iv.j. public services

Wilshire Center Project IV.J. Public Services Draft Environmental Impact Report Page IV.J-1

ENVIRONMENTAL IMPACT ANALYSIS J. PUBLIC SERVICES

1. POLICE PROTECTION

ENVIRONMENTAL SETTING

The Los Angeles Police Department (LAPD) is the local law enforcement agency responsible for providing police protection service to the Proposed Project Site and immediate project vicinity. The LAPD is divided into four Police Station Bureaus: Central Bureau, South Bureau, Valley Bureau, and West Bureau. The Proposed Project Site is located within the jurisdiction of the Central Bureau, which includes the Northeast Area, Hollenbeck Area, Newton Area, Central Area, and Rampart Area Community Divisions. The Rampart Community Division is the primary division that would serve the Proposed Project. As depicted in Figure IV.J-1, Central Bureau Police Service Area, the Rampart Area covers approximately eight square miles and is generally bounded by Santa Monica Boulevard and Sunset Boulevard to the north, the Santa Monica Freeway to the south, Normandie Avenue and Hoover Street to the west, and the Harbor Freeway (110) to the east.

The Proposed Project would be served by the Rampart Community Police Station, located at 2710 West Temple Street, approximately 1.5 miles from the Proposed Project Site. In addition to the main Rampart Station, the Project Site would also be served by the Rampart/Wilshire Community Service Center, located at 3442 Wilshire Boulevard, approximately 0.4 miles from the Project Site (see Figure IV.J-2, Police and Fire Station Location Map). Together, the Rampart Community Police Station and the Rampart/Wilshire Community Service Center form the Rampart Community Division. The Rampart Community Division has approximately 350 sworn officers and 24 civilian support staff engaged in serving the surrounding community.1 The Rampart Area has an existing police service population of approximately 375,000 persons and an approximate officer-to-population ratio of 1:1,070.2

The crime rate, which represents the number of crimes reported, affects the “needs” projection for staff and equipment for the LAPD. To some extent, it is logical to anticipate that the crime rate in a given area will increase as the level of activity or population, along with the opportunities for crime, intensifies. However, because a number of other factors also contribute to the resultant crime rate such as police presence, crime prevention measures, and on-going legislation/funding, the potential for increased crime is not necessarily directly proportional to increases in land use activity.

1 Los Angeles Police Department, Information Technology Division, Statistical Digest 2004, and the Official

Website of the Los Angeles Police Department: http://www.lapdonline.org (January 3, 2006).

2 The Official Website of the LAPD, website: http://www.lapdonline.org/portal/getinformed.php (January 4, 2006).

City of Los Angeles May 2006


Figure IV.J-1 Central Bureau Police Service Area



Figure IV.J-2 Police and Fire Station Location Map



Table IV.J-1, Crime by Type, below, provides crime statistics for the Rampart Area as well as citywide. As the table demonstrates, crime rates have dropped by 27 percent over the past two years in the Rampart Area and by 22.6 percent citywide.

Table IV.J-1 Crimes by Type

Rampart Area Citywide Type of Crime

Year 2005 % Change From 2003

Year 2005 % Change From 2003

Homicide 33 -11% 478 -5.7% Rape 64 -9% 909 -21.6% Robbery 1,062 -25% 13,189 -18.5% Aggravated Assaults 999 -55% 15,225 -49% Child/Spousal Abuse 76 n/a 1,429 n/a Burglary 758 -29% 21,172 -13.4% Grand Theft Auto 1,518 -9% 26,093 -17.2% BTFV 1,520 -21% 31,903 -21% Personal/Other Theft 1,217 -15% 29,185 -15.4% Total 7,031 -27% 138,154 -22.6% Source: 2005 Crime Statistic Summary and COMPSTAT Rampart Area Profile, website: http://lapdonline.org/general_information/crime_statistics (January 3, 2006)

ENVIRONMENTAL IMPACT

Thresholds of Significance

In accordance with Appendix G of the State CEQA Guidelines, a significant impact could occur if a project were to:

(a) Result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services.

Furthermore, as set forth in the City of Los Angeles L.A. CEQA Thresholds Guide, the determination of significance shall be made on a case-by-case basis, considering the following factors:

(a) The population increase resulting from the proposed project, based on the net increase of residential units or square footage of non-residential floor area;

(b) The demand for police services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvements to LAPD



services (i.e., facilities, equipment, and officers) and the project’s proportional contribution to the demand; and

(c) Whether the project includes security and/or design features that would reduce the demand for police services.

Project Impacts

Short-Term Construction Impacts

Construction sites can be sources of nuisances, providing hazards and inviting theft and vandalism. Therefore, when not properly secured, construction sites can become a distraction for local law enforcement. The construction of the Proposed Project would therefore present a potentially significant impact on police protection services. However, the Proposed Project would employ mitigation measures including erecting temporary fencing around the construction site to discourage trespassers and deploying roving security guards to monitor the construction site and deter any potential criminal activity. These mitigation measures would diminish the need for police services during construction of the Proposed Project and reduce the potentially significant impact to less-than-significant.

As discussed in Section IV.K.1. (Transportation and Traffic), construction of the Proposed Project would have the potential to create some traffic impacts in the vicinity of the Project Site. Generally, construction workers would be expected to arrive and depart the site outside of the normal peak hours, i.e. during off-peak hours. They would typically arrive before 7:00 am and depart around 3:00 or 3:30 pm. The impact of construction worker trips on the AM peak hour and PM peak hour traffic is therefore expected to be negligible.

Construction truck traffic would be expected to be distributed more evenly across the workday, perhaps with some tendency for some truck trips to occur sometimes during the AM peak hour, but with only negligible truck activity in the PM peak hour. The impact of truck trips on the peak traffic hours is therefore expected to be negligible.

Construction could also require temporary lane closures on streets adjacent to the Project site. Such closures may be necessary for utility relocations, for delivery of materials, or for certain construction procedures. Traffic lane closures are not expected for any extended periods for construction, as it is expected that construction will be able to take place within project limits, or by using protected pedestrian passages on street sidewalks. It is not expected that complete closures of any streets would be required during construction.

The construction-related traffic impacts discussed above could have the potential to temporarily disrupt police services. However, in order to mitigate the potential temporary and short-term traffic impacts of any necessary lane and/or sidewalk closures during the construction period, a Construction Traffic Control/Management Plan would be developed to minimize the effects of construction on vehicular and



pedestrian circulation and assist in the orderly flow of vehicular and pedestrian circulation in the area of the Project. (see mitigation measure J.1-8 below.) Implementation of this measure would serve to reduce any potential construction traffic impacts to a less-than-significant level. Therefore, with the implementation of the identified mitigation measures, the Proposed Project’s construction-related impacts to police protection services would be less than significant.

Long-Term Operational Impacts

As discussed in Section IV.H (Population and Housing), the Proposed Project would introduce a net increase of approximately 1,137 new residents to the Project Site. This Project-related increase in persons on the Project Site represents 0.3 percent of the total existing residential police service population of the Rampart Area (1,137/350,000). In order to maintain the existing 1:1,070 officer-to-civilian ratio, the addition of 1,137 persons to the Project Site would require approximately one additional officer in the Rampart Area. The addition of one officer to the Rampart Area would not be expected to cause a need for new or expanded facilities, and thus no environmental impact would result.

While there is not a directly proportional relationship between increases in land use activity and increases in demand for police protection services, the number of calls requesting police responses to home and retail burglaries, vehicle burglaries, damage to vehicles, traffic-related incidents, and crimes against persons would be anticipated to increase somewhat with the increase in onsite activity and increase in traffic on adjacent streets and arterials. Such calls are typical of problems experienced in existing residential neighborhoods in the project area and do not represent unique law enforcement issues specific to the Proposed Project. Furthermore, the Proposed Project would include strategically positioned functional and thematic lighting to enhance public safety. Visually obstructed and infrequently accessed “dead zones” would be limited and, where possible, security would be controlled to limit public access. The building and layout design of the Proposed Project would also include crime prevention features, such as nighttime security lighting, full-time onsite professional security, building security systems, and secure parking facilities (see security plan discussion, below). In addition, the continuous visible and non-visible presence of residents and employees at all times of the day would provide a sense of security during evening and early morning hours.

As part of the Proposed Project, an on-site security plan would be conceived and implemented by the Applicant in consultation with the LAPD to minimize the potential for on-site crime and reduce demands upon additional LAPD services. While a security plan has not yet been finalized, such a plan would be required as a condition of project approval and would be developed in consultation with the LAPD Crime Prevention Unit (CPU) as part of the final site plan review process (see Mitigation Measures). Such a security plan may include some or all of the following components:

• Provisions for an on-site private security force for the commercial and residential areas. Through individual lease agreements for the proposed retail/commercial uses and property management services for the residential uses, private on-site security services would provide a 24-hour presence. Security officers would be responsible for patrolling all common areas including the



back service corridors and alleys, parking garages, and stairwells. All security officers will carry radios and patrol the grounds primarily by foot; however, bike patrol may be implemented in the parking garages and on the surrounding roadways.

• The parking garages shall be designed to cordon off residential and commercial serving parking areas to provide increased security for project residents. Both residential and commercial parking areas shall be fitted with emergency features such as closed circuit television (CCTV) or emergency call boxes that will provide a direct connection with the on-site security force or the LAPD 911 emergency response system.

• The proposed urban park shall be maintained by the Project Applicant and shall be open to the public during daylight hours only.

• Security lighting to incorporate the following:

o Design of entryways, seating areas, lobbies, elevators, locker rooms, service areas, and parking areas with good illumination and minimum dead space to eliminate areas of concealment.

o Full cut-off fixtures shall be installed which minimize glare from the light source and provide light downward and inward to structures to maximize visibility.

With the implementation of the mitigation measures identified under the “Mitigation Measures” subheading below, the Proposed Project would not significantly increase the demand for police services in the Rampart Area, nor would the Proposed Project result in the provision of new or physically altered police protection facilities or the need for new facilities, the construction of which could cause significant environmental impacts. Therefore, the Proposed Project’s operational impacts to police protection services would be less than significant.

CUMULATIVE IMPACTS

The Proposed Project, in combination with ambient growth and the 49 related projects (see Section III, Environmental Setting), would increase the demand for police protection services in the Rampart Area. The Rampart Area has an existing police service population of approximately 375,000 persons.3 By the year 2008, the police service population in the Rampart service area would be expected to increase by approximately 11,334 persons due to ambient growth.4 The 49 Related Projects within the Rampart Area would contribute 28,083 persons to the area’s population and the Proposed Project would add 1,137 permanent residents to the Project Site. The Proposed Project, combined with ambient growth and the 49

3 The Official Website of the LAPD, website: http://www.lapdonline.org/portal/getinformed.php (January 4,

2006)

4 Based on an ambient growth rate of 1.5 percent per year over two years, which is projected to be the duration of project construction.



related projects, would result in a 40,552-person cumulative increase in the police service population in the Rampart Area, of which the Proposed Project would comprise approximately 2.7 percent.

The cumulative increase of 40,552 persons in terms of police service population would require approximately 38 additional officers to maintain the existing 1:1,070 ratio of officers to civilians. It is possible that the additional 38 officers generated by the Proposed Project in combination with the related projects and ambient growth could be accommodated by the Rampart Community Division. It is likely that over time a new or expanded police station would be needed to accommodate the 38 additional officers that would need to be hired as a result of the cumulative growth.

Furthermore, any new or expanded police station would be funded via existing mechanisms (i.e., sales taxes, government funding) to which the Proposed Project and related projects would contribute. In addition, similar to the Proposed Project, each of the related projects would be individually subject to LAPD review, and would be required to comply with all applicable safety requirements of the LAPD and the City of Los Angeles in order to adequately address police protection service demands. Impacts created by new development would be reduced by the incorporation of required security measures into each proposed development. In addition, the Proposed Project and most of the related projects include infill development, which would revitalize the Wilshire Center/Koreatown Redevelopment Area. Ongoing revitalization efforts would help reduce the cumulative crime impacts in the Rampart Area. Therefore, cumulative impacts on police protection services would be less-than-significant.

MITIGATION MEASURES

To ensure that potentially significant project impacts to police protection services would be less than significant; the following mitigation measures would be implemented as part of the Proposed Project:

Code-Required Measures

(J.1-1) Prior to Project Approval, the Project Applicant shall submit plot plans to the Los Angeles Police Department’s Crime Prevention Section for review and comment. Security features recommended by the LAPD shall be implemented to the extent feasible.

(J.1-2) The Project Applicant shall file all building plans with the Central Area Commanding Officer. Plans shall include access routes, floor plans, and any other additional information that might facilitate prompt and efficient police response.

(J.1-3) The Project Applicant shall install alarms and or/locked doors on doorways providing public access to commercial facilities.

(J.1-4) The Project Applicant shall develop and implement a Security Plan in consultation with the LAPD, outlining the security services and features to be provided in conjunction with the Proposed Project. The plan shall be coordinated with the LAPD and a copy of said plan shall



be filed with the LAPD Central Bureau Commanding Officer. Said security plan may include some or all of the following components:

i. Provisions for an on-site private security force for the commercial and residential areas. Through individual lease agreements for the proposed retail/commercial uses and property management services for the residential uses, private on-site security services would provide a 24-hour presence. Security officers would be responsible for patrolling all common areas including the back service corridors and alleys, parking garages, and stairwells. All security officers will carry radios and patrol the grounds primarily by foot; however, bike patrol may be implemented in the parking garages and on the surrounding roadways.

ii. The parking garages shall be designed to cordon off residential and commercial serving parking areas to provide increased security for project residents. Both residential and commercial parking areas shall be fitted with emergency features such as closed circuit television (CCTV) or emergency call boxes that will provide a direct connection with the on-site security force or the LAPD 911 emergency response system.

iii. The proposed urban park shall be maintained by the Project Applicant and shall be open to the public during daylight hours only.

iv. Security lighting to incorporate the following:

1. Design of entryways, seating areas, lobbies, elevators, locker rooms, service areas, and parking areas with good illumination and minimum dead space to eliminate areas of concealment.

2. Full cut-off fixtures shall be installed which minimize glare from the light source and provide light downward and inward to structures to maximize visibility.

Project Mitigation Measures

(J.1-5) The Project shall erect temporary fencing around the Project Site during construction activities to secure the Project Site and discourage trespassers.

(J.1-6) The Project Applicant shall employ security guards to monitor the Project Site during construction to secure the site and deter any potential criminal activity.

(J.1-7) The Project Applicant shall implement an on-site security plan in consultation with the Los Angeles Police Department to provide a safe and secure environment within the proposed urban park area. The urban park shall be designed and constructed in a manner that



eliminates dead spaces and concealed areas to the maximum extent feasible. Low-level directional security lighting shall be provided to increase visibility for security personnel and passers by.

(J.1-8) In order to mitigate the potential temporary and short-term traffic impacts of any necessary lane and/or sidewalk closures during the construction period, the Project should, prior to construction, develop a Construction Traffic Control/Management Plan to be approved by LADOT, to minimize the effects of construction on vehicular and pedestrian circulation and assist in the orderly flow of vehicular and pedestrian circulation in the area of the Project. The Plan should include temporary roadway striping and signage for traffic flow as necessary, as well the identification and signage of alternative pedestrian routes in the immediate vicinity of the Project if necessary.

LEVEL OF SIGNIFICANCE AFTER MITIGATION

Project impacts on police protection service would be less than significant.


IV. ENVIRONMENTAL IMPACT ANALYSIS J. PUBLIC SERVICES 2. FIRE PROTECTION


Fire prevention, fire suppression, and life safety services are provided throughout the City of Los Angeles by the Los Angeles Fire Department (LAFD), as governed by the Fire Protection and Prevention Plan (Plan), an element of the City’s General Plan, as well as the Fire Code section of the Los Angeles Municipal Code (LAMC). The Plan and the Fire Code serve as guides to City Departments, government offices, developers, and the public for the construction, maintenance, and operation of fire protection facilities located within the City of Los Angeles. The LAFD has 3,562 uniformed personnel and 338 non-uniformed support staff. Their services include fire prevention, firefighting, emergency medical care, technical rescue, hazardous materials mitigation, disaster response, public education, and community service. A professionally trained staff of 1,045 firefighters (including 217 paramedic-trained personnel) is on duty at all times at 103 neighborhood fire stations located across the LAFD’s 470-square-mile jurisdiction.5

Fire Stations

The Proposed Project is located within the Wilshire area of the LAFD’s jurisdiction. As seen in Figure IV.J-2, the Project Site receives primary fire protection and paramedic service from three fire stations: Station 6, Station 11, and Station 13.

Fire Station No. 13 is located approximately 1.0 mile from the Project Site (at 1206 S. Vermont Avenue) and would have primary response duties to calls from the Proposed Project.6 Fire Station No. 13 is staffed with six members at all times and is prepared to respond to emergencies with both a single Fire Engine Company and a Paramedic Rescue Ambulance.

Fire Station No. 6, located at 326 N. Virgil Avenue, and Fire Station No. 11, located at 1819 West 7th Street, would also respond to calls from the Proposed Project. Fire Station No. 6 is located 1.2 miles from the Project Site and Fire Station No. 11 is located 1.1 miles from the Project Site. Fire Station No. 6 is equipped with a single Engine Company and a Paramedic Rescue Ambulance along with a staff of five at all times. Fire Station No. 6 also serves as Battalion 11 Headquarters. Fire Station No. 11 is equipped with an Engine Company, a Task Force Truck, and Paramedic Rescue Ambulance along with a staff of 12 at all times.

5 Los Angeles Fire Department, website: http://www.lafd.org/about.htm, (January 4, 2006).

6 Written Correspondence with Captain William N. Wells, Planning Section, Los Angeles Fire Department, 1-23-06.



Response Time

Response time relates directly to the physical linear travel distance (i.e., miles between a fire station and a site) and the Fire Department’s ability to successfully navigate the given accessways and adjunct circulation system. Roadway congestion and intersection level of service along the response route can affect the response distance when viewed in terms of travel time. It is estimated that the response time to the Project Site from Fire Station No. 13 would be 4.6 minutes, while the response time to the Project Site from Station No. 11 would be 4.9 minutes and from Station No. 6 would be 5.6 minutes. These response times meet the desired performance standards of the LAFD.7

Response Distance and Emergency Access

The City of Los Angeles Fire Code specifies the maximum response distances allowed between specific sites and engine and truck companies, based upon land use and fire flow requirements. Table IV.J-2 provides the maximum response distance for fire stations based on a project’s proposed land use. When response distances exceed these requirements, all structures must be equipped with automatic fire sprinkler systems and any other fire protection devices deemed necessary by the Fire Chief (e.g., fire signaling systems, fire extinguishers, smoke removal systems, etc.). Automatic fire sprinkler systems are also required for all high-rise structures within the City that exceed 75 feet in height. The Project Site is designated in the Wilshire Community Plan as a “Regional Commercial Center.”

Table IV.J-2

Maximum Response Distance (miles)

Land Use Engine Company Max. Response Distance (mi)

Truck Company Max. Response Distance (mi)

Neighborhood Land Uses • Low Density Residential/High

Density Residential/Neighborhood 1.5 2.0

Regional Land Uses • Industrial/Commercial 1.0 1.5

Commercial and Industrial Centers • High Density Commercial/High

Density Industrial 0.75 1.0

Source: City of Los Angeles Fire Code, Los Angeles Municipal Code (LAMC), Section 57.09.07.

7 Ibid.



Access to the Project Site for the purposes of fire suppression and emergency medical service (EMS)8 vehicles is currently provided via public roadways located directly adjacent to the Project Site, including Wilshire Boulevard, Shatto Place, and Vermont Avenue. As discussed in Section IV.K (Traffic/Transportation/Parking), studied intersections in proximity of the Project Site currently operate at LOS C or better during the AM peak hour, with the exception of the intersection of 6th Street & Vermont Avenue, which operates at LOS E. During the PM peak hour, the studied intersections currently operate at LOS D or better.

Fire Flow

The adequacy of fire protection for a given area is based on required fire flow; response time from existing fire stations, and the LAFD’s judgment for assessing the needs in a given area. The required fire flow is closely related to the type and size of the land use. The quantity of water necessary for fire protection varies with the type of development, life hazard, occupancy, and the degree of fire hazard. City-established fire flow requirements, which are established in the Fire Code, vary from 2,000 gallons per minute (gpm) in low-density residential areas, to 12,000 gpm in high-density commercial or industrial areas. In any instance, a minimum residual water pressure of 20 pounds per square inch (PSI) is to remain in the water system while the required gpm is flowing.9 The lowest static water pressure in the mains surrounding the Project Site ranges from 46 to 57 psi.10

The Fire Code also establishes requirements for fire hydrant types and spacing by land use type. Required distances between hydrants on roads and fire lanes range from 300 feet for high-density residential, industrial, and commercial uses to 600 feet for low-density residential uses. Required types of fire hydrants include 2 ½-inch by 4-inch double hydrants and 4-inch by 4-inch double hydrants. Furthermore, pursuant to Section 57.09.07 of the LAMC, the maximum response distance between residential land uses and a LAFD fire station that houses an Engine or Truck Company is 1.5 miles. When response distances exceed these recommendations, all structures must be equipped with automatic fire sprinkler systems and any other fire protection devices deemed necessary by the Fire Chief (e.g., fire signaling systems, fire extinguishers, smoke removal systems, etc.).

Water for fire flows for the area surrounding the Project Site is provided by the City of Los Angeles Department of Water and Power (LADWP). All water mains and lines that are designed and sized according to LADWP standards take into account fire flow and pressure requirements. Refer to Section

8 EMS includes both EMT units and paramedic units, the latter of which are specially trained and equipped to

handle severe medical emergencies.

9 Fire Code of the Los Angeles Municipal Code, Section 57.09.06.

10 Written Correspondence with Charles C. Holloway, Supervisor of Environmental Assessment, City of Los Angeles Department of Water and Power, 1-17-06.



IV.I.1. (Water Supply) for a complete discussion of water service infrastructure in the Proposed Project area.

ENVIRONMENTAL IMPACT


In accordance with Appendix G of the State CEQA Guidelines, a significant impact would occur if a project were to result in the following:

(a) Substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives of the fire department.

Similarly, as set forth in the City of Los Angeles L.A. CEQA Thresholds Guide, a project would normally have a significant impact on fire protection if:

(a) The project requires the addition of a new fire station or the expansion, consolidation or relocation of an existing facility to maintain service.

Project Impacts

Construction

Removal of the existing onsite buildings and construction of the Proposed Project would increase the potential for accidental onsite fires from such sources as the operation of mechanical equipment, the use of flammable construction materials, and the careless disposal of cigarettes. In most cases, the implementation of “good housekeeping” procedures by the construction contractors and the work crews would minimize these hazards. Good housekeeping procedures that would be implemented during demolition and construction of the Proposed Project include: the maintenance of mechanical equipment in good operating condition; careful storage of flammable materials in appropriate containers; and the immediate and complete cleanup of spills of flammable materials when they occur (see “Mitigation Measures” subheading below for a complete list of requirements).

Construction activities also have the potential to affect fire protection services, such as emergency vehicle response times, by adding construction traffic to the street network and by partial lane closures during street improvements and utility installations. These impacts, while potentially adverse, are considered to be less than significant for the following reasons:

(1) Construction impacts are temporary in nature and do not cause lasting effects; and



(2) Partial lane closures would not greatly affect emergency vehicles, the drivers of which normally have a variety of options for avoiding traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Additionally, if there are partial closures to streets surrounding the project site, flagmen would be used to facilitate the traffic flow until construction is complete.

Project construction would not be expected to tax fire fighting and emergency services to the extent that there would be a need for new or expanded fire facilities, in order to maintain acceptable service ratios, response times, or other performance objectives of the LAFD. Therefore, construction-related impacts to fire protection services would be less than significant.

Operation

Implementation of the Proposed Project would increase the need for fire protection and emergency medical services in the Wilshire Center area. The following discussion analyzes the major criteria for determining the Proposed Project’s impacts on fire protection services.

Response Distance and Emergency Access

As discussed above, the Proposed Project is designated in the Wilshire Community Plan as a “Regional Commercial Center.” Since the nearest engine company is approximately 1.0 miles from the Project Site, it would be .16 miles beyond the required response distance for structures not fitted with sprinkler systems. However, the nearest truck company is located approximately 1 mile from the Project Site, just within the maximum response distance. Nevertheless, due to the fact that the Proposed Project includes the development of two-high rise residential towers, automatic fire suppression sprinklers would be required by the Fire Code.

Emergency vehicle access to the Proposed Project Site would continue to be provided from local public roadways. Major roadways adjacent to the Project Site (i.e., Wilshire Boulevard, Shatto Place, and Vermont Avenue) would continue to provide public and emergency access. The LAFD considers intersections with an LOS of E or F to inhibit emergency response. The Proposed Project would not cause any intersections in the Proposed Project vicinity to be significantly impacted (see Section IV.K (Traffic/Transportation/Parking). Therefore, the Proposed Project would not inhibit emergency vehicle access, and impacts related to emergency access would be less than significant.

Fire Flow

Water service for fire fighting purposes would continue to be provided by the City of Los Angeles Department of Water and Power (LADWP). The existing water system would serve both domestic and firewater needs. The Water Operations Division of the LADWP will perform a flow study at the time of permit review in order to ascertain whether further water system or site-specific improvements are necessary. As discussed above, the adequacy of fire protection for a given area is based on required fire flow; response time from existing fire stations, and the LAFD’s judgment for assessing the needs in a



given area. The required fire flow is closely related to the type and size of the land use. The quantity of water necessary for fire protection varies with the type of development, life hazard, occupancy, and the degree of fire hazard. City-established fire flow requirements, which are established in the Fire Code, vary from 2,000 gallons per minute (gpm) in low-density residential areas, to 12,000 gpm in high-density commercial or industrial areas. In any instance, a minimum residual water pressure of 20 pounds per square inch (PSI) is to remain in the water system while the required gpm is flowing.11 Since the lowest static water pressure in the mains surrounding the Project Site ranges from 46 to 57 psi, there would be adequate water in the mains even if the highest (12,000 gpm) requirement were imposed by the LAFD.12 Additional hydrants would be installed per Fire Code requirements based upon the specific land uses to be introduced (i.e., multi-family residential, commercial, and parking uses). As such, impacts related to fire flow are anticipated to be less than significant.

CUMULATIVE IMPACTS

The Proposed Project, in combination with the construction and operation of the related projects, would increase the demand for fire protection services in the Proposed Project area. Specifically, there would be increased demands for additional LAFD staffing, equipment, and facilities over time. This need would be funded via existing mechanisms (i.e., property taxes, government funding), to which the Proposed Project and related projects would contribute.

Similar to the Proposed Project, each of the related projects would be individually subject to LAFD review and would be required to comply with all applicable construction-related and operational fire safety requirements of the LAFD and the City of Los Angeles in order to adequately mitigate fire protection impacts. For example, all related projects would be required to assure that LAFD access remains clear during all demolition and construction activities. In addition, for any residential related project more than 1.5 miles from the nearest LAFD Engine or Truck Company, or for any commercial related project more than one mile from an LAFD Engine Company or 1.5 miles from an LAFD Truck Company, LAMC Section 57.09.07 would require the installation of automatic fire sprinkler systems, in order to compensate for the additional response distance. Therefore, the Proposed Project would not have a cumulatively considerable incremental effect upon fire protection services and the Proposed Project’s cumulative impact would be less than significant.

11 Fire Code of the Los Angeles Municipal Code, Section 57.09.06.

12 Written Correspondence with Charles C. Holloway, Supervisor of Environmental Assessment, City of Los Angeles Department of Water and Power, 1-17-06.



MITIGATION MEASURES

Code Required Measures

(J.2-1) All requirements of LAMC Section 57.09.07, pertaining to the installation of automatic sprinkler systems in high rise structures shall be followed.

Project Mitigation Measures

Although significant impacts were not identified in the above analysis, the following mitigation measures are included to highlight the project features that allow for this conclusion, as well as further ensure that project impacts to fire protection services would be less than significant:

(J.2-2) During demolition, the Fire Department access shall remain clear and unobstructed.

(J.2-3) Fire lane width shall not be less than 20 feet. When a fire lane must accommodate the operation of Fire Department aerial ladder apparatus or where fire hydrants are installed, those portions shall not be less than 28 feet in width.

(J.2-4) The width of private roadways for general access use and fire lanes shall not be less than 20 feet clear to the sky.

(J.2-5) Fire lanes, where required and dead ending streets, shall terminate in a cul-de-sac or other approved turning area. No dead ending street or fire lane shall be greater than 700 feet in length or secondary access shall be required.

(J.2-6) Where access for a given development requires accommodation of Fire Department apparatus, minimum outside radius of the paved surface shall be 35 feet. An additional six feet of clear space must be maintained beyond the outside radius to a vertical point 13 feet 6 inches above the paved surface of the roadway.

(J.2-7) No building or portion of a building shall be constructed more than 300 feet from an approved fire hydrant. Distance shall be computed along the path of travel, except for dwelling units, where the travel distance shall be computed to the front door of the unit.

(J.2-8) No building or portion of a building shall be constructed more than 150 feet from the edge of a roadway of an improved street, access road, or designated fire lane.

(J.2-9) Access for Fire Department apparatus and personnel to and into all structures shall be required.

(J.2-10) At areas designated by the Fire Department, the structural system shall be demonstrated, by engineering calculations, as capable of sustaining Fire Department vehicle loads. The design



methodology shall conform to the latest edition of the State of California Department of Transportation Bridge Design Specifications Manual.

• Basic design requirement (within the public right-of-way and for private roads, alleys, streets, etc.):

AASHTO HS20-44 with the Impact Increment = 30%

• Special case for areas which are outside the public right-of-way, not a road and restricted to passenger vehicles only:

AASHTO HS15-44 with Impact Increment = 30%

(J.2-11) The proposed project shall comply with all applicable State and local codes and ordinances, and guidelines found in the Fire Protection and Fire Prevention Plan, as well as the Safety Plan, both of which are elements of the General Plan for the City of Los Angeles.


Project impacts on fire protection service would be less than significant.


ENVIRONMENTAL IMPACT ANALYSIS J. PUBLIC SERVICES

3. SCHOOL SERVICES


Public schools in the City of Los Angeles are under the jurisdiction of the Los Angeles Unified School District (LAUSD). The LAUSD is divided into eight local districts. The Proposed Project area is generally located within Local District 4, which encompasses most of the Mid-City area. The LAUSD schools that currently serve the Proposed Project Site include: Hoover Elementary School, located at 2726 Francis Avenue; Berendo Middle School, located at 1157 South Berendo Street; and Belmont Senior High School, located at 1575 West 2nd Street (see Figure IV.J-3, School and Library Locations, for the locations of these schools)13. In addition, according to LAUSD, the Central LA Area New Middle School #3 is proposed at the southeast corner of Vermont Avenue and 6th Street, approximately one block north of the Project Site. This school is anticipated to provide approximately 810 seats upon buildout in Spring 2008.14 The 2004-2005 enrollments, enrollment capacities, and number of students above/below capacity for each of these schools are listed in Table IV.J-3, below.

Table IV.J-3 School Capacity and Enrollment

School 2004-2005

Enrollment a Enrollment

Capacity

(-)Under/ (+)Over Capacity

Hoover Elementary 1655 1714 -59

Berendo Middle 3248 3216 +32 Central LA Area New Middle School #3 n/a 810 (in 2008) n/a

Belmont Senior High 4941 4915 +26 a Written Communication with Glenn Striegler, Environmental Assessment Coordinator, Los Angeles Unified School District Department of Environmental Health and Safety, 1-23-06.

13 Los Angeles Unified School District, Find a School website: http://search.lausd.k12.ca.us/cgi-

bin/fccgi.exe?w3exec=schfinder0, December 21, 2005.

14 Los Angeles Unified School District, January 2005 Strategic Execution Plan: Exhibit D, website: http://www.laschools.org/sep/sep-exhibit-d-project-list-by-district-opt.pdf, July 20, 2005.



Figure IV.J-3, School and Library Locations



Open Enrollment Policy

The open enrollment policy is a State-mandated policy that enables students anywhere in the LAUSD to apply to any regular, grade-appropriate LAUSD school with designated “open enrollment” seats. The number of open enrollment seats is determined annually. Each individual school is assessed based on the principal’s knowledge of new housing and other demographic trends in the attendance area. Open enrollment seats are granted through an application process that is completed before the school year begins. Students living in a particular school’s attendance area are not displaced by a student requesting an open enrollment transfer to that school.15

School Facilities Fees

California Education Code Section 17620(a)(1) states that the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities. The LAUSD School Facilities Fee Plan has been prepared to support the school district’s levy of the fees authorized by Section 17620 of the California Education Code.16

The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required to pay to mitigate a project’s impacts on school facilities. The maximum fees authorized under SB 50 apply to zone changes, general plan amendments, zoning permits and subdivisions. The provisions of SB 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other State or local laws (Government Code Section 65996).

The California Education Code Section 17620(a)(1) states that the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities. The LAUSD School Facilities Needs Analysis has been prepared to support the school district’s levy of the fees authorized by Section 17620 of the California Education Code.17 Per section 65995.5-7 of the Government Code, Level 2 residential developer fees have been imposed at a rate of $3.60 per square foot of new residential construction, $0.34 per square foot of commercial construction, and $0.09 per square foot of parking structure construction within the boundaries of the LAUSD.18

15 News Release, Los Angeles Unified School District, Office of Communications, April 17, 2000.

16 Los Angeles Unified School District, School Facilities Fee Plan, March 2, 2002.

17 Los Angeles Unified School District, School Facilities Needs Analysis, September 9, 2002 (fees updated September 2005).

18 Ibid.



Payment of these fees would be mandatory, and would reduce any impact upon school services generated by the Proposed Project.

ENVIRONMENTAL IMPACTS


In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant effect on the environment if it were to:

(a) Result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives of the school district.


(a) The population increase resulting from the proposed project, based on the increase in residential units or square footage of non-residential floor area;

(b) The demand for school services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvement to LAUSD services (i.e., facilities, equipment and personnel) and the project’s proportional contribution to the demand;

(c) Whether (and the degree to which) accommodation of the increased demand would require construction of new facilities, a major reorganization of students or classrooms, major revisions to the school calendar (such as year-round sessions), or other actions which would create a temporary or permanent impact on the school(s); and

(d) Whether the project includes features that would reduce the demand for school services (e.g., onsite school facilities or direct support to LAUSD).

Project Impacts

Implementation of the Proposed Project would involve the development of 464 residential condominium units and 41,000 square feet of commercial space. LAUSD generation rates indicate that approximately one elementary student is generated by the existing 42,000 square feet of commercial development currently in use on the Project Site. As shown in Table IV.J-4, Estimated Student Generation by Proposed Project, on page IV.J-22, the Proposed Project would result in the net generation of 27 elementary students, 14 middle school students, and 14 high school students. Thus, the Project’s total net generation of LAUSD students is 55 students.



Table IV.J-4 Estimated Student Generation by Proposed Project

Land Use Size Elementary

School Students Middle

School Students High

School Students Total Existing: Commercial 42,000 sf 1 0 0 1 Proposed: Condominiumsa 464 units 27 14 14 55 Retail and Restaurantb 41,000 sf 1 0 0 1

Proposed Net Total 27 14 14 55 a Student generation rates are as follows for single family attached (condominium) uses: 0.0573 elementary, 0.0289 middle and 0.0289 high school students per dwelling unit. Los Angeles Unified School District, School Facilities Needs Analysis, September 2005). b Student generation rates are as follows for retail/service uses: .0149 elementary, .0069 middle and .0067 high school students per 1,000 square feet. Los Angeles Unified School District, Commercial/Industrial Development School Fee Justification Study, September 2002. Source: Christopher A. Joseph & Associates, February 2006.

While it is likely that some of the students generated by the Proposed Project would already reside in areas served by LAUSD and would already be enrolled in LAUSD schools, for a conservative analysis it is assumed that all students generated by the Proposed Project would be new to LAUSD. This analysis is also conservative in that the majority of condominiums would be 1-bedrooms and therefore less likely to be occupied by families with school age children. In addition, according to LAUSD, the Central LA Area New Middle School #3 is proposed at the southeast corner of Vermont Avenue and 6th Street, approximately one block north of the Project Site. This school is anticipated to provide approximately 810 seats upon buildout in Spring 2008.19 As the Proposed Project is also expected to be completed in 2008, it can be assumed for analytical purposes that the project-generated middle school students would be accommodated by the existing Berendo Middle School and the proposed Central LA Area New Middle School #3. Table IV.J-5, Proposed Project Impact on LAUSD Schools, on page IV.J-24, shows the Proposed Project’s expected impacts on LAUSD schools.

19 Los Angeles Unified School District, January 2005 Strategic Execution Plan: Exhibit D, website:

http://www.laschools.org/sep/sep-exhibit-d-project-list-by-district-opt.pdf, July 20, 2005.



Table IV.J-5 Proposed Project Impacts on LAUSD Schools

School Current (-)Under / (+) Over Capacity Status a

Net Project Generated Students

With Project (-)Under / (+) Over Capacity

Hoover Elementary -59 27 -32 Central LA Area New Middle School #3 n/a 7 n/a

Belmont Senior High +26 14 +40 a Written Communication with Glenn Striegler, Environmental Assessment Coordinator, Los Angeles Unified School District Department of Environmental Health and Safety, 1-23-06.

After implementation of the Proposed Project, one school serving the Project Site would be over capacity. Belmont Senior High School would be over capacity by 40 students. Hoover Elementary School would remain under capacity by 32 students. It is likely that the Central LA area New Middle School No. 3 will relieve much of the Berendo Middle School crowding by the time of the Proposed Project’s buildout in 2008. Furthermore, the LAUSD has planned seven additional schools in the Proposed Project vicinity to relieve overcrowding in the near future including four new high schools, an additional middle school and an additional elementary school.20 Therefore, the students generated by the Proposed Project would not be expected to require the construction of new facilities, a major reorganization of students or classrooms, major revisions to the school calendar (such as year-round sessions), or other actions which would create a temporary or permanent impact on the school(s).

Furthermore, LAUSD operates a number of charter schools in the Local District serving the Proposed Project. Charter schools serve 33,000 students in the Los Angeles Unified School District. There is no tuition at charter schools and enrollment is open and ultimately determined by lottery.21 There are 19 independent charter schools operating in Local District 4.22 It is possible that a portion of the students generated by the Proposed Project would elect to attend these neighboring charter schools.

Additionally, the implementation of the mitigation measure identified below, requiring the mandatory payment of school fees in conformance with SB 50, would address the Proposed Project’s impact on schools by providing funds for future LAUSD expansion. Furthermore, in accordance with SB 50,

20 Written Communication with Glenn Striegler, Environmental Assessment Coordinator, Los Angeles Unified

School District Department of Environmental Health and Safety, 1-23-06.

21 Los Angeles Unified School District, Charter School Fact Sheet, website: http://www.lausd.k12.ca.us/newLAUSDnet/pdf/FACTSHEET_Charter_Schools.pdf

22 Los Angeles Unified School District, List of Charter Schools, website: http://notebook.lausd.net/pls/ptl/docs/PAGE/CA_LAUSD/FLDR_ORGANIZATIONS/FLDR_INSTRUCTIONAL_SVCS/CHARTER_SCHOOLS/ROSTER/CHARTER%20SCHOOLS%20ROSTER%202005-06.PDF



payment of school fees is deemed to provide full and complete mitigation to impacts on schools pursuant CEQA. Therefore, project impacts on schools would therefore be less than significant.

CUMULATIVE IMPACTS

The Proposed Project, in combination with the related projects, is expected to result in a cumulative increase in the demand for school services. There are a total of 49 related projects, all within the jurisdiction of LAUSD. It is important to note that of the 49 related projects, eight involve the development of either public or private schools.23 Together, the related projects would have the potential to generate students that would attend the same schools as the Proposed Project. The related projects would generate approximately 673 elementary students, 317 middle school students and 310 high school students. Of the 1,355 students generated by the Proposed Project and related projects, the Proposed Project represents approximately 4.0 percent (see Table IV.J-6, below).

Table IV.J-6 Estimated Cumulative Student Generation

Related Projects’ Land Uses Size

Elementary School Students

Middle School Students

High School Students Total

Commercial, Retail, Office, Church, Clinic & Restauranta

1,340,546 sf 23 11 10 44

Residential (Apartments & Lofts)b

2,338 du 498 229 223 950

Residential (Condominiums) c 2,658 du 152 77 77 306

Cumulative Projects Total 673 317 310 1,300 Proposed Project Net Total 55

Cumulative Plus Project Total 1,355 Proposed Project Percent of Total 4.0%

a Student generation rates are as follows for retail/service uses: .0149 elementary, .0069 middle and .0067 high school students per 1,000 square feet. Los Angeles Unified School District, Commercial/Industrial Development School Fee Justification Study, September 2002. bStudent generation rates are as follows for multifamily units (apartments):0.02131 elementary, 0.0979 middle and 0.0953 high school students per dwelling unit. Los Angeles Unified School District, School Facilities Needs Analysis, September 2005). Note: Lofts are calculated as apartments. c Student generation rates are as follows for single family attached (condominium) uses: 0.0573 elementary, 0.0289 middle and 0.0289 high school students per dwelling unit. Los Angeles Unified School District, School Facilities Needs Analysis, September 2005). Source: Christopher A. Joseph & Associates, December 2005.

23 See Section III (Environmental Setting) for a list of Related Projects.



Similar to the Proposed Project, it is likely that some of the students generated by the related projects would already reside in areas served by the LAUSD and would already be enrolled in LAUSD schools. Furthermore, as with the Proposed Project, the applicants of the related commercial and residential projects would be expected to pay required developer school fees to the LAUSD (pursuant to SB 50) to reduce any impacts they may have on school services. The provisions of SB 50, discussed above, provide full and complete mitigation of school facilities impacts. The payment of these fees by the Proposed Project and the related projects would be mandatory, and would reduce the cumulative impact upon school services to a less-than-significant level.

MITIGATION MEASURE

The potentially significant impact the Proposed Project would have on LAUSD schools would be reduced to a less-than-significant impact through the implementation of the identified mitigation measure.

Code Required Measure

(J.3-1) The project applicant shall pay all applicable school fees to the Los Angeles Unified School District to offset the impact of additional student enrollment at schools serving the project area.


The Proposed Project’s impact to schools would be less than significant.


IV. ENVIRONMENTAL IMPACT ANALYSIS J. PUBLIC SERVICES

4. RECREATION AND PARKS


The City of Los Angeles Department of Recreation and Parks (LADRP) manages all municipally owned and operated recreation and park facilities within the City. The LADRP operates and maintains approximately 15,600 acres of parkland with 387 neighborhood and regional parks, seven lakes, 176 recreation centers, 372 children’s play areas, 13 golf courses, 387 tennis courts, eight dog parks, 58 swimming pools, and seven skate parks, including those in the project vicinity.24

The Public Recreation Plan, a portion of the Public Facilities and Service Systems Element of the City’s General Plan, provides standards for the provision of recreational facilities throughout the City and includes local recreation standards. The standard ratio of neighborhood and community parks to population is four acres per 1,000 people. The Public Recreation Plan categorizes parks into three groups: neighborhood, community, and regional. Ideally, neighborhood parks are five to 10 acres in size, have a service radius of approximately one-half mile, and are pedestrian-accessible without crossing a major arterial street or highway/freeway. According to the Public Recreation Plan, community parks are ideally 15 to 20 acres, have a service radius of two miles, and are easily accessible to the area served. Regional parks in the City are ideally greater than 50 acres, provide specialized recreational facilities and/or attractions, and have a service radius encompassing the entire Los Angeles region.

Within the Wilshire Community Plan area, there are approximately 191 acres of designated open space land, including approximately 100 acres of private golf course land (Wilshire Country Club).25 There is one regional park, nine community parks and recreation centers, and ten neighborhood parks and recreation centers. Table IV.J-7, Parks and Recreational Facilities Serving the Project Site, on page IV.J-28, includes those recreational facilities and parks that are located within an approximately two-mile radius of the Project Site (see also Figure IV.J-4, Park and Recreation Center Locations, for park locations). In 2004, the Wilshire Community Plan Area was estimated to have a population of approximately 310,225 persons.26 Therefore, the Wilshire Community Plan area currently provides approximately seven percent of the 1,240 acres of public parkland desired under the citywide standard of

24 Los Angeles Department of Recreation and Parks, Department, website: http://www.laparks.org/dept.htm,

December 19, 2005.

25 City of Los Angeles, Wilshire Community Plan, September 19, 2001, page III-13.

26 City of Los Angeles Department of City Planning, Statistical Information: Population & Housing Profile: Community Plan Area: Wilshire, website: http://cityplanning.lacity.org, December 19, 2005.



4 acres per 1,000 people.27 The public parks and recreational facilities in both the neighborhood of the Proposed Project and the City of Los Angeles are well below federal, State, and City standards.28

Table IV.J-7 Parks and Recreational Facilities Serving the Project Site

Facility Location L.A. High Memorial Park 4625 W. Olympic Boulevard MacArthur Park 2230 W. 6th Street Pico Union Park 1827 S. Hoover Street Robert L. Burns Park 4900 Beverly Boulevard Harold A. Henry Park 890 S. Lucerne Avenue Shatto Recreation Center 3191 W.4th Street Aardmore Recreation Center 3250 San Marino Street Bellevue Recreation Center 826 Lucile Avenue Normandie Recreation Center 1550 S. Normandie Avenue Lemon Grove Recreation Center 4959 Lemon Grove Queen Anne Recreation Center 1240 West Boulevard Source: City of Los Angeles Department of Parks and Recreation, Center Locator, website: http://gis.lacity.org/recandpark/recandpark.htm, January 5, 2006.

Pursuant to Chapter II, Article 1.10 Section 10.21.3 of the Los Angeles Municipal Code (LAMC), the City of Los Angeles imposes a mandatory dwelling unit construction excise tax to reduce impacts upon parks and recreational facilities. The tax collected pursuant to this ordinance is required to be placed in a “Park and Recreational Sites and Facilities Fund,” to be used exclusively for the acquisition and development of park and recreational sites and facilities. Any future residential development on the Proposed Project Site, including the Proposed Project, would be subject to this fee.

Furthermore, since the Proposed Project includes “for sale” units, the applicable provisions of Section 17.12 of the LAMC would also apply, requiring the project applicant to pay all applicable in lieu fees (Quimby fees) to the City of Los Angeles for the construction of condominium uses. To alleviate the demand on City parks and recreational facilities, the City requires developers of subdivisions to pay a public open space fee, as permitted under the Quimby Act. The Quimby Act allows California municipalities to require developers of new residential subdivisions to dedicate parkland or to pay fees in lieu of parkland dedication. In subdivisions containing more than 50 dwelling units, the City allows developers to dedicate parkland in lieu of paying fees (LAMC Section 17.12).

27 310,225 persons x (4 acres / 1,000 persons) = 1240 acres; 91acres / 1240 acres = 7%

28 City of Los Angeles, Wilshire Community Plan, September 19, 2001, page III-13.



Figure IV.J-4, Park and Recreation Center Locations



The Quimby fees are used to acquire necessary land and/or develop new neighborhood and community parks or recreation facilities, which would reasonably serve each residential project. It should be noted that although both fees would apply to the Proposed Project, each has a provision to allow a credit where the other fee has been paid, in order to avoid a doubling of payment.



In accordance with Appendix G of the State CEQA Guidelines, a significant impact would occur if a project would:

(a) Result in substantial adverse physical impacts associated with the provision of new or physically altered parks, or need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives of the parks department;

(b) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or

(c) Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.


(a) The net population increase resulting from the proposed project;

(b) The demand for recreation and park services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvements to recreation and park services (i.e., renovation, expansion, or addition) and the project’s proportional contribution to the demand; and

(c) Whether the project includes features that would reduce the demand for recreation and park services (e.g., onsite recreation facilities, land dedication or direct financial support to the Department of Recreation and Parks).

Project Impacts

Development of the Proposed Project is anticipated to result in an increase of 1,137 permanent residents.29 Employees of the proposed restaurant/commercial uses are less likely to patronize parks during working

29 See Section IV.H (Population and Housing).



hours, and are more likely to use parks near their own homes during non-work hours. Based on the City General Plan ratio, the Proposed Project would generate a need for 4.55 (1,137 x 4/1,000) acres of public parkland in the project area.

As stated above, the City requires developers of subdivisions to dedicate parkland or to pay fees in lieu of parkland dedication. If and to the extent the proposed onsite recreational and outdoor facilities do not fully satisfy the requirements of the Quimby Act, the project applicant would be required to pay Quimby fees to the City, to satisfy the balance of its obligations under the Quimby Act. The provision of the onsite recreational and outdoor facilities, together with the payment of any required Quimby fees, would reduce the Proposed Project’s impact upon parks and recreational facilities to a less-than-significant level.

If the Quimby fees are less than the fees required by Section 21.10.3 (Dwelling Unit Construction Tax) of the LAMC, then the Proposed Project would be required to pay fees pursuant to Section 21.10.3 instead.

Although the Proposed Project impacts would be mitigated through payment of the required fees, it is important to note that the Proposed Project would include an approximate 10,190 sf urban park located at 665 S. Shatto Place. This space would be maintained by the developer and condominium Homeowner associations and would be opened to the public during the daylight hours. Additionally, the Proposed Project would integrate a landscaped plaza and swimming pool on the podium level and one recreation room in each residential tower. The potential environmental impacts associated with the construction of these onsite facilities are addressed as part of the Proposed Project throughout this Draft EIR. Because portions of the proposed on-site recreational features would be open to the public, the Proposed Project would help alleviate the City’s existing substandard provision of parkland and recreational facilities. The on-site recreational amenities would help reduce Project-related impacts by providing on-site facilities that future residents may use in lieu of public parks.

CUMULATIVE IMPACTS

The Proposed Project in combination with the related projects would be expected to increase the cumulative demand for parks and recreational facilities in the City of Los Angeles. Of the 49 related projects, 25 projects would generate residents and, therefore, would combine with the Proposed Project to create a cumulative demand for parkland in the Wilshire community.30 In general, the other 24 related projects would generate employees and/or students who would not be expected to use local park or recreational facilities to a great extent, as they typically would not have long periods of time during their work or school days to visit parks and recreational facilities and would be more likely to patronize park and recreational facilities near their homes during non-work or non-school hours.

As stated previously, the current parkland-to-residents ratio is below the standard set by the City. The 25 related projects that include residential uses would generate a total of 12,240 residents (including

30 See Section III (Environmental Setting) for a list of Related Projects.



apartment, loft, and condominium residents). These residents, combined with the 1,137 net residents generated by the Proposed Project, would generate a need for 53.5 acres of public parkland.31 The development of the Proposed Project in combination with the 25 residential related projects would further decrease the City of Los Angeles’ parkland to population ratio, which would result in a potentially significant impact.

Although the Proposed Project would constitute approximately eight percent of the cumulative demand, the Proposed Project would provide a degree of onsite open space plus maintenance and recreational opportunities. Therefore, the Proposed Project’s incremental contribution would be less than considerable. Furthermore, similar to the Proposed Project, the related project’s that include residential units would be required to pay the applicable Quimby fees or other applicable parks and recreation fees, and/or would incorporate park and recreational facilities on-site. With the mandatory payment of the Quimby or other applicable fees by the residential related projects, cumulative parks and recreation impacts would be reduced. Therefore, the Proposed Project would not have a cumulatively considerable incremental effect on parks and recreational facilities, and the associated cumulative impact would be less than significant.

MITIGATION MEASURES

Code Required Measures

The following code required measures would be required as part of the project approval process:

(J.4-1) Pursuant to Section 17.12 of the Los Angeles Municipal Code, the project Applicant shall pay all applicable Quimby fees to the City of Los Angeles for the construction of condominium and apartment uses.

(J.4-2) Pursuant to Section 21.10.3 of the LAMC, the project Applicant shall pay all applicable dwelling unit construction taxes.


Project impacts to parks and recreational facilities would be less than significant.

31 (12,240 persons + 1,137 persons)(4 acres/1,000 persons) = 53.5 acres


IV. ENVIRONMENTAL IMPACT ANALYSIS J. PUBLIC SERVICES

5. LIBRARIES


The City of Los Angeles Public Library (LAPL) provides library services throughout the City of Los Angeles. City library policy is guided by the Public Libraries Plan, an element of the City of Los Angeles General Plan. The Public Libraries Plan guides the construction, maintenance, and operation of public libraries and specifies standards in defining geographic service area and facility size.

The LAPL Branch Facilities Plan, adopted by the Board of Library Commissioners in August 1988 (revised in February 1998), contains the required facilities expansion needs of the City Public Library system. According to the current LAPL Branch Facilities Plan, service criteria are based on floor area required to serve varying amounts of residential population. Current LAPL branch building size standards are presented below in Table IV.J-8, below.

Table IV.J-8 City of Los Angeles Public Library Branch Building Size Standards

Population Served Size of Facility 50,001 – 100,000 12,500 sf 35,001 – 50,000 10,500 sf 25,001 – 35,000 9,000 sf Under 25,000 Special Size

Notes: sf = square feet Source: Los Angeles Public Library Branch Facilities Plan, adopted 1988, revised 1998.

The State of California also has standards that apply to libraries. The State of California states that 0.5 square feet of library facility per capita should be provided.32 In addition, the State of California standard for library volumes per capita is two per person.

Within the City of Los Angeles, the LAPL provides library services at the Central Library, seven regional branch libraries, 56 community branches and two bookmobile units, consisting of a total of five individual bookmobiles. The LAPL collection is comprised of approximately 6.5 million books and other written and electronic materials.

32 City of Los Angeles, Los Angeles Citywide General Plan Framework Draft Environmental Impact Report,

Pages 2.13.1 & 2.13.



According to the Citywide General Plan Framework Draft EIR, libraries in the City of Los Angeles have a service area of two miles.33 There are currently three libraries operating within a two-mile radius of the Project Site. Residents of the project area can utilize the following adjoining branch libraries (see Figure IV.J-3, School and Library Locations, on page IV.J-20, for the locations of these facilities):

• Felipe De Neve Library at 2820 West 6th Street.

• Pio Pico- Koreatown Library at 694 South Oxford Street

• Pico Union Library at 1030 South Alvarado Street

The Felipe De Neve Branch is located approximately .75 miles east of the Project Site, the Pio Pico- Koreatown Branch is located approximately 1.0 mile west of the Project Site and the Pico Union Branch is located approximately 1.5 miles southeast of the Project Site. As the closest of the libraries to the Project Site, the Felipe de Neve library would likely be the primary library serving the Proposed Project. Table IV.J-9, below, indicates the details of the Felipe de Neve library.

Table IV.J-9

Felipe de Neve Library Statistics

Library Size Staff

Positions Total Library Service Population (persons)

Felipe De Neve Brancha 9,273 sf 11 98,100 Written Correspondence with Rona Berns, LAPL Library Facilities Division, 1-23-06. Source (table) Christopher A. Joseph & Associates, 2006.

In November 1998, 73 percent of Los Angeles voters passed Proposition DD, a Library Bond Issue to renovate and construct 32 branch libraries. The Pico-Union Branch Library was funded through this bond, and opened to the community in May of 2004.34 The Felipe de Neve library also received a renovation and an expansion in 1998.35 The Pio Pico-Koreatown branch is one of two LAPL libraries chosen to share a $105,000 Microsoft cash grant in order to modernize its electronic services.36 Regular funding for the

33 City of Los Angeles, Los Angeles Citywide General Plan Framework Draft Environmental Impact Report,

Figure L-1, Page 2.13-8, January 1995.

34 Los Angeles Public Library, 1998 Library Bond Program Annual Report, Page 18, July 2005. Website: http://www.lapl.org/about/BondAnnRept2005.pdf, December 23, 2005.

35 Written Correspondence with Rona Berns, LAPL Library Facilities Division, 1-23-06.

36 Los Angeles Public Library, Branch libraries, website: www.lapl.org/branches, 1-26-06.



operation of the LAPL system comes from the General Fund. The amount received by the LAPL fluctuates according to the priorities of the City.37



In accordance with Appendix G of the State CEQA Guidelines, a significant impact would occur if a project were to:

(a) Result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities, or need for new or physically altered library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for library services.


(a) The net population increase resulting from the proposed project;

(b) The demand for library services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvements to library services (renovation, expansion, addition or relocation) and the project’s proportional contribution to the demand; and

(c) Whether the project includes features that would reduce the demand for library services (e.g., on-site library facilities or direct support to the LAPL).

Project Impacts

Development of the Proposed Project would increase demand for library services by increasing the permanent residential population in the area by approximately 1,137 persons (see Section IV.H, Population and Housing). In general, employees of commercial sites are not likely to patronize libraries during working hours, as they are more likely to use libraries near their homes during non-work hours. Therefore, based on State of California standards, the Proposed Project would generate a need for approximately 569 square feet (1,137 x 0.5) of library space and 2,274 (1,137 x 2) volumes of permanent collection.

As discussed above, the nearest library to the Project Site is the Felipe de Neve branch library, which serves a population of approximately 98,100 and has a total square footage of 9,273 sf. This is below the desired 12,500 sf size for libraries serving up to 100,000 persons. The addition of the 1,137 residents of the Proposed Project could represent a potentially significant impact to the Felipe de Neve library since it

37 Los Angeles Citywide General Plan Framework Draft Environmental Impact Report, 1996, page 2.12-12.



would further increase the demand on an already-undersized library. However, as discussed above, the Pico Union and Pio Pico-Koreatown libraries are also located in the general vicinity of the Project Site and have recently received expansions and/or funding for modernization. As such future residents of the project would have access to adequate library facilities, but within a larger service area. Furthermore, Proposition DD money has funded the expansion and renovation of a total of 32 libraries in Los Angeles as a whole. In light of the recent improvements to the LAPL system and the nearness of the two additional libraries to the Project Site, the impact of the Proposed Project’s 1,137 residents would be less than significant.

CUMULATIVE IMPACTS

Development of the Proposed Project in conjunction with the 49 related projects listed in Section III (Environmental Setting) would result in an increase in employees and permanent residents in the project area. Employees generated by the commercial related projects would not typically enjoy long periods of time during the workday to visit the library facilities. However, the increase in the residential population by the related projects in the vicinity of the Proposed Project would increase demand at library facilities serving the Wilshire Center/Koreatown community. As noted in Section IV.H (Population and Housing) of this Draft EIR, the related projects in combination with the Proposed Project would be expected to add an additional 4,707 persons to the Wilshire CPA. According to State of California standards, this addition would generate a need for approximately 2,354 square feet (4,707 x 0.5) of library space and 9,414 (4,707 x 2) volumes. The additional population generated by the related Projects in combination with the Proposed Project could potentially impact the LAPL library system. However, as discussed above, 32 LAPL libraries have recently been renovated and expanded by Proposition DD, funded by City of Los Angeles voters. Furthermore, as the related projects are scattered in a radius of approximately 1.5 miles around the Project Site, they may also be served by other nearby libraries including the Cahuenga branch (4591 Santa Monica Boulevard), the Central Library (630 W. 5th St.) the Echo Park branch (1410 W. Temple St.), and the Washington Irving branch (4117 W. Washington Boulevard) in addition to the three libraries closest to the Project Site. Together, these resources would be sufficient to serve the related projects in combination with the Proposed Project and there would be a less-than-significant impact.

MITIGATION MEASURES

The Proposed Project would have a less-than-significant impact on library services. Therefore, no mitigation measures are required.


Project impacts to library services would be less than significant.

iv.j. public services

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