Gardena City Council
January 14, 2025

5.0.1 REMOVE OBSTACLES TO POPULATION GROWTH OR REQUIRE THE

CONSTRUCTION OF NEW OR EXPANDED FACILITIES THAT COULD

CAUSE SIGNIFICANT ENVIRONMENTAL EFFECTS
The Project would not remove obstacles to population growth through the construction or extension of major infrastructure facilities. The Project site is developed and in an urban area bordered by existing residential uses and roadways. Therefore, the area is already served by existing utilities and service systems (i.e., water, wastewater, solid waste, natural gas, and electricity), which would provide services to the Project. While minor modifications to the existing utilities are required, major infrastructure already exists in the area. The utility improvements that are being implemented are distribution lines that would serve the proposed onsite land uses. The Project does not propose improvements that would extend services to areas that currently are not served or provide additional capacity in these infrastructure improvements, thereby facilitating new offsite development. There are no properties adjacent to the Project site that would benefit by having the utilities extended.

5.0.1 ENCOURAGE AND FACILITATE OTHER ACTIVITIES THAT COULD

SIGNIFICANTLY AFFECT THE ENVIRONMENT, EITHER INDIVIDUALLY

OR CUMULATIVELY
Project implementation is anticipated to have a beneficial economic effect. The introduction of new housing and residents to this Project site could encourage the creation of new businesses and services and provide a new customer base to help existing businesses. Section 4.1 through Section 4.16 of this EIR address the specific and potential cumulative Project impacts.

5.4 MANDATORY FINDINGS OF SIGNIFICANCE
CEQA requires preparation of an EIR when certain specified impacts may result from construction or implementation of a project. An EIR has been prepared for the Project, which fully addresses the Mandatory Findings of Significance, as described below.

5.0.1 DEGRADATION OF THE ENVIRONMENT AND POTENTIAL IMPACTS

ON HABITAT OR WILDLIFE SPECIES, AND CALIFORNIA HISTORY OR

PREHISTORY
Would the Project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Degradation of the Environment. State CEQA Guidelines §15065(a)(1) requires a finding of significance if a project “has the potential to substantially degrade the quality of the Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 5.0
Draft Environmental Impact Report Other CEQA Considerations

environment.” In practice, this is the same standard as a significant effect on the environment, which is defined in State CEQA Guidelines §15382 as “a substantial or potentially adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance.” As discussed throughout this EIR, the Project has the potential to degrade the environment’s quality/result in significant environmental impacts concerning construction noise that would not be reduced to less than significant, despite compliance with the established regulatory framework (i.e., local, state, and federal regulations), Project COA, and with mitigation incorporated. This EIR in its entirety addresses and discloses all known potential environmental effects associated with Project development, including direct, indirect, and cumulative impacts.

A summary of all potential environmental impacts, level of significance, and mitigation measures is provided in Section 1.0: Executive Summary.

Impacts on Habitat or Species. State CEQA Guidelines §15065(a)(1) states that “A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur: (1) The project has the potential to:
substantially degrade the quality of the environment; substantially reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or animal community; substantially reduce the number or restrict the range of an endangered, rare or threatened species; or eliminate important examples of the major periods of California history or prehistory.” Because the Project site is fully developed and devoid of any natural habitats, the Project would not have the potential to reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal. As such, the Initial Study prepared for the Project found that the Project would have no impact or a less than significant impact to biological resources.

Therefore, biological resources are not evaluated in this EIR.

Impacts on California History and Prehistory. Section 4.2: Cultural Resources analyzed the Project’s potential impacts to historic and prehistoric cultural resources. Analysis found no recorded historic resources on the Project site. Analysis found that the existing onsite structures are not historically significant resources pursuant to State CEQA Guidelines §15064.5. However, the archaeological assessment determined the Project site has a moderate sensitivity for containing historic period (non–Native American) archaeological resources, which could be discovered during construction. Although such a discovery is unlikely, any previously unidentified archaeological resources, if present, have the potential to be significant under CEQA.

Additionally, as determined in the Project’s preliminary geotechnical investigation, the Project site’s surface area consists of weakly consolidated alluvial sediments dating back to the late Pleistocene, which are of an age to preserve fossil resources and therefore the Project would also Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 5.0
Draft Environmental Impact Report Other CEQA Considerations

have high paleontological potential. As such, mitigation proposed within these sections, Section 4.2: Cultural Resources, Section 4.4: Geology, Soils, and Paleontological Resources, and Section 4.14: Tribal Cultural Resources, identifies the retention of a professional archaeologist (MM CUL-1), Native American tribal representative (MM TCR-1), and paleontologist (MM GEO-1) to monitor any ground disturbing activities. MM TCR-2 in Section 4.2: Cultural Resources identifies steps to be taken in the event of an inadvertent discovery of an archaeological resource.

MM TCR-3 in Section 4.2: Cultural Resources identifies steps to be taken in the event of an inadvertent discovery of human remains where the NAHC resource designates the Gabrieleno Band of Mission Indians-Kizh Nation the Most Likely Descendent (“MLD”). The mitigation presented in these sections further lowered the significance of the potential impacts to less than significant levels. Therefore, the Project would not eliminate important examples of the major periods of California history or prehistory.

5.0.1 SHORT-TERM VS. LONG-TERM GOALS
State CEQA Guidelines §15065(a)(2) states that “A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur: the project has the potential to achieve short-term environmental goals to the disadvantage of long-term environmental goals.” Section 5.2: Significant Irreversible Environmental Changes, of this document addresses the short-term and irretrievable commitment of natural resources to ensure that the consumption is justified on a long-term basis. As summarized in Section 5.2: Significant Irreversible Environmental Changes, Project implementation would result in the irretrievable commitment of limited, slowly renewable, and nonrenewable resources, which would limit the availability of these resource quantities for future generations or for other uses during the Project’s life. However, use of such resources would be on a relatively small scale in a regional context. Although irreversible environmental changes would result from Project implementation, such changes would not be considered significant. In addition, Section 1.0: Executive Summary identifies all significant and unavoidable impacts that could occur that would result in a short-term impact on the environment. There would be periodic, temporary, unavoidable significant noise impacts that would cease upon completion of construction activities. Lastly, Section 5.3: Growth-Inducing Impacts of the Proposed Action, identifies any long-term environmental impacts associated with economic and population growth that are associated with the Project. The Project would directly, but not indirectly, generate population growth in the City. However, the Project would not remove obstacles to population growth through the construction or extension of major infrastructure facilities.

5.0.1 CUMULATIVELY CONSIDERABLE IMPACTS
Would the Project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 5.0
Draft Environmental Impact Report Other CEQA Considerations

when viewed in connection with the effects of the past projects, the effects of other current projects, and the effects of probable future projects.) State CEQA Guidelines §15065(a)(3) states that “A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur: the project has potential environmental effects that are individually limited but cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” As discussed throughout this EIR, the Project the Project could have impacts that are individually limited, but cumulatively considerable. This EIR in its entirety addresses and discloses all known potential cumulative environmental impacts. Cumulative impacts are addressed in Section 4.1 through Section 4.16.

5.0.1 SUBSTANTIAL ADVERSE EFFECTS ON HUMAN BEINGS
Would the Project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
As required by State CEQA Guidelines §15065(a)(4), “A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur: the environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.” Under this standard, a change to the physical environment that might otherwise be minor must be treated as significant if people would be significantly affected. This standard relates to adverse changes to the environment of human beings generally, and not to effects on particular individuals. While changes to the environment that could directly or indirectly affect human beings would be possible in all of the CEQA issue areas identified in the Initial Study, those that could directly affect human beings are aesthetics, air quality, geology and soils, hazards and hazardous materials, hydrology and water quality, noise, land use and planning, public services and utilities, transportation, water resources, wildfire hazards, and climate change, all of which are addressed in the appropriate sections of this EIR and in the Initial Study; see Table of Contents for specific section numbers.

The following topic area was determined to be significant and unavoidable with respect to adverse effects on human beings:
 Construction Noise: Project construction activities would result in a temporary significant unavoidable construction-related noise impact due to the increase in ambient noise levels and given the extended construction period, building height, and construction-related noise levels exceeding the City’s standard by more than 10 dBA despite MM NOI-1 and MM NOI-2.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 5.0
Draft Environmental Impact Report Other CEQA Considerations

This page intentionally left blank.

Kimley>>>Horn

6.0 ALTERNATIVES TO THE

PROPOSED PROJECT

Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

6.0 ALTERNATIVES TO THE PROPOSED PROJECT
Under the California Environmental Quality Act (CEQA), the identification and analysis of alternatives to a project is a fundamental part of the environmental review process. Public Resources Code (PRC) §21002.1(a) establishes the need to address alternatives in an EIR by stating that in addition to determining a project’s significant environmental impacts and indicating potential means of mitigating or avoiding those impacts, “the purpose of an environmental impact report is ... to identify alternatives to the project.” Direction regarding project alternatives is further provided in State CEQA Guidelines §15126.6(a), as follows:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.

The State CEQA Guidelines emphasize that the selection of project alternatives be based primarily on the ability to reduce significant impacts relative to the proposed project, “even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.”1 The State CEQA Guidelines further direct that the range of alternatives be guided by a “rule of reason,” such that only those alternatives necessary to permit a reasoned choice are addressed.2
In selecting project alternatives for analysis, potential alternatives must pass a test of feasibility.

State CEQA Guidelines §15126.6(f)(1) states that:

Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site...

Beyond these factors, State CEQA Guidelines require the analysis of a “no project” alternative and an evaluation of alternative location(s) for the project, if feasible. Based on the alternatives analysis, an environmentally superior alternative is to be designated. “If the environmentally superior alternative is the no project alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” 3 In addition, State CEQA Guidelines 1 State CEQA Guidelines §15126.6(b).
2 State CEQA Guidelines §15126.6(f).
3 State CEQA Guidelines §15126.6(e)(2).

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

§15126.6(c) requires that an EIR identify any alternatives that were considered for analysis but rejected as infeasible and discuss the reasons for their rejection.

The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making. The range of potential alternatives to the proposed project shall also include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. An alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative need not be considered.

PROJECT SUMMARY
The Normandie Crossing Specific Plan Project site is in the County of Los Angeles, approximately 12 miles southwest of downtown Los Angeles, in the southeast portion of the City of Gardena (“City”), at 16829, 16835, and 16907 South Normandie Avenue. The approximately 5.25-acre Project site is comprised of four parcels (APN: 6106-030-011, 6106-030-015, 6106-030-016, 6106- 030-017) generally bound by West 169th and West 170th Streets on the north and south, and South Normandie Avenue and Brighton Way on the east and west.

The Project proposes a 403-dwelling unit (DU) multi-family residential development with two types of residential uses: an apartment building with 328 DU at the Project site’s northern portion; and 75 townhome-style units within nine buildings at the Project site’s southern portion and along the western site boundary. The Project also proposes offsite sidewalk and railroad improvements. The offsite sidewalk improvements are proposed along the south side of 169th Street, west of the Project site, between Brighton Way and the alley just west of Brighton Avenue.

The offsite track and other railroad improvements are proposed on South Normandie Avenue along the Project site’s eastern boundary, pursuant to California Public Utilities Commission (CPUC) standards and Union Pacific Railroad (UPRR) guidelines. To allow the proposed development, the Applicant is proposing the Normandie Crossing Specific Plan (NCSP) (SP #1-21), which would establish the site-specific zoning regulations and development standards for this area. The NCSP includes the statutorily required elements, including a land use plan, a circulation plan, a description of existing and proposed utilities and infrastructure, design guidelines, development standards, and administrative provisions. In addition to requiring a Specific Plan, the Project requires various other approvals, including the following: General Plan/General Plan Map Amendment (GPA #3-21), Zone Change and Zone Map Amendment (ZC #4-21), Zoning Text Amendment (ZTA #6-21), Normandie Crossing Specific Plan (NCSP) (SP #1-21), Site Plan Review (SPR #11-21), Vesting Tentative Tract Map (TTM #4-21), Development Agreement (DA #2-21), and CPUC General Order 88-B Permit). A full project description is provided in Section 2.0: Project Description.

PROJECT OBJECTIVES
The proposed Project objectives presented below are, as outlined, in Section 2.5: Goals and Objectives.

6.1 6.2
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

1. Diversify the City of Gardena’s existing housing options, by providing a range of housing types and sizes, to serve the region’s growing and evolving technology and creative sectors and aid in recruiting and retaining talent for local companies.

2. Support the expanding technology and creative sector with newly constructed, highquality housing opportunities, enabling local employees to live close to where they work.

3. Cluster urban residential development near technology firms, other large employment centers, and commercial corridors providing City residents with the opportunity to live, work, and shop with less reliance on automobiles.

4. Establish housing development that meets high standards of design and pursues environmental sustainability.

5. Redevelop a blighted site, increase tax revenues to the City, provide affordable housing to support the City’s Regional Housing Needs Assessment goals, and create a catalyst for future development in this part of Gardena.

PROJECT IMPACTS

6.3.1 PROJECT SIGNIFICANT AND UNAVOIDABLE IMPACTS
Per State CEQA Guidelines, only those impacts found significant and unavoidable are relevant in making the final determination of whether an alternative is environmentally superior or inferior to the proposed Project. As discussed throughout Section 4.0: Environmental Analysis, there would be a significant and unavoidable Project impact related to construction noise. There would be no other significant and unavoidable Project impacts.

6.3.2 IMPACTS THAT CAN BE MITIGATED BELOW A LEVEL OF SIGNIFICANCE Impacts associated with the following topics would be significant without incorporation of mitigation measures, but would be reduced to a less-than-significant level with incorporation of the mitigation measures identified in the EIR:

Cultural Resources – cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines §15065.5; disturb human remains.

Geology and Soils (Paleontological Resources) – directly or indirectly destroy a unique paleontological resource or site or unique geological feature.

Hazards and Hazardous Materials – create a significant hazard through reasonably foreseeable upset and accident conditions involving the release of hazardous materials.

Recreation – include recreational facilities which might have an adverse effect on the environment.

Tribal Cultural Resources – cause a substantial adverse change in the significance of a tribal cultural resource.

6.3 ■
■
■
■
■
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Utilities - result in the relocation or construction of new or expanded water, wastewater conveyance, stormwater drainage, electric power, and telecommunication facilities, the construction or relocation of which could cause significant environmental effects.

PROJECT ALTERNATIVES
The analysis presented below compares the potential environmental impacts associated with the following alternatives to impacts from the proposed Project:
“No Project/No Construction” Alternative;
“No Project/Existing Land Use Designation” Alternative; “Reduced Density” Alternative.

Throughout the following analysis, the alternatives’ impacts are analyzed for each environmental issue area, as examined in Sections 4.1: Air Quality through 4.16: Aesthetics. In this manner, each Alternative can be compared to the Project on an issue-by-issue basis. Table 6-3:

Comparison of Alternatives, included at the end of this Section, provides an overview of the alternatives analyzed and a comparison of each Alternative’s impacts in relation to the Project.

This Section also identifies alternatives that were considered by the lead agency but were rejected as infeasible. Section 6.6: Environmentally Superior Alternative, references the “environmentally superior” Alternative, as required by the State CEQA Guidelines.

6.4.1 “NO PROJECT” ALTERNATIVES
Under State CEQA Guidelines §15126.6(e), the specific Alternative of “no project” shall also be evaluated along with its impact. The purpose of describing and analyzing a no project alternative is to allow decision-makers to compare the impacts of approving the proposed Project with the impacts of not approving the proposed Project. The “no project” analysis is required to discuss the existing conditions (at the time the Notice of Preparation is published), as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

The discussion of the no project alternative usually proceeds along one of two lines. If the project is not a land use or regulatory plan, for example a development project on identifiable property, the “no project” alternative is the circumstance under which the project does not proceed. Here, the discussion would compare the environmental effects of the property remaining in its existing state against environmental effects which would occur if the project were approved. If disapproval of the project under consideration would result in predictable actions by others, such as the proposal of some other project, this “no project” consequence should be discussed. In certain instances, the no project alternative means “no build” wherein the existing environmental setting is maintained. However, where failure to proceed with the project would not result in preservation of existing environmental conditions, the analysis should identify the practical result of the project’s non-approval and not create and analyze a set of artificial assumptions that would be required to preserve the existing physical environment. ■

6.4 ■
■
■
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Therefore, two “no project” alternatives are analyzed below: the circumstance under which the Project does not proceed and the Project site remains in its existing state (the “No Project/No Construction” Alternative); and the circumstance under which the Project does not proceed, but the Project site is developed, based on current plans (i.e., Gardena General Plan (GGP) and Gardena Municipal Code Zoning Ordinance (GMC)) and consistent with available infrastructure and community services (what would reasonably be expected to occur in the foreseeable future, if the Project were not approved) (the “No Project/Existing Land Use Designation” Alternative).

6.4.2 “NO PROJECT/NO CONSTRUCTION” ALTERNATIVE

DESCRIPTION OF ALTERNATIVE
The Project site is within a fully urbanized area and is generally surrounded by single- and multifamily residential uses. As depicted in Exhibit 2-2: Local Vicinity Map, the Project site is fully developed with six industrial buildings, asphalt surface parking lots, hardscapes, and minimal landscaping. Approximately 115,424 square feet (SF) of industrial floor area is present on the Project site. One of the buildings on Parcel 4 contains approximately 9,324 SF of industrial floor area that is in a dilapidated condition and is not occupiable, therefore, only 106,100 SF of industrial uses are currently operational. Additionally, the Project site includes a railroad spur from the adjacent UPRR northern track. The spur is associated with former onsite industrial operations but is no longer in use. Table 2-1: Existing Onsite Land Uses, summarizes the land uses that are present within the Project site and surrounding area.

The No Project/No Construction Alternative would retain the Project site in its current condition.

With this Alternative, the Project site’s existing improvements would remain and the approximately 106,100 SF of industrial uses would continue to operate. None of the proposed Project improvements would be implemented. Further, the Project’s requested entitlement (i.e., General Plan/General Plan Map Amendment (GPA #3-21), Zone Change and Zone Map Amendment (ZC #4-21), Zoning Text Amendment (ZTA #6-21), Normandie Crossing Specific Plan (NCSP) (SP #1-21), Site Plan Review (SPR #11-21), Vesting Tentative Tract Map (TTM #4-21), Development Agreement (DA #2-21), and CPUC General Order 88-B Permit) would not be granted. The following discussion evaluates the potential environmental impacts associated with the No Project/No Construction Alternative, as compared to impacts from the proposed Project.

IMPACT COMPARISON TO THE PROPOSED PROJECT
Air Quality
The Project’s short-term air quality impacts from demolition, grading, and construction activities would be less than significant. Under the No Project/No Construction Alternative because there would be no development, and no construction-related air pollutant emissions would be generated. This Alternative would also not expose sensitive receptors to substantial pollutant concentrations, which is concluded to be less than significant for the Project through compliance with the established regulatory framework.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

The Project’s operational emissions would not exceed significance thresholds, thus would be less than significant. Similar to the proposed Project, with continuation of existing uses, there would be no emissions that would violate any air quality standard or contribute substantially to an existing or projected air quality violation or result in a cumulatively considerable net increase of any criteria pollutant for which the region is in nonattainment. As with the proposed Project, operational impacts would be less than significant under this Alternative.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding air quality, because although the Project would not exceed short- or long-term air emissions thresholds, the existing conditions (this Alternative) would generate less criteria pollutants than the proposed Project.

Cultural Resources
The Project would result in no impact to historical resources and less than significant impacts to potentially discovered archaeological resources, with mitigation incorporated. Under this Alternative, these potential Project impacts would be avoided, as no ground disturbing activities would occur. This Alternative would also avoid the Project’s potential for disturbing human remains, which is concluded to be less than significant through compliance with the established regulatory framework and with mitigation incorporated.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding cultural resources. Under this Alternative, there would be no potential for impacting resources since no ground disturbing activities would occur.

Energy
The Project would result in construction-related energy consumption from water, diesel fuel, and gasoline usage; see Table 4.3-5: Project and Countywide Energy Consumption. However, the Project would result in less than significant impacts concerning construction-related energy usage since wasteful, inefficient, or unnecessary consumption of energy resources would not occur following compliance with Title 24 requirements. Under the No Project/No Construction Alternative, construction-related energy consumption would not occur because no development would occur. Therefore, the No Project/No Construction Alternative would have no impact concerning energy demand, whereas the Project would result in a less than significant impact.

The Project’s operational energy consumption would occur from building energy use, water use, and transportation-related fuel use. The Project would be subject to compliance with applicable energy standards. Therefore, Project operations would not result in wasteful, inefficient, or unnecessary consumption of energy resources, resulting in a less than significant impact concerning energy. Further, the Project would not conflict with/obstruct a State or local plan for renewable energy or energy efficiency. Under the No Project/No Construction Alternative, no change in existing operational electricity, natural gas, gasoline, or diesel fuel consumption would occur, as would occur with the proposed Project. Although this Alternative would generate less electric power demand than the Project (see Table 4.15-8: Estimated Project Electric Power Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Demand), the existing use consists of industrial buildings initially constructed between 1952 and 1976, which are not operating under the latest CALGreen standards as would the Project. For this reason, and since the Project would not generate a natural gas demand, this Alternative is assumed to result in inefficient energy consumption.

The No Project/No Construction Alternative would result in greater impacts than the proposed Project regarding energy consumption because although no construction-related energy consumption would occur, this Alternative would not operate under the latest CALGreen standards, thus, is assumed to result in inefficient energy consumption and would continue to consume natural gas, whereas the Project would not consume any.

Geology, Soils, and Paleontological Resources
Project construction-related impacts (i.e., ground disturbing activities) on paleontological resources are concluded to be less than significant, with mitigation incorporated. Since the No Project/No Construction Alternative would not involve construction, this Alternative would avoid the Project’s potential for impacting unique paleontological resources. This Alternative would have no impact on paleontological resources, whereas the Project’s impacts would be less than significant with mitigation incorporated.

The No Project/No Construction Alternative would result in less impacts than the proposed Project regarding paleontological resources. There would be no potential for impacting resources since no ground disturbing activities would occur.

Greenhouse Gas Emissions
The Project would result in less than significant construction-related greenhouse gas (GHG) emissions and direct and indirect operational GHG emissions, as concluded in Section 4.5:

Greenhouse Gas Emissions. Direct operational emissions include GHG emissions from operational vehicular traffic, onsite combustion of natural gas, and landscaping equipment.

Indirect operational emissions include GHG emissions from offsite generation of electrical power and the energy required to convey water to and wastewater from the Project site. Under the No Project/No Construction Alternative, there would be no construction activities or new development, thus there would be no short-term GHG emissions nor long-term direct and indirect operational GHG emissions. This Alternative would not generate additional GHG emissions, whereas the Project’s GHG emissions would be less than significant.

The Project’s construction emissions and increase in operational GHG emissions would not occur under the No Project/No Construction Alternative. Therefore, the No Project/No Construction Alternative would result in less impact than the proposed Project regarding GHG emissions.

Hazards and Hazardous Materials
The proposed Project would require demolition of onsite buildings which could expose construction workers to concentrations exceeding federal and state thresholds. Additionally, Project construction activities could create a significant hazard to the public or the environment Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Implementation of COA HAZ-1 and COA HAZ-2, and MM HAZ-1, would reduce impacts to less than significant. These impacts would be avoided with the No Project/No Construction Alternative since no construction would occur. This Alternative would result in no impact concerning construction activities, whereas the Project’s impact would be less than significant with mitigation incorporated.

The Project’s operational-related impacts concerning tetrachloroethene (PCE) concentrations that exceed Department of Toxic Substance Control (DTSC) screening levels for residential applications, which was considered less than significant with mitigation incorporated, would be avoided with this Alternative, as no residential uses would be developed. However, under this Alternative, existing operations which consist of the use, storage, and transportation of hazardous materials associated with industrial uses, would continue. As discussed in Section 4.6:

Hazards and Hazardous Materials, the existing industrial uses involved materials (e.g., paints and oils), which were found to be properly labeled and stored at the time of the assessment, and there were no signs of leaks, stains, or spills. Thus, the existing use was not considered a recognized environmental concern. This Alternative would result in less than significant operational impacts, as would the Project.

The No Project/No Construction Alternative would result in less impacts than the proposed Project regarding hazards and hazardous materials, since no construction or ground disturbing activities would occur, and no buildings or structures would be demolished.

Hydrology and Water Quality
The Project would result in less than significant short-term water quality impacts following compliance with National Pollutant Discharge Elimination System (NPDES) and GMC requirements. The No Project/No Construction Alternative would not result in short-term water quality impacts since no construction activities would occur. The Project’s less than significant short-term water quality impacts would be avoided with this Alternative.

Following compliance with NPDES and GMC requirements, which include implementation of water quality best management practices (BMPs), the Project’s operational activities would not violate any water quality standards or otherwise substantially degrade surface or groundwater quality. The last building permit on the Project site was issued in approximately 1987. Therefore, the No Project/No Construction Alternative would involve continued operations, which do not include water quality facilities compliant with current NPDES and GMC requirements. As such, this Alternative is assumed to result in potentially greater operational water quality impacts, than the Project.

The Project would not impede or redirect flood flows and would decrease the existing peak flow rates due to a decrease in impervious surface coverage. The Project would not result in substantial erosion, increase the rate or amount of surface runoff, or create runoff that would exceed the capacity of existing stormwater drainage systems. The No Project/No Construction Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Alternative’s long-term hydrology impacts would be greater than the proposed Project since the decrease in the existing peak flow rates that would occur with the proposed Project would not occur under this Alternative.

The Project’s potential construction-related impacts to groundwater would be less than significant with mitigation incorporated. The Project would decrease potential impacts to groundwater resources, as compared to existing conditions, through a decrease in impervious surfaces and increase in infiltration of stormwater runoff. As with the Project, this Alternative’s impacts concerning demand for groundwater supplies would be less than significant. Under the No Project/No Construction Alternative, less groundwater recharge would occur than with the Project due to the existing condition’s larger impervious surface area and lesser infiltration rate.

The No Project/No Construction Alternative would result in greater impacts regarding hydrology and water quality, since no increase in infiltration of stormwater runoff or decrease in impervious surfaces would occur.

Land Use and Planning
To accommodate the proposed apartment building and townhomes, the Project would remove the approximately 115,424 SF of industrial buildings. The Project would replace the Project site’s existing General Plan Industrial and Industrial, High Density 30 Overlay land use designations to Specific Plan, and Industrial (M-1), General Industrial (M-2), and Housing Overlay 4 (HO-4) zoning with Normandie Crossing Specific Plan (NCSP). To implement the Project, the Applicant would require several discretionary permits/approvals, including General Plan/General Plan Map Amendments, a Zone Change and Zone Map Amendment, Zoning Text Amendment, and Normandie Crossing Specific Plan (NCSP), among others; see Section 2.6: Agreements, Permits, and Approvals. The No Project/No Construction Alternative would retain the Project site in its current condition – none of the existing land uses would be removed and the apartment building and townhomes would not be constructed. The No Project/No Construction Alternative would not require any discretionary permits/approvals.

The No Project/No Construction Alternative would result in less impact than the proposed Project concerning land use and planning because it would avoid the Project’s proposed General Plan/General Plan Map Amendments, Zone Change and Zone Map Amendment, Zoning Code Text Amendment, and Normandie Crossing Specific Plan (NCSP), among others.

Noise
The Project’s construction-related noise impacts would be significant and unavoidable despite implementation of mitigation concerning construction equipment and requiring a temporary noise barrier. The Project’s construction-related vibration impacts would be less than significant with mitigation. Under the No Project/No Construction Alternative, no new land uses would be constructed. Therefore, this Alternative would avoid the Project’s construction-related noise and vibration impacts.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Table 4.9-11: Composite Noise Impacts identifies the existing ambient noise levels (Leq) and the Project’s composite noise levels. As shown in Table 4.9-11, the composite noise level, which accounts for onsite Project-related noise sources such as mechanical equipment, parking facility, and outdoor uses, would be below the significance thresholds, resulting in a less than significant impact. Noise associated with industrial uses is generally considered higher than residential uses.

Thus, under the No Project/No Construction Alternative, existing noise levels, which are likely higher than the proposed Project’s, would continue. See Section 4.9: Noise, for existing noise levels surrounding the Project site.

The Project would result in less than significant impacts from operational off-site traffic noise sources. Under this Alternative, mobile-source noise associated with trucks from the existing industrial uses, would continue. The No Project/No Construction Alternative could generate greater mobile source noise than the Project since this Alternative involves truck traffic.

The No Project/No Construction Alternative would result in less impacts than the proposed Project regarding noise. Although the Project’s increase in offsite roadway traffic noise would be negligible and the operational noise would be less than existing conditions, the Project’s construction-related noise impacts would be significant and unavoidable and would be avoided under the No Project/No Construction Alternative.

Population and Housing
The Project proposes 403 DUs. As indicated in Table 4.10-7: Existing Plus Project Growth Forecast, the Project is forecast to generate a population growth of approximately 1,088 persons.

The Project would induce unplanned population growth in the City directly through new housing, but the Project’s forecast population growth is not considered substantial. Under the No Project/No Construction Alternative, the Project site would remain in its present condition, - no housing would be developed, and no population growth would occur. Unlike the proposed Project, this Alternative would not induce unplanned population growth. Like the Project, this Alternative would not displace existing housing.

The 2021-2029 (6th Cycle) Housing Element Update (HEU) identified a total of 122 opportunity housing sites, which includes a portion of the Project site (Sites A and B). As shown in Table 4.10- 6: City of Gardena RHNA Allocation, the City’s RHNA allocation is 5,735 units. The Project would meet approximately 7 percent of the City’s 6th Cycle RHNA allocation, including providing 20 units of affordable housing. Thus, the Project would be in furtherance of meeting the City’s 6th Cycle RHNA allocation. Under this Alternative, no DUs would be constructed, thus, this Alternative would not be in furtherance of meeting the City’s RHNA allocation. However, Housing Elements include a housing buffer in the sites inventory to avoid violating the No Net Loss requirement.

The HEU sites inventory provides for a total (including ADUs) of 6,586 housing units, a 13 percent buffer above the City’s RHNA allocation. Therefore, given the 13 percent buffer in housing units included in the HEU, this Alternative’s exclusion of housing would not preclude the City from meeting their RHNA obligation.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

The No Project/No Construction Alternative would result in greater impacts than the proposed Project regarding housing and population because this Alternative would not be in furtherance of the City meeting its 6th Cycle RHNA allocation.

Public Services
The Project would generate an incremental increase in demand for fire and police protection, and library services. However, because the Project site is in a developed area where these services and equipment/infrastructure are already in place, the Project would not require construction of new or physically altered fire and police protection, or library facilities, resulting in a less than significant impact. The No Project/No Construction Alternative would retain the existing land uses, with no increase in population or demand for these services and facilities.

The Project is forecast to generate a student population growth of approximately 151 students at the Los Angeles Unified School District (LAUSD), which would incrementally increase the demand for school facilities and services. Although, insufficient capacity exists at the high school, with payment of school impact fees in accordance with Senate Bill (SB) 50, Project impacts would be fully mitigated and no physical impacts concerning school facilities would occur. The No Project/No Construction Alternative would retain the existing land uses, with no increase in student population or demand for school facilities.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding public services, since increases in demands for police, fire, medical, schools, and library services would not occur, although neither would require construction of new or physically altered facilities.

Recreation
The Project’s forecast population growth would incrementally increase the use of existing neighborhood and regional parks and/or other recreational facilities, but it would not be such that substantial physical deterioration of existing facilities would occur or be accelerated given the Project would provide onsite open space and recreational facilities. Because the No Project/No Construction Alternative does not involve residential uses, this Alternative would not increase the use of existing facilities.

Neither this Alternative nor the Project would result in adverse physical impacts associated with park facilities, since neither proposes to provide or physically alter a park facility. The Project does propose onsite open space and recreational amenities, which would result in a less than significant physical effect on the environment with mitigation incorporated. The environmental effects of the Project’s proposed open spaces and recreational amenities would be avoided with this Alternative, as no recreational uses would be developed.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding recreational facilities since increases in demand for recreational facilities and construction of new facilities would not occur under this Alternative.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Transportation
The proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The No Project/No Construction Alternative would retain the existing land uses and would also not conflict with a program, plan, ordinance, or policy addressing the circulation system.

The Project is located within a low vehicle miles traveled (VMT) generating area, one of the three screening criteria for VMT. Therefore, the Project would result in a less than significant impact concerning VMT. Under the No Project/No Construction Alternative, the existing industrial use would continue to operate and is assumed to involve fewer cars and light trucks, but more heavyduty trucks, than the Project. Because VMT refers to the amount and distance of automobile (cars and light trucks) travel and does not include heavy-duty truck travel, this Alternative is anticipated to generate less VMT than the Project, although the Project would result in a less than significant impact.

Project construction would require traffic lane, parking lane and/or sidewalk closures, but would not result in the complete closure of any public or private streets and would implement a Construction Traffic Management Plan (PDF TR-1), approved by the City, to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access. Temporary Project construction activities would not impede the use of road for emergencies or emergency response vehicles. Therefore, the Project would result in less than significant impacts concerning emergency access. The No Project/No Construction Alternative would not result in any construction activities; thus, emergency access would remain unchanged.

The No Project/No Construction Alternative would result in less impact than the Project regarding VMT. Under this Alternative, fewer VMT would be generated.

Tribal Cultural Resources
The Project would result in less than significant potential impacts to as yet undiscovered tribal cultural resources, with mitigation incorporated. Under this Alternative, these potential Project impacts would be avoided, as no ground disturbing activities would occur.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding tribal cultural resources. There would be no potential for impacting tribal cultural resources under this Alternative since no ground disturbing activities would occur.

Utilities and Service Systems
As shown in Table 4.15-7: Estimated Project Wastewater Generation, Table 4.15-8: Estimated Project Electric Power Demand, and Table 4.15-9: Estimated Project Water Demand, Project operations would increase wastewater generation, and electricity and water demand compared to the existing industrial land uses. However, the Project would decrease solid waste generation, Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

as industrial uses have higher solid waste generation rates than residential. 4 The Project would
require construction of new connections to nearby existing water, wastewater conveyance, stormwater, electric power, and telecommunication facilities. Notwithstanding, with mitigation incorporated, the Project would result in less than significant environmental effects associated with construction of these facilities. Under this Alternative, no utility and service system facilities would be constructed, therefore, the Project’s environmental effects associated with construction of proposed utilities and service systems would be avoided.

The No Project/No Construction Alternative would result in less impact than the proposed Project regarding utilities and service systems since the Project’s environmental effects associated with construction of utilities and service systems would be avoided.

Aesthetics
Under this Alternative, the site’s visual character/quality would not be altered, as the proposed apartment building and townhomes would not be developed, and the existing land use would not be removed. The existing landscape, including the blighted industrial buildings and associated onsite parking, would not be removed, or replaced with the proposed multi-family residential structures. A portion of one existing building is dilapidated, and the property is inadequately maintained and devoid of landscaping. Although the existing uses conform to the current land use, the subject property is surrounded by single- and multi-family residential development, and the property is an eyesore in the neighborhood. The lighting associated with the existing use would continue. Removal of the existing buildings and replacement with the multi-family residential structure that would occur with the Project, would not occur under this Alternative.

The Project’s generation of light and glare, which was concluded to be a less than significant impact, would not occur with this Alternative, but the existing industrial lighting would continue.

The No Project/No Construction Alternative would result in more impact than the proposed Project regarding aesthetics because the site’s existing light and glare would remain under this Alternative and the existing dilapidated structure and industrial uses would remain adjacent to residential uses.

ABILITY TO MEET PROJECT OBJECTIVES
The No Project/No Construction Alternative would not meet any of the Project objectives, as identified above.

6.4.3 “NO PROJECT/EXISTING LAND USE DESIGNATION” ALTERNATIVE

DESCRIPTION OF ALTERNATIVE
This Alternative consists of a “No Project” condition whereby the Project site is redeveloped pursuant to the existing General Plan land use designation. Table 2-2: Existing Land Use 4 California Department of Resources Recycling and Recovery (CalRecycle). (2019). Estimated Solid Waste Generation Rates. Retrieved from:
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates, accessed July 2023.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Designations and Zoning identifies the GGP land use designations for the Project site and indicates the Project site is designated Industrial, which provides for a wide range of industries, technology-related uses and supporting facilities, and business parks. Additionally, the GGP assigns a High Density 30 Overlay to the northern approximately 1.4 acres of the Project site.

Based on the existing Industrial land use designation, the Project site’s maximum development capacity is approximately 228,690 SF of industrial floor area; see Table 4.8-2: Existing General Plan Land Use Designations. It is noted, although the High Density 30 Overlay on the Project site’s northerly 1.4 acres would allow development of residential uses, only industrial uses would be allowed on the site’s southerly portion. Also, because no roadway or other buffer would exist between these two areas, this Alternative assumes no residential development on the Project site. Therefore, this Alternative assumes demolishing the existing 115,424 SF of industrial uses and in their place constructing up to 228,690 SF of industrial uses. Given that the Industrial land use designation is intended for a wide range of industrial uses, and since the Project site is surrounded by residential uses, this Alternative assumes development of an industrial business park, which could include any uses permitted within the Industrial zone; see GMC §18.36.020.

Because the proposed access driveways under this Alternative are unknown, it is unknown whether it, like the Project, would require offsite railroad improvements pursuant to California Public Utilities Commission (CPUC) standards and Union Pacific Railroad (UPRR) guidelines.

Table 6-1: Comparison Between Proposed Project and No Project/Existing Land Use Designation Alternative compares development under the Project and the No Project/Existing Land Use Designation Alternative.

Table 6-1: Comparison Between Proposed Project and No Project/Existing Land Use Designation Alternative
Description Apartment
Building (DU)1
Townhomes
(DU)1
Density
(DU/AC)1
Floor Area
(SF)1
Proposed Project 328 75 77 429,000
(Residential)
No Project/Existing Land Use
Designation Alternative
228,690
(Industrial)
Difference -328 -75 -200,310
% Difference -100% -100% -47%
Note:

1. DU = dwelling units; AC = acre; SF = square feet.

IMPACT COMPARISON TO THE PROPOSED PROJECT
Air Quality
The Project’s short-term air quality impacts from demolition, grading, and construction activities would be less than significant. The No Project/Existing Land Use Designation Alternative proposes approximately half as much floor area as the Project; thus, this analysis assumes this Alternative would result in less construction emissions as presented in Table 4.1-5: Construction Air Pollutant Emissions. Like the Project, this Alternative would not expose sensitive receptors to Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

substantial pollutant concentrations, which is concluded to be less than significant for the Project through compliance with the established regulatory framework.

As shown in Table 4.1-6: Operational Air Pollutant Emissions, the Project’s operational criteria pollutant emissions would be below the SCAQMD’s mass daily significance thresholds resulting in a less than significant air quality impact. As also shown in Table 4.1-6, the approximately 106,100 SF of existing industrial land uses also generate emissions well below the SCAQMD’s mass daily significance thresholds. This Alternative would involve approximately 228,690 SF of industrial land uses, or approximately double the industrial floor area (approximately 115 percent more) as under existing conditions. As such, it can be reasonably inferred that this Alternative’s operational criteria pollutant emissions would be approximately double the existing emissions shown in Table 4.1-6 but would still be below the SCAQMD’s mass daily significance threshold, and significantly less than the proposed Project’s operational criteria pollutant emissions. Thus, under the No Project/Existing Land Use Designation Alternative, there would be less emissions than with the Project. As with the proposed Project, this Alternative’s operational air quality emissions would be less than significant.

The No Project/Existing Land Use Designation Alternative would result in less impact than the proposed Project regarding air quality because although the Project would not exceed short- or long-term air emissions thresholds, this Alternative would generate less criteria pollutants than the proposed Project.

Cultural Resources
The Project would result in no impact to historical resources and less than significant impacts to as yet undiscovered archaeological resources, with mitigation incorporated. Also, the Project’s potential to disturb as yet undiscovered human remains is concluded to be less than significant through compliance with the established regulatory framework and with mitigation incorporated. The No Project/Alternative Land Use Designation Alternative would also involve demolition and ground disturbing construction activities; thus, similar impacts would occur, with mitigation incorporated under this Alternative.

The No Project/Existing Land Use Designation Alternative would result in similar impacts as the proposed Project regarding cultural resources. Under this Alternative, ground disturbing activities would occur within a similar footprint as the Project.

Energy
As shown in Table 4.3-5: Project and Countywide Energy Consumption, the Project would result in construction-related energy consumption from water, diesel fuel, and gasoline usage.

However, the Project would result in less than significant impacts concerning constructionrelated energy consumption since wasteful, inefficient, or unnecessary consumption of energy resources would not occur following compliance with Title 24 requirements. Under the No Project/Existing Land Use Designation Alternative, construction-related energy consumption would be less than the Project, given this Alternative proposes approximately half as much floor Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

area as the Project. However, both the Project and this Alternative would not result in wasteful, inefficient, or unnecessary consumption of energy resources during construction, resulting in a less than significant impact concerning energy.

The Project’s operational energy consumption would occur from building energy use, water use, and transportation-related fuel use; see Table 4.3-5. The Project would be subject to compliance with applicable energy standards; therefore, Project operations would not result in wasteful, inefficient, or unnecessary consumption of energy resources, resulting in a less than significant impact concerning energy. Further, the Project would not conflict with/obstruct a State or local plan for renewable energy or energy efficiency. Under the No Project/Existing Land Use Designation Alternative, operational energy consumption would be less than the Project, given this Alternative would involve approximately half as much floor area as the Project. As also shown in Table 4.3-5, the approximately 106,100 SF of existing industrial land uses consume a nominal amount of total energy consumption in the County. This Alternative would involve approximately 228,690 SF of industrial land uses, or approximately double the industrial floor area (approximately 115 percent more) as under existing conditions. As such, it can be reasonably inferred that this Alternative’s operational energy consumption would be approximately double the energy consumption shown in Table 4.3-5, but would still be nominal, and significantly less than the proposed Project’s operational energy consumption. The Project would not generate a natural gas demand and it is unknown whether this Alternative would do so. Notwithstanding, both the Project and this Alternative would operate under the latest CALGreen standards, and would not result in wasteful, inefficient, or unnecessary consumption of energy resources during operations, resulting in a less than significant impact concerning energy.

Geology, Soils, and Paleontological Resources
Project construction-related impacts (i.e., ground disturbing activities) on paleontological resources are concluded to be less than significant, with mitigation incorporated. Since the No Project/Existing Land Use Alternative would also involve demolition and ground disturbing construction activities, similar impacts would occur with mitigation incorporated.

The No Project/Existing Land Use Designation Alternative would result in similar impacts as the proposed Project regarding paleontological resources. Under this Alternative, ground disturbing activities would occur within a similar footprint as the Project.

Greenhouse Gas Emissions
The Project would result in less than significant construction-related GHG emissions and direct and indirect operational GHG emissions, as concluded in Section 4.5. Under the No Project/Existing Land Use Designation Alternative, less construction-related GHG emissions would occur than with the Project because this Alternative proposes approximately half the floor area.

As shown in Table 4.5-3: Summary of Operational GHG Emissions, the approximately 106,100 SF of existing industrial land uses would generate GHG emissions well below the proposed Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Project’s emissions. This Alternative would involve approximately 228,690 SF of industrial land uses, or approximately double the industrial floor area (approximately 115 percent more) as under existing conditions. As such, it can be reasonably inferred that this Alternative’s operational GHG emissions would be approximately double the existing GHG emissions shown in Table 4.5-3 but would still be approximately half of the Project’s operational GHG emissions.

Thus, under the No Project/Existing Land Use Designation Alternative, there would be approximately half the GHG emissions as the proposed Project. Like the proposed Project, this Alternatives operational GHG emissions would be less than significant.

Hazards and Hazardous Materials
The proposed Project would require demolition of onsite buildings which could expose construction workers to concentrations exceeding federal and state thresholds. Additionally, Project construction activities could 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. Implementation of COA HAZ-1 and COA HAZ-2, and MM HAZ-1, would reduce impacts to less than significant. The No Project/Existing Land Use Designation Alternative would also involve construction activities, thus this Alternative, like the Project, would result in a less than significant impact with mitigation incorporated.

The Project’s operational-related impacts concerning PCE concentrations that exceed DTSC screening levels for residential applications, which was considered less than significant with mitigation incorporated, would be avoided with this Alternative, as no residential uses would be developed. However, under this Alternative, it is unknown whether mitigation would be required for PCE concentrations that exceed DTSC screening levels for industrial business park applications. Project operations would involve the use of typical hazardous materials/chemicals associated with residential uses, whereas this Alternative could involve transport, handling, storage, and disposal of hazardous substances associated with industrial business park uses. As such, although operations under this Alternative must adhere to federal, state, and local regulations, an industrial use is considered to have greater potential for accidental upset or accident conditions concerning hazardous materials.

The No Project/Existing Land Use Designation Alternative would result in greater impacts than the Project regarding hazards and hazardous materials because it proposes an industrial business park use with greater potential for accidental upset or accident conditions concerning hazardous materials, as compared to the Project which proposes residential uses.

Hydrology and Water Quality
Like the Project, the No Project/Existing Land Use Designation Alternative construction activities would result in less than significant short-term water quality impacts following compliance with NPDES and GMC requirements. However, this Alternative’s impacts would be less than the Project’s since the Alternative proposes approximately half the floor area.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Following compliance with NPDES and GMC requirements, which include implementation of water quality BMPs, the Project’s operational activities would not violate any water quality standards or otherwise substantially degrade surface or groundwater quality. Similarly, the No Project/Existing Land Use Designation Alternative would result in less than significant operational water quality impacts following compliance with current NPDES and GMC requirements. As such, this Alternative is assumed to result in similar operational water quality impacts as the Project.

The Project would not impede or redirect flood flows and would decrease the existing peak flow rates due to a decrease in impervious surface coverage. The Project would not result in substantial erosion, increase the rate or amount of surface runoff, or create runoff that would exceed the capacity of existing stormwater drainage systems. This Alternative is also anticipated to decrease the site’s impervious surface coverage, although to a lesser degree than the Project given industrial business parks are not required to provide minimum open space areas, as are residential uses. Like the Project, this Alternative would not impede or redirect flood flows or modify peak flow rates, since a no net increase in flows would be expected. Also, similar to the Project, this Alternative would not result in substantial erosion, increase the rate or amount of surface runoff, or create runoff that would exceed the capacity of existing stormwater drainage systems.

The Project’s potential construction-related impacts to groundwater would be less than significant with mitigation incorporated. The Project would decrease potential impacts to groundwater resources through a decrease in impervious surfaces and increase in infiltration of stormwater runoff. As with the Project, this Alternative’s impacts concerning demand for groundwater supplies would be less than significant. The No Project/Existing Land Use Designation Alternative proposes approximately half as much floor area as the Project. Assuming more area devoted to the industrial business park and impervious surfaces, this Alternative would have more impervious surfaces compared to the Project, given industrial business parks are not required to provide minimum open space areas, and therefore less groundwater infiltration. Under the No Project/Existing Land Use Designation Alternative, less groundwater recharge would occur than with the Project.

The No Project/Existing Land Use Designation Alternative would result in greater impacts than the proposed Project regarding hydrology and water quality, since less infiltration of stormwater runoff or decrease in impervious surfaces would occur under this Alternative.

Land Use and Planning
To accommodate the proposed apartment building and townhomes, the Project would remove the approximately 115,424 SF of industrial buildings. The Project would replace the Project site’s existing General Plan Industrial and Industrial,High Density 30 Overlay land use designations with Specific Plan, and the Industrial (M-1), General Industrial (M-2), and Housing Overlay 4 (HO-4) zoning with Normandie Crossing Specific Plan (NCSP). To implement the Project, the Applicant would require several discretionary permits/approvals, including General Plan/General Plan Map Amendments, Zone Change and Zone Map Amendment, Zoning Text Amendment, and Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Normandie Crossing Specific Plan (NCSP), among others; see Section 2.6: Agreements, Permits and Approvals. The No Project/Existing Land Use Designation Alternative would not change the Project site’s existing land uses designations or zoning but would demolish the existing onsite land uses and construct 228,690 SF of industrial business park land uses. The No Project/Existing Land Use Designation Alternative would likely require fewer discretionary permits/approvals than the Project, depending on the proposed Site Plan.

The No Project/Existing Land Use Designation Alternative would result in less impact than the proposed Project concerning land use and planning because it would avoid the Project’s proposed General Plan/General Plan Map Amendments, Zone Change and Zone Map Amendment, Zoning Text Amendment, and Normandie Crossing Specific Plan (NCSP).

Noise
The Project’s construction-related noise impacts would be significant and unavoidable, despite implementation of mitigation concerning construction equipment and a temporary noise barrier, based on exceedance of noise standards, the proposed building height (seven stories), and extended construction period. The Project’s construction-related vibration impacts would be less than significant with mitigation. Although the No Project/Existing Land Use Designation Alternative’s construction activities would occur over a shorter time period and involve less building height and approximately half the floor area as the Project, this Alternative’s construction activities would take place within a similar footprint and distance from sensitive receptors, and thus are likely to exceed noise standards. Therefore, like the Project, this Alternative is anticipated to result in a significant and unavoidable construction noise impact.

As shown in Table 4.9-11, the Project’s composite stationary source noise level would be below the significance thresholds, resulting in a less than significant impact. Noise associated with industrial business park uses is generally considered higher than residential uses. Noiseproducing equipment typical of industrial business park uses includes rooftop mechanical ventilation units, truck deliveries, truck loading/unloading, trash compactors, forklifts, and generators. The cumulative noise level from industrial business park equipment would vary at the property line depending on the location and orientation of the equipment, the amount of each type of equipment, and the size of each type of equipment. Thus, under the No Project/Existing Land Use Alternative, the operational noise levels would likely be higher than the Project’s, although this Alternative would also be subject to compliance with the City’s noise standards.

The Project would result in less than significant impacts from mobile noise sources. This Alternative would also be anticipated to result in less than significant impacts from mobile noise sources, as it is not anticipated to double existing traffic levels. However, given this Alternative would involve an industrial business park, which would likely involve truck traffic, greater mobile source noise impacts could occur as this Alternative than the Project.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Like the Project, the No Project/Existing Land Use Designation Alternative would result in a significant unavoidable construction noise impact, therefore, this Alternative would result in similar impacts asthe proposed Project regarding construction noise and vibration. However, this Alternative would result in greater operational impacts than the proposed Project.

Population and Housing
The Project proposes 403 DUs. As indicated in Table 4.10‑7, the Project is forecast to generate a population growth of approximately 1,088 persons. The Project would induce unplanned population growth in the City directly through new housing, but the Project’s forecast population growth is not considered substantial. Under the No Project/Existing Land Use Designation Alternative, approximately 228,690 SF of industrial business park uses would be constructed, no housing would be developed, and no population growth would occur. Unlike the proposed Project, this Alternative would not induce unplanned population growth. Like the Project, this Alternative would not displace existing housing. Since the No Project/Existing Land Use Designation Alternative assumes development consistent with the GGP, as presented in Table 6- 1, it would not exceed the growth forecasts from the relevant planning documents. Therefore, as with the Project, this Alternative would result in less than significant impacts regarding unplanned population growth.

The 6th Cycle HEU identified a total of 122 opportunity housing sites, which includes a portion of the Project site (Sites A and B). As shown in Table 4.10-6, the City’s RHNA allocation is 5,735 units.

The Project would meet approximately 7 percent of the City’s 6th Cycle RHNA allocation, including providing 20 units of affordable housing. Thus, the Project would be in furtherance of meeting the City’s 6th Cycle RHNA allocation. Under this Alternative, no DUs would be constructed, thus, this Alternative would not be in furtherance of meeting the City’s RHNA allocation. However, Housing Elements include a housing buffer in the sites inventory to avoid violating the No Net Loss requirement. The HEU sites inventory provides for a total (including ADUs) of 6,586 housing units, a 13 percent buffer above the City’s RHNA allocation. Therefore, given the 13 percent buffer in housing units included in the HEU, this Alternative’s exclusion of housing would not preclude the City from meeting their RHNA obligation and the City would be able to make the findings required under Government Code §65863.

The No Project/Existing Land Use Designation Alternative would result in greater impacts than the proposed Project regarding population and housing because this Alternative would not be in furtherance of the City meeting its 6th Cycle RHNA allocation.

Public Services
The Project would generate an incremental increase in demand for fire and police protection, and library services. However, because the Project site is in a developed area where these services and equipment/infrastructure are already in place, the Project would not require construction of new or physically altered fire and police protection, or library facilities, resulting in a less than significant impact. Like the proposed Project, the No Project/Existing Land Use Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Designation Alternative would generate an incremental increase in demand for fire and police protection, but none for library services. However, because the Project site is in a developed area where these services and equipment/infrastructure are already in place, like the Project, this Alternative would not require construction of new or physically altered fire and police protection facilities, resulting in a less than significant impact.

The Project is forecast to generate a student population growth of approximately 151 students at the LAUSD, which would incrementally increase the demand for school facilities and services.

Although, insufficient capacity exists at the high school, with payment of school impact fees in accordance with Senate Bill (SB) 50, Project impacts would be fully mitigated and no physical impacts concerning school facilities would occur. The No Project/Existing Land Use Designation Alternative would involve an industrial business park, with no increase in student population or demand for school facilities.

The No Project/Existing Land Use Designation Alternative would result in similar impacts as the proposed Project regarding public services. Incremental increases in demands for public services would occur, but like the Project, this Alternative would not result in the need for construction of new or physically altered facilities.

Recreation
The Project’s forecast population growth would incrementally increase the use of existing neighborhood and regional parks and/or other recreational facilities, but it would not be such that substantial physical deterioration of existing facilities would occur or be accelerated given the Project would provide onsite open space and recreational facilities. Because the No Project/Existing Land Use Designation Alternative does not involve residential uses, this Alternative would not increase the use of existing facilities.

Neither this Alternative nor the Project would result in adverse physical impacts associated with park facilities, since neither proposes to provide or physically alter a park facility. The Project proposes onsite open space and recreational amenities, which would result in a less than significant physical effects on the environment with mitigation incorporated. The environmental effects of the Project’s proposed open spaces and recreational amenities would be avoided with this Alternative, as no recreational uses would be developed. The No Project/Existing Land Use Designation Alternative would result in less impact than the proposed Project regarding recreational facilitiessince increases in demand for recreational facilities and construction of new facilities would not occur under this Alternative.

Transportation
The proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The No Project/Existing Land Use Designation Alternative would be subject to compliance with the applicable programs, plans, ordinances, or policies, thus, is also not anticipated to result in a conflict in this regard.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

The Project is located within a low VMT generating area, one of the three screening criteria for VMT. Therefore, the Project would result in a less than significant impact concerning VMT. Under the No Project/Existing Land Use Designation Alternative, the industrial business park would operate on the Project site, which is assumed to involve fewer cars and light trucks, but more heavy-duty trucks, than the Project. Because VMT refers only to the amount and distance of automobile (cars and light trucks) travel and does not include heavy-duty truck travel, this Alternative is anticipated to generate less VMT than the Project, although the Project would result in a less than significant impact.

Project construction would require traffic lane, parking lane and/or sidewalk closures, but would not result in the complete closure of any public or private streets and would implement a Construction Traffic Management Plan (PDF TR-1), approved by the City, to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access. Temporary Project construction activities would not impede the use of road for emergencies or emergency response vehicles. Therefore, the Project would result in less than significant impacts concerning emergency access. Because the proposed access driveways under the No Project/Existing Land Use Designation Alternative are unknown, it is unknown whether it, like the Project, would require traffic lane, parking lane and/or sidewalk closures. It is also unknown whether UPRR improvements would be required under this Alternative. If this Alternative required the partial or full closure of streets or sidewalks, it would be required to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access.

Although the Project’s transportation impacts would be less than significant, the No Project/Existing Land Use Designation Alternative would result in less impact than the Project regarding VMT because under this Alternative, fewer VMT would be generated.

Tribal Resources
The Project would result in less than significant impacts to as yet undiscovered tribal cultural resources, with mitigation incorporated. The No Project/Alternative Land Use Designation Alternative would also involve demolition and ground disturbing construction activities; thus, similar impacts would occur, with mitigation incorporated.

The No Project/Existing Land Use Designation Alternative would result in similar impacts as the proposed Project regarding tribal cultural resources similar ground disturbing activities would occur within the same footprint as the Project.

Utilities and Service Systems
As shown in Table 4.15-7, Table 4.15-8, and Table 4.15-9 Project operations would increase wastewater generation, electricity demand, and water demand as compared to existing conditions. However, the Project would decrease solid waste generation, as industrial uses have higher solid waste generation rates than residential. The Project would require construction of Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

new connections to nearby existing water, wastewater conveyance, stormwater, electric power, and telecommunication facilities. Notwithstanding, with mitigation incorporated, the Project would result in less than significant environmental effects associated with construction of the proposed utilities and service systems. Under the No Project/Existing Land Use Designation Alternative, operations would increase wastewater generation, electricity demand, water demand, and solid waste generation compared to the existing industrial land uses, however, to a lesser degree than the Project since residential land uses typically generate greater demand.

As also shown in Table 4.15-7, Table 4.15-8, and Table 4.15-9, the approximately 106,100 SF of existing industrial land uses’ wastewater generation, electricity demand, water demand, and solid waste generation is far less than the proposed Project’s. This Alternative would involve approximately 228,690 SF of industrial land uses, or approximately double the industrial floor area (approximately 115 percent more) as under existing conditions. Assuch, it can be reasonably inferred that this Alternative’s operational wastewater generation, electricity demand, water demand, and solid waste generation would be approximately double the generations/demands under existing conditions, but significantly less than the proposed Project’s generations/demands. Notwithstanding, with mitigation incorporated, this Alternative would also result in less than significant environmental effects associated with construction of utilities and service systems given the area’s built out conditions.

The No Project/Existing Land Use Designation Alternative would result in less demands concerning utilities and service systems than the Project, but similar impacts concerning environmental effects associated with construction of the proposed utilities and service systems.

Aesthetics
The Project proposes an apartment building approximately 90 feet tall and nine townhome buildings approximately 40 feet tall, as measured from the finished floor (i.e., the level of the finished floor on the ground level) of the roof’s highest point. This Alternative assumes redevelopment of the existing blighted industrial use; the existing 106,100SF industrial use and associated surface parking would be removed and replaced with a 228,690 SF industrial business park development. With this Alternative, the degree of visual alteration would be less than the Project since this Alternative proposes a land use similar in scale and mass to existing conditions, and approximately half as much floor area as the Project. Further, per GMC § 18.32.050, this Alternative would not propose structures exceeding 35 feet since the site is within 100 feet of a zone R-1 and R-2 zone. Although this Alternative would involve less change from existing conditions concerning scale and mass, the Project would introduce residential uses, which would be more compatible with the surrounding residential uses.

The existing urbanized area is comprised primarily of residential land uses. The Project would not result in a significant source of light or glare. This Alternative would introduce new sources of light and glare as well, but to a lesser degree than with the Project since this Alternative involves approximately half as much floor area of development. Although both the Project and this Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Alternative would not cause a significant source of light or glare, this Alternative would result in less impact than the Project.

Therefore, this Alternative would result in less impacts as the proposed Project regarding aesthetics/light and glare.

ABILITY TO MEET PROJECT OBJECTIVES
The No Project/Existing Land Use Designation Alternative would not meet any of the Project objectives, as identified above.

6.4.4 “REDUCED DENSITY” ALTERNATIVE

DESCRIPTION OF ALTERNATIVE
The “Reduced Density” Alternative assumes development of the Project site similar to the proposed Project. The townhomes would remain unchanged; however, for purposes of this Alternative, the apartment building would be reduced to 192 DUs (from 328) and the building height would be reduced to five stories (from seven stories). This Alternative proposes a total of 267 DU, or approximately 34 percent fewer DU than the Project, and would reduce the density to 51 DU/AC. However, with fewer units, the Applicant would not be able to provide the affordable housing. It is assumed that the access driveways would be the same under this Alternative, thus, similarly to the Project, this Alternative would require offsite railroad improvements pursuant to CPUC standards and UPRR guidelines. Table 6-2: Comparison Between Proposed Project and Reduced Density Alternative compares development under the Project and the Reduced Density Alternative.

Table 6-2: Comparison Between Proposed Project and Reduced Density Alternative Description
Apartment
Building
(DU)1
Townhome
s (DU)1
Density
(DU/AC)
Height of
Building
(Stories)
Floor Area
(SF)
Proposed Project 328 75 77 7 429,000
Reduced Density
Alternative 192 75 51 5 253,110
Subtotal Difference -136 -0
Total Difference -136 -2 -175,890
% Difference -34% -41%
Note: DU = dwelling units; and AC = acre.

IMPACT COMPARISON TO THE PROPOSED PROJECT
Air Quality
The Project’s short-term air quality impacts from demolition, grading, and construction activities would be less than significant. The Reduced Density Alternative proposes approximately 34 percent fewer DU than the Project and less floor area (approximately 253,110 SF compared to Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

approximately 429,000 SF), thus, proportionately fewer construction emissions as presented in Table 4.1-5 would occur. This Alternative would also not expose sensitive receptors to substantial pollutant concentrations, which is concluded to be less than significant for the Project through compliance with the established regulatory framework.

As shown in Table 4.1-6, the Project’s operational criteria pollutant emissions would be below the SCAQMD’s mass daily significance thresholds and would result in a less than significant air quality impact. Under the Reduced Density Alternative, proportionately less operational emissions would occur compared to the Project, as there would be fewer DUs developed.

Therefore, like the Project, less than significant operational emissions would occur.

The Reduced Density Alternative would result in less impacts than the proposed Project regarding air quality. Less short-term construction emissions and long-term operational emissions would occur than the Project, as fewer DU would be developed.

Cultural Resources
The Project would result in no impact to historical resources and less than significant impacts to as yet undiscovered archaeological resources, with mitigation incorporated. The Project’s potential to disturb as yet undiscovered human remains was concluded to be less than significant through compliance with the established regulatory framework and with mitigation incorporated. The Reduced Density Alternative would also involve demolition and ground disturbing construction activities; thus, similar impacts would occur, with mitigation incorporated.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding cultural resources since the ground disturbing activities would occur within a similar footprint.

Energy
As shown in Table 4.3-5, the Project would result in construction-related energy consumption from water, diesel fuel, and gasoline usage. However, the Project would result in less than significant impacts concerning construction-related energy consumption since wasteful, inefficient, or unnecessary consumption of energy resources would not occur following compliance with Title 24 requirements. Under the Reduced Density Alternative, less construction-related energy consumption would occur, given this Alternative proposes approximately 34 percent fewer DU. Further, this Alternative would also be subject to compliance with Title 24 requirements. Like the Project, this Alternative’s construction would not result in wasteful, inefficient, or unnecessary consumption of energy resources, resulting in a less than significant impact concerning energy.

The Project’s operational energy consumption would occur from building energy use, water use, and transportation-related fuel use; see Table 4.3-5. The Project would be subject to compliance with applicable energy standards. Therefore, Project operations would not result in wasteful, inefficient, or unnecessary consumption of energy resources, resulting in a less than significant Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

impact concerning energy. Further, the Project would not conflict with/obstruct a State or local plan for renewable energy or energy efficiency. Under the Reduced Density Alternative, operational energy consumption would be proportionately less as the Project, as fewer DU would be developed, but this Alternative would also operate under the latest CALGreen standards. Like the Project, this Alternative would not result in wasteful, inefficient, or unnecessary consumption of energy resources during operations, resulting in a less than significant impact concerning energy.

The Reduced Density Alternative would result in less energy consumption than the proposed Project. Notwithstanding, like the Project, this Alternative would not result in wasteful, inefficient, or unnecessary consumption of energy resources, resulting in less than significant impacts concerning energy.

Geology, Soils, and Paleontological Resources
Project construction-related impacts (i.e., ground disturbing activities) on paleontological resources are concluded to be less than significant, with mitigation incorporated. Since the Reduced Density Alternative would involve demolition and ground disturbing construction activities in a similar footprint, similar impacts would occur as the Project, with mitigation incorporated.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding paleontological resources. Under this Alternative, ground disturbing activities would occur within a similar footprint as the Project.

Greenhouse Gas Emissions
The Project would result in less than significant construction-related GHG emissions and direct and indirect operational GHG emissions, as explained in Section 4.5. Under the Reduced Density Alternative, less construction-related GHG emissions would occur than with the Project because fewer DU would be constructed.

The Reduced Density Alternative would result in less GHG emissions than the proposed Project since fewer DU would be developed. Notwithstanding, like the Project, GHG emissions would not exceed significance thresholds, thus would be less than significant under this Alternative.

Hazards and Hazardous Materials
The proposed Project would require demolition of onsite buildings which could expose construction workers to concentrations exceeding federal and state thresholds. Additionally, Project construction activities could 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. Implementation of COA HAZ-1 and COA HAZ-2, and MM HAZ-1, would reduce impacts to less than significant. The Reduced Density Alternative would also involve construction activities, thus this Alternative, like the Project, would result in a less than significant impact with mitigation incorporated.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

The Project’s operational-related impacts concerning PCE concentrations that exceed DTSC screening levels for residential applications, which was considered less than significant with mitigation incorporated, would be similar with this Alternative, as residential uses are also proposed.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding hazards and hazardous materials, because like the Project, this Alternative proposes development of residential uses within a similar footprint.

Hydrology and Water Quality
Like the Project, the Reduced Density Alternative construction activities would result in less than significant short-term water quality impacts following compliance with NPDES and GMC requirements. However, this Alternative’s impacts would be less than the Project’s since this Alternative proposes less floor area.

Following compliance with NPDES and GMC requirements, which include implementation of water quality BMPs, the Project’s operational activities would not violate any water quality standards or otherwise substantially degrade surface or groundwater quality. Similarly, the Reduced Density Alternative would result in less than significant operational water quality impacts following compliance with current NPDES and GMC requirements. As such, this Alternative is assumed to result in similar operational water quality impacts as the Project.

The Project would not impede or redirect flood flows and would decrease the existing peak flow rates due to a decrease in impervious surface coverage. The Project would not result in substantial erosion, increase the rate or amount of surface runoff, or create runoff that would exceed the capacity of existing stormwater drainage systems. This Alternative would also decrease the site’s impervious surface coverage similar to the Project, as this Alternative proposes a similar site plan but only five stories of apartments, rather than seven. Like the Project, this Alternative would not impede or redirect flood flows or modify peak flow rates, since a no net increase of flows would be expected. Also, similar to the Project, this Alternative would not result in substantial erosion, increase the rate or amount of surface runoff, or create runoff that would exceed the capacity of existing stormwater drainage systems. The Project’s potential construction-related impacts to groundwater would be less than significant with mitigation incorporated. The Project would decrease potential impacts to groundwater resources through a decrease in impervious surfaces and increase in infiltration of stormwater runoff. Given similar development footprints and impervious surfaces, this Alternative would also result in less than significant impacts with mitigation incorporated. As with the Project, this Alternative’s impacts concerning demand for groundwater supplies would be less than significant. The Reduced Density Alternative would have a similar footprint as the Project and would therefore have a similarly sized area devoted to pervious surfaces, and therefore increased levels of groundwater infiltration. The Reduced Density Alternative would result in similar impacts as the proposed Project regarding hydrology and water quality, since the same reductions to runoff, impervious surface, and improvements to water quality during operations would occur.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Land Use and Planning
To accommodate the proposed apartment building and townhomes, the Project would remove the approximately 115,424 SF of industrial buildings. The Project would replace the Project site’s existing General Plan Industrial and Industrial, High Density 30 Overlay land use designations with Specific Plan, and Industrial (M-1), General Industrial (M-2), and Housing Overlay 4 (HO-4) zoning with Normandie Crossing Specific Plan (NCSP). To implement the Project, the Applicant would require several discretionary permits/approvals, including General Plan/General Plan Map Amendments, Zone Change and Zone Map Amendment, and Zoning Text Amendment, and Normandie Crossing Specific Plan (NCSP), among others; see Section 2.6. The Reduced Density Alternative assumes similar entitlements and development as the Project; however, this Alternative proposes 136 fewer DU, as indicated in Table 6-2. Comparatively, this Alternative proposes approximately 34 percent fewer DU. The Project was concluded to be consistent with the GGP policies and plans and GMC standards. This Alternative would similarly be consistent with GGP policies and plans and GMC standards. The Reduced Density Alternative’s impacts involving land use consistency would be similar to the Project, as the same land use type would be developed.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding land use and planning. The same use would occur on the Project site and be similarly consistent with the GGP policies and plans and GMC standards.

Noise
The Project’s construction-related noise impacts would be significant and unavoidable, despite implementation of mitigation concerning construction equipment and a temporary noise barrier, based on exceedance of noise standards, the proposed building height (seven stories), and extended construction period. The Project’s construction-related vibration impacts would be less than significant with mitigation. Although the Reduced Density Alternative’s construction activities would occur over a shorter time period, involve less building height, and approximately 41 percent fewer square feet, construction activities would take place within a similar footprint and distance from sensitive receptors, and thus will also exceed noise standards. Therefore, like the Project, this Alternative would still result in a significant unavoidable impact concerning construction noise, but to a slightly lesser degree than the Project.

As shown in Table 4.9-11, the Project’s composite stationary source noise level would be below the significance thresholds, resulting in a less than significant impact. The Reduced Density Alternative would have similar noise sources as the Project, but slightly less impacts would occur since this Alternative proposes 34 percent fewer DU.

The Project would result in less than significant impacts from mobile noise sources. This Alternative would also be anticipated to result in less than significant impacts from mobile noise sources, however, proportionately less than the Project as this Alternative would generate fewer trips. The Reduced Density Alternative would result in slightly less impacts than the proposed Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Project regarding noise, given less construction and operational noise would occur compared to the Project, although the Project’s significant unavoidable construction impacts would also occur under this Alternative.

Population and Housing
The Project proposes 403 DUs. As indicated in Table 4.10-7, the Project is forecast to generate a population growth of approximately 1,088 persons. The Project would induce unplanned population growth in the City directly through new housing, but the Project’s forecast population growth is not considered substantial. Under this Alternative, population growth would be approximately 34 percent less, as 136 fewer DUs would be constructed. And due to economies of scale, this Alternative would not be able to provide any affordable units. As with the proposed Project, this Alternative would induce unplanned population growth, but it would not be significant. Like the Project, this Alternative would not displace existing housing.

The 2021-2029 Housing Element Update identified a total of 122 opportunity housing sites, which includes a portion of the Project site (Sites A and B). As shown in Table 4.10-6, the City’s RHNA allocation is 5,735 units. The Project would meet approximately 7 percent of the City’s 6th Cycle RHNA allocation, including providing 20 units of affordable housing. Thus, the Project would be in furtherance of meeting the City’s 6th Cycle RHNA allocation.

Under this Alternative, 136 fewer DUs would be constructed, and no affordable housing units would be provided. Thus, this Alternative would be in furtherance of meeting the City’s RHNA allocation, however, to a lesser degree than the Project. However, Housing Elements include a housing buffer in the site inventory to avoid violating the No Net Loss requirement. The HEU sites inventory provides for a total (including ADUs) of 6,586 housing units, a 13 percent buffer above the City’s RHNA allocation. Therefore, given the 13 percent buffer in housing units included in the HEU, this Alternative’s provision of fewer housing units and no affordable units would not preclude the City from meeting their RHNA obligation and the findings under Government Code §65863 can be made.

The Reduced Density Alternative would result in greater impacts than the proposed Project regarding population and housing, as this Alternative would be in furtherance of the City’s efforts to meet the 6th Cycle RHNA allocation, but to a much lesser degree than the Project given this Alternative would provide fewer above-market rate units and exclude the affordable units.

Public Services
The Project would generate an incremental increase in demand for fire and police protection, and library services. However, because the Project site is in a developed area where these services and equipment/infrastructure are already in place, the Project would not require construction of new or physically altered fire and police protection, or library facilities, resulting in a less than significant impact. Like the proposed Project, this Alternative would incrementally increase demands on fire and police protection services, and library facilities, but to a lesser degree than the Project given fewer DUs would be developed. Notwithstanding, neither this Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Alternative nor the Project would result in a significant impact concerning fire and police protection services, or library facilities as neither would result in an adverse physical impact associated with the provision of new or physically altered facilities.

The Project is forecast to generate a student population growth of approximately 151 students at the LAUSD, which would incrementally increase the demand for school facilities and services.

Although, insufficient capacity exists at the high school, with payment of school impact fees in accordance with Senate Bill (SB) 50, Project impacts would be fully mitigated and no physical impacts concerning school facilities would occur. The Reduced Density Alternative would involve approximately 34 percent fewer DU, with proportionately less student population increase and demand for school facilities as the Project. Like the Project, payment of school impact fees would fully mitigate potential impacts and no physical impacts concerning school facilities would occur.

The Reduced Density Alternative would result in less demand for public services, as the Project since fewer DUs would be constructed. But, like the Project, would not result in an adverse physical impact associated with the provision of new or physically altered facilities.

Recreation
The Project’s forecast population growth would incrementally increase the use of existing neighborhood and regional parks and/or other recreational facilities, but it would not be such that substantial physical deterioration of existing facilities would occur or be accelerated given the Project would provide onsite open space and recreational facilities. Under the Reduced Density Alternative, fewer DUs would be developed, but it would also incrementally increase the use of existing neighborhood and regional parks and/or other recreational facilities, although to a lesser degree than the Project. Neither the Alternative nor the proposed Project would result in an adverse physical impact associated with the construction or expansion of recreational facilities.

Neither this Alternative nor the Project would result in adverse physical impacts associated with park facilities, since neither proposes to provide or physically alter a park facility. The Project proposes onsite open space and recreational amenities, which would result in a less than significant physical effects on the environment with mitigation incorporated. The environmental effects of the Project’s proposed open spaces and recreational amenities would occur also with this Alternative, as recreational uses would also be developed.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding recreational facilities, although slightly less demand for recreational facilities would occur. Like the Project, less than significant physical effects on the environment would occur with mitigation incorporated from open space and recreational amenities.

Transportation
The proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The Reduced Density Alternative proposes a similar residential development; therefore, it would also not Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

conflict with a program, plan, ordinance, or policy addressing the circulation system and would result in less than significant impacts.

The Project is located within a low VMT generating area, one of the three screening criteria for VMT. Therefore, the Project would result in a less than significant impact concerning VMT. This Alternative is on the same site, thus, would also be screened from further VMT, resulting in a less than significant impact concerning VMT.

Project construction would require traffic lane, parking lane and/or sidewalk closures, but would not result in the complete closure of any public or private streets and would implement a Construction Traffic Management Plan (PDF TR-1), approved by the City, to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access. Temporary construction activities would not impede the use of road for emergencies or emergency response vehicles.

Therefore, the Project would result in less than significant impacts concerning emergency access.

The Reduced Density Alternative would involve similar construction activities and it would be required to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access, similar to the Project. Assuming similar traffic management measures are implemented as a part of this Alternative’s construction, less than significant impacts would also occur.

The Reduced Density Alternative would result in similar impacts as the proposed Project regarding transportation. This Alternative would also be within a Low VTM generating area and would minimize potential circulation impacts through traffic management measures.

Tribal Resources
The Project would result in less than significant impacts to as yet undiscovered tribal cultural resources, with mitigation incorporated. The Reduced Density Alternative would also involve demolition and ground disturbing construction activities; thus, similar impacts would occur with mitigation incorporated.

The Reduced Density Alternative would be result in similar impacts as the proposed Project regarding tribal cultural resources. Under this Alternative, ground disturbing activities would occur within the same footprint as the Project.

Utilities and Service Systems
As shown in Table 4.15-7, Table 4.15-8, and Table 4.15-9, Project operations would increase wastewater generation, electricity demand, and water demand, but would decrease solid waste generation. Thus, the Project would require construction of new connections to nearby existing water, wastewater conveyance, stormwater, electric power, and telecommunication facilities.

Notwithstanding, with mitigation incorporated, the Project would result in less than significant environmental effects associated with construction of the proposed utilities and service systems.

The Reduced Density Alternative would result in an overall increase in wastewater generation, Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

electricity demand, and water demand, but proportionately less than the Project since this Alternative would propose 34 percent fewer DUs.

The Reduced Density Alternative would result in less demands concerning utilities and service systems than the Project, but similar impacts concerning environmental effects associated with construction of the proposed utilities and service systems.

Aesthetics
The Project proposes a 403-unit apartment building and 75 townhomes. The maximum height of the apartment building and townhomes would be seven stories and three stories, respectively.

Under this Alternative, the site’s visual character/quality would be altered similar to the Project since the existing industrial use would be removed and replaced with residential uses (a 192 DU apartment building and 75 townhomes). With this Alternative, the apartment building would be only five stories, thus, shorter than the Project.

The Project would not result in a significant source of light or glare. This Alternative proposes 136 fewer DU, thus aesthetic impacts from light and glare would be proportionately less under this Alternative compared to the Project. As with the Project, this Alternative would result in less than significant light and glare impacts.

The Reduced Density Alternative would result in less impacts than the proposed Project regarding aesthetics/light and glare. This Alternative proposes fewer DUs and fewer stories, thus, proportionately less visual alteration would occur than the Project. Like the Project, impacts would be less than significant under this Alternative.

ABILITY TO MEET PROJECT OBJECTIVES
The Reduced Density Alternative would fulfill most of the Project objectives but would not provide as much housing and would fail to provide any affordable housing. This Alternative would not provide as much diversity for Gardena’s existing multi-family housing options, but would still support the expanding technology and creative sector with newly constructed high-quality housing opportunities, cluster urban residential development near technology firms and large employment centers, establish housing development that meets high standards of design and pursues environmental sustainability, and redevelop a blighted site while increasing tax revenues to the City and supporting the City’s above-market rate RHNA goals. However, because this Alternative proposes 136 fewer DUs (41 percent fewer apartments, 34 percent fewer overall DU) than the Project, this Alternative would not accomplish these objectives to the same degree as the Project. In addition, the tax revenues to the City would be proportionately reduced and the City’s RHNA goals would be supported to a lesser degree. This Alternative would not avoid the Project’s unavoidable significant impact of construction-related noise impacts but would slightly lessen the construction noise impact given a reduced construction period and reduced building height.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

ALTERNATIVES CONSIDERED, BUT REJECTED
In accordance with State CEQA Guidelines §15126.6(c), an EIR should identify any alternatives that were considered for analysis but rejected as infeasible and briefly explain the reasons for their rejection. According to the State CEQA Guidelines, among the factors that may be used to eliminate alternatives from detailed consideration are the alternative’s failures to meet most of the basic project objectives, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts.

In addition to the three alternatives analyzed above, an “Avoid Construction Noise Impact” Alternative was considered but rejected. The “Avoid Construction Noise Impact” Alternative would reduce the Project size and density to avoid the Project’s significant unavoidable construction noise impact.

To avoid the Project’s significant and unavoidable construction-related noise impact, analysts considered noise during construction phases and whether these noise levels could be reduced by reducing the development footprint under the Avoid Noise Impact Alternative. As indicated in Table 4.9-6: Estimated Construction Noise Levels, the Project’s estimated construction noise levels would exceed the City’s significance thresholds at all noise-sensitive receptor locations except R3 despite incorporation of mitigation achieving an approximately 12-dBA attenuation (i.e., noise reduction). Further, the City’s significance thresholds are exceeded for all noisesensitive receptor locations except R3 during every phase of construction, including demolition.

Accordingly, unless demolition is avoided (and the existing structures remain), no modification of the Project would avoid the Project’s significant unavoidable construction noise impacts.

Therefore, the Avoid Construction Noise Impact Alternative was rejected because, to avoid the Project’s significant unavoidable construction noise impact, demolition would have to be completely avoided. Thus, it would not be practical and would not accomplish the Project’s objectives.

An “Alternative Site” Alternative was also considered but rejected given that the Applicant does not have interest in any alternative site within the City that is currently not already being developed.
“ENVIRONMENTALLY SUPERIOR” ALTERNATIVE
According to State CEQA Guidelines §15126.6(e)(2), “No Project” Alternative, “If the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.” Table 6-3 summarizes the comparative analyses presented above (i.e., the Alternatives compared to the proposed Project).

As indicated in Table 6-3, the environmentally superior Alternative is the No Project/No Construction Alternative. Among the other Alternatives, the Reduced Density Alternative is the environmentally superior Alternative. As shown in Table 6-3, it would result in similar or less impacts for all resources areas except population and housing, for which it would result in greater impacts than the Project. However, this Alternative would not eliminate the only unavoidable

6.5 6.6
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

significant impact of construction noise and would not achieve the objectives to the same degree as the proposed Project.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Table 6-3: Comparison of Alternatives
Sections
Alternative 6.4.2:

No Project/No
Construction
Alternative 6.4.3:

No Project/Existing
Land Use Designation
Alternative 6.4.4:

Reduced Density
Air Quality   
Cultural Resources  = =
Energy   
Paleontological Resources  = =
Greenhouse Gas
Emissions
  
Hazards & Hazardous
Materials   =
Hydrology & Water
Quality   =
Land Use & Planning   =
Noise*  ** **
Population & Housing   
Public Services  = 
Recreation   =
Transportation   =
Tribal Cultural Resources  = =
Utilities & Service Systems  = =
Aesthetics   
 Indicates an impact that is greater than the proposed Project (environmentally inferior).  Indicates an impact that is less than the proposed Project (environmentally superior). = Indicates an impact that is equal to the proposed Project (neither environmentally superior nor inferior). ** Impact would still be significant and unavoidable.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

Table 6-4: Alternatives Ability to Meet Project Objectives Would the Alternative:

Alternative 6.4.2:

No Project/No
Construction
Alternative 6.4.3:

No Project/Existing
Land Use Designation
Alternative 6.4.4:

Reduced Density
Diversify the City of Gardena’s
existing housing options, by
providing a range of housing types
and sizes, to serve the region’s
growing and evolving technology
and creative sectors and aid in
recruiting and retaining talent for
local companies?
No No
Yes –
but to a lesser degree
Support the expanding technology
and creative sector with newly
constructed, high-quality housing
opportunities, enabling local
employees to live close to where
they work?
No No
Yes –
but to a lesser degree
Cluster urban residential
development near technology firms,
other large employment centers,
and commercial corridors providing
City residents with the opportunity
to live, work, and shop with less
reliance on automobiles?
No No
Yes –
but to a lesser degree
Establish housing development that
meets high standards of design and
pursues environmental
sustainability?
No No Yes
Redevelop a blighted site, increase
tax revenues to the City, provide
affordable housing to support the
City’s Regional Housing Needs
Assessment goals, and create a
catalyst for future development in
this part of Gardena.

No No
Partially, it would not
provide affordable
housing.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 6.0
Administrative Draft Environmental Impact Report Alternatives to the Proposed Project

This page intentionally left blank.

Kimley>>>Horn

7.0 EFFECTS FOUND NOT TO BE

SIGNIFICANT

Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.0 EFFECTS FOUND NOT TO BE SIGNIFICANT
CEQA provides that an EIR shall focus on a project’s significant effects on the environment, discussing the effects with emphasis in proportion to their severity and probability of occurrence.

The environmental topics dismissed in an Initial Study (Environmental Checklist) as clearly not significant and unlikely to occur need not be discussed further in the EIR unless information inconsistent with the Environmental Checklist findings is subsequently received.

California Public Resources Code (PRC) §21100 (c) states that an EIR shall contain a statement briefly indicating the reasons that a project’s various possible significant effects were determined not to be significant and were, therefore, not discussed in detail in the Draft EIR (PRC §21000 et. seq.). State CEQA Guidelines §15128 adds, “Such a statement may be contained in an attached copy of an Initial Study (Environmental Checklist)” (14 CCR 15000 et. seq.). The environmental topics included in the Initial Study (Environmental Checklist) prepared with the Notice of Preparation (NOP) included a determination of potential impact significance. The Draft EIR further evaluates all of the Project’s possible significant effects in accordance with the State CEQA Guidelines. Where the Initial Study (Environmental Checklist) determined the Project would have a “less than significant impact” or “no impact,” these threshold issues have not been addressed in the EIR, except to be listed in this section. The Initial Study (Environmental Checklist) thresholds are provided below followed by an explanation supported by cited information sources of all “no impact” and “less than significant impact” responses. The sequence and numbering of the below thresholds are consistent with the sequence and numbering provided in the Initial Study (Environmental Checklist); see Appendix 1.0-1: Initial Study, Notice of Preparation, and Comments Letters.

7.1 AESTHETICS

7.1a Would the project have a substantial adverse effect on a scenic vista? No Impact. Under CEQA, a scenic vista is defined as a viewpoint that provides expansive views of a highly valued landscape for the public’s benefit. No such conditions exist on or near the Project site. Additionally, the GGP does not specifically address scenic vistas. Therefore, the Project would not have an adverse effect on a scenic vista.

7.1b Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway? No Impact. The area surrounding the Project site is predominately developed, with no natural landforms or scenic features present. There are no State- or County-designated scenic highways Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

in the Project site vicinity.1 Therefore, the Project would not damage scenic resources within a State scenic highway.

7.2 AGRICULTURE AND FORESTRY RESOURCES

7.2a Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?

7.2b Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?

7.2c Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code §12220(g)), timberland (as defined by Public Resources Code §4526), or timberland zoned Timberland Production (as defined by Government Code §51104(g))?

7.2d Would the project result in the loss of forest land or conversion of forest land to non-forest use?

7.2e Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact. No Prime Farmland, Unique Farmland, or Farmland of Statewide or Local Importance is mapped in the City. 2 Further, the Project site is not the subject of a Williamson Act Contract.3 The Project site is zoned M-1, M-2, and HO-4.4 No agricultural, forest land, or timberland zoning exists in the City. Therefore, the Project would result in no impact concerning mapped farmlands, Williamson Act contracts, or agricultural, forest, or timber land zoning.

The Project site is fully developed with approximately 106,100 SF of industrial land uses. No farmland, forest land, or timberland exist in the City. Therefore, the Project would not result in the conversion or loss of Farmland, forest land or timberland. 1 California Department of Transportation. (2019). California State Scenic Highway System Map. Retrieved from https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. 2 California Department of Conservation. (2016). California Important Farmland Finder. Retrieved from https://maps.conservation.ca.gov/dlrp/ciff/.
3 California Department of Conservation. (2016). Williamson Act/Land Conservation Act. Retrieved from http://www.conservation.ca.gov/dlrp/lca.
4 City of Gardena. (2020). Zoning Map. Gardena, CA: City of Gardena Planning Division. Retrieved from https://cityofgardena.org/wpcontent/uploads/2020/11/Gardena_Zonning_2020.pdf.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.3 BIOLOGICAL RESOURCES

7.3a 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?

7.3b 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?

7.3c 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? No Impact. The Project site is fully developed with approximately 106,100 SF of industrial land uses. No natural habitats are present on-site, with only landscaping (i.e., ornamental vegetation) present. The Project site is bordered by single- and multi-family residential uses. No natural habitats are present within these adjacent areas, with only landscaping (i.e., ornamental vegetation) present. Based on review of the existing and adjacent site conditions, no candidate, sensitive, or special-status plant or wildlife species, riparian habitat or other sensitive natural community, or wetlands are present on or adjacent to the Project site. The nearest wetlands to the Project site are the Gardena Willows Wetland Preserve, which is approximately 0.5 mile from the Project site, at 1202 West 170th Street in the City of Gardena. Therefore, the Project would not have an adverse effect on any candidate, sensitive, or special-status plant or wildlife species, riparian habitat or other sensitive natural community, or wetlands.

7.3d 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? Less Than Significant Impact. Corridors are linear linkages between two or more habitat patches, which provide for wildlife movement and dispersal. The Project site is fully developed and contains no natural habitats, with only minimal landscaping. The Project site is also bounded by single- and multi- family residential uses on all sides. No natural habitats are present on these adjacent areas, and only landscaping (i.e., ornamental vegetation) is present.

The Dominguez Channel is located 0.4 mile south of the Project site. There are no established wildlife movement corridors that traverse this segment of the Dominguez Channel.5 Because this drainage is concrete lined, its habitat values in this urban area are low. The Channel does not necessarily include habitat capable of supporting all requirements of a species, but it could be 5 Environmental Sciences Associates, LA County Flood Control District Enhanced Watershed Management Programs Draft Program Environmental Impact Report, January 2015.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

used for wildlife movement. However, because Project construction activities would occur entirely within Project site boundaries and would be restricted to daytime hours, in accordance with the GMC, the Project’s potential impacts concerning interference with an established wildlife movement would be less than significant.

As previously noted, the Project site is fully developed and contains only ornamental vegetation, no natural habitats, with only landscaping. The on-site vegetation and trees could provide suitable nesting habitat for birds. The Project would clear and grade the Project site including the vegetation with the potential to support nesting migratory birds. The Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC) are intended to protect migratory birds. Under MBTA provisions, it is unlawful “by any means or manner to pursue, hunt, take, capture (or) kill” any migratory birds except as permitted by regulations issued by the USFWS. The term “take” is defined by USFWS regulation to mean to “pursue, hunt, shoot, wound, kill, trap, capture or collect” any migratory bird or any part, nest or egg of any migratory bird covered by the conventions, or to attempt those activities. In addition, the CFGC extends protection to non‐ migratory birds identified as resident game birds (CFGC §3500) and any birds in the orders Falconiformes or Strigiformes (birds‐of‐prey) (CFGC §3503). To address potential impacts to migratory birds from construction activities during the nesting season, the Project would be subject to compliance with GMC §18.42.210E: Migratory Bird Protection, 6 which includes provisions concerning construction activities both within and outside the nesting season to avoid effects to migratory birds. Therefore, following compliance with the relevant regulatory framework (MBTA, CFGC, and GMC §18.42.210E), the Project’s potential impacts to nesting migratory birds would be mitigated to a less than significant level.

7.3e Would the project conflict with local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? No Impact. GMC §13.60.080: Permit, requires a Trimming Permit, Tree Removal Permit, and/or a Tree Planting Permit for cutting, trimming, pruning, planting, removing, injuring, or interfering with any tree, shrub, or plant upon any Street or Public Place in the City. The Project would be developed on private property and no tree trimming or tree removal within any of the City’s streets or public places would occur as a result of Project construction. Therefore, the Project would not conflict with GMC §13.60.080.

7.3f 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?
No Impact. The Project site is not located within the boundaries of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or 6 City of Gardena, California, Municipal Code Ordinance No. 1848. Retrieved from https://cityofgardena.org/wpcontent/uploads/2023/03/ORD-NO-1848-Establishment-of-Housing-Overlays-and-Devlopment-Standards.pdf.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

state habitat conservation plan. Therefore, the Project would not result in conflicts with such plans. No impact would occur.

7.4 GEOLOGY AND SOILS

7.4ai Would the project directly or indirectly cause potential substantial adverse effects, including the risks of loss, or death involving the 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 Special Publication 42.

No Impact. The Alquist-Priolo Earthquake Fault Zoning Act was passed in 1972 to mitigate the hazard of surface faulting to structures for human occupancy. The Act’s main purpose is to prevent the construction of buildings used for human occupancy on the surface trace of active faults. The Act requires the State Geologist to establish regulatory zones, known as “Alquist-Priolo (AP) Earthquake Fault Zones,” around the surface traces of active faults and to issue appropriate maps. If an active fault is found, a structure for human occupancy cannot be placed over the trace of the fault and must be set back from the fault (typically 50 feet). The Project site is not located within an Alquist-Priolo Earthquake Fault Zone.7 Additionally, the potential for surface fault rupture at the Project site during the design life of onsite structures is considered low.8 The Project would not expose people or structures to adverse effects involving rupture of a known earthquake fault. Therefore, no impact would occur in this regard.

7.4aii Would the project directly or indirectly cause potential substantial adverse effects, including the risks of loss, or death involving strong seismic ground shaking? Less Than Significant Impact. The City is located between several active fault zones including the Newport-Inglewood-Rose Canyon Fault Zone, Palos Verdes Fault, and Compton Blind Thrust Fault.9 The zoned fault nearest the Project site is the Newport-Inglewood Fault Zone, located approximately 0.6 miles to the west. The Project site is in an area of high regional seismicity.

Ground shaking originating from earthquakes along active faults in the region is expected to induce lower horizontal accelerations due to smaller anticipated earthquakes and/or greater distances to other faults. The region has experienced shaking from several earthquakes recorded back to 1812. The nearest large historic earthquake is the 1994 Northridge Earthquake, with an epicenter approximately 33.6 miles northwest of the Project site.10 Historic earthquakes with magnitudes of greater than or equal to 6.0 and have been epicentered within approximately 30 miles of the Project site.
7 California Department of Conservation. (2015). Earthquake Zones of Required Investigation Inglewood Quadrangle. Retrieved from http://gmw.consrv.ca.gov/SHP/EZRIM/Maps/INGLEWOOD_EZRIM.pdf. 8 Hamilton & Associates. (2022). Preliminary Geotechnical Investigation. page 8. 9 Ibid., page 7-6.
10 Southern California Earthquake Data Center. (2019). Significant Earthquakes and Faults. Retrieved from https://scedc.caltech.edu/significant/index.html.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

The faults described above could cause moderate to intense ground shaking during the Project’s lifetime. Additionally, the Project site has experienced earthquake-induced ground shaking in the past and can be expected to experience further shaking in the future. Therefore, Project implementation could expose people and structures to potential adverse effects involving strong seismic ground shaking. The intensity of ground shaking on the Project site would depend upon the earthquake’s magnitude, distance to the epicenter, and geology of the area between the Project site and epicenter. Regulatory controls to address potential seismic hazards would be imposed on the Project through the permitting process. Pursuant to GMC Chapter 15.04: General Building Provisions, the City has adopted the 2022 California Building Standards Code (CBSC), subject to certain amendments and changes, including those that address seismic resistance.

CBSC design standards correspond to the level of seismic risk in a given location and are intended primarily to protect public safety and secondly to minimize property damage. The Project would be subject to compliance with all applicable regulations in the most recently published CBSC (as amended by GMC Chapter 15.04), which specifies design requirements to mitigate the effects of potential earthquake hazards. Moreover, the Gardena Building Services Division will review construction plans to verify compliance with standard engineering practices, the GMC/CBSC, and the Preliminary Geotechnical Investigation’s 11 recommendations for Project design and construction, including concerning seismic design parameters. Following compliance with standard engineering practices, the established regulatory framework (i.e., GMC and CBSC), and the Preliminary Geotechnical Investigation’s recommendations, the Project’s potential impacts concerning exposure of people or structures to potential adverse effects involving strong seismic ground shaking would be less than significant.

7.4aiii Would the project directly or indirectly cause potential substantial adverse effects, including the risks of loss, or death involving seismic‐related ground failure, including liquefaction?
Less Than Significant Impact. Liquefaction is a phenomenon where earthquake-induced ground vibrations increase the pore pressure in saturated, granular soils until it is equal to the confining, overburden pressure. When this occurs, the soil can completely lose its shear strength and enter a liquefied state. For liquefaction to occur, three criteria must be met: underlying loose, coarse-grained (sandy) soils, a groundwater depth of approximately 25 feet, and a potential for seismic shaking from nearby large-magnitude earthquakes. Liquefaction-related effects include loss of bearing strength, amplified ground oscillations, lateral spreading, and flow failures.

The State’s Seismic Hazards Maps 12 do not classify the Project site as part of the potentially “Liquefiable” area. This determination is based on groundwater depth records, soil type, and distance to a fault capable of producing a substantial earthquake. Additionally, onsite soils consist predominantly of very stiff fine-grained soils (clays and silts), with one layer of borderline stiff to very stiff fine-grained soil, and occasional layers or lenses of dense sands. Deeper soils are mostly 11 Hamilton & Associates. (2022). Preliminary Geotechnical Investigation; Appendix 4.4-1: Preliminary Geotechnical Investigation. 12 California Department of Conservation. Seismic Hazard Zones, Map Data Viewer. Retrieved from Maps and Data (ca.gov).

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

very stiff fine-grained soils with dense to very dense sand layers or lenses. Liquefaction potential of these soil types is characteristically nil to low.13 Analysis was also performed to evaluate potential seismically induced settlement of onsite earth materials during a seismic event, considering historic high groundwater depth of approximately 15 feet below existing grade.

Results of the liquefaction analysis further support that liquefaction potential at the site is considered nil to low;14 see Appendix B of Appendix 1.0-1. Therefore, the Project’s potential impacts concerning exposure of people or structures to potential adverse effects involving liquefaction would be less than significant. Further, as discussed in Response 4.7aii, the Gardena Building Services Division will review construction plans to verify compliance with standard engineering practices, the GMC/CBSC, and the Preliminary Geotechnical Investigation’s recommendations for Project design and construction.

7.4aiv Would the project directly or indirectly cause potential substantial adverse effects, including the risks of loss, or death involving landslides? No Impact. Landslides are mass movements of the ground that include rock falls, relatively shallow slumping and sliding of soil, and deeper rotational or transitional movement of soil or rock. According to the California Geological Survey’s Earthquake Zones of Required Investigation Inglewood Quadrangle Map, the Project site does not lie in a landslide hazard zone.15 Since the site is relatively flat and not within a landslide hazard zone, no potential for earthquake-induced land sliding would occur. Therefore, the Project would not directly or indirectly cause potential adverse effects involving landslides. No impact would occur in this regard.

7.4b Would the project result in substantial soil erosion or the loss of topsoil? Less Than Significant Impact. The Project site is relatively flat, and its geology is composed of fill materials and native alluvial soils. Grading and earthwork activities during construction would expose soils to potential short-term erosion by wind and water. During construction, the Project would be subject to compliance with the GMC §8.70.110.B.1: Development Construction, erosion and siltation control measures and the National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2009-0009-DWQ, and all subsequent amendments) (Construction General Permit); see also Response 4.9a. GMC §8.70.110.B.1 specifies that no Grading Permit shall be issued to construction projects that disturb 1.0 or more acres of soil without obtaining a General Construction Activity Stormwater Permit (GCASWP) from the State Water Resources Control Board. Following compliance with the established regulatory framework (i.e., the GMC and Construction General Permit), the Project’s potential impacts concerning soil erosion and loss of topsoil would be less than significant.
13 Hamilton & Associates. (2022). Preliminary Geotechnical Investigation; Appendix 4.4-1. 14 Ibid. 15 Ibid.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.4c 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?

7.4d 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? Less Than Significant Impact. The Project site would not be subject to seismically induced liquefaction or lateral spreading (see Response 4.7aiii) or landslides (see Response 4.7aiv). The Gardena Building Services Division would review construction plans to verify compliance with standard engineering practices, the GMC/CBSC, and the Preliminary Geotechnical Investigation’s recommendations, including those concerning expansive soils. Following compliance with standard engineering practices, the established regulatory framework (i.e., GMC and CBSC), and the Preliminary Geotechnical Investigation’s recommendations, the Project would not create substantial direct or indirect risks to life or property concerning expansive soils. Therefore, impacts would be less than significant in this regard.

7.4e Would the project have soils incapable of adequately supporting the use ofseptic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
No Impact. Sewers would be available for disposal of Project-generated wastewater; see Responses 4.19aii and 4.19aiii. The Project would not utilize septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur in this regard.

7.5 HAZARDS AND HAZARDOUS MATERIALS

7.5a Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Less Than Significant Impact. Project construction would involve the routine transport, storage, use and/or disposal of limited quantities of hazardous materials, such as fuels, solvents, degreasers, and paints. Examples of such activities include fueling and servicing construction equipment and applying paints and other coatings.

The Project proposes a residential development, which is not anticipated to involve the routine transport, use, or disposal of large quantities of hazardous materials that could create a significant hazard to the public or environment. The maintenance materials would be stored, handled, and disposed of in accordance with applicable regulations and the City’s programs to control and safely dispose of hazardous materials and wastes. Specifically, the City’s Hazardous Materials Release Response Plans and Inventory Program requires the owner or operator of any business that handles or stores hazardous materials equal to or above the reportable quantities to submit a Hazardous Materials Inventory and Contingency Plan. Compliance with these regulations would ensure that all hazardous wastes would be properly handled, recycled, treated, stored, and disposed.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

Therefore, following compliance with standard City practices and federal and State regulations, the Project would result in a less than significant impact concerning its potential to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

7.5c Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact. The school nearest the Project site, Peary Middle School, is at 1415 West Gardena Boulevard, City of Gardena, which is approximately 0.4 mile north of the Project site. Therefore, the Project site is more than 0.25 mile from this existing school. Notwithstanding, the routine transport, use, and disposal of hazardous materials during Project construction would be subject to federal, state, and local regulations for transport, handling, storage, and disposal of hazardous substances. Compliance with the regulatory framework would ensure Project construction activities would not create a significant hazard to nearby schools.

Additionally, the Project does not propose any uses which could generate hazardous emissions or involve the handling of hazardous materials, substances, or waste in significant quantities that could impact surrounding schools. The types of hazardous materials that would be routinely handled during Project operations would be limited to household cleaners, paints, solvents, and fertilizers and pesticides for site landscaping. The routine transport, use, and disposal of hazardous materials during operations would be subject to federal, state, and local regulations for transport, handling, storage, and disposal of hazardous substances. Compliance with the regulatory framework would ensure Project operations would not create a significant hazard to nearby schools.

7.5d 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?
No Impact. Government Code §65962.5 refers to the Hazardous Waste and Substances Site List, commonly known as the Cortese List, maintained by the DTSC. The Cortese list contains hazardous waste and substance sites including public drinking water wells with detectable levels of contamination, sites with known underground storage tanks (USTs) having a reportable release, solid waste disposal facilities from which there is a known migration, hazardous substance sites selected for remedial action, historic Cortese sites, and sites with known toxic material identified through the abandoned site assessment program. The Project site is not included on a list of hazardous materials sites compiled pursuant to Government Code §65962.5.16 Therefore, the Project would result in no impact in this regard. 16 California Department of Toxic Substances Control. Department of Toxic Substances Control EnviroStor. Retrieved from:
https://www.envirostor.dtsc.ca.gov/public/search?cmd=search&reporttype=CORTESE&site_type=CSITES,FUDS&status=ACT,BKLG,COM&report title=HAZARDOUS+WASTE+AND+SUBSTANCES+SITE+LIST+%28CORTESE%29, accessed November 2023.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.5e 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. The Project site is not located within an airport land use plan or within two miles of a public airport or public use airport. The airport located nearest the Project site is Hawthorne Municipal Airport/Jack Northrop Field (“Airport”), approximately 3.4 miles to the northwest. This Airport is an FAA-designated general aviation reliever airport owned by the City of Hawthorne.

Therefore, the Project would not result in a safety hazard or excessive noise for people residing or working in the Project area. No impact would occur in this regard.

7.5f Would the project impair implementation of or physically interfere with an emergency response plan or emergency evacuation plan?
Less Than Significant Impact. The Project Site is located in an urbanized area where adequate circulation and access are provided to facilitate emergency response. The Gardena Public Safety Plan 17 outlines emergency response actions in the event of a large-scale disaster, such as a hazardous materials emergency. Further, while Project construction would likely require traffic lane, parking lane, and/or sidewalk closures, it would not require the complete closure of any public or private street. The Project would implement PDF TR-1 (see Section 4.13:

Transportation), which requires a Construction Traffic Management Plan, approved by the City, to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction, as well as ensure adequate emergency access. Temporary construction activities would not impede use of the streets for emergencies or access for emergency response vehicles. Further, Project construction would be subject to compliance with the following Public Safety Plan Policies:
 PS 1.7: Development Review. Ensure that law enforcement, crime prevention, and fire safety concerns are considered in the review of planning and development proposals in the City.
 PS 2.2: Building and Fire Codes. Require that all buildings and facilities within Gardena comply with local, state, and federal regulatory standards such as the California Building and Fire Codes as well as other applicable fire safety standards.  PS 2.7: New Development. Require adequate fire protection services, fire protection plans, and emergency vehicle access for new development. Locate, design, and construct new development to minimize the risk of structural loss from fires.  PS 3.1: California Building Code. Require compliance with seismic safety standards in the California Building Code, as adopted and amended.
17 City of Gardena. (2022). Public Safety Plan. Retrieved from https://cityofgardena.org/wp-content/uploads/2022/04/Gardena_Public-SafetyElement_FINAL-FOR-ADOPTION.pdf.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

Therefore, following compliance with City policies, as specified above, the Project’s potential impacts concerning impairing implementation of or physically interfering with an emergency response plan or related policies would be less than significant.

4.9g Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? No Impact. The Project site is in a fully urbanized area, and it is not adjacent to any wildland.

Therefore, the Project would not expose people or structures to a risk involving wildland fires.

No impact would occur in this regard.

7.6 HYDROLOGY AND WATER QUALITY

7.6d In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
No Impact. Federal Emergency Management Agency’s (FEMA’s) Flood Insurance Rate Map (FIRM) indicates the Project Site is within Zone X, which depicts areas determined to be outside of the 0.2-1.0% (500-year) annual chance floodplain.18
Tsunamis are sea waves that are generated in response to large-magnitude earthquakes. When these waves reach shorelines, they sometimes produce coastal flooding. Seiches are the oscillation of large bodies of standing water, such as lakes, which can occur in response to ground shaking. The Project site is approximately eight miles east of the Pacific Ocean and there are no nearby bodies of standing water. Therefore, the Project site is not within a tsunami or seiche zone.

The Project proposes a residential development that would involve the use of materials associated with routine property maintenance, such as janitorial supplies for cleaning purposes and/or herbicides and pesticides for landscaping. The Project is not within a flood hazard, tsunami, or seiche zone. Therefore, no risk of release of pollutants due to Project inundation by these hazards would occur.

7.7 LAND USE AND PLANNING

7.7a Would the project physically divide an established community? No Impact. Examples of projects that could physically divide an established community include a new freeway or highway that traverse an established neighborhood. The Project proposes residential infill development. The Project replaces the existing industrial use and does not propose any new roadways or other physical barriers. Given its nature and scope, the Project would not physically divide an established community. No impact would occur in this regard. 18 Federal Emergency Management Agency. (April 2019). FEMA Flood Map Service Center. Retrieved from https://msc.fema.gov/portal/search?AddressQuery=1515%20W%20178th%20St%2C%20Gardena%2C%20CA%2090248#searchresultsanch or.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.8 MINERAL RESOURCES

7.8a 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?

7.8b 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? No Impact. The Surface Mining and Reclamation Act of 1975 (SMARA) requires classification of land into mineral resource zones (MRZs) according to the area’s known or inferred mineral potential.19 The Project site is located in Mineral Resource Zone-1 (MRZ-1). Areas designated MRZ-1 are noted to have adequate information that no significant20mineral deposits are present, or it is judged that little likelihood exists for their presence.21 Further, the GGP does not identify the Project site as a locally important mineral resource recovery site. Therefore, the proposed Project would have no impact concerning mineral resources.

7.9 NOISE

7.9c Would the project be 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. The Project site is not located within the vicinity of a private airstrip or an airport land use plan, or within two miles of a public airport or public use airport. The airport located nearest the Project site is Hawthorne Municipal Airport/Jack Northrop Field (“Airport”), approximately

3.4 miles to the northwest. This Airport is an FAA-designated general aviation reliever airport owned by the City of Hawthorne. Therefore, the Project would not expose people residing or working in the Project area to excessive airstrip- or airport-related noise levels. No impact would occur in this regard.

7.10 POPULATION AND HOUSING

7.10a Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? No Impact. The Project would remove the existing onsite industrial uses and, in their place, construct residential uses. The Project would not displace existing housing or people or require construction of replacement housing elsewhere. Therefore, no impact would occur in this regard. 19 California Department of Conservation. (2018). California Statutes and Regulations for the California Geological Survey. Sacramento, CA:

California Geological Survey. 20 Note that use of the term “significant” in this context is used in the MRZ definitions of zones to describe economic value of mineral resources and does not refer to a level of impact under CEQA. 21 California Department of Conservation. (2015). CGS Information Warehouse: Regulatory Maps. Special Report 143, Plate 4-1. Retrieved from http://maps.conservation.ca.gov/cgs/informationwarehouse/.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

7.11 WILDFIRE

7.11a Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?

7.11b Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

7.11c Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?

7.11d Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The Project site is in a local responsibility area and classified as Non-Very High Fire Hazard Severity Zone (Non-VHFHSZ).22 Because the Project is not located in or near a State responsibility area or lands classified as VHFHZ, the Project would result in no impact concerning wildfire.
22 CalFire. (September 2011). Los Angeles County FHSZ Map. Retrieved from https://osfm.fire.ca.gov/media/7280/losangelescounty.pdf.

Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 7.0
Draft Environmental Impact Report Effects Found Not to be Significant

This page intentionally left blank.

Kimley>>>Horn

8.0 LIST OF PREPARERS
Normandie Crossing Specific Plan Project Section 8.0
Draft Environmental Impact Report List of Preparers

8.0 LIST OF PREPARERS

8.1 LEAD AGENCY

CITY OF GARDENA
1700 West 162nd Street
Gardena, California 90247-3732
Greg Tsujiuchi, Community Development Director
Amanda Acuna, Senior Planner, Community Development Department Lisa Kranitz, Assistant City Attorney (Law Offices of Lisa E. Kranitz)

8.2 APPLICANT

SAIKO INVESTMENT CORPORATION
1590 Rosecrans Avenue, Suite D-303
Manhattan Beach, California 90266
Fred Shaffer, President

8.3 LEAD CONSULTANT
KIMLEY-HORN AND ASSOCIATES, INC.
1100 W Town and Country Road, Suite 700
Orange, California 92868
Rita Garcia, Project Manager
Olivia Chan, Technical Manager (Energy Analysis and Air Quality, GHG Emissions, and Noise Peer Review)
Rajat Parashar, Senior Transportation Planner (Transportation Peer Review) Jennifer Steen, AICP (Hazardous Materials Peer Review)
Heather Boland, Environmental Analyst
Sarah Miller, Environmental Analyst
James Thomas, Environmental Analyst
Eric Wang, Environmental Analyst
Amanda McCallum, Document Production
Lauren Jumanan, P.E., Railroad Track Infrastructure
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 8.0
Draft Environmental Impact Report List of Preparers

8.4 TECHNICAL CONSULTANTS
Ramboll Americas Engineering Solutions, Inc. (Air Quality/Greenhouse Gas Emissions) 5 Park Plaza, Suite 500
Irvine, California 92614
Eric C. Lu, Principal
Air Quality Dynamics (Health Risk Assessment)
23150 Ostronic Drive
Woodland Hills, California 91367
Bill Piazza
BCR Consulting LLC (Cultural Resources Peer Review and Historical Resources Assessment) 505 West 8th Street
Claremont, California 91711
David Brunzell, Principal Investigator/Archaeologist
Acoustical Engineering Services, Inc. (Noise)
22801 Crespi Street
Woodland Hills, California 91364
Amir Yazdanniyaz
Hamilton & Associates (Geology and Soils)
1641 Border Avenue
Torrance, California 90501
David T. Hamilton, PE, GE
Iwasa Consulting (Geology and Soils Peer Review)
25 Crescent Drive, #A349
Pleasant Hill, California 94523
Dean H. Iwasa, PE, GE
Hillmann Consulting LLC (Phase II Peer Review)
1745 W. Orangewood Avenue Suite #201
Orange, California 92868
Dan Louks, Professional Geologist 4883
Kimley>>>Horn
Normandie Crossing Specific Plan Project Section 8.0
Draft Environmental Impact Report List of Preparers

Hillmann Consulting LLC (Vapor Intrusion Risk Evaluation) 1745 W. Orangewood Avenue Suite #201
Orange, California 92868
Dan Louks, Professional Geologist 4883
Fuscoe Engineering, Inc. (Hydrology and Drainage, Civil and Utilities) 600 Wilshire Boulevard, Suite 1470,
Los Angeles, California 90017
Keith Malloy, PE, Project Manager
Fehr & Peers (Transportation)
100 Oceangate, Suite 550
Long Beach, California 90802
Emily Finkel, Senior Transportation Planner
SWCA Environmental Consultants (Tribal Cultural and Cultural Resources) 51 W Dayton Street
Pasadena, California 91105
Aaron Elzinga M.A., RPA, Katie Dumm M.Sc., RPA, and Liz Denniston, M.A. RPA Kimley>>>Horn

REVISED AND UPDATED FINAL

ENVIRONMENTAL IMPACT REPORT
SCH # 2023050241

NORMANDIE CROSSING

SPECIFIC PLAN PROJECT

LEAD AGENCY

CITY OF GARDENA
Greg Tsujiuchi - Community Development Director
Amanda Acuna – Community Development Manager
Community Development Department
1700 West 162nd Street
Gardena, California 90247
310.217.9593

APPLICANT

CONSULTANT
KIMLEY-HORN AND ASSOCIATES, INC.

Rita Garcia – Project Manager
1100 W Town and Country Road, Suite 700
Orange, California 92868
714.786.6116
NOVEMBER 2024
Normandie Crossing Specific Plan Project
Revised and Updated Final Environmental Impact Report Table of Contents Page i November 2024
Table of Contents

1.0 INTRODUCTION ............................................................................................................1-1

1.1 Public Review Draft Environmental Impact Report............................................1-1

1.2 Final Environmental Impact Report...................................................................1-1

2.0 COMMENT LETTERS AND RESPONSES...........................................................................2-1

2.1 Lists of Public Agencies, Persons, and Organizations Commenting on the DEIR .2-1

2.2 Comment Letters and Responses......................................................................2-2

3.0 ERRATA TO THE DRAFT EIR ...........................................................................................3-1

3.1 Public Review Draft Environmental Impact Report............................................3-1

4.0 MITIGATION MONITORING AND REPORTING PROGRAM ..............................................4-1 APPENDICES (Hyperlinked)
Appendix 4.7-2: Water Resources Analysis
Appendix 4.9-2: Operational Noise Analysis
Appendix 4.13-2: Local Transportation Assessment
Appendix 6.0-1: Air Quality, Greenhouse Gas, and Noise Modeling Data Appendix 6.0-2: Preliminary Geotechnical Report
Appendix 6.0-3: VIRE
Normandie Crossing Specific Plan Project Section 1.0
Revised and Updated Final Environmental Impact Report Introduction

1.0 INTRODUCTION

1.1. PUBLIC REVIEW DRAFT ENVIRONMENTAL IMPACT
REPORT
In accordance with State California Environmental Quality Act (CEQA) Guidelines §§ 15120 through 15132, the City of Gardena prepared a Draft EIR (DEIR) for the Normandie Crossing Specific Plan Project (SCH No. 2023050241). The DEIR was made available for review and comment to the public, responsible and trustee agencies, interested groups, and organizations for a 45-day period that occurred between December 4, 2023 and January 20, 2024. The DEIR was also made available directly to State agencies through the State Clearinghouse, Office of Planning and Research.

The Project was heard before the Planning Commission at the March 19, 2024, public hearing. As a result of input received from the community through the public hearing and public review processes, as well as from a follow-up meeting the Applicant had with neighborhood residents following the Planning Commission hearing, the Applicant proposed plans for a revised project which is now included as the Community Input Alternative. This new Alternative addresses the following primary concerns that were raised by the community and neighborhood residents:
density; and apartment building height and mass, parking and the alignment of the driveway on 170th Street. This revised and Updated Final Environmental Impact Report (FEIR) includes the Community Input Alternative in addition to responses to comments received after the public comment period closed on January 20, 2024.

1.2. FINAL ENVIRONMENTAL IMPACT REPORT
Before approving a project, CEQA requires that the Lead Agency prepare and certify an FEIR. The contents of a FEIR are specified in State CEQA Guidelines § 15132, as follows:
(a) The draft EIR or a revision of the draft.
(b) Comments and recommendations received on the draft EIR either verbatim or in summary. (c) A list of persons, organizations, and public agencies commenting on the draft EIR. (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
(e) Any other information added by the Lead Agency.

The FEIR allows the public and Lead Agency an opportunity to review DEIR revisions, the comments and responses, and other EIR components, such as the Mitigation Monitoring and Reporting Program (MMRP) before Project approval. The FEIR serves as the environmental Normandie Crossing Specific Plan Project Section 1.0
Revised and Updated Final Environmental Impact Report Introduction

document to support a decision on the proposed Project. This FEIR document consists of the following components:
 Section 1.0: Introduction,
 Section 2.0: Comment Letters and Responses,
 Section 3.0: Errata to the DEIR, and
 Section 4.0: Mitigation Monitoring and Reporting Program.

It is noted, none of the corrections/clarifications identified in this FEIR constitute “significant new information” pursuant to State CEQA Guidelines § 15088.5. The new information added merely clarifies/amplifies and makes insignificant modifications to the DEIR. The corrections/ clarifications do not involve changes in the Project or significant new information. They do not result in a new impact or substantial increase in the severity of an environmental impact identified in the DEIR. No new or substantially different mitigation measures than those identified in the DEIR are required. Moreover, the new information does not affect the DEIR’s overall conclusions. Therefore, recirculation of the DEIR is not warranted.

Pursuant to State CEQA Guidelines § 15090, prior to approving a project, the Lead Agency must certify that:

1. The Final EIR has been completed in compliance with CEQA;

2. The Final EIR was presented to the decision-making body of the Lead Agency, and that the decision-making body reviewed and considered the information in the Final EIR prior to approving the Project; and

3. The Final EIR reflects the Lead Agency’s independent judgment and analysis.

These certifications, or “Findings of Fact,” are not part of the FEIR, but can be found in the Resolution certifying the EIR. Both the FEIR and the Findings will be submitted to the Lead Agency for consideration of the proposed Project.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

2.0 COMMENT LETTERS AND RESPONSES

2.1 LISTS OF PUBLIC AGENCIES, PERSONS, AND

ORGANIZATIONS COMMENTING ON THE DEIR
In accordance with State CEQA Guidelines § 15132, the public agencies, and persons and organizations commenting on the DEIR are listed below in Table 2-1: List of Commenting Public Agencies and Persons and Organizations. As indicated in Table 2-1, comments on the DEIR were received from three public agencies, one organization, and three residents.

Table 2-1: List of Commenting Public Agencies And Persons And Organizations No. Date Author Author Title Agency/Organization
Public Agencies
A1 01/04/24 Ronald M. Durbin
Chief, Forestry
Division, Prevention
Services Bureau
County of Los Angeles Fire
Department
A2 01/17/24 Frances Duong Acting LDR/CEQA
Branch Chief
State of California
Department of Transportation
District 7
A3 01/23/24 Curtis M. Welty, PG Associate Oil and
Gas Engineer
State of California
Department of Conservation
Geologic Energy Management
Division
Persons and Organizations
A4 01/19/24 Stephanie Papayanis Attorney Western States Regional Council of Carpenters
A5 02/25/24 Tish McCauley Resident N/A
A6 02/18/24 Keren Hwang Resident N/A
A7 02/01/24 Kevin Collier Resident N/A
A8 03/13/24 Donnetta Jalomo Resident N/A
A9 03/04/24 Kevin Collier Resident N/A
A10 3/18/24 Mitchell M. Tsai Attorney Western States Regional Council of Carpenters
A11 03/19/24 Brenda Rodriguez Resident N/A
A12 03/19/24 Dalia R. Juarez Resident N/A
A13 03/19/24 Terri C. Resident N/A
A14 03/19/24 Yvonne & Arthur
Acosta Residents N/A
A15 03/19/24 Ace Rose Resident N/A
Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Table 2-1: List of Commenting Public Agencies And Persons And Organizations No. Date Author Author Title Agency/Organization
A16 03/20/24 Brandon Smith Residents N/A
A17 03/20/24 Gloria Mazzocco Homeowner N/A
A18 03/20/24 Liliana Arreguin Resident N/A
A19 04/02/24 Various Residents N/A
A20 03/19/24 Layne Fajeau Attorney Supporters Alliance for Environmental Responsibility
A21 03/27/24 Bryan Flynn Attorney Supporters Alliance for Environmental Responsibility
A22 10/23/24 Note to File N/A N/A

2.2 COMMENT LETTERS AND RESPONSES
In compliance with State CEQA Guidelines § 15132, this Section includes all comments received on the DEIR, along with the City of Gardena’s responses to significant environmental points raised by those comments. The comments are grouped according to author (i.e., Public Agencies and Persons and Organizations). Each individual comment letter listed in Table 2-1 is reproduced on the following pages. Each letter and the individual comments in each letter have been consecutively numbered for ease of reference. Following each comment letter, a response is provided for each comment raising substantive environmental issues. The responses are numbered and correlated to the bracketed and identified portions of each comment letter.

Responses may include text revisions to clarify or amplify information in the DEIR, as a result of environmental points issues in the comments, or as requested by the Lead Agency. A response to a comment requiring DEIR revisions presents the relevant DEIR text in a box, with deleted text indicated by strike through and added text indicated by double underline, as follows:

Deleted DEIR text Added DEIR text
DEIR text revisions are also presented in FEIR Section 3.0: Errata to the Draft EIR.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A1 – County of Los Angeles Fire Department

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A1 – County of Los Angeles Fire Department

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A1 – County of Los Angeles Fire Department

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A1
Ronald M. Durbin, Chief, Forestry Division, Prevention Services Bureau County of Los Angeles Fire Department
January 4, 2024
A1-1 This comment from the Planning Division states that the fire protection for the area appears to be adequate for existing development. This comment also notes that each development (including this Project) would increase the demand on existing resources.

As noted in DEIR Section 4.11: Public Services, the Project would result in population growth that would incrementally increase the demand for fire protection in the area.

However, as the Project site is currently served by fire protection services and is in a suburban setting where fire protection services and equipment/infrastructure are already in place, the Project does not propose and would not require new or physically altered fire protection facilities to maintain fire service objectives. Therefore, impacts concerning fire protection would be less than significant. No further discussion is necessary.

A1-2 This comment provides the Land Development Unit’s comments on the DEIR. The comment states that the Project development must comply with all applicable code and ordinance requirements for construction, access, water mains, fire flows, and fire hydrants.

As stated in DEIR Section 4.11, the Project would be constructed with fire safety features in compliance with applicable provisions of the adopted Los Angeles County Fire Code, ordinances, and standard conditions regarding fire prevention and suppression measures related to water improvement plans, fire hydrants, fire access, and water availability (DEIR Page 4.11-6). The Los Angeles County Fire Department (LACFD) Fire Prevention Division has reviewed the Project, including the Site Plan, and provided requirements regarding firefighter and fire truck access, water system, fire flow, fire hydrant type/location, building address numbers, etc., which would enhance the Project’s fire protection. The comment notes that the corrections and comments provided to the Applicant have not changed. The Applicant is required to continue to work with Fire Prevention Engineering to satisfy all requirements issued during the Fire Prevention Engineering Section’s Building Plan Check Review. It is noted, LACFD also reviewed the Project’s NOP and provided Conditions of Approval, which the Project would be required to comply with. The comment also provides contact information for further communication. This comment does not address the DEIR’s adequacy or raise a significant environmental issue.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

The Applicant had several meetings with LACFD to address its concerns and revised the Conceptual Site Plan. According to the Applicant, these plans have been reviewed and approved by the LACFD Fire Prevention Division. As such, no further response is necessary.

A1-3 This comment provides the Forestry Division’s comments on the DEIR and details the Division’s responsibilities within the LACFD. The comment requests that potential impacts within their responsibilities be addressed. Watershed management and erosion control are discussed in DEIR Section 4.7: Hydrology and Water Quality and archeological and cultural resources are discussed in DEIR Section 4.2: Cultural Resources. Impacts concerning these resources are addressed and, where a potential impact would occur, mitigation is incorporated. Therefore, with mitigation incorporated, impacts concerning issues would be less than significant. Regarding impacts to oak trees, fire hazards, and endangered species, as discussed in DEIR Section 7.0: Effects Found Not to be Significant, there are no trees, fire hazards, or endangered species on or adjacent to the Project site. No further discussion is necessary.

A1-4 This comment provides the Health Hazardous Materials Division’s comments on the DEIR and recommends that a soil management plant (SMP) be implemented at the Project site prior to grading as an additional mitigation measure. As discussed in DEIR Section 4.6: Hazards and Hazardous Materials, MM HAZ-1 requires a Construction Management Plan to be prepared prior to issuance of demolition permits which would address potential undocumented contaminated soil. MM HAZ-1 sufficiently addresses the Health Hazardous Materials Division’s request for a SMP. Thus, no modifications to MM HAZ-1 are required. No further discussion is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A2 – State of California Department of Transportation District 7

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A2 – State of California Department of Transportation District 7

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A2 – State of California Department of Transportation District 7

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A2 – State of California Department of Transportation District 7

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A2
Frances Duong, Acting LDR/CEQA Branch Chief
State of California Department of Transportation, District 7 January 17, 2024
A2-1 This comment introduces the California Department of Transportation (Caltrans) response and summarizes the Project. This comment does not address DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

A2-2 This comment provides the Project’s environmental setting within the context of transit services. This comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

A2-3 This comment provides the Project’s environmental setting within the context of pedestrian and bicycle facilities. This comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

A2-4 This comment summarizes vehicle miles travelled (VMT) screening criteria under Senate Bill (SB) 743 and notes that the Project can be screened out from a full VMT analysis based on the City’s transportation guidelines and impact thresholds. The commenter further notes the DEIR does not show why other criteria are not considered (specifically, Criteria 1 and 3). Therefore, the comment recommends a VMT analysis be performed to “preempt any potential environmental challenges from third parties, ensuring a thorough evaluation of transportation impacts.” City VMT guidelines do not require a project to meet multiple criteria to screen out from a VMT analysis. The Project meets a criterion in the City guidelines and therefore would have a less than significant impact concerning VMT. However, DEIR Appendix

4.13-1: CEQA Transportation Study, specifically states that Criterion 1 does not apply because the Project would generate more than 110 daily trips based on the 11th Edition ITE Trip Generation Manual. Additionally, DEIR Appendix 4.13-1 specifies that Criterion 3 does not apply because the Project is not located in proximity to high quality transit. Therefore, additional analysis concerning VMT is not required or warranted. No further response is necessary.

A2-5 This comment encourages the City to evaluate transportation demand management (TDM) strategies and intelligent transportation system (ITS) applications to better manage its transportation network. The Project implements TDM strategies and ITS applications via features such as unbundled parking, additional bicycle parking, and a Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

one-month free transit pass to help renters become acquainted with public transit and pre-leasing for area employees. No further response is necessary.

A2-6 This comment recommends a mitigation measure concerning VMT which would require a VMT analysis to be done after development is completed to help validate the City’s VMT traffic model results. CEQA’s purpose is to inform government decisionmakers and the public of the potential environmental effects and to prevent significant, avoidable environmental damage. CEQA does not require a project to “look back” or “prove itself” after approval. Additionally, the Project would result in a less than significant impact concerning VMT, therefore, no mitigation is required; see DEIR Impact 4.13-2. Therefore, no mitigation measures are required under CEQA. No further response is necessary.

A2-7 The comment expresses concern concerning the DEIR’s adequacy in addressing a previous comment requesting a safety analysis for highway off-ramps near the Project as neither transportation appendices (i.e., DEIR Appendix 4.13-1 or DEIR Appendix

4.13-2: Local Transportation Study) appear to address their previous comment. The comment reminds the Applicant that traffic safety is a CEQA matter and therefore should be considered in the analysis.

Additional discussion has been added to the Local Transportation Assessment (DEIR Appendix 4.13-2); see below. The Project would not result in safety impacts to Caltrans facilities due to the small number of trips to these facilities and distance to these facilities.

DEIR Appendix 4.13-2: Local Transportation Assessment
DEIR Page 9

3.3.1 Freeway Ramp & Intersection Queueing at State Facilities As detailed below in section 3.7, based on the Project’s estimates, trip generation and distribution, few trips are expected at the I-405 off-ramps to Normandie/190th or the I-110 off-ramps to Redondo Beach Boulevard (<25 peak hour trips at each location). Therefore, the Project is not expected to add two or more car lengths to these off-ramp queues during peak hours, exacerbate potentially unsafe ramp conditions at these locations (if such conditions exist or are projected to occur in the opening year of the Project), and analysis is not needed. At the intersection of SR91 and Vermont Avenue, Project traffic is expected to primarily be eastbound and westbound through movements since primary Project access is from Normandie Avenue, where most turning movements would Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

occur. As such, the Project is not expected to add substantial traffic to any left or right-turning movements at the intersection of SR-91 and Vermont Avenue, and the Project is not expected to materially affect the utilization of turn pocket storage that would lead to an impedance of through traffic.

Therefore, no further analysis is needed related to queueing at these locations.

3.3.2 Pedestrian & Bicycle Volumes at State Facilities
As detailed below in section 3.7, 5% of the Project’s net new trips are expected to be walking or biking in nature, which may also include a subsequent trip on transit. This amounts to less than 10 trips during either peak hour in total. Most of these non-transit biking and walking trips are expected to be local in nature, accessing nearby schools and businesses within 0.5 miles of the Project Site. Substantial bicycle and pedestrian trips generated by the Project are not expected to occur at the SR-91 and Vermont Avenue, I-405 off-ramps at Normandie/190th, or I-110 off-ramps at Redondo Beach Boulevard intersections given how far away they are from the Project Site. SR-91 and Vermont Avenue is located 0.8 miles from the Project Site, while the other two intersections are located over one mile from the Project Site. Because these locations are outside of the Project Study Area, Multi-Modal Conflict Analyses and/or Complete Street Access considerations should not be necessary.

A2-8 This comment provides resources for guidance on performing VMT safety analysis and notes that use of oversized transport vehicles on State highways would require a Caltrans permit. This comment does not address the adequacy or raise a significant environmental issue. As such, no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A3 – State of California Department of Conservation Geologic Energy Management Division

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A3 – State of California Department of Conservation Geologic Energy Management Division

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A3
Curtis M. Welty PG, Associate Oil and Gas Engineer
State of California Department of Conservation Geologic Energy Management Division January 23, 2024
A3-1 This comment introduces the California Department of Conservation – Geologic Energy Management Division (CalGEM) and summarizes the department’s jurisdictional authority. This comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

A3-2 This comment provides a revision to the DEIR’s existing setting concerning nearby existing wells and notes the adjacent plugged well (an abandoned “wildcat” well identified as “Gardena E.H.”) mapped outside the Project is within the Project site (approximately 121 feet north, 55 feet east). This comment is noted, and a minor revision to the existing setting and impact analysis in DEIR Section 4.6: Hazards and Hazardous Materials is included as shown below.

DEIR Section 4.6: Hazards and Hazardous Materials
DEIR Page 4.6-9
According to California Division of Oil, Gas and Geothermal Resources (CalGEM), no oil or gas wells are located on one abandoned “dry hole” “wildcat” well, identified as “Gardena E.H,” exists 121 feet north and 55 feet east from the intersection of 170th Street and Brighton Way thereby placing the well within the parking area east of the southernmost building. There are no oil or gas wells located or immediately adjacent to the site. The closest well was identified to be located approximately 480 feet south of the site and is reported as “abandoned”.

DEIR Page 4.6-21
As previously addressed, the Phase I ESAs identified various onsite RECs associated with past uses of the Project site. As discussed in Section 4.6.1:

Existing Setting, there is an existing abandoned well within the Project site where townhomes are proposed. This well is already abandoned and would be capped during Project construction in coordination with CALGEM.

A3-3 This comment reiterates the requirement to contact the Division’s district office to obtain information on the requirements and approval of remedial operations if any well is damaged or uncovered during Project operations. Further, the comment recommends that “a diligent effort be made to avoid building over any plugged and Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

abandoned well.” This comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A4 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A4
Stephanie Papayanis, Attorney
Western States Regional Council of Carpenters
January 19, 2024
A4-1 This comment is introductory in nature and states that the Law Office of Mitchell M.

Tsai has submitted comments on behalf of the Western States Regional Council of Carpenters. No further response is necessary.

A4-2 The comment states that the commenter reserves the right to supplement the comments and incorporates by reference all comments regarding the EIR. The comment is noted. No further response is necessary.

A4-3 The commenter requests receipt of further notices referring to or related to the Project. The City acknowledges the commenter’s request and will include the commenter on the mailing list for future Project-related CEQA notices. No further response is necessary.

A4-4 The commenter requests that the City require the Project to be built using local workers who have graduated from a specified apprenticeship program.

The Project includes approval of a Development Agreement which includes a requirement that the Applicant implement a local hiring policy as specified in Development Agreement Exhibit D as a public benefit. The commenter does not explain or provide any evidence, let alone substantial evidence, as to how using labor that has graduated from a state-approved apprenticeship training program, or who are registered apprentices in such a program, creates any environmental benefits. The commenter’s request does not address the DEIR’s adequacy or identify an environmental issue. As such, no further response is necessary.

A4-5 The commenter suggests that using local workers (i.e., residing within 10.0 miles of the Project site) would reduce VMT, reduce greenhouse gas emissions(GHG), improve jobs/housing balance, and the Project’s economic performance. See Response A4-4, noting that the Development Agreement already requires utilizing a local workforce where possible as a public benefit. Additionally, see Responses A4-6 thru A4-8. The commenter also suggests that local hire provisions can improve the positive economic impact of the Specific Plan. Economics are not a CEQA issue. Nonetheless, it is noted that Development Agreement Exhibit D also includes a “buy local” provision.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

A4-6
Thru
A4-8 The commenter references an attachment to the comment letter from Soil Water Air Protection Enterprise (SWAPE) (“SWAPE Letter”; March 8, 2021) and refers the reader to the SWAPE Letter for commentary and analysis related to local hire requirements related to GHG modeling. This commenter alleges that workforce requirements promote the development of skilled trades that yield sustainable economic development. The comment states that labor should be considered an investment and well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.

This commenter also alleges that workforce policies have significant environmental benefits and that they improve an area’s jobs-housing balance, and decrease the amount and length of job commutes and the associated greenhouse gas emissions.

The commenter refers to a 2021 South Coast Air Quality Management District statement that the use of a local state-certified apprenticeship program can result in air pollutant reductions. This comment alleges that local hire mandates and skill training are critical facets of a strategy to reduce VMT. The commenter also references a 2006 article from the Journal of the American Planning Association to note the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.

See Response A4-4, noting that the Development Agreement already requires utilizing a local workforce where possible as a public benefit. Additionally, as mentioned above, sustainable economic development is not an environmental issue, as such no further response is necessary.

The commenter included a letter from SWAPE dated March 8, 2021 (which predates the NOP’s release), which discusses GHG emissions associated with trip lengths for construction workers traveling to a job site. The SWAPE letter provided calculations for GHG emissions reductions resulting from local hire provisions being applied to the referenced project’s construction. The SWAPE letter concludes that if a local hire provision with a 10.0-mile radius were implemented, the GHG emissions associated with the Project’s construction would decrease. The SWAPE letter states that it ran a model “reducing all worker trip lengths to 10 miles….” Therefore, the SWAPE letter assumes that a local hire program would produce 100 percent local residents as a project’s construction workforce while being located within 10.0 miles of a project site. It is noted that the SWAPE letter and the calculations provided used data related to a different project in a separate jurisdiction, the Village South Specific Plan in the City of Claremont, respectively. The calculations also use prior versions of CalEEMod Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

and EMFAC. Therefore, the calculations do not pertain to the Project and are not based on correct modeling.

The commenter also relies on a 2008 California Roundtable discussion noting that people who live and work in the same jurisdiction could include potential reductions in VMT and vehicle hours traveled.

The DEIR concluded that the Project would result in less than significant impacts concerning GHG emissions and VMT and therefore no further mitigation would be required; see DEIR Section 4.5: Greenhouse Gas Emissions and DEIR Section 4.13:

Transportation, respectively. As impacts related to GHG and VMT are less than significant, there is no obligation pursuant to CEQA to further reduce these potential impacts. Additionally, the commenter does not provide any substantial evidence (only conclusory opinions) to dispute the DEIR’s analysis to demonstrate that local hire mandates and skill-training policies would specifically reduce VMT. These comments do not relate to the DEIR’s adequacy or content, do not provide new information or evidence related to the DEIR’s analysis, and do not affect the DEIR’s completed analysis or conclusions.

A4-9 This comment provides background information concerning the Affordable Housing and High Road Jobs Act of 2022 and reiterates its comments that the City should consider utilizing local workforce policies to benefit the local area economically and to mitigate GHG emissions, improve air quality, and reduce transportation impacts.

The commenter’s opinions are noted; see Response A4-4 thru A4-8.

A4-10 The comment suggests the incorporation of training requirements for construction activities to prevent community spread of COVID-19 and other infectious diseases during Project construction and notes that such requirements include construction site design requirements, testing procedures, and infectious disease preparedness and response timing.

COVID-19 is a public health issue, not a Project-related CEQA effect. State and local governments implement regulations and enforce safe working conditions for construction sites. Project construction activities would be subject to compliance with all applicable safety regulations if COVID-19 persists at the commencement of construction of any Project phase. Construction workers would be required to comply with any guidelines and requirements issued by the State of California, the County of Los Angeles, and the City of Gardena, as well as any additional safety measures required by the Project site’s construction manager. This comment does not relate to the DEIR’s adequacy or content, does not provide new information or evidence Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

related to the DEIR’s analysis, and does not affect the DEIR’s completed analysis or conclusions. No further response is necessary.

A4-11 This comment provides background to CEQA and the fair argument test regarding an EIR’s analysis. No further response is necessary.

A4-12 This comment provides a background to the standards and purposes of Phase I, II, and III ESAs and questions the adequacy of the DEIR’s analysis of hazardous materials due to the Phase I ESA’s using an older assessment standard.

ASTM E1527-13 already includes “likely presence” as a test, as the commenter notes on page 13. Furthermore, the use of older ASTM standard would not change conclusion. As the commenter notes, the site was identified as a REC, so the analysis and conclusion (and thus mitigation) would remain unchanged with an updated Phase I. As analyzed in DEIR Impact 4.6-1, the Project would comply with COA HAZ-1, which requires an asbestos survey prior to demolition and COA HAZ-2 which requires independent evaluation for lead-based paint (LBP) to address potential impacts to construction workers during demolition of structures which could include asbestos or LBP. Furthermore, the Project would be required to prepare a Construction Management Plan per MM HAZ-1, which would mitigate construction impacts from undocumented contaminants to less than significant.

A4-13 This comment questions the relevancy of the DEIR’s Phase I ESA analysis as they are outdated and use older, less stringent standards rather than the newer and current standard (ASTM-E1627-13 vs. ASTM E1527-21).

Please see Response A4-12 above.

A4-14 This comment notes that there is potential for the presence of asbestos-containing materials (ACM) and/or LBP citing the North Phase I ESA (DEIR Appendix 4.6-1). The comment further discusses the harms of ACM and LBP to human health and concludes that these risks should be considered significant and concludes that the DEIR should be revised and recirculated “to thoroughly assess the potential hazards impact of the Project and its required demolition activities and potential handling of asbestos and lead-based paint and mitigate those impacts to a level of insignificance.” As discussed in DEIR Section 4.6, the Phase I ESA notes the potential presence of ACM and LBP and designates existing buildings as a REC. However, as discussed in DEIR Section 4.6, these potential impacts would be addressed by COA HAZ-1 and COA HAZ2, which would require an asbestos survey prior to demolition and LBP testing if paint Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

is separated from building materials during demolition, thereby reducing the potential impacts to less than significant. No further response is necessary.

A4-15 The comment cites the DEIR’s construction nose analysis and alleges MM NOI-1 and NOI-2 are insufficient in addressing noise impacts concerning the Project. The comment suggests the City revise and recirculate the DEIR to “adequately mitigate the Project’s significant noise impacts,” but provides no suggestions or mitigation measures to reduce the impact to less than significant.

As discussed in DEIR Section 4.9: Noise, noise impacts from construction would be considered significant and unavoidable. As noted in DEIR Section 4.9, the Project’s construction activities would be exempt from the City’s noise standards with certain restrictions pursuant to Gardena Municipal Code (GMC) § 8.336.080 (construction activities would not take place during City-set days/hours). However, construction noise levels have been conservatively analyzed to the City’s operational noise standards. Mitigation measures NOI-1 and NOI-2 would reduce construction noise by establishing a temporary sound barrier and requiring all power construction equipment (including combustion engines), fixed or mobile to be equipped and maintained with state-of-the-art noise shielding and muffling devices. Nonetheless, impacts would remain significant and unavoidable. The commenter does not provide any suggested mitigation measures which could reduce construction noise below the operational noise standards. As discussed in DEIR Section 6.5: Alternatives Considered but Rejected, unless demolition is avoided (and the existing structures remain), no modification of the Project would avoid the Project’s significant unavoidable construction noise impacts. This was rejected as infeasible, as it would preclude development throughout the majority of the Project site.

A4-16 The comment summarizes and concludes the letter by suggesting the City should revise and recirculate the DEIR to address “comments and issues identified in this letter.” Further, the comment suggests the City “should require additional environmental studies be performed to comply with CEQA and other state laws.” Please see Responses A4.4 - A4.15 above. No further response is necessary.

A4-17 This comment includes attachments referenced in the comment letter, including a March 8, 2021 SWAPE letter to Mitchem M. Tsai RE: Local Hire Requirements and Considerations for Greenhouse Gas Modeling and the professional work experiences for two experts (on unrelated projects). As such, no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A5 – Tish McCauley

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A5
Tish McCauley, Resident
February 25, 2024
A5-1 This comment is introductory in nature and does not address an environmental topic.

As such, no response is required.

A5-2 This comment notes concerns with existing traffic volumes on South Normandie Avenue and how Project trips would affect these traffic volumes. Specifically, the commenter notes existing traffic congestion during school drop-off and pick-up times Monday through Friday. The Project would increase trips on South Normandie Avenue. However, the Project has been designed to minimize increased trips through TDM strategies and ITS applications. These include features such as unbundled parking, additional bicycle parking, and a one-month free transit pass to help renters become acquainted with public transit and pre-leasing for area employees.

The commenter is concerned that Project traffic would use West 170th Street to avoid congestion on South Normandie Avenue. The townhome component has an entry/exit onto West 170th Street as well as West 169th Street. The apartment component does not have access to West 170th Street. Thus, it is likely only townhome residents would use West 170th Street. Additionally, the townhome component also has an entry/exit on West 169th Street, thus, only the townhomes closer to West 170th Street would use this entry/exit.

This comment also notes another residential development on South Normandie Avenue and Magnolia Avenue. As shown on DEIR Appendix 4.13-2 Figure 3 and listed in DEIR Appendix 4.13-2 Table 4, this future development is analyzed as Related Project #6.

A5-3 This comment notes concerns with mass and height. The Project has been designed to buffer surrounding land uses from the apartment component by including threestory townhomes at the perimeter of the Project site, adjacent to existing residential uses. There are already two-story residential uses and a multi-family development on West 169th Street north of the Project site, thus, the Project would be similar in character and use to surrounding land uses.

Additionally, in response to community feedback, the “Community Input” Alternative, which would reduce the apartment building height from seven to five above ground Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

stories, has been analyzed in DEIR Section 6.0: Alternatives; see FEIR Section 3.0:

Errata to the Draft EIR for a complete description of the Community Input Alternative.

A5-4 This comment notes concerns with the apartment building height and breeze to residential uses east of the Project site. It is noted that South Normandie Avenue is east of the Project site and the apartment building would be more than 80 feet away from the residences to the east. Additionally, a single building is unlikely to interfere with breeze. Furthermore, breeze and air conditioning are not an environmental concern. Therefore, no further response is necessary.

A5-5 This comment notes concerns with street parking by Project residents on surrounding streets. The Project proposes 399 parking spaces for the apartment building and 160 parking spaces for the townhomes. Based on the provided parking and connection to surrounding public transit, it is not anticipated that Project residents would park on surrounding streets. Furthermore, regular street parking by Project residents would also be inconvenient, as Project residents would need to carry belongings to and from the Project site. Finally, parking is not an environmental concern, therefore, no further response is necessary.

A5-6 This comment notes the classification of Brighton Way as an alley. The DEIR already refers to this street as an alley throughout (see DEIR Page 2-1). Therefore, no further response is required. The comment also says that the alley would be used as an entrance/exit. However, the Conceptual Site Plan clearly showsthe entrance and exits to the Project site are not through the alley.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A6 – Keren Hwang

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A6
Keren Hwang, Resident
February 18, 2024
A6-1 This comment states concern over traffic on South Normandie Avenue. As shown in DEIR Appendix 4.13-2 Table 7, all intersections operate at acceptable levels of service except for the South Normandie Avenue at West 169th Street intersection. It is typical for minor street stop-controlled intersections to operate at lower levels of service.

The commenter incorrectly states that South Normandie Avenue is two lanes. South Normandie Avenue is a four-lane street with left turn pockets to turn west at West 169th Street and to turn east at West 170th Street.

A6-2 This comment states concern over the apartment building height. A building of similar height is under construction at 12850 Crenshaw Boulevard, at the City’s northwestern extent. Given the blighted condition of the existing site, redevelopment would improve the site’s visual condition. Additionally, the Project’s building heights would be consistent with the development standards in the proposed Normandie Crossing Specific Plan. For further discussion on building height, see Response A8-1.

A6-3 This comment states concern over earthquakes. As discussed in DEIR Section 7, the Project site is not within an Alquist-Priolo fault zone. Additionally, Project’s Preliminary Geotechnical Investigation; see DEIR Appendix 4.4-1: Preliminary Geotechnical Investigation) was prepared and found that risk of surface fault rupture was low. The geotechnical report contains recommendations which the Applicant is required to follow in accordance with GMC § 18.42.200A. Therefore, no impact would occur and no mitigation was required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A7 – Kevin Collier

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A7
Kevin Collier, Resident
February 1, 2024
A7-1 This comment requests clarification on the electric vehicle (EV) charging provided by the Project. In conformance with the Specific Plan standards and the latest Title 24 requirements, the apartment building would provide 20 stalls with EV chargers installed, 40 spaces that are EV capable with electrical panel space and load capacity, and 100 spaces that are EV ready with branch circuit, raceway, and receptacles. Each townhome unit would have one EV ready space within each garage.

A7-2 This comment requests clarification on the total parking provided by the Project. The Project includes four types of parking: standard, accessible (for compliance with the Americans with Disabilities Act [ADA] requirements), EV parking as described above, and tandem parking (tandem refers to two spaces that in front of each other, rather than side by side). Each tandem space can accommodate two vehicles. The Project proposes the following parking:
• Level 1: 195 spaces, 155 of which would be standard, 8 of which would be handicapped, and 32 of which would be tandem;
• Level 2: 204 spaces, 170 of which would be standard and another 34 would be tandem. The EV spaces referred to in Response A7-1 would be spread between the two floors.

A7-3 This comment suggests alternative means to incentivize public transit. The commenter begins by suggesting issuing street parking permits to surrounding residents. The Applicant cannot issue parking permits to surrounding residents, however, this suggestion will be passed on to the City Council. Regular street parking by Project residents would also be inconvenient, as Project residents would need to carry belongings to and from the apartment component daily.

The next alternative offered is to provide free garage parking to apartment residents.

Providing free garage parking to residents would not incentivize use of public transport, thus, this suggestion is not feasible. Furthermore, Assembly Bill (AB) 1317 requires all residential parking to be unbundled from rent for any residential use of 16 or more units that are issued a certificate of occupancy after January 1, 2025. The Project apartment component includes 328 units and would be issued a certificate of occupancy after January 1, 2025; thus, the Project would be required to comply with AB 1317 and prohibited from providing free garage parking.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

The final alternative offered is to increase the number of EV chargers to incentivize EV owners to park off-street. As discussed in Responses A7-1 and A7-2, the Project provides EV parking, which is consistent with State regulatory requirements. As the Project does not have any significant air quality or GHG impacts, it is not necessary to install more chargers at this time to mitigate impacts. However, the comment about installing more chargers has been passed on to the Applicant.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A8 – Donnetta Jalomo

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A8
Donnetta Jalomo, Resident
March 13, 2024
A8-1 This comment questions the Project’s compatibility with the existing surrounding uses concerning the development’s density and apartment building’s height.

The Project site would be developed at a density of approximately 77 dwelling unit per acre (DU/AC). Higher density residential uses were already anticipated for the northerly portion of the Project, which is designated High Density 30 Overlay and zoned Housing Overlay 4 (HO-4), allowing 21-30 dwelling unit per acre (DU/AC). The Project would remove six circa 1952-1979 industrial buildings, which are in a blighted condition, and fully improve a property that is currently inadequately maintained and devoid of landscaping with residential uses and landscaping. The Project would also comply with City Policy DS 2.7, which requires appropriate setbacks, massing, articulation, and height limits to provide privacy and compatibility where multiplefamily housing is developed adjacent to single-family housing. The apartment building’s design and access is oriented towards Normandie Avenue and away from the nearest single-family housing located to the south and west of the Project site.

Further, the Project appropriately transitions building massing from a single- to multifamily scale by locating the townhomes along the Project boundary that borders single-family housing (south and west) and the apartment building near the multifamily apartments (north) and Normandie Avenue (east). Additionally, the Project’s building heights would be consistent with the development standards in the proposed Normandie Crossing Specific Plan. This comment does not address DEIR’s adequacy or raise a significant environmental issue.

Additionally, in response to community feedback, the “Community Input” Alternative, which would reduce the apartment building height from seven to five above ground stories, has been analyzed in DEIR Section 6.0: Alternatives; see FEIR Section 3.0:

Errata to the Draft EIR for a complete description of the Community Input Alternative.

This comment also suggests that the proposed Project does not provide adequate parking spaces and requests clarification about access to the parking areas. Parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, as noted in DEIR Section 2.0: Project Description, the Project proposes 399 parking spaces for the apartment building and 160 parking spaces for the townhomes. Additionally, the Project further promotes use of multi-modal transportation networks through its proximity to such networks. The Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Project site is less than one mile from five different bus routes and the Harbor Gateway Transit Center; see DEIR Section 4.13: Transportation. Existing GTrans bus stops are located less than 600 feet to the north of the Project site along 166th Street.

Additional Torrance Transit and Metro services are located approximately 0.25 mile to the south of the Project site, at the intersection of Artesia Boulevard and South Normandie Avenue. The Los Angeles County Metropolitan Transportation Authority (Metro) Harbor Gateway Transit Center is also located approximately 0.9-mile to the south, providing more access to public transit opportunities. The Project would also implement TDM strategies such as unbundled parking, additional bicycle parking, and a one-month free transit pass to help renters become acquainted with public transit and pre-leasing for area employees. These strategies provide alternative transportation options, reducing parking demand. Given these factors, it is not anticipated that Project residents would park on surrounding streets.

Concerning access to the Project, vehicular access to the proposed Project site would be provided by the following four driveways:
• Driveway 1 would serve Subarea A and provide access to the apartment building’s parking garage from 169th Street west of South Normandie Avenue. • Driveway 2 would serve Subarea A and provide a right-in/right-out only driveway that would also serve the apartment building’s parking garage from southbound South Normandie Avenue.
• Driveway 3 would serve Subarea B and provide access to the townhomes from 170th Street. This driveway would also serve as fire truck access for both Subareas A and B.
• Driveway 4 would serve Subarea B and provide access to the townhomes from 169th Street. This driveway would also serve as fire truck access for both Subareas A and B.

There would be adequate access to the Project’s parking areas Therefore, this comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is necessary.

A8-2 This comment expresses concern about the Project’s proposed parking areas and requests clarification if there would be two parking spaces per unit and where parking would be located. As noted above in Response A8-1, parking is not considered an environmental issue per CEQA, and this comment does not address the DEIR’s Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, the Project proposes 399 parking spaces for the apartment building and 160 parking spaces for the townhomes. Parking for the apartment complex is proposed to be in the apartment building’s first two levels.

Parking for the townhomes would be in attached garages and would have an additional 10 surface parking spaces for guests.

This comment also requests clarification about the Project’s driveways and whether there would an entrance point on 168th Street and Brighton Way. As shown on DEIR Exhibit 2-4: Conceptual Site Plan, no driveways or access points for the proposed Project are proposed on 168th Street or on Brighton Way. Vehicular access to the proposed Project site is described in Response A8-1. As described in Response A8-1, there would be a proposed access driveway for the Apartment building’s parking garage from 169th Street west of South Normandie which is located across the street from the multifamily development located at 16819 Normandie Avenue. The commenter notes that the multifamily development located at 16819 Normandie Avenue utilizes parking on the local streets to avoid utilizing the electronic garage.

Parking is not an environmental issue pursuant to CEQA, as such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion concerning parking. All roadway and driveway improvements would be constructed pursuant to Los Angeles County Fire Department requirements. Therefore, this comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is necessary.

A8-3 This comment requests clarification about the access driveways for the proposed townhomes and whether they would be located on 170th Street. The comment also suggests that access to the proposed townhomes should utilize the existing signal at Normandie Avenue to reduce traffic impacts in the neighborhood. As mentioned above in Response A8-2, Driveway 3 would provide access to the townhomes from 170th Street and Driveway 4 would provide access to the townhomes from 169th Street. No access to the townhomes is proposed on Normandie Avenue near the existing signal, however, an access driveway to the proposed apartment building is proposed on Normandie Avenue. The apartment building would utilize the driveway at Normandie Avenue to access the parking lot rather than using the other Project access points. Finally, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)). Notwithstanding, the Project has been designed to minimize traffic through TDM strategies and ITS applications. These include features such as unbundled parking, additional bicycle parking, and a one- Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

month free transit pass to help renters become acquainted with public transit and pre-leasing for area employees. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is necessary.

A8-4 This comment expresses concern about neighborhood compatibility and suggests that residential developments be limited to three stories high. Please refer to Response A8-1 concerning neighborhood compatibility and Project building height. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is necessary.

A8-5 This comment discusses housing affordability and expresses dissatisfaction with the high rental prices at nearby developments. As this comment does not address the adequacy of the EIR or raise a significant environmental issue, no further response is required.

A8-6 This comment expresses dissatisfaction with current traffic congestion in the Project area and concern that the Project would worsen traffic conditions. As mentioned above in Response A8-3, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). Also, the Project has been designed to minimize traffic through TDM strategies and ITS applications. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

This comment also expresses concern about mobile source noise generated by Project traffic. As noted in DEIR Section 4.9: Noise, Project traffic would result in a maximum noise level increase of 1.8 dBA CNEL along West 170th Street (west of Normandie Avenue). In addition, the estimated noise level increases along Normandie Avenue and West 169th Street (west of Normandie Avenue) would be 0.2 dBA CNEL and 0.3 dBA CNEL, respectively. As previously noted, a 3-dBA increase is considered a “barely perceptible” difference (i.e., the change in noise is perceived but does not cause a human response). As such, the Project’s estimated traffic noise level increases are considered negligible. The comment does not address the DEIR’s adequacy or provide any evidence to support the assertion of additional and excessive noise.

A8-7 This comment expresses concern that the Project would increase housing density in Gardena and result in traffic congestion similar to the neighboring cities of Carson and Torrance. Please refer to Response A8-3 for a discussion concerning traffic congestion.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A8-8 This comment notes its opposition to the Project and encourages the public and lead agency to oppose it as well. This comment is noted, and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A9 – Kevin Collier

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A9 – Kevin Collier

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A9
Kevin Collier, Resident
March 14, 2024
A9-1 This comment notes its opposition to the Project due to its density and the resulting potential impacts on local street parking and traffic congestion. This comment also notes its support of the Reduced Density Alternative. Please refer to Response A8-1 for a discussion concerning Project density. Regarding parking, parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion concerning parking. Finally, please refer to Response A8-3 for a discussion concerning traffic congestion.

A9-2 This comment expresses concern regarding a statement made at the January 31, 2024 community meeting regarding leasing parking spaces and how this could potentially lead to Project tenants parking in the surrounding streets. Parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, Assembly Bill (AB) 1317 requires all residential parking to be unbundled from rent for any residential use of 16 or more units that are issued a certificate of occupancy after January 1, 2025 in Los Angeles County. The proposed apartment building includes 328 units and would be issued a certificate of occupancy after January 1, 2025. Therefore, pursuant to AB 1317 requirements, the proposed Project would not provide free garage parking. As noted above in Response A9-1, it is not anticipated that Project residents would park on surrounding streets.

A9-3 This comment requests clarification for Project consistency with Gardena Climate Action Plan Policy LUT E2. Gardena Climate Action Plan Policy LUT E2 is as follows:

Measure LUT: E2 – Unbundle Parking Costs From Property Costs. Unbundling separates parking from property costs, allowing individuals who wish to purchase parking spaces to do so and those that don’t, to save money. Parking can be priced separately from home rents/purchase prices or office leases. This measure can help reduce the number of vehicles per household.

Refer to Response A9-2 for a discussion concerning unbundled parking. Therefore, the project would be consistent with Gardena Climate Action Plan Policy LUT E2 by providing unbundled parking. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

A9-4 This comment questions the Project’s consistency with General Plan Policy LU 1.5 stating that rather than encourage alternative transit modes, the Project would encourage on-street parking. As stated in DEIR Table 4.8-4: Gardena General Plan 2006 Analysis, the Project would not conflict with General Plan Policy LU 1.5 as it would provide adequate residential amenities including off-street parking (i.e., approximately 399 off-street vehicle and 173 bicycle parking spaces). The parking proposed by the Project is consistent with the Normandie Crossing Specific Plan but less than the City’s parking requirements, providing 1.2 parking spaces per apartment unit. Refer to Response A8-1 for a discussion concerning parking demand. Further, new residents who sign a 12-month lease would be offered one free monthly Metro pass. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A9-5 This comment questions the adequacy of the Project’s traffic study (DEIR Appendix 4.13-2: Local Transportation Assessment) and claims the study date is not representative of typical traffic conditions. With the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).) Notwithstanding, the analysis of existing traffic conditions in Appendix 4.13-2 was based on 2022 intersection traffic counts. As stated in Appendix 4.13-2, the analysis assumes that traffic levels around the Los Angeles region that were affected by the COVID-19 Pandemic stabilized in 2022 since schools resumed in-person instruction and remaining restrictions were lifted. Although the COVID-19 Pandemic resulted in both temporary and permanent shifts in traffic patterns, pandemic-related restrictions that could affect travel largely expired/stabilized in 2022. Therefore, the traffic counts that were collected are considered adequate and appropriate for use in the Project’s analysis. No further response is required.

A9-6 This comment expresses support for the Reduced Density Alternative. This comment is noted, and no further response is required.

A9-7 This comment requests that the City require the Applicant to provide more than 20 EV charging stalls and more than 20 EV ready charging stalls to encourage Project tenants to use parking spaces in the garage rather than street parking. The Project complies with the Normandie Crossing Specific Plan standards and the latest Title 24 requirements regarding EV parking spaces. The apartment building would provide 20 stalls with EV chargers installed, 40 spaces that are EV capable with electrical panel space and load capacity, and 100 spaces that are EV ready with branch circuit, Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

raceway, and receptacles. Each townhome would have one EV ready space within each garage. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A10 – Western States Regional Council of Carpenters

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A10
Mitchell M. Tsai , Attorney
Western States Regional Council of Carpenters
March 18, 2024
A10-1
Thru
A10-17 This comment letter is a duplicate of Comment Letter No. A4 written on behalf of the Western States Regional Council of Carpenters. For responses to A10-1 through A10- 17, please refer to Responses A4-1 through A4-17 above.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A11 – Brenda Rodriguez

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A11 – Brenda Rodriguez

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A11
Brenda Rodriguez, Resident
March 19, 2024
A11-1 This comment expresses opposition to the Project. This comment has been noted and no further response is necessary.

A11-2 This comment expresses concern about the Project leading to traffic in the surrounding neighborhoods, as well as such traffic leading to air quality impacts from mobile sources. As mentioned in Response A8-3, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).).

Notwithstanding, please refer to Response A8-3 for a discussion regarding traffic.

Regarding air quality impacts, DEIR Table 4.1-6: Operational Air Pollutant Emissions, presents the Project’s operational mobile source emissions and maximum daily total and indicates they would be below the SCAQMD’s mass daily significance thresholds.

As such, Project operations would result in a less than significant air quality impact.

The comment does not provide any evidence regarding traffic and air impacts or address the DEIR’s adequacy, thus, no further response is required.

A11-3 This comment discusses affordability of the housing provided by the Project and expresses concerns of resident displacement. Please refer to Response A8-5 for a discussion concerning affordable housing units. Regarding displacement of residents, as concluded in DEIR Section 7.0: Effects Found Not to be Significant, the Project would remove the existing onsite industrial uses and, in their place, construct residential uses. The Project would not displace existing housing or people or require construction of replacement housing elsewhere and no impact would occur in this regard. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A11-4 This comment urges decision makers to deny the proposed Project in order to protect the community from overdevelopment. This comment is noted, and no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A12 – Dalia Juarez

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A12
Dalia Juarez, Resident
March 19, 2024
A12-1 This comment notes its opposition to the Project and discusses housing affordability in the Project area. Please refer to Response A8-5 for a discussion concerning affordable housing units. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A12-2 This comment expresses concern with the Project’s trip generation and resulting impacts to traffic and road maintenance services. As mentioned in Response A8-3, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). Notwithstanding, please refer to Response A8-3 for a discussion regarding traffic. Regarding roadway maintenance, this is not an environmental issue pursuant to CEQA. Notwithstanding, the overall condition of the City’s pavement network is rated as "Good," with a weighted average Pavement Condition Index (PCI) of 81.2 (range from 0 to 100). Additionally, the City's Public Works Department continues to allocate funds from its Capital Improvement Plan toward annual network pavement maintenance and rehabilitation, which is expected to gradually improve the City's weighted PCI over time. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A12-3 This comment notes that multiple tenants could live in a singular unit. This comments also notes that people deserve fair and equitable housing and questions if the City will make use of the Tenant Protection Act of 2019, a state law that protects tenants from excessive rent increases and evictions without cause. This comment does not address the DEIR’s adequacy or raise a significant environmental issue. This comment has been provided to City staff. This comment is noted, and no further response is necessary.

A12-4 This comment questions the Project’s impact to local schools. As concluded in DEIR Section 4.11: Public Services, sufficient capacity exists at the existing elementary and middle school facilities to accommodate the Project’s forecast student population. Further, the Project would be subject to payment of school impact fees in accordance with SB 50. Pursuant to Government Code §65995(3)(h), “payment of statutory fees is deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

or development of real property…”. Therefore, the Project would not result in adverse physical impacts associated with the construction of school facilities. A less than significant impact would occur in this regard, and no mitigation is required. This comment does not address the DEIR’s adequacy and no further response is required.

A12-5 This comment suggests that the Project could increase traffic in the surrounding neighborhood and result in impacts to street parking in the local neighborhoods if there is no parking lot. As mentioned in Response A8-3, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). Notwithstanding, please refer to Response A8-3 for a discussion regarding traffic. Additionally, parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion regarding parking.

A12-6 This comment expresses concern about the Project’s building heights and architecture and impacts to solid waste generation, water demand, and construction emissions.

Please refer to Response A8-1 for a discussion concerning Project building height.

Regarding solid waste generation, as concluded in DEIR Section 4.15: Utilities and Service Systems(Impact 4.15-7), the Project would not generate solid waste in excess of state or local standards, in excess of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Regarding water demand, as concluded in DEIR Section 4.15 (Impact 4.15-5), Golden State Water Company would have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years. Please refer to Response A11-2 for a discussion concerning air quality impacts. The commenter does not provide any evidence to substantiate their allegations and does not address the DEIR’s adequacy. No further response is required.

A12-7 This comment expresses discontent with the noticing of the proposed Project and has been provided to City staff. This comment is noted, and no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A13 – Terri C.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A13 – Terri C.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A13
Terri C., Resident
March 19, 2024
A13-1 This comment questions the density of the Project and the long-term compatibility of the project within the City. Please refer to Response A8-1 for a discussion concerning Project density . The City’s General Plan (Gardena General Plan 2006) is a staterequired long-range planning document, which identifies the City’s long-term objectives for the next 15-20 years; see DEIR Section 4.8.: Land Use and Planning for a discussion of Project consistency with the Gardena General Plan. As concluded in Section 4.8, the Project would not conflict with the relevant Gardena General Plan goals and policies and would not result in a significant environmental impact concerning a conflict with the Gardena General Plan. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A13-2 This comment expresses concern with the Project’s density and how it will impact the sense of community in Gardena. Please refer to Response A8-1 for a discussion concerning Project density. Sense of community is not a CEQA matter, however, this comment has been noted and passed on to decision makers. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A13-3 This comment asks about Project construction duration, and noted concern about construction noise, construction air quality, and construction-related road blockages/traffic. As stated in DEIR Section 2.0: Project Description, construction is anticipated to occur over approximately 3.5 years. Please refer to Response A4-15 for a discussion concerning construction noise. Please refer to Response A11-2 for a discussion concerning air quality impacts. Finally, regarding construction-related road blockages and traffic, as stated in DEIR Section 4.13: Transportation, Project construction may require traffic lane, parking lane, and/or sidewalk closures, including along Normandie Avenue, but would not result in the complete closure of any public or private street. The Project would implement PDF TR-1, which requires a Construction Traffic Management Plan, approved by the City, to minimize the potential conflicts between construction activities, street traffic, bicyclists, and pedestrians during construction. With implementation of the Construction Traffic Management Plan, temporary construction activities would not impede use of the streets for emergencies or access for emergency response vehicles. As such, Project construction would not result in inadequate emergency access and a less than Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

significant impact would occur. Therefore, this comment does not address the DEIR’s adequacy e and no further response is required.

A13-4 This comment expresses concern about safety related to pedestrian facilities. As discussed in DEIR Section 4.13: Transportation, the Project proposes to construct sidewalks along the Project site frontage: on the south side of West 169th Street (between Brighton Way and Normandie Avenue), on the north side of West 170th Street (between Brighton Way and Normandie Avenue), on the west side of Normandie Avenue (between West 169th Street and West 170th Street), and on the east side of Brighton Way (between West 169th Street and West 170th Street).

Additionally, the Project proposes to construct approximately 266 linear feet of offsite sidewalk improvements along the south side of West 169th Street, just west of the Project site, between Brighton Way and the alley to the west of Brighton Avenue. The sidewalk improvements would be constructed pursuant to GMC §17.08.170:

Improvements and designed to be consistent with the GGP Circulation Element requirements for a Local Street. With the incorporation of these proposed sidewalk improvements, the Project would create a continuous and complete pedestrian network in the area surrounding the Project site, thereby increasing pedestrian safety within the area. This comment does not address the DEIR’s adequacy and no further response is required.

A13-5 This comment requests the lead agency to consider the opinions of current constituents when considering the Project. This comment is noted, and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A14 – Yvonne and Arthur Acosta

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A14 – Yvonne and Arthur Acosta

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A14
Yvonne and Arthur Acosta
March 19, 2024
A14-1 This comment expresses concern about the Project’s traffic and air quality impacts to the neighborhood directly behind the Project site. With the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)).

Notwithstanding, please refer to Response A8-3 for a discussion concerning traffic congestion. Please refer to Response A11-2 for a discussion concerning air quality impacts. This comment does not address the DEIR’s adequacy and no further response is required.

A14-2 This comment suggests that decision makers should focus efforts on improving, protecting, and funding the natural environment and green spaces, namely the Gardena Wetlands Willows specifically. It is noted that this is a private Project, and no City funds are being spent. This comment has been noted and passed on to decision makers.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A15 – Ace Rose

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A15
Ace Rose
March 19, 2024
A15-1 This comment expresses concerns about the Project’s impact to traffic and parking in local neighborhoods. With the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)). Notwithstanding, please refer to Response A8-3 for a discussion concerning traffic congestion. Additionally, parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion regarding parking. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A15-2 This comment notes that decision makers may have an interest in the Project as it could lead to property taxes and revenue, but that they oppose the Project and urge decision makers to do the same. This comment has been noted and passed on to decision makers.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A16 – Brandon Smith

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A16 – Brandon Smith

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A16
Brandon Smith
March 20, 2024
A16-1 This comment notes that housing projects with high unit counts can positively impact rent prices for local renters and surrounding residences. This comment is noted, and no further response is necessary.

A16-2 This comment notes that the Reduced Density Alternative would raise rent prices for the remaining units in order for the Applicant to recuperate costs. It reiterates that the Project’s proposed density would help reduce rent prices, and while it would be preferred to have 100 percent affordable homes, it would not be an economically feasible option for the Applicant. This comment has been noted, and no further response is necessary.

A16-3 This comments notes that the concerns surrounding local traffic and safety is the responsibility of the City to resolve; see also Responses A8.3 above, respectively. The comment suggested that the City consider options such as speed bumps, chicanes, and crosswalk bump-outs to slow traffic and prevent 169th street from becoming a shortcut for drivers. This comment is noted and has been passed on to the decision makers.

A16-4 This comment suggests that the City require a concession from the builder to pay for Class IV bicycle paths which would incentivize use of alternatives modes of transportation. The comment notes that the local area is ideal for bicycle travel and that the 173 bicycle spaces proposed by the Project helps incentivize bicycle travel.

As noted in DEIR Section 4.13: Transportation, there are existing and proposed South Bay Bicycle Master Plan (SBBMP) bike routes near the Project site. As stated in DEIR Section 4.13 (Impact 4.13-1), the Project does not propose any changes to the existing bicycle facilities surrounding the Project site and it would not impede or alter the installation of the SBBMP’s -planned bicycle facilities, including the Bike Friendly Street segment planned along West 170th Street. This comment has been noted and will be passed on to decision makers.

A16-5 This comment notes that the Project would result in additional funding for first responders and City infrastructure and would reduce visually blighted areas in the City. This comment has been noted, and no further response is necessary.

A16-6 This comment notes that the City needs housing projects that do not displace current residents in order to resolve the housing crisis and meet the minimum required Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

housing allowance. This comments notes its support of the proposed Project. This comment is noted and, no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A17 – Gloria Mazzocco

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A17 – Gloria Mazzocco

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A17
Gloria Mazzocco, Homeowner
March 20, 2024
A17-1 This comment expresses concerns about the Project’s impacts to local infrastructure, schools, and traffic congestion. As concluded in DEIR Section 4.19: Utilities and Service Systems, with mitigation incorporated, the Project would result in less than significant environmental effects associated with construction of the proposed water facilities, wastewater facilities, stormwater drainage facilities, electric power and telecommunication facilities. Additionally, the proposed Project would result in a less than significant impact in regard to water supply, wastewater treatment, and solid waste generation. Please refer to response A12-4 for a discussion concerning impacts to local schools. With the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)). Notwithstanding, please refer to Response A8-3 for a discussion concerning traffic congestion. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A17-2 This comments states that the Initial Study failed to mention the Gardena Willows Wetland Preserve. The Gardena Wetland Willows Preserve is located 0.3-mile southeast of the Project, just north of the commercial development at the northwest corner of Vermont Avenue and Artesia Boulevard. While the Initial Study did not mention the Gardena Wetland Willows Preserve in the analysis, the Initial Study concluded that based on review of the existing and adjacent site conditions, no candidate, sensitive, or special-status plant or wildlife species, riparian habitat or other sensitive natural community, or wetlands are present on or adjacent to the Project site. The Project site is fully developed and contains no natural habitats, with only minimal landscaping. The Project site is also bounded by roadways and surrounded by urban uses (i.e., single- and multi- family residential on all sides).

Finally, Project construction activities would also occur entirely within Project site boundaries. Therefore, the Project would not have an adverse effect on any candidate, sensitive, or special-status plant or wildlife species, riparian habitat or other sensitive natural community, or wetlands. This comment does not address the DEIR’s adequacy or provide any evidence of an impact to the Willows Wetland. No further response is required.

A17-3 This comment expresses concern of the Project’s impact to Gardena Wetland Willows due to the reduction of impermeable surface area and the resulting impacts on runoff, Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

water quality, soil, and air quality. As concluded in DEIR Section 4.7: Hydrology and Water Quality, the proposed Project would result in an increase in landscaped areas throughout the Project site, which would decrease impervious surfaces from 99.7 percent under existing conditions to 85.9 percent under proposed Project conditions.

The Project would reduce impervious surfaces thereby reducing flows under 10-year, 25-year, and 50-year storm events between 11.7 percent and 13.8 percent, when compared to existing conditions. Because the Project would decrease surface runoff, it would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or result in flooding on- or off-site.

The Project would also treat site runoff in accordance with the LID Standards Manual.

Further, as concluded in DEIR Impact 4.8-1, the Project would be subject to compliance with NPDES and GMC requirements, which include implementation of BMPs. Overall, the Project would not substantially contribute to runoff.

Regarding water quality, following compliance with NPDES and GMC requirements, which include implementation of BMPs as a Condition of Approval, the Project’s construction and operational activities would not violate any water quality standards or otherwise substantially degrade surface or groundwater quality. Concerning soil, the Projects proposed LID systems are designed to safely convey stormwater runoff into the sub-surface soil without the threat of contaminant mobilization and will assist in improving the groundwater quality.

Finally, concerning air quality, as noted in DEIR Section 4.2: Air Quality, the Project’s construction and operational emissions would be below SCAQMD thresholds and would result in a less than significant impact.

The comment does not provide any evidence of any impacts and does not address the DEIR’s adequacy No further response is required.

A17-4 This comment expresses concern about the Project’s proposed parking areas suggesting that the Project would result in parking on local streets. Parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion regarding parking.

A17-5 This comment notes that a seven-story apartment building is excessive for the City.

Please refer to Response A8-1 concerning Project building height. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

A17-6 This comment notes that a residential project to the north uses the local streets for parking; see Response A17-5 above concerning parking on local streets. This comment also mentions that the residential project to the north took a long time to become fully occupied and notes discontent that only 20 units for the Project will be deemed affordable. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A17-7 This comment expresses concerns about Project construction-related air quality and noise impacts to nearby sensitive receptors. Please refer to Response A11-2 for a discussion concerning air quality impacts. Please refer to Response A4-15 for a discussion concerning construction noise. This comment does not address the DEIR’s adequacy and no further response is required.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A18– Liliana Arreguin

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A18
Liliana Arreguin, Resident
March 20, 2024
A18-1 This comment expresses concern about the Project’s potential impacts to congestion.

With the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3)). Notwithstanding, please refer to Response A8-3 for a discussion concerning traffic congestion. This comment does not address the DEIR’s adequacy or raise a significant environmental issue and no further response is required.

A18-2 This comment expresses concern about the Project’s construction noise impacts and the potential impacts to parking on local streets. Please refer to DEIR Section 4.9:

Noise and to Response A4-15 for a discussion concerning construction noise. The comment does not address the DEIR’s adequacy on this issue and no further response is necessary.

Additionally, parking is not an environmental issue pursuant to CEQA, and this comment does not address the DEIR’s adequacy or raise a significant environmental issue. As such, no further response is necessary. Notwithstanding, please refer to Response A8-1 for a discussion regarding parking.

A18-3 This comment expresses opposition to the Project. This comment is noted, and no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Letter A19– Various

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A19
Various, Residents
April 2, 2024
A19-1 This petition is has been provided to City staff. The petition expresses concern with the height and density of the proposed apartment building, and potential impacts related to traffic and quality of life. Please refer to Response A8-1 for a discussion concerning Project building height and density. As mentioned in Response A8-3, with the adoption of the changes to the State CEQA Guidelines in 2018, automobile delay, as measured by “level of service” (LOS) and other similar metrics, no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).). Notwithstanding, please refer to Response A8-3 for a discussion regarding traffic. As traffic and quality of life are not CEQA issues, this comment has been noted, and no further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Comment Letter A20 – Layne Fajeau
Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A20
Layne Fajeau, Attorney
March 19, 2024
A20-1 This comment is introductory in nature and states that the Law Office of Lozeau Drury has submitted comments on behalf of the Supporters Alliance for Environmental Responsibility (SAFER). No further response is necessary.

A20-2 The comment suggests the City should revise and recirculate the DEIR to address “all feasible mitigation measures to reduce noise pollution.” Further, the comment suggests the City recirculate the Draft EIR.

As discussed in Section 4.9, due to the distance to sensitive receptors, there are no feasible mitigation measures to mitigate construction noise to less than significant. As discussed in Section 6.5, the analysis considered, but ultimately rejected, an alternative which would avoid the Project’s significant unavoidable construction noise, given the only way to avoid the significant impact would be no construction.

Section 6.5 includes discussion of other mitigation measures incorporated to attempt to mitigate the impact, but nevertheless the impact would remain significant and unavoidable. The commenter has not provided substantial evidence of any other feasible mitigation measures that should be adopted.

A20-3 The comment states that the commenter reserves the right to supplement the comments and incorporates by reference all comments regarding the EIR. The comment is noted. No further response is necessary.

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Comment Letter A21 – Brian Flynn

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Comment Letter A21 – Brian Flynn

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Comment Letter A21 – Brian Flynn

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

Comment Letter A21 – Brian Flynn

Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses

RESPONSE TO COMMENT LETTER NO. A21
Bryan Flynn, Attorney
March 27, 2024
A21-1 This comment is introductory in nature and states that the Law Office of Lozeau Drury has submitted comments on behalf of the Supporters Alliance for Environmental Responsibility (SAFER). The comment also summarizes the Project. No further response is necessary.

A21-2 This comment states that SAFER has concerns regarding the Draft EIR and believes the Draft EIR should be recirculated. See responses A21-3 through A21-4. This is simply a generalized comment that does not require a response.

A21-3 This comment states that COA HAZ-1 and MM HAZ-1 are deferred mitigation measures, as neither include performance standards or criteria. Given the potential for unknown hazardous materials/contamination is unknown (place, medium, amount, type of contaminant, etc.), it is not possible to set performance standards for unknown contamination that could be included in MM HAZ-1. In regard to COA HAZ- 1, Section 18.42.200 of the GMC requires the Project to comply with SCAQMD Rule 1403 for asbestos-containing materials. SCAQMD Rule 1403 provides requirements for demolition and renovation activities to include asbestos surveying, notification, ACM removal procedures and time schedules, ACM handling and cleanup procedures, and storage, disposal, and landfilling requirements for asbestoscontaining waste materials. Therefore, if the Asbestos Survey required per COA HAZ- 1 determines that there are ACMs present, the criteria and standards of performance for removal would be completed in accordance with standard procedures set forth in SCAQMD Rule 1403. Therefore, COA HAZ-1 would not be deferred mitigation as the removal process pursuant to SCAQMD rule 1403 is required per the GMC. Phase I Environmental Site Assessments, Phase II Environmental Site Assessments, and a Vapor Intrusion Risk Assessment (VIRE) were prepared for the Project to assess potential for hazardous materials and contamination; see DEIR Section 4.6. This comment is noted, and additional discussion to the regulatory setting and impact analysis in DEIR Section 4.6: Hazards and Hazardous Materials is included as shown below.

DEIR Section 4.6: Hazards and Hazardous Materials
DEIR Page 4.6-19
Pursuant to GMC Section 18.42.200 (B), the Project is required to comply with the objective standards of the South Coast Air Quality Management District (SCAQMD) Rule 1403 for asbestos-containing materials. SCAQMD Rule 1403 Normandie Crossing Specific Plan Project Section 2.0
Revised and Updated Final Environmental Impact Report Comment Letters and Responses