errata to the final environmental impact report

32
ERRATA TO THE FINAL ENVIRONMENTAL IMPACT REPORT La Brea Gateway Date: .5- ./ CJ1 Submitted in f)H Committee Council File No: Ok t?9J( Item No.: f A:+- 4.8 Deputy: ~,e~") March 10, 2009

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ERRATA TO THE FINAL ENVIRONMENTAL IMPACT REPORT

La Brea Gateway

Date: .5- ./CJ1Submitted in f)H Committee

Council File No: Ok t?9J(Item No.: f A:+- 4.8Deputy: ~,e~")

March 10, 2009

INTRODUCTION

This document serves as an errata to the Final Environmental Impact Report (EIR) for the La BreaGateway project (project or Proposed Project), which was published in December 2008. The Final EIR isa companion to the May 2008 Draft EIR, both of which are incorporated by reference.

The Draft EIR evaluated the potential environmental impacts of the Proposed Project under the followingenvironmental issue areas:

• Agricultural Resources

Biological Resources

Mineral Resources

Aesthetics

Air Quality

Cultural Resources

Geology and Soils

Hazards and Hazardous Materials

Surface Water and Groundwater Hydrology and Water Quality

Land Use and Planning

Noise

Population and Housing

Public Services

o Fire Protection

o Police Protection

o Schools

o Parks

o Libraries

Transportation/Traffic

Utilities and Service Systems

o Wastewater

o Water Supply

o Solid Waste

•••••

•••••

••

The Draft EIR concluded that all potential environmental impacts of the Proposed Project could bereduced to less-than-significant levels by the mitigation measures recommended within the document.

The Draft EIR also evaluated a range of alternatives to the Proposed Project to provide informed decisionmaking in accordance with the requirements of the California Environmental Quality Act (CEQA). The

IntroductionPagei

La Brea GatewayErrata to the Final Environmental Impact ReportENV-2005-6164-EAF

City of Los Angeles March 10, 2009

alternatives analyzed in the Draft EIR include: 1) No Project Alternative; 2) Studio Alternative; 3) LightManufacturing Alternative; 4) Mixed-Use Coudominium Alternative; and 5) RAS3 Zone Alternative.

The Final EIR responded to comments on the Draft EIR that were received by the City of Los Angeles.Portions of the Draft EIR text were revised, and mitigation measures were added and revised. However,comments received in response to the Draft EIR did not change the conclusion that the potentialenvironmental impacts of the Proposed Project could be reduced to less-than-significant levels with theimplementation ofthe recommended mitigation measures.

Section I of this errata has been prepared to provide an evaluation of a design modification that wouldshift the density and heights of the residential uses within the Project site. With this design modification,building height on the western half of the site would decrease from a maximum of75 feet to a maximumof 54 feet, and building height on the eastern half of the site would increase from a maximum of75feet toa maximum of 84 feet. This design modification would have the same amount of development (buildingsize, commercial space, residential units, and parking) as the Proposed Project. It would generate thesame number of vehicle trips, air pollutant eruissions, students, wastewater, etc. It would have the samedemand for public services such as potable water, [ITeand police protection, parks, etc. The same amountof subterranean parking would be provided and the vehicle access points would be the same. Thepotential site-specific development impacts to biological resources, land use, hydrology and water quality,and geology, would be the same as the Proposed Project. The site development elevations for this designmodification are shown in the following figure.

Since this design modification would have the same amount of development as the Proposed Project, theonly potential environmental impact would be with respect to Aesthetics. Section I evalnates the potentialaesthetic impacts of this design modification in relation to those of the Proposed Project.

Section II of this errata provides technical clarifications to the Draft and Final EIRs.

La Brea GatewayErrata to the Final Environmental Impact ReportENV-2005-6164-EAF

IntroductionPage ii

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I. DESIGN MODIFICATION AESTHETIC IMPACT ANALYSIS

VIEWS OF THE PROJECT SITE

As with the Proposed Project, the development that would occur with respect to this modified designwould substantially change the current appearance and increase the visibility ofthe Project site. Views ofthe Project would likely be available from more off-site locations than at present, as the Project, with themodified design, would iucrease the height of buildings on the Project site from approximately 27 feet to84 feet iu the east and 54 feet in the west. However, this impact is not considered to be substantial giventhe existiug mix of uses withiu the Project vicinity, iucluding the four-story office buildiug and the WestHollywood Gateway project located north of the site along La Brea Avenue. As with the ProposedProject, the modified design would iuclude townhouse apartments along the Willoughby Avenue sidebutwould reduce heights to 37 feet, gradually stepping back to the north, rising to 54 feet for that part of theProject adjacent to existing residential uses. Although the design modification would permit heights ofup to 84 feet on the north side of the Project site, this part of the site is adjacent to existiug commercialand industrial uses. Thus the design modification would provide better integration of the residential,commercial and industrial surrounding uses by tyiug the design more closely to the surrounding uses.Therefore, the potential impacts of the Proposed Project with the modified design on the area's visualquality and character would remaiu less than significant and would be less than the impacts of theProposed Project without the design modifications.

Currently, the appearance of the Project site, as viewed from the residential development locatedimmediately south of Willoughby Avenue consists of mostly vacant two-story commercial buildings,satellite dishes, and a large billboard. The Proposed Project, with the modified design, would replace thisview with a building face, articulated by varying facades and setbacks, up to 54 feet in height iu thewestern half of the site and 84 feet iu the eastern half of the site. On the residential levels, setbacks tocreate open space and balcony areas would be provided. These open space areas would provide visualrelief from the mass of the building. As viewed from the residential development to the south of theProject site along Willoughby Avenue, this change would still substantially iucrease the sense of heightand massiug on-site from that which currently exists on the site. With respect to differences between theProposed Project without the design modification, there would be limited change in views of the' Projectsite from Detroit Street due to the increased distance of the viewer from the Project site. As discussed iuthe Draft ErR, there are no height restrictions under the existiug zoning for the Project site. Thus, thepotential impact of the Proposed Project, with the modified design, on views of the Project site wouldremain less than significant, and would be less than the impacts of the Proposed Project without thedesign modification.

Overall, impacts related to the change iu the visual appearance and character of the Project site wouldremain less than significant, as viewed from adjacent streets and the areas surroundiug the Project site.However, by reducing the height of the development iu the western half ofthe site from 75 to 54 feet, theProposed Project with the design modification would be more compatible with the existing siugle familyresidential uses located along the southern side of Willoughby Avenue west of Detroit Street, and theimpacts would be less than those ofthe Proposed Project.

La Brea GatewayErrata to the Final Environmental Impact ReportENV-2005-6164-EAF

1. Design Modification Aesthetic Impact AnalysisPage I-I

City of Los Angeles March J0, 2009

VIEWS THROUGH THE PROJECT SITE

The maximum height of the huilding would be approximately 84 feet above the existing ground level inthe eastern half of the Project site and 54 feet in the western half of the site. Therefore, view lines abovethe site would be slightly reduced. No views of scenic resources south, east and west of the Project sitewould be affected, due to the absence of such resources in the area. As with the Proposed Project, distantviews toward the Santa Monica Mountains (Hollywood Hills) available to pedestrians from the southernside of Willoughby Avenue would be blocked by the development of the Proposed Project with thedesign modification. However, such views are intermittent, are already affected by multi-storycommercial and retail buildings located along Santa Monica Boulevard, and are not considered animportant visual characteristic associated with this area. Further, views of the hills would continue to beavailable when looking north along La Brea and Formosa Avenues. Thus impacts associated with theblockage of views to the Hollywood Hills from Willoughby Avenue would be less than significant.However, by reducing the height of the development in the western half of the site from 75 to 54 feet, thisdesign modification would provide greater opportonity for people along Detroit Street to see views to thenorth of the site, and the impacts would be less than those of the Proposed Project.

SHADE AND SHADOW

Under the modified design, the maximum height of the buildings would be approximately 84 feet (anincrease from 75 feet) above the existing ground in the eastern half of the site and 54 feet (a decreasefrom 75 feet) in the western half of the site. A shadow analysis was prepared for this design modification,based on conservative assumptions with regard to building heights and building footprints. Shadows areshown in the following figures for the winter solstice, cast from 9:00 A.M. to 3:00 P.M., and for thesummer solstice, cast from 9:00 A.M. to 5:00 P.M., identifying the maximum extent of winter andsummer shadows that would be cast off-site by the design modification.

As shown, the proposed structures would cast shadows over a large area to the northeast and northwest ofthe site for short time periods of the day. The only uses that would be shaded, however, are the non-shadow-sensitive industrial and commercial uses to the north of the site. The shadow-sensitive residentialuses located to the south and west of the site would not be shaded by the Proposed Project with the designmodification. Therefore, no shading impacts would occur. The impact is the same as the ProposedProject without the design modification.

LIGHT AND GLARE

Ambient nighttime lighting presently emanates from the Project site, as well as from other developmentin the project locale including street lights, automobile headlights, security lighting, and indoor buildingillumination (light emanating from the interior of adjacent structures through windows).

La Brea Gateway

Errata to the Final Environmental Impact ReportENV-2005-6J64-EAF

1. Design Modification Aesthetic Impact AnalysisPage /-2

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City of Los Angeles March 10, 2009

As with the Proposed Project, the design modification would illuminate the Project site with lighting fromwithin the commercial, retail and residential uses, security lighting, and lighting in the common areas.Streetlights adjacent to the Project site would be provided along both La Brea and Willoughby Avenues.As part of the City's Conditions of Approval, all lighting would be shielded and focused on the Projectsite and directed away from the neighboring residential land uses. Furthermore, all lighting would besimilar to the amount oflighting provided by adjaceut commercial and retail uses. Therefore, the designmodification would not result in a substantial amount of additional light that would adversely affect theday or nighttime views in the project vicinity, and impacts would be less than significant, which is thesame as the Proposed Proj ect.

As described in the Draft EIR, the Proposed Project would include architectural features and facades thathave a low level of reflectivity. Furthermore, the Proposed Project would incorporate a variety ofbuilding materials, which will be selected and located so as to minimize the transmission of illuminationfrom interior lights toward adjacent uses. The design modification would not change any of thesefeatures. Although the design modification includes glass windows, which could increase the amount ofglare coming from the project site with respect to the development on the eastern portion of the sitebecause of the increased height, with the implementation of City Conditions of Approval regarding theuse of reflective materials, impacts would continue to be less than significant. This impact is the same asthe Proposed Project.

As with the Proposed Project, the design modification would also provide illuminated signs along thewestern commercial portion of Willoughby Avenue. These signs would generate light levels similar toother commercial and retail uses along La Brea Avenue and adjacent side streets, which are not expectedto be substantial. Just as the impacts described in the Draft EIR for the Proposed Project, these signscould, however, possibly disturb residents located along Willoughby Avenue if they cast light onto theresidential structures late at night when people are trying to sleep. This would be a potentially significantimpact, similar to that of the Proposed Project, which would be reduced to a less-than-significant level bymitigation measures B-2 through B-6.

GRAFFITI

Aesthetic impacts due to graffiti and accumulation of rubbish and debris along the walls adjacent topublic rights-of-way would remain the same for the Proposed Project or the Proposed Project with themodified design. This impact would be reduced to a less-than-significant level by mitigation measures B-7 and B-S.

La Brea GatewayErrata to the Final Environmental Impact ReportENV-2005-6164-EAF

I Design Modification Aesthetic Impact AnalysisPage 1-9

LEVEL OF SIGNIFICANCE AFTER MITIGATION

Potential impacts associated with visual characteristics, view corridors, nighttime illumination and glarewould be less than significant. Neither the Proposed Project nor the Proposed Project with the designmodification would result in any shading impacts to nearby shadow sensitive uses during any part of theyear. The mitigation measures listed in the Draft and Final EIRs would further reduce potential impactsfrom light and glare, and reduce to less-than-significant levels the potential impacts associated with

City of Los Angeles March 10, 2009

signage and graffiti. However, by reducing the height of the development in the western half of the sitefrom 75 to 54 feet, design modification would be more compatible with nearby residential uses andprovide greater opportunity for people along Detroit Street to see views to the north of the site, and theimpacts would be less than those ofthe Proposed Project without the design modification.

La Brea GatewayErrata to the Final Environmental Impact ReportENV·2005·6l64·EAF

I Design Modification Aesthetic Impact AnalysisPage ]·]0

II. TECHNICAL CLARIFICATIONS TO THEDRAFT AND FINAL EIRS

City of Ios Angeles

CLARIFICATION OF OCCUPANCY RATIO IN THE DRAFT EIR

The Draft EIR uses two Proposed Project unit occupancy ratios: the Project Description (Section III) andthe Population and Housing section (Section IV.J) apply the Hollywood Planning Area's average of 2.1persons per household in its analysis of the population and housing impacts ofthe Proposed Project, whileportions of the Public Services section (Section IV.K) and parts of the Alternatives to the ProposedProject section (Section VI) apply a Project-specific 1.33 persons per uoit residential occupancy ratio toanalyze the impacts of the Proposed Project on public services. As set forth in further detail below, uodereither occupancy ratio, the environmental impacts of the Proposed Project would continue to be less thansignificant.

As discussed in the Draft EIR, the 2.1 persons per uoit residential occupancy ratio is based on localcensus data from 2000. Specifically, census data for the Hollywood Planning Area revealed that in 2000,a total of 210,824 residents lived in 99,939 housing uoits, which equates to an average of approximately2.1 persons per household. The Draft EIR used this ratio to estimate the anticipated population of theProposed Project and assess the Proposed Project's impacts to population and housing. However, due toa variety of Project-specific factors-including the fact that over 70% of the Proposed Project'sresidential uoits would be studio or l-bedroom apartments with a size range of 450 to 775 square feet aswell as the Applicant's experience with other multi-family projects-the Project Applicant estimated thatthe Proposed Project's actual occupancy rate would be approximately 1.33 persons per uoit. This lowerresidential occupancy ratio is based on an average occupancy rate of 1.03 persons per studio uoit (450 sq.ft'/uoit), 1.05 persons per Bl uoit (675 sq. ft'/uoit), 1.10 persons per B2 uoit (775 sq. ft'/uoit), 1.95persons per Cl unit (1,000 sq. ft'/uoit), 2.03 persons per C2 unit (1,050 sq. ft'/uoit), and 2.05 persons perLfW uoit (1,100 sq. ft./unit). The Draft EIR applies the 1.33 persons per uoit ratio to the analysis of theProposed Project's impacts on public services to assess the Project's impacts in the areas of fire .protection, police protection, schools, parks, and libraries. All other environmental impact areas,including air quality and transportation/traffic, were based on either the more conservative 2.1 persons peruoit residential occupancy ratio, or did not rely on residential occupancy ratios to determine theenvironmental impacts ofthe Proposed Project.

The following discussion, involving the application of the higher 2.1 residential occupancy ratio to theProposed Project's public services impacts analysis (where applicable), clarifies that impacts to publicservices would remain less than significant, regardless of which occupancy ratio is applied. As discussedbelow, other environmental impacts areas do not rely on the Proposed Project's residential occupancyratios to establish significance thresholds, and therefore no further analysis of those environmentalimpacts areas is required.

La Brea GatewayFinal Environmental Impact ReportENV-2005-6l64-EAF

II. Technical Clarifications to the Draft and Final EIRsPageII-l

City of Los Angeles March J0, 2009

Public Services

Fire Service

As discussed in the Draft EIR (Section IV,K,I), potential impacts to fire services are based on responsedistance, fire flows, and a determination by the Los Angeles Fire Department (LAFD) as to whetherexisting staffmg levels, equipment and facilities could accommodate the increased demand for fireprotection service associated with the pn?posed Project. Response distance is based on the Project Site'slocation, not the Proposed Project's residential occupancy ratio, Any additional Proposed Projectpopulation associated with the 2.1 persons per unit occupancy ratio would not change the analysis or theimpact conclusion. Moreover, LAFD's determinations that fire flow requirements were sufficient andexisting staffing levels, equipment and facilities could accommodate the increased demand for fireprotection services associated with the Proposed Project were based on the Proposed Project's unit count,not the residential population. (Facsimile correspondence, Kathleen White, Inspector II, LAFD,Construction Services Unit - Hydrant and Access, November 16, 2004, and phone conversation, KathleenWhite, Inspector II, LAFD, Construction Services Unit - Hydrant and Access, November 17, 2004.Responses confirmed on May 22, 2007. Written correspondence, Nadia Dale, Enviromnental Specialist,Los Angeles Department of Water and Power, December 17, 2004. LADWP, Fire Service Fire PressureFlow Report for 913 N. La Brea Avenue, November 18, 2004.) Because the number of units in theProposed Project remains fixed at 219 units, a potentially higher Project population associated with the2.1 persons per unit occupancy ratio would not effect the Draft EIR's analysis or conclusion that impactsto fire services would be less than significant, and impacts to fire services would remain less thansignificant.

Police Protection

As discussed in the Draft EIR (Section IV.K.2), potential impacts to police protection are based on the netincrease of residential units or square footage of non-residential units; the demand for police servicesanticipated at the time of Project buildout compared to the expected level of service available; andwhether the project includes security and/or design features that would reduce the demand for policeservices. The Los Angeles Police Department's (LAPD) determination that the Proposed Project wouldhave a less than significant impact on police services in the Hollywood area was based on the ProposedProject's total unit count, rather than total project population, as required by the CEQA Guidelines.(Written correspondence, Fred Booker, Lieutenant, Los Angeles Police Department, July 12, 2007.)Based on the current ratio of one officer for every 648 people, both the 2.1 persons per unit and 1.33persons per unit occupancy ratios for the Proposed Project could generate the need for approximately onemore officer. As such, the Proposed Project would not result iu the need for the expansion of existing orthe construction of new police protection facilities under either occupancy ratio. Moreover, the ProposedProject's extensive security and design features that are analyzed in the Draft EIR remain the same underthe 2.1 persons per unity occupancy ratio.. Therefore, applying the higher 2.1 persons per unit occupancyratio would not generate any increased impacts, and impacts to police services would remain less thansignificant.

La Brea GatewayFinal Environmental Impact ReportENV-2005-6J64-EAF

II. Technical Clarifications to the Draft and Final EIRsPageII-2

City of Los Angeles March J0, 2009

Schools

As set forth in the Draft ErR (Section IV.K.3), the significance thresholds for public schools impacts arebased on the proposed increase in residential units or square footage of non-residential floor area, andhow that increase affects the demand for school services anticipated at the time of project buildoutcompared to the expected level of service available. The Los Angeles Unified School District (LAUSD)applies student generation rates to the number of residential units and the square footage of non-residential floor area to determine the approximate number of students a proposed project would generate.Therefore, the Proposed Project's impacts to the demand for school services would not change andschools serving the Project Site would have adequate capacity, even if the Proposed Project's populationis based on the 2.1 persons per unit occupancy ratio. Moreover, Mitigation Measure K.3-7, whichreqnires the payment of school fees to the LAUSD, bases the total reqnired school fee on a project'ssquare footage, rather than a project's residential occupancy ratio. Payment of these fees would helpfurther reduce any less than significant impact upon school services generated by the Proposed Project.Because a proposed project's impacts to public schools is not based on a proposed project's anticipatedpopulation, application of the 2.1 persons per unit occupancy ratio to the Proposed Project would not alterthe Draft EIR's conclusion that impacts to public schools would be less than significant, and impacts topublic schools would remain less than significant.

Libraries

As discussed in the Draft EIR (Section IV.K.3), the determination of significance for library impacts isbased in part on a proposed project's anticipated residential population. Development of the ProposedProject would increase the demand for library services by increasing the permanent residential populationin the area, with demand based on the State of California standards of .5 square feet of facility space perresident and two volumes of permanent collection per resident. The Draft EIR analyzed the ProposedProject's library impacts on the basis of the 1.33 persons per unit occupancy ratio, resulting in a Projectpopulation of 292 residents. On the basis of this population, the Draft EIR determined that the ProposedProject would generate an additional library need of approximately 146 (292 x .5) square feet of spaceand 584 (292 x 2) volumes of permanent collection. Applying these same standards, the Proposed Projectwith a 2.1 persons pet unit Dccnpancy ratio (resulting in a total Project population of 460 persons) wouldgenerate a need for approximately 230 (460 x .5) square feet of space and 920 (460 x 2) volumes ofpermanent collection. Thus, the required library facility square footage and number of volumes would behigher using the 2.1 persons per unit occupancy rate. However, as discussed in the Draft ErR, thelibraries serving the Proposed Project have the capacity to accommodate the additional need of 230square feet of library space generated by the Proposed Project's 460 residents, as well as the demand foran additional 920 volumes of permanent collection.

La Brea GatewayFinal Environmental Impact ReportENV-2005-6J64-EAF

II Technical Clarifications to the Draft and Final EIRsPageII-3

Although it is anticipated that the 1.33 persons per unit occnpancy ratio more accurately reflects theanticipated number of residents at the Proposed Project, for purposes of providing the most conservativeanalysis, the higher population is assumed. Pursuant to Mitigation Measure K.5-1, the Applicant wouldbe required to pay a mitigation fee of $200 per capita based upon the projected residential population of

City of Los Angeles March J0, 2009

the Proposed Project. Assuming a projected population of 460 residents, the applicant shall be required toprovide a fee of $92,000 to the Los Angeles Public Library, although impacts to library facilities wouldnevertheless be less than significant prior to mitigation.

Parks

As set forth in the Draft EIR (Section IV.K.4), potential impacts to parks are based in part on the netpopulation increase resulting from a proposed project. The Draft EIR analyzes the Proposed Project'sparks impacts on the basis of the 1.33 persons per unit occupancy ratio, which results in a total Projectpopulation of292 residents. Applying the Community Plan area's more conservative 2.1 persons per unitoccupancy ratio to the Proposed Project generates a total Project population of 460 residents. Using theCity's 4 acres per 1,000 residents parkland ratio, the Draft EIR found that the Proposed Project with apopulation of 292 residents would generate a need for 1.2 acres. Applying this same 4 acres per 1,000residents standard, the Proposed Project with a population of 460 residents would generate a need for 1.84acres. While application of the higher unit occupancy rate would generate a need for an additional .64acres, impacts to parks would nevertheless be mitigated to less-than-significant levels through thepayment of an open space fee, as permitted under the Quimby Act. The Draft EIR already lists this as amitigation measure for the Proposed Project (Mitigation Measure K.4-1). While it is anticipated that the1.33 persons per unit occupancy ratio more accurately reflects the anticipated number of Proposed Projectresidents, to ensure that impacts to parks are reduced to less than significant levels, the Applicant wouldprovide open space fees for the Proposed Project assuming the more conservative Proposed Projectpopulation of 460 residents.

Other Impact Areas

As discussed in greater detail below, because the determinations of less-than-significant impacts in thefollowing enviromnental impact areas are not dependent upon the Proposed Project's total residentialpopulation, any additional Proposed Project population associated with the higher 2.1 persons per unitoccupancy ratio would not change the impacts analysis, and enviromnental impacts would remain lessthan significant: Aesthetics, Air Quality, Cultural Resources, Geology and Soils, Hazards and HazardousMaterials, Hydrology, Land Use and Planning, Noise, Traffic and Transportation, and Utilities and PublicServices. Moreover, because the Population and Housing section of the Draft ErR analyzes impacts onthe basis of the 2.1 persons per unit occupancy rate, population and housing impacts have already beenanalyzed using the more conservative figures in the Draft EIR, and no further analysis is required.

Aesthetics

As discussed in the Draft EIR (Section IV.B), impacts to aesthetics-including views, light and glare,shade/shadow, and graffiti- are based upon the relationship of a proposed project's physicalcharacteristics to its surrounding enviromnent. The Proposed Project's residential occupancy ratio doesnot, therefore, inform the Draft EIR's aesthetics analysis or conclusions, and the Proposed Project's less-than-significant impacts to aesthetics would remain less than significant.

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Air Quality

As discussed m the Draft EIR's air quality impacts analysis (Section IV.C), a proposed project'sconsistency with the Air Quality Management Plan (AQMP) is based on conformance witb anticipatedregional populations forecasts for the overall City and the Hollywood area. Because it is estimated thatpopulations within both the City and Hollywood areas are expected to increase significantly over the nextten to twenty years, application of either the lower 1.33 residents per unit occupancy ratio (resulting in atotal Project population of 292 residents) or the higher 2.1 residents per unit occupancy ratio (resulting ina Project population of 460 residents), results in the determination that the Proposed Project would beconsistent with the anticipated regional populations forecast for the City and the Hollywood area, and theProposed Project would remain consistent with the AQMP.

With respect to daily operational air quality impacts, the associated emissions are calculated based on thenumber of residential units, non-residential buildings' square footage, and the number of vehicle trips thatwould be generated by the Proposed Project. Because the number of units in the Proposed Projectremains fixed at 219 units, the emissions estimated for the Proposed Project would not change and theProposed Project's impacts to air quality would remain less than significant.

Cultural Resources

As discussed in the Draft ElR (Section IV.D), impacts relating to cultural resources are based on aproposed project's physical relationship to identified historical, archaeological, or paleontologicalresources. The Proposed Project's residential occupancy ratio does not, therefore, inform the Draft EIR'scultural resources analysis or conclusions, and the Proposed Project's less-than-significant impacts tocultural resources would remain less than significant.

Geology and Soils

As discussed in the Draft EIR (Section IV.E), impacts relating to geology and soils-including faultingand seismicity, liquefaction, landslides, earth materials stability, groundwater, and expansive soils-arebased on a proposed project's siting, design, and engineering, as well as a project site's location andtopography. The Proposed Project's residential occupancy ratio does not, therefore, inform the DraftEIR's geology and soils analysis or conclusions, and the Proposed Project's less-than-significant impactsto geology and soils would remain less than significant.

Hazards and Hazardous Materials

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As discussed in the Draft ElR (Section IV.F), impacts relating to hazards and hazardous materials-including hazardous substances and wastes, storage tanks, onsite wells, asbestos containing materials,lead-based paint, soil and groundwater contamination, and methane-are based on factors other than aproposed project's anticipated residential occupancy ratio. Relevant significance criteria include prioruses at a project site and proposed remediation measures to mitigate anyon-site contaminants. Therefore,the Proposed Project's residential occupancy rate does not inform the Draft ElR's hazards and hazardous

City of Los Angeles March J0, 2009

materials analysis or conclusions, and the Proposed Project's less-than-significant impacts to hazards andhazardous materials would remain less than significant.

Surface Water and Groundwater Hydrology and Water Quality

As discussed in the Draft EIR (Section IV.G), impacts relating to hydrology-including surface water andgroundwater-are based on a site's topography, prior and proposed site coverage, and runoff rates. TheProposed Project's residential occupancy rate does not, therefore, inform the Draft EIR's hydrologyanalysis or conclusions, and the Proposed Project's less-than-significant impacts to hydrology wouldremain less than significant.

Land Use and Planning

As discussed in the Draft EIR (Section IV.H), land use and planning impacts are based on a proposedproject's consistency with local zoning and other land use goals and regulations. Therefore, the ProposedProject's anticipated residential occupancy ratio does not inform the Draft EIR's land use and planninganalysis or conclusions, and the Proposed Project's less-than-significant impacts to land use and planningwould remain less than significant.

Noise

As discussed in the Draft EIR (Section IV.I), operational noise impacts to locations in the vicinity of theProject site are based on an increase in the on-site population and resulting increase in motor vehicle tripstraveling to and from the Project site. Roadway traffic noise levels were calculated using data from theProject's Traffic Impact Analysis for a Proposed Mixed Use Development (the "Traffic Impact Analysis"),included as Appendix H in the Draft EIR. The Project traffic generation estimates are calculated based onthe number of residential units and non-residential building square footage. These numbers are not basedon the residential population of the Proposed Project. The estimated noise levels associated with newHVAC equipment are based on the types of Proposed Uses and are also not dependent on the residentialpopulation of the Proposed Project. The sound of people talking is one component ofthe noise levels thatwould be generated by activities within the proposed parking structure. However, this component is veryminor in relation to the noise levels associated with motor vehicles, such as tires squealing, enginesaccelerating, doors slamming, and car alarms. Therefore, the Proposed Project's less-than-significantimpacts to noise would remain less than significant, regardless of the Proposed Project's anticipatedresidential occupancy ratio.

TransportationlTraffic

The Proposed Project's Traffic Impact Analysis, included as Appendix H to the Draft EIR, serves as theunderlying document upon which the Draft EIR bases its traffic and transportation conclusions. Pursuantto the Institute of Transportation Engineers' CITE") Trip Generation, r: Edition handbook, which hasbecome the industry standard for estimating traffic generated for different land uses, traffic associatedwith residential apartment uses and retail/commercial space are quantified on the basis of a proposed

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project's total number of residential units and commercial square footage, respectively, rather thanresidential occupancy ratios. The Proposed Project's Traffic Impact Analysis applied these ITE-mandatedfactors in analyzing the Proposed Project's traffic impacts. Therefore, the Draft EIR's analysis andconclusion that the Proposed Project's impacts to traffic and transportation would be less than significantremain unchanged, irrespective of the Proposed Project's residential occupancy ratio.

Utilities and Service Systems

As discussed in the Draft EIR (Section IV.M), impacts to utilities and service systems- includingwastewater, water supply, and solid waste- are based on a proposed project's total number of residentialunits and non-residential square footage. Therefore, the Proposed Project's residential occupancy ratiodoes not affect the Draft EIR's analysis and conclusion that the Proposed Project will generate less-than-significant impacts to utilities and service systems, and impacts to utilities and service systems wouldremain less than significant.

The following redline clarifications to the La Brea Gateway EIR, which do not change any of theconclusions reached therein, are hereby incorporated into EIR #ENV-2005-6164-EAF:

ADDITIONAL CLARIFICATIONS TO THE DRAFT EIR

I. INTRODUCTION/SUMMARY

Page 1-1

The purpose of this Draft Environmental Impact Report (EIR) is to inform decision makers and thegeneral public of the potential environmental impacts resulting from the proposed La Brea Gatewayproject (Proposed Project or Project), a mixed-use project proposed to be located at the northwest comerof La Brea Avenue and Willoughby Avenue at the confluence of the Mid-Wilshire, Hancock Park, andWest Hollywood districts of the City of Los Angeles. The Project applicant is La Brea Gateway, LLC,101 South La Brea Avenue, Los Angeles, California 90036. A detailed description of the ProposedProject is contained in Section III, Project Description, of this Draft EIR.

lY.D. CULTURAL RESOURCES

Page lY.D-I0

Surface examination often cannot reveal whether archeological resources are present at a specific projectlocation. However, according to the records search conducted by the South Central Coastal InformationCenter, there are no identified prehistoric archaeological sites, prehistoric isolates, historic archaeologicalsites, or historic isolates within the boundaries of the Project site. Thus, no evidence of archeologicalremains on the Project site have ever been discovered, and excavation on site and development of theProject site is not anticipated to affect archaeological resources. However, the Project site has beendeveloped with at-grade land uses since the 1920s, and it is difficult to know what lies beneath the groundsurface. Even though the records search identified no known archaeological resources within a O.5-mile

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radius of the Project site, since no substantial excavation has ever occurred within the Project site, impactsto archaeological resources could occur during excavation activities for the proposed subterraneanparking structure. Destruction of a currently unknown significant archaeological resource at the Projectwould constitute a significant impact.

IV.K. PUBLIC SERVICES

Page IV.K-13

Very few of the residents are assumed to be of public school age. However, using the student generationrates provided by the LAUSD, development of the Proposed Project would generate a net increase ofapproximately 4Q~ elementary students, 2.Q.).& middle-school students, and 12.+high school students, (seeTable IV.K-3).

Page IV.K-14

Table IV.K-3Estimated Student Generation - Proposed Project

):):)i;)~~~~iifs,~:!!:I:;);i !):l~:~)ji;f;{;:;~.:., ..•.•f· 51 ,~",j"i; ·\i I.,r{~'!;'.·i. 'i'i il8:·.·.·.c .•·.·: •••••Existine UsesOffice" I 56,126 sq. ft. 1 I 1 I 3Proposed UsesMulti-family Residences" I ;lffi-2 J} Units 42,46 W).1. .J.<>_~Q +'J.8}Retail/Commercial" I 35,OOOsq. ft. I 0 0 1

Proposed Total <847 ±!Ill ±SlO go 88Less Existinz Total (1) (1) (1) (3)

Net Total 42.46 ±S20 1.+19 +185a Student generation rates are as follows for office uses: .0233 elementary, .0108 middle and .0104 high school students per1, 000 square feet.h Student generation rates are as follows for multi-family residential uses: .2089 elementary, .0942 middle and .0891 highschool students per dwelling unit.e Student generation rates are as follows for retail/commercial uses: .0149 elementary, .0069 middle and .0067 high schoolstudents per 1,000 square feet.

Source: Christopher A. Joseph & Associates, 2007.

Table IV.K-lPublic School Impact Summary - Proposed Project

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BancroftMiddle School 1,702 1,346 +820 ~-336

City of Los Angeles March 10, 2009

- -, ' '.', 'J E.nro,llmelit I, 'Studeuts

234258Melrose ElementarySchool 369 212 4l_46

FairfaxHigh School 3,600 2,922 -l-+ 19 -46-1. -629Source: Christooher A. Joseph & Associates, 2007

Page IV.K-1S

The Proposed Project, in combination with the related projects and the development of the Add-On Area,is expected to result in a cumulative increase in the demand for school services. There are a total of 138related projects. As shown in Table IV.K-5, the cumulative student generation is approximately 1,861J.elementary school students, 8504-8middle school students, and 80;\.+high school students.

IV.L. TRANSPORTATION/TRAFFIC

Page IV.L-14

The future cumulative analysis includes other development projects located within the study area that areeither under construction or planned. As part of this analysis, development lists were obtained fromLADOT and the City of West Hollywood Planning Department. These lists were reviewed to identifythose projects that could produce additional traffic at the study intersections by the future study year. Itshould be noted that the Proposed Project, or any actions taken by the City regarding the ProposedProject, does not have a direct bearing on these other proposed related projects. The descriptions of the138 related projects are listed in Table II-I with its location illustrated in Figure II-lO". Estimates ofthedaily and peak hour trips generated by these related projects are shown in Table IV.L-6.

Pages IV.L-24 and IV.L-2S

The analysis of traffic impacts considers the effects of both background growth in the region and theRelated Projects listed in Tahle II-I. Consequently, impacts of cumulative growth are alreadyincorporated into the traffic model and are equivalent to those indicated for the "Future With Project"condition. The additional cumulative traffic, without the Project, would increase the number of vehiclestraveling through each of the 16 study intersections. Under existing conditions, only ~ight of the 16intersections operate at LOS D or worse during one or more of the peak hours. Following the addition ofnon-Project ambient and cumulative development traffic growth, a total of ei-ght-nulfJocations wouldexhibit LOS D or worse conditions, with f-Effil.~ei"htof the 16 study intersections operating at LOS E orLOS F during one or both peak hours. With the addition of the Project traffic, peak-hour conditionswould change only nominally and one additional intersection would operate at LOS D or worse.However, as discussed previously in this Draft ErR section, the traffic generated by the Proposed Projectwould significantly impact the intersections of Willoughby Avenue and La Brea Avenue, and Romaine

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Street and La Brea Avenue. For the purpose of this Draft ErR the significant intersection capacityimpacts caused by the Proposed Project are also considered to be cumulatively considerable.

IV.M. UTILITIES AND SERVICE SYSTEMS

Page IV.M-2S

M.3-4 The building owner(s) shall only contract for operational waste disposal services with a companythat recycles <.lemBli-t;eI'Hlilll-c-Bflstffietiefi-relat-e-<'l--operationalwastes. The contract specifyingrecycled waste service shall be presented to the Department of Building and Safety prior toapproval of Certificate of Occupancy.

V. GENERAL IMPACT CATEGORIES

Page V-2

The Proposed Project could foster economic growth by increasing the number of residents at the ProjectSite who could patronize local bnsinesses and services in the area. In addition, employment opportunitieswould be provided during the construction and operation of the Proposed Project. As discussed inSection IV.J, Population and Housing, the Proposed Project would result in an increase of 219 apartmentunits with approximately ~60 residents (assmning a 2.1 persons per unit occupancy ratio) and 35,000square feet of retail space at the Project Site. This growth would be consistent with area-wide populationand housing forecasts for the Hollywood Community Plan area. The Proposed Project would provide taxrevenue for the City with the 35,000 square-foot retail component. The revenue ultimately would bereinvested into the community. The Proposed Project could stimulate redevelopment and revitalization ofthe immediate neighborhood and contribute to the overall Hollywood and nearby areas revitalization.

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VI. ALTERNATIVES TO THE PROPOSED PROJECT

Page VI-7

Under the No Project Alternative, no new housing or other land uses would be developed which couldpotentially increase the demand for police protection services. This Alternative would not result in anincrease in demand for police protection services. However, the Proposed Project would result in abeneficial impact with respect to security based on the continuous presence of employees and residents atthe Project site. .This beneficial impact would not occur under the No Project Alternative. Thisalternative also would not implement the security measures that are recommended in this Draft EIR tofurther reduce the less than significant police protection impacts of the Project. Therefore, impacts wouldbe less than significant under this alternative, but may be greater than the less-than-significant impacts ofthe Proposed Proj ect.

City of Los Angeles March 10, 2009

Pages VI-14 and VI-IS

The projected student population for the Studio Alternative is based on the type of each land usedeveloped on the Project site. The Proposed Project would generate a total of 85 students. The StudioAlternative would replace the residential and retail/commercial components of the Proposed Project withstudio space, which would generate 3 elementary, 2 middle school, and 2 high school students, totaling 7students as shown in Table VI-I. Therefore, the Studio Alternative would generate Ql+JI, fewer studentsthan the Proposed Project. As such, school impacts under the Studio Alternative would be less thansignificant, and impacts would be less than the less-than-significant impacts of the Proposed Project.

Under the Studio Alternative, there would be no new demand for additional library facilities in the sitevicinity as employees of the proposed studio are less likely to patronize libraries during working hours,and are more likely to use libraries near their homes during non-work hours. Therefore, there would beno new demand for additional library space or additional volumes of permanent collection. Applying the1.33 persons per unit occupancy ratio, +!he Proposed Project would result in a demand for approximately146 square feet of space and 584 volumes of permanent collection. Therefore, no impact to libraryservices would occur under the Studio Alternative, and impacts would be less than the less-than-significant impacts of the Proposed Project. This alternative would not, however, provide any fees to theLos Angeles Public Library to help buy books for residents of the local vicinity as would occur with theProposed Project.

Page VI-28

The projected student population for the Light Manufacturing Alternative is based on the type of eachland use developed on the Project site. The Proposed Project would generate a total of 85 students. TheLight Manufacturing Alternative would replace the residential and retail/commercial components of theProposed Project with studio space, which would generate 3 elementary, 2 middle school, and 2 highschool studeuts, totaling 7 students as shown in Table VI-6. Therefore, the Light ManufacturingAlternative would generate Ql+&-Jewer students than the Proposed Project. As such, school impactsunder the Light Manufacturing Alternative would be less than significant, and impacts would be less thanthe less-than-significant impacts of the Proposed Project.

Page VI-29

Uuder the Light Manufacturing Alternative, no permanent residents would be generated as this alternativewould only generate employees who are less likely to patronize parks during working hours and morelikely to use parks near their homes during non-work hours. Therefore, there would be no new demandfor additional public parkland or recreational facilities in the site vicinity as employees of the studio areless likely to patronize parks during working hours, and are more likely to use parks near their homesduring non-work hours. AP.plyillg the 1.3~_.pyr~Q1l._B-.R.\TUlliliccupan9'_IAt[Q.L+!he Proposed Projectwould result in a demand for approximately 1.2 acres of public parkland or recreational facilities.Therefore, no impacts on recreational facilities or parks would occur under the Light ManufacturingAlternative, and impacts would be less than the less-than-significant impacts of the Proposed Project.

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Unlike the Project, however, this alternative would not provide Recreation and Park fees to help the Cityacquire additional parkland for its residents.

Under the Light Manufacturing Alternative, there would be no new demand for additional libraryfacilities in the site vicinity as employees of the proposed studio are less likely to patronize librariesduring working hours, and are more likely to use libraries near their homes during non-work hours.Therefore, there would be no new demand for additional library space or additional volumes of permanentcollection. Applying the 1.33 persons per unit occupancy ratio, +J:heProposed Project would result in ademand for approximately 146 square feet of space and 584 volumes of permanent collection. Therefore,no impact to library services would occur under the Light Manufacturing Alternative, and impacts wouldbe less than the less-than-significant impacts of the Proposed Project. This alternative would not,however, provide any fees to the Los Angeles Public Library to help buy books for residents of the localvicinity as would occur with the Proposed Project.

Page VI-33

The Light Manufacturing Alternative would generate a net increase of approximately 984 ppd of solidwaste as shown in Table VI-lO. This increase is greater than the net increase of 714 ppd associated withthe Proposed Project (see Table rv.M-7¥I.M-9).

Page VI-38

This alternative would add 170 residential units to the City's housing inventory. The addition of these170 residential units would not exceed the projected growth rates for the Hollywood Community Planarea. Since the addition of357 residents (assuming a 2.1 persons per unit residential occupancy ratio) and170 new residential units to the Hollywood Community Plan area would not exceed growth projections,the impacts of population and housing growth under this alternative would be less than significant, batgreate<and less than the less-than-significant impacts of the Proposed Project. In addition,implementation of this alternative would have a positive impact of providing additional housing units toan area in need of revitalization, although it would not provide as many housing units as the ProposedProject.

Page VI-39

Under the Mixed-Use Condominium Alternative, fewer dwelling units would be constructed compared tothe Proposed Project. Heweve."Therefore, the condominium units would have a slightly smaller more-on-site population compared to the Proposed Project. Because of ffier-eawa-a reduced on-site population, thetype and frequency of fire protection services required to serve the Project Site would be slightlyi"€''eased-decreased. compared to the Proposed Project. The Los Angeles Fire Department has indicatedthat staffmg and resources are adequate to accommodate the Proposed Project. Therefore, it is assumedthat impacts with respect to fire protection services would be less than significant under the Mixed-UseCondominium Altemative, wt--and slightly gT€{lteJ.,-lesssiznificant than th<'-tlle already less-than-significant impacts of the Proposed Project.

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Under the Mixed-Use Condominium Alternative, fewer dwelling units would be constructed compared tothe Proposed Project. HoweverTherefore, the condominium units would have mere-a slightly smaller on-site population compared to the Proposed Project. Because of ~"leduced on-site population, thelyre and frequency of police protection services required to serve the Project Site would be slightlyincroased decreased compared to the Proposed Project. The Los Angeles Police Department has indicatedthat staffmg and resources are adequate to accommodate the Proposed Project. Therefore, it is assumedthat impacts with respect to police protection services would be less than significant under the Mixed-UseCondominium Alternative, andWt-_slightly greater-less siJrnificant than the already less-than-significantimpacts of the Proposed Project.

Pages VI-39 and VI-40

Assuming a 2.1 persons per unit residential occunancy rati~±!he residential component of the Mixed'Use Condominium Alternative would generate a need for approximately 1.4 acres of recreational space,which is greater less than the +d-ac-res-1.84 acres needed for the Proposed Project, assuming the sameresjgential occnQan"y-ratiQ. This need would be addressed through the payment of Quimby fees to helpthe City acquire additional parkland for its residents. Therefore, impacts to parks and recreationalfacilities under the Mixed-Use Condominium Alternative would be less than significant, Wt-and_slightlygl'e-alef-Iesssignificant than the already less-than-significant impacts ofthe Project.

Page VI-40

Assuming a 2.1 nersons per unit re~idential occuRancy ratio, +!he residential component of the Mixed-Use Condominium Alternative would generate a need for approximately 179 square feet of space and 714volumes of permanent collection, which is slightly gI_ than the Proposed Proj eetless than theProposed_l'IQiect if the same resic!ential occupancy ratio is applied. The same mitigation measure thatwould be implemented under the Proposed Project would also be implemented under the Mixed-UseCondominium Alternative. Therefore, impacts to libraries under the Mixed-Use CondominiumAlternative would be less than significant, But-and slightly greater less significant than the less-than-significant impacts of the Project.

Page VI-42

Based on wastewater generation rates listed in Section rv.M.!. (Wastewater) of this Draft EIR, theMixed-Use Condominium Alternative would generate a net increase of approximately 21,581 gpd ofwastewater as shown in Table VI-l3. This increase is less than the net increase of22,141 gpd associatedwith the Proposed Project (see Table IV¥I.M-l).

Page VI-43

Based on the water consumption rates listed in Section rv.M.2 (Water) of this Draft EIR, the Mixed-UseCondominium Alternative would consume a net increase of approximately 25,897 net gpd of water as

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shown in Table VI-14. This increase is less than the net increase of 26,569 gpd associated with theProposed Project (see Table TVV+.M-;l.4).

Page VI-44

Based on the solid waste generation rates listed in Section N.M.3 (Solid Waste) of this Draft EIR, theMixed-Use Condominium Alternative would generate a net increase of approximately 518 pounds perday (Ppd) of solid waste as shown in Table VI-15. This increase is less than the net increase of 714 ppdassociated with the Proposed Project (see Table IV¥±.M-19).

Page VI-48

Under the RAS3 Zone Alternative, fewer dwelling units would be constructed compared to the ProposedProject. Therefore, permanent population generation would be lower than for the Proposed Project.Similar to the Proposed Project, this alternative would not result in the displacement of any existinghomes or people. Using the average population of 1.33 persons per unit for the Proposed Project, thisalternative would generate 164 residents, which is less than the 292 residents who would be generated asa result of the Proposed Project. Alternately, app.\yjgfLthe 2.1 persons per unit residential occupancyratio, the RAS3 Altemative would generate 258 residents, which is less than the 460 residents generatedas a result ofthe Proposed Project, if the same residential occuQancy ratio iQ.i!Pplied. The 164 residents(or 258 residents based on the 2.1 persons per unit residential occupancy ratio) resulting fromimplementation of the RAS3 Zone Alternative is considered minimal, as #-either figure would representan increase of less than one percent of the population of the Hollywood Community Plan area, and wouldbe within the population projection in the Hollywood Community Plan area.

This altemative would add 123 residential units to the City's housing inventory. The addition of these123 residential units would not exceed the projected growth rates for the Hollywood Community Planarea. Since the addition of 164 residents (or 258 residents, depending npon which residential occupancyratio is applied) and 123 new residential units to the Hollywood Community Plan area would not exceedgrowth projections, the impacts of population and housing growth under this alternative would be lessthan significant and less than the less-than-significant impacts of the Proposed Project. In addition,implementation of this alternative would have a positive impact of providing additional housing units toan area in need of revitalization, although it would not provide as many honsing units as the ProposedProject.

Page VI-50

Assuming a residential occupancy ratio of 1.33 persons per unit, +,he residential component of the RAS3Zone Alternative would generate a need for approximately 0.7 acres of recreational space, which is lessthan the 1.2 acres needed for the Proposed Project, assuming the same residential occupancy ratio.A!temat~y, assumillg a residential occl!P.!lnc.Y..ratiQ~[2.L~Isons per unit, the residential comp_onentofthe RAS3 Zone Altemative would generate a need for approximately 1.0 acres of recreational space,while the Proposed Project would generate a need for 1.84 acres of recreational space, assuming the same

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K~sidentli.'LQccl!llil!lr;yratio~This need would be addressed through the payment of Recreation and Parkfees to help the City acquire additional parkland for its residents. Therefore, impacts to parks andrecreational facilities uuder the RAS3 Zone Alternative would be less than siguificant and less than theless-than-significant impact of the Project.

Assuming a residential occupancy ratio of 1.33 persons per unit. +1;heresidential component of the RAS3Zone Alternative would generate a need for approximately 82 square feet of space and 328 volumes ofpermanent collection, which is less than the Proposed Project. assuming the sarne 1.33 residentialoccupancv ratio. Altemately. assuming a residential occupancy ratio of 2.1 persons per nnit. theresidential component of the RAS3 Altemative would generate a need for aRNQ!;imately 129 smL,!"efe<;t:of Iibraty space and 516 volumes of pennanent collection. which is less than the Proposed Project,assllming the satne 2.1 residential occupancy ratio is aPJllied. The sarne ruitigation measure that would beimplemented uuder the Proposed Project would also be implemented under the RAS3 Zone Alternative.Therefore, impacts to libraries uuder the RAS3 Zone Alternative would be less than significant and lessthan the less-than-significant impact of the Project.

Page VI-52

Based on wastewater generation rates listed in Section IV.M.1. (Wastewater) of this Draft EIR, the RAS3Zone would generate a net increase of approximately 14,061 gpd of wastewater as shown in Table VI-18.This increase is less than the net increase of 22,141 gpd associated with the Proposed Project (see TablerVV-l.M-1).

Page VI-53

Based on the water consumption rates listed in Section IV.M.2 (Water). of this Draft EIR, the RAS3 ZoneAlternative would consume a net increase of approximately 16,873 net gpd of water as shown in TableVI-19. This increase is less than the net increase of26,569 gpd associated with the Proposed Project (seeIV.M -3+able-¥I-4),

Page VI-54

Based on the solid waste generation rates listed in Section IV.M.3 (Solid Waste) of this Draft EIR, theRAS3 Zone Alternative would generate a net increase of approximately 330 pouuds per day (Ppd) of solidwaste as shown in Table VI-20. This increase is less than the net increase of 714 ppd associated with theProposed Project (see Table lV.M-7¥T-9).

VII, ADD AREA ANALYSIS

Page VII-3

As discussed below uuder the topic of Population and Housing, development of the Add Area in a mannerconsistent with the RAS4 zone would have an average population of approximately 1,3021l4lf residents.This represents an increase of less than one percent of the total resident population in the Hollywood

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Planning Area, which would not represent substantial population growth within the area. Therefore, theAdd Area development would be consistent with the regional populations forecasts for the City of LosAngeles and the Hollywood area, and it would not jeopardize attainment of State and national ambient airquality standards in the Basin and the Los Angeles County portion of the Basin.

Page VII-19

Development of the Add Area in a manner consistent with the RAS4 zone would introduce 1,302&94-residents to the Add-On Area (based on a ratio of 2.1;P, residents per apartment unit for 620 apartmentunits) and would also increase the number of site visitors and employees within the Add Area. Thisincrease in residents, employees, and visitors would generate a potential increase in the demand for fireprotection services. The following discussion analyzes the major criteria for determining the Add Area'simpacts to fire protection services, including response distance and fire flows.

Page VII-20

Development of the Add Area in a manner consistent with the RAS4 zone is likely to accommodateapproximately 1,302349-residents, based on an assumed ratio of 2.1;P, persons per apartment unit for620 apartment units. Based on the current officer to citizen ratio, the development of the Add Area couldgenerate the need for approximately two more officers. As such, the development of the Add Area wouldnot result in the need for the expansion of existing or the construction of new police protection facilities.Therefore, a less than significant impact would occur. Furthermore, the development of the Add Areawould result in a beneficial impact with respect to security based on the continuous presence ofemployees and residents in the Add Area.

Page VII-22

It is estimated that the development of the Add Area in a manner consistent with the RAS4 zone wouldresult in an increase of 1,302<549-permanent residents!. In general, employees of commercial sites are notlikely to patronize parks during working hours, as they are more likely to use parks near their homesduring non-work hours. Therefore, using the standard park ratio, the development of the Add-On Areawould necessitate 5.2M acres of public parkland.

Pages VII-22 and VII-23

Development of the Add Area in a manner consistent with the RAS4 zone would increase the demand forlibrary services by increasing the permanent residential population in the area. As previously stated, theAdd Area development scenario would increase the local permanent residential population byapproximately 1.302 &W-persons2

• In general, employees of commercial sites are not likely to patronize

2

Based on 2..J.J-dl persons per apartment unit,for 620 apartment units.

Based on 2...LhJ.J-persons per apartment unit and 620 apartment units.

La Brea GatewayFinal Environmental Impact ReportENV-2005-6164-EAF

II Technical Clarifications to the Draft and Final EIRs

Pagell-16

City of Los Angeles March 10, 2009

libraries during working hours, as they are more likely to use libraries near their homes during non-workhours. Therefore, the development of the Add Area in a manner consistent with the RAS4 zone wouldgenerate an additional library need of approximately 651~ (l,302ll49 x 0.5) square feet of space and2,60:1:-1-;6913(1,302&49 x 2) volumes of permanent collection.

As stated above, the Will and Ariel Durant Branch Library would have the capacity to accommodate theadditional library need of 4~651 square feet of the Add-On Area generated by the lWil,302 residents.Therefore, although the John C. Fremont Branch Library is currently uuderserving the surrouudingcommuui1y, with the combined library services provided by the John C. Fremont and Will and ArielDurant Branch Libraries, the two branch libraries would be able to satisfy the library demand generatedby the development of the Add Area while maintaining adequate library service to the existingpopulation. As such, no new or expanded library facilities would be required to serve the Add Area, andthe associated impact would be less than significant.

CLARIFICATIONS TO THE FINAL EIR

III. CORRECTIONS AND ADDITIONS

Pages III-9 and lII-lO

95 Condominiums 35 du as 3 3 1396 Condominiums 28 du as 3 as 1297 Condominiums 23 du as 2 as 998 Condominiums 18 du as 2 as 8

99 Condominiums 130du as 12 as 51Theater 99 seats as 0 as 0

100 Condominiums 180 du as 17 as 71Retail 14,000 sf as 0 as 0

101 Office 85,000 sf as 1 as 4102 Museum 15,000 sf as 0 as 0

Retail 13,500 sf as 0 as 0

lOS Office 40000 sf as 0 as 1Condominiums 124 du as 12 as 49

Restaurant 5,300 sf as 0 as 0106 Retail 10,000 sf as 0 as 0107 Condominiums 54du as 5 as 21

108 A artments 270du as 25 as 105Retail 9,000 sf as 0 as 0

109 Condominiums 218 du as 21 as 86

La Brea Gateway II. Technical Clarifications to the Draft and Final EIRsFinal Environmental Impact Report Pagell-I7ENV-2005-6164-EAF

Table IV.K-l (Continued)Estimated Stndent Generation - Cumulative Development

(Cumulative Stndent Generation for the Schools Serving the Proposed Project)

City of Los Angeles March 10, 2009

osasasasasasasasasasasasasasasas

3,435

Restaurant & Club 6,000 sfCondominiums 54 du

110 asaso5

o21

Condominiums 32 duIII as 3 13

116

Ni htclub 13,000 sf113 as o oCondominiums 60 duOffice Condos 5 du

asas6I

243

Senior Housin 104 du117 as o oCondominiums 32 du119

Retail 7,000 sfasas

3o

13o

Condominiums 48 du120 as 5 19Condominiums 40 du121 as 4 16

122 Bar/Loun e Unknown as o o123 Restaurant 14,000 sf as o o

Office 120,000 sf125Retail 7,000 sf

asas o5o

Condominiums 96 du126 as 9 38Retail 12,986 sf as o

Related Proiects TotalPro osed Pro' ect Total

Cumulative Total

118 453 2921-7c12

J(JJIJlla Calculated assuming I seat per 120 square feet.b Calculated assuming 120 square feet per employee.

Calculated assuming 1.500 square feel per hotel roomNote: du=dwelling unit; sf=square feet; as = other school not serving the Proposed Project.Source: LAUSD, School Facilities Needs Analysis, 2006.Student generation rates are as follows for multi-family residential uses: .2089 elementary, .0942 middle and .0891high school students per dwelling unit.Student generation rates are asfollowsfor office uses; 0.0233 elementary (K-5), 0.0108 middle (6-8), and 0.0104 high(9-12) student per 1,000 square feet.Student generation rates are as/allows/or commercial/retail/restaurant uses: 0.0149 elementary (K-5), 0.0069middle (6-8), and 0,0067 high (9-12) students per 1,000 square feet,Student generation rates are as follows for hotel uses; 0.0076 elementary (K-5), 0.0035 middle (6-8), and O.0034 high(9-12) students per 1,000 square feet.Student generation rates are as follows for industrial uses: 0.0180 elementary (K-5), 0.0083 middle (6-8), and 0.0080high (9-12) students per 1,000 square feet.

Source: Christo her A. Jose h & Associates, 2008.

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II Technical Clarifications to the Draft and Final EIRsPage //-18