and erosion control measures used during construction to manage runoff flows. These BMPs are designed to contain stormwater or construction watering on the Project Site such that runoff does not impact off -site drainage facilities or receiving waters. In addition, Project construction activities would occur in accordance with City grading permit regulations that require necessary measures, plans, and inspections to reduce sedimentation and erosion. Thus, through compliance with all NPDES General Construction Permit requirements and compliance with applicable City grading permit regulations, construction activities for the Project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. As such, construction -related impacts to hydrology would be less than significant, consistent with the Certified PEIR.

With respect to operations, as discussed above in Threshold c.i), the amount of impermeable surface areas on the Project Site would remain substantially similar at 7.2 acres (86 percent). In addition, the Project would include a drywell system that captures the 85th percentile runoff volume for water quality treatment and provides infiltration consistent with the City’s SUSMP and LID requirements and preferred stormwater management system priorities. As discussed in the Hydrology and Water Quality Technical Memorandum, with the drywells system in place, the combined storage capacity volume of the system would meet or exceed the required capacity of approximately 27,321 CF. Therefore, the Project is anticipated to implement a drywall system, along with an underground tank system for added storage to allow the drywell to infiltrate the required treatment volume. If future site -specific soils investigation results in unfavorable conditions for implementing a drywell system, the Project would still provide the re quired stormwater treatment compliance by implementing a rainwater harvesting/reuse or alternative treatment system in coordination with the City. Under existing conditions, during a 50-year storm event, runoff is 16 cfs. With the Project’s drywell system, runoff from the Project Site during the 50-year storm event would remain at 16 cfs. Thus, offsite runoff would remain the same under the proposed Project conditions, consistent with City LID and SUSMP requirements. Flows would continue to be accommodated by the existing stormwater treatment and conveyance system . Therefore, the Project would not substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Thus, Project impacts would be less than significant and would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

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iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update could impact existing drainage systems. However, the Certified PEIR notes that the majority of the City is currently developed, and new development would primarily consist of infill development.

Furthermore, future development would be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No.

CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Therefore, compliance to applicable regulatio ns would ensure that impacts are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to altering the drainage pattern that would create or contribute runoff water that would exceed the capacity of stormwater drainage systems or provide substantial additional sources of polluted runoff , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As discussed in Threshold c.i), the Project Site’s stormwater runoff would remain at 16 cfs with the Project during a 50- year storm event. Flows would be accommodated by the proposed stormwater drywell treatment and conveyance system, which would capture, treat and infiltrate the 85th percentile storm event consistent with the City’s SUSMP and LID requirements and preferred stormwater management system priorities. In addition, as discussed under Response No. X.a, the implementation of BMPs required by the City would target the pollutants that could potentially be carried in stormwater runoff. As such, the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Therefore, with the incorporation of the proposed drywell system (or similar complaint system as discussed above) and LID BMPs, operation of the Project would not create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff . Thus, Project impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

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iv) impede or redirect flood flows?
Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update could impact existing drainage systems. However, the Certified PEIR notes that the majority of the City is currently developed, and new development would primarily consist of infill development.

Furthermore, future development would be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No.

CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Therefore, compliance to applicable regulations would ensure that impacts are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to impeding or redirecting flood flows , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is designated by the Federal Emergency Management Agency (FEMA) as an Area of Minimal Flood Hazard , and it is not located within a mapped flood zone, including the 100-year flood zone.47 The Project Site is located in an urbanized area and there are no rivers, streams, or other water bodies (natural or urban) that could produce substantial flood flows on or through the Project Site.

Therefore, the Project would not substantially alter the existing drainage pattern of the Project Site or the area in a manner that would impede or redirect flood flows. As such, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
d) In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to Project inundation?
Impact Determination in the Certified PEIR
The City, which is located approximately 1.5 miles inland from nearby coastal areas, is located outside of tsunami inundation zones. In addition, there are no enclosed large water bodies within the City with potential for seiche effects or waves generated by failure of retaining structures. Furthermore, the majority of the City is located outside of a flood hazard zone. Future development facilitated under the General Plan

47 Federal Emergency Management Agency, Flood Insurance Rate Map, Map Number 06037C1760F, Map Revised: October 2020.

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2045 and Zoning Code Update will be required to comply with all applicable laws, regulations, and permits related to drainage and flooding hazards, which will reduce the risk of onsite flooding and release of pollutants. Therefore, compliance with existing regulations would ensure that impacts associated with release of pollutants from inundation by flood, tsunami, or seiche are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to risk of release of pollutants due to inundation from flood hazard, tsunami, or seiche , nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
A seiche is a temporary disturbance or oscillation of a body of water in an enclosed or semi-enclosed basin, such as a reservoir, harbor, lake, or storage tank. A tsunami is a great sea wave, commonly referred to as a tidal wave, produced by a significant disturbance undersea, such as a tectonic displacement of sea floor associated with large, shallow earthquakes.

As discussed in Threshold c.iv), the Project Site is mapped by FEMA as an Area of Minimal Flood Hazard.

As such, the Project would have a less than significant impact related to risk of pollutants for a project within a flood hazard zone.

According to the County of Los Angeles Tsunami Hazards Area Map, the Project Site is not located within mapped tsunami inundation boundaries.
48 Therefore, the Project would not be subject to flooding hazards associated with tsunamis.

As provided in the Culver City Natural Hazards – Fire and Flooding Map, the Project Site is not within any inundation areas.49 Therefore, the Project would not be subject to flooding hazards associated with seiches.

Based on the above, the Project would not result in the release pollutants due to inundation by flooding, tsunami, or seiche. Thus, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

48 California Department of Conservation, CGS Information Warehouse: Tsunami Hazard Area Map, https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/?extent=-13249590.3641%2C3986280.7635%2C- 13132183.0887%2C4038410.8168%2C102100&utm_source=cgs+active&utm_content=losangeles. Accessed April 25, 2025. 49 City Culver City, Natural Hazards – Fire and Flooding, February 1, 2007. https://www.culvercity.org/files/assets/public/v/1/documents/information- technology/maps/culver_city_natural_hazards_map.pdf. Accessed April 25, 2025.

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e) Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Impact Determination in the Certified PEIR
The Certified PEIR determined that future development under the General Plan 2045 and Zoning Code Update will not degrade water quality due to compliance with all applicable federal, state, regional and local water quality laws, regulations, and permits. The General Plan 2045 contains goals and policies that promote improved water quality and groundwater sustainability in the City, as well as continued compliance with state and local water quality regulations, which is intended to ensure that water quality and groundwater sustainability is managed to the maximum extent practicable. Future development will not interfere with or conflict with the Groundwater Sustainability Plan since the City is a member of the Santa Monica Basin Groundwater Sustainability Agency and the General Plan 2045 includes various implementation actions that support the Groundwater Sustainability Plan, including incentivizing and mandating stormwater infiltration where feasible and participating in regional coordination regarding aquifer recharge and sustainable groundwater supply. Thus, future development facilitated under the General Plan 2045 and Zoning Code Update will not conflict with the Santa Monica Subbasin Groundwater Sustainability Plan, and impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to a conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As required by Section 303(d) of the Clean Water Act (CWA), the State and the Regional Water Boards assess water quality data for California’s waters every two years to determine if they contain pollutants at levels that exceed protective water quality criteria and standards. 50 The LARWQCB most recently prepared
a list of impaired waterbodies in the region as part of the 2022 assessment cycle. This list is referred to as the 303(d) list. All waterbodies on the 303(d) list are subject to the development of a Total Maximum Daily Load (TMDL). The nearest water body to the Project Site that has been identified as an impaired water body is Ballona Creek, approximately 1.7 miles west of the Project Site. Impairment for Ballona Creek include trash, toxic pollutants, bacteria, metals, and sediment.

As previously discussed, in terms of polluted runoff, the Project’s proposed uses would be typical of residential and commercial uses and would not introduce substantial sources of polluted water that a use such as an industrial use would generate, for example. Moreover, the Project will also include the use of drywells which would serve to address any potential polluted runoff generated by the Project. With implementation of the drywells, polluted runoff would be minimized under the Project Site. As such, the Project would not conflict with or obstruct any water quality control plans. No other water quality control

50 State Water Resources Control Board, Impaired Water Bodies, accessed April 20, 2024, https://www.waterboards.ca.gov/water_issues/programs/water_quality_assessment/2020_2022_integrated_report.html.

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plans or sustainable groundwater management plans would be affected by development of the Project . As such, impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Construction
As discussed in the Certified PEIR, the Project Site falls under the jurisdiction of the LARWQCB (Region 4) Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. The LARWQCB is also given authority to issue waste discharge requirements, enforce actions against stormwater discharge violators, and monitor water quality. In California, the NPDES stormwater permitting program is administered by the SWRCB and the local RWQCB, which in this area is the LARWQCB. In addition, the Project Site straddles the boundaries of Groundwater Basin 4-011.01, Coastal Plain of Los Angeles –Santa Monica, and Groundwater Basin 4 -011-03, Coastal Plain of Los Angeles -West Coast. 51 The Sustainable
Groundwater Management Act (SGMA) passed in 2014 requires local Groundwater Sustainability Agencies (GSAs) in high - and medium -priority basins to develop and implement Groundwater Sustainability Plans (GSPs) or to develop Alternatives to G SPs. GSPs provide a roadmap for how groundwater basins will reach long -term sustainability. The Coastal Plain of Los Angeles– Santa Monica, which is a medium -priority groundwater basin, requires the formation of a groundwater sustainability agency and GSP that includes objectives of maintaining groundwater quality. On the other hand, the West Coast Basin is a low-priority basin and does not include a GSP.

As discussed in Threshold a), since the construction site would be greater than one acre, the Project would be required to obtain coverage under the NPDES Construction General Permit, which would be under the jurisdiction of the LARWQCB. In accordance with the requirements of this pe rmit, the Project would implement a SWPPP that specifies BMPs and erosion control measures to be used during construction to manage runoff flows, prevent pollution, and avoid on- or off-site flooding during construction. The NPDES Construction General Perm it and SWPPP measures are designed to contain and treat, as necessary, stormwater or construction watering on the Project Site, so runoff does not impact off-site drainage facilities or receiving waters with sediment or other pollutants. In addition, the Project would be required to comply with all applicable City grading permit regulations that require necessary measures, plans, and inspections to reduce sedimentation and erosion, control runoff from the construction site, and avoid on- and off-site flooding during the construction period. Compliance with the Construction General Permit and City grading permits during construction would prevent degradation of water quality, which would be consistent with the objectives of the Basin Plan and the GSP, resulti ng in a less than significant impact . As such, impacts would be within the scope of impacts analyzed in the Certified PEIR.

Operation
The County of Los Angeles and the City of Culver City are co-permittees under the Los Angeles County NPDES MS4 Permit and, as such, are required to implement development planning guidance and control measures regarding water quality impacts from new development.

The Los Angeles County MS4 Permit contains provisions for implementation and enforcement of stormwater management and includes a LID Plan that designates BMPs that must be used by projects to address water infiltration, filtering, treatment, and peak -flow discharge. The City of Culver City supports

51 California Department of Water Resources website, SGMA Portal, accessed April 20, 2025, https://sgma.water.ca.gov/webgis/?appid=160718113212&subbasinid=4-011.01.

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the requirements of the Los Angeles County MS4 Permit through the Culver City SUSMP and local regulations that provide guidance to developers of newly developed projects for compliance with regulatory standards. The Project is also within the jurisdiction of the Stormwater Quality Master Plan developed by Culver City, which includes descriptions of BMPs required by the city for stormwater quality management.

The Project would install building roof drain downspouts, catch basins, and planter drains to collect roof and site runoff and direct stormwater via a series of underground storm drainpipes to its drywell system.

Water captured and treated in the drywells would be infiltrated into the underlying soils. This storm water capture, treatment and infiltration system would be consistent with the LARWQCB’s Basin Plan for the Coastal Waters of Los Angeles and Ventura Counties.

The Project’s potential impacts regarding water quality are evaluated under Response X.a. As indicated in that analysis, since the existing Project Site currently does not implement BMPs and has no significant means for treatment of stormwater runoff, the Project would substantially improve the quality of stormwater runoff discharged from the Project Site. With the implementation of the Project’s on-site storm water capture and treatment system, the Project would have less-than -significant impacts on both s urface and groundwater quality during operation.

The Project’s potential impacts regarding groundwater supplies and groundwater recharge are evaluated above under Threshold b).

Therefore, in conjunction with the implementation of necessary BMPs to support the applicable plans, the Project would not conflict with or obstruct implementation of a water quality control plan ( e.g., the Basin Plan) or sustainable groundwater management plan (e.g., the GSP) during operation of the Project, resulting in a less than significant impact . As such, impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to hydrology and water quality would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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3.10 Land Use and Planning
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Land Use and Planning: Would the project:
(a) Physically divide an established community? Less than Significant No Less than
Significant N/A
(b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? Less than
Significant No Less than
Significant N/A

a) Would the Project physically divide an established community? Impact Determination in the Certified PEIR
The Certified PEIR determined that implementation of the General Plan 2045 and Zoning Code Update would improve connectivity and land use patterns within and between existing neighborhoods, thereby providing more linkages within the City and the region. Because the General Plan 2045 and Zoning Code Update provides strategies for thoughtful infill development and redevelopment and establishes a land use pattern that promotes a multi-modal network and pedestrian connectivity, the Certified PEIR determined that the General Plan 2045 and Zoning Code Update would not physically divide an established community.

Therefore, impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to physically dividing an established community, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is currently developed with four one- to two-story office buildings, areas of asphalt-paved surface parking, and ornamental landscaping. The Project vicinity is urbanized and generally built out and is characterized by a mix of office, business park and residential uses and includes a fully developed roadway system. As such, the Project would represent redevelopment and infill development of an already fully developed site. Furthermore, the Project would not close any public streets or othe rwise alter established infrastructure in the area. The Project would encourage multiple modes of travel by providing bicycle access and bicycle parking spaces. For all of these reasons, the Project would not physically divide an established community, and thus the impact would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

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Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Impact Determination in the Certified PEIR
The Certified PEIR determined that the General Plan 2045 and Zoning Code Update will not conflict with California Government Code Section 65302, SCAG’s 2024 RTP/SCS, the Complete Streets Act (AB 1358), the 2021-2029 Housing Element Update , Culver City and Culver City Unified School District Multi- Jurisdictional Hazard Mitigation Plan, the Culver City Bicycle & Pedestrian Action Plan, or the Culver City Urban Forest Master Plan. Thus, the General Plan 2045 and Zoning Code Update will not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and impacts would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to conflicts with a land use plan, policy, or regulation, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
As discussed below, the Project will not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect State Planning Law
The Certified PEIR determined that the General Plan 2045 and Zoning Code Update would not conflict with California Government Code Section 65302. The Project is proposing the development of commercial and residential uses consistent with the types of uses envisioned for the Project Site under the General Plan 2045 and in furtherance of the goals and policies that were implemented to support the City’s land use approach and vision. As such, no Project conflicts would occur with State Planning Law.

SCAG Connect SoCal 2024
As discussed in Section 3.7, Greenhouse Gas Emissions, the purpose of SCAG’s 2024 –2050 RTP/SCS (Connect SoCal) is to achieve the regional per capita GHG reduction targets for the passenger vehicle and light-duty truck sector established by CARB pursuant to SB 375. Generally, projects are considered to not conflict with applicable County and regional land use plans and regulations, such as Connect SoCal , if they are compatible with the general intent of the plans and would not preclude the attainment of their primar y goals. As discussed in Section 3.7, Greenhouse Gas Emissions, and shown in Table 1 5, the Project would not conflict with the Connect SoCal goals. The Project would provide 305 bicycle parking spaces for residents, employees and visitors, including 31 short-term and 274 long-term spaces, in compliance with

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City codes. In addition, the Project would provide electric vehicle (EV) ready and Full EV charging stations per the requirements of CCMC Section 17.320.035, which would be forty percent of the parking spaces provided for EV ready ( 522 spaces) and ten percent of the parking spaces as Full EV charging stations (131spaces). The Project’s EV parking would help support SCAG’s GHG reduction goals and policies.

Furthermore, the Project would implement strategies and action plans as part of a comprehensive TDM program (see TRAF-PDF-2) to reduce single occupancy vehicle trips while promoting the use of alternative transportation modes, thereby further reducing Project VMT. The Project would co-locate high -density residential and commercial uses near existing educational, employment, and commercial uses to enhance the mixed-use environment in which residents benefit from nearby shopping and employment opportunities and would be within walking distance of the Culver City Transit Center, which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity include, to the north, Culver City Bus Line 3 – Crosstown, which includes Stop 305 Hann um Ave/Bristol Pkwy, and to the west, Stop 386 Bristol/Hannum for Metro Bus Line 110 and Culver City Bus Line 3. Also within 0.2 mile east of the Project Site is Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 307 Hannum Ave/Buckingham Parkway. The Project’s land use characteristics, including its location near transit, housing, and bicycle/pedestrian facilities, would encourage non-automotive forms of transportation.

Overall, the integration of land uses on the Project Site and Project features discussed above would produce substantial reductions in automobile trips to and from the Project Site that would help the region accommodate growth and promote public transit ridership and alternative transportation modes that minimize GHG emission increases and reduce per capita emissions. Thus, the Project would not conflict with the goals/policies of Connect SoCal and would be within the scope of the Certified PEIR.

California Complete Streets Act Consistency
Assembly Bill (AB) 1358, the Complete Streets Act (Government Code Sections 65040.2 and 65302), requires cities and counties, when updating the part of a local general plan that addresses roadways and traffic flows, to ensure that those plans account for the needs of all ro adway users. The Certified PEIR determined that the General Plan 2045 and Zoning Code Update will not conflict with AB 1358 because the General Plan 2045 includes policies that support the City’s efforts to implement the Complete Streets Act. The Project is not updating a local general plan, but is proposing the development of uses that would be consistent with the types of uses envisioned for the Project Site under the General Plan 2045.

Additionally, the Project is aligned with the General Plan 2045’s transportation-related goals and will not prevent the City from completing any of its Complete Streets projects. See Section 3.16, Transportation , for additional discussion. Thus, no Project conflicts would occur with the California Complete Streets Act.

Regional Housing Needs Assessment
The City recently adopted the 2021-2029 Housing Element Update, which is one of the State -mandated elements that must be included in the General Plan. State law stipulates that the Housing Element include certain items, such as a Housing Needs Assessment; goals, policies, and objectives regarding housing in City; and implementation programs to work toward achieving those goals. For the 6th Cycle Housing Element planning period of 2021 to 2029, the City received a RHNA allocation of 3,341 units. Per State mandate, the City must zone sufficient land for housing affordable to people at all income levels. The General Plan 2045 includes the land use and zoning amendments necessary to allow for the development of the residential units needed to meet the City’s 6th cycle RHNA allocation. Here, the Project is consistent with the General Plan’s land use designation, and the Project’s inclusion of 1,077 residential units will help

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the City meets its housing needs as included in the 6th cycle RHNA allocation. As such, no Project conflicts would occur with the City’s Housing Element Update or the RHNA.

Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan
The Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) presents a strategy for reducing the City's and the Culver City Unified School District’s (CCUSD) vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The MJHMP is a framework that guides the City in making decisions and developing policies to reduce or eliminate risk to life and property. The Certified PEIR determined that the General Plan 2045 and Zoning Code Update will not conflict with the MJHMP. The General Plan and the MJHMP are complementary planning documents that together achieve the goal of the reduction of risk exposure to residents within the Planning Area. No aspects of the Project would interfere with or conflict with implementing the emergency and evacuation planning policies included in the MJHMP.

Culver City Bicycle & Pedestrian Action Plan
The Culver City Bicycle & Pedestrian Action Plan (Action Plan) establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network. The Action Plan includes goals to support increased access to neighborhood destinations and transit stations, empowering residents to live a more active lifestyle, and increasing affordability and collaboration for transpor tation within the community. Although the objectives, policies, and actions of Action Plan are directed towards the City and therefore not directly applicable to the Project, the Project would nonetheless support the Action Plan. Both sides of Hannum Avenue, adjacent to the Project Site, contain a Class II Bike lane. No driveways are proposed along Hannum Avenue by the Project that would interfere with operations of these bike lanes.

The approved Action Plan also recommends Class II bicycle lanes on Bristol Parkway between Slauson Avenue and Centinela Avenue, which is adjacent to the Project Site . The Project would not preclude the development of the contemplated bike lane s along Bristol Parkway and rather would be compatible with such development given that the Project will include bicycle parking and storage places, both for project residents and the public.

In addition to promoting bicycling as a mode of transportation, the Project will also encourage other modes of transportation by providing EV parking spaces and by being located in close proximity to numerous public transit options. The Project Site is also located in close proximity to various employment places, institutions, and local retail shops, which will allow residents to get to many places via a short walk or bicycle ride. Furthermore, the Project would support the Action Plan through the provision of an enhanced streetscape plan. The Project will incorporate ground floor landscaping, a paseo with seating, various plaza areas, and neighborhood-serving commercial uses that will all help enhance the pedestrian experience in and around the Project Site. Those who live or work near the Project would also be able to take a short walk or bicycle ride to the Project to take advantage of these amenities rather than having to drive farther for similar options. To ensure maximum visibility, the Project’s driveways would meet all of the City’s access requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site, as well as bicyclists and pedestrians wishing to cross the driveways. Overall, the Project would not conflict with any of the applicable goals and actions of the Culver City Bicycle & Pedestrian Action Plan and thus would be within the scope of impacts analyzed in the Certified PEIR.

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Safer Fox Hills Project
The Project would not conflict with improvements contemplated within the Safer Fox Hills Project, which is a neighborhood-focused initiative that brings over 2.5 miles of new protected bike lanes to Green Valley Circle, Buckingham Parkway, Bristol Parkway, and Hannum Avenue. In addition to expanding bicycle infrastructure, the Safer Fox Hills project adds three new high -visibility crosswalks across Green Valley Circle and introduces a range of additional pedestrian safety and traffic calming improvements throughout the neighborhood. The Safer Fox Hills Project contemplates a protected intersection at Hannum Avenue and Bristol Parkway, as well as a directional concrete-protected bikes lanes along Hannum Avenue and Bristol Parkway adjacent to the Project Site. Development of the Project would not preclude future development of these transportation improvements identified in the Safer Fox Hills Project. Rather, the Project, with its various bicycle-centric amenities and neighborhood-serving retail use, is harmonious with the planned improvements under the Safer Fox Hills Project.

Culver City Urban Forest Master Plan
Chapter 2 of the UFMP provides recommendations for the urban forest, beginning with the large scale and broad vision for the urban environment of the City. It envisions an urban forest to strengthen the important network of “green connections” throughout the City. More than just tree-lined streets, the UFMP describes a green infrastructure that includes the urban forest, park land, sustainable transportation networks, and pedestrian areas that would provide vital functions for the City, including improving air and water quality, mitigating the urban heat island effect, reducing energy demand, and improving public health.

As indicated in the UFMP, in the vicinity of and adjacent to the Project Site, Hannum Avenue is designated as proposed bicycle lane, although the bike lanes have already been built since the Plan was adopted in 2016, where additional trees and landscaping are recommended to provide shade and aid in wayfinding. 52 The UFMP recommends planting trees along bicycle routes to provide shade and to aid in wayfinding in an effort to promote cycling and walking. One of the most important components of the UFMP is the Tree Palette, which provides a plan for creating a more resilient urban forest in Culver City. The Tree Palette is a master list of the species that are recommended for Culver City’s urban forest based on proven local performance, ability to thrive in urban conditions, resiliency, environmental benefits, a esthetics, habitat/ecosystem value, and good “new” species for Culver City.

Currently, there are no street trees along the southern side of Hannum Avenue adjacent to the Project. Street trees would be planted along Bristol Parkway, Hannum Avenue, and Uplander Way to provide shade and reflect the existing trees in the area. Final species selection would be implemented during permitting and construction based on the proposed palette and the Urban Forest Master Plan.

The Project’s landscaping and trees would also enhance the pedestrian character along Bristol Parkway, Hannum Avenue, and Uplander Way. Shade trees would be planted within the publicly accessible centrally- located open space paseo. Because the Project would provide street trees in accordance with the UFMP palette and include a landscaped, publicly accessible, privately maintained open space area s, it would not conflict with policies related to providing shade and wayfinding improvements within the designate d (or proposed) bicycle routes shown in the UFMP along Hannum Avenue . Therefore, the Project would not

52 City of Culver City, Culver City Urban Forest Master Plan, 2016, page 164.

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conflict with UFMP policies adopted to avoid or mitigate an environmental effect and thus would be within the scope of impacts analyzed in the Certified PEIR.

City of Culver City Municipal Code
The Project proposes to maintain the site’s Mixed Use High General Plan designation and the MU -HD zoning district. The Mixed Use High designation allows densities up to 100 units per acre. The MU -HD zoning district identifies areas appropriate for large- scale residential, office, and commercial uses emphasizing a variety of retail uses, including anchor tenants, entertainment, and restaurant uses that may share parking and serve a regional market area per CCMC Section 17.220.010. CCMC Section 17.220.020, Table 2-8, Mixed-Use District Development Standards, provides development standards for development of MU-HD sites.

Per CCMC Section 17.220.020, Table 2-8, Mixed-Use Development Standards, the maximum allowable height for the Project is 56 feet. However, the Project is proposing to include 78 units of its residential units as VLI affordable units. These VLI units will be distributed across each of the three proposed Project Site parcels (17, 36, and 25 units, respectively). By doing so, consistent with the CCMC and State Density Bonus Law (Gov’t Code § 65915), the Project is entitled to receive development incentives and waivers including a height increase. The Project is requesting a height increase of 37 feet and six inches beyond the maximum allowable height as a development incentive for providing affordable units. With this incentive, the Project would have a maximum height of 93 feet and 6 inches. Approval of these incentives as project design features would not result in a significant physical impact on the environment, as analyzed throughout this CEQA document. Refer to Section 3.1, Aesthetics, section for a discussion of aesthetics impacts.

CCMC Section 17.220.020, Table 2-8, also provides development standards for development of MU -HD sites. The applicable standards include providing a minimum front and side street setback of 10 feet for residential uses, and a zero -foot minimum f ront and street side setback requirement for n on-residential ground floor uses with up to a 10- foot or greater maximum setback permitted under certain conditions. 53 The Project’s setbacks would be consistent with the applicable MU-HD setback development standards and is requesting a waiver from any dedications under the Safer Fox Hills plan.

The Project is seeking approval of extended construction hours per CCMC Section 9.07.035.C.1. Per CCMC Section 9.07.035.A, Construction, allowed construction hours are 8:00 a.m. and 8:00 p.m. Mondays through Fridays; 9:00 a.m. and 7:00 p.m. Saturdays; 10:00 a.m. and 7:00 p.m. Sundays. The Project is requesting an approval for Extended Hours of Construction, as allowed by CCMC Section 9.07.035.C.1, to allow for a 7:00 a.m. daily start, Monday through Friday as well as a n 8:00 a.m. start on Saturdays. The extended construction hours are being requested for the entire construction duration. As analyzed in Section

3.12, Noise, the Project would not create any new significant impacts related to generation of noise, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

The Project would also require Site Plan Review to construct a new residential project with more than 26 units (CCMC Section 17.540) and a Vesting Tentative Parcel Map to consolidate the existing four Project

53 If a development provides a covered arcade, publicly-accessible plazas or forecourts, public art, fountains, or outdoor dining, and there is clear visibility between the sidewalk and building entrance, the maximum setback on the ground floor shall be 10 feet, or a greater setback may be allowed with Director approval.

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Site parcels and subsequently divide the Project Site into three parcels, each to contain one of the three Project buildings. Other ministerial approvals that would be required for the Project include, but may not be limited to, demolition, grading, excavation, and building permits as well as haul route permits. None of these approvals would conflict with an applicable land use plan, policy or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an env ironmental effect.

These approvals have been assessed as part of the Project throughout this document.

Based on the above, the Project will not conflict with the CCMC and thus is within the scope of the impacts analyzed in the Certified PEIR.

City of Culver City General Plan - Land Use and Community Design Element Section 4.10, Land Use and Planning, in the Certified PEIR did not specifically analyze impacts associated with future development projects consistency with applicable goals and policies of the Land Use and Community Design Element, however, such analysis is relevant to development of the Project. The General Plan’s Land Use and Community Design Element (Element 4), designates the proposed distribution, location, and extent of different uses of land, and expresses community intentions regarding urban form and design. Goals and Policies within this Element seek to develop higher density/mixed uses near transit (Goals LU-1, Policy LU-1.1 to LU-1.3, Goal LU-8, Policy LU8.1); provide a vibrant, mixed use Fox Hills area (Goal LU-7, Policy LU-7.2 to LU-7.3); provide a diverse range of housing options (Goal LU-2, Policy LU-11.2); provide high quality, walkable development, with active street frontages and gathering spaces (Policy LU-2.6, Goal LU -3, Policy LU -8.2, Goal LU -15, Policy LU -15.1 to LU -15.5, Policy LU -15.7); provide attractive, pedestrian -oriented, human-scale and well -landscaped streets and civic spaces throughout the city for all ages and abilities (Goal LU-14, Policy LU-14.1 to Policy LU-14.9); and provide sustainable landscape design (Goal LU16, Policy LU-16.1 to LU16.6).

As described above, the Project includes 1,077 residential units, and 5,772 sf of commercial uses. These proposed uses would be consistent with the types of uses envisioned under the General Plan 2045, and would be within the projections analyzed therein. The Project would be consistent with the General Plan land use designation and zoning of the Project Site, which is Mixed Use High, and allows for 100 du/acre, a maximum nonresidential FAR of 3.5:1 and a broad range of mixed use, residential, and commercial uses.

The Project would have a FAR of 3 .05:1. The Project is proposing to include 78 units (7 percent of its allowed base density of 1,077 units based on 100 du/acre allowed by Mixed -Use High designation per City’s Land Use Element) of its residential units as Low Income affordable units. By doing so, consistent with the CCMC and State Density Bonus Law (Gov’t Code §65915), the Project is entitled to receive development incentives and waivers including a height increase. The Project is requesting a height increase of 37 feet and six inches beyond the maximum allowable height as a development incentive for providing affordable units. With this incentive, the Project would have maximum building heights of up to 93 feet and six inches to the top of the roof to accommodate grade changes.

As summarized in Table 2 -4, General Plan 2045 Projections by Land Use , in Section 2.0 , Project Description, of the Certified PEIR, the General Plan 2045 allows for a net increase of 12,700 units for residential, 3,332,000 sf for commercial uses, 364,800 sf for industrial uses, and no net change for institutional uses. The total projected housing units included new infill, accessory dwelling units, housing on opportunity sites, pipeline projects, and existing residential units to remain. The Project would be considered an infill site and would be well within the City’s growth projections.

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Consistent with the applicable policies of the General Plan, the Project would provide a mix of uses at a density envisioned for the Project Site in the General Plan, which concentrates development within a TOC area that access to multiple alternative tran sportation options. The Project includes 78 units (7 percent of base density) as Low Income affordable units. The Project’s housing units would range in size and would include studio, one-bedroom and two-bedroom units, thereby providing multiple housing opportunities for members of the community. The commercial uses would include retail, which would contribute to the economic diversity within the City. The Project would activate Hannum Avenue by providing ground floor retail uses, aesthetic treatments on building facades, landscaping, street trees, lighting, seating areas and a landscaped publicly accessible paseo creating a place for gathering and community along Hannum Avenue. Finally, the Project is intending to incorporate sustainable design features equ ivalent to LEED Silver standards or better. As it relates to landscaping and water conservation, the Project would incorporate efficient water management through low flow faucets and water -efficient landscape design with weather - based controllers and drip irrigation systems, as well through the use of drought tolerant plant species. All landscaping would be subject to review and approval by the City confirm compliance with applicable policies and regulations.

Overall, as demonstrated throughout this document and as discussed above, the Project would not conflict with Culver City General Plan policies adopted to avoid or mitigate an environmental effect and, as such, impacts with respect to the General Plan would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Conclusion
Based on the analysis above, with approval of the requested discretionary actions, the Project would not conflict with or impede implementation of applicable land use plans, policies, or regulations of an agency with jurisdiction over the Project (including but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect.

Therefore, the Project’s impact would be less than significant, consistent with the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to land use and planning would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

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5757 Uplander Project 3-107 City of Culver City
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3.11 Mineral Resources
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Mineral Resources: Would the project:
(a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Less than
Significant No No Impact N/A
(b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Less than
Significant No No Impact N/A

a) Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b) Would the Project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? Impact Determination in the Certified PEIR
The Certified PEIR indicates that there are no aggregate or other mineral resource (shale, diatomite, clay or gypsum) mines within the Planning Area , and the Planning Area is not known to contain sand or gravel deposits of any economic importance. As such, the General Plan 2045 and Zoning Code Update would have no impact to aggregate mineral resources. Regarding oil and gas resources, the IOF is located within the City of Culver City and the unincorporated area of Los Angeles County known as Baldwin Hills. The current active IOF boundary is approximately 1,000 acres, of which 100 acres are located within the City of Culver City. While there is ongoing oil and gas production within the City’s portion of the IOF, the City adopted the Oil Termination Ordinance, which requires the closure of the City’s portion of the IOF. The General Plan 2045 and Zoning Code Update will not change the existing open space land use designation for the IOF that lies within the Planning Area. This designation, which allows open space, recreational, and/or park development, will ensure the presence and access to the existing oil and gas deposits will remain. Therefore, the General Plan 2045 and Zoning Code Update will not result in the loss of the regionally or locally important oil and gas resources. Thus, impacts to mineral resources would be less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts to mineral resources, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The closest oil field to the Project Site is the Inglewood Oil Field (Oil Field), which is located within the City of Culver City and the unincorporated area of Los Angeles County known as Baldwin Hills. The

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-108 City of Culver City
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current active Oil Field boundary is approximately 1,000 acres of which 100 acres are located within the City of Culver City. The Oil Field is located approximately 0.9 miles northeast of the Project Site. The Project Site is located in an urbanized area and is currently developed with four one- to two-story business park/office buildings, associated asphalt-paved surface parking lot and landscaping. As such, the potential of uncovering mineral resources during Project construction is considered low. The ne arest oil well to the Project is a former, inactive plugged well located approximately 0.5 miles northeast of the Project Site. 54 Therefore, the Project would not result in the loss of availability of a known mineral resource that would be of value to the region or the residents nor would it result in the loss of a known mineral resource delineated on a local general plan, specific plan, or other land use plan as there are no known mineral resources or mineral resource recovery sites on or near the Project Site. Thus, no impact would occur, and the impacts would be within the scope of impacts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to mineral resources would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

54 California Department of Conservation, Geologic Energy Management Division's (CalGEM), Well Finder, accessed April 17, 2024, https://maps.conservation.ca.gov/doggr/wellfinder/.

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5757 Uplander Project 3-109 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.12 Noise
Thresholds (and Supporting Information Sources):

Impact
Determination in
the Certified PEIR
Does the
Project
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Noise: Would the project result in:
(a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other
agencies?
Significant and
Unavoidable No
Less Than
Significant with
Mitigation
Yes
(b) Generation of excessive groundborne vibration or
groundborne noise levels?
Significant and
Unavoidable No Less Than
Significant Yes
(c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? No Impact No No Impact N/A

a) Would the Project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Impact Determination in the Certified PEIR
The Certified PEIR noted that c onstruction activity noise levels will fluctuate depending on the particular type, number, and duration of use of the various pieces of construction equipment. The exact locations of future projects and construction that will occur under the General Plan 2045 and Zoning Code Update is unknown, though it is assumed that some of the activities will take place in close proximity to sensitive receptors given that the City is generally built out. Even with mandatory compliance with Municipal Code requirements, it is possible that some future development projects could include construction in which multiple pieces of heavy -duty construction equipment and/or heavy-duty trucks may be required and that construction period noise levels could exceed the significance thresholds. Therefore, construction activities could result in a significant impact. Implementation of Mitigation Measure PEIR MM NOI-1 will help to reduce the potentially significant construction -related impacts resulting from a substantial temporary increase in ambient noise levels in the vicinity of future development projects in excess of the threshold.

However, even with implementation of Mitigation Measure PEIR MM NOI -1, the Certified PEIR determined that impacts could still be significant and unavoidable.

In contrast, the Certified PEIR found that s tationary noise, such as rooftop heating, ventilation, and air conditioning units, will be required to comply with applicable regulations. Therefore, the impact from stationary equipment will be less than significant.

With regard to operational noise, the Certified PEIR found that permanent increases in noise would occur primarily as a result of increased traffic due to future development that would occur as a result of the General Plan 2045 and Zoning Code Update . Future traffic noise levels were evaluated along 35 roadway

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-110 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

segments within the City. As shown in the Certified PEIR, there is no discernable difference for the majority of the segments when comparing existing noise levels with future project levels. However, since noise levels could exceed the threshold at the property line along one segment ( Washington Boulevard between Inglewood Boulevard and S. Centinela Avenue), the General Plan 2045 and Zoning Code Update’s impact on traffic noise was determined to be significant and unavoidable. The Certified PEIR found that there are no feasible mitigation measures to reduce such traffic noise levels.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to generation of noise, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Existing Ambient Noise Levels
To quantify the existing noise environment, two sets of short-term ( 15-minute) measurements were conducted at five locations, representing the ambient noise levels at land uses identified as R1 through R5 in Figure 22, Noise Measurement Locations. A 15-minute measurement is a standard duration for sampling ambient noise levels where street traffic is the dominant source, as traffic noise generally does not vary significantly within an hour. Ambient sound measurements were conducted on Wednesday, January 29th, 2025 to characterize the existing noise environment in the Project vicinity at the nearest sensitive receptors analyzed in the section below. The measurement locations are described below:
• R1: Medical and fire station building s are located approximately 50 feet from the Project boundary; medical uses at the Pacific Interventional Vascular Access Center are to the southwest of the Project Site, and a fire station is to the immediate west of the Project Site. • R2: Multi-family residential uses are located to the east of the Project Site, east of Buckingham Parkway and south of Windsor Way, approximately 420 feet from the Project boundary. • R3: Fox Hills Park is located to the south of the Project Site, west of Buckingham Parkway, approximately 250 feet from the Project boundary.

Future noise-sensitive uses near the Project Site that have been proposed or in-development at the time of preparation of this Draft EIR include the following:
• R4: (Proposed) Future multi-family residential uses will be located to the east of the Project Site, on the east side of Uplander Way where the existing US Veterans Affairs Department office exists, approximately 75 feet from the Project boundary. (In Development) Future preschool/kindergarten school uses will be located to the south of the Project Site at 5840 Uplander Way, on the south side of Uplander Way, located approximately 75 feet from the Project boundary.

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

SOURCE : ; ESA, 2025
Project Site
•
Noise Monitoring Locations
5757 Uplander Project
Figure 22
Noise Measurement Locations

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-112 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Commercial land uses, such as retail and office, are not considered sensitive noise receptors. However, for informational purposes only, the following commercial land uses near the Project Site were evaluated:
• R5: Commercial/Office land uses north of the Project Site, located approximately 100 feet from the Project boundary.

Noise measurements were conducted using Larson -Davis LxT1 Sound Level Meters (SLM). The Larson - Davis LxT1 SLM is a Type 1 standard instrument as defined in the American National Standard Institute (ANSI) S1.4. All instruments were calibrated and operated according to the applicable manufacturer specification. The recording microphones were placed at a height of 5 feet above the local grade elevation.

The sound level meters were setup to collect the hourly average noise level (L eq).

The results of the ambient sound measurements are summarized in Table 1 7, Summary of Ambient Noise Measurements.

TABLE 17

SUMMARY OF AMBIENT NOISE MEASUREMENTS
Location Measured Ambient Daytime Noise Levels, dBA Leq R1 57.2
R2 64.6
R3 56.2
R4 57.8
R5 64.6
SOURCE: ESA, 2025.

Existing Roadway Noise Levels
To further characterize the Project area’s ambient noise environment, Community Noise Equivalent Level (CNEL) noise levels attributed to existing traffic on local roadways were calculated using a traffic noise prediction model, which was developed based on calculation methodologies provided in the Federal Highway Administration (FHWA) Traffic Noise Model (TNM) Technical Manual, 55 and traffic data provided in the Project’s Transportation Study 56 (see Appendix I of this document). The TNM model calculates the average noise level at specific locations based on traffic volumes, average speeds, and site environmental conditions.

Existing roadway noise levels were calculated for 35 roadway segments located in the vicinity of the Project Site. The roadway segments selected for analysis are those expected to be most directly impacted by Project-related traffic, which, for the purpose of this analysis, include the roadways located near and immediately adjacent to the Project Site. These roadways, when compared to roadways located further away from the Project Site, would experience the greatest percentage increase or largest increase in volume

55 The traffic noise model which was developed based on calculation methodologies provided in the Caltrans TeNS document and traffic data provided in the Project’s Transportation Impact Study are provided in Appendix K to this document. This methodology, considered an industry standard, allows for the definition of roadway configurations, barrier information (if any), and receiver locations.
56 Fehr & Peers, Transportation Impact Study for Link Culver City, June 2025 2025. Provided in Appendix K of this document.

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5757 Uplander Project 3-113 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

from traffic generated by the Project (as distances are increased from the Project Site, traffic is spread out over a greater geographic area and its effects are reduced).

The ambient noise environment in the Project vicinity can be characterized by 24 -hour CNEL levels attributable to existing traffic on local roadways. Table 18, Predicted Existing (202 5) Vehicular Traffic Noise Levels, indicates the calculated CNEL from actual existing traffic volumes on the analyzed roadway segments.

TABLE 18

PREDICTED EXISTING VEHICULAR TRAFFIC NOISE LEVELS
Roadway Segment
Existing Land Uses Located along
Roadway Segment
CNEL (dBA)
Existing (2025)
Bristol Pkwy
between Hannum Ave and Uplander Way Commercial 67.4
between Slauson Ave and Hannum Ave Commercial 66.4
between Uplander Way and Green Valley Cir Commercial 67.7 n/o Slauson Ave Cemetery 55.4
s/o Green Valley Cir Residential/Hotel/Cemetery 66.7
Buckingham Pkwy
between Slauson Ave and Hannum Ave Residential/Commercial/ Open Space 61.8 n/o Slauson Ave Commercial 60.2
s/o Hannum Ave Residential/Commercial 64.5
Corning Ave
n/o Slauson Ave Residential 62.0
s/o Slauson Ave Residential 64.3
Fox Hills Dr
s/o Hannum Ave Commercial 65.4
Green Valley Cir
e/o Bristol Pkwy Residential/Commercial 66.8
w/o Bristol Pkwy Commercial/Hotel 67.7
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.3
between Fox Hills Dr and Bristol Pkwy Commercial 68.5
between Slauson Ave and Hannum Avenue Commercial 66.8
between Uplander Wy and Buckingham Pkwy Commercial 68.0 n/o Slauson Ave Residential/Commercial 70.1
La Cienga Boulevard (NB)
n/o Slauson Avenue Residential 67.9
s/o Slauson Avenue Residential 68.1
La Cienga Boulevard (SB)
n/o Slauson Avenue Residential 70.6
s/o Slauson Avenue Residential 63.7

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-114 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 18

PREDICTED EXISTING VEHICULAR TRAFFIC NOISE LEVELS
Roadway Segment
Existing Land Uses Located along
Roadway Segment
CNEL (dBA)
Existing (2025)
Shenandoah Avenue
n/o Slauson Avenue Residential 61.9
s/o Slauson Avenue Residential 63.6
Slauson Avenue
Between Bristol Pkwy and Buckingham Pkwy Commercial 76.9 Buckingham Pkwy and Shenandoah Ave Commercial 77.0
Corning Ave and La Cienega Blvd (SB) Commercial 76.7
Hannum Ave and Bristol Pkwy Commercial/Marina Freeway 76.6 La Cienega Blvd (SB) and LA Cienega Blvd
(NB)
Residential 76.0
Shenandoah Ave and Corning Ave Residential 76.5
e/o La Cienega Blvd Commercial/Residential 75.5
w/o Hannum Ave Commercial 70.5
Uplander Way
e/o Bristol Pkwy Commercial 58.3
n/o Hannum Ave Commercial 57.7
s/o Hannum Ave Commercial 58.4
SOURCE: ESA 2025. Appendix I of this document

On-Site Construction Noise
Consistent with Mitigation Measure PEIR MM NOI- 1 (see below), a project -specific construction noise analysis was conducted to determine if the Project has the potential to generate significant noise impacts during construction. Noise modeling data is included in Appendix I of this document.

Noise impacts from construction activities are generally a function of the noise generated by construction equipment, equipment locations, the sensitivity of nearby land uses, and the timing and duration of the noise-generating activities.

Construction sequencing would include demolition; grading/excavation; subterranean work/concrete structure; building construction; architectural coating; and paving/sitework. Project construction would require the use of mobile heavy -duty equipment with high noise-level characteristics. Individual pieces of construction equipment expected to be used during Project construction could produce maximum noise levels of 74 dBA to 90 dBA L
max at a reference distance of 50 feet from the noise source, as shown in Table 19, Construction Equipment Noise Levels. These maximum noise levels would occur when equipment is operating under full power conditions. The estimated usage factor for the equipment is also shown in Table

19. The usage factors are based on the FHWA’s Roadway Construction Noise Model User’s Guide. 57 57 Federal Highway Administration, Roadway Construction Noise Model User’s Guide, 2017. https://www.gsweventcenter.com/Draft_SEIR_References/2006_01_Roadway_Construction_Noise_Model_User_Guide_FH WA.pdf

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5757 Uplander Project 3-115 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 19

CONSTRUCTION EQUIPMENT NOISE LEVELS
Equipment Estimated Usage Factor, %
Maximum Noise Level at 50 feet from
Equipment, dBA (Lmax)
Aerial Lift (Man Lift) 20 75
Air Compressor 40 78
Bore/Drill Rig 20 79
Concrete Saw 20 90
Crane 16 81
Excavator 40 81
Forklift 10 75
Generator Sets 50 81
Off Highway Truck (Dump Truck) 40 76
Other Equipment 50 85
Paver 50 77
Paving Equipment (Pavement Scarafier) 20 90
Pumps 50 81
Rough Terrain Forklift 10 75
Rubber Tired Dozer 40 82
Rubber Tired Loader 40 79
Skid Steer Loader 40 78
Sweepers/Scrubbers 10 82
Tractor/Loader/Backhoe 40 78
SOURCE: FHWA Roadway Construction Noise Model User’s Guide, 2017.

A summary of construction noise impacts at existing nearby sensitive receptors for different scenarios is provided in Table 20, Estimated Construction Noise Levels at Existing Off -Site Sensitive Receptors, with supporting calculations provided in Appendix I of this document.

As shown in Table 20, projected construction noise levels would exceed daytime noise thresholds (ambient plus 5 dBA) at R1 and R3 through R5, and impacts would be potentially significant before implementation of mitigation measures. CCMC noise regulations state that construction activity shall be prohibited, except between the hours of 8:00 a.m. and 8:00 p.m. Mondays through Fridays; 9:00 a.m. and 7:00 p.m. Saturdays; and 10:00 a.m. and 7:00 p.m. Sundays. A s part of its requested approvals, the Project is requesting an approval for Extended Hours of Construction, as allowed by CCMC Section 9.07.035.C.1, to allow for a 7:00 a.m. daily start, Mond ay through Friday as well as an 8:00 a.m. start on Saturdays. The extended construction hours are being requested for the entire construction duration.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-116 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 20

ESTIMATED CONSTRUCTION NOISE LEVELS AT EXISTING OFF-SITE SENSITIVE RECEPTORS Noise
Sensitive
Receptor
Daytime
Noise
Threshold
(Ambient +
5 dBA)
Maximum Unmitigated
Construction Noise Levels,a,b,c
(Exterior/Interior with windows
open/Interior with windows
closed) Hourly Leq (dBA)
Maximum Mitigated
Construction Noise Levels,a,c,e
(Exterior/Interior with windows
open/Interior with windows
closed) Hourly Leq (dBA)
Exceeds Threshold?
(Exterior/Interior with
Windows Open/Interior
with Windows Closed)
R1 62.2 84.7 / 71.7 / 59.7 61.7 / 48.7 / 36.7 No / No / No R2 69.6 69.1 / 56.1 / 44.1 46.1 / 33.1 / 21.1 No / No / No R3 61.2 72.9 49.9 No
R4 62.8 81.3 / 68.3 / 56.3 58.3 / 45.3 / 33.3 No / No / No R5 69.6 NAd / 65.7 / 53.7 NA / 65.7 / 53.7 No / No / No NOTES:
a. Estimated construction noise levels represent the worst-case condition when noise generators are located closest to the receptors. b. Bold values indicate an exceedance of daytime noise threshold. c. Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
d. Note that location R5 is commercial land uses and as such, exterior noise levels were not analyzed. e. Noise levels assume a noise barrier along the eastern boundary to shield receptors SOURCE: ESA, 2025.

As Project construction would result in temporary increases of 5 dBA or more in ambient noise , it would exceed the thresholds of significance at nearby noise sensitive receptors. Therefore, construction noise impacts would be potentially significant, and mitigation measures would be required.

As a result of implementing Mitigation Measure PEIR NOI-1 (see below), the Project-specific noise analysis has resulted in two foreseeable supplemental mitigation measures listed out below as Mitigation Measures Project MM NOI -1 and Project MM NOI -2. Mitigation Measure Project MM NOI -1 includes the use of temporary noise barriers and Mitigation Measure Project MM NOI-2 includes various construction equipment features which can reduce noise levels by a minimum of 6 dBA with the usage of improved mufflers. A study prepared for the U.S. Department of Transportation found that in cases where a particular piece of equipment either does not have or has a very poor muffler, the application of a good muffler will reduce the overall noise by 6 to 12 dBA.
58 As described below in MM-NOI-1, a noise barrier would be capable of reducing on-site construction noise levels by 17 to 19 dBA. As shown in Table 20 , with the implementation of Mitigation Measures Project MM -NOI-1 and MM -NOI-2, construction noise would be reduced by 23 dBA at the surrounding sensitive receptors to the west, east, and the south. Therefore, with the implementation of Mitigation Measures Project MM -NOI-1 and MM -NOI-2, impacts would be less than significant given construction noise levels at all receptor locations would be reduced below the 5-dBA significance threshold.

Off-Site Construction Noise
Delivery and haul truck trips would occur throughout the construction period, including during extended hours between 7:00 a.m. and 8:00 a.m. on weekdays and 8:00 a.m. to 9:00 a.m. on Saturdays during the entire construction period.

58 Toth, William J. 1979, August. “Noise Abatement Techniques for Construction Equipment.” Prepared for the National Highway Traffic Safety Administration. US Department of Transportation.

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As shown in Table 21, Estimate of Off-Site Construction Traffic Noise Levels, Project construction would yield an addition of 100 haul truck trips, 70 vendor truck trips, and 500 worker trips per day (12 truck trips, 9 vendor trips, and 63 worker trips per peak hour) from the phase with the greatest amount of haul trips and overlap which is during Parcel 1 finish, Parcel 1 paving, and Parcel 2 concrete structure overlap, which would result in a 4.8 dBA CNEL increase over the ambient condition along Uplander Way. Trucks and workers entering the site would arrive from Interstate 405, drive north on Sepulveda, drive east on Slauson Avenue, drive south on Bristol Parkway drive east on Hannum Ave and drive south on Uplander Way. Trucks and workers exiting the site would drive north of Uplander Way and exit Uplander Way east onto Hannum Avenue/Buckingham Parkway, and then either drive west on Slauson Ave to State Route 90 or drive east on Slauson Avenue again. This would not result in noise level increases above the 5 dBA threshold any studied roadway segments in the Project vicinity. Therefore, impacts would be less than significant.

TABLE 21

ESTIMATE OF OFF-SITE CONSTRUCTION TRAFFIC NOISE LEVELS
Roadway Segment
Existing Land Uses
Located along
Roadway Segment
CNEL (dBA)
Existing
(2025)
(A)
Existing
(2025)
with Project
Construction
(B)
Project
Increment
(B–A)
Exceed
Threshold?
Bristol Parkway
between Hannum Ave and Uplander Wy Commercial 67.4 68.3 1.0 No between Slauson Ave and Hannum Ave Commercial 66.5 67.6 1.2 No between Uplander Way and Green Valley Cir Commercial 67.7 68.6 0.9 No Buckingham Parkway
s/o Hannum Ave Commercial/Residential 64.5 66.2 1.8 No
Hannum Avenue
between Uplander Wy and Buckingham Pkwy Commercial 68.0 68.9 0.9 No Slauson Avenue
Between Bristol Pkwy and Buckingham Pkwy Commercial 76.9 77.0 0.2 No Buckingham Pkwy and Shenandoah Ave Commercial 77.0 77.2 0.2 No Corning Ave and La Cienga Blvd (SB) Commercial 76.7 76.8 0.1 No Hannum Ave and Bristol Pkwy Commercial/Marina
Freeway

76.6 76.8 0.2 No
La Cienga Blvd (SB) and LA Cienga Blvd (NB) Residential 76.0 76.2 0.2 No Shenandoah Ave and Corning Ave Residential 76.5 76.7 0.2 No e/o La Cienga Blvd Commercial/Residential 75.5 75.8 0.3 No Uplander Way
e/o Bristol Parkway Commercial 58.3 63.1 4.8 No
s/o Hannum Avenue Commercial 58.4 63.1 4.8 No
SOURCE: ESA 2025. Appendix I of this document.

Operational Noise
In this section, the Project’s various on -site operational noise sources are first evaluated and analyzed individually, and subsequently the composite impact of all on-site operational noise sources is reviewed.

I I
I I
I I

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As explained below in more detail, none of the individual noise sources nor the combined impact of all of the sources exceed the applicable noise threshold.

Fixed Mechanical Equipment
The Project would include new mechanical equipment (e.g., air ventilation equipment), which would be located at the roof level. Mechanical equipment such as air conditioning equipment and emergency generators may generate audible noise levels. However, the equipment would be located within enclosed mechanical rooms, which would shield the noise at off-site noise sensitive uses so as to avoid land use noise conflicts with adjacent uses and minimize audible increases in exterior noise levels at off-site noise sensitive uses. Table 22, Mechanical Equipment Noise Levels at Noise Sensitive Receptors, presents the estimated Project on-site mechanical equipment noise levels at the off-site receptor locations.

TABLE 22

MECHANICAL EQUIPMENT NOISE LEVELS AT NOISE SENSITIVE RECEPTORS Receptor
Location
Existing
Ambient
Noise
Levels,a
dBA (Leq)
Estimated Noise from
Project Mechanical
Equipment,b,c
(Exterior/Interior with
windows open/Interior with
windows closed) dBA (Leq)
Ambient + Project Noise
Levels (Exterior/Interior
with windows
open/Interior with
windows closed),
dBA (Leq)
Significance
Thresholdd
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 57.2 56.9 / 43.9 / 31.9 60.1 / 47.1 / 35.1 62.2 0.0 No R2 64.6 38.4 / 25.4 / 13.4 64.6 / 51.6 / 39.6 69.4 0.0 No R3 56.2 42.9 56.4 61.2 0.0 No
R4 57.8 53.4 / 40.4 / 28.4 59.1 / 46.1 / 34.1 62.8 0.0 No R5 64.6 50.9 / 37.9 / 25.9 64.8 / 51.8 / 39.8 69.6 0.0 No NOTES:
a. The ambient noise level is based on the measured daytime noise levels shown in Table 4.8-4, is used for the purposes of impact determination. b. Exterior reference noise levels for air condenser units, fans, and related equipment, the primary sources of noise from fixed mechanical equipment, would be 81.9 dBA Leq measured at a distance of 5 feet (based on noise data from large shopping center projects in Southern California). Refer to: City of Moreno Valley, Moreno Valley Walmart Noise Impact Analysis, Table 9-1, Page 71, February 10, 2015; and City of Pomona, Pomona Ranch Plaza Walmart Expansion Project, Table 4.4-5, Pg. 4.4-33, August 2014. Assumes mechanical equipment noise generated by the closest Project building to each sensitive receptor. c. Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
d. Significance thresholds are equivalent to the measured daytime ambient noise levels, plus 5 dBA.

SOURCE: ESA 2025.

As shown i n Table 2 2, the estimated noise levels from the mechanical equipment would be below the existing ambient noise levels. As such, the estimated noise levels at all off-site receptor locations would be below the significance threshold of 5 dBA (Leq) above ambient noise levels. As such, the Project would not result in the generation of a substantial permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established by the City . As such, impacts from mechanical equipment noise would be less than significant and within the scope of the Certified PEIR.

Parking Structure Noise
Cars accessing and parking within the Project would occur along Uplander Way, Hannum Way, and Bristol Parkway. Based on the traffic data provided to ESA, the afternoon peak hour traffic volume at the three project driveways would result in a total of 425 vehicle trips. To provide a worse-case conservative analysis, it was assumed all 425 vehicles entered the parking structure along Uplander Way during peak hour traffic

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-119 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

conditions. FTA’s Transit Noise and Vibration Impact Assessment Manual was used to calculate noise generated by parking lot traffic. The entering vehicles would create noise levels up to 53 dBA.59 Sources of noise within the below-grade parking structure would primarily include vehicular movements, engine noise and vehicle door opening and closing. Noise generated within the parking structure would be effectively shielded from off -site sensitive receptor locations given that the parking structure is primarily subterranean and is fully enclosed on all sides and oriented in the center of the Project’s buildings at the ground floor level. However, for purposes of this analysis, peak hour trips from the Project are assumed to occur at the closest parking garage driveway to each sensitive receptor. Table 23, On-Site Parking Noise Levels at Noise Sensitive Receptors, presents the Project’s estimated noise levels from the parking garage at the off -site receptor locations. As indicated in Table 2 3, the estimated noise levels from the Project’s parking garage would be well below existing ambient noise levels and the significance threshold of 5 dBA (L
eq) above ambient noise levels. As such, the Project would not result in the generation of a substantial permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established by the City. Thus, impacts from parking facilities would be less than significant and would be within the scope of the impacts analyzed in the Certified PEIR.

TABLE 23

ON-SITE PARKING NOISE LEVELS AT NOISE SENSITIVE RECEPTORS Receptor
Location
Existing
Ambient
Noise
Levels,a
dBA (Leq)
Estimated Noise from
Project Parking,
(Exterior/Interior with
windows open/Interior
with windows closed)b
dBA (Leq)
Ambient + Project
Noise Levels
(Exterior/Interior with
windows open/Interior
with windows closed)
dBA (Leq)
Significance
Thresholdc
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 57.2 49.2 / 36.2 / 24.2 57.8 / 45.8 / 33.8 62.2 0.0 No R2 64.6 33.6 / 20.6 / 8.6 64.6 / 51.6 / 39.6 69.6 0.0 No R3 56.2 38.4 56.3 61.2 0.0 No
R4 57.8 47.6 / 34.6 / 22.6 58.2 / 45.2 / 33.2 62.8 0.0 No R5 64.6 43.1 / 30.1 / 18.1 64.6 / 51.6 / 39.6 69.6 0.0 No NOTES:
a. The ambient noise level is based on the measured daytime and morning noise levels shown in Table 17 and is used for the purposes of impact determination.
b. Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
c. Significance thresholds are equivalent to the measured daytime ambient noise levels, plus 5 dBA.

SOURCE: ESA 2025.

Loading Areas and Refuse Collection
Based on a noise survey that was conducted at a loading area and trash collection facilities by ESA, loading area activity (namely idling semi -trucks and backup alarm beeps) and trash compactors could generate noise levels of approximately 70 dBA Leq and 66 dBA Leq, respectively, at a reference distance of 50 feet.60

59 FTA, Transit Noise and Vibration Impact Assessment. September, 2018, Tables 4-13 and 4-14. 60 The loading dock facility noise measurements were conducted at a loading dock facility at a Wal-Mart store using the Larson-Davis 820 Precision Integrated Sound Level Meter (“SLM”) in May 2003. The Larson-Davis 820 SLM is a Type 1 standard instrument as defined in the American National Standard Institute S1.4. All instruments were calibrated and operated according to the applicable manufacturer specification. The microphone was placed at a height of approximately 5 feet above the local grade.

3. Comparative Analysis of Project Impacts
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CEQA Guidelines Sections 15168(c) Clearance October 2025

Delivery truck idling is restricted to no more than five consecutive minutes in the loading area pursuant to State regulation ( Title 13 CCR, Section 2485) . Pursuant to CCR Title 13, Section 2485, signs would be posted in delivery loading areas specifying this idling restriction. Based on the engine idling limitation of five minutes, the reference noise level of an hourly average noise level would be 59.2 dBA L eq at 50 feet.

As shown in Table 2 4, Loading Areas and Refuse Collection Noise Levels, loading activity and trash compaction associated with the Project would be below the significance thresholds of each sensitive receptor identified. The noise levels from the Project’s loading and refuse collection areas would be approximately 55.1 dBA L
eq or lower at the surrounding sensitive receptors. The noise levels from the Project’s loading and refuse collection areas would not exceed by 5 dBA over the ambient noise levels captured at sensitive receptors in the Project vicinity . Thus, impacts would be less than significant and within the scope of the impacts analyzed in the Certified PEIR.

TABLE 24

LOADING AREAS AND REFUSE COLLECTION NOISE LEVELS
Receptor
Location
Existing
Ambient
Noise
Levels,a
dBA (Leq)
Estimated Noise from
Project Parking,
(Exterior/Interior with
windows open/Interior with
windows closed)b
dBA (Leq)
Ambient + Project Noise
Levels (Exterior/Interior
with windows
open/Interior with
windows closed)
dBA (Leq)
Significance
Thresholdc
Exceedance
over
Significance
Threshold
Significant
Impact?
R1 57.2 55.1 / 42.1 / 30.1 59.3 / 46.3 / 34.3 62.2 0.0 No R2 64.6 39.7 / 26.7 / 14.7 64.6 / 51.6 / 39.6 69.6 0.0 No R3 56.2 39.6 56.3 61.2 0.0 No
R4 57.8 48.3 / 35.3 / 23.3 58.3 / 45.3 / 33.3 62.8 0.0 No R5 64.6 49.7 / 36.7 / 24.7 64.7 / 51.7 / 39.7 69.6 0.0 No NOTES:
a. The ambient noise level is based on the measured daytime noise levels shown in Table 17. b. Noise levels account for an exterior-to-interior noise attenuation rate of 13 dBA for buildings with windows open and 25 dBA for buildings with windows closed.
c. Significance thresholds are equivalent to the measured daytime ambient noise levels, plus 5 dBA.

SOURCE: ESA 2025.

Operational Outdoor Open Space Noise
Outdoor common spaces for residents would include lounge seating, gathering spaces, and small speakers installed in discreet areas to be used for low volume ambient sound and music, to be developed in accordance with NOI-PDF-5 (see NOI -PDF-5 in Table 3 for additional details) . Occasional events for residents only would be held throughout the year within the courtyard or roof deck as an amenity for the residents. As for noise from the residents themselves, in accordance with recent case law, 61 typical noise
from residents is not a significant impact under CEQA.62 Composite Noise Level Impacts from Project Operations
An evaluation of composite noise levels, including all Project -related noise sources plus existing ambient noise levels, was conducted to identify the potential maximum Project-related noise level increase that may occur at the noise -sensitive receptor locations. The overall sound environment at the sensitive receptors surrounding the Project Site would include contributions from each on-site and off -site individual noise

61 Make UC A Good Neighbor et al. v. Regents of the University of California (2024) 16 Cal. 5th 43, 57. 62 PRC § 21085.

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CEQA Guidelines Sections 15168(c) Clearance October 2025

source associated with maximum daily operation of the Project. As discussed above, principal on-site noise sources associated with the Project would include mech anical equipment, traffic, and parking and loading facilities. Table 2 5, Composite Noise Impacts, presents the estimated noise from Project -related noise sources in terms of CNEL. For informational purposes only, operational noise levels at nearby commercial land uses represented by R5 from the Project’s mechanical equipment, parking structure, and loading/refuse collections areas are presented. As indicated in Table 25, the Project would not result in an increase of 5.0 dBA CNEL at any receptor. Therefore, the Project would not result in the generation of a substantial permanent increase in ambient noise levels at any receptor in excess of standards established by the City.

Thus, the Project’s operational composite noise would be less than significant and within the scope of the impacts analyzed in the Certified PEIR.

Off-Site Operational Traffic Noise
Impacts Under Existing Traffic Baseline Conditions
Existing roadway noise levels were calculated along various roadway segments near the Project Site.

Roadway noise attributable to Project development was calculated using the traffic noise model previously described and was compared to baseline noise levels that would occur under the “No Project” condition.

Project impacts are shown in Table 26, Off-Site Traffic Noise Impacts – Existing Plus Project Conditions, with supporting calculation files provided in Appendix I of this document . As indicated therein, the maximum increase in Project-related traffic noise levels over existing traffic noise levels would be 3.5 dBA CNEL, which would occur along Uplander Way south of Hannum Avenue . This increase in noise level would be below a “clearly noticeable” increase of 5 dBA CNEL. The increase in sound level would be lower at the remaining roadway segments analyzed. Therefore, Project-related noise increases would be less than the applicable threshold and therefore less than significant and within the scope of the impacts analyzed in the Certified PEIR.

Impacts Under Future plus Project Conditions Traffic Noise Future off -site traffic-generated noise impacts were assessed based on a comparison of the future base traffic volumes with the Project to the future year (2031 ) base traffic volumes without the Project. The results of that comparison are provided in Table 2 7, Off-Site Traffic Noise Impacts – Future Plus Project Conditions. Table 2 7 shows the Project’s contribution to the cumulative noise levels. The maximum cumulative noise increase from the Project plus related Project traffic would be 2.0 dBA CNEL, which would occur along Uplander Way south of Hannum Avenue. This increase in sound level would not exceed the significance thresholds of an increase of 5 dBA CNEL. As a result, future off-site traffic-related noise impacts would be less than significant and within the scope of the impacts analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts
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CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 25

COMPOSITE NOISE IMPACTS
Receptor
Location
Estimated Composite Noise, (Exterior / Interior with
windows open/Interior with windows closed) dBA (Leq)
Project Composite Noise
Levels, (Exterior /Interior
with windows open/
Interior with windows
closed) (dBA (Leq)
Ambient
Noise
Levels,a
dBA (Leq)
Ambient Plus
Project
Composite
Noise Levels,
dBA (Leq)
Maximum
Increase in
Noise Levels
Due to Project,
dBA (Leq)
Significance
Threshold
Significant
Impact? Mechanical Parking Loading Area
R1 56.9 / 43.9 / 31.9 49.2 / 36.2 / 24.2 55.1 / 42.1 / 30.1 59.5 / 46.5 / 34.5 57.2 61.5 / 57.6 / 57.2 4.3 62.2 No R2 38.4 / 25.4 / 13.4 33.6 / 20.6 / 8.6 39.7 / 26.7 / 14.7 42.7 / 29.7 / 17.8 64.6 64.6 / 64.6 / 64.6 0.0 69.6 No R3b 42.9 38.4 39.6 45.5 56.2 56.6 0.4 61.2 No
R4 50.9 / 37.9 / 25.9 47.6 / 34.6 / 22.6 48.3 / 35.3 / 23.3 55.4 / 42.4 / 30.4 57.8 59.8 / 58.3 / 58.2 2.0 62.8 No R5 50.9 / 37.9 / 25.9 43.1 / 30.1 / 18.1 49.7 / 36.7 / 24.7 53.7 / 40.7 / 28.7 64.6 64.9 / 64.6 / 64.6 0.3 69.6 No NOTES:
a. The ambient noise level is based on the measured daytime noise levels shown in Table 17, and the lower value (daytime or morning) is used for the purposes of impact determination. b. Receptor R3 is an outdoor sensitive receptor and therefore, there is no interior noise reduction.

SOURCE: ESA, 2025.

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5757 Uplander Project 3-123 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 26
OFFSITE TRAFFIC NOISE IMPACTS – EXISTING PLUS PROJECT CONDITIONS

CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Existing
Existing
+
Project Difference
Bristol Pkwy
between Hannum Ave and Uplander Way Commercial 67.4 67.5 0.1 between Slauson Ave and Hannum Ave Commercial 66.4 66.4 - between Uplander Way and Green Valley Cir Commercial 67.7 67.8 0.1 n/o Slauson Ave Cemetery 55.4 55.4 -
s/o Green Valley Cir Residential/Hotel/Cemetery 66.7 66.8 0.1 Buckingham Pkwy
between Slauson Ave and Hannum Ave Residential/Commercial/ Open Space 61.8 62.5 0.7 n/o Slauson Ave Commercial 60.2 60.2 -
s/o Hannum Ave Residential/Commercial 64.5 64.5 -
Corning Ave
n/o Slauson Ave Residential 62.0 62.0 -
s/o Slauson Ave Residential 64.3 64.3 -
Fox Hills Dr
s/o Hannum Ave Commercial 65.4 65.4 -
Green Valley Cir
e/o Bristol Pkwy Residential/Commercial 66.8 66.9 0.1
w/o Bristol Pkwy Commercial/Hotel 67.7 67.7 -
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.3 68.6 0.3 between Fox Hills Dr and Bristol Pkwy Commercial 68.5 68.8 0.3 between Slauson Ave and Hannum Avenue Commercial 66.8 67.2 0.4 between Uplander Wy and Buckingham Pkwy Commercial 68.0 68.3 0.3 n/o Slauson Ave Residential/Commercial 70.1 70.2 0.1
La Cienga Boulevard (NB)
n/o Slauson Avenue Residential 67.9 67.9 -
s/o Slauson Avenue Residential 68.1 68.0 -0.1
La Cienga Boulevard (SB)
n/o Slauson Avenue Residential 70.6 70.7 0.1
s/o Slauson Avenue Residential 63.7 63.7 -
Shenandoah Avenue
n/o Slauson Avenue Residential 61.9 61.9 -
s/o Slauson Avenue Residential 63.6 63.6 -

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5757 Uplander Project 3-124 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 26
OFFSITE TRAFFIC NOISE IMPACTS – EXISTING PLUS PROJECT CONDITIONS

CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Existing
Existing
+
Project Difference
Slauson Avenue
Between Bristol Pkwy and Buckingham Pkwy Commercial 76.9 76.9 - Buckingham Pkwy and Shenandoah Ave Commercial 77.0 77.1 0.1 Corning Ave and La Cienga Blvd (SB) Commercial 76.7 76.7 - Hannum Ave and Bristol Pkwy Commercial 76.6 76.6 -
La Cienga Blvd (SB) and LA Cienga Blvd (NB) Residential 76.0 76.0 - Shenandoah Ave and Corning Ave Residential 76.5 76.5 - e/o La Cienga Blvd Commercial/Residential 75.5 75.6 0.1 w/o Hannum Ave Commercial/ Marina Freeway 70.5 70.5 -
Uplander Way
e/o Bristol Pkwy Commercial 58.3 59.6 1.3
n/o Hannum Ave Commercial 57.7 57.7 -
s/o Hannum Ave Commercial 58.4 61.9 3.5
NOTE: e/o: east of; w/o: west of; n/o: north of; s/o: south of a. Calculated based on existing traffic volumes.

SOURCE: ESA, 2025.

TABLE 27
OFFSITE TRAFFIC NOISE IMPACTS – FUTURE PLUS PROJECT CONDITIONS

CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Future
Future +
Project Difference
Bristol Pkwy
between Hannum Ave and Uplander Way Commercial 67.9 68.1 0.2 between Slauson Ave and Hannum Ave Commercial 66.6 66.7 0.1 between Uplander Way and Green Valley Cir Commercial 68.1 68.3 0.2 n/o Slauson Ave Cemetery 55.4 55.4 -
s/o Green Valley Cir Residential/Hotel/Cemetery 67.0 67.1 0.1 Buckingham Pkwy
between Slauson Ave and Hannum Ave Residential/Commercial/ Open Space 64.1 64.8 0.7 n/o Slauson Ave Commercial 60.2 60.2 -
s/o Hannum Ave Residential/Commercial 64.7 64.8 0.1
Corning Ave
n/o Slauson Ave Residential 62.1 62.1 -
s/o Slauson Ave Residential 64.3 64.3 -
Fox Hills Dr
s/o Hannum Ave Commercial 65.5 65.5 -

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-125 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 27
OFFSITE TRAFFIC NOISE IMPACTS – FUTURE PLUS PROJECT CONDITIONS

CNEL (dBA) at Referenced
Distances from Roadwaya
Roadway Segment Adjacent Land Use Future
Future +
Project Difference
Green Valley Cir
e/o Bristol Pkwy Residential/Commercial 67.1 67.1 -
w/o Bristol Pkwy Commercial/Hotel 67.8 67.8 -
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.8 69.0 0.2 between Fox Hills Dr and Bristol Pkwy Commercial 69.0 69.2 0.2 between Slauson Ave and Hannum Avenue Commercial 67.4 67.7 0.3 between Uplander Wy and Buckingham Pkwy Commercial 68.7 69.0 0.3 n/o Slauson Ave Residential/Commercial 70.5 70.6 0.1
La Cienga Boulevard (NB)
n/o Slauson Avenue Residential 68.0 68.0 -
s/o Slauson Avenue Residential 68.2 68.1 -0.1
La Cienga Boulevard (SB)
n/o Slauson Avenue Residential 70.8 70.9 0.1
s/o Slauson Avenue Residential 63.9 64.5 0.6
Shenandoah Avenue
n/o Slauson Avenue Residential 62.1 62.1 -
s/o Slauson Avenue Residential 63.7 63.7 -
Slauson Avenue
Between Bristol Pkwy and Buckingham Pkwy Commercial 77.1 77.1 - Buckingham Pkwy and Shenandoah Ave Commercial 77.4 77.4 - Corning Ave and La Cienga Blvd (SB) Commercial 77.0 77.1 0.1 Hannum Ave and Bristol Pkwy Commercial 76.8 76.9 0.1
La Cienga Blvd (SB) and LA Cienga Blvd (NB) Residential 76.1 76.2 0.1 Shenandoah Ave and Corning Ave Residential 76.8 76.9 0.1 e/o La Cienga Blvd Commercial/Residential 75.6 75.7 0.1 w/o Hannum Ave Commercial/ Marina Freeway 70.5 70.6 0.1 Uplander Way
e/o Bristol Pkwy Commercial 61.3 62.0 0.7
n/o Hannum Ave Commercial 57.7 57.7 -
s/o Hannum Ave Commercial 61.5 63.5 2.0
NOTE: e/o: east of; w/o: west of; n/o: north of; s/o: south of a. Calculated based on existing traffic volumes
SOURCE: ESA, 2025.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-126 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Certified PEIR’s Mitigation Measures Addressing Impact
The following mitigation measure is set forth in the Certified PEIR and the associated MMP to address noise impacts under Threshold a) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM NOI-1 is also applicable to the Project.

PEIR MM NOI-1: Construction Noise. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) shall submit a noise study to the City Planning Department for review and approval prior to issuance of a grading or building permit. The study shall include noise -reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards as applicable to construction (i.e., CCMC Chapter 9.07). All noise -reduction measures approved by City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during construction activities.

Potential noise -reduction measures may include, but are not limited to, one or more of the following, as applicable to the project:
• Install temporary sound barriers for construction activities that occur adjacent to occupied noise-sensitive receptors.
• Equip construction equipment with effective mufflers, sound-insulating hoods or enclosures, vibration dampers, and other Best Available Control Technology (BACT). • Limit non-essential idling of construction equipment to no more than five minutes per hour.

This mitigation measure shall not apply and is superseded once a Citywide noise ordinance goes into effect that establishes construction noise standards for noise -reduction measures that ensures project construction noise compliance with the Culver City Noise Ordinance standards for development projects within the City.

Mitigation Measure PEIR MM NOI-1 is applicable to the Project, and in connection therewith a noise study was conducted for the Project and, as discussed below, project -specific noise-reduction measures will be implemented. As of the time this document was prepared, there has not been a Citywide noise ordinance that has superseded PEIR MM NOI-1.

Project-Specific Mitigation Measures Addressing Impact
The Project specific noise analysis conducted per Mitigation Measure PEIR MM NOI-1 has resulted in the below Project-specific mitigation measures.

Project MM-NOI-1: Temporary noise barriers shall be installed along portions of the southern, western, and eastern Project boundary, as specified below, to shield the identified sensitive receptors from construction noise. The barrier along the eastern Project boundary shall only be required if the proposed residence at receptor R4 has a valid Certificate of Occupancy (CoO) issued by the City and is occupied, and demolition and ground disturbance activities of the Project is still ongoing and shall be required to have a minimum height of 15 feet. The barriers along the southern and western Project boundaries shall have a minimum height of eight feet. The noise barrier shall consist of material such as plywood or other solid material capable of reducing on-site construction noise levels by 17 to 19 dBA. Sound blankets or other similar sound absorbing material may be attached to the barrier to achieve the required noise level reduction. Access points or gates shall be permissible to allow for adequate and safe worker, vehicle, and equipment access to the

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CEQA Guidelines Sections 15168(c) Clearance October 2025

construction area. The temporary construction noise barriers shall remain in -place during demolition and ground disturbance activities until equipment are solely used within the excavated pit or during exterior vertical building construction, when the use of on-site noise-generating heavy- duty construction equipment occurs at or within eight feet of ground level. The required placement of the noise barrier is based on which parcel(s) is undergoing construction as follows and as shown in Figure 23, Proposed Noise Barrier Mitigation Scenarios, below:
• Construction of Parcel 1 – The southern boundary of Parcel 1 and western boundary of Parcel 2 that are shared between the Project Site and the fire station shall have an eight -foot barrier installed.
• Overlapping Construction of Parcel 1 & 2 –The southern boundary of Parcel 1, western boundary of Parcel 2, and northern boundary of Parcel 3 shared between the Project Site and the fire station shall have an eight -foot barrier installed. The barrier shall extend further south along the western boundary on Parcel 3 to the southwest corner of the Project Site, ensuring that the medical office is also protected from noise. If the proposed residence at receptor R4 has a valid CoO issued by the City and is occupied, the entire length of Parcel 2 on the eastern project boundary shall have a 15-foot barrier installed. • Construction of Parcel 2 –The western boundary of Parcel 2, and northern boundary of Parcel 3 shared between the Project Site and the fire station shall have an eight -foot barrier installed.

The barrier shall extend further south along the western boundary of Parcel 3 to the southwest corner of the Project Site, ensuring that the medical office is also protected from noise. If the proposed residence at receptor R4 has a valid CoO issued by the City and is occupied, the entire length of Parcel 2 on the eastern project boundary shall have a 15-foot barrier installed. • Overlapping Construction of Parcel 2 & 3 – The western boundary of Parcel 2 and northern boundary of Parcel 3 that are shared between the Project Site and the fire station shall have a n eight-foot barrier installed. The barrier shall extend further south along the western boundary of Parcel 3 to the southwest corner of the Project Site, ensuring that the medical office is also protected from noise. An eight-foot barrier shall be installed along the full southern Project Site boundary of Parcel 3. If the proposed residence at receptor R4 has a valid CoO issued by the City and is occupied, the entire length of Parcel 2 and 3 on the eastern project boundary shall have a 15-foot barrier installed.
• Construction of Parcel 3 – The western boundary of Parcel 3 and northern boundaries that are shared between the Project Site and fire station shall have an eight -foot barrier installed. The barrier shall extend further south along the western boundary of Parcel 3 to the southwest corner of the Project boundary, ensuring that the medical office is also protected from noise. An eight- foot barrier shall be installed along the full southern Project Site boundary. If the proposed residence at receptor R4 has a valid CoO issued by the City and is occupied, the entire length of Parcel 3 on the eastern project boundary shall have a 15-foot barrier installed.

Project MM -NOI-2: Since construction equipment operates intermittently and the types of equipment change with the stage of construction, noise emitted during construction would be mobile and highly variable. The following features shall be implemented during Project construction to reduce noise levels:
• Maintain all construction tools and equipment in good operating order according to manufacturers’ specifications.
• To the extent practicable, schedule construction activity during normal working hours between 8 a.m. and 5 p.m. on weekdays when higher sound levels are typically present and are found acceptable.

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• Equip internal combustion engines with properly operating mufflers that are free from rust, holes, and leaks.
• For construction equipment that utilize s internal combustion engines, ensure the engine’s housing doors are kept closed, and mount noise-insulating material on the engine housing consistent with manufacturers’ guidelines, if possible. b) Would the Project result in generation of excessive groundborne vibration or groundborne noise levels?
Impact Determination in the Certified PEIR
As indicated above, the locations of future projects and construction methods for the future projects are not known at this time. However, it is assumed that some of the activities will take place in close proximity to sensitive receptors given that the Ci ty is generally built out. With regard to structural damage and human annoyance during construction, activities could generate excessive ground vibration and potentially exceed damage criteria for surrounding existing structures. In addition, multiple piec es of equipment or other sources of groundborne vibration and/or groundborne noise could cause levels to exceed the threshold.

Therefore, future development projects that will occur under the General Plan 2045 and Zoning Code Update could result in a significant impact. Implementation of Mitigation Measure PEIR MM NOI -2 will reduce the severity of impacts related to excessive groundborne vibration or groundborne noise during construction. However, even with implementation of Mitigation Measure PEIR MM NOI -2, vibration impacts during construction could exceed the significance thresholds, and therefore construction vibration impacts are significant and unavoidable.

During operation, future projects could generate groundborne vibration and groundborne noise from vehicle and truck traffic on roadways and from stationary mechanical equipment such as pumps and compressors.

However, groundborne vibration from traffic and the operation of mechanical equipment is not expected to generate excessive vibration or noise. Therefore, impacts during operation relative to groundborne vibration and groundborne are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to groundborne vibration, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
Structural Damage
Consistent with Mitigation Measure PEIR MM NOI-3 (see below), a project-specific construction vibration analysis was conducted to determine if the Project has the potential to generate significant vibration impacts that could cause structural damage. Vibration data is included in Appendix I of this document.

SOURCE : ESA, 2025
Project Site
• Noise Monitoring Locations
- Noise Barrier
- Eastern Noise Barrier (If needed, should R4 be operational) NOTE: For all scenarios, barriers not to the
east must be 8 feet tall. Eastern barrier
must be a minimum of 15 feet tall.
200
Feet
5757 Uplander Project
Figure 23
Proposed Noise Barrier Mitigation Scenarios

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3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-131 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Construction
Construction activities can generate varying degrees of groundborne vibration, depending on the construction procedures and the construction equipment used. The operation of construction equipment generates vibrations that spread through the ground and diminish in amplitude with distance from the source. The effect on buildings located in the vicinity of the construction site varies depending on soil type, ground strata, and construction characteristics of the receptor buildings. The results from vibration can range from imperceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibration from construction activities rarely reaches levels that damage structures. The Caltrans guidance manual incorporates FTA standard vibration velocities for construction equipment operations (Table 18 of the Caltrans guidance manual). The PPV vibration velocities for the types of construction equipment that can generate perceptible vibration levels and that would be used for the Project are listed in Table 28, Vibration Source Levels for Construction Equipment.

TABLE 28

VIBRATION SOURCE LEVELS FOR CONSTRUCTION EQUIPMENT
Equipment
Approximate PPV (in/sec) Approximate RMS (VdB)
10 Feet
25 Feet
50 Feet
60 Feet
75 Feet
100
Feet
10 Feet
25 Feet
50 Feet
60 Feet
75 Feet
100
Feet
Large Bulldozer 0.352 0.089 0.031 0.024 0.017 0.011 95 87 78 76 73 69 Loaded Trucks 0.300 0.076 0.027 0.020 0.015 0.010 94 86 77 75 72 68 Wheel Loader 0.300 0.076 0.027 0.020 0.015 0.010 94 86 77 75 72 68 Fork Lift 0.186 0.047 0.016 0.013 0.009 0.006 89 81 72 70 67 63 Jackhammer 0.138 0.035 0.012 0.009 0.007 0.004 87 79 70 68 65 61 Earth Mover 0.043 0.011 0.004 0.003 0.002 0.001 77 69 60 58 55 51 Small Bulldozer 0.0119 0.003 0.001 0.0008 0.0006 0.0004 66 58 49 47 44 40 SOURCE: FTA, Transit Noise and Vibration Impact Assessment, September 2018; ESA, 2025.

Because vibration level in root mean square (RMS) is best for characterizing human response to building vibration, and vibration level in peak particle velocity (PPV) is best used to characterize potential for damage, this construction vibration impact analysis assessed the potential for building damage using vibration levels in PPV (in/sec). Potential human annoyance is assessed in the next subsection using vibration levels in VdB.

Because vibration impacts occur normally at or within buildings, the distance to the nearest sensitive uses for vibration impact analysis purposes is measured between the nearest off-site sensitive use buildings and the Project construction equipment area near the Project boundary. As shown in Table 28, large bulldozers generate approximately 0.089 in/sec PPV when measured at 25 feet. The FTA guidelines indicate that a vibration level of 0.5 inch/sec PPV is considered safe for buildings consisting of reinforced concrete, steel, or timber (no plaster), and would not result in any construction vibration damage. For a non-engineered timber and masonry building, the construction vibration damage criterion is 0.2 inch/sec PPV. The stricter

0.2 inch/sec PPV threshold will be used for this analysis. 63 63 Federal Transit Administration, Noise and Vibration Manual, 2018, Page 218,

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-132 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Based on the vibration data provided in Table 28 , vibration velocities from construction equipment would range from approximately 0.003 to 0.089 inches per second PPV at 25 feet from the source of activity. The nearest off-site buildings to the Project Site that could be subjected to Project-related vibration structural damage include the fire station building to the west (50 feet) and commercial/office buildings which are planned to be redeveloped into residential in the future to the east (75 feet) as measured from the Project Site boundary. Pile driving would not be used at the Project Site boundary and other vibration-generating equipment would normally operate at least 50 feet or more from the nearest off-site buildings. Thus, based on the vibration data provided in Table 28, the nearest off-site buildings would not be exposed to vibration levels that would cause structural damage, and impacts would be less than significant.

Operation
The Project’s operations would include typical commercial -grade stationary mechanical and electrical equipment, such as air handling units, condenser units, and exhaust fans, which could produce vibration. In addition, the primary sources of transient vibration would include passenger vehicle circulation within the proposed parking area. Groundborne vibration generated by each of the above -mentioned activities would generate approximately up to 0.005 in/sec PPV adjacent to the Project Site. 64 Thus, the potential vibration levels from all Project operational sources at the closest existing sensitive receptor locations would be less than the significance threshold of 0.2 in/sec PPV for potential residential building damage. As such, vibration impacts associated with operation of the Project would be below the significance threshold and impacts would be less than significant and within the scope of the impacts analyzed in the Certified PEIR.

Human Annoyance
Construction
The CEQA Thresholds Guide identifies residences, schools, motels and hotels, libraries, religious institutions, hospitals, nursing homes, and parks as sensitive uses. Off-site non-residential uses such as retail and commercial uses are not considered vibration sensitive receptors for human annoyance under CEQA.

Groundborne noise specifically refers to the rumbling noise emanating from the motion of building room surfaces due to vibration of floors and walls and is perceptible only inside buildings. 65 For typical buildings,
groundborne vibration results in groundborne noise levels approximately 25 to 40 decibels lower than the velocity level. 66 According the FTA Noise and Vibration Manual , most of the studies of groundborne vibration in this country have focused on urban rail transit and the problems with groundborne vibration and noise that are common when there is less than 50 feet between a subway structure and building foundations. Any vibrations created by Project construction would be intermittent and temporary and thus would not create any on-going and continuous groundborne vibration and noise similar to that of an urban rail transit system. As such, groundborne noise impacts would be less than significant.

Nearby vibration-sensitive uses for potential human annoyance in the Project vicinity include the future residences approximately 75 feet away to the east of the Project Site, where the current US Veterans Affairs Department office is located, with other residential structures at greater distances. At a distance of 75 feet or more, the maximum vibration level would be attenuated by 14 VdB to 73 VdB or less.

64 This vibration estimate is based on data presented in the USDOT Federal Transit Administration, 2018; which is included in Appendix I of this document.
65 Federal Transit Administration, Noise and Vibration Manual, 2018, Page 112, 66 Federal Transit Administration, Noise and Vibration Manual, 2018, Page 119.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-133 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Nearby vibration-sensitive uses for potential human annoyance in the Project vicinity include the medical building and fire station approximately 50 feet to southwest and west of the Project Site, with other vibration sensitive structures at greater distances. At a distance of 50 feet or more, the maximum vibration level would be attenuated by 9 VdB to 78 VdB or less.

The Project would generate occasional transient vibrations from period construction and not generate continuous vibrations. Thus, Project construction would not exceed the FTA’s 78 VdB threshold for occasional events at the nearest noise-sensitive receiver locations (Category 3: institutional land uses with primarily daytime uses) during daytime hours. In addition, construction vibration-generation activities would not occur during the nighttime hours when people normally sleep. Compliance with Chapter 9.07 of the CCMC would eliminate the potential for groundborne vibration and groundborne noise human annoyance impacts at the nearby residential uses during sensitive nighttime hours. Therefore, the Project would not exceed the FTA’s 75 VdB threshold for occasional events at residential receivers (Category 2:
residences and building where people normally sleep). Impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

Operation
Post-construction on-site activities would be limited to residential uses, commercial retail uses, and associated mechanical equipment such as HVAC units, none of which would be anticipated to generate excessive groundborne noise or vibration. Project operational vibration levels would be substantially less than during construction. As such, groundborne vibration and noise impact to human annoyance associated with the lo ng-term operation of P roject would be less than significant and within the scope of impa cts analyzed in the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The following mitigation measure is set forth in the Certified PEIR and the associated MMP to address vibration impacts under Threshold b) and is applicable to the General Plan 2045 and Zoning Code Update Project. Mitigation Measure PEIR MM NOI-2 is also applicable to the Project.

PEIR MM NOI-2: Construction Vibration. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non -exempt projects) and that are located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) shall submit a vibration impact evaluation to the City Planning Department for review and approval prior to issuance of a grading or building permit. The evaluation shall include a list of project construction equipment and the associated vibration levels and a predictive analysis of potential project vibration impacts. If construction -related vibration is determined to exceed applicable standards, project-specific measures shall be required to ensure project compliance with vibration standards. All project-specific measures approved by the City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, gr ading plans and building plans) and implemented during project construction. Examples of equipment vibration source-to-receptor distances at which impact evaluation should occur vary with equipment type (based on FTA reference vibration information) and are as follows:
• Jackhammer: 23 feet.
• Dozer, hoe-ram, drill rig, front-end loader, tractor, or backhoe: 43 feet.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-134 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

• Roller (for site ground compaction or paving): 75 feet. • Impact pile-driving: 280 feet.

This mitigation measure shall not apply and is superseded once a Citywide groundborne vibration ordinance goes into effect that establishes construction groundborne vibration standards for vibration-reduction measures that ensures project construction grou ndborne vibration compliance with applicable standards for development projects within the City Planning Area.

Mitigation Measure PEIR MM NOI-2 is applicable to the Project and in connection therewith a noise study was conducted for the Project and, as discussed below, project -specific noise-reduction measures will be implemented. As of the time this document was prepared, there has not been a Citywide noise ordinance that has superseded PEIR MM NOI-2.

Project-Specific Mitigation Measures Addressing Impact
No mitigation measures are required as impacts would be less than significant. c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Impact Determination in the Certified PEIR
Impacts related to airport land use plans were evaluated in the Initial Study prepared as part of the Certified PEIR, and it was determined that no impacts would occur since there are no airport land use plans or public airports within the Planning Area.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to airport land use plans, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project Site is not located within an airport land use plan area or within two miles of a public airport or public use airport. The Project Site is not located within the vicinity of a private airstrip, or heliport or helistop. Airport and airfields in proximity to the Project Site include Santa Monica Airport, approximately

4.2 miles to the northwest, and Los Angeles International Airport , approximately 2.4 miles to the south/southwest. Therefore, the Project would not expose people to excessive noise levels from such uses and no impact would occur, consistent with the impact findings of the Certified PEIR.

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-135 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Conclusion
Based on the above, the Project’s potential environmental impacts with regard to noise would be within the scope of the Certified PEIR and would not result in any of the conditions set forth in PRC Section 21166(c) or CEQA Guidelines Sections 15162 or 15163 that would require the preparation of a Supplemental or Subsequent EIR.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-136 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

3.13 Population and Housing
Thresholds (and Supporting Information Sources):

Impact
Determination
in the
Certified PEIR
Does the
Project Involve
New Significant
Impacts or
Substantially
More Severe
Impacts?
Impact
Determination
for the Project
Certified
PEIR’s
Mitigation
Measures
Addressing
Impact
Population and Housing: Would the project:
(a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less than
Significant No Less than
Significant N/A
(b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing
elsewhere?
Less than
Significant No No Impact N/A

a) Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Impact Determination in the Certified PEIR
The Certified PEIR determined that the projected growth that would occur as a result of the General Plan 2045 and Zoning Code Update both in housing and employment is considered planned growth. The Project will accommodate the 6th cycle Regional Housing Needs Assessment (RHNA) allocation of 3,341 new units as well as future cycles through 2045. The General Plan 2045 is intended to accommodate planned regional growth requirements for the next 25 years with the densities allowed for various land uses and with the provision of infrastructure and public services to accommodate such growth. New residential opportunities will be a result of targeted residential and mixed-use development in activity centers and along commercial corridors to provide housing near jobs, neighborhood amenities, and health care facilities. This type of infill development focuses on redevelopment and revitalization of areas already served by infrastructure and will not require extensions of roads or other infrastructure. While an increase in employment opportunities within the City is expected during the 2045 planning horizon, the General Plan 2045 will ensure that housing needs, including future housing needs for the projected increase in employment, will be met. Therefore, the General Plan 2045 and Zoning Code Update will not induce substantial unplanned population growth, either directly or indirectly, and impacts are less than significant.

Does the Project involve new significant impacts or substantially more severe impacts?
As discussed below, the Project would not create any new significant impacts related to unplanned population growth, nor would it result in a substantial increase in a previously identified significant impact as analyzed in the Certified PEIR.

Impact Determination for Project
The Project would involve demolition of the existing office buildings on the Project Site to support a mixed- use development with residential and retail uses. As shown in Table 29, Projected Increases in Population,

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-137 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Housing, and Employment , the Project would increase the residential population of Culver City by introducing 1,077 residential units that would generate an estimated population of 2,693 residents at the Project Site.67 In addition, the Project would include approximately 5,772 sf of retail space, which would generate an estimated increase of approximately 21 employees on the Project Site. 68 When taking into account the demolition of 146,414 sf of existing office uses on the Project Site and associated estimated employment based on the Employment Generation Factor identified in the Culver City Unified School District 2022 Developer Fee Justification Study, the Project would result in a net decrease of 679 employees, as shown in Table 29.

TABLE 29

PROJECTED INCREASES IN POPULATION, HOUSING, AND EMPLOYMENT Housing Units and Population
Use Amount Average Household Sizea Total Population
Residential 1,077 units 2.5 2,693
Existing Employees
Use Amount
Employment Generation Factor
(per 1,000 square feet)b,c
Existing Number of
Employees
Office 146,414 square feet 4.78 700
Total Existing Employees 700
Projected Employees
Use Amount
Employment Generation Factor
(per 1,000 square feet)b,d Number of Employees
Retail 5,772 square feet 3.62 21
Total Projected Employees 21
Net Employees -679
NOTES:
a. The Certified PEIR assumed 2.5 persons/household for new development in population projections. b. Culver City Unified School District, Developer Fee Justification Study, March 2020, page 12. c. Commercial Office Category employee generation factor, Table 4 of Developer Fee Justification Study. d. Neighborhood Shopping Center Category employee generation factor, Table 4 of Developer Fee Justification Study.

SOURCE: ESA, 2025.

As shown in Table 30, General Plan 2045 Population, Household, and Job Growth Projections , it is predicted that by 2045 the existing population in Culver City would increase from 40,800 to 62,400, the existing housing units would increase from 17,000 to 28,310, and the existing jobs would increase from 68,040 to 84,300.

67 As described in Table 29, the total population is estimated based on the number of units multiplied by the average household size for Culver City based on new development projections used in the Certified PEIR. 68 As described in Table 29, the number of employees is based on the square footages by land use multiplied by employment generation factors provided by LAUSD’s Developer Fee Justification Study.

3. Comparative Analysis of Project Impacts
5757 Uplander Project 3-138 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

TABLE 30
GENERAL PLAN 2045 POPULATION, HOUSEHOLD, AND JOB GROWTH PROJECTIONS Existing
General Plan 2045
Projections
Net Change (General
Plan 2045 – Existing)
Population 40,800 (2020) 62,400 21,600
Households 17,000 (2019) 28,310 11,310
Jobs 68,040 (2019) 84,300 16,260
SOURCE: City of Culver City General Plan 2045 and Zoning Code Update Project PEIR, March 2024

The population, housing, and employment projections assumed for the General Plan 2045 are higher than SCAG’s Connect Socal 2020-2045 and 2024-2 050 estimates since the General Plan 2045 provides for additional population, housing, and employment capacity not anticipated by SCAG. However, since SCAG projections are based on the General Plan land uses, future SCAG planning documents would be updated to reflect the General Plan 2045 projections.

The Project’s 1,077 units would comprise approximately 9 .5 percent of the General Plan 2045 projected housing increase for the City from 2019 to 2045. Compared to existing uses, the Project would result in a decrease of 679 employees, approximately -4.1 percent of General Plan 2045 projected employment increase for the City from 2019 to 2045. The Project’s increases in population and housing would be within the General Plan 2045 projections for the City. The Project would support and not conflict with relevant goals, objectives, and policies in the General Plan 2045 . While the Project would result in an overall decrease of jobs, the Project would provide high-quality infill housing through the provision of 1,077 residential units with a diverse mix of dwelling types, containing both market-rate and 78 Very Low Income units, which will accommodate a range of household sizes. These characteristics of the Project would support Land Use and Housing objectives and policies for increasing housing supply and affordable housing in the City and promoting access to affordable housing through the use of Stat e and local incentives. The Project’s residential and commercial uses would promote the General Plan’s policy for mixed-use development that would be sensitive to adjacent residential uses.

The Project would link with and tie into existing infrastructure in the Project area. As described below under Section 3.18, Utilities and Service Systems, new infrastructure for public service and utility systems that would be required, such as service connections to local water and sewer network , and electricity and natural gas utilities would be sized to serve only the Project’s needs. Project operation would modify access from streets that surround the Project Site as described. However, these modificat ions represent improvements that would not induce substantial population growth indirectly through the extension of roads or other infrastructure into undeveloped areas. The Project would not have indirect effects on growth through such mechanisms as the extension of roads and infrastructure, since the Project would represent infill development and would utilize the existing transportation and utility infrastructure to serve the Project.

Based on the analysis above, the Project would not induce substantial population growth in the area, either directly or indirectly, that cannot be reasonably accommodated, and impacts would be less than significant and within the scope of impacts analyzed in the Certified PEIR.

3. Comparative Analysis of Project Impacts

5757 Uplander Project 3-139 City of Culver City
CEQA Guidelines Sections 15168(c) Clearance October 2025

Certified PEIR’s Mitigation Measures Addressing Impact
The Certified PEIR determined that no mitigation measures would be required. Since, as determined above, the Project does not involve new significant impacts or substantially more severe impacts, no new or additional mitigation measures are needed.
b) Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Impact Determination in the Certified PEIR
The Certified PEIR determined that the General Plan 2045 and Zoning Code will provide infill development opportunities in vacant and underutilized areas in the City, while seeking to preserve existing neighborhoods. The General Plan 2045 and Zoning Code Update will increase the overall number of dwelling units in the City as well as include policies that seek to ensure equity and protect diversity in the City’s communities. Therefore, the General Plan 2045 and Zoning Code Update will not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere, and impacts are less than significant.

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