b. The impact on arrival, departure, and en route procedures for aircraft operating under IFR follows:
Aeronautical study disclosed that the proposed structure would have no effect on any existing or proposed arrival or en route IFR operations or procedures.
c. The impact on all planned public-use airports and aeronautical facilities follows: Study did not disclose any significant adverse effect on existing or proposed public-use or military airports or navigational facilities, nor would the proposed structure affect the capacity of any known existing or planned public-use or military airport.
d. The cumulative impact resulting from the proposed construction or alteration of a structure when combined with the impact of other existing or proposed structures is not considered to be significant.
4. CIRCULATION AND COMMENTS RECEIVED
As a result of the negotiation process the sponsor requested circularization of the proposed structure. The proposal was circularized for public comment on August 6, 2021. No comments were received as a result of the circularization.
5. DETERMINATION - NO HAZARD TO AIR NAVIGATION
It is determined that the proposed structure would not have a substantial adverse effect on the safe and efficient use of navigable airspace by aircraft.
6. BASIS FOR DECISION
Part 77 establishes standards for determining obstructions to air navigation. A structure that exceeds one or more of these standards is presumed to be a hazard to air navigation unless the obstruction evaluation study determines otherwise. Just because a proposed structure exceeds a Part 77 surface does not automatically make it a hazard. In this case the proposal would exceed Section 77.19(a) horizontal surface by 26 feet; however, it would not conflict with airspace require to conduct normal VFR traffic pattern operations. There are no IFR impacts and the VFR traffic pattern airspace is not impacted. The incorporation of lighting would provide additional pilot conspicuity for IFR and VFR operations conducted in the vicinity of HHR airport.
7. CONDITIONS
The structure shall be lighted as outlined in Chapters 4, 5(Red) & 15 of the Advisory Circular AC 70/7460-1M.
The advisory circular is available online at https://www.faa.gov/regulations_policies/advisory_circulars/ index.cfm/go/document.information/documentID/1038519
Within five days after the structure reaches its greatest height, the proponent is required to file on line the Supplemental Notice, FAA form 7460-2, with actual construction details, at the OE/AAA website (https:// oeaaaa.faa.gov/oeaaa). Detailed instructions are available under the Instructions link. This Supplemental Notice notification will be the source document detailing the site location, site elevation, structure height, and date structure was built for the FAA to map the structure on aeronautical charts and update the national database.
TOPO Map for ASN 2021-AWP-10833-OE
Sectional Map for ASN 2021-AWP-10833-OE
Appendix H
Noise Technical Data
AMBIENT NOISE MEASUREMENTS
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Session Report
6/30/2022
Information Panel
Name 1233 Myrtle Avenue
Comments
Start Time 6/29/2022 9:09:19 AM
Stop Time 6/29/2022 9:24:22 AM
Run Time 00:15:03
Serial Number SE40213991
Device Name SE40213991
Model Type Sound Examiner
Device Firmware Rev R.11C
Company Name
Description
Location
User Name
Summary Data Panel
Description Meter ValueDescription Meter Value
Leq 1 62.3 dB
Exchange Rate1 3 dB Weighting 1 A
Response 1 SLOW Bandwidth 1 OFF
Logged Data Chart
1233 Myrtle Avenue: Logged Data Chart
Logged Data Table
Date/Time Lapk-1 Lasmn-1 Lasmx-1 Leq-1
November 2020
6/29/2022 9:10:19 AM 96 55.5 80.6 67.2
9:11:19 AM 85.7 56.5 72.3 64.5
9:12:19 AM 77.5 52.5 63.8 57
9:13:19 AM 81 52.5 66.1 60.5
9:14:19 AM 81.3 50.9 67.2 60.2
9:15:19 AM 78.5 48.2 65.3 58.7
9:16:19 AM 83.1 50.4 69.2 62.6
9:17:19 AM 89.4 54.9 75 64.9
9:18:19 AM 84.8 46.8 74.9 63.6
9:19:19 AM 80.7 48.5 65.3 57.7
9:20:19 AM 81.8 49.5 66.9 60.9
9:21:19 AM 82.8 51.6 67.4 61
9:22:19 AM 81.2 46.1 62.8 55.4
9:23:19 AM 83.5 49.8 70.1 60.6
9:24:19 AM 85.1 56.4 69.7 64.5
Date/Time Lapk-1 Lasmn-1 Lasmx-1 Leq-1
November 2020
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Sound Power Level (Lw)109.7 dB
Existing Leq Noise New LeqDifference
LeqSignificant?
65.0 48.9 65.1 0.1 No
Residences, Myrtle Avenue 62.3 45.7 62.4 0.1 No
Residences, Century Boulevard 65.8 57.8 66.4 0.6 No
Motels, Century Boulevard 65.0 53.3 65.3 0.3 No
65.0 63.0 67.1 2.1 No
65.0 59.5 66.1 1.1 No
56.8 64.5 65.2 8.4 Yes
Construction Noise Impacts (Unmitigated)
Receptor
Sea Breeze Inn
Residences, Freeman Avenue (10000 block)
Residences, 101st Street
Residences, Freeman Avenue (10100 block)
Sound Power Level (Lw)109.7 dB
Existing Leq Noise New LeqDifference
LeqSignificant?
65.0 49.0 65.1 0.1 No
Residences, Myrtle Avenue 62.3 45.9 62.4 0.1 No
Residences, Century Boulevard 65.8 58.0 66.5 0.7 No
Motels, Century Boulevard 65.0 53.3 65.3 0.3 No
65.0 63.2 67.2 2.2 No
65.0 58.8 65.9 0.9 No
56.8 59.8 61.6 4.8 No
Note: Sound Power Level (Lw) assumes full sphere propagation Residences, Freeman Avenue (10100 block)
Residences, 101st Street
Residences, Freeman Avenue (10000 block)
Construction Noise Impacts (Mitigated)
Receptor
Sea Breeze Inn
OFF-SITE CONSTRUCTION-RELATED TRAVEL VOLUMES
Construction Phase Worker TripsVendor TripsHaul Trips Total % of Traffic Volumes Demolition 6 - 17 23 0.8% Site Preparation 4 - 4 0.1% Grading 5 - 505 510 17.0% Below Grade Parking 148 253 401 13.4% Above Grade Parking 148 253 401 13.4% Hotel and Apartment 148 253 401 13.4% Architectural Coatings 89 - 89 3.0% Vendor and Haul trips represent heavy-duty truck trips with a 19.1 Passenger Car Equivalent applied 3000Traffic Volumes on Century Boulevard between Freeman Avenue and Myrtle Avenue
GRADING ANALYSIS
SOIL TRANSPORT WITH SHRINK AND SWELL FACTORS
CY % Swell Adjusted CYTruck Capacity
(CY) Truck Trips
Topsoil 5,208 56% 8,125 10 1,625 Clay (Dry) 69,792 50% 104,688 10 20,938 Clay (Damp) 67% - 10 - Earth, loam (Dry) 50% - 10 - Earth, loam (Damp) 43% - 10 - 56% - 10 -
TOTAL 75,000 112,813 22,563
Note: Topsoil considered the top ten inches of soil (Wikipedia) Note: Soil below topsoil assumed to be dry clay; Source: Lyngso website, https://www.lyngsogarden.com/community-resources/tips-on-modifying-your-california-soil-with-amendments/ Source: US Department of Transportation Determination of Excavation and Embankment Volumes; https://highways.dot.gov/federal-lands/pddm/dpg/earthwork-design
DEMOLITION ANALYSIS
CONSTRUCTION BUILDING DEBRIS
Materials Total SF Height Cubic YardsPounds per Cubic YardTons Truck Capacity
(CY) Truck Trips
Construction and Demolition 0 Low Low
General Building 61,000 12 1,130 1,000 565 16 141 Single Family Residence - 12 - 1,000 - 16 - Multi-Family Residence 12 - 1,000 - 16 - Mobile Home 1,000 - 16 - Mixed Debris 500 - 16 - Vegetative Debris (Hardwoods) 500 - 16 - Vegetative Debris (Softwoods) 333 - 16 - Asphalt or concrete (Construction Debris)40,502 0.5 750 2,400 900 16 94 TOTAL 1,880 1,465 235
2.4 3.79
Source: Federal Emergency Management Agency, Debris Estimating Field Guide (FEMA 329), September 2010 Source (Asphalt or concrete): CalRecycle Solid Waste Cleanup Program Weights and Volumes for Project Estimes; http://www.calrecycle.ca.gov/swfacilities/cdi/Tools/Calculations.htm
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Composite Noise Impact Summary
Sensitive ReceptorExisting CNELTrafficMechanicalLoading and Solid WasteOutdoor SpacesProject CompositeExisting + ProjectIncreaseThreshold of SignificanceSignificant? Sea Breeze Inn63.058.024.4-16.830.758.064.21.268.0NoResidences - Myrtle Ave.56.234.823.9-16.931.336.756.20.061.2NoResidences - Century Blvd.63.857.729.6-13.634.357.764.81.068.8NoMotels- Century Blvd.63.058.113.5-11.831.358.164.21.268.0NoResidences - Freeman Ave. (10000 block)63.056.233.6-10.227.856.263.80.868.0NoResidences - Freeman Ave. (10100 block)63.052.933.014.625.653.063.40.468.0NoResidences - 101st St.54.857.413.528.231.357.459.34.559.8No Sensitive ReceptorSea Breeze InnSource Sound Pressure Level10^(x/10)Traffic 58.0630957=IF(C5="Add",10^(B5/10),10^(B5/10)*-1)Mechanical 24.4275Parking 1Loading and Solid Waste-16.80Outdoor Spaces30.711756 17 18 19 110 111 112 1Total 58.0632415.6858=IF(D17<0,"n/a",10*LOG(D17))=sum(D5:D16) Sensitive ReceptorResidences - Myrtle Ave.Source Sound Pressure Level10^(x/10)Traffic 34.83020=IF(C5="Add",10^(B5/10),10^(B5/10)*-1)Mechanical 23.9245Parking 1Loading and Solid Waste16.949Outdoor Spaces31.313496 17 18 19 110 111 112 1Total 36.74671.363376=IF(D17<0,"n/a",10*LOG(D17))=sum(D5:D16) Sensitive ReceptorResidences - Century Blvd.Source Sound Pressure Level10^(x/10)Traffic 57.7588844=IF(C5="Add",10^(B5/10),10^(B5/10)*-1)Mechanical 29.6912Parking 1Loading and Solid Waste-13.60Outdoor Spaces34.326926 17 18 19 110 111 112 1Total 57.7592455.2447=IF(D17<0,"n/a",10*LOG(D17))=sum(D5:D16) Sensitive ReceptorMotels- Century Blvd.Source Sound Pressure Level10^(x/10)Traffic 58.1645654=IF(C5="Add",10^(B5/10),10^(B5/10)*-1)Mechanical 13.522Parking 1Loading and Solid Waste-11.80Outdoor Spaces31.313496 17 18 19 110 111 112 1Total 58.1647033.6452=IF(D17<0,"n/a",10*LOG(D17))=sum(D5:D16) Sensitive ReceptorResidences - Freeman Ave. (10000 block)Source Sound Pressure Level10^(x/10)Traffic 56.2416869=IF(C5="Add",10^(B5/10),10^(B5/10)*-1)Mechanical 33.62291Parking 0.0 1Loading and Solid Waste-10.20Outdoor Spaces27.86036 17 18 19 110 111 112 1Total 56.2419770.9062=IF(D17<0,"n/a",10*LOG(D17))=sum(D5:D16) Operational Noise Impacts
OPERATIONS NOISE CALCULATIONS (DAY)
OPERATIONS NOISE CALCULATIONS (EVENING)
OPERATIONS NOISE CALCULATIONS (NIGHT)
OPERATIONS NOISE CALCULATIONS (CNEL)
CONSTRUCTION VIBRATION
Construction Vibration Impact Analysis
_________________________________________________________________________DKA Planning 4200 West Century Boulevard Project Page 1
Construction Vibration: UNMITIGATEDConstruction Vibration: UNMITIGATED Receptor: Crestridge Inn Receptor: Crestridge Inn
Equipment: Large Bulldozer, Auger Drill RigEquipment: Loaded Trucks Source PPV (in/sec) 0.089 Source PPV (in/sec) 0.076
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 10 Distance (ft) 10
Unmitigated Vibration Level (in/sec)0.223 Unmitigated Vibration Level (in/sec) 0.190 Receptor: Super 8 Motel Receptor: Super 8 Motel
Equipment: Large Bulldozer, Auger Drill RigEquipment: Large Bulldozer, Auger Drill Rig Source PPV (in/sec) 0.089 Source PPV (in/sec) 0.076
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 10 Distance (ft) 10
Unmitigated Vibration Level (in/sec)0.223 Unmitigated Vibration Level (in/sec) 0.190 Receptor: Residences 101st St and Freeman AveReceptor: Residences 101st St and Freeman Ave Equipment: Large Bulldozer, Auger Drill RigEquipment: Large Bulldozer, Auger Drill Rig Source PPV (in/sec) 0.089 Source PPV (in/sec) 0.076
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 60 Distance (ft) 60
Unmitigated Vibration Level (in/sec)0.037 Unmitigated Vibration Level (in/sec) 0.032 4200 West Century Boulevard Project Page 2
Receptor: Crestridge Inn Receptor: Crestridge Inn
Equipment: Small Dozer-Type Equipment Equipment: Jackhammer Source PPV (in/sec) 0.003 Source PPV (in/sec) 0.035
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 10 Distance (ft) 10
Unmitigated Vibration Level (in/sec)0.008 Unmitigated Vibration Level (in/sec) 0.088 Receptor: Super 8 Motel Receptor: Super 8 Motel
Equipment: Small Dozer-Type Equipment Equipment: Jackhammer Source PPV (in/sec) 0.003 Source PPV (in/sec) 0.035
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 10 Distance (ft) 10
Unmitigated Vibration Level (in/sec)0.008 Unmitigated Vibration Level (in/sec) 0.088 Receptor: Residences 101st St and Freeman AveReceptor: Residences 101st St and Freeman Ave Equipment: Small Dozer-Type Equipment Equipment: Jackhammer Source PPV (in/sec) 0.003 Source PPV (in/sec) 0.035
Reference Distance (ft) 25 Reference Distance (ft) 25
Ground Factor (N) 1 Ground Factor (N) 1
Distance (ft) 60 Distance (ft) 60
Unmitigated Vibration Level (in/sec)0.001 Unmitigated Vibration Level (in/sec) 0.015 Sources
Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment, May 2006 California Department of Transportation (Caltrans), Transportation and Construction Vibration Guidance Manual, September 2013.
CUMULATIVE PROJECTS
1 2
7 City of Inglewood
1) 1050 S. Prairie Avenue
2) 316 Hardy Street
3) 616-620 E. 99th Street
4) 4049-4055 W. Century Boulevard
5) 3846 W. Century Boulevard
6) 3820 W. 102nd Street
City of Los Angeles
7) 10505 Hawthorne Boulevard
Project Site
Related Projects
Source: Google Maps 2024.
Figure _
Related Projects Radius Map
Approximate Scale (Feet)
0 500 1000
Legend
3 4
5 6
0.25 Mile 0.5 Miles
CUMULATIVE CONSTRUCTION NOISE IMPACTS
Level Corrections
Source name Size ReferenceDay EveningNightCwallCICT
m/m² dB(A) dB(A) dB(A)dBdBdB
Construction Site 7924 m²Lw/unit 109.7 - - - - -
Related Project - 616-610 E. 99th St. 1432 m²Lw/unit 109.7 - - - - - Related Project - 4049-4055 W. Century Bl.1414 m²Lw/unit 109.7 - - - - - Noise emissions of industry sources
Douglas Kim & Associates LLC 808 Holly Road Belmont, CA 94002 CoordinatesBuilding HeightLimitLevel w/o NPLevel w NPDifferenceConflict No.Receiver name X Y sideFloorabv.grd.Day Day Day Day Day in meter m dB(A)dB(A)dB(A)dB dB
1Motels - Century Boulevard11375302.963756912.00NorthGF29.14 - 55.1 53.3 -1.9 - 2Residences - 101st Street11375356.983756814.53NorthGF29.33 - 64.5 60.0 -4.5 - 3Residences - Century Boulevard11375425.983756942.63SouthGF29.45 - 57.9 58.0 0.1 - 4Residences - Freeman Ave (10100 block)11375419.653756814.30NorthGF29.59 - 60.0 58.9 -1.0 - 5Residences - Freeman Avenue (10000 block)11375418.253756864.25WestGF29.51 - 62.9 63.0 0.1 - 6Residences - Myrtle Avenue11375308.953757006.25EastGF29.83 - 59.2 46.6-12.6 - 7Sea Breeze Inn 11375230.393756947.78SouthGF29.67 - 49.1 49.1 0.0 - Receiver list
Douglas Kim & Associates LLC 808 Holly Road Belmont, CA 94002 Level w/o NP Level w NP
Source name Traffic lane Day Day
dB(A) dB(A)
Motels - Century Boulevard GF 55.1 53.3
Construction Site - 53.2 53.1
Related Project - 616-610 E. 99th St. - 41.5 35.8
Related Project - 1200 99th St. - 48.8 -
Related Project - 4049-4055 W. Century Bl. - 44.2 38.4
Residences - 101st Street GF 64.5 60.0
Construction Site - 64.4 60.0
Related Project - 616-610 E. 99th St. - 43.5 37.4
Related Project - 1200 99th St. - 41.3 -
Related Project - 4049-4055 W. Century Bl. - 45.5 40.8
Residences - Century Boulevard GF 57.9 58.0
Construction Site - 57.9 58.0
Related Project - 616-610 E. 99th St. - 29.2 29.2
Related Project - 1200 99th St. - 31.6 -
Related Project - 4049-4055 W. Century Bl. - 34.3 30.4
Residences - Freeman Ave (10100 block) GF 60.0 58.9
Construction Site - 59.5 58.8
Related Project - 616-610 E. 99th St. - 45.1 39.0
Related Project - 1200 99th St. - 41.6 -
Related Project - 4049-4055 W. Century Bl. - 47.1 43.0
Residences - Freeman Avenue (10000 block) GF 62.9 63.0
Construction Site - 62.8 63.0
Related Project - 616-610 E. 99th St. - 33.5 32.2
Related Project - 1200 99th St. - 41.1 -
Related Project - 4049-4055 W. Century Bl. - 35.0 33.5
Residences - Myrtle Avenue GF 59.2 46.6
Construction Site - 45.8 46.0
Related Project - 616-610 E. 99th St. - 37.5 34.2
Related Project - 1200 99th St. - 58.9 -
Related Project - 4049-4055 W. Century Bl. - 40.8 35.6
Sea Breeze Inn GF 49.1 49.1
Construction Site - 48.9 49.0
Related Project - 616-610 E. 99th St. - 25.7 25.6
Related Project - 1200 99th St. - 31.6 -
Related Project - 4049-4055 W. Century Bl. - 30.8 26.8
Contribution levels of the receivers
Douglas Kim & Associates LLC 808 Holly Road Belmont, CA 94002
Sound Power Level (Lw)109.7 dB
Existing LeqNoiseNew LeqDifference LeqSignificant?
65.0 49.1 65.1 0.1 No
Residences, Myrtle Avenue 62.3 59.2 64.0 1.7 No
Residences, Century Boulevard 65.8 57.9 66.5 0.7 No
Motels, Century Boulevard 65.0 55.1 65.4 0.4 No
65.0 62.9 67.1 2.1 No
65.0 60.0 66.2 1.2 No
56.8 64.5 65.2 8.4 Yes
Cumulative Construction Noise Impacts (Unmitigated)
Receptor
Sea Breeze Inn
Residences, Freeman Avenue (10000 block)
Residences, 101st Street
Residences, Freeman Avenue (10100 block)
Sound Power Level (Lw)109.7 dB
Existing LeqNoiseNew LeqDifference LeqSignificant?
65.0 49.1 65.1 0.1 No
Residences, Myrtle Avenue 62.3 46.6 62.4 0.1 No
Residences, Century Boulevard 65.8 58.0 66.5 0.7 No
Motels, Century Boulevard 65.0 53.3 65.3 0.3 No
65.0 63.0 67.1 2.1 No
65.0 58.9 66.0 1.0 No
56.8 60.0 61.7 4.9 No
Cumulative Construction Noise Impacts (Mitigated)
Receptor
Sea Breeze Inn
Residences, Freeman Avenue (10000 block)
Residences, 101st Street
Residences, Freeman Avenue (10100 block)
Appendix H2
LAX Noise Contours
SOURCES: LAWA, 2014; ESA Airports, 2014; ESRI ArcGIS Online, 2011; ESRI World Imagery - Aerial; PCR Services Corporation, 2012 NOTES: CNEL = Community Noise Equivalent Level; dB = Decibel.
Los Angeles International Airport
Aircraft Noise Contours
LOS ANGELES
COUNTY
BoulevardHawthorne
CenturyBoulevard
PROJECT SITE
Appendix I
Transportation Assessment
TRANSPORTATION IMPACT ANALYSIS
4200 CENTURY
City of Inglewood, California
August 9, 2024
Prepared for:
4200 QOF LLC
4200 West Century Boulevard
Inglewood, CA 90304
LLG Ref. 1-21-0574-1
Prepared by: Under the Supervision of:
Jason A. Shender, AICP David S. Shender, P.E.
Senior Transportation Planner Principal
600 S. Lake Avenue
Suite 500
Pasadena, CA 91106
626.796.2322 T
626.792.0941 F
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 1-21-0574-1 4200 Century
U:\0574\report\TIA\0574-TIA rpt4.doc
TABLE OF CONTENTS
SECTION PAGE
1.0 Introduction ................................................................................................................................ 1
2.0 Project Description .................................................................................................................... 4
2.1 Site Location ....................................................................................................................... 4
2.2 Existing Project Site ........................................................................................................... 4
2.3 Project Description ............................................................................................................. 4
3.0 Site Access and Circulation ...................................................................................................... 7
3.1 Existing Vehicular Site Access .......................................................................................... 7
3.2 Vehicular Project Site Access ............................................................................................ 7
3.2.1 Residential Component Vehicular Access ........................................................... 7
3.2.2 Hotel and Event and Entertainment Area Component Vehicular Access .......... 7
3.3 Project Loading .................................................................................................................. 8
4.0 Existing Street System ............................................................................................................... 9
4.1 Regional Highway System ................................................................................................ 9
4.2 Local Roadway System and Roadway Descriptions ........................................................ 9
4.3 Public Transit Services ....................................................................................................... 11
5.0 Project Traffic Generation ....................................................................................................... 14
6.0 Consistency with Local Plans, Programs, Ordinances, or Policies .................................... 18
6.1 Impact Criteria and Methodology ..................................................................................... 18
6.2 Review of Project Consistency .......................................................................................... 19
6.3 Review of Cumulative Consistency .................................................................................. 19
7.0 Vehicle Miles Traveled Assessment ........................................................................................ 20
7.1 Introduction ........................................................................................................................ 20
7.2 Impact Criteria and Methodology ..................................................................................... 21
7.3 Summary of Project VMT Analysis .................................................................................. 21
7.4 CEQA Transportation Mitigation Measures ..................................................................... 23
7.5 Summary of Cumulative Impacts ...................................................................................... 24
8.0 Geometric Design Hazards ...................................................................................................... 25
8.1 Introduction ........................................................................................................................ 25
8.2 Impact Criteria and Methodology ..................................................................................... 25
8.3 Qualitative Review of Site Access Points ......................................................................... 26
8.4 Sight Distance Review of Proposed 101st Street Driveways ........................................... 28
9.0 Conclusions ................................................................................................................................. 30
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TABLE OF CONTENTS (continued)
LIST OF FIGURES
SECTION—F IGURE # P AGE
1–1 Vicinity Map ............................................................................................................................. 2 2–1 Project Si te Plan ........................................................................................................................ 6 4–1 Existing Public Transit Routes ................................................................................................. 13
LIST OF TABLES
SECTION—T ABLE # P AGE
4–1 Existing Public Transit Routes......................................................................................... 12 5–1 Project Trip Generation ................................................................................................... . 16
APPENDICES
APPENDIX
A. Loading Area Maneuvering Exhibits
B. Local Plans, Programs, Ordinances, and Policies Review C. City of Inglewood VMT Calculator Outputs
D. Sight Distance Exhibits for the Proposed 101st Street Driveways
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TRANSPORTATION IMPACT ANALYSIS
4200 CENTURY
City of Inglewood, California
August 9, 2024
1.0 INTRODUCTION
This Transportation Impact Analysis (“TIA”) has been conducte d to identify and evaluate the potential transportation impacts of the proposed 4200 Century project (“Project”) located at 4200 W. Century Boulevard and 4229-4233 W. 101 st Street (“Project Site”) in the City of Inglewood (“City”). The Project Applicant seeks to cons truct a new 13-story mixed -use development with 118 residential apartment dwelling units, 11 resi dential condominium dwelling units, 175 hotel guestrooms, and 42,350 square feet of event and entertainment area. The Project Site is bounded by Century Boulevard to the north, 101 st Street to the south, an existing motel to the west, and Freeman Avenue to the east. The Project Site location and ge neral vicinity are shown in Figure 1–1.
This TIA follows the City of Inglewood Transportation Impact Analysis Guidelines 1 (“TIA Guidelines”). In compliance with the Califor nia Environmental Quality Act (“CEQA”), the City’s TIA Guidelines identify Vehicle Miles Traveled (“VMT”) as the primary metric for evaluating a project’s transportation impacts . Additional CEQA metrics for evaluating a project’s transportation impacts include whether the proposed project conflicts or is inconsistent with local programs, plans, ordinances, or policies that address the circulation system, and whether a project would increase hazards due to a geometric design feature.
In September 2013, the Governor’s Office signed Senate Bill 743 (“SB 743”), starting a process that fundamentally changes the way transportation impact analysis is conducted under CEQA.
Within the State’s CEQA Guidelines, these changes include the elimination of auto delay, Level of Service (“LOS”), and similar measurements of vehicular roadway capacity and traffic congestion as the basis for determining significant traffic impacts. SB 743 identifies VMT as the most appropriate CEQA transportation metric, al ong with the elimination of auto delay/LOS for CEQA purposes statewide. The jus tification for this paradigm shift is that LOS impacts lead to improvements that increase roadway capacity and therefore induce more traffic and greenhouse gas emissions.
While LOS and auto delay are no longer utilized as metrics for evaluating the transportation impacts of a project under CEQA, the City’s TIA Guidelines requi re that land use projects continue to perform a non-CEQA LOS analysis agai nst the City’s established criteria to inform decision makers on the overall transportation effects of a project. Accordingly, a separate non- CEQA Local Transportation Assessment (“LTA”) ha s been prepared to provide a LOS analysis and other non-CEQA analyses deemed appropriate by the City for the Project in accordance with the TIA Guidelines.
1 City of Inglewood Transportation Impact Analysis Guidelines, City of Inglewood Public Works, October 2022. -1-
Vicinity Map
4200 Century
Figure 1-1
Project Site
Burin
97th
Myrtle
Grevillea
Larch
La
rch
Freeman
104th
98th
102nd
104th
Flower
103rd
Maple
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98th
104th
Grevillea
97th
101st
S Grevillea Ave S La Brea Ave
S Prairie Ave
S Hawthorne Blvd
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This TIA presents (i) a CEQA assessment of whether the Project conflicts or is inconsistent with local transportation-related plans and policies, (i i) a CEQA assessment of Project-related VMT, and (iii) a CEQA assessment of whether the Project increases hazards due to a geometric design feature or incompatible use.
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2.0 PROJECT DESCRIPTION
2.1 Site Location
The Project Site is located at 4200 W. Century Avenue and 4229-4233 W. 101 st Street in City of Inglewood. The Project Site is bounded by Century Boulevard to the north, 101 st Street to the south, an existing motel to the west, and Freeman Avenue to the east. The Project Site location and general vicinity are shown in Figure 1–1.
2.2 Existing Project Site
The Project Site is improved an existing hote l with 137 guestrooms a nd associated surface parking (Assessor Parcel Nos. 4034-002-001, 4034-002-002, and 4034-002-004). Vehicular access to the existing Project Si te is provided via two drivew ays (one inbound-only and one outbound-only) along the south side of Century Boulevard and tw o driveways along the west side of Freeman Avenue. In addition, there are two existing curb cuts along the north side of 101
st Street. However, these driveways are gated off and not operational.
2.3 Project Description
The Project proposes to remove the existing imp rovements and construct a new 13-story mixed- use development with 118 reside ntial apartment dwel ling units, 11 residential condominium dwelling units, 175 hotel guestrooms, and 42,350 squa re feet of event and entertainment area.
The event and entertainment area consists of 3,600 square feet of lobby/lounge space, 7,730 square feet of main event space, a 9,000 square-f oot food hall, 1,330 square feet of café space, 9,300 square feet of bowling lanes, 800 square feet of retail space, 6,220 square feet of lounge/bar space, and 4,370 square feet of virtual sports suites.
The Project Site is in close proximity to major existing attractions within and near the City of Inglewood including LAX (approximately three miles to the west), as well as SoFi Stadium, YouTube Theater, and the Forum (all approximately one mile to the northeas t). In addition, the future Inglewood Basketball and Entertainment Center (“IBEC”), since renamed as the Intuit Dome, will be within a one-third mi le distance from the Project Site. It is envisioned that future residents of the Project will take advantage of th e Project’s proximity to these uses (e.g., a renter or owner of a residential unit at the Project will be an official with a professional sports league or team, fly to LAX, and then use shared ride services to travel to the Project Site as well as to one of the nearby venues while in town). Accordi ngly, it is assumed that the Project’s residential units would be occupied on a part-time basis. In addition, the Project ’s event/entertainment space is intended to attract pers ons already traveling to Inglew ood to attend a game, concert or other event at one or more of the existing and future venues (e .g., a fan attending a Clippers game will arrive early to the Proj ect Site, have dinner, and then walk to the Intuit Dome). Based on the existing and expected future calendar of ev ents at all of the ne arby venues, there will likely be some event occurring near the Project Site almost every day of the year.
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The Project will provide a total of 915 vehicula r parking spaces within an on-site parking structure with one subterranean level, one at -grade level, and six above-grade levels.
Construction and occupancy of the proposed Proj ect is planned to be completed by the year 2027. The site plan for the proposed Project is illustrated in Figure 2–1.
Vehicular access to the Project Site will be provided via Freeman Avenue and 101 st Street.
Further discussion of the Project Site access and circulation schemes is provided in Section 3.0
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Project Site Plan
Ground Floor Plan
4200 Century
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3.0 SITE ACCESS AND CIRCULATION
The proposed site access scheme for the Project is displayed in Figure 2–1. A description of the proposed site access and circulation scheme is provided in the following subsections.
3.1 Existing Vehicular Site Access
Vehicular access to the existi ng hotel’s drop-off/pick-up area is provided via one inbound-only driveway along the south side of Century Boulevard, opposite Myrtle Avenue. Vehicular egress from the existing ho tel’s drop-off/pick-up area is provided via one outbound-only driveway along the south side of Ce ntury Boulevard, east of the Myrtle Avenue intersection. Vehicular access to the existing Project Site ’s main parking area is provi ded via one driveway along the west side of Freeman Avenue. A second drivew ay is provided on the west side of Freeman Avenue, just north of the 101st Street intersection. However, this driveway is scarcely utilized.
In addition, there are two existing curb cuts along the north side of 101 st Street. However, these driveways are gated off and not operational.
3.2 Vehicular Project Site Access
Vehicular access to the Project will be provided via two access points. Project residents and their guests will access th e Project’s on-site parking garage via a driveway along the north side of 101 st Street. Vehicular access fo r the Project’s hotel and event and entertainment space components will be provided via an access poin t along the west side of Freeman Avenue.
Further details are provided in the sections below.
3.2.1 Residential Component Vehicular Access
Vehicular access to the Project’s on-site parking garage related to the residential component will be provided via one driveway along the north side of 101 st Street. The new driveway on 101 st Street is proposed to accommodate full vehicula r access (left-turn and right-turn ingress and egress movements).
3.2.2 Hotel and Event and Entertainment Area Component Vehicular Access For the hotel and event and entertainment area co mponents, the Project will provide an on-site valet, with the valet drop-off/pick-up area to be located along the west side of Freeman Avenue.
Vehicles bound to the Project’s valet area will access the valet drop-off/pick-up area by making a southbound right-turn from Freema n Avenue into the northerly Freeman Avenue Driveway.
Vehicles will continue southbound in the valet dr op-off/pick-up area and leave their vehicle with a valet attendant. The attendant will then park the vehicle in the on-site parking garage.
Vehicles leaving the Project Site from the valet drop-off/pick-up area will exit via the outbound- only southerly Freeman Avenue Driveway via a left - or right-turn onto Freeman Avenue. It is noted that valet attendants will be able to access the parking garage internally from the valet drop-off/pick-up area and will not need to utilize local streets (i.e., Freeman Avenue and 101 st Street) to park vehicles.
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3.3 Project Loading
Loading activities associated with service and delivery operations will occur within the loading dock along the north side of 101 st Street, east of the driveway providing access to the Project’s on-site parking garage for the residential comp onent. Vehicles bound to the Project’s loading dock will make a right-turn into the Project Site from westbound 101 st Street. Vehicles exiting the Project’s loading area will make a left-turn onto eastbound 101 st Street. The Project’s loading dock has been designed to accommodate vehicles up to 23 feet in length.
The AutoTURN software package was utilized to demonstrate that delivery vehicles can successfully enter and exit the Project’s loading space. Exhibits demonstrating the maneuvers of 23-foot delivery vehicles (DL-23) entering and exiting the Project’s loading dock are contained within Appendix A. As shown in the exhibits contained within Appendix A, DL-23 vehicles can enter the Project’s loading dock via a conti nuous westbound right-turn movement (i.e., three- point turns are not required). Similarly, DL-23 vehicles can exit the Project’s loading dock via a continuous southbound left-turn movement. It is noted that inbound left-turn movements and outbound right-turn movements to and from the loading dock will be prohibited.
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4.0 EXISTING STREET SYSTEM
4.1 Regional Highway System
Regional access to the Project Site is provided by the I-405 (San Diego) Freeway and I-105 (Glenn Anderson) Freeway. Brief descriptions of the I-405 Freeway and I-105 Freeway are provided in the following paragraphs.
I-405 (San Diego) Freeway is a north-south freeway that extends across southern California from the Granada Hills area of the City of Los Angeles to Irvine. In the Project vicinity, five mainline freeway lanes (four mixed-flow lanes and one carpool lane) are provided in each direction on the I-405 Freeway, with auxiliary merge/weave la nes provided between some interchanges.
Northbound and southbound on- and off-ramps are provided on the I-405 Freeway at Century Boulevard in the Project vicinity, which are located approximately 1.2 miles west of the Project Site.
I-105 (Glenn Anderson) Freeway is an east-west freeway th at extends from El Segundo to Norwalk. In the Project vicinity, five mainlin e freeway lanes (four mi xed-flow lanes and one carpool lane) are provided in each direction on the I-105 Freeway, with auxiliary merge/weave lanes provided between some interchanges. Eastbound and westbound on- and off-ramps are provided on the I-105 Freeway at Prairie Av enue and are located approximately 1.3 miles southeast of the Project Site . Additionally, an eastbound on-ra mp and westbound off-ramp are provided on the I-105 Freeway at Hawthorne Boul evard and are located approximately 1.2 miles southwest of the Project Site.
4.2 Local Roadway System and Roadway Descriptions
Immediate access to the Project Site will be pr ovided via Century Boulevard, Freeman Avenue, and 101 st Street. A brief description 2 of the roadways in the immediate Project vicinity is provided in the following paragraphs.
Hawthorne Boulevard is a north-south oriented roadway located west of the Project Site. Within the Project study area, Hawthorne Boulevard is designated as a Major Arterial by the City and as a Major Highway by the County of Los Angeles (t he “County”). Three through travel lanes are provided in each direction on Hawthorne Boulevar d within the Project study area. Separate exclusive left- and ri ght-turn lanes are provided in the northbound direction on Hawthorne Boulevard at the Century Boulevard intersec tion. North of Centur y Boulevard, Hawthorne Boulevard becomes La Brea Avenue. Hawthorne Boulevard has a posted speed limit of 35 miles per hour within the Project study area.
La Brea Avenue is a north-south oriented roadway locate d west of the Project Site. Within the Project study area, La Brea Avenue is designated as a Major Arterial by the City and as a Major Highway by the County. Three th rough travel lanes are provided in each direction on La Brea
2 For reference, the street descriptions provided include designations under the Circulation Element of the Inglewood General Plan, City of Inglewood, December 1992, and the Los Angeles County Highway Plan. -9-
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Avenue within the Project study area. A separate exclusive left-turn lane is provided in the southbound direction on La Brea Avenue at the Century Boulevard intersection. South of Century Boulevard, La Brea Ave nue becomes Hawthorne Boulev ard. La Brea Avenue has a posted speed limit of 35 miles per hour within the Project study area.
Myrtle Avenue is a north-south oriented roadway located north of the Project Site. Within the Project study area, Myrtle Avenue is designated as a Collector by the City and as a Local Street by the County. One through travel lane is provided in each direc tion on Myrtle Avenue within the Project study area. Myrtle Avenue has a pos ted speed limit of 30 miles per hour within the Project study area.
Freeman Avenue is a north-south oriented roadway that borders the Project Site to the east.
Within the Project study area, Freeman Avenue is designated as a Collector by the City and as a Local Street by the County. One through travel la ne is provided in each direction on Freeman Avenue within the Project study area. There is no speed limit posted on Freeman Avenue within the Project study area, thus a prima facie speed limit of 25 miles per hour is assumed, consistent with California Vehicle Code Section 22352(b)(1).
Prairie Avenue is a north-south oriented roadway located west of the Project Site. Within the Project study area, Prairie Avenue is designated as a Major Arterial by the City and as a Major Highway by the County. Three through travel la nes are provided in each direction on Prairie Avenue within the Project study area. Separate exclusive left-turn lanes are provided in each direction on Prairie Avenue at major intersections. Prairie Avenue has a posted speed limit of 40 miles per hour within the Project study area.
Century Boulevard is an east-west oriented roadway that borders the Project Site to the north.
Within the Project study area, Ce ntury Boulevard is designated as a Major Arterial by the City and as a Major Highway by the County. Three through travel lanes are provided in each direction on Century Boulevard within the Project study area. Sepa rate exclusive left-turn lanes are provided in each direction on Century Boulevard at major intersections. A separate exclusive right-turn lane is provided in the westbound dire ction on Century Boulevard at the Prairie Avenue intersection. Century Boulevard has a posted speed limit of 40 miles per hour within the Project study area.
101
st Street is an east-west oriented roadway that borders the Project Site to the south. Within the Project study area, 101 st Street is designated as a Local Street by the City and the County.
One through travel lane is provided in each direction on 101 st Street within the Project study area. There is no speed limit posted on 101 st Street within the Projec t study area, thus a prima facie speed limit of 25 miles pe r hour is assumed, consistent with California Vehicle Code Section 22352(b)(1).
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4.3 Public Transit Services
Public transit service within the Project study area is currently provided by the Los Angeles County Metropolitan Transit Authority (“Metro”), the City of Torrance (“Torrance Transit”), and Los Angeles County Public Works (“The Link”). A summary of the existing transit service, including the transit route, destinations and peak hour headways is presented in Table 4–1. The existing public transit routes in the Project Site vicinity are illustrated in Figure 4–1.
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23-Jan-24
ROADWAY(S)
ROUTE DESTINATIONS NEAR SITE DIR AM PM
Metro 40 Downtown Los Angeles to South Bay/Redondo Beach La Brea Avenue, Hawthorne Boulevard NB 7 6 (via King Boulevard and Hawthorne Boulevard) SB 6 7
Metro 117 LAX City Bus Center to Downey Century Boulevard EB 4 4 (via Century Boulevard and Imperial Highway) WB 4 4
Metro 211/215 Inglewood to Redondo Beach Prairie Avenue, CW 1 1 (via Prairie Avenue and Inglewood Avenue) Inglewood Avenue CCW 1 1 Metro 212 Hollywood/Highland Station to Hawthorne/Lennox Station Prairie Avenue NB 7 6 (via La Brea Avenue) SB 6 6
The Link - Lennox Roundtrip from Lennox Park Freeman Avenue, Century Boulevard, CW 0 0 (via Lennox Boulevard, 104th Street, and Century Boulevard) Myrtle Avenue, Hawthorne Boulevard CCW 2 2 Torrance Transit Line 10 Downtown Inglewood Station to Crenshaw Boulevard/Pacific Coast Highway Prairie Avenue NB 1 1 (via Crenshaw Boulevard, Imperial Highway, and Prairie Avenue) SB 1 1 Total 40 39
[1] Sources: Los Angeles County Metropolitan Transportation Authority ("Metro") website, 2024.
Unincorporated County of Los Angeles Transit Services ("The Link") website, 2024.
City of Torrance Transit ("Torrance Transit") website, 2024.
CW: Clockwise
CCW: Counterclockwise
Table 4-1
EXISTING PUBLIC TRANSIT ROUTES [1]
NO. OF BUSES
DURING PEAK HOUR
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4200 Century
Figure 4-1
Existing Public Transit Routes
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5.0 PROJECT TRAFFIC GENERATION
Traffic volumes expected to be generated by the proposed Project during the weekday AM and PM peak hours, as well as on a daily basis were estimated using rates published in the Institute of Transportation Engineers’ (“ITE”) Trip Generation Manual.3 The following trip generation rates were used to forecast the traffic volumes expected to be generated by the Project:
Apartments: ITE Land Use Code 221 (Multifa mily Housing [Mid-Rise]) trip generation average rates were used to forecast the traf fic volumes expected to be generated by the residential apartment component of the Proj ect. While the residential apartments are expected to be occupied on a part-time basis, use of the standard ITE trip rates reflect a conservative analysis.
Condominiums: ITE Land Use Code 221 (Mu ltifamily Housing [Mid-Rise]) trip generation average rates were used to fore cast the traffic volumes expected to be generated by the residential condominiu m component of the Project. While the residential condominiums are expe cted to be occupied on a part-time basis, use of the standard ITE trip rates reflect a conservative analysis. Hotel: ITE Land Use Code 310 (Hotel) trip generation average rates were used to forecast the traffic volumes expected to be generated by the hotel component of the Project. Restaurant: ITE Land Use Code 930 (Fast Casu al Restaurant) trip generation average rates were used to forecast the traffic volumes e xpected to be generated by the food hall and café uses contained within the Project’s event and entertainment area. Retail: ITE Land Use Code 822 (Strip Retail Plaza [40k]) trip generation average rates were used to forecast the traffic volumes exp ected to be generated by the retail space contained within the Project’s event and entertainment area. Bar: ITE Land Use Code 975 (Dri nking Place) trip generation average rates were used to forecast the traffic volumes expected to be generated by the 2 nd floor lounge /bar and virtual sports suites uses contained within the Project’s event and entertainment area. Event/Entertainment: ITE Land Use Code 435 (Multipurpose Recreational Facility) trip generation average rates were used to fore cast the traffic volumes expected to be generated by the lobby/lounge, main event spac e, and bowling uses contained within the Project’s event/entertainment area.
In addition to the trip generati on forecasts for the Project (which are essentially an estimate of the number of vehicles that could be expected to enter and exit the Project Site access points), an adjustment was made to the trip generation forecast based on the Project Site’s existing land use.
The existing land use in cludes a hotel with 137 gue strooms. The trips associated with the
3 Institute of Transportation Engineers Trip Generation Manual, 11th Edition, Washington, D.C., 2021. -14-
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existing use will be subtracted from the projecte d Project trips to account for the existing environmental condition. ITE Land Use Code 310 (Hotel) trip generation average rates were used to estimate the trip reduction related to the existing use.
A forecast was also made of the transit trips that will be generated by the Project in lieu of trips by the private automobile. The Project Site is currently served by many local lines and regional/commuter lines via stops located within convenient walking distance along Century Boulevard, Hawthorne Boulevard, La Brea Avenue, and Prairie Avenue. The transit lines include Metro Local Lines 40, 117, 211/215, 212, the Lo s Angeles County Department of Public Works’ The Link – Lennox shuttle, and Torrance Tran sit Line 10. A transit adjustment of five percent (5%) has been utilized.
Furthermore, a forecast was also made of the wa lk-in trips that will be generated by the Project in lieu of trips by the private automobile. The walk-in trip reduction accounts for walk-in patronage both from within the Project as well as other surrounding land uses, specifically the Intuit Dome (which will be operational prior to the opening of the Project), SoFi Stadium, YouTube Theater and other uses within the Hollywood Park Specifi c Plan site, as well as the Forum. A walk-in adjustment of 15% has been utilized for the Project’s hotel and event and entertainment space components, as well as the existing hotel, due to the Project Site’s proximity to major pedestrian attractors.
Lastly, an internal capture adjustment has been applied for the Project to account for synergistic effects of the planned land use mix. Internal capture trips are those trips made internal to the site between land uses in a mixed or multi-use devel opment, due to the fact that land uses tend to interact, and thus attract a portion of each other’s trip generation. An internal capture adjustment of 10% has been utilized to account for the inter actions between the residential, hotel, and event and entertainment uses provided within the Project Site.
As shown in Table 5–1 , the Project is expected to generate 60 net new vehicle trips (19 inbound trips and 41 outbound trips) during the weekday AM peak hour. During the weekday PM peak hour, the Project is expected to generate 313 net new vehicle trips (176 inbound trips and 137 outbound trips). Over a 24-hour pe riod, the Project is forecast to generate 3,067 net new daily vehicle trips ends (approximately 1,534 inbound tr ips and 1,533 outbound trips) during a typical weekday.
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Table 5-1
PROJECT TRIP GENERATION [1]
26-Jan-24
DAILY AM PEAK HOUR PM PEAK HOUR
TRIP ENDS [2] VOLUMES [2] VOLUMES [2]
LAND USE SIZE VOLUMES IN OUT TOTAL IN OUT TOTAL
Proposed Project
Apartments [3], [4] 118 DU 536 10 34 44 28 18 46
Condominiums [3], [4] 11 DU 50 134224
Hotel [5] 175 Rooms 1,398 45 36 81 53 50 103
Restaurant [6], [7], [8] 10,330 GSF 1,003 -- -- -- 72 58 130 Retail [7], [9] 800 GLSF 44 -- -- -- 3 2 5
Bar [7], [10], [11], [12] 10,590 GSF 1,330 -- -- -- 73 60 133 Event/Entertainment [7], [13], [14], [15] 20,630 GSF 740 -- -- -- 41 33 74
Subtotal 5,101 56 73 129 272 223 495
Transit Trips [16]
Apartments (5%) (27) (1) (2) (3) (1) (1) (2)
Condominiums (5%) (3) 000000
Hotel (5%) (70) (2) (2) (4) (3) (3) (6)
Restaurant (5%) (50) 0 0 0 (4) (3) (7)
R e t a i l ( 5 % ) ( 2 ) 000000
Bar (5%) (67) 0 0 0 (4) (3) (7)
Event/Entertainment (5%) (37)
0 0 0 (2) (2) (4)
Subtotal (256) (3) (4) (7) (14) (12) (26)
Walk-In Trips [17]
Hotel (15%) (199) (6) (5) (11) (8) (7) (15)
Restaurant (15%) (143) 0 0 0 (10) (8) (18)
R e t a i l ( 1 5 % ) ( 6 ) 000000
Bar (15%) (189) 0 0 0 (10) (9) (19)
Event/Entertainment (15%) (105) 0 0 0 (6) (5) (11)
Subtotal (642) (6) (5) (11) (34) (29) (63)
Internal Capture [18]
Restaurant (10%) (81) 0 0 0 (6) (5) (11)
R e t a i l ( 1 0 % ) ( 4 ) 000000
Bar (10%) (107) 0 0 0 (6) (5) (11)
Event/Entertainment (10%) (60) 0 0 0 (3) (3) (6)
Subtotal (252) 0 0 0 (15) (13) (28)
Subtotal Project Driveway Trips 3,951 47 64 111 209 169 378 Existing Site
Hotel [5] (137) Rooms (1,095) (35) (28) (63) (41) (40) (81) Subtotal (1,095) (35) (28) (63) (41) (40) (81)
Existing Transit Trips [16]
Hotel (5%) 55 2 1 3 2 2 4
Subtotal 5 5 213224
Existing Walk-In Trips [17]
Hotel (15%) 156 5 4 9 6 6 12
Subtotal 1 5 6 54966 1 2
Subtotal Existing Driveway Trips (884) (28) (23) (51) (33) (32) (65) NET INCREASE DRIVEWAY TRIPS 3,067 19 41 60 176 137 313
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[1] Source: ITE Trip Generation Manual, 11th Edition, 2021. [2] Trips are one-way traffic movements, entering or leaving. [3] ITE Land Use Code 221 (Multifamily Housing [Mid-Rise]) trip generation average rates. - Daily Trip Rate: 4.54 trips/dwelling unit; 50% inbound/50% outbound - AM Peak Hour Trip Rate: 0.37 trips/dwelling unit; 23% inbound/77% outbound - PM Peak Hour Trip Rate: 0.39 trips/dwelling unit; 61% inbound/39% outbound [4] While residential units are expected to be occupied on a part-time basis, use of the standard ITE trip rates reflect a conservative analysis.
[5] ITE Land Use Code 310 (Hotel) trip generation average rates. - Daily Trip Rate: 8.36 trips/room; 50% inbound/50% outbound - AM Peak Hour Trip Rate: 0.47 trips/room; 59% inbound/41% outbound - PM Peak Hour Trip Rate: 0.60 trips/room; 51% inbound/49% outbound [6] ITE Land Use Code 930 (Fast Casual Restaurant) trip generation average rates. - Daily Trip Rate: 97.14 trips/1,000 SF of floor area; 50% inbound/50% outbound - PM Peak Hour Trip Rate: 12.55 trips/1,000 SF of floor area; 55% inbound/45% outbound [7] Use will not be open during weekday AM peak hour, and therefore is assumed to generate negligible trips. [8] Restaurant uses include Food Hall (9,000 square feet) and Café (1,330 square feet) uses. [9] ITE Land Use Code 822 (Strip Retail Plaza [<40k]) trip generation average rates. - Daily Trip Rate: 54.45 trips/1,000 SF of floor area; 50% inbound/50% outbound - PM Peak Hour Trip Rate: 6.59 trips/1,000 SF of floor area; 50% inbound/50% outbound [10] ITE Land Use Code 975 (Drinking Place) trip generation average rates. - Daily Trip Rate: Unavailable
- PM Peak Hour Trip Rate: 11.36 trips/1,000 SF of floor area; 66% inbound/34% outboun d
[11] PM Peak Hour trips assumed to be 10% of Daily trips. [12] Bar uses include include 2nd Floor Lounge/Bar (6,220 square feet) and Virtual Sports Suites (4,370 square feet) uses. [13] ITE Land Use Code 435 (Multipurpose Recreational Facility) trip generation average rates. - Daily Trip Rate: Unavailable
- PM Peak Hour Trip Rate: 3.58 trips/1,000 SF of floor area; 55% inbound/45% outboun d
[14] PM Peak Hour trips assumed to be 10% of Daily trips. [15] Event/Entertainment uses include Lobby/Lounge space (3,600 square feet), Main Event Space (7,730 square feet), an d
Bowling (9,300 square feet) uses.
[16] The transit reduction is based on the Project Site's proximity to Metro bus stops and various bus lines, as well as the land use characteristics of the existing site and the Project.
[17] The walk-in trip reduction accounts for walk-in patronage both from within the Project as well as other surrounding uses (i.e., future Clippers arena, SoFi Stadium, Hollywood Park, and the Forum). [18] The internal capture reduction for the restaurant, retail, bar, and Event/Entertainment uses within the Project Site is based on the synergy between the residential, hotel, restaurant, retail, bar, and Event/Entertainment land uses provided within the Project Site.
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6.0 CONSISTENCY WITH LOCAL PLANS, PROGRAMS, ORDINANCES, OR POLICIES
6.1 Impact Criteria and Methodology
The impact criteria set forth in Appendix G to the State CEQA Guidelines, as well as Section 3.1 of the City's TIA Guidelines, regarding conflicts with plans, programs, ordinances, or policies are as follows:
Would the project conflict with a program, plan, or dinance, or policy addressing the circulation system, including transit, roadways, bicycle, and pedestrian facilities? The threshold test is to assess whether a project would conflict with an adopted program, policy, plan, or ordinance that is adopted to protect the environment. In genera l, transportation policies or standards adopted to protect the environment are those that support multimodal transportation options and a reduction in VMT. Conversely, a project would not always have a significant impact merely based on whether it would implement a particular transportation-related program, plan, policy, or ordinance. Many of these prog rams must be implemented by the City itself over time, and over a broad area, and it is the intention of this threshold test to ensure that proposed development projects and plans do not preclude the City from implemen ting adopted programs, plans and policies.
The methodology for determining a project's transportation impact associated with conflicts with plans, programs, ordinances, or policies is describe in the TAG as follows:
A project that generally conforms with a nd does not obstruct the City’s development policies and standards will generally be cons idered to be consistent. The Project Applicant should review the documents and ordinances identi fied in the TIA Guidelines (refer to Table 3.1-1 thereof) for City plans, policies, programs, ordinances, and standards relevant to determining project consistency.
The City has prepared and adopted many plans, programs, ordinanc es, or policies that establish the framework for transportation planning involv ing all travel modes. These policies have overall goals to provide a safe, accessible, and sustainable tran sportation infrastructure for all users.
Generally, the City’s transportation policies or standards that protect the environment are outlined to support multi ‐modal transportation options resu lting in a reduction of VMT. A project would not specifically be shown to resu lt in an impact by virtue of not implementing a plan, program, ordinance, or policy as a whole, since many of these are implemented by the City over time, and over a broader area, but the intention of th is threshold is to ensure that proposed development projects and plans do not preclude the City fro m implementing these plans, programs, ordinances, or programs. The project should coordinate with the City to ensure compliance with the City’s current list of plans, programs, ordinances, or policies. -18-
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6.2 Review of Project Consistency
This section provides a summary of the consistency review that co mpares the characteristics of the Project and site design features (i.e., includ ing the site access and circulation scheme) with the City’s relevant plans and policies. Appendix B provides a thorough review of plans, programs, ordinances, and policies listed in Table 3.1-1 of the City’s TIA Guidelines.
As confirmed in Appendix B , the Project would not conflict with the relevant City plans, programs, ordinances, or policies and does not include a ny features that would preclude the City from completing and complying with these guid ing documents and policy objectives. The Project will not conflict with a ny plans or policies that govern the public right-of-way, such as Circulation Element of the City’s General Plan. The Project has been found to be consistent with the greenhouse gas (“GHG”) reduction strategies in Connect SoCal4, the Regional Transportation Plan/Sustainable Communities Strategy (“RTP/SCS”) of the Southern California Association of Governments (“SCAG”).
Therefore, the Project would not conflict with a program, plan, or dinance, or policy addressing the circulation system, including transit, roadways, bicycle, and pedestrian facilities, and the impact would therefore be “less than significant ”. Furthermore, the Project Applicant will comply with existing applicable City ordinances and other requirements pursuant to the City’s Municipal Code.
6.3 Review of Cumulative Consistency
As with the Project, the Intuit Dome and othe r nearby related projects will include adequate bicycle facilities and include high density urba n uses in proximity to the nearby multimodal transportation facilities. The related projects, as with the Project, w ould not conflict with adjacent street designations and classifications. No street widenings would be necessary for these projects. Accordingly, there would be no significant cumulative impacts to which the Project, as well as other nearby re lated projects contribute to rega rding transportation policies or standards adopted to protect the environment and support multimodal transportation options and a reduction in VMT.
Based on the discussion and conclusion in the preceding Section 6.2 and review of related projects in the Project vicinity, this documentation is sufficient to demonstrate that there is also no cumulative inconsistency with local plans, programs, ordinances, or policies, and therefore, the cumulative impacts of the Project would be less than significant. In addition, since the Project does not include any features that would preclude the City from completing and complying with these guiding documents and policy objective s, there is no cumulative inconsistency that can be determined.
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7.0 VEHICLE MILES TRAVELED ASSESSMENT
7.1 Introduction
VMT is defined as a measuremen t of miles traveled by vehicles within a specified region and for a specified period of time. VMT is a measure of the use a nd efficiency of the transportation network. VMTs are calculated ba sed on individual vehicl e trips generated and their associated trip lengths. VMT accounts for two-way (round-trip) travel and is often estimated for a typical weekday for the purpos es of measuring transportation impacts.
In September 2013, the Governor’s Office signed SB 743, starting a process that fundamentally changes the way transportation impact analysis is conducted under CEQA. Within the State’s CEQA Guidelines, these changes include the elimination of auto delay, LOS, and similar measurements of vehicular roadway capacity and traffic congestion as the basis for determining significant traffic impacts. SB 743 identifies VMT as the most appropriate CEQA transportation metric, along with the elimination of auto delay/LOS for CEQA purposes statewide. The justification for this paradigm shift is that LOS impacts lead to improvements that increase roadway capacity and therefore induce more traffic and greenhouse gas emissions.
The State of California Governor’s Office of Planning and Research (“OPR”) issued proposed updates to the CEQA Guidelines in November 2017 and an accompanying technical advisory guidance
5 in April 2018 (“OPR Technical Advisory ”) that amends the Appendix G question for transportation impacts to delete reference to vehicle delay and level of service and instead refer to Section 15064.3, subdivision (b)(1) of the CEQA Guidelines asking if the project will result in a substantial incr ease in vehicle miles traveled (VMT). Sec tion 15064.3, subdivision (b)(1) states the following:
Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact . Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high-quality transit corridor should be presumed to cause a less than significant transportation impact.
Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be considered to have a less than significant transportation impact.
Comprehensive updates to the State CEQA Guide lines were certified and adopted by the California Natural Resources Agency in D ecember 2018. Accordingly, the City adopted significance criteria for transportation impacts ba sed on VMT for land use projects and plans in accordance with the amended Appendix G question:
Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
4 Connect SoCal – The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments, Southern California Association of Governments, September 3, 2020. 5 Technical Advisory on Evaluating Transportation Impacts in CEQA, Governor’s Office of Planning and Research, December 2018.
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For land use projects, the intent of this threshol d is to assess whether a land use project causes substantial vehicle miles traveled. The City ha s developed screening criteria to address this question. The criteria below are based on the OPR Technical Advisory but reflect local considerations.
If the project requires discretionary action, and the answer is no to the following question, further analysis will not be required and a “less than significant” determination can be made:
Does the development project generate a net increase of 250 or more daily vehicle trips? o As indicated in Section 5.0, and as summarized in Table 5–1 , the Project is expected to generate a net increase of 3,067 daily vehicl e trips. Therefore, the Project is required to perform a VMT analysis.
7.2 Impact Criteria and Methodology
For development projects, the proposed project will have a potential VMT impact if the project meets the following:
For residential projects, the project would generate residential VMT per capita exceeding 15% below the existing residential VMT per capita for the Baseline Area in which the project is located, or greater than 9.66 residential VMT per capita. For office projects, the project would generate employment VMT per employee exceeding 15% below the existing employment VMT per employee for the Baseline Area in which the project is located, or greater than 14.46 employment VMT per employee. For event centers and regional serving retail projects, the project would result in a net increase in total VMT (citywide).
For other land use types (i.e ., the hotel employee component of the Project), measure VMT impacts for the work trip element using the criteria for office projects above.
7.3 Summary of Project VMT Analysis
The evaluation of the potential transportation impacts due to th e Project as measured through VMT is provided below:
Residential
The Project proposes 118 residential apartmen t dwelling units and 11 residential condominium dwelling units. As previously stated, it is expected that the residential units will be utilized by persons associated with sports teams, leagues, concert promoters, and ot hers regularly visiting the nearby entertainment venues, (SoFi Stadium, Intuit Dome, YouTube Theater, the Forum, etc.). Residents of the Project are therefore expected to occupy th eir units on a part-time basis.
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the Project’s units were consider ed as traditional fully-occupied dwelling units for purposes of conservative VMT analysis.
The residential VMT per capita for the Project was estimated utilizing the City’s VMT Calculator. The detailed City’s VMT Calcul ator worksheet for the Project’s residential component is contained in Appendix C . The City’s VMT Calculator contains a menu of transportation demand management (“TDM”) strategies that may be implemented as either Project Design Features (“PDF”) or mitigation measures. The Project will implement the Promotions and Marketing strategy (Strategy 4-N) within the City’s VMT Calculator, with 100% of residents participating. The Project will ut ilize promotional and marketing tools to educate and inform residents about alternative transpor tation options and the e ffects of their travel choices. Rather than two-way communication tools or tools that would encourage an individual to consider a different mode of travel at the time the trip is taken (i.e., smartphone application, daily email, etc.), this TDM strategy includes passive educational and promotional materials, such as posters, information boards, or a website with information that residents can choose to read at their own leisure. Ma terials would be placed in an ar ea with the greatest amount of visibility for Project residents (e.g., lobby, mailroom, elevator, etc.).
As shown in Appendix C , the estimated residential VMT pe r capita for the Project, with the Promotions and Marketing TDM strategy implemen ted with 100% of residents participating, is
8.81, which is less than the City’s significance threshold of 9.66 residential VMT per capita.
Therefore, the residential component of the Project would have a less than significant VMT impact.
Hotel and Event and Entertainment
The Project proposes a hotel co mponent with 175 guestrooms and an event and entertainment area totaling 42,350 square feet of retail, restaurant, and related commercial uses. It is noted that an existing hotel on the Project Site providing 137 guestrooms will be removed to accommodate construction of the Project. As previously stated , it is expected that the hotel will be utilized by guests to fly into Los Angeles at nearby LAX a nd then attend an event at one of the nearby venues located within a mile of the Project Site . As also previously noted, the event and entertainment area of the Project is intended to se rve as an ancillary use for residents and hotel guests at the Project, as well as to provide pre- and post-event dining and gathering opportunities for attendees of the nearby entertainment venues.
The employment VMT per employ ee expected to be generated by the Project was estimated utilizing the City’s VMT Calculator. While the City’s VMT Calculator does not allow for direct inputs for hotel uses, it does include direct inputs for office us es. General office employment VMT is similar to hotel and event/entertainment space employment VMT since in each instance, the employment VMT is the VMT generated by Home-Based Work trip attractions. While the employment trips to an d from home may occur at different hours, the character istics of these trips are similar (e.g., general of fice, hotel, and event/entertainment employees dr ive from home to work and back).
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To utilize the office-equivalency use in the City’s VMT Tool, an estimate of the number of hotel and event/entertainment employees at the Project is needed, which then can be converted to the approximate equivalent amount of office building floor area. The City utilizes a factor of 12 employees per 10 hotel guestrooms, which resu lts in 210 employees. For the event and entertainment area, a factor of four employees per 1,000 square fe et of floor area is utilized, which results in approximately 170 employees. In total, it is estimated that that Project would have 380 employees based on the employment factors accepted by the City. In order to calculate the daily commute trips, the total employment is multiplied by two, which results in 760 daily commute trips. The calculation for determining the office equivalent square footage is as follows:
760 trips / 10.84 trips *1,000 square feet = 70,111 square feet.
Based on the City’s accepted methodology, the employment generated by the Project’s hotel and event and entertainment component would correlate to a 70,111 square-foot office use.
Based on the methodology described above, the em ployment VMT per employee expected to be generated by employees of th e Project’s hotel and event a nd entertainment component was estimated utilizing the City’s VMT Calculator. The detailed City’s VMT Calculator worksheet for the Project’s hotel and event and entertainment component are contained in Appendix C. The Project will implement the Promot ions and Marketing strategy (Strategy 4-N) within the City’s VMT Calculator, with 100% of employees part icipating. The Project will utilize promotional and marketing tools to educate and inform empl oyees about alternative transportation options and the effects of their travel choices. Rather than two-way communicati on tools or tools that would encourage an individual to consider a different mode of travel at the time the trip is taken (i.e., smartphone application, daily email, etc.), this TDM strategy includes passive educational and promotional materials, such as posters, informati on boards, or a website with information that employees can choose to read at their own le isure. Materials would be placed in an area with the greatest amount of visibility for Project employees (e.g., an employee break room).
As shown in Appendix C, the estimated employment VMT pe r employee for the Project’s hotel and event and entertainment co mponent, with the Promotions and Marketing TDM strategy implemented with 100% of employees participa ting, is 14.67 employment VMT per employee.
This exceeds the City’s significance threshold of 14.46 employment VMT per employee.
Therefore, the hotel and event and entertainmen t component of the Project as it relates to employees would have a significant VMT impact prior to consideration of potential mitigation measures (See Section 7.4).
7.4 CEQA Transportation Mitigation Measures
As stated above, prior to the implementation of mitigation measures, the Project’s hotel and event and entertainment component would have a significant employm ent VMT per employee impact. The City’s VMT Calculator contains a menu of TDM strategies that can be implemented as mitigation measures. The Project will implement the Transit Subsidies strategy (Strategy 1-C) within the City’s VMT Calculator. Specifically, the Project will offer a minimum transit subsidy -23-
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of $0.75 per day to a minimum of 30% of the Project’s hotel and ev ent and entertainment employees. With the Transit Subsidies TDM strategy, the Project’s employment VMT per employee is reduced to 14.39 employment VMT pe r employee and would fall below the City’s threshold of 14.46 employment VMT per employee. Therefore, with implementation of the mitigation measures, the Project’s hotel and event and entert ainment component is expected to have a less than significant employment VMT per employee impact. No additional mitigation measures would be required.
7.5 Summary of Cumulative Impacts
Per the City’s TIA Guidelines, all development projects should consider short-term and long- term effects on VMT. Short-te rm effects are evaluated in th e detailed project-level VMT analysis. Cumulative effects that are long-term are demonstrated through consistency with the SCAG RTP/SCS. Since the SCAG RTP/SCS de monstrates compliance with air quality conformity requirements and GHG re duction targets, projects that are consistent with the SCAG RTP/SCS in terms of development location, densit y, and intensity would be part of the regional solution for meeting air polluti on and GHG goals and therefor e, would have a less than significant cumulative impact on VMT. As disc ussed in Section 6.2 herein and confirmed in Appendix B, the Project has been found to be consis tent with the GHG reduction strategies in Connect SoCal, SCAG’s RTP/SCS. Furthermore, as confirmed in Section 7.4, the Project would have a less than significant VMT impact on the Project level. Thus, as the Project does not demonstrate a significant impact in the Project level VMT analysis, a less than significant impact in the cumulative impact analysis can also be determined.
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8.0 GEOMETRIC DESIGN HAZARDS
8.1 Introduction
As stated in the City’s TIA Guidelines (refer to Section 3.5 thereof), impacts regarding the potential increase of hazards due to a geometric design feature generally relate to the design of access points to and from the project site, and may include safety, operational, or capacity impacts. Impacts can be related to vehicle/vehi cle, vehicle/bicycle, or vehicle/pedestrian conflicts as well as to operational delays caused by vehicles slowing and/or queuing to access a project site. These conflicts may be created by the driveway configuration or through the placement of project driveway(s) in areas of inadequate visibility, adjacent to bicycle or pedestrian facilities, or too close to busy or congested intersections.
Evaluation of access impacts requires details relative to project land use, size, design, location of access points, etc. These impacts are typically ev aluated for permanent conditions after project completion but can also be evaluated for temporary conditions during project construction.
Project access can be analyzed in qualitative and/ or quantitative terms, and in conjunction with the review of internal site circulation and access to parking areas. All proposed site access points should be evaluated.
8.2 Impact Criteria and Methodology
The impact criteria set forth in Appendix G of th e CEQA Guidelines, as we ll as the City’s TIA Guidelines for substantially increasing hazards due to a geometric design feature or incompatible use is defined as follows:
Would the Project substantially increase hazards due to a ge ometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Preliminary project access plans are to be re viewed in light of commonly accepted traffic engineering design standards to ascertain whether any deficiencies are appare nt in the site access plans which would be considered significant. The dete rmination of significa nce shall be on a case-by-case basis, considering the following factors:
The relative amount of pedestrian activity at project access points. Design features/physical configurations that affect the visibility of pedestrians and bicyclists to drivers entering and exiting the si te, and the visibility of cars to pedestrians and bicyclists.
The type of bicycle facilities the project driveway(s) crosses and the relative level of utilization.
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The physical conditions of the site and surrounding area, such as curves, slopes, walks, landscaping or other barriers, that could result in ve hicle/pedestrian, vehicle/bicycle, or vehicle/vehicle safety hazards.
The project location, or project-related change s to the public right -of-way, relative to proximity to the Pedestrian Routes to School program area. Any other conditions, including the approximate location of incompatible uses that would substantially increase a transportation hazard.
With respect to vehicle, bicycle and pedestrian safety impacts, the City’s TIA Guidelines (refer to Section 3.5 thereof) indicate that a review of all project access points, internal circulation, and parking access from an operational and safety perspe ctive (for example, tu rning radii, driveway queuing, line of sight for turns into and out of project drivew ay[s]) should be conducted. Where project driveways would cross pedestrian facilities or bicycle facilities (bike lanes or bike paths), operational and safety issues rela ted to the potential for vehicle/ pedestrian and vehicle/bicycle conflicts and the severity of consequences that could result shoul d be considered. In areas with moderate to high levels of pedestrian or bicycl e activity, the collection of pedestrian or bicycle count data may be required.
8.3 Qualitative Review of Site Access Points
As discussed in Section 4.2 herein, the Projec t Site has frontage alo ng Century Boulevard, Freeman Avenue, and 101 st Street. Century Boulevard is designated by the City as a Major Arterial by the City with a posted speed limit of 40 miles per hour. Freeman Avenue is designated by the City as a Collector with an assumed speed limit of 25 miles per hour. 101 st Street is designated by the City as a Local Street with an assumed speed limit of 25 miles per hour.
The Project will improve the pedestrian experience along these corridors, including at the Project Site access points, which will enhance connections to and from the numerous pedestrian destinations in the direct vicinity of the Proj ect Site. The Project wi ll improve the sidewalks along the Century Boulevard, Freeman Avenue, and 101 st Street property frontages to enhance the pedestrian experience and ensure ADA comp liance. Newly surfaced sidewalks will be provided along the Project Site’s Century Boulevard, Freeman Avenue, and 101 st Street frontages. Signalized crossings are provided with in convenient walking distance to the Project Site along the Century Boulevar d, La Brea Avenue, Hawthorne B oulevard, and Prairie Avenue corridors.
Bicycle facilities are not curr ently provided along Century Boul evard, Freeman Avenue, and 101st Street in the Project study area . While future bicycle facilities are currently not planned along these roadways, the Project would not precl ude the City from instal ling bicycle facilities on these roadways, or any other roadway in the Project vicinity. -26-
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The Project will remove the existing driveways along the south si de of Century Boulevard and new driveways will not be installed. Removal of the Cent ury Boulevard driveways would eliminate potential vehicle/pede strian conflicts at the existing site driveways, which would enhance the pedestrian experience along the corridor. As Project re sidents, guests, and visitors would travel on foot to the nearby pedestrian attractors such as the Intuit Dome (which will be operational prior to the opening of the Project), So Fi Stadium, YouTube Theater, and other uses within the Hollywood Park Specific Plan site, as well as the Fo rum, the pedestrian experience along the Century Boulevard corridor is of the utmost importance to the Project.
The Project will maintain and improve the existing Project Site access points along the west side of Freeman Avenue, which will be utilized for th e Project’s valet operations. Vehicles bound to the Project’s valet area will access the valet drop-off/pick-up area by making a southbound right- turn from Freeman Avenue into the northerly Freeman Avenue Driv eway. Vehicles will continue southbound in the valet drop-off/pick-up area and leave their vehi cle with a valet attendant. The attendant will then park the ve hicle in the on-si te parking garage. Vehicles leaving the Project Site from the valet drop -off/pick-up area will exit via the outbound-only southerly Freeman Avenue Driveway via a left- or right-turn onto Freeman Avenue. It is noted that valet attendants will be able to access th e parking garage internally from the valet drop- off/pick-up area and will not need to utilize local streets (i.e., Freeman Avenue and 101 st Street) to park vehicles. The Projec t’s valet drop-off/pick -up area has been de signed to provide circulation internal to the Proj ect Site to reduce conflicts w ith vehicles, pedestrians, and bicyclists along Freeman Avenue. Further review of the valet area is provided in Section 8.4 below. Additionally, access to the Project’s park ing garage will be provided via one driveway along the north side of 101st Street.
As detailed in Section 3.3, access to the Projec t’s loading docks will be provided via a new driveway along the nor th side of 101 st Street, east of the propos ed driveway providing access to the Project’s parking garage. The AutoTURN software package was utilized to demonstrate that delivery vehicles can successfully enter and exit the Project’s loading space. Exhibits demonstrating the maneuvers of 23-foot deliv ery vehicles (DL-23) entering and exiting the Project’s loading dock are contained within Appendix A . As shown in the exhibits contained within Appendix A , DL-23 vehicles can enter the Proj ect’s loading dock via a continuous westbound right-turn movement (i.e ., three-point turns are not required). Similarly, DL-23 vehicles can exit the Project’s loading dock via a continuous southbound left-turn movement.
The sidewalk and driveway improvements will be designed to improve conditions for all modes of travel and reduce the potential for vehicle/pedestrian conflicts at the driveways. An excellent line of sight is provided for all modes of travel (motorists, pedestrians, and bicyclists) at the Project’s proposed driveways.
The Project Site is located on flat terrain and the phys ical condition of the Project Site and the proposed entry/exit points would be improved in conjunction with the Project, therefore, the potential for vehicle/pede strian, vehicle/bicycle, or vehicle/vehicle impacts would be reduced.
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planned reduction of curb cuts along Cent ury Boulevard, and the proposed sidewalk improvements along the property’s Centur y Boulevard, Freeman Avenue, and 101 st Street frontages, no safety concerns related to geometric design are noted.
The driveways would not require the removal or relocation of existing passenger transit stops and would be designed and config ured to avoid or minimize potential conflicts with transit services and pedestrian traffic. No security ga tes or other parking control features are proposed along the Project Site driveways in close proximity to the public right-of-way. The driveways and site access points will be de signed to ensure adequate maneuvering by vehicles entering and exiting the Project Site. It is recommended th at “No Parking” signs be installed along the Project’s 101st Street frontage from the Freeman Avenue intersection to a point approximately 85 feet west of the residential parking access point (a pproximately 300 feet in total) to ensure that passenger and delivery vehicles entering and exiting the Project Site can do so safely. Assuming an average on-street parking space length of 26 feet, this would result in the loss of approximately 12 on-street parking spaces. Furt her discussion of the loss of street parking spaces is provided in the section below.
Therefore, based on the above, it can be determin ed that the Project w ould not substantially increase hazards due to a geometric design f eature or incompatible use, and a less than significant impact determination can be reached.
8.4 Sight Distance Review of Proposed 101st Street Driveways A sight distance review has been conducted to evaluate the adequacy of the sight distance provided at the two proposed driveways on 101 st Street. The westerly 101 st Street driveway will provide access to the Project’s on-site parking garage related to the residential component. The easterly 101st Street driveway will provide access to the Project’s loading dock. Specifically, the sight distance analysis has been prepared in order to determine the adequacy of motorists’ line of sight departing the two driveways.
The sight distance analysis has been prepared in accordance with the Cali fornia Department of Transportation (“Caltrans”) Highway Design Manual
6 (“HDM”). As discussed in Section 4.2
herein, 101 st Street is designated as a Local Street by the City and the County. One through travel lane is provided in each direction on 101st Street within the Project study area. There is no speed limit posted on 101 st Street within the Project study area, thus a prima fa cie speed limit of 25 miles per hour is assumed, cons istent with California Vehicle Code Section 22352(b)(1). Per Table 201.1 of the HDM, a stopping sight distance of 150 feet in each direction should be provided.
Appendix D contains exhibits displaying the minimum required stopping sight distance at each of the 101
st Street driveways. As illustrated in the exhibits contained in Appendix D, the front bumper of the vehicle wa s placed at the edge of the curb cut, with the driver set back approximately eight feet. The exhibits show th at the removal of parking spaces along the north
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side of 101st Street will be required to provide the minimum stopping sight distance. In total, it is estimated that 12 street parking spaces would n eed to be removed in order to accommodate the proposed driveways.
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9.0 CONCLUSIONS
This TIA has been prepared to evaluate the potential transportation impacts due to the proposed 4200 Century project located at 4200 W. Century Avenue and 4229-4233 W. 101 st Street in the City of Inglewood.
Project Description – The Project proposes to rem ove the existing improvements and construct a new 13-story mixed-use development with 118 residential apartment dwelling units, 11 residential condominium dwelling units , 175 hotel guestrooms, and 42,350 square feet of event and entertainment area. The event and entertainment area consists of 3,600 square feet of lobby/lounge space, 7,730 square feet of main event space, a 9,000 square-foot food hall, 1,330 square feet of ca fé space, 9,300 square feet of bowling lanes, 800 square feet of retail space, 6,220 square feet of lounge/bar space, and 4,370 square feet of virtual sports suites.
The Project Site is in close proximity to ma jor existing attractions within and near the City of Inglewood including L AX (approximately three miles to the west), as well as SoFi Stadium, YouTube Theater, and the Fo rum (all approximately one mile to the northeast) and the Forum. In addition, the Intuit Dome, will be w ithin a one-third mile distance from the Project Site. It is envisione d that future residents of the Project will take advantage of the Projec t’s proximity to these uses (e.g., a renter or owner of a residential unit at the Project will be an offici al with a professional sports league or team, fly to LAX, and then use shared ride services to travel to the Project Site as well as to one of the nearby venues while in town). Acco rdingly, it is assumed that the Project’s residential units would be oc cupied on a part-time basis. In addition, the Project’s event/entertainment space is intended to attract persons already traveling to Inglewood to attend a game, concert or othe r event at one or more of the existing and future venues (e.g., a fan attending a Clippers game will arrive early to the Project Site, have dinner, and then walk to the Intuit Dome). Based on the existing and expected future calendar of events at all of the nearby venues, there will likely be some event occurring near the Project Site almost every day of the year.
The Project will provide a total of 915 vehicula r parking spaces within an on-site parking structure with one subterranean level, one at-grade level, and six above-grade levels.
Construction and occupancy of the proposed Pr oject is planned to be completed by the year 2027.
Study Scope – This TIA presents (i) a CEQA assessment of whether the Project conflicts or is inconsistent with local transportation-related plans and policies, (ii) a CEQA assessment of Project-related VMT, and (iii) a CEQA assessment of whether the Project increases hazards due to a geometric design feature or incompatible use.
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Project Trip Generation – The Project is expected to generate 60 net new vehicle trips (19 inbound trips and 41 outbound trips) during the weekday AM peak hour. During the weekday PM peak hour, the Project is expect ed to generate 313 net new vehicle trips (176 inbound trips and 137 outbound trips). Over a 24-hour period, the Project is forecast to generate 3,067 net new daily vehicle trips ends (approximately 1,534 inbound trips and 1,533 outbound trips) during a typical weekday. CEQA Analysis
o Consistency with Local Programs, Plans, Ordinances, and Policies: The Project has been found to be consistent with the relevant programs, plans, ordinances, and policies that address the circulation system, and does not include any features that would preclude the City from completi ng and complying w ith these guiding documents and policy objectives. Ther efore, a less than significant impact determination can be made for the Proj ect with respect to consistency with transportation plans, programs, ordinances, or policies. Furthermore, the Project Applicant will comply with existing ap plicable City ordinances and other requirements pursuant to the City’s Municipal Code.
o Vehicle Miles Traveled Analysis: The Project would not result in a significant VMT impact following consideration of r ecommended mitigation measures. As discussed in Section 7.3 herein, based on the City’s VMT Calculator, the Project’s residential VMT per capita is less than the City’s established threshold. The City’s accepted office-equivalency VM T methodology has been utilized to forecast the employment VMT per empl oyee related to hotel and event and entertainment component employees. Prio r to mitigation, the Project’s hotel and event/entertainment component would have a significant employment VMT per employee impact. As discussed in Sec tion 7.4 herein, a TDM mitigation measure has been identified, which woul d reduce the Project’s hotel and event/entertainment employment VMT per employee impact to a less than significant level. Based on the Project-rel ated VMT analysis and the conclusions discussed in Sections 7.3 and 7.4 (which demonstrate that the Project falls under the City’s efficiency-based impact thresholds and thus are already shown to align with the long-term VMT and GHG reduction goals of SCAG’s RTP/SCS), the Project would have a less than significant cumulative VMT impact. o Geometric Design Review: Given the existing physical condition of the Project Site, surrounding land uses, and planned pedestrian enhancements, no safety concerns related to geometric design ar e noted. Vehicular access to the Project Site will be provided via Project’s on-site parking garage will be provided via one driveway along the north side of 101
st Street. In addition, the Project will provide
an on-site valet, with the valet drop-off/pick-up area to be located along the west side of Freeman Avenue. Vehicles bound to the Project’s valet area will access the valet drop-off/pick-up area by making a southbound right-turn from Freeman -31-
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Avenue into the northerly Freeman Avenue Driveway. Vehicles will continue southbound in the valet drop-off/pick-up area and leave their vehicle with a valet attendant. The attendant will then park the vehicle in the on-site parking garage.
Vehicles leaving the Project Site from the valet drop-off/pick-up area will exit via the outbound-only southerly Freeman Avenue Driveway via a left- or right-turn onto Freeman Avenue. It is noted that va let attendants will be able to access the parking garage internally from the valet drop-off/pick-up area and will not need to utilize local streets (i.e., Freeman Avenue and 101
st Street) to park vehicles.
Access to the Project’s loading docks will be provided via a new driveway along the north side of 101
st Street, east of the proposed driveway providing access to the Project’s parking garage. The AutoTU RN software package was utilized to demonstrate that 23-foot delivery vehicl es can successfully enter and exit the Project’s loading space via an inbound right-turn movement and an outbound left- turn movement without having to make a three-point tur n. The Project’s driveways will be designed per City sta ndards. Furthermore, upon completion of the Project, the number of driveways along the Project Site’s Century Boulevard frontage will be redu ced from two to zero. Therefore, it can be determined that the Project will not substantially increas e hazards due to a geometric design feature or incompatible use, resulting in a less than significant impact determination.
o Sight Distance Review of Proposed 10 1st Street Driveways: A sight distance review has been conducted to evaluate the adequacy of the sight distance provided at the two proposed driveways on 101 st Street. Based on the analysis, it can be concluded that the minimum required stopping sight distance of 150 feet in each direction can be provided for the proposed driveways on 101 st Street. It is estimated that up to 12 street parking spaces along the north side of 101 st Street
would need to be removed to accommodate
the required stopping sight distance.
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APPENDIX A
LOADING AREA MANEUVERING EXHIBITS
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APPENDIX B
LOCAL PLANS, PROGRAMS, ORDINANCES, AND
POLICIES REVIEW
PLANS, PROGRAM, ORDINANCE OR POLICY (Year Adopted) CONSISTENCY ANALYSIS General Plan CirculaƟon Element (1992)
The CirculaƟon Element of the City of Inglewood General Plan idenƟfies the system of freeways, major and minor arterials, and collector streets needed to carry traffic within and through the City.
The primary purpose of the CirculaƟon Element, as stated within, is to require that the provision of adequate street access and traffic capacity is considered for current and future land use needs. The CirculaƟon Element also describes transit services within the City and designates truck routes and bicycle routes throughout the City.
The I-405 Freeway is a north-south freeway that runs through the western porƟon of the City, and the I-105 Freeway is an east-west freeway that runs along the southernmost porƟon of the
City. The CirculaƟon Element defines the following classificaƟons of streets:
• Major Arterials. Major arterials are the most important surface streets, funcƟoning as primary intercity routes and collecƟng and distribuƟng a large porƟon of local traffic. Major arterials are typically designed to carry over 30,000 vehicles per day with a
minimum of two travel lanes in each direcƟon and a separate median lane to accommodate leŌ-turn movement.
• Minor Arterials. Minor arterials, also referred to as secondary arterials, are similar to major arterials except that they may be disconƟnuous within the City and may carry less traffic volume. Minor arterials are typically designed to carry 15,000 to 30,000 vehicles per day with a minimum of two travel lanes in each direcƟon. A separate median lane to accommodate leŌ-turn movement is desirable if there is sufficient roadway width.
• Collectors. Collectors are transiƟonal streets between arterials and local streets, collecƟng vehicles from the local street system and transporƟng them to the arterial system. Collectors may also provide cross-city access. Collectors may be designed to carry up to 15,000 vehicles per day, although 3,000 to 10,000 vehicles is more typical.
Collectors will have at least one travel lane in each direcƟon, although two travel lanes may be uƟlized depending upon volume and funcƟon.
Consistent: Based on review of the CirculaƟon Element,
the street classificaƟons for roadways within the
immediate vicinity of the Project (i.e., Century Boulevard, Freeman Avenue, 101st Street, etc.) would not change
due to the Project. Furthermore, street widenings are not anƟcipated to be required or recommended as a result of the Project.
In addiƟon, the CirculaƟon Element designates truck
routes and bicycle routes within the City. Century
Boulevard is designated as a truck route, and the Project would not disrupt the flow of trucks along the Century
Boulevard corridor. While Century Boulevard, Freeman
Avenue, and 101st Street have not been idenƟfied as
potenƟal bicycle routes within the City, the Project would not preclude the City from installing bicycle infrastructure along these roadways in the future. Therefore, the
Project would not conflict with the CirculaƟon Element.
General Plan Land Use Element (2020)
The Project is currently designated for Commercial Land Uses, but the Project includes a request to redesignate the site under the Commercial-ResidenƟal land use designaƟon. This designaƟon is intended to support the development of mixed-use projects containing residenƟal and nonresidenƟal uses through
implementaƟon of the City’s Planned Assembly Development (PAD) zoning procedures.
Consistent. The Project includes the development of a
mixed-use building, which would include residenƟal,
hotel, and event/entertainment uses. The ground floor of the building would contain the hotel lobby, event space, and parking, with all residenƟal units on floors 7 through
12. The Project would be designed and constructed in
accordance with the City’s zoning and development
requirements, including the proposed PAD regulaƟons
being sought as part of the Project’s enƟtlements. The
residenƟal and non-residenƟal porƟons of the Project
would be integrated through design, lighƟng, and
wayfinding signage, but would be separated by floors. The proposed building would be oriented toward Century
Boulevard, Freeman Avenue, and 101st Street, providing
the primary pedestrian access on Century Boulevard and
the primary vehicular access on 101st Street.
The Project would therefore be consistent with the
primary goal and purpose of the Commercial-ResidenƟal
land use designaƟon, which therefore also supports the
alignment of the Project with other aspects of the Land Use Element that relate to the circulaƟon system,
including transit, roadways, bicycle and pedestrian
faciliƟes.
Envision Inglewood - 2019 City of Inglewood Mobility Plan (2019) The Envision Inglewood - 2019 City of Inglewood Mobility Plan (“Mobility Plan”) is designed to provide the framework for addressing current and future infrastructure needs in a responsible, sustainable manner. It also provides the tools necessary to help the City assess future transportaƟon infrastructure demands as it evaluates proposed development projects and the potenƟal for public-private partnerships, considering all implementaƟon tools.
The Mobility Plan establishes the vision, goals, policies, infrastructure enhancements and program requirements, including transportaƟon and traffic control measures and strategies necessary to improve and augment the City’s local transportaƟon network and access to the regional transportaƟon system so as to minimize neighborhood intrusion caused by increased traffic resulƟng from entertainment and sporƟng events.
The Mobility Plan features seven goals that are equal in weight and define the City’s high-level mobility prioriƟes. Each of the goals contain strategies that are specific, measurable, and outline how the goals are met. For each goal, several objecƟves or strategies were established to guide the City as it implements its Mobility Plan.
Goal 1: Sustainability and Environmental ConsideraƟons
Goal 2: Neighborhood ProtecƟon and PreservaƟon
Goal 3: Create an Efficient, Balanced, MulƟmodal Mobility Network Goal 4: CongesƟon ReducƟon and TransportaƟon Management System
Goal 5: Safety
Goal 6: Accessibility
Goal 7: Reliability
To achieve these goals, the City conƟnues to embrace previous mobility concepts, including several from the 1992 City of Inglewood General Plan CirculaƟon Element, but also seeks to broaden its overall approach and prioriƟes to advance mobility, innovaƟon and climate acƟon.
Consistent: The Mobility Plan draws upon the 1992
CirculaƟon Element, as well as state laws like SB 743 that seek to promote alternaƟve forms of mobility and
circulaƟon to support the goal of reducing greenhouse
gas emissions. The Project implements many goals and
strategies of the Mobility Plan and does not conflict with the Mobility Plan. These features of the Project include:
- Providing EV charging staƟons and
infrastructure
- Providing bicycle parking faciliƟes
- Providing new residenƟal and commercial uses
near public transit
- ConsolidaƟng the overall number of curb
cuts/driveways
- Making new ADA-compliant pedestrian
improvements and ensuring pedestrian safety
through improvement of the sidewalk and right
of way
- Enhancing on-site lighƟng to provide safer
pedestrian pathways
The Project is consistent with the goals and strategies of the Mobility Plan relaƟve to the circulaƟon system,
including transit, roadways, bicycle and pedestrian
faciliƟes.
General Design Guidelines (1979)
The General Design Guidelines provide guidelines for the improvement and development of property in the City of Inglewood, Consistent: Vehicle parking would be provided in one
subterranean level and a five-story parking garage at the which are intended to supplement the standards in the Zoning Ordinance. The guidelines below are relevant to circulaƟon:
Parking Guidelines
1. Outdoor parking lots may be a cheaper method of providing required parking spaces; however, they consume valuable site area and there must be landscaped to be visually aƩracƟve. Parking structures may be a greater iniƟal expense but generally provide a more efficient use or the land.
2. Generally, the most economical parking paƩerns are achieved with spaces located off both sides of each aisle and with the spaces aligned at 90 degrees. DeviaƟon from the 90 degree parking angle may add to the ease of entering and backing out of parking spaces, but the addiƟonal area required for the same number of parking spaces may restrict the use of parking paƩerns that are less than 90 degrees.
3. Entrances and exits to parking faciliƟes should be limited in number and should be designed and located to minimize any interference with the flow of street traffic.
4. To reduce intrusion into residenƟal neighborhoods, parking lots should take access from other than residenƟal streets except when a lot is serving a residenƟal use.
5. Barren parking lots are considered to be unsightly and distracƟng.
Parking areas should be located and designed to minimize direct exposure to public view. These areas should be buffered with landscaping to reduce the visual impact and may be located at the rear of buildings, or by taking advantage of natural topography or planned grading, created in areas which are above or below adjacent street and property grades.
ResidenƟal Standards
1. Parking spaces shall be located on the same lot as the use and be within 200 feet of the entrance to the residence. They shall not be located in the required side yards and shall be farther than 40 feet from the front line except for two spaces which are permiƩed within 40 feet of the front line.
2. A minimum of two enclosed parking spaces shall be provided for each residenƟal unit. The spaces required for one or two unit developments shall be fully enclose and include garage doors.
Carports do not saƟsfy the requirements for residenƟal parking spaces.
3. All parking spaces located within a building shall have the following minimum inside dimensions.
• Each space adjacent to another with no intervening obstrucƟons (8 feet wide x 19 feet long)
• Any single space separated by walls or other obstrucƟons (9 feet and 6 inches wide x 19 feet long)
back of the proposed building. Entrances/exits to the
parking would be limited to one access point on Freeman Avenue and two access points on 101st Street, none of
which are on residenƟal streets. All parking spaces would be constructed and located in accordance with the City’s requirements including those set forth in the Project’s proposed PAD zoning regulaƟons.
4. Garage door clearances shall be a minimum of 8 feet wide per space and 6 feet and 8 inches high.
5. Garage entrances facing the front street shall be 22 feet or more from the front lot line.
6. Garage entrances facing the side street of a corner lot shall not be located within the strip which is defined by drawing lines 10 feet and 22 feet from the exterior side lot line and parallel to it.
7. Required driveways for residenƟal developments shall provide the unobstructed minimum widths of 10 feet for one to 9 living units, and 16 feet for 10 to 20 living units. Refer to the Municipal Code when residenƟal driveways serve more than 20 living units. No driveway shall exceed 28 feet in width at the front or exterior side lot line.
8. ResidenƟal driveways shall be paved with not less than 3 1/2 inches of Portland cement concrete.
9. When access to any parking space requires a 90 degree or right angle turn, an unobstructed area with a depth of 25 feet shall be provided for maneuvering into the space.
10. When access to any parking space involves a reverse turn or "S" turn, an unobstructed area shall be provided for maneuvering into the space. The required minimum depth of unobstructed area is dependent upon the encroachment into the line of direct access to the parking space, and is shown in the following diagram and table [refer to page 20 in the Design and Development Standards and Guidelines].
11. ResidenƟal parking faciliƟes, including the driveway, for 3 or more living units shall be separated from any abuƫng residenƟal property by a masonry wall not less than 5 feet high. All porƟons of this required wall which are adjacent to the required front yard of the residenƟal property shall be 3 feet 6 inches high. (See Walls and Fences.)
12. All required parking spaces shall be maintained for parking purposes only.
Commercial and Industrial Standards
1. Parking faciliƟes shall be located within 300 feet of the use for which they are provided.
2. Every development shall provide the minimum number of standard size off-street parking spaces as specified by the Inglewood Municipal Code. The following is provided only to indicate that the required number of spaces varies with the use and gross floor area. • Theaters and recreaƟonal uses = 1 space/35 sf
• Restaurants and grocery stores = 1 space/150 sf
• Offices and general commercial = 1 space/300 sf
• Manufacturing and general industrial = 1 space/500 sf • Warehouse = 1 space/1,500 sf
1. All parking spaces located outside of a building shall have the following minimum dimensions.
• Spaces not alongside a wall or obstrucƟon = 8 feet and 6 inches wide x 20 feet long
• Spaces alongside a wall or obstrucƟon = 9 feet and 6 inches wide x 20 feet long
2. All parking spaces located within a building shall have the following minimum inside dimensions.
• Each space adjacent to another with no intervening obstrucƟon = 8 feet wide x 19 feet long
• Any single space separated by walls or other obstrucƟons 9 feet and 6 inches x 19 feet long
3. Each parking lot shall provide a minimum of one parking space, 12 feet wide, specifically for the use of the handicapped. This space shall be in close proximity to the main entrance of the building and shall be clearly designated, "RESERVED FOR THE HANDICAPPED.”
Loading Guidelines
1. Entrances and exits to loading faciliƟes should be limited in number and should be designed and located to minimize any interference with the flow of traffic along the street.
2. To reduce the intrusion into residenƟal neighborhoods, loading areas should have access from other than residenƟal streets.
3. Loading areas are considered to be unsightly and should be located and designed to minimize direct exposure to public view. These areas should be buffered with landscaping to reduce the visual impact.
4. The design of loading faciliƟes must take into consideraƟon the specific dimensions required for maneuvering the combinaƟons of trucks and tractor-trailers into and out of loading posiƟon at docks or in stalls and driveways. The maneuvering space required is largely dependent on three factors: (1) overall length of the tractor-trailer unit; (2) the width-of the space in which the vehicle must be placed; and (3) the turning radius of the tractor-truck which pulls the unit.
Inasmuch as the tractor-trailer uses slightly more space to pull out than to back in, all reference to maneuvering space is based on the requirements for pulling out.
Standards
1. Every commercial development shall provide a loading stall for service vehicles. Industrial developments shall be designed to provide loading stalls in accordance with the expected use of the property.
2. Loading areas shall be visibly separated from public entrances and parking areas.
Consistent: The Project would include one loading
entrance/exit, which would occur from 101st Street, and would be constructed in accordance with applicable
standards.
3. Loading stalls shall be designed to not interfere with circulaƟon or parking, and to permit trucks to fully maneuver on the property without backing from or onto a public street.
4. The minimum loading stall width shall be 12 feet. The recommended width of 15 feet is required for loading stalls alongside a wall or other obstrucƟon.
5. For general commercial developments the minimum loading stall length shall be 20 feet. For other developments in which trucking is an acƟvity the minimum stall length shall be 30 feet or equal to the length of the longest trucks and tractor-trailers expected at the facility, whichever is greater.
6. The depth of the loading apron shall be sufficient to permit trucks to maneuver into and out of the loading stalls. The minimum loading apron depth shall be 25 feet or equal to the length of the loading stall, whichever is greater.
7. Loading areas shall be graded to drain surface water to an alley, street or public storm drain. Surface water shall be conducted under any intervening public sidewalk by a drain approved by the Public Works Department.
8. The surface area used for any loading acƟvity shall be paved with not less than 2 inches of asphalƟc concrete on 4 inches of crushed rock base, or with 3 1/2 inches of Portland cement concrete. Soil condiƟons or the nature of the trucking acƟvity may necessitate greater requirements as determined by the Division of Building and Safety.
9. Each loading space aligned with and directly adjacent to a parking space shall be clearly designated “LOADING ONLY.”
10. Poured concreate curbs shall be provided at the perimeter of the planter areas that abut paved vehicle areas.
11. A combinaƟon of masonry walls and landscaping shall be provided to buffer or screen loading areas from direct public view and from abuƫng residenƟal properƟes. (See Landscaping.)
12. All arƟficial illuminaƟon shall be installed, directed, and shielded to confine all direct rays within the property.
13. All loading facility improvements, including the pavement, striping, curbs, and landscaping shall be conƟnuously maintained, which includes repairs, repainƟng, replacement, and regular cleaning.
Pedestrian Guidelines
1. Where grades become excessive, ramps or stairs must be used. It is best to have a set of stairs no higher than eye level so that a pedestrian may judge the distance to the top of the landing safely.
2. The width of walks or plazas in a pedestrian circulaƟon system depends on capacity requirements, scale, and their relaƟon to other elements.
Consistent: The Project would provide pedestrian
circulaƟon ameniƟes in compliance with all City size and locaƟon standards. AddiƟonally, the Project would be
required to comply with Americans with DisabiliƟes Act
(ADA) requirements.
3. A clearly defined and delineated access from the public sidewalk to the primary building entrance should be provided.
4. Special aƩenƟon should be given to the provision of convenient access to the pedestrian circulaƟon system for handicapped persons.
This will require extra consideraƟon in designing the placement of building entrances in relaƟon to parking lots and/or public sidewalks.
Standards
1. Width: Minimum acceptable sidewalk width is 4 feet without obstrucƟons. In appropriate locaƟons, methods other than paved walkways may be uƟlized to delineate pedestrian ways.
2. Ramps: Grades in excess of 6.67% (1 verƟcal to 15 horizontal) shall be considered a ramp and shall meet building code requirements for ramps. The maximum acceptable ramp grade is 12.5% (1 verƟcal to 8 horizontal).
3. Handrails: Any ramp or set of steps shall be provided with handrails for pedestrian safety.
4. Handicapped Access: All new construcƟon is required to have an entrance accessible to handicapped persons. To qualify as a handicapped entrance there must be access from a parking lot with designated handicapped spaces or access from a public sidewalk that meets the following:
a. no steps or curbs
b. no sidewalk grade greater than 5%
c. no ramp grade greater than 8.33% (1 verƟcal to 12 horizontal) d. adequate plaƞorm space at the building entrance to provide a wheelchair while opening the door. (See Building Code.)
5. Handicapped Access – Public Right-of-Way: If a curb or sidewalk is reconstructed within a pedestrian crosswalk area, or is located before a site that is being developed, the developer shall construct a sidewalk access ramp (wheelchair ramp) for the handicapped as part of the improvements required by the Department of Public Works, unless directed otherwise by the Engineer.
New Downtown and Fairview Height Transit Oriented Development Plan and Design Guidelines (2016)
The Downtown TOD Plan area consists of approximately 585 acres located in the center of Inglewood along the new Crenshaw/LAX line just east of the Florence Avenue/La Brea Avenue intersecƟon. This Downtown planning and zoning area extends approximately ½ mile in all direcƟons from the Metro StaƟon. The Fairview Heights TOD Plan area consists of approximately 328 acres located near the intersecƟon of Florence Avenue and West Boulevard. This Fairview Heights planning and zoning area also extends approximately ½ mile in all direcƟons from the Metro StaƟon. However, only the westerly porƟon of the half-mile radius area is included in this plan because the easterly porƟon of the half-mile radius lies within the City of Los Angeles.
Not Applicable / Consistent: The Project is not located within the boundaries of the New Downtown and
Fairview Height Transit Oriented Development Plan area
and it is located approximately 1.5 miles away from the Downtown Inglewood Metro StaƟon and approximately
2.2 miles from the Fairview Heights Metro StaƟon.
Nevertheless, the Project will bring new residenƟal
tenants, commercial visitors, and commercial jobs to
Century Boulevard, near several local bus stops. The
Project will supplement the New Downtown and Fairview
Height Transit Oriented Development Plan goal of
locaƟng housing and jobs in Inglewood within proximity
to transit resources. The Project is consistent with and would not conflict with the TOD Plan policies relaƟve to the circulaƟon system, including transit, roadways,
bicycle and pedestrian faciliƟes.
Hollywood Park Specific Plan (2015)
The Hollywood Park Specific Plan project site is located on the northeast corner of Prairie Avenue and Century Boulevard. The streets that border the Specific Plan area include, Prairie Avenue on the west and Century Boulevard to the south. Access to the site can also be obtained from Pincay Drive to the north. Manchester Boulevard (State Route 42) and Crenshaw Boulevard are located a few blocks north and east, respecƟvely. All of the roads, menƟoned above, provide access to the nearby regional freeway network. The purpose of the Hollywood Park Specific Plan is to provide the land use framework for the redevelopment of the 238-acre Hollywood Park site with a mix of parks, retail, housing, entertainment, gaming, hotel and civic uses.
The transportaƟon goals for the Specific Plan area are to:
• Provide pedestrian connecƟons from Hollywood Park to major transit corridors on Century Boulevard and Prairie Avenue. • Reduce reliance on the private automobile by enhancing opportuniƟes for transit ridership, walking and biking. • Reduce traffic compared to other developments by providing a mix of commercial, entertainment, restaurant, residenƟal and park uses in proximity to each other and to exisƟng transit routes.
Not Applicable / Consistent: The Project is not located within the boundaries of the Hollywood Park Specific Plan area and it is located approximately 1,500 feet southwest corner of the Specific Plan area at Century Boulevard and Prairie Avenue.
Nevertheless, the Project aligns with the transportaƟon and circulaƟon goals of the Hollywood Park Specific Plan by co-locaƟng housing, commercial uses that generate
jobs, and other visitor serving ameniƟes in close proximity to each other. The Project will provide adequate on-site parking and bicycle parking which will accommodate the
demands of the Project and avoid conflict with the
Hollywood Park redevelopment.
The Project would provide pedestrian circulaƟon
ameniƟes in compliance with all City size and locaƟon
standards, which will complement the new ameniƟes
generated through implementaƟon of the Specific Plan.
The Project is consistent with the policies of the
Hollywood Park Specific Plan that address circulaƟon.
AcƟve TransportaƟon Plan (Imagine Inglewood) (2022)
The City of Inglewood has developed an AcƟve TransportaƟon Plan and Safe Routes to School Plan (ATP/SRTS) that incorporates bicycling, walking, safe routes to school, and Americans with DisabiliƟes Act (ADA) consideraƟons. The ATP/SRTS establishes a vision for the City and will guide the community toward a future where acƟve transportaƟon is a viable opƟon for all ages who live, work, and play within its borders. The Plan also allows access to increasing public transit connecƟvity to the rest of the Los Angeles region and it will create a network that will meet the needs for those who are transit dependent, those looking for alternaƟves, and recreaƟonal users.
The purpose of this ATP/SRTS is to create a Complete Streets update to the City of Inglewood General Plan. This Plan is comprised of the following four main components: (1) Bicycle FaciliƟes Plan, (2) Pedestrian FaciliƟes Plan, (3) SRTS Plan, and an (4) ADA TransiƟon Framework Plan.
Consistent: The Project is consistent with and does not conflict with the AcƟve TransportaƟon Plan and Safe
Routes to School Plan (ATP/SRTS). The Project
implements many goals and strategies that are included
within the ATP/SRTS. These features of the Project
include:
- Providing bicycle parking faciliƟes
- Providing new residenƟal and commercial uses
near public transit
- ConsolidaƟng the overall number of curb
cuts/driveways
- Making new ADA-compliant pedestrian
improvements and ensuring pedestrian safety
through improvement of the sidewalk and right
of way
- Enhancing on-site lighƟng to provide safer
pedestrian pathways
City of Inglewood Municipal Code, Chapter 3: Motor Vehicles and Traffic
City of Inglewood Municipal Code, Chapter 3: Motor Vehicles and Traffic includes standards related to traffic enforcement, parking, truck route regulaƟons, parking meter regulaƟons, bicycle Not Applicable / Consistent: The Project will include off- street vehicle parking and bicycle parking faciliƟes as required and condiƟoned. These off-street faciliƟes will regulaƟons, seizure and forfeiture of vehicles, regulaƟons for nuisance vehicles, and prohibiƟons of illegal motor vehicle speed contests. These regulaƟons primarily address regulaƟon and enforcement of standards in the public way.
follow all applicable regulaƟons and are not proposed in such a way that would conflict with the City’s
enforcement of City of Inglewood Municipal Code,
Chapter 3: Motor Vehicles and Traffic.
All users, guests, patrons, employees, and others who
visit or reside at the Project will sƟll be subject to the enforcement of appliable public regulaƟons and traffic
enforcement. As such, the Project will not conflict with the regulaƟons of the City of Inglewood Municipal Code, Chapter 3: Motor Vehicles and Traffic relaƟve to the
circulaƟon system, including transit, roadways, bicycle and pedestrian faciliƟes.
City of Inglewood Municipal Code, Chapter 12: Planning and Zoning The Project is currently designated for Commercial Land Uses, but the Project includes a request to redesignate the site to the Commercial-ResidenƟal land use designaƟon, which is intended to facilitate the development of mixed-use residenƟal and
nonresidenƟal developments pursuant to the City’s PAD zoning process, which the Project has requested approval of.
Consistent: The current zoning designaƟon for the
Project Site as well as the immediately surrounding area is C-2A (Airport Commercial), which allows commercial and
hotel uses but does not permit residenƟal uses. In
conjuncƟon with the requested General Plan Amendment
to establish a Commercial-ResidenƟal land use
designaƟon for the Project Site, a corresponding PAD
approval is being requested that would facilitate the
redevelopment of the Project Site’s exisƟng hotel uses
with a new verƟcally integrated development containing
commercial, lodging, entertainment, and housing uses
that will enhance pedestrian acƟvity and reflect high
architectural design quality. The PAD regulaƟons will
achieve this goal by establishing specific use,
development, and design standards that will ensure the
compaƟbility of the Project with both nearby uses as well as the City’s long-range planning and policy goals to
encourage increased commercial acƟvity along its key
corridors.
ConnectSoCal: 2020-2045 SCAG RTP/SCS (2020)
On September 3, 2020, SCAG adopted the 2020-2045 RTP/SCS, which calls for $639 billion in transportaƟon investments and reducing VMT by 19 percent per capita from 2005 to 2035. The updated plan accommodates 21.3 percent growth in populaƟon from 2016 (3,933,800) to 2045 (4,771,300) and a 15.6 percent growth in jobs from 2016 (1,848,300) to 2045 (2,135,900). The updated RTP/SCS calls for a number of land use-based strategies to accommodate growth, minimize criteria pollutant emissions, and achieve the following climate change objecƟves:
• Decreasing drive-along work commutes by three percent • Reducing per capita VMT by five percent and vehicle hours traveled per capita by nine percent
• Increasing transit commuƟng by two percent
• Reducing travel delay per capita by 26 percent
• CreaƟng 264,500 new jobs annually
The Project is consistent with the goals and policies of ConnectSoCal: 2020-2045 SCAG RTP/SCS (2020), as it:
• Provides EV charging infrastructure that, at minimum, meets the most ambiƟous voluntary standard in the
California Green Building Standards Code at the Ɵme of
project approval.
• Is located on infill sites that are surrounded by exisƟng urban uses and reuses or redevelops previously
undeveloped or underuƟlized land that is presently
served by exisƟng uƟliƟes and essenƟal public services
(e.g., transit, streets, water, sewer)
• Consists of transit-supporƟve densiƟes (minimum of 20 residenƟal dwelling units per acre), or is in proximity to exisƟng transit stops (within a half mile), or saƟsfies more detailed and stringent criteria specified in the region’s SCS.
• Reduces parking requirements by: EliminaƟng parking
requirements or including maximum allowable parking
raƟos (i.e., the raƟo of parking spaces to residenƟal units • Reducing greenfield development by 29 percent by focusing on smart growth
• LocaƟng six more percent household growth in HQTAs, which concentrate roadway repair investments, leverage transit and acƟve transportaƟon investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potenƟal to improve public health and housing affordability.
• LocaƟng 15 percent more jobs in HQTAs
or square feet); or providing residenƟal parking supply at a raƟo of less than one parking space per dwelling unit; or for mulƟfamily residenƟal development, requiring parking costs to be unbundled from costs to rent or own a
residenƟal unit.
The Project is consistent with and does not conflict with the ConnectSoCal: 2020-2045 SCAG RTP/SCS plan.
Metro 2020 Long Range TransportaƟon Plan (2020)
The 2020 Long Range TransportaƟon Plan (LRTP) provides a detailed roadmap for how Metro will plan, build, operate, maintain, and partner for improved mobility in the next 30 years. The LRTP will guide future funding plans and policies needed to move LA County forward for a more mobile, resilient, accessible and sustainable future.
Not Applicable / Consistent: The Project does not
propose any public transportaƟon improvements nor will
it conflict with any long range proposals in the Metro
2020 Long Range TransportaƟon Plan.
The Project is consistent with the Metro 2020 Long Range TransportaƟon Plan as it proposes new housing and
commercial uses that will locate employment
opportuniƟes near transit. The Project users will have
access to bus and rail transit opportuniƟes that are
proposed for and currently exist within Inglewood. The
Project will also include bike parking and pedestrian
improvements that will provide opportuniƟes for
alternaƟve mobility, as prioriƟzed by the Metro plan. The Project is consistent with and will not conflict with this plan.
Metro Short Range TransportaƟon Plan 2014 (2014)
The Short Range TransportaƟon Plan was developed as a focused ten- year plan to guide Metro acƟons through 2024. The Plan will advance Metro toward the long-term goals outlined in the 2009 Long Range TransportaƟon Plan (LRTP), a 30-year vision for addressing growth and traffic in LA County. The Plan monitors Metro’s progress in moving projects and programs forward to ensure our system moves people and goods safely.
Not Applicable / Consistent: The Project does not
propose any public transportaƟon improvements nor will
it conflict with any long range proposals in the Metro
Short Range TransportaƟon Plan 2014.
The Project is consistent with the Metro Short Range
TransportaƟon Plan 2014 as it proposes new housing and
commercial uses that will locate employment
opportuniƟes near transit. The Project users will have
access to bus and rail transit opportuniƟes that are
proposed for and currently exist within Inglewood. The
Project will also include bike parking and pedestrian
improvements that will provide opportuniƟes for
alternaƟve mobility, as prioriƟzed by the Metro plan. The Project is consistent with and will not conflict with this plan.
Inglewood First/Last Mile Plan 2019 (2019)
The Inglewood First/Last Mile Plan is a joint effort between Metro and the City of Inglewood to develop first/last mile improvements for improving the walking and bicycling environment for four Metro staƟons in and adjacent to the City. With Metro’s coordinaƟon with local jurisdicƟons and other agencies including the City of Inglewood, City of Los Angeles, City of Hawthorne, and LAWA, the Inglewood First/Last Mile Plan builds on the ongoing development and transportaƟon changes occurring in the area.
Not Applicable / Consistent: As described herein, the
Project is not located within one mile of any of the
specified transit staƟons. The Project does not propose
any major infrastructural improvements that are contrary to the recommendaƟons of the First/Last Mile Plan.
Nevertheless, the Project includes ameniƟes and features that will complement the goals and intent of the First/Last Mile Plan 2019 including: bicycle parking, sidewalk
repaving, addiƟon of street-adjacent landscaping,
The four staƟons are:
• Fairview Heights Crenshaw/LAX Line StaƟon
• Downtown Inglewood Crenshaw/LAX Line StaƟon
• Westchester/Veterans Crenshaw/LAX Line StaƟon
• Crenshaw Green Line StaƟon
The First/Last Mile Plan idenƟfied some key challenges to pedestrian and bicycle access to the staƟons. The challenges included the following:
• Long blocks
• Wide arterial streets to cross
• Freeway crossings
• Lack of streetscape ameniƟes
The top recommendaƟons include:
• Crosswalk improvements (high-visibility crosswalks, dual curb ramps, pedestrian signals, etc.)
• New sidewalks and sidewalk repaving
• Bicycle infrastructure
• AddiƟonal lighƟng
• Visual enhancements that reflect characterisƟcs of the city and local neighborhoods
intenƟonally designed lighƟng for user safety, and visual enhancements that improve the pedestrian experience.
The Project does not conflict with the First/Last Mile Plan 2019.
City of Los Angeles Crenshaw Boulevard Streetscape Plan (2015) In September 2015, the City of Los Angeles approved the Crenshaw Boulevard Streetscape Plan to create a complete, mulƟ-modal street that reflects the future Metro Crenshaw/LAX Light Rail Transit Project. The boundaries of the Crenshaw Boulevard Streetscape Plan extend along Crenshaw Boulevard from Adams Boulevard to the north, and the 79th Street to the south, within the City of Los Angeles boundary. While the Streetscape Plan does not apply to boundaries within the City of Inglewood, it recommends street improvements along Crenshaw Boulevard from 67th Street to 70th Street:
• ExisƟng: Six lanes, center turn lane
• Proposed: Two lanes, center turn lane (with scaƩered medians), parking/bus plaƞorm on both travel direcƟons, buffered bike lanes (6’ bike lanes with 4’ raised buffer)
Not Applicable / Consistent: The Project is located on
Century Boulevard, approximately 2.5 miles from
Crenshaw Boulevard and 70th Street, where the
Streetscape Plan is applicable. The Project does not
propose any improvements which would conflict with the
policies in the City of Los Angeles Crenshaw Boulevard
Streetscape Plan that address circulaƟon.
The Project includes improvement and maintenance of
the public right of way and new landscaping as required by the City, which will support the intent of the
Streetscape Plan to improve pedestrian connecƟvity and
walkability.
City of Inglewood Pedestrian Safety Assessment (2015)
In 2013, the City commissioned a Pedestrian Safety Assessment (PSA) which analyzed current safety condiƟons for pedestrians and to a limited degree, bicyclists. The assessment documented that Not Applicable / Consistent: None of the site-specific
locaƟons for recommended improvements are within the
immediate proximity of the Project site. Even so, the
Inglewood has a need to plan for effecƟve investments to reduce serious pedestrian and safety issues, and to provide a disadvantaged community with a broader range of high-quality transportaƟon opƟons. RecommendaƟons included general and locaƟon-specific improvements such as enhancements to motorist’s visibility of pedestrians, intersecƟon improvements, ADA-compliancy, and suggested bikeway treatments. As part of the pedestrian safety assessment a walking audit was conducted at five focus areas, and site-specific improvements were recommended at each of the focus areas. These locaƟons are listed below:
• La Tijera School
• La Tijera Blvd/Fairview Blvd.
• La Tijera Blvd./64th Pl.
• Downtown Inglewood
• Mid-block crosswalk on Market St between Queen St. and Regent St.
• Market St./Regent St.
• Market St./Florence Ave.
• Locust St./Florence Ave.
• Locust St./Grace Ave.
• Parking garage on Locust St. between Queen St. and Manchester Blvd.
• Locust St./Hillcrest Blvd.
• Market St. at Hillcrest Blvd./Kelso St.
• Maitland Ave. between 80th St. and Van Ness Ave.
• Crenshaw Blvd. between Imperial Blvd. and I-105 light rail staƟon • Imperial Blvd./Crenshaw Blvd.
• Crenshaw Blvd. near Crenshaw LRT staƟon
Project includes sidewalk improvements and maintenance
of the public right of way as required by the City, which will improve the pedestrian experience and enhance
safety for pedestrians. The Project is consistent with and will not conflict with the recommendaƟons of the City of Inglewood Pedestrian Safety Assessment.
City of Inglewood Energy and Climate AcƟon Plan (2013)
In March 2013, the City adopted the Inglewood Energy and Climate AcƟon Plan (ECAP), which outlines a roadmap for achieving community-wide energy consumpƟon and GHG emissions reducƟons.
The ECAP includes several strategies and acƟons related to energy efficiency and conservaƟon, including energy and water conservaƟon design features in new development projects. Strategy 4 specifically addresses transportaƟon and circulaƟon.
Strategy 4: Improve TransportaƟon OpƟons and Manage
TransportaƟon Demand
Consistent: Through compliance with the City’s Green
Building Code as required of the Project by the City, the Project would support the energy consumpƟon
reducƟons outlined in the ECAP , which may include the
following:
• MeeƟng/exceeding Title 24 energy standards
• Provision of electric vehicle (EV) charging staƟons
• Implement TransportaƟon Demand Management (TDM)
measures in accordance with SecƟon 12-42.1
• Make roadways more efficient
• Improve transit
• Improve bicycle faciliƟes
• Make parking more efficient
• Reduce commute trips
• Encourage land use intensificaƟon and diversity
(TransportaƟon Demand Management Requirements for
Carpool Parking and Bicycle FaciliƟes) of the City’s
Municipal Code and the provisions of the Project’s
proposed Mixed-Use Overlay zoning designaƟon
• Unbundled parking
• Minimize driveway cuts
• Provision of sidewalk ameniƟes
AddiƟonally, the Project represents a more intense use of the Project Site with a diverse mix of complementary
uses. Along with the Project Site’s proximity to transit, the Project would allow for a reducƟon in traffic trips, VMT, and associated consumpƟon of fossil fuels.
For these reasons, the Project would not conflict with the Inglewood Energy and Climate AcƟon Plan (ECAP) policies relaƟve to the circulaƟon system, including transit,
roadways, bicycle and pedestrian faciliƟes.
Westchester/Veterans StaƟon Area Transit Oriented Development Plan and Design Guidelines (2021)
The Westchester/Veterans TOD Plan area consists of roughly 379 acres on the western side of the City of Inglewood. The TOD Plan area lies roughly within one-half mile of the Westchester/Veterans Metro staƟon, which is currently under construcƟon as part of the Crenshaw/LAX Line at the northwest corner of Florence and Hindry Avenues. A key purpose explained in the Westchester/Veterans TOD Plan is to maximize the uƟlizaƟon of the Metro Crenshaw/LAX Line as a means of accessing both housing and jobs for transit riders both deparƟng from and entering Inglewood.
Not Applicable / Consistent: The Project is not located within the boundaries of the Westchester/Veterans TOD
Plan area and it is located approximately 1.8 miles away from the Westchester/Veterans Metro StaƟon.
Nevertheless, the Project will bring new residenƟal
tenants, commercial visitors, and commercial jobs to
Century Boulevard, near several local bus stops. The
Project will supplement the Westchester/Veterans TOD
Plan goal of locaƟng housing and jobs in Inglewood within proximity to transit resources. The Project is consistent with and would not conflict with the TOD Plan policies
relaƟve to the circulaƟon system, including transit,
roadways, bicycle and pedestrian faciliƟes.
Crenshaw/Imperial Transit Oriented Development Plan and Design Guidelines (2021)
The Crenshaw/Imperial TOD Plan area consists of roughly 103 acres in the southern part of the City of Inglewood. Most of the TOD Plan area lies within one-half mile of Crenshaw StaƟon on the Metro Green Line, located in the median of the 105 freeway at Crenshaw Boulevard.
A key purpose of the Crenshaw/Imperial TOD Plan area is to maximize the uƟlizaƟon of the Metro Green Line as a means of accessing both housing and jobs for transit riders both deparƟng from and entering Inglewood.
Not Applicable / Consistent: The Project is not located within the boundaries of the Crenshaw/Imperial TOD Plan area and it is located approximately 1.8 miles away from the Crenshaw/Imperial Metro StaƟon. Nevertheless, the
Project will bring new residenƟal tenants, commercial
visitors, and commercial jobs to Century Boulevard, near several local bus stops. The Project will supplement the Crenshaw/Imperial TOD Plan goal of locaƟng housing and
jobs in Inglewood within proximity to transit resources.
The Project is consistent with and would not conflict with the TOD Plan policies relaƟve to the circulaƟon system, including transit, roadways, bicycle and pedestrian
faciliƟes.
LLG Ref. 1-21-0574-1
4200 Century
U:\0574\report\TIA\0574-Appendix Covers (TIA).docx
Proposed Land Use Details Project Information
Propose Project Total Population290 Total Employees 0 Project Name 4200 Century Value Units Value Units Project Address 4200 Century Boulevard and 4229-4233 W. 101st Street Residential Industrial Project APNs
Single Family 0 DU Light Industrial 0.000 ksf
Multi Family - Mid-Rise 129 DU Manufacturing 0.000 ksf
Affordable Housing - Family 0 DU Warehousing 0.000 ksf
Mini-warehouse 0.000 ksf
Retail Other
General Retail 0.000 ksf Hotel 0 Rooms
Supermarket 0.000 ksf School - Private School (K-12) 0 Students Proposed ProjectProposed Project Bank 0.000 ksf Without MitigationWith Mitigation
Health Club 0.000 ksf Custom - Other Non-residential / Non-retail Uses Daily Vehicle Trips 490 490 Restaurant (non-fast food) 0.000 ksf Total Non-residential / Non-Retail Daily Trips0 Trips Daily VMT 4,614 4,614 Fast-Food Restaurant 0.000 ksf Total Employees 0 Emplolyees Residential VMT per Capita 8.81 8.81 Gas Station 0.000 ksf HBW_P HBO_P NHB_P HBW_P HBO_P NHB_P Residential Impact? (>9.66) No No Auto Repair 0.000 ksf 0% 0% 0% 0% 0% 0% Employment VMT per Employee N/A N/A Office Custom - Other Residential Uses Work Impact? (>14.46) N/A N/A General Office (non-medical) 0.000 ksf Total Residential Daily Trips 0 Trips Medical Office 0.000 ksf Total Residents 0 Residents
TDM Strategy Details
Strategy Type Description Proposed Project With Mitigation Transit
(1-a) Reduce transit headways Reduction in headways or increase in frequency (%) N/A N/A Level of implementation (<50%, >=50%) N/A N/A
(1-b) Implement neighborhood shuttle Degree of implementation (low, medium, high) N/A N/A Employees, residents, and visitors eligible (%) N/A N/A (1-c) Transit subsidies Daily transit subsidy amount ($) N/A N/A Employees and residents eligible (%) N/A N/A
Parking
(2-d) Unbundle parking Monthly parking cost ($) N/A N/A (2-e) Reduce parking supply Base city code parking requirement (spaces) N/A N/A Actual parking provision (spaces) N/A N/A
(2-f) Price workplace parking Daily parking charge ($) N/A N/A Employees subject to priced parking (%) N/A N/A
(2-g) Parking cash-out Employees eligible (%) N/A N/A
Commute Trip Reductions
(3-h) CTR with required monitoring Employees eligible (%) N/A N/A (3-i) Ridesharing program Employees eligible (%) N/A N/A (3-j) Telecommuting Employees eligible (%) N/A N/A
(3-k) Alternative work schedules Strategy (9-day/80-hour, 4-day/40-hour) N/A N/A Employees participating (%) N/A N/A
(3-l) Association- or employer sponsored vanpool, Degree of implementation (low, medium, high) N/A N/A circulator or shuttle Employees eligible (%) N/A N/A
Education & Encouragement
(4-m) Voluntary travel behavior change program Employees and residents participating (%) N/A N/A (4-n) Promotions and marketing Employees and residents participating (%) 100% N/A Shared Mobility
(5-o) Car-share If the TDM is implemented (yes/no) N/A N/A (5-p) Bike-share If the TDM is implemented (yes/no) N/A N/A (5-q) Other shared mobility devices If the TDM is implemented (yes/no) N/A N/A (5-r) School carpool program Degree of implementation (low, medium, high) N/A N/A Neighborhood / Site Enhancement
(6-s) Traffic calming measures Intersections with traffic calming improvements (%) N/A N/A Streets with traffic calming improvements (%) N/A N/A
(6-t) Pedestrian network improvements Inclusion (within project only, within project and connecting off-site) N/A N/A (6-u) Shared use paseos or paths If the TDM is implemented (yes/no) N/A N/A Results Report
Model Runs Not Required
4034-002-001, 4034-002-002, 4034-002-004
Analysis Results
Significant Impact? No No
Page: Results
Proposed Land Use Details Project Information
Propose Project Total Population 0 Total Employees 228 Project Name 4200 Century Value Units Value Units Project Address 4200 Century Boulevard and 4229-4233 W. 101st Street Residential Industrial Project APNs
Single Family 0 DU Light Industrial 0.000 ksf
Multi Family - Mid-Rise 0 DU Manufacturing 0.000 ksf
Affordable Housing - Family 0 DU Warehousing 0.000 ksf
Mini-warehouse 0.000 ksf
Retail Other
General Retail 0.000 ksf Hotel 0 Rooms
Supermarket 0.000 ksf School - Private School (K-12) 0 Students Proposed ProjectProposed Project Bank 0.000 ksf Without MitigationWith Mitigation
Health Club 0.000 ksf Custom - Other Non-residential / Non-retail Uses Daily Vehicle Trips 650 638 Restaurant (non-fast food) 0.000 ksf Total Non-residential / Non-Retail Daily Trips0 Trips Daily VMT 7,252 7,117 Fast-Food Restaurant 0.000 ksf Total Employees 0 Emplolyees Residential VMT per Capita N/A N/A Gas Station 0.000 ksf HBW_P HBO_P NHB_P HBW_P HBO_P NHB_P Residential Impact? (>9.66) N/A N/A Auto Repair 0.000 ksf 0% 0% 0% 0% 0% 0% Employment VMT per Employee 14.67 14.39 Office Custom - Other Residential Uses Work Impact? (>14.46) Yes No General Office (non-medical) 70.111 ksf Total Residential Daily Trips 0 Trips Medical Office 0.000 ksf Total Residents 0 Residents
TDM Strategy Details
Strategy Type Description Proposed Project With Mitigation Transit
(1-a) Reduce transit headways Reduction in headways or increase in frequency (%) N/A N/A Level of implementation (<50%, >=50%) N/A N/A
(1-b) Implement neighborhood shuttle Degree of implementation (low, medium, high) N/A N/A Employees, residents, and visitors eligible (%) N/A N/A (1-c) Transit subsidies Daily transit subsidy amount ($) N/A 0.75$ Employees and residents eligible (%) N/A 30%
Parking
(2-d) Unbundle parking Monthly parking cost ($) N/A N/A (2-e) Reduce parking supply Base city code parking requirement (spaces) N/A N/A Actual parking provision (spaces) N/A N/A
(2-f) Price workplace parking Daily parking charge ($) N/A N/A Employees subject to priced parking (%) N/A N/A
(2-g) Parking cash-out Employees eligible (%) N/A N/A
Commute Trip Reductions
(3-h) CTR with required monitoring Employees eligible (%) N/A N/A (3-i) Ridesharing program Employees eligible (%) N/A N/A (3-j) Telecommuting Employees eligible (%) N/A N/A
(3-k) Alternative work schedules Strategy (9-day/80-hour, 4-day/40-hour) N/A N/A Employees participating (%) N/A N/A
(3-l) Association- or employer sponsored vanpool, Degree of implementation (low, medium, high) N/A N/A circulator or shuttle Employees eligible (%) N/A N/A
Education & Encouragement
(4-m) Voluntary travel behavior change program Employees and residents participating (%) N/A N/A (4-n) Promotions and marketing Employees and residents participating (%) 100% N/A Shared Mobility
(5-o) Car-share If the TDM is implemented (yes/no) N/A N/A (5-p) Bike-share If the TDM is implemented (yes/no) N/A N/A (5-q) Other shared mobility devices If the TDM is implemented (yes/no) N/A N/A (5-r) School carpool program Degree of implementation (low, medium, high) N/A N/A Neighborhood / Site Enhancement
(6-s) Traffic calming measures Intersections with traffic calming improvements (%) N/A N/A Streets with traffic calming improvements (%) N/A N/A
(6-t) Pedestrian network improvements Inclusion (within project only, within project and connecting off-site) N/A N/A (6-u) Shared use paseos or paths If the TDM is implemented (yes/no) N/A N/A Results Report
Model Runs Not Required
4034-002-001, 4034-002-002, 4034-002-004
Analysis Results
Significant Impact? Yes No
Page: Results
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 1-21-0574-1 4200 Century
U:\0574\report\TIA\0574-Appendix Covers (TIA).docx
APPENDIX D
SIGHT DISTANCE EXHIBITS FOR THE PROPOSED
101ST STREET DRIVEWAYS
CENTURY BLVD
101ST ST
FREEMAN AVE
EXISTINGCURBEXISTINGCURB
8'
Existing Street Parking SpacesWithin Sight Distance Triangle SSD @ 25 MPH = 150'
SSD @ 25 MPH = 150'
Horizontal Perspective - 8' Setback4200 CENTURYStopping Sight Distance at Loading Dock Driveway SCALE 1" = 50'
N
CENTURY BLVD
101ST ST
FREEMAN AVE
EXISTINGCURBEXISTINGCURB
8'
Existing Street Parking SpacesWithin Sight Distance Triangle SSD @ 25 MPH = 150'
SSD @ 25 MPH = 150'
Horizontal Perspective - 8' Setback4200 CENTURYStopping Sight Distance at Residential Access Driveway SCALE 1" = 50'
N
Appendix J
Water Will Serve Letter
April 18, 2022
Scarlette Dersarkissian (consultant)
KPFF Consulting Engineers
700 South Flower Street, Suite 2100
Los Angeles, CA 90017
[email protected]
Re: Will Serve Letter for 4200 W. Century Blvd., Inglewood CA 90304
To Whom it May Concern:
This letter is to inform you that water service is available to the above referenced address from Golden State Water Company’s (GSWC) Southwest District water system located in Los Angeles County. Service to the address can be provided from our existing water facilities within Century Boulevard.
Upon completion and execution of an agreement between Golden State Water Company (GSWC) and the applicant that contains satisfactory financial arrangements and other provisions governing the extension of water service under the Water Service Agreement, GSWC will begin providing water service for the referenced address once all owner obligations have been satisfied.
Analysis of more detailed development plans may require the owner to participate i n the construction of special facilities prior to the Company providing water service.
GSWC is committed to providing water service to all customers within its service area, consistent with the company’s obligations under rules, statutes and regulations o f both the California Department of Public Health and the California Public Utilities Commission.
Unless modified or extended by GSWC, this Will Serve Letter shall terminate and be of no further force and effect one year from the date indicated above.
If you have any questions concerning the issues addressed in this letter, please let us know.
Sincerely,
Joseph Zhao, P.E., PhD.
Operations Engineer Southwest District
LETTER NO. 1 – UNITE HERE LOCAL 11 (DECEMBER 3, 2024)
Jordan R. Sisson
Law Office of Jordan R. Sission
3993 Orange Street, Suite 201
Riverside, CA 92501
Comment No. 1-1
On behalf of UNITE HERE Local 11 (“Local 11”), this office respectfully submits these comments1 to the City of Inglewood (“City”) regarding the above-referenced proposal to develop a 333,500 square -foot, 13 -story mixed -use building that will include 11 condos, a 175 -room hotel, 118 extended stay serviced apartments, and retail uses (“Projec t”) on an approximately
1.98-acre property located at 4200 West Century Boulevard currently developed with a 137 - room hotel and associated surface parking lot (proposed for demolition) (“Site”).
In furtherance of the Project, 4200 QOF LLC (“Applicant”) see ks various land use approvals from the City under the Inglewood Municipal Code (“IMC” or “Code”), including: a General Plan Amendment to change the Project Site’s land use designation from Industrial to Commercial / Residential; a Zoning Code Amendment reg arding extended -stay hotel use; Approval of a Planned Assembly Development and Special Use Permit for the Project Site to allow certain deviations from various IMC provisions; a Tract Map and Condominium Plan; Site Plan Review; a Sign Agreement to allow th e Project’s proposed digital signage; and a Tree Removal Permit (collectively “Entitlements”).2 Additionally, for environmental review under the California Environmental Quality Act (“CEQA”), 3 the Applicant seeks approval of an Initial Study/Mitigated Negative Declaration (“IS/MND”).4, 5
Upon review of the relevant documents, Local 11 has concerns with the Project and the requested Entitlements and IS/MND (collectively “Project Approvals”). Local 11 has a significant interest in the Project given it represe nts more than 25,000 workers employed in hotels, restaurants, airports, sports arenas, and convention centers throughout Southern California and Phoenix, Arizona.
Response to Comment No. 1-0
This comment introduces the commenter and expresses general concern about the Project. The commenter is referred to Responses to Comments No. 1-2 through No. 1-11.
Comment No. 1-2
As discussed further below, the Project’s IS/MND seems to contain various flaws. First, the IS/MND’s air quality analysis relies on an outdated construction timeline, the land use discussion does not address the Project’s seemingly unprecedented height under the Code, nor does the energy impact analysis provide any specific details about the use of sola r panels onsite.
Additionally, the Project’s greenhouse gas (“GHG”) emissions seem to exceed widely used thresholds, and the IS/MND’s consistency evaluation of applicable GHG plans is too cursory.
Furthermore, the IS/MND’s impact analysis of vehicle miles traveled (“VMT”) seems to rely on several unsupported assumptions. Collectively, these flaws may mask impacts that warrant further mitigation—particularly those measures intended to reduce GHGs and VMTs, including but not limited to the following:
1. Including restricted affordable and/or workforce housing to ensure reduced VMTs and mobile emissions,
2. Maximizing onsite solar panel use,
3. Achieving LEED Platinum, and/or achieving Tier 1 or Tier 2 CalGreen status, and
4. Applying a hotel/entertainment -specific mandato ry commuter reduction program, with robust transportation demand management (“TDM”) strategies, such as:
A specific performance level to be reached (e.g., specific VMT or average daily trip reduction or both);
A specified participation level (e.g., 100 % employees); Participation in guaranteed ride programs;
Incentives such as employee carpool/vanpool access to preferential parking spaces or hotel valet service or both;
Full subsidized transit passes for all hotel/entertainment workers and patrons; and A dedicated shuttle service for hotel patrons to nearby destinations.
For these reasons, Local 11 respectfully asks the City to stay its action on Project Approvals until the issues discussed below are cured in a CEQA-compliant review.
Response to Comment No. 1-2
This comment asserts that the IS/MND contains flaws related to the air quality, land use and planning, energy, greenhouse gas (GHG) emissions, and vehicle miles traveled (VMT) analyses, and mitigating impacts. The commenter is referred to Response to C omment No. 1-3 regarding the air quality analysis in the IS/MND ; Response to Comment No. 1-4 regarding the zoning code consistency analysis for building height ; Response to Comment No. 1-5 regarding the energy analysis and use of solar panels; Response No. 1-6 regarding the GHG analysis; Responses to Comments No. 1-7, No. 1-8, and No. 1-9 regarding the GHG emissions analysis; and Response to Comment No. 1-10 regarding the VMT analysis. Also, regarding mitigating impacts, the commenter is referred to Response to Comment No. 1-11.
Comment No. 1-3
A. AIR QUALITY ANALYSIS MAY BE UTILIZING OUTDATED CONSTRUCTION
ASSUMPTIONS
Under CEQA, air quality impacts and their concomitant impacts on human health must be studied in CEQA documents. (See Bakersfield Citizens fo r Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1220 [quoting CEQA Guidelines § 15126.2(a)].) Here, the IS/MND states that the Projec t’s construction is anticipated over 26 months. (IS/MND, PDF p. 11, 41, 93.) However, the air quality m odeling under CalEEMod appears outdated and shorter, with assumptions of a 21 -month construction schedule from November 2022 through August 2024. (APP, PDF pp. 161, 304.) This discrepancy may impact the IS/MND’s air quality analysis, which may impact sensi tive residential receptors immediately south of the Project Site. (IS/MND, PDF p. 59, 97, 202; APP, PDF p. 60 [SR #1]; PDF p. 803 [Receptor 7].) This assumption may result in an underestimation of air impacts that may warrant further mitigation.
It may als o infect the IS/MND’s other analysis as it relates to GHG impacts (discussed further below).
Response to Comment No. 1-3
This comment asserts that the discrepancy in the Project’s construction schedule (i.e., 26 months stated in the text of the IS/MND vs. 21 months assumed in the technical air quality modeling) and the estimated start/finish construction dates could result in an underestimation of the Proj ect’s construction air quality impacts and construction -related air quality impacts on sensitive recept ors near the Project Site. The technical air quality modeling prepared for the Project estimated the Project’s construction emissions based on 2 9-month construction schedule. The impact analyses and conclusions in the IS/MND are based on the 29 -month construction schedule. The 26 -month construction schedule noted on page 3 -27 in Section 3 (Project Description) is a typo. Additionally, the technical air qua lity modeling’s estimation that the Project’s construction schedule would begin in 2022 and end in 202 5 (dates that have already passed at the time of this writing), is more conservative for impact determination than if the construction schedule timeframe had been shifted to a future date of 202 6-2028 (for example), since the air quality modeling program (C alEEMod) assumes continued improvements in combustion efficiencies over time, leading to the generation of less pollutant emissions. Thus, for all these reasons, the Project’s construction pollutant emissions, air quality impacts, including related impacts to sensitive receptors outlined in the IS/MND , are not underestimated, and no additional Project impacts not already identified in the IS/MND woul d occur.
Comment No. 1-4
B. THE PROJECT’S EXCESSIVE HEIGHT SEEMS INCONSISTENT WITH ZONING CODE Under CEQA, any inconsistencies between the proposed development and applicable land use plans should be addressed. (CEQA Guidelines § 15125(d); Pfeiffer v. City of S unnyvale City Council (2011) 200 Cal.App.4th 1552, 1566; Friends of the Eel River v. Sonoma County Wate r Agency (2003) 108 Cal.App.4th 859, 881.) Here, the Site is zoned C -2A (Airport Commercial), and the Project is proposing 13 stories reaching heights up to 150 feet. (IS/MND, PDF p. 18, 44, 191.) This seems inconsistent with the City’s zoning code., which limits hotel structures (with a minimum of 50 units) to seven stories or 75 feet. (IMC § 12 -24-12.1.) So too, this seems incompatible with the single -story, single-family homes immediately south of the Project Site. (IS/MND, PDF pp. 59, 97, 202; APP, PDF p. 60 [SR #1], p. 803 [Receptor 7].) Thus, a revised CEQA-compliant review should address this potential inconsistency.
Response to Comment No. 1-4
This comment asserts that the Project’s proposed height is inconsistent with the City’s Zoning Code, is not compatible with the single-story single-family homes south of the Project Site, and that the alleged inconsistency was not addressed in the IS/MND. Under the proposed Commercial/Residential land use designation, there is no maximum building height regulati on, and the proposed Project’s building height would be authorized pursuant to the requested Planned Assembly Development (PAD) approval . Additionally, as discussed on pages 4 -135 and 4 -136 of the IS/MND, the Federal Aviation Administration (FAA) has concl uded that by following FAA requirements (outlined in Mitigation Measure HAZARDS -1), the height of the Project’s building would not have a substantial adverse effect on the safe and efficient utilization of the navigable airspace by aircraft or on the opera tion of air navigation facilities and as such, the Project would not be a hazard to air navigation.
“Compatibility” of a project with surrounding land uses is not in and of itself an issue required to be addressed under CEQA. To the degree that the Project’s height could result in environmental impacts is discussed in detail under the Aesthetics topic in the IS/MND on pages 4 -1 through 4-
26. As discussed t herein, the Project’s height would not result in any impacts related to scenic resources and scenic vistas. Under CEQA, potential impacts related visual character/ quality for project’s located in urban areas (such as the Project) are based on the project’s consistency with applicable zoning and other regulations governing scenic quality. As stated on page 4-2 of the IS/MND, “ The proposed mixed -use building would include residential, hotel, and event space uses within 13 stories, reaching a maximum height o f 150 feet, reflecting contemporary architecture and consistent with the use and development standards established by the Project’s proposed Commercial Residential land use designation and Planned Assembly Development (PAD) zoning regulations.” Table I-1 on pages 4-3 through 4-13 includes all of the applicable guidelines and standards from the City’s Design and Development Standards and Guidelines. As discussed therein, the Project would be substantially consistent with all of the City’s applicable design guidelines and standards. Additionally, the Project would be required to undergo Site Plan Review by the City to ensure the Project complies with the City’s design standards and achieves compatibility with the existing built environment. Thus, the Project would not conflict with applicable zoning or other regulations governing scenic quality.
Therefore, Project impacts related to scenic quality would be less than significant.
Comment No. 1-5
C. THERE ARE NO SPECIFIC DETAILS ABOUT THE PROJECT’S USE OF SOLAR PANELS
THAT MAY INDICATE ENERGY IMPACTS
CEQA requires an EIR to analyze a project’s energy consumption. (Pub. Res. Code § 21100(b)(3).) In addition to examining whether there is a “wasteful, inefficient, or unnecessary use of energy, or wasteful use of energy resources,” lead agencies must investigate whether any renewable energy features could be incorpora ted into the project. (CEQA Guidelines § 15126.2(b); League to Save Lake Tahoe v. County of Placer (2022) 75 Cal.App.5th 63, 167-168 [duty to investigate renewable energy option is required as part of determining whether project impacts on energy resources are significant].) A project’s compliance with building codes may not be enough where they do not address many considerations under Appendix F of the CEQA Guidelines, like “whether a building should be constructed at all, how large it should be, where it should be located, whether it should incorporate renewable energy resources, or anything else external to the building’s envelope.” ( California Clean Ene rgy Committee v. City of Woodland (2014) 225 Cal.App.4th 173, 211.)
Here, the IS/MND states that the Pr oject would not have an energy impact and would be consistent with the City’s 2013 Energy and Climate Action Plan (“ECAP”). However, there is no in-depth discussion of whether solar panels will be incorporated. (See e.g., IS/MND, PDF p. 113 [including solar panels in a laundry list of other measures that “may” be incorporated], p. 158 [only stipulating “reservation of solar -ready areas”].) This may indicat e that the energy impacts are underestimated and warrant mitigation, which is also relevant to the Proj ect’s GHG analysis (discussed below).
Response to Comment No. 1-5
This comment asserts that the IS/MND does not specifically state whether the Project will include the use of solar panels and that this omission may indicate that the Project’s energy (and GHG emissions) impacts have been underestimated. The commenter is referred to pages 4-66 through 4-72 of the IS/MND that include a detailed discussion of the Project’s consistency with applicable “considerations” outlined in Appendix F of the CEQA Guideline s. An “in-depth discussion of whether solar panels will be incorporated” into the Project is not a discussion that is necessary to assess whether the Project would result in “wasteful, inefficient, or unnecessary use of energy, or wasteful use of energy re sources.” The estimation of the Project’s energy consumption in the IS/MND is conservative and does not reflect the effectiveness of energy conservation measures such as those listed on pages 4 -71 and 4 -72 of the IS/MND, including the potential use of solar panels, that would reduce the Project’s energy consumption. (As of the date of this writing, inclusion of solar panels in nonresidential construction is not mandatory under CALGreen or by the City. ) Thus, the energy impacts of the Project have not been underestimated, and because the Project would not result in the “wasteful, inefficient, or unnecessary use of energy, or wasteful use of energy resources, ” no mitigation measures are warranted.
Comment No. 1-6
D. MORE ROBUST GHG ANALYSIS IS NEEDED
The California Supreme Court demands a robust GHG analysis to assess a project’s impact on climate change. Lead agencies must provide “the contours of their logical argument,” leaving no “analytical gaps” in the analysis, and supporting determinations “through sub stantial evidence and reasoned explanation.” (Center for Biological Diversity v. Cal. Dept. of Fish and Wildlife (“Newhall Ranch”) (2015) 62 Cal.4th 204 , 227; see also Cleveland National Forest Foundation v. San Diego Assn. of Governments (“Cleveland II”) (2017) 3 Cal.5th 497, 504, 519 [analysis must be “based to the extent possible on scientific and factual data … stay[ing] in step with evolving scientific knowledge and state regulatory schemes.” (Quoting CEQA Guidelines § 15064(b))].) This analysis must include good faith efforts to disclose a project’s anticipated emissions and consider consistency with the State’s GHG reduction requirements, such as:
reducing to 1990 GHG emission levels by 2020 (i.e., AB 32); 40 percent below 1990 levels by 2030 (i.e., SB 32); and 80 percent below 1990 levels by 2050 (i.e., Executive Order S -3-05). (See CEQA Guidelines § 15064.4.)
Response to Comment No. 1-6
This comment summarizes CEQA requirements for a GHG emissions analysis but is not a comment on the IS/MND. No further response is required.
Comment No. 1-7
1. FAILURE TO APPLY OBJECTIVE BRIGHT LINE AND EFFICIENCY THRESHOLDS Here, while the IS/MND claims there is “ no ‘bright line’ threshold of significance for GHG emissions” (IS/MND, PDF p. 145), the City has previo usly used thresholds proposed by South Coast Air Quality Management District (“SCAQMD”) —including SCAQMD’s Tier 3 bright -line threshold of 3,000 MTCO2e/yr for mixed -use developments and SCAQMD’s Tier 4 efficiency standard for year 2035 of 3.0 MTCO2e/yr per service population (i.e., residents + workers) (“sp”) for project-level and 4.1 MTCO2e/yr/sp for plans. 6, 7 Also noteworthy, the City has previously used a “net-zero threshold” for other redevelopment projects.8 According to the IS/MND’s GHG modeling (i.e ., CalEEMod), the Site’s existing uses generate 2,019 metric tons of CO2 equivalent per year (“MTCO2e/yr”), with the proposed Project anticipated to generate 5,662 MTCO2e/yr, for a net total increase of 3,643 MTCO2e/yr. (IS/MND, PDF pp. 156 -157 [Tbl. VIII-7].) The IS/MND also estimates that the Project will serve 383 residents and 380 jobs for a total service population of 763. (IS/MND, PDF pp. 219 [Tbl.
XIV-2].) Accordingly, the Project’s net increase in GHG emissions (i.e., 3,643 MTCO2e/yr) exceeds SCAQMD’s Tier 3 bright line threshold for mixed -use projects (i.e., 3,000 MTCO2e/yr).
Additionally, the Project’s annual emissions (i.e., 5,662 MTCO2e/yr) divided by its service population (i.e., 763 residents + employees) results in 7.42 MTCO2e/yr/sp efficiency level, which exceeds SCAQMD’s Tier 4 project -level efficiency standard (i.e., 3.0 MTCO2e/yr/sp for year 2035). So too, this exceeds the City’s prior net zero threshold.
Courts recognize exceeding SCAQMD’s unadopted thresholds as substantial evidence that a development will have a significant GHG impact. 9 Furthermore, SCAQMD’s thresholds are similar to other thresholds adopted by other air districts, including Sacramento Metropolitan AQMD,10 Bay Area AQMD 11 Placer County APCD, 12 and San Luis Obispo County A PCD13— which is further evidence that bright line and efficiency thresholds are “in step with evolving scientific knowledge and state regulatory schemes.” (Cleveland II , supra, 3 Cal.5th at 519 [Quoting CEQA Guidelines § 15064(b)].)
Response to Comment No. 1-7
This comment asserts that the IS/MND should have used “ SCAQMD’s Tier 3 bright line threshold for mixed-use projects (i.e., 3,000 MTCO2e/yr),” which SCAQMD has not adopted and does not recommend use of, for determining the Project’s GHG emissions impact . “There is no iron-clad definition of "significance ,” for greenhouse gas emissions. ( Center for Biological Diversity v. Department of Fish & Wildlife, supra, 62 Cal.4th at p. 221 .) “[E]ach lead agency [has] broad discretion to determine significance thresholds ,” and the CEQA Guidelines do "not mandate any one particular method to addre ss greenhouse gas emissions." (McCann v. City of San Diego (2021) 70 Cal.App.5th 5 1, 91 [285 Cal.Rptr.3d 175] .) For the Project, the City (as lead agency)
As stated on page 4 -103 of the IS/MND, because there is no “bright line” threshold of significance for GHG emissions adopted by the City or SCAQMD , the basis for determining the significance of the Project’s GHG emissions impacts in the IS/MND as determined by the City (as the lead agency) for evaluating the Project’s impacts related to GHG emissions focuses on consistency of the Project with statewide, regional, and local plans adopt ed for the purpose of reducing and/or mitigating GHG emissions. As discussed in detail on pages 4-78 through 4-132 in the IS/MND, the Project would be substantially consistency with all applicable statewide, regional, and local plans adopted for the purpos e of reducing and/or mitigating GHG emissions, and impacts related to GHG emissions would be less than significant.
Comment No. 1-8
2. CONSISTENCY EVALUATION SEEMS ABBREVIATED
Here, the IS/MND provides a brief evaluation of the Project’s consistency with the City’s 2013 ECAP citing four generic strategies. (IS/MND, PDF pp. 157 -158.) However, there is no discussion of specific “local actions” or “state policies & regulations” or “implementation action[s]” listed in the ECAP for each of the strategies. 14 Nor is there any discussion of the points achieved by the Project for a “fully compliant” ECAP project, 15 as the City has done for another development project.16
Response to Comment No. 1-8
This comment expresses an opinion that the evaluation of the Project’ s consistency with the City’s 2013 ECAP in the IS/MND is brief. The City’s ECAP does not meet the statutory criteria to be considered a qualified CAP, but nonetheless, the consistency of the Project with the applicable strategies outlined in the City’s ECA P is discussed in the IS/MND , as the City has done with other recent CEQA documents. Furthermore, as discussed in Response to Comment No. 1-7, due to the absence of a “bright line” threshold of significance for GHG emissions adopted by the City or SCAQMD, the City as lead agency has determined that the basis for determining the significance of the Project’s GHG emissions impacts focuses on the Project’s consistency with applicable plans, policies, regulations, and requirements related to reducing GHG emissions, of which the ECAP is one such plan.
Comment No. 1-9
Additionally, the IS/MND claims the Project is consistent with SCAG’s adoption of the 2020 - 2045 RTP/SCS, primarily relying on the generic description that the Project is a mixed -use development designed to reduce VMTs. (IS/MND, PDF pp. 171 -173 [Tbl. VIII-9].) However, the IS/MND CalEEMod estimates the Project would collectively generate 11,536,920 VMTs annually. (APP, PDF p. 170.) Even assuming the 763 service population (discussed supra), the Project would generate 41.42 VMT/sp, which exceeds the 2020 RTP/SCS assumed daily VMT per capita for Los Angeles County (22.2 VMTs in base year 2016 to 19.2 VM Ts in 2045 under plan).17 This may indicate the Project is inconsistent with the RTP/SCS.
In sum, excee dances of SCAQMD’s thresholds and potential conflicts with plans may indicate significant GHG impacts that warrant further mitigation.
Response to Comment No. 1-9
This comment asserts that the Project’s VMT is 41.42 per “service population” that exceeds SCAG’s projected 22.2 (2016)/21.4 (2020)/19.7 (2035) VMT per capita for Los Angeles County.
The 41.42/capita/day VMT calculation is based on the very conservative annual VMT estimation of 11,536,920 total annual VMT made in CalEEMod, the modeling program use d to estimate a project’s pollutant emissions. The CalEEMod VMT estimation for the Project is based on default VMT values in CalEEMod that were not overridden to reflect a more accurate VMT estimation for the Project when the modeling was conducted for the IS/MND. The more conservative CalEEMod VMT calculations for the Project were used in the IS/MND’s Air Quality and GHG Emissions analyses to allow for a conservative analysis. As discussed in detail on page s 4-207 and 4-208 the IS/MND, the Project’s reside ntial VMT per capita is 8.81 (with PDF -1), with an employment VMT per employee of 14.39 (with PDF -1), respectively. Thus, the Project’s VMT per capita/employee is much lower than SCAG’s projected VMT preferences. As a result, the Project is not inconsistent with SCAG’s RTP/SCS.
Comment No. 1-10
E. VMT AND TRAFFIC ASSUMPTIONS SEEM UNSUBSTANTIATED
CEQA requires analysis of VMT traffic impacts related to a p roject. (See Kings County Farm Bureau v. Hanford (1990) 221 Cal.App.3d 692, 727.) In particular, CEQA r equires analysis of project-related traffic impacts in a manner that does not minimize cumulative impacts. (See e.g., Cleveland III, 17 Cal.App.5th at 444-445 [on remand, traffic analysis based on methodology with known data gaps that underestimated traffi c impacts necessarily prejudiced informed public participation and decisionmaking]; Kings County Farm Bureau , supra at 718, 727 [rejecting determination that less than one percent of area emissions was less than significant because analysis improperly focu sed on the project -specific impacts and did not properly consider the collective effect of the relevant projects on air quality]; Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th 1059, 1072 [upholding analysis under “stringent cumulativ e- impact threshold”]; Al Larson Boat Shop, Inc. v. Board of Harbor Comm’rs , (1993) 18 Cal.App.4th 729, 749 [upholding analysis where cumulative impacts w ere not minimized or ignored].) The relevant inquiry is not only the relative amount of increased traffic that the Project will cause but whether any additional amount of Project traffic should be considered significant in light of an already serious problem. (See Los Angeles Unified School District v. City of Los Angeles (1997) 58 Cal.App.4th 1019, 1025.)
Here, the IS/MND estimated the Project’s traffic generation utilizing traffic rates based on the assumption that the Project included 118 apartment dwelling units (using ITE code 221 for multi- family housing), 11 condos (same), and 175 hotel rooms (ITE c ode 310 for hotels). (IS/MND, PDF p. 246.) However, the IS/MND characterizes the Project’s apartment dwelling units as “118 ‘serviced apartment’ extended stay hotel rooms” (id., at PDF p. 11, 18-19), which are anticipated to be occupied only part -time associated with sports teams, leagues, concert promoters, and other nearby entertainment venues (e.g., SoFi Stadium, intuit Dome, YouTube Theater, Forum, etc.) (id., at PDF pp. 219, 249). These are not “primary places of residence” and will be occupied only on an intermittent basis. (Id., at PDF p. 19 [fn 3].) However, there is no proposed condition of approval restricting occupants/tenants to those working at nearby locations, nor are these units considered workforce housing for onsite employees. These units seem indistinguishable from extended-stay hotel units, which should be analyzed as such under ITE code 310 for hotel use (i.e., 8.36 trips per unit) vers us ITE code 221 for mid -rise multi-family (i.e., 4.54 trips per dwelling unit). (APP, PDF pp. 880 -881 [Traffic Study Tbl. 5-1].) Furthermore, because extended -stay is not a permanent housing but instead temporary lodging for hotel guests, the service population may need to be revised to remove the hotel guests that are being counted as residents under the I S/MND (i.e., “2.97 persons per household”) (IS/MND, PDF p. 219 [Tbl. XIV -2]), and consider only the employees generated by the hotel component (discussed further below).
Additionally, for the 175 hotel guest rooms, the IS/MND’s VMT analysis relies on an employment generation assumption of 12 employees per 10 hotel guestrooms (1.2 per unit) and four employees per 1,000 square feet of floor area of event/entertainment uses. (IS/MND, PDF p. 92, 219, 250; APP, PDF p. 887.) However, no facts or other evidence ha ve been provided to support this assumption. In contrast, other traffic experts have opined on other developments that the ITE trip rate for hotel use (i .e., ITE code 310) generates one employee per two hotel rooms (i.e., 0.5 employees per unit). 18 This one worker per two hotel rooms is also consistent with the City of Los Angeles VMT assumptions about job generation. 19 Overestimating the number of employees could artificially reduce the number VMTs per employee metric in some instances. So too, inaccurate employee assumptions could infect the VMT equivalency assumptions (discussed below).
Furthermore, the IS/MND relies on an office equivalency formula cl aiming the general office employment VMT is similar to hotel and event/entertainment space employment VMT. (IS/MND, PDF p. 250; APP, PDF p. 887.) However, office projects tend to generate the majority of their VMTs by employees, whereas hotels and regional entertainment uses tend generate the majority of their VMTs from non -employee patrons.20 Here, the VMT analysis does not consider the VMTs generated by the hotel/event/entertainment patrons. Also, the IS/MND does not explain where the hotel-to-office formula’s 10.84 trips is derived. (Id.) In sum, these assumptions seem unsubstantiated, and the IS/MND do es not provide the fundamental data justifying these assumptions. Not only should this be disclosed, but the City should also consider the best available data about job generation and VMTs, including but not limited to similarly situated uses in the City, such as the existing 137 -room hotel operation on the Project Site. This and other City hotels and event centers should be inventoried and considered when making assumptions about the proposed VMTs and vehicle trips associated with the Project. Additionally , the City should consider the hotel/event patron VMTs, which are inherently “event center and regional serving retail” and, thus, subject to the stated no net increase VMT threshold. (IS/MND, PDF p. 249.) Ultimately, the current VMT analysis may have resulted in traffic/VMT impacts being underestimated and warranting further mitigation.
Response to Comment No. 1-00
This comment asserts that the VMT and traffic assumptions used in the traffic analysis for the Project are unsubstantiated. As described in the attached response memorandum from Linscott, Law and Greenspan, the Project’s traffic engineer, t he trip generation forecast for the Project (refer to Table XVII -2 on page 4 -204 of the IS/MND ) conservatively assumes that the 118 proposed apartment dwelling units would be occupied on a full -time basis, when the likelihood would be that the units would be occupied on a part-time basis. However, no reductions were made to the trip generation forecast or VMT to account for the units being occupied on a part - time basis. Furthermore, while not primary places of residence, the 118 units would be utilized as a place of residence for those staying in the units, with primary trips conservatively assumed to being made to and f rom work. The VMT analysis provided in the IS/MND does not assume any reduction in vehicle travel lengths that may occur related to Project residents wo rking at nearby locations.
Regarding hotel employees and trip generation rates, t he City, as the Lead A gency under CEQA, is responsible for providing the guidance related to the preparation of the VMT analysis for the Project. While other jurisdictions have their own guidance, the City is responsible for setting their own standards. City staff provided th e employment generation factors utilized in the VMT analysis.
Regarding the office equivalency formula, Per Section 3.2.3 of the City’s Transportation Impact Analysis Guidelines (TIA Guidelines), VMT screening and impact evaluation for hotel projects should be evaluated based on travel patterns of hotel employees (i.e., Employment VMT per Employee). Employee trip patterns related to the hotel and event/entertainment component of the Project are assumed to be similar to office uses, where employees primaril y travel from home to work and back. The Project’s event/entertainment component is an ancillary use to the hotel, and therefore, its employment is dire ctly associated. Furthermore, the event/entertainment component is expected to be an ancillary use of the Project, intended to serve hotel guests, as well as guests and visitors of other nearby entertainment venues (e.g., SoFi Stadium, Intuit Dome, YouTube Theater, Forum, etc.). It is not intended or expected to be a standalone regional attraction.
City s taff directed LLG to prepare the VMT analysis for the hotel and event/entertainment components of the Project based on the office equivalency methodology provided in the TIA, including the 10.84 trip factor, which is equal to the average daily trip rate fo r ITE Land Use Code 710 (General Office Building), of 10.84 trips per 1,000 square feet of floor area.
Comment No. 1-11
F. STRONGER MITIGATION SHOULD BE CONSIDERED
Here, the IS/MND applies no energy or GHG mitigation (IS/MND, PDF pp. 108/, 120) and applies minimal traffic-related design features and mitigation for traffic impacts, including PDF -1 Promotions and Marketing TDM Strategy 4 -N (i.e., passive ed ucation/promotion materials) and mitigation measure TRAFFIC-1 (minimum of $0.75 per day transit subsidy to a minimum of 30 percent of the Project’s hotel and event and entertainment employees). (IS/MND, PDF pp. 41, 249, 251.) The above -mentioned issues may have resulted in underestimated impacts that warrant additional mitigation, such as those numerous fea sible mitigations intended to reduce GHGs and VMTs recommended by SCAG, SCAQMD, California Air Pollution Control Officers Association (“CAPCOA”), California Air Resources Board (“ CARB”), and the Office of Planning Research (“OPR”),21, 22 including but not limited to:
1. Including restricted affordable housing or workforce housing units to ensure reduced VMTs and mobile emissions,
2. maximizing onsite solar panel use,
3. achieving LEED Platinum, and/or achieving Tier 1 or Tier 2 CalGreen status, and
4. applying a hotel/ entertainment-specific mandatory commuter reduction program, which could include:
A specific performance level to be reached (e.g., specific VMT or avera ge daily trip reduction or both);
A specified participation level (e.g., 100 % employees); Participation in guaranteed ride programs;
Incentives such as employee carpool/vanpool access to preferential parking spaces or hotel valet service or both;
Subsidized transit passes for hotel workers and patrons; and A dedicated shuttle service for hotel patrons toward nearby destinations.23 Response to Comment No. 1-01
This comment asserts that mitigation is required for the Project’s GHG emissions and VMT impacts. Regarding the Project’s GHG emissions impacts, no significant GHG emissions impacts were identified in the IS/MND, and therefore, no mitigation measures are required.
As described in the attached response memorandum from Linscott, Law and Greenspan, the Project’s traffic engineer, and as discussed on page 4-209 of the IS/MND, prior to mitigation, the estimated employment VMT per Employee for the Project’s hotel and event and entertainment components is 15.28 employm ent VMT per Employee. This exceeds the City’s significance threshold of 14.46 employment VMT per Employ ee. As discussed on the same page of the IS/MND, implementing the Transit Subsidies TDM strategy (Strategy 1 -C) as a mitigation measure (Mitigation Measure TRAFFIC-1) (specifically a minimum daily transit subsidy of $0.75 offered to a minimum of 30 percent of employees) reduces the Project’s employment VMT per Employee to 14.39 VMT per Employee and would fall below the City’s threshold of 14.46 VMT per Em ployee. Therefore, the impact is mitigated to a less -than-significant level , and no additional mitigation measures are required.
In addition to implementing the Transit Subsidies TDM strategy as a mitigation measure, the Project would implement the Promotions and Marketing TDM strategy as a PDF (Strategy 4 -N), with 100 percent of employees participating. As shown in Table 7 -1 of the Transportation Impact Analysis (TIA) prepared for the Project, included in Appendix C to the IS/MND , with the Promotions and Marketing TDM strategy implemented as a PDF in addition to the Transit Subsidies TDM strategy implemented as a mitigation measure, the Project’s VMT per Employee remains at 14.39 VMT per employee, less than the City’s threshold of 14.46 VMT per Employee.
Comment No. 1-12
In conclusion, Local 11 is concerned with the Project’s potentially significant impac t on air quality, land use consistency, energy, GHG, and VMT impacts. Collectively, the IS/MND errors discussed herein could mask potentially significant impacts that can be lessened via project - specific mitigation added to the Project. Until such time, th e MND fails to incorporate applicable mitigation contrary to CEQA. Thus, Local 11 respectfully asks the City to stay action on the Project Approvals until the various errors are cured in a CEQA -compliant environmental review that incorporates additional mitigation, including those referenced above.
Local 11 reserves the right to supplement these comments at future hearings and proceedings for this Project. (See Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109, 1120 [ CEQA litigation not limited only to claims made during EIR comment period].) This office requests, to the extent not already on the notice list, all notices of CEQA actions and any approvals, Project CEQA determinations, or public hearings to be held on th e Project under state or local law requiring local agencies to mail such notices to any person who has filed a written request for them. (See Pub. Res. C ode §§, 21092.2, 21167(f) and Gov. Code § 65092.) Please send notice by electronic and regular mail to the address identified on page one of this letter.
Thank you for consideration of these comments. We ask that this letter be placed in the administrative record for the Project.
Response to Comment No. 1-02
This comment includes closing statements for the comment letter. The commenter is referred to Responses to Comments No. 1-2 through 1-11.
VIA EMAIL:
RE: IS/MND Comments 4200 Century Blvd. Project
1 (“Local 11”), thisϐice respectfully
to the City of Inglewood (“City”) regarding the above
, and retail uses (“Project”) on an approximately 1.98
(“Site”).
(“Applicant”)
Inglewood Municipal Code (“IMC” or “Code”)
Project Site’s land use
Project’s proposed digital signage; and
“Entitlements”).
Quality Act (“CEQA”),
Declaration (“IS/MND”).
collectively “Project Approvals”).
As discussed further below, the Project’s IS/MND seems to contain variousϐlaws. First, the ’s
does not address the Project’s seemingly unprecedented height under the Code, nor does Herein, page citations are either the stated pagination (i.e., “ ”) or PDF page location (i.e., “ ”) Pub. Res. Code § 21000 et seq. and 14 Cal. Code Regs. (“CEQA Guidelines”) § 15000 et seq. (“APP”)
LHWWHU
1 2
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
Additionally, the Project’s reenhouse gas (“GHG”)
thresholds, and the IS/MND’s consistency evaluation of applicable GHG plans is too cursory.
IS/MND’s traveled (“VMT”) seems to rely on
—
management (“ ”)
v
A. A IR QUALITY ANALYSIS MAY BE UTILIZING OUTDATED CONSTRUCTION ASSUMPTIONS Bakerϔeld Ctzens for Local Control v.ty of Bakersϔld the Project’s construction is anticipated over
This discrepancy may impact the IS/MND’s air quality analysis infect the IS/MND’s other analysis as it
B. T HE PROJECT’S EXCESSIVE HEIGHT SEEMS INCONSISTENT WITH ZONING CODE Pfefer v. Cty of Sunnyvale Cty
Councl Frds of the Eel Rer v. Sonoma County Water Agency seems inconsistent with the City’s zoning code
/HWWHU (Cont.)
2 (Cont.)
3 4
•
•
•
•
•
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
C. T HERE ARE NO SPECIFIC DETAILS ABOUT THE PROJECT’S USE OF SOLAR PANELS THAT MAY
INDICATE ENERGY IMPACTS
project’s
“wasteful,
resources,”
League to Save Lake Tahoe v. County of Placer
project’s
“whether
building’s envelope.” California Clean Energy Committee v. City of Woodland consistent with the City’s 2013 Energy and Climate Action Plan (“ECAP”). However, there is no in “ ”
stipulating “reservation of solar ready areas”]
underestimated and warrant mitigation, which is also relevant to the Project’s GHG analysis D. M ORE ROBUST GHG ANALYSIS IS NEEDED
The California Supreme Court demands a robust GHG analysis to assess a project’s impact on climate change. Lead agencies must provide “the contours of their logical argument,” leaving no “analytical gaps” in the analysis, and supporting determinations “thr reasoned explanation.” (Center for Biological Diversity v. Cal. Dept. of Fish and Wildlife (“Newhall Ranch”) (2015) 62 Cal.4th 204, 227; see also Cleveland National Forest Foundation v. San Diego Assn. of Governments (“Cleveland II”) (2017) 3 Cal.5th 497, 504, 519 [analysis must be “based to the extent possible on scientiϐic and factual data … stay[ing] in step with evolving scienti ϐic knowledge and state regulatory schemes.” (Quoting CEQA Guidelines § 15064(b) good faith efforts to disclose a project’s anticipated emissions and consider consistency with the State’s GHG reduction requirements, such as: reducing to 1990 GHG emission levels by 2020 (i.e., /HWWHU(Cont.)
4 (Cont.)
5 6
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
1. FAILURE TO APPLY OBJECTIVE BRIGHT LINE AND EFFICIENCY THRESHOLDS hile the IS/MND claims there is “no ‘bright line’ threshold of signiϐicance for GHG emissions” (IS/MND, PDF p. 145), the City has
Air Quality Management District (“SCAQMD”)—including SCAQMD’s Tier 3 bright use developments and SCAQMD’s
2035 of 3.0 MTCO2e/yr per service population (i.e., residents + workers) (“sp”) for project a “net
threshold” for other redevelopment projects.
IS/MND’s GHG modeling (i.e., CalEEMod), the Site’s existing uses generate 2,019 metric tons of CO2 equivalent per year (“MTCO2e/yr”), with the proposed Project anticipated 2].) Accordingly, the Project’s
net increase in GHG emissions (i.e., 3,643 MTCO2e/yr) exceeds SCAQMD’s Ti Additionally, the Project’s annual
employees) results in 7.42 MTCO2e/yr/sp efϐiciency level, which exceeds SCAQMD’s Tier 4 project level efϐiciency standard (i.e., 3.0 MTCO2e/yr/sp for year 2035). So too, this exceeds the City’s prior SCAQMD’s unadopted thresholds as substantial evidence that a Furthermore, SCAQMD’s
– –
IBC Business Owners for Sensible Development v. City of Irvine 12 (“(GHG)
change … the District recommends that lead agencies address the impacts of climate change on a proposed /HWWHU(Cont.)
7 IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
—
evidence that bright line and efϐiciency thresholds are “ and state regulatory schemes.” Cleveland II
2. CONSISTENCY EVALUATION SEEMS ABBREVIATED
Here, the IS/MND provides a brief evaluation of the Project’s consistency with the City’s discussion of speciϐic “local actions” “state policies & ” or “implementation action[s]” “fully compliant” ECAP project
project and its ability to adapt to these changes in CEQA documents … [thus urging] evaluating whether the contribution to global climate change.”[emphasis original]), 4 (“No single project could generate enough GHG
climate change and its associated environmental impacts.”), 22 (“CEQA requires
that the lead agency review not only a project’s direct effects on the environment, but also the cumulative Guidelines § 15064]”),
30, 42 (“No single land use
/HWWHU(Cont.)
7 (Cont.)
8 IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
’s
In sum, exceedances of SCAQMD’s thresholds and
E. VMT AND TRAFFIC ASSUMPTIONS SEEM UNSUBSTANTIATED
Kings County Farm
Bureau v. Hanford
Cleveland III,
Kings County Farm Bureau,
Save Cuyama Valley v. County of Santa
Barbara (2013) 213 Cal.App.4th 1059, 1072 [upholding analysis under “stringent cumulative impact threshold”]; Al Larson Boat Shop, Inc. v. Board of Harbor Comm’rs Los Angeles Unϔied School District v. City of Los Angeles Here, the IS/MND estimated the Project’s trafϐic generation utilizing trafϐic rates based on PDF p. 246.) However, the IS/MND characterizes the Project’s “118 ‘serviced apartment’ extended stay hotel rooms” (id., at PDF p. 11, 18 at PDF pp. 219, 249). These are not “primary place of residence” and /HWWHU(Cont.)
9 10
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
“
”
or the 175 hotel guest rooms, the IS/MND’s VMT analysis relies on an ’s
“
” no net increase
/HWWHU(Cont.)
10 (Cont.)
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
F. S TRONGER MITIGATION SHOULD BE CONSIDERED
percent of the Project’s hotel and event and entertainment (“CAPCOA”) California Air Resources Board (“CARB”) Of ice of Planning Research (“OPR”) Local 11 is concerned with the Project’s potentially signiicant impact on air – 71 (see “project level mitigation measures” for air
; CARB’s 2017 Scoping Plan,
Letter 1 (Cont.)
11 12
IS/MND Comments RE: 4200 Century Blvd. Project
December 03, 2024
Galante Vineyards v. Monterey Peninsula Water Management Dist.
Letter 1 (Cont.)
12 (Cont.)
13 LETTER NO. 2 – UNITE HERE LOCAL 11 (DECEMBER 4, 2024) Jordan R. Sisson
Law Office of Jordan R. Sission
3993 Orange Street, Suite 201
Riverside, CA 92501
Comment No. 2-1
On behalf of UNITE HERE Local 11 ("Local 11"), this office respectfully submits these comments1 to the City of Inglewood ("City") Planning Commission regarding the above - referenced proposal of a 13 -story, 293-room hotel, 11 condos development ("Project") located on an approximately 1.98 -acre property currently developed with a 137 -room hotel ("Site").
These comments supplement prior comments submitted yesterday regarding the Project's Initial Study/Mitigated Neg ative Declaration ("IS/MND") and other land use entitlements ("Entitlements") (collectively "Project Approvals"), which are attached hereto.
In short, Local 11 has concerns with the Project's IS/MND compliance with the California Environmental Quality Act ("CEQA").2 As thoroughly discussed in Exhibit A, the Project's IS/MND seems to contain various flaws that may mask potential impacts on air quality durin g construction, land use consistency, energy impacts, greenhouse gas ("GHG"), and vehicle miles traveled ('VMT"). These flaws potentially mask impacts that warrant further mitigation - particularly those measures intended to reduce GHGs and VMTs. Based on the above - referenced item Staff Report dated December 4, 2024, we would add:3
1. Staff report claims the request for higher intensity "in concentrated commercial nodes … less than half a mile from the Intuit Dome and the sports and entertainment district , including SoFi stadium, Hollywood Park retail, and the Forum." (Staff Report, PDF p. 4 [emphasis added].) Ye t, this is mid -block, not adjacent to the district (Id., at PDF p.12 [Attachment 2 Project Plans, p. 2].)
2. Staff report) claims the "General Plan Amendment removes inconsistencies between the zoning designation ...." (Id., at PDF p. 4.) Yet, the C -2A zone l imits height to seven stories (75 feet), which the Project greatly exceeds (i.e., 13 stories. 150 feet). While the Sports Entertainment Overlay may allow 150 feet in height (IMC§ 12 -38.95.2), that is limited to an "Event Center Structure" that includes an "Arena" (IMC § 12 -38.91), which this does not include. Nor is this an "Event Center Supporting Structure" within the SE overly that is allowed 100 feet in height (IMC§§ 12 -38.91 [definitions],12 -38.95.2 [height].)
3. Staff Report states additional entitlement s are required (e.g., PAD, Tract Map, Site Plan Review, etc.). (Staff Report, PDF p. 5.) However, you are only being asked to approve the General Plan Am endment without these other approvals. This does not allow the Planning Commission to apply necessary c onditions of approval that address the potential impacts of this Project. In short, you are placing the cart before the horse.
Response to Comment No. 2-1
This comment addresses land use and zoning items in the City’s staff report and is not a comment on the content of the IS/MND. The City will respond to this comment.
Comment No. 2-2
This is a huge entertainment venue with a bowling alley, event space/hall, glove simulator, broadcast studio, rooftop pool, health club, food hall, bar/café shown. (Id at PDF pp. 13, 22- 27,
29.) This should be subject to the City’s no net increase VMT threshold.
Response to Comment No. 2-2
This comment claims that the Project should be made subject to a no -net-increase threshold of significance regarding VMT, which the City’s TIA Guidelines identify as the appropriate threshold of significance for event centers and regional -serving retail projects. However, as clearly described in the IS/MND’s Project Description section, the Project is neither an event center nor a regional -serving retail project, but instead predominantly consists of condominium and both serviced apartment/extended stay and non-extended stay hotel uses, with an ancillary event and entertainment component. Specifically, as reflected in the traffic analysis prepared for the IS/MND, the Project’s trip-generating event and entertainment component comprises 42,350 square feet of floor area, or only approximately 12 percent of the overall Project’s floor area of 333,500 square feet, the remainder of which comprises residential condominium and serviced apartment/extended-stay and non-extended-stay hotel uses. Therefore, the City, as lead agency under CEQA, has determined that the Project’s residential and non -residential components should properly be analyzed for potential VMT impacts under the City’s adopted VMT thresholds for such residential and non-residential uses.
Comment No. 2-3
5. The Staff Report does not address the Project's compliance with the C -2A zoning height limits of seven stories and 75 feet (IMC§12-24.12.1), nor other hotel/motel regulations (IMC§ 12-16.1).
6. Zone changes must be recommended by Planning Commission for City Council approval (IMC§12-99.7 &12-99.8). It is unclear whether tonight's Planning Commission is being asked to approve the Gener al Plan Amendment or make a recommendation f or the City Council.
Please confirm all local rules and policies regarding appeal and/or request for City Council consideration of this action, as required under state law. (See Gov. Code§ 65354.5(a) [request for a hearing by legislative body], § 65355 [legislative body shall hold at least one public hearing].)
7. You are being asked to approve the IS/MND; please also confirm any and all appeal procedures and requirements.
For these reasons, Local 11 respectfully asks the City to stay its action on the IS/M ND and General Plan Amendment until the issues discussed herein and the attached comment letter is cured in a CEQA-compliant review that considers additional measures to be incorporated, such as:
1. Including restricted affordable and/or workforce housing to ensure reduced VMTs and mobile emissions,
2. Maximizing onsite solar panel use,
3. Achieving LEED Platinum, and/or achieving Tier 1 or Tier 2 CalGreen status, and
4. Applying a hotel/entertainment -specific mandatory commuter reduction program, with robust transportation demand management ("TDM") strategies, such as:
o A specific performance level to be reached (e.g., specific VMT or average daily trip reduction or both);
o A specified participation level (e.g., 100 % employees); o Participation in guaranteed ride programs;
o Incentives such as employee carpool/vanpool access to preferential parking spaces or hotel valet service or both;
o Full subsidized transit passes for all hotel/entertainment workers and patrons; and o A dedicated shuttle service for hotel patrons to nearby destinations.
Thank you for consideration of these comments.
Response to Comment No. 2-3
This comment addresses land use and zoning items in the City’s staff report and is not a comment on the content of the IS/M ND. The City will respond to this comment. Regarding the commenter’s attached second commenter letter, the commenter is referred to Responses to Comments No. 1-1 through 1-12.
U:\0574\hearings\Responses to Comments (01.10.25).docx
Christine Rivera
City of Inglewood
January 10, 2025
David S. Shender, P.E.
Jason A. Shender, AICP
Linscott, Law & Greenspan, Engineers
1-21-0574-1
Responses to Comments on the Initial Study/Mitigated Negative Declaration for the 4200 Century Project
Linscott, Law & Greenspan (“LLG”) in in receipt of comments1 prepared by the Law Office of Jordan R. Sisson on behalf of UNITE HERE Local 11 (“Local 11”). The comments were provided in response to the Transportation Impact Analysis2 (“TIA”) prepared as part of the Initial Study/Mitigated Negative Declaration (“IS/MND”) for the 4200 Century project (“Project”) located at 4200 W. Century Boulevard and 4229-4233 W. 101st Street (“Project Site”) in the City of Inglewood (“City”). This memorandum provides responses to the individual traffic and transportation-related comments contained in the Local 11 letter.
Provided below are the restated (or paraphrased) comments, followed by a response prepared by LLG:
Comment No. 1
The trip generation forecast utilized rates based on the assumption that the Project included 118 apartment dwelling units, 11 condominiums, and 175 hotel guestrooms. ITE Land Use Code 221 (Multifamily Residential [Mid-Rise]) trip generation average rates were utilized to forecast trips for the 118 apartment dwelling units and 11 condominiums, while ITE Land Use Code 310 (Hotel) trip generation average rates were utilized to forecast trips for the 175 hotel guestrooms. However, the IS/MND characterizes the 118 apartment dwelling units as “serviced apartment” extended stay hotel rooms, which are anticipated to be occupied only part-time associated with sports teams, leagues, concert promoters, and other nearby entertainment venues (e.g., SoFi Stadium, Intuit Dome, YouTube Theater, Forum, etc.). These are not primary places of residence and will be occupied only on an intermittent basis. However, there is no proposed condition of approval restricting occupants/tenants to those working at nearby locations, nor are these units considered workforce housing for onsite employees. These units seem indistinguishable from extended-stay hotel units, which should be analyzed as such under ITE Land Use Code 310 for hotel use.
Response to Comment No. 1
The trip generation forecast prepared for the Project (provided in Table 5-1 of the TIA) conservatively (i.e., “worst case”) assumes that the 118 apartment dwelling units would be occupied on a full-time basis. As discussed in the IS/MND and the TIA, the 118 units
1 IS/MND Comments 4200 Century Blvd. Project, Law Office of Jordan R. Sisson, December 3, 2024. 2 Transportation Impact Analysis – 4200 Century, Linscott, Law & Greenspan, Engineers, August 16, 2024.
Christine Rivera
January 10, 2025
U:\0574\hearings\Responses to Comments (01.10.25).docx
are anticipated to be occupied only on a part-time basis. However, no reductions were made to the trip generation forecast to account for the units being occupied on a part-time basis, and therefore a reduction in Vehicle Miles Traveled (“VMT”). Furthermore, while not primary places of residence, the 118 units will be utilized as a place of residence for those staying in the units, with primary trips conservatively assumed to being made to and from work. The VMT analysis provided in the IS/MND does not assume any reduction in vehicle travel lengths that may occur related to Project residents working at nearby locations.
Comment No. 2
For the 175 hotel guest rooms, the VMT analysis provided in the IS/MND relies on an employment generation assumption of 12 employees per 10 hotel guestrooms and four employees per 1,000 square feet of floor area of event/entertainment uses. However, no facts or other evidence have been provided to support this assumption. In contrast, other traffic experts have opined on other developments that the ITE trip rate for hotel use (i.e., ITE Land Use Code 310) generates one employee per two hotel rooms (i.e., 0.5 employees per unit). This one worker per two hotel rooms is also consistent with the City of Los Angeles VMT assumptions about job generation.
Response to Comment No. 2
The City, as the Lead Agency under the California Environmental Quality Act (“CEQA”), is responsible for providing the guidance related to the preparation of the VMT analysis for the Project. While other jurisdictions (i.e., City of Los Angeles) have their own guidance, the City is responsible for setting their own standards. City staff provided the employment generation factors utilized in the VMT analysis.
Comment No. 3
Furthermore, the VMT analysis provided in the IS/MND relies on an office equivalency formula claiming the general office employment VMT is similar to hotel and event/entertainment space employment VMT. However, office projects tend to generate the majority of their VMT by employees, whereas hotels and regional entertainment uses tend generate the majority of their VMT from non-employee patrons. Here, the VMT analysis does not consider the VMT generated by the hotel/event/entertainment patrons.
Also, the IS/MND does not explain where the hotel-to-office formula’s 10.84 trips is derived.
Response to Comment No. 3
Per Section 3.2.3 of the City’s Transportation Impact Analysis Guidelines3 (“TIA Guidelines”), VMT screening and impact evaluation for hotel projects should be evaluated based on travel patterns of hotel employees (i.e., Employment VMT per Employee).
Employee trip patterns related to the hotel and event/entertainment component of the Project are assumed to be similar to office uses, where employees primarily travel from home to work and back. The Project’s event/entertainment component is an ancillary use
3 City of Inglewood Transportation Impact Analysis Guidelines, City of Inglewood Public Works, October 2022.
Christine Rivera
January 10, 2025
U:\0574\hearings\Responses to Comments (01.10.25).docx
to the hotel, and therefore, its employment is directly associated. Furthermore, the event/entertainment component is expected to be an ancillary use of the Project, intended to serve hotel guests, as well as guests and visitors of other nearby entertainment venues (e.g., SoFi Stadium, Intuit Dome, YouTube Theater, Forum, etc.). It is not intended or expected to be a standalone regional attraction.
City staff directed LLG to prepare the VMT analysis for the hotel and event/entertainment components of the Project based on the office equivalency methodology provided in the TIA, including the 10.84 trip factor, which is equal to the average daily trip rate for ITE Land Use Code 710 (General Office Building), of 10.84 trips per 1,00 square feet of floor area.
Comment No. 4
The Project applies minimal transportation-related design features and mitigation for transportation impacts, including implementing Promotions and Marketing (TDM Strategy 4-N as a Project Design Feature (“PDF”) and providing a minimum daily transit subsidy (TDM Strategy 1-C) of $0.75 per day to a minimum of 30% of the Project’s hotel and event and entertainment employees.
Response to Comment No. 4
As discussed in Section 7.3 of the TIA, prior to mitigation, the estimated employment VMT per Employee for the Project’s hotel and event and entertainment components is
15.28 employment VMT per Employee. This exceeds the City’s significance threshold of
14.46 employment VMT per Employee. As discussed in Section 7.4 of the TIA, implementing the Transit Subsidies TDM strategy (Strategy 1-C) as a mitigation measure (specifically a minimum daily transit subsidy of $0.75 offered to a minimum of 30% of employees) reduces the Project’s employment VMT per Employee to 14.39 VMT per Employee and would fall below the City’s threshold of 14.46 VMT per Employee.
Therefore, the impact is mitigated, and no additional mitigation measures would be required.
In addition to implementing the Transit Subsidies TDM strategy as a mitigation measure, the Project will implement the Promotions and Marketing TDM strategy as a PDF (Strategy 4-N), with 100% of employees participating. As shown in Table 7-1 of the TIA, with the Promotions and Marketing TDM strategy implemented as a PDF in addition to the Transit Subsidies TDM strategy implemented as a mitigation measure, the Project’s VMT per Employee remains at 14.39 VMT per employee, less than the City’s threshold of 14.46 VMT per Employee.
cc: File
VIA EMAIL & HAND DELIVERY:
RE: Item 6a, Planning Commission Hearing Scheduled December 4, 2024; 4200 Century Blvd. Hotel Project (GPA-2022-001)
1 (“Local 11”), thisϐice respectfully
to the City of Inglewood (“City”)
(“Project”)
(“Site”).
’
Study/Mitigated Negative Declaration (“IS/MND”) “ ”
“Project Approvals”) which are attached hereto
’s IS/MND compliance with the
Environmental Quality Act (“CEQA”) the Project’s IS/MND reenhouse gas (“ ”) traveled (“VMT”)
—
“i commercial nodes … less
than half a mile entertainment district
”
“
….”
“Event Center Struc ” tha “Arena” (
“ ”
either the stated pagination (i.e., “ ”) or PDF page location (i.e., “ ”) Pub. Res. Code § 21000 et seq. and 14 Cal. Code Regs. (“CEQA Guidelines”) § 15000 et seq.
Letter 2
1 ’
’s complia
’
management (“TDM”)
Letter 2 (Cont.)
1 (Cont.)
2 3
LETTER NO. 3 – CALIFORNIA DEPARTMEN T OF TRANSPORTATION (DECEMBER 3, 2024)
Department of Transportation
District 7
100 S. Main Street, MS 16
Los Angeles, CA 90012
Comment No. 3-1
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above -referenced project. The Proj ect includes the demolition and removal of all existing uses from the Project Site and the development of the site with a 333,500-square-foot mixed-use building. The building would be 13 stories over one level of subterranean parking, reaching a maximum he ight of 150 feet, and would reflect a contemporary architectural style. The building would include 11 residential condominium units on levels 9-12; 118 “serviced apartment” extended stay hotel rooms located on levels 7 -12; 175 hotel rooms on levels 3 -6; and approximately 54,700 square feet of event/entertainment space, hotel lobby/lounge, and hotel-associated bar and restaurant on levels 1-2. The City of Inglewood is the Lead Agency under the California Environmental Quality Act (CEQA).
The closest state fa cilities are SR 105 and I -405. After reviewing the project’s documents, Caltrans has the following comments:
Caltrans aims to reach zero traffic -related fatalities and serious injuries by 2050 as there is a direct link between impact speeds and the likelih ood of fatality or seriou s injury. To reach this goal, Caltrans encourages the Lead Agency to incorporate high -quality Complete Streets infrastructure for the proposed project. The most effective methods to reduce pedestrian and bicyclist exposure to vehic les are through physical design and geometrics, therefore Caltrans recommends the following improvements for this project:
o Promote increased usage of public transportation along W. Century Blvd., as there are several stops and nearby attractions accessible via transit. o Exceed the minimum requirements of IMC Section 12 -42.1 by adopting best practices for bike parking siting and design. For further information, please see EssentialsofBikeParking_FINA.pdf.
o Construct physically separated facilities such as Clas s IV bikeways, wide sidewalks, curb extensions, pedestrian refuge islands, landscaping, street furniture, and reductions in crossing distances through roadway narrowing.
o Include visual indicators such as pedestrian and bicyclist warning signage, flashing beacons, crosswalks, signage, and striping should be used in addition to physical design improvements to indicate to motorists that they can expect to see and yield to people walking or riding bikes.
Response to Comment No. 3-1
This comment summarizes the P roject description and identifies pedestrian and transit improvements for the Project. The commenter should note that as noted on page 3 -27 in Section 3 (Project Description) of the IS/MND, the Project will “promote increased usage of public transportation along W. Century Blvd.” through utilization of promotional and marketing tools to educate and inform employees and residents about alternative transportation options and the effects of their travel choices . Additionally, as noted on page 4 -209 in Section 4 (Environmental Impact Analysis) in Mitigation Measure TRAFFIC -1, the Project will offer a minimum transit subsidy of $0.75 per day to a minimum of 30 percent of the Project’s hotel and event and entertainment employees . (Implementation of this mitigation measure alone would ensure that Project impacts related to transportation would be less than significant.) The Project will also include bicycle parking in accordance with City regulations as implemented through the requested Planned Assembly Development and Special Use Permit approvals. Further, the Project includes sidewalk improvements along the Project Site frontages and site access points.
Finally, a safety assessment of the Project’s access points was included in the IS/MND on pages 4 -209 through 4 -212. As discussed in detai l there, the Project will not result in any significant pedestrian and bicycle safety impacts.
Comment No. 3-2
Additionally, Caltrans requests that the MND provide the Traffic Impact Analysis Report (Appendix I) for the VMT and Tr affic analysis. Caltrans recommends limiting large truck travel and construction traffic to off -peak commute hours. A permit for any heavy construction equipment and or materials that require the use of oversized transport vehicles on State highways. If co nstruction traffic is exp ected to cause issues on any State facilities, please submit a construction traffic control plan detailing potential impacts for Caltrans for review.
If you have any questions, please feel free to contact Jaden Oloresisimo, the pro ject coordinator, at [email protected] and refer to GTS # 07-LA-2024-04685.
Response to Comment No. 3-2
This comment requests the Traffic Impact Analysis Report for the Project. This report is available on the City’s website at:
https://www.cityofinglewood.org/DocumentCenter/View/20824/MND--NOI-Appendices-A-thru-J
“Provide a safe and reliable transportation network that serves all people and respects the environment.”
STATE OF CALIFORNIA------- CALIFORNIA STATE TRANSPORTATION AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF TRANSPORTATION
DISTRICT 7
100 S. MAIN STREET, MS 16
LOS ANGELES, CA 90012
PHONE (213) 266-3562
FAX (213) 897-1337
TTY 711
www.dot.ca.gov
Making Conservation
a California Way of Life
December 3, 2024
Christine Rivera
City of Inglewood
1 W. Manchester Boulevard, 4th Floor
Inglewood, CA 90301
RE: 4200 Century Mixed-Use Project: MND
GTS # 07-LA-2024-04685
SCH # 2024110250
Vic. SR 105 PM 34.997
I-405 PM 22.241
Dear Christine Rivera:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above-referenced project. The Project includes the demolition and removal of all existing uses from the Project Site and the development of the site with a 333,500-square-foot mixed-use building. The building would be 13 stories over one level of subterranean parking, reaching a maximum height of 150 feet, and would reflect a contemporary architectural style. The building would include 11 residential condominium units on levels 9-12; 118 “serviced apartment” extended stay hotel rooms located on levels 7-12; 175 hotel rooms on levels 3-6; and approximately 54,700 square feet of event/entertainment space, hotel lobby/lounge, and hotel-associated bar and restaurant on levels 1-2. The City of Inglewood is the Lead Agency under the California Environmental Quality Act (CEQA).
The closest state facilities are SR 105 and I-405. After reviewing the project’s documents, Caltrans has the following comments:
Caltrans aims to reach zero traffic-related fatalities and serious injuries by 2050 as there is a direct link between impact speeds and the likelihood of fatality or serious injury. To reach this goal, Caltrans encourages the Lead Agency to incorporate high-quality Complete Streets infrastructure for the proposed project. The most effective methods to reduce pedestrian and bicyclist exposure to vehicles are through physical design and geometrics, therefore Caltrans recommends the following improvements for this project:
o Promote increased usage of public transportation along W. Century Blvd., as there are several stops and nearby attractions accessible via transit.
Letter 3
1 Christine Rivera
December 3, 2024
“Provide a safe and reliable transportation network that serves all people and respects the environment.”
o Exceed the minimum requirements of IMC Section 12-42.1 by adopting best practices for bike parking siting and design. For further information, please see EssentialsofBikeParking_FINA.pdf.
o Construct physically separated facilities such as Class IV bikeways, wide sidewalks, curb extensions, pedestrian refuge islands, landscaping, street furniture, and reductions in crossing distances through roadway narrowing.
o Include visual indicators such as pedestrian and bicyclist warning signage, flashing beacons, crosswalks, signage, and striping should be used in addition to physical design improvements to indicate to motorists that they can expect to see and yield to people walking or riding bikes.
Additionally, Caltrans requests that the MND provide the Traffic Impact Analysis Report (Appendix I) for the VMT and Traffic analysis. Caltrans recommends limiting large truck travel and construction traffic to off-peak commute hours. A permit for any heavy construction equipment and or materials that require the use of oversized transport vehicles on State highways. If construction traffic is expected to cause issues on any State facilities, please submit a construction traffic control plan detailing potential impacts for Caltrans for review.
If you have any questions, please feel free to contact Jaden Oloresisimo, the project coordinator, at [email protected] and refer to GTS # 07-LA-2024-04685.
Sincerely,
Anthony Higgins
Acting LDR Branch Chief
cc: State Clearinghouse
Letter 3 (Cont.)
1 (Cont.)
2