Reasons Why the Project is Exempt from CEQA
The four proposed Digital Displays at 395 Santa Monica Place (the Project) are categorically exempt from CEQA pursuant to Section 15301 (Class 1 – Existing Facilities), Section 15303 (Class 3 - New Construction or Conversion of Small Structures), and Section 15311 (Accessory Structures), and Section 15332 (Infill Projects) of the CEQA Guidelines.
• Section 15301 of CEQA Guidelines exempts the operation, repair, maintenance, permitting, or minor alteration of existing public or private structures, facilities, mechanical equipment or topographical features, involving negligible or no expansion of use beyond that existing at the time of the lead agency's determination. Projects that fall into this class of exemption include interior or exterior alterations and new copy on existing on-premise and off-premise signs and additions to existing structures provided that the addition will not result in an increase of more than: (1) 50 percent of the floor area of the structures before the addition, or 2,500 square feet, whichever is less; or (2) 10,000 square feet. The Digital Displays would be affixed to the existing Santa Monica Place shopping center. These Digital Displays are considered alterations to the existing shopping center and parking structure. No expansion of the land uses is proposed.
Therefore, the Project is exempt under Section 15301.
• Section 15303 of CEQA Guidelines exempts the construction and location of limited numbers of new small facilities or structures; installation of small new equipment and facilities in small structures; and the conversion of existing small structures from one use to another where only minor modifications are made in the exterior of the structure. Projects that fall into this class of exemption include accessory (appurtenant) structures including garages, carports, patios, swimming pools, and fences. The Digital Displays would be accessory structures to the existing shopping center, and therefore, the Project is exempt under Section 15303.
• Section 15311 of CEQA Guidelines provides (Class 11) exemption for the construction, or placement of minor structures accessory to (appurtenant to) existing commercial, industrial, or institutional facilities. Projects that fall into this class of exemption include construction, or placement of minor structures accessory to (appurtenant to) existing commercial, industrial, or institutional facilities, including but not limited to: (a) On-premise signs. The Digital Displays would be accessory structures to the existing shopping center, and therefore the Project is exempt from CEQA under Section 15311.
• Section 15332 of the CEQA Guidelines exempts projects characterized as in-fill development meeting the conditions below.
o The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
o The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses. o The project site has no value, as habitat for endangered, rare or threatened species.
o Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
o The site can be adequately served by all required utilities and public services.
The Project meets the qualifications of the in-fill exemption as it would be generally consistent with the general plan, would consist of the installation of Digital Displays on a site of no more than 5 acres in an urban area that has no value for endangered, rare, or threatened species. Additionally, the installation of the Digital Displays would not result in significant effects related to traffic, noise, air quality or water quality, and the displays can be adequately served by all required utilities and public service. Therefore, the Project is exempt under Section 15332.
In addition, none of the exceptions specified in Section 15300.2 of CEQA Guidelines would apply that would preclude the use of these CEQA exemptions:
• The Project site is not located in a sensitive environment – The Project site is located in the urbanized Downtown area of Santa Monica, encompassing specifically the Third Street Promenade and Santa Monica Place shopping center. The Project Site and surrounding area is fully developed with existing buildings and urban infrastructure, and does not contain any natural or sensitive habitats. The likelihood of the presence of any sensitive or special status species is extremely remote. The Digital Displays would be installed on the existing shopping center. No vegetation, including sensitive or riparian vegetation, would be affected by the Digital Displays. • The Project will not have a significant effect on the environment due to unusual circumstances – Digital displays are not unusual for entertainment districts and shopping centers. Such digital displays are common in high activity urban areas in the Los Angeles region, particularly within entertainment districts, downtowns, and commercial nightlife corridors (i.e., Downtown LA, West Hollywood’s Sunset Strip).
This includes digital displays at:
o 8775 Sunset Blvd–two digital displays consisting of approximately 1,000 sf and 500 sf in area
o 9157 Sunset Blvd - approximately 1,000 sf (20'6" tall and 50'5" wide) o 8739 Sunset Blvd - approximately 1,026 sf (19’ tall and 54’ feet wide) o 1200 S. Figueroa (LA Live) – approximately 66’ tall and 120’ wide o 1200 S. Figueroa (LA Live) – approximately 53’ tall and 112’ wide o 1200 S. Figueroa (LA Live) – approximately 53’ tall and 85’ wide o 1260 S. Figueroa (LA Live) – approximately 50’ tall and 300’ wide Key issues of concern associated with the Digital Displays include aesthetics (specifically, light/glare), energy use, and driver distraction effects. As described below, the Digital Displays would not have a significant effect related to these issues due to unusual circumstances:
Light/Glare
A Light Study was prepared (Attachment A) to analyze the Digital Displays District’s potential lighting and glare impacts to nearby sensitive uses, taking into account the illumination standards and regulations included in the Ordinance. For a worst case (conservative analysis), the Study analyzes all proposed and potentially future illuminated signs that could be installed in the District (up to 16 signs), including the Digital Displays at 395 Santa Monica Place. In analyzing light and glare impacts, the study identified and conducted monitoring at nearby sensitive receptors shown in the graphic below:
The Project Site is commercially zoned and is the City’s main economic activity center, and therefore, existing and future lighting levels experienced by residential uses are expected to be higher as compared to a residential use in a residential zoned area.
Commercial use properties such as office buildings restaurants, or retail stores are not considered sensitive use properties.
Monitoring sites are utilized to describe and evaluate the existing lighting conditions at and surrounding the District to determine the maximum potential impacts that may result from light or glare onto the nearest sensitive use properties. All monitoring site locations are within the District or located in proximity of the District and would have views of the digital displays. Several monitoring sites are also potential future display locations.
Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 California Code of Regulations, Sections 15000–15387) provides a set of sample questions to evaluate impacts with regard to aesthetics, including light and glare. The City of Santa Monica does not have established quantitative thresholds for assessing the significance of light/glare impacts of digital displays on sensitive uses nor is there an industry-wide standard or consistent application of significant thresholds to evaluate such impacts.
Therefore, for the purposes of the Lighting Study in compliance with CEQA, the City of Santa Monica provides an analysis of impacts based on the CEQA Guidelines Appendix G “questions”.
As further described in the Lighting Study, a digital display would have a significant impact with regard to artificial light or glare if:
Light
• Light trespass illuminance from a digital display exceeds 3.0 fc at nearby residential use properties within the District and therefore adversely changes the ambient light level.
The 3.0 fc threshold corresponds to the maximum permitted illuminance from signs by the City of Los Angeles Municipal Code, and is appropriate given that the District is an urban downtown, is predominantly commercial in nature, and is a designated nighttime entertainment district. The lighting within District is anticipated to function in a manner similar to the Los Angeles Sports and Entertainment District which supports nighttime activity. • Light trespass illuminance from a digital display exceeds 1.4 fc at residential use outside the District, and therefore adversely changes the ambient light level.
The 1.4 fc threshold takes into account the high density urban nature of the area, with residential uses that are interspersed amongst predominantly commercial uses.
Glare
• Or, the digital display creates glare with new high contrast conditions, with contrast ratio greater than 30:1, visible from a field of view from a residential use property.
• Or, the digital display creates glare effects on drivers of motor vehicles by exceeding the maximum luminance standards established by Section 21466.5 of the California Vehicle Code, where maximum brightness of the display within 10 degrees from the driver’s normal field of view is greater than 1,000 times the minimum measured brightness in the driver’s field of view, or when the minimum measured brightness in the field of view is 10 footlamberts or less, the measured brightness of the light source in footlambert exceeds 500 plus 100 times the angle, in degrees, between the driver’s field of view and the light source.
As analyzed and detailed further in the Lighting Study, light trespass resulting from the Project’s Digital Displays will be less than the significance threshold of 3.0 fc for existing residential use properties within the District and less than 1.4 fc for residential use properties outside of the District. Furthermore, at all residential use properties, the maximum luminance of the displays will be less than 30 to 1 contrast ratio.
Therefore, light and glare impacts from the Project would be less than significant.
Additionally, pursuant to Public Resources Code Section 21099, aesthetic impacts of the Project shall not be considered significant impacts on the environment since the Project is an employment center project on an infill site within a transit priority area (see table below).
“Employment center project”
means a project located on
property zoned for commercial
uses with a floor area ratio of no
less than 0.75 and that is located
within a transit priority area.
The Project Site is commercially zoned
Transit Adjacent Zone, developed with
existing building improvements with
FAR greater than 0.75, and is located
with a transit priority area.
“Infill site” means a lot located
within an urban area that has been
previously developed, or on a
The Project site is fully developed with
urban uses and surrounded by urban
uses.
vacant site where at least 75
percent of the perimeter of the site
adjoins, or is separated only by an
improved public right-of-way from,
parcels that are developed with
qualified urban uses.
“Transit priority area” means an
area within one-half mile of a major
transit stop that is existing or
planned, if the planned stop is
scheduled to be completed within
the planning horizon included in a
Transportation Improvement
Program or applicable regional
transportation plan.
The Project site is located within a
transit priority area as it is located within
½ mile of the Downtown Station for the
Metro E Line at 4th Street and Colorado
Avenue.
Energy
The Project would comply with Section 9.61.205(G)(6) of the Digital Display District Ordinance, which requires that all new digital displays utilize 100% renewable energy resources; therefore, the Project would not result in the inefficient, unnecessary, or wasteful consumption of energy.
Driver Distraction
The Project would comply with Section 9.61.205(H) of the Digital Display District Ordinance, which establishes standards and requirements to minimize driver distraction effects and ensure traffic safety. These standards include:
• Prohibition of directional, warning, danger, or information sign, or any other display likely to be mistaken for a traffic direction sign.
• Prohibition of any red, flashing, blinking, or intermittent lighting that may be mistaken for warning or danger signals
• Refresh rate of no more often than once every eight seconds for static images. • Transition fade in from the previous image over no less than one second for static or animated image.
• Prohibition of stroboscopic or flashing images, text, or lighting which rapidly change direction, oscillate, flash or reverse in contrast, and scrolling text With adherence to these requirements that are contained within the Ordinance, driver distraction effects associated with the Project would not be significant.
Furthermore, the City of West Hollywood recently commissioned a traffic safety study to address driver distraction effects that could occur due to the new digital billboards that have been installed on Sunset Boulevard. The study peer-reviewed existing research on the effects of full motion billboards on traffic safety conditions and collision rates, including a comparative collision analysis, comparing crash patterns on Sunset Boulevard with three other major corridors in the Los Angeles area. The study concludes that the “comparative collision analysis does not reveal any trends that suggest the presence of numerous billboards leads to a greater number of collisions compared with corridors in a similar urban environment with fewer billboards.” The existing urban conditions of the District pose less traffic safety and driver distraction risks than in West Hollywood and other urban locations that the traffic safety study reviewed. The Ordinance’s permitted locations for digital displays, particularly the corner Promenade buildings, have lower posted travel speeds than on Sunset Boulevard and on freeways where digital billboards are common. Additionally, the adjacent roadways to the display locations have less capacity (1-2 travel lanes in each direction). Therefore, the risk of driver distraction effects is anticipated to be further reduced in comparison to the traffic safety study.
The Project would not damage scenic resources - There are no scenic resources or scenic highways within or adjacent to the District boundaries. Pacific Coast Highway (PCH), located west of the Downtown, is eligible for designation as scenic highway, but it is not currently designated as such by the State or the County of Los Angeles nor is the highway located within the same viewshed as the District. Therefore, the Project would not have impacts on scenic resources.
The Project is not located on a hazardous waste site - The following hazardous materials databases were checked in November 2025 to determine if the Project site is identified as a known hazardous materials site pursuant to Government Code Section 65962.5:
• Department of Toxic Substances Control’s (“DTSC”) Envirostor database for hazardous waste and substances sites;1
• State Water Board’s Geotracker Database for cleanup program sites, land disposal sites, leaking underground storage tank sites, military sites, permitted UST sites, oil and gas monitoring sites, and National Pollutant Discharge Elimination System sites2
• State Water Board’s list of solid waste disposal sites with waste constituents above hazardous waste levels;3
• California Environmental Protection Agency’s Lists of active Cease and Desist Orders (“CDO”), Cleanup and Abatement Orders (“CAO”), Contaminated Solid Waste Disposal Sites.4
The Project Site is not listed on any hazardous material sites lists compiled pursuant to Government Code Section 65962.5. The former Sears Auto Center, which was located directly across the intersection of Colorado Boulevard and 4th Street, is listed on the DTSC’s Envirostor Database. Nonetheless, the former Sears Auto Center was remediated under a under a Work Plan prepared by MACTEC Engineering and Consulting, and listed as requiring No Further Action by the DTSC on April 4, 2012. Further, the Project includes the installation of digital displays on the exterior facades of SMP and does not include grounddisturbing activities, such as foundation work, grading, or excavation, where subsurface hazardous waste sites could be encountered. Therefore, no impacts related to hazardous waste site listing pursuant to Government Code Section 65962.5 would occur.
• The project would not cause a substantial adverse change in the significance of a historical resource – As part of the EIR prepared for the Santa Monica Civic Center EIR in 2005, a report entitled “Historic Resources Technical Report Santa Monica Civic Center Specific Plan”, was prepared by PCR in March 2004 (see Attachment B). At that time, SMP was included as part of the Civic Center Specific Plan. As discussed in the report, SMP opened in 1980 as another step in the redevelopment of Santa Monica’s central retail core that began in 1965 when the pedestrianoriented Santa Monica Mall (now Third Street Promenade) was inaugurated. The designer of Santa Monica Place was Frank O. Gehry & Associates, with Hak Sik Son as Project Designer. Since the construction of SMP, Frank Gehry has become one of the world’s most renowned contemporary architects, receiving the 1990 Pritzker Architecture Prize, architecture’s highest honor, as well as the American Institute of Architects’ Gold Medal in 1999. For these reasons, the property was evaluated for National Register eligibility. Despite being positively reviewed upon its opening, SMP was renovated in 1990 and substantially renovated again in 2007 to the current open-air shopping center and no longer reflects a Frank O. Gehry & Associates original design. As a result of the renovations and lack of integrity with its original design, the 2004 PCR Historical Resources Technical Report concluded that SMP is not a historical resource pursuant to the CEQA Guidelines, Section 15064.5(a)(2)-(3). Therefore, the proposed installation of digital displays would not result in an adverse effect on a historic resource.
Based on the above analysis, this Project is categorically exempt per Sections 15301, 15303, 15311, and 15332 of the CEQA Guidelines.