martin expo town center initial study

Martin Expo Town Center

Initial Study

PREPARED FOR: The City of Los Angeles

Department of City Planning Environmental Analysis Section

200 North Spring Street, Room 750 Los Angeles, CA 90012-2601

APPLICANT: Philena Properties, L.P.

c/o Martin Cadillac 12101 West Olympic Boulevard

Los Angeles, CA 90064

PREPARED BY: CAJA Environmental Services, LLC

11990 San Vicente Boulevard, Suite 250 Los Angeles, CA 90049

March 2013

Martin Expo Town Center Table of Contents Initial Study Page i

TABLE OF CONTENTS

Section Page

I. Project Description ............................................................................................................................. I-1 II. Initial Study Checklist ........................................................................................................................ II-1

I. Aesthetics ............................................................................................................................. II-6 II. Agricultural and Forestry Resources ................................................................................... II-9 III. Air Quality ......................................................................................................................... II-11 IV. Biological Resources ......................................................................................................... II-14 V. Cultural Resources ............................................................................................................. II-17 VI. Geology and Soils .............................................................................................................. II-21 VII. Greenhouse Gas Emissions ............................................................................................... II-26 VIII. Hazards and Hazardous Materials ..................................................................................... II-30 IX. Hydrology and Water Quality ........................................................................................... II-33 X. Land Use and Planning ...................................................................................................... II-37 XI. Mineral Resources ............................................................................................................. II-39 XII. Noise ................................................................................................................................... II-40 XIII. Population and Housing ..................................................................................................... II-43 XIV. Public Services ................................................................................................................... II-44 XV. Recreation .......................................................................................................................... II-46 XVI. Transportation/Traffic ........................................................................................................ II-47 XVII. Utilities and Service Systems ............................................................................................ II-49 XVIII. Mandatory Findings of Significance ................................................................................. II-52

Table Page

I-1 Project Site Information ........................................................................................................ I-4 I-2 Existing Uses ......................................................................................................................... I-4

Figures Page

I-1 Regional Map ........................................................................................................................ I-2 I-2 Aerial Map ............................................................................................................................ I-3 I-3 Views of the Site, 1-4 ........................................................................................................... I-5 I-4 Views of the Site, 5-8 ........................................................................................................... I-6 I-5 Views of the Site, 9-12 ......................................................................................................... I-7 I-6 Views of the Site, 13-16 ....................................................................................................... I-8 I-7 Views of the Site, 17-20 ....................................................................................................... I-9 I-8 Views of the Site, 21-24 ..................................................................................................... I-10

City of Los Angeles March 2013

Martin Expo Town Center Table of Contents Initial Study Page ii

I-9 Views of Surrounding Uses, 1-4 ........................................................................................ I-13 I-10 Views of Surrounding Uses, 5-8 ........................................................................................ I-14 I-11 Views of Surrounding Uses, 9-12 ...................................................................................... I-15 I-12 Views of Surrounding Uses, 13-16 .................................................................................... I-16 I-13 Views of Surrounding Uses, 17-20 .................................................................................... I-17 I-14 Views of Surrounding Uses, 21-24 .................................................................................... I-18 I-15 Site Plan............................................................................................................................... I-20

Appendices Appendix A: Cultural Resource Letters

Martin Expo Town Center I. Project Description Initial Study Page I-1

I. PROJECT DESCRIPTION

The subject of this Initial Study (IS) is the proposed Martin Expo Town Center Project (the Project).

Project Information

Project Title: Martin Expo Town Center

Project Location: 12101 West Olympic Boulevard, Los Angeles, California 90064

Project Applicant: Philena Properties, L.P. c/o Martin Cadillac 12101 West Olympic Boulevard Los Angeles, California 90064

Lead Agency: City of Los Angeles

Department of City Planning 200 North Spring Street, Room 750 Los Angeles, California 90012

Regional Location

The Project Site is located within the West Los Angeles Community Plan Area in the City of Los Angeles. Regional access to the Project Site is provided by Interstate 405 (I-405), approximately one mile to the east, and Interstate 10 (I-10), approximately 0.4-mile to the south. The Site is three miles east of the Pacific Ocean and 11 miles west of downtown Los Angeles. Figure I-1, Regional Map, shows the Site within the context of Los Angeles.

Local Setting

The Project Site is located at 12101 West Olympic Boulevard, at the northwest corner of Olympic Boulevard and Bundy Drive. Other local streets in the vicinity include north-south streets such as Centinela Avenue (which is the next north-south street to the west) and Barrington Avenue (which is the next major north-south street to the east). East-west streets include Exposition and Pico Boulevards (which are south of the Project Site); Mississippi Avenue, La Grange Avenue, and Missouri Avenue which are east of the Project Site; and Nebraska Avenue, which is north of the Project Site. Figure I-2, Aerial Map, shows the Site and surrounding land uses.

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PROJECTLOCATION

Figure I-1Regional and Project Vicinity Map

Source: CAJA Environmental Services, LLC, 2013.

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Figure I-2Aerial Map

Source: Bing Aerial and CAJA Environmental Services, LLC, 2013.Scale (Feet)

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Legend

Project Site



Existing Uses

The Site contains the Martin Cadillac dealership, which consists of surface parking, a service building with rooftop parking, and a dealership/office building. The buildings total approximately 99,399 square feet (sf) and provide 611 parking spaces. The buildings were built in approximately 1975 and are approximately 38 years old. Current access to the Site is from Bundy Drive and Olympic Boulevard. The Site's assessor parcel number (APN), zoning, census tract, land use, and acreage are listed in Table I-1, Project Site Information.

Table I-1 Project Site Information

Address APN Zoning Census Tract Land Use Designation Size 12101 West Olympic 4259019008 M2-1 2676.00 Light Manufacturing 4.76 acres

APN = assessor parcel numbers Source: http://zimas.lacity.org/ Table by CAJA Environmental Services, October 2012.

The Site is approximately 207,162 sf or approximately 4.76 acres, and is zoned M2-1, where “M2” refers to Light Industrial Zone and the “1” refers to Height District 1. For a Height District of 1 in an M zone, the floor-area-ratio (FAR) is limited to 1.5:1. The Site is in the West Los Angeles Community Plan and West Los Angeles Transportation Improvement and Mitigation Specific Plan and has a General Plan Land Use Designation of Light Manufacturing.

The breakdown of existing uses is listed in Table I-2. Photographs of the existing uses are provided in Figures I-3 through I-8.

Table I-2 Existing Uses

Use Size (sf) Showroom/New Car Delivery 17,659

Parts Department 7,803 Service Department 61,980 Service Reception 6,194

General Office 4,628 Customer Convenience 1,135

Total Building 99,399

Table by CAJA Environmental Services, October 2012.

View 1 View 2

View 3 View 4

Source: CAJA Environmental Services, LLC., 2013.

Figure I-3Views of the Site

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View 5 View 6

View 7 View 8



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Surrounding Land Uses

Photographs of the surrounding land uses are provided in Figures I-9 through I-14.

The surrounding land uses are characterized by a mix of commercial and low-density residential uses, with a concentration of commercial and office uses located along Olympic Boulevard and Bundy Drive. The immediate surroundings are zoned M2 (Light Industrial). Further south, uses along Exposition Boulevard are zoned R1 (Single-Family Residential) and RD (Restricted Density Multiple Dwelling). The Metro Expo Line (currently under construction) right-of-way is zoned PF (Public Facilities), and there will be a Metro Expo Line Station at Exposition Boulevard and Bundy Drive in 2015.1

North

Adjacent to the Project Site on the north is the FOX Television Center (located at 1999 Bundy Drive), which consists of a 3-story office building with microwave and satellite equipment on the roof.

South

South, across Olympic Boulevard, is the four-story Westside Media Center (located at 12100 and 12000 Olympic Boulevard). The Westside Media Center contains office and retail uses, including Bodies in Motion Gym, Kilroy Realty office, Altour travel agency, Lemon Moon restaurant, and ShopZilla.

East

East, across Bundy Drive, from south to north beginning at Olympic Boulevard are the following uses:

Chevron Gas Station, surrounded by Olympic Boulevard, Bundy Drive, and Mississippi Avenue;

Staples office supply store, at the corner of Bundy Drive and Mississippi Avenue;

Henry Radio and Royal Lighting;

OSH Home and Garden; and

Lamps Plus, at the corner of Bundy Drive and La Grange Avenue.

1 Metro Expo Line Facto Sheet of September 2012: http://www.metro.net/projects_studies/exposition_phase2/images/Expo_Phase_2_Fact_Sheet.pdf.



West

Adjacent to the Project Site on the west is the Tribeca West office complex (located at 12233 Olympic Boulevard), which consists of five 3-story buildings, situated around several courtyards. The complex caters to companies doing editing, post-production, and other creative businesses. In addition, a Los Angeles Department of Water and Power (LADWP) Yard is located to the northwest of the south, south of Nebraska Avenue.

Proposed Project

The Project proposes removal of all existing structures, and a total of 807,200 square feet of new development (approximately 707,801 net new square feet), with a proposed floor-area-ration (FAR) of 3.90:1. The Project is seeking flexible land use entitlements (based on equivalent environmental impacts) with a base plan of 516 dwelling units (540,200 gross square feet), 67,000 square feet of retail floor area, 200,000 square feet of creative office floor area, and associated subterranean parking. The proposed uses may also include an auto showroom for the dealership. The 516 dwelling units would include 78 studio units, 206 1-bedroom units, 207 2-bedroom units, and 25 3-bedroom units. Figure I-15 provides the proposed site plan.

The Project would include a Land Use Equivalency Program (LUEP) to allow development flexibility of the Project’s land uses and floor areas. The LUEP would define a framework within which a mix of land uses could be modified within the development envelope defined by the approved entitlements without resulting in any new significant impacts. Therefore, the Site Plan, included as Figure I-15, represents a “concept plan,” but the timing and nature of actual development would be subject to the allowances and limitations set forth by the LUEP.

Height

The residential portion of the Project would be 125 feet from grade (with the majority at 85 feet), including 11 stories over a podium. The retail and office portion of the Project would be 155 feet, including 10 stories over a podium.

Parking

The residential portion of the Project would provide 849 parking spaces, and the retail and office portion of the Project would provide 926 parking spaces. The total amount of parking spaces would be shared among uses. Access would be provided from Olympic Boulevard and Bundy Drive.

View 1: View south across Mississippi Avenue to Chevron Gas Station.

View 2: Royal Lighting and Henry Radio buildings on Bundy Drive, across from Project Site.

View 3: Henry Radio building on Bundy Drive. View 4: View east across Bundy Drive to Royal Lighting and Henry Radio buildings.


Figure I-9Views of Surrounding Uses

1-4

View 5: OSH Home and Garden store on Bundy Drive, across from Project Site.

View 6: View east across Bundy Drive to OSH Home and Garden store.

View 7: View east across Bundy Drive to Staples office supply store, across from Project Site.

View 8: View west across Mississippi Avenue to Staples office supply store. The Project Site is visible beyond the stop sign.



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View 9: View northwest at intersection of La Grange Avenue and Bundy Drive to FOX Television Center.

View 10: View west across Bundy Drive to FOX Television Center.

View 11: View northwest to FOX Television Center. View 12: View northeast at intersection of La Grange Avenue and Bundy Drive to office building.



9-12

View 13: View south across La Grange Avenue to Lamps Plus store.

View 14: View northeast across Bundy Drive to Lamps Plus store.

View 15: View south across Olympic Boulevard to Westside Media Center office building.

View 16: View southeast across Olympic Boulevard to Westside Media Center office building.



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View 17: Tribeca West office complex, west adjacent to the Project Site.

View 18: View north across Olympic Boulevard to Tribeca West office complex.

View 19: View north across Olympic Boulevard to Tribeca West office complex.

View 20: View north across Olympic Boulevard. The Tribeca West office complex is to the left of the telephone pole and the Project Site is to the right.



17-20

View 21: View southeast at intersection of Bundy Drive and Olympic Boulevard to Chevron gas station.

View 22: View east at intersection of Bundy Drive and Olympic Boulevard to Shell gas station

View 23: View northeast at intersection of Bundy Drive and Olympic Boulevard.

View 24: View north at intersection of Bundy Drive and Olympic Boulevard.



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Recreational Facilities and Residential Amenities

The Project would have a swimming pool, fitness room, clubroom, and theatre room.

Signage and Billboards

Two existing freestanding, double-faced billboards are currently on the Site and would remain on the Site with the Project. Each billboard face has a dimension of 14 feet by 48 feet (672 square feet) for a total of 2,688 square feet (672 square feet x 4 faces). One is located on Olympic Boulevard, near the western boundary of the Site. The other is located on Bundy Drive, near the northern boundary of the Site.

The Project would not be adding any additional off-site billboard square footage, but may be replacing the existing billboards with new infrastructure.

Lighting

Night lighting for security, wayfinding, and commercial sign illumination would be provided.

Source: Togawa Smith Martin Architects, 2012.

Figure I-15Site Plan

Scale (Feet)

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Discretionary Actions

Entitlements

1. General Plan Amendment from “Light Industrial” to “General Commercial.” The Applicant will also seek to amend Footnote No. 1, which limits development to Height District No. 1. The current footnote contains three exceptions and allows Height District No. 2 to apply to three specific areas. The Applicant is asking that a fourth exception be added: “The approximately 4.76-acre site at the northwest corner of Olympic Boulevard and Bundy Drive.”

2. Zone change request from M2-1 to C2-2D to allow for the development of the site as proposed. (LAMC Section 12.32)

3. Replacement of existing signage with new signage in accordance with City Code.

4. Pursuant to LAMC Section 14.4, the Applicant seeks to install signage.

5. Vesting Tentative Tract Map for the creation of airspace lots, including residential condominium units. (LAMC Section 17.01)

6. Waiver of the Advisory Agency Policy regarding off-street parking for residential condominium units. (Policy 2000-1)

7. Haul route approval. (LAMC Section 17.13)

8. Conditional Use Permit for Wireless Telecommunications Facility. (LAMC Sections 12.21 A20 and 12.24 W.49)

9. Conditional Use Permit for Major Development Project. (LAMC Section 12.24 U.14)

10. Conditional Use Permit for Off-site (grocery store, wine store) and On-site (restaurants) sales and consumption of alcoholic beverages. (LAMC Section 12.24 W.1)

11. Site Plan Review. (LAMC Section 16.05)

12. Green Building. (LAMC Section 16.10)

13. Zone variance to allow outdoor sales (including kiosks) in the C2 zone (LAMC Section 14.14 A (b)(3)).

14. Zone variance to allow outdoor dining in locations other than the ground floor in the C2 zone (LAMC Section 14.14 A (b)(3)).



15. Compliance with the West Los Angeles Transportation and Improvement Mitigation Specific Plan.

16. The Applicant will be seeking a reduction in required parking spaces based on the development mix, hours of operation, and proximity to the planned Expo station.

Martin Expo Town Center II. Initial Study Checklist Initial Study Page II-1

II. INITIAL STUDY CHECKLIST

LEAD CITY AGENCY

Los Angeles City Planning Department

COUNCIL DISTRICT

11, Bill Rosendahl

DATE

RESPONSIBLE AGENCIES

Southern California Air Quality Management District; Los Angeles Regional Water Quality Control Board

PROJECT TITLE/NO.

Martin Expo Town Center

CASE NO.

ENV-2012-3063-EIR

PREVIOUS ACTIONS CASE NO.

DOES have significant changes from previous actions.

DOES NOT have significant changes from previous actions.

PROJECT DESCRIPTION:

See Section I (Project Description).

ENVIRONMENTAL SETTING:

See Section I (Project Description).

PROJECT LOCATION

12101 West Olympic Boulevard, Los Angeles, California 90064

PLANNING DISTRICT

West Los Angeles Community Plan Area

STATUS:

PRELIMINARY

PROPOSED

ADOPTED July 27, 1999

EXISTING ZONING

M2-1

MAX. DENSITY ZONING

M2 (same as R5): 1 Unit / 200 sf

DOES CONFORM TO PLAN

✓ DOES NOT CONFORM TO PLAN

NO DISTRICT PLAN

PLANNED LAND USE & ZONE

Residential, Retail, Creative Office

C2-2D

MAX. DENSITY PLAN

1.5:1

SURROUNDING LAND USES

Commercial, Residential, and Retail

PROJECT DENSITY

3:90:1



DETERMINATION (To be completed by Lead Agency)

On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION

will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions on the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE

DECLARATION will be prepared.

I find the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT

is required.

I find the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on earlier analysis as described on attached sheets. An ENVIRONMENTAL

IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation

measures that are imposed upon the proposed project, nothing further is required.

____________________________________________________

SIGNATURE

_____________________________________________________

TITLE



EVALUATION OF ENVIRONMENTAL IMPACTS:

1) A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants based on a project-specific screening analysis).

2) All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3) Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less that significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

4) “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of a mitigation measure has reduced an effect from “Potentially Significant Impact” to “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from “Earlier Analysis,” as described in (5) below, may be cross referenced).

5) Earlier analysis must be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR, or negative declaration. Section 15063 (c)(3)(D). In this case, a brief discussion should identify the following:

1) Earlier Analysis Used. Identify and state where they are available for review.

2) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis.

3) Mitigation Measures. For effects that are “Less Than Significant With Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.



6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated

7) Supporting Information Sources: A sources list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whichever format is selected.

9) The explanation of each issue should identify:

1) The significance criteria or threshold, if any, used to evaluate each question; and

2) The mitigation measure identified, if any, to reduce the impact to less than significance.



ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.

Aesthetics Greenhouse Gas Emissions Population/Housing

Agricultural and Forestry Resources Hazards & Hazardous Materials Public Services

Air Quality Hydrology/Water Quality Recreation

Biological Resources Land Use/Planning Transportation/Traffic

Cultural Resources Mineral Resources Utilities/Service Systems

Geology/Soils Noise Mandatory Findings of Significance

INITIAL STUDY CHECKLIST (To be completed by the Lead City Agency)

BACKGROUND

PROPONENT NAME

Philena Properties, L.P.

PHONE NUMBER

310-826-3879

PROPONENT ADDRESS

12101 West Olympic Boulevard, Los Angeles, California 90064

Contact: Dana R. Martin, Jr ([email protected])

AGENCY REQUIRING CHECKLIST

City of Los Angeles Planning Department

DATE SUBMITTED



ENVIRONMENTAL IMPACTS (Explanations of all potentially and less than significant

impacts are required to be attached on separate sheets)

Potentially

Significant Impact

Potentially Significant Unless

Mitigation

Incorporated

Less Than

Significant Impact No Impact

I. Aesthetics. Would the project:

a. Have a substantial adverse effect on a scenic vista?

b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings, or other locally recognized desirable aesthetic natural feature within a city-designated scenic highway?

c. Substantially degrade the existing visual character or quality of the site and its surroundings?

d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

Response a:

A significant impact would occur if a proposed project introduces incompatible visual elements within a field of view containing a scenic vista or substantially blocks a scenic vista. As described in the City of Los Angeles CEQA Thresholds Guide, panoramic views or vistas provide visual access to a large geographic area, for which the field of view can be wide and extend into the distance. Panoramic views are usually associated with vantage points looking out over a section of urban or natural area, which provide a geographical orientation not commonly available. Examples of panoramic views might include an urban skyline, valley, mountain range, the ocean, or other water bodies.

The Project Site is in an urbanized portion of West Los Angeles, and is topographically relatively flat. The Project would construct four buildings, separated at the ground level by an office/retail courtyard, a paseo walkway/driveway, and a residential courtyard above a commercial level podium. The tallest building would have a height of approximately 160 feet. The Project would increase the building heights on the Project Site as compared with existing uses (which are currently one and two stories).

The building to the south on Olympic Boulevard is four stories, the building to the east at the intersection of Bundy Drive and La Grange Avenue is eight stories, and there are two buildings to the east across Bundy Drive that are six stories and 12 stories, respectively.

Views in the area are typically found along Bundy Drive and Olympic Boulevard, looking north toward the Santa Monica Mountains. As the Proposed Project would increase the building heights on the Site as



compared to current conditions, and beyond what is permitted under existing zoning, there is the potential to impact a scenic vista. Therefore, this potential impact will be analyzed in the EIR.

Response b:

A significant impact would occur only where scenic resources would be damaged or removed by the Project. The Project Site does not contain trees with scenic significance or rock outcroppings and is not located within a state scenic highway.2

The nearest Los Angeles Historic Cultural Monuments (LA HCM) and Santa Monica (SM) are:3

Sierra Springs (SM #522), 11800 Texas Avenue, 4,220 feet northeast of the Project Site;

Jones & Emmons Building (LA HCM #696), 12248 Santa Monica Blvd., 1 mile north of the Site;

Durham House (LA HCM #745), 1851 Kelton Avenue, 1.36 miles northeast of the Site;

Pengelly House (LA HCM #746), 1845 Kelton Avenue, 1.36 miles northeast of the Site; and

Siple House (LA HCM #747), 1841 Kelton Avenue, 1.36 miles northeast of the Site.

Since none of these scenic resources would be damaged or removed by the Proposed Project, none of these historic resources would be impacted by the Project. Therefore, this impact would be less than significant. Further evaluation of this issue in an EIR is not required.

Response c:

A significant impact may occur if a project introduces incompatible visual elements on the Project Site or visual elements that would be incompatible with the character of the area surrounding the Project Site.

The Project would increase the building height on the Site from existing uses, and beyond what is permitted under existing zoning, and would introduce new architectural buildings to the area. The potential to create visual elements that would be incompatible with the character of the area will therefore be analyzed in the EIR.

2 California Scenic Highway Mapping System, Los Angeles County: http://www.dot.ca.gov/hq/LandArch/scenic_highways/index.htm

3 Los Angeles Historic-Cultural Monuments in the West Los Angeles Community Plan: http://cityplanning.lacity.org/complan/HCM/dsp_hcm_result.cfm?community=West%20Los%20Angeles%20-%20Century%20City%20-%20Rancho%20Park



Response d:

A significant impact may occur if a project introduces new sources of light or glare on the Project Site which would be incompatible with the areas surrounding the Project Site or which pose a safety hazard, such as to motorists utilizing adjacent streets.

Artificial Light

An adverse impact would occur if the Project created a substantial new source of artificial light that would adversely affect the surrounding area. Artificial light may be generated from individual (i.e., point) sources as well as from indirect sources of reflected light. Uses such as residences, hospitals, and hotels are considered light sensitive since they are typically occupied by persons who are subject to disturbance by bright light sources during evening hours.

The Project Site is located in a well-lit urban portion of Los Angeles where there are high levels of ambient nighttime lighting including street lighting, architectural and security lighting, and indoor building illumination (light emanating from the interior of structures which passes through windows), all of which are common to densely populated areas.

Nevertheless, aesthetic impacts to the nearby residential properties (south of the Site along Exposition Boulevard and northeast of the Site along Bundy Drive/Missouri Avenue) may result due to additional illumination at the Project Site. Therefore, this issue will be analyzed further in an EIR.

Glare

An adverse impact would occur if the Project created a substantial new source of glare that would adversely affect day or nighttime views in the area. Glare is a common phenomenon in the southern California area due mainly to the occurrence of a high number of days per year with direct sunlight and the highly urbanized nature of the region, which results in a large concentration of potentially reflective surfaces. Potential reflective surfaces in the Project vicinity include automobiles traveling and parked on streets in the vicinity of the Project, exterior building windows, and surfaces of brightly painted buildings in the project vicinity.

Excessive glare not only restricts visibility, but increases the ambient heat reflectivity in a given area. The potential exists for glass or other shiny building materials to cause glare impacts at nearby residential uses. However, implementation of the following standard City mitigation measure would ensure that impacts with respect to glare are less than significant. Therefore, further analysis of this issue in the EIR is not required.



Mitigation Measure

I-1 The exterior of the proposed structures shall be constructed of materials such as, but not limited to, high-performance and/or non-reflective tinted glass (no mirror-like tints or films) and pre-cast concrete or fabricated wall surfaces to minimize glare and reflected heat.

Shade/Shadow

The analysis of the Proposed Project’s potential shade/shadow impacts focuses on changes in shading conditions for those off-site uses and activities that are dependent on access to natural light. Off-site uses and activities that meet this criteria include routinely used outdoor spaces associated with residential, recreational, or institutional uses (pre-schools, schools, nursing homes); or commercial uses such as pedestrian-oriented outdoor spaces or restaurants with outdoor eating areas; and existing solar collectors.

The Project would consist of four buildings, separated at the ground level by an office/retail courtyard, a paseo walkway/driveway, and a residential courtyard above a commercial level podium. The tallest building would have an approximate height of 160 feet. The existing buildings on the Site are a mix of one and two stories. Due to the changes in height, this issue will be analyzed further in an EIR.

Potentially

Significant Impact


Mitigation

Incorporated

Less Than


II. Agricultural And Forestry Resources. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest Range and Assessment Project and Forest Legacy Assessment project and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


agricultural use?

b. Conflict the existing zoning for agricultural use, or a Williamson Act Contract?

c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined by Public Resources Code section 122220(g)), timberland (as defined by Public Resources Code section 4526, or timberland zoned Timberland Production (as defined by Government Code section 51104(g)?

d. Result in the loss of forest land or conversion of forest land to non-forest use?

e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use?

Responses a-e:

A significant impact may occur if a project were to result in the conversion of state-designated agricultural land from agricultural use to another non-agricultural use, the conversion of land zoned for agricultural use or under a Williamson Act contract from agricultural use to another non-agricultural use, results in the rezoning of forest land or timberland, or involves other changes in the existing environment which, could result in conversion of Farmland to non-agricultural use.

The Project Site is currently developed with an auto dealership and service center. The Site does not contain any agricultural uses, and is not delineated as such on any maps prepared pursuant to the Farmland Mapping and Monitoring Program.4 The Site is zoned light industrial (M2). No Williamson Act Contract applies to the Site. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

4 State of California Department of Conservation, Division of Land Resource Protection, Farmland Mapping and Monitoring Program, website: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2006/los06.pdf, October 12, 2012..



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


III. Air Quality. The significance criteria established by the South Coast Air Quality Management District (SCAQMD) may be relied upon to make the following determinations. Would the project result in:

a. Conflict with or obstruct implementation of the SCAQMD or Congestion Management Plan?

b. Violate any air quality standard or contribute substantially to an existing or projected air quality violation?

c. Result in a cumulatively considerable net increase of any criteria pollutant for which the air basin is non-attainment(ozone, PM 2.5, & PM 10) under an applicable federal or state ambient air quality standard?

d. Expose sensitive receptors to substantial pollutant concentrations?

e. Create objectionable odors affecting a substantial number of people?

Response a:

A significant impact may occur if a project is not consistent with the applicable Air Quality Management Plan (AQMP) or would in some way represent a substantial hindrance to employing the policies or obtaining the goals of that plan.

The Project Site is located within the 6,600-square mile South Coast Air Basin (Basin). The South Coast Air Quality Management District (SCAQMD) is required, pursuant to the Clean Air Act, to reduce emissions of criteria pollutants for which the Basin is in non-attainment (i.e., ozone [1-hour and 8-hour standards], PM10, and PM2.5). As such, the Project would be subject to the SCAQMD’s AQMP. The AQMP contains a comprehensive list of pollution control strategies directed at reducing emissions and achieving ambient air quality standards. These strategies are developed, in part, based on regional population, housing, and employment projections prepared by the Southern California Association of Governments (SCAG).

SCAG is the regional planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino and Imperial Counties, and addresses regional issues relating to transportation, the economy, community



development and the environment.5 With regard to air quality planning, SCAG has prepared the Regional Comprehensive Plan and Guide (RCPG), which includes Growth Management and Regional Mobility chapters that form the basis for the land use and transportation control portions of the AQMP, and are utilized in the preparation of the air quality forecasts and consistency analysis included in the AQMP. Both the RCPG and AQMP are based, in part, on projections originating with the City’s General Plan.

A significant impact may occur if the Project is inconsistent with the growth assumptions upon which the AQMP was based. As a result, Project development could have an adverse effect on the SCAQMD’s implementation of the AQMP. Therefore, this issue will be analyzed further in an EIR.

Response b:

A project would result in a significant air quality impact if project-related emissions exceed federal, State or regional standards or thresholds, or if project-related emissions would substantially contribute to an existing or projected air quality violation.

Construction and operation of the Project has the potential to generate emissions which could exceed federal, State, or regional standards or thresholds or contribute to an existing or projected air quality violation. Therefore, this issue will be analyzed further in an EIR.

Response c:

A significant impact would occur if the Proposed Project would result in a cumulatively considerable net increase in a federal or State non-attainment pollutant. Because the Basin is currently in non-attainment for ozone (1-hour and 8-hour standards), PM10, and PM2.5, cumulative development could violate an air quality standard or contribute to an existing or projected air quality violation.

With regard to determining the significance of the Project’s contribution to regional emissions, the SCAQMD recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project specific impacts. Therefore, according to the SCAQMD, individual projects that generate construction or operational emissions that exceed the SCAQMD recommended daily thresholds for project-specific impacts would also cause a cumulatively considerable increase in emissions for those pollutants for which the Basin is in non-attainment.

The Project has the potential to add a cumulatively considerable contribution to a federal or State non-attainment pollutant. Therefore, this issue will be analyzed further in an EIR.

5 SCAG is the federally designated metropolitan planning organization (MPO) for Southern California region.



Response d:

A significant impact may occur if a project were to generate pollutant concentrations to a degree that would significantly affect sensitive receptors. Land uses that are considered more sensitive to air pollution than others include hospitals, schools, residences, playgrounds, childcare centers, athletic facilities, and retirement homes.6

Sensitive receptors in the Project vicinity include, but are not limited to, the residential neighborhoods located in the Project vicinity (south of the Site along Exposition Boulevard and northeast of the Site along Bundy Drive at Missouri Avenue) as well as an animal hospital located at Olympic Boulevard and Centinela Avenue.

The Project could expose these sensitive receptors to substantial pollutant concentrations. Therefore, this issue will be analyzed further in an EIR.

Response e:

A significant impact would only occur if the Project would generate substantial odors. The SCAQMD’s CEQA Air Quality Handbook, identifies those land uses that are associated with odor complaints, which typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding.

Potential sources that may emit odors during construction activities include the use of architectural coatings and solvents as well as asphalt paving. SCAQMD Rules 1108 and 1113 limit the amount of volatile organic compounds from cutback asphalt and architectural coatings and solvents, respectively. Via mandatory compliance with SCAQMD Rules, no construction activities or materials are proposed which would create a significant level of objectionable odors and would limit potential objectionable odor impacts during the Project’s short-term construction phase to a less than significant level.

The Project does not include any of the uses identified by the SCAQMD as being associated with odors. The Project would be required to comply with industry standard odor control practices, SCAQMD Rule 402 (Nuisance), and SCAQMD Best Available Control Technology Guidelines would limit potential objectionable odor impacts during the Project’s long-term operations phase to a less than significant level.

The Project would not create objectionable odors affecting a substantial number of people during construction or long-term operation. Therefore, a less than significant impact would occur. Further evaluation of this issue in an EIR is not required.

6 South Coast Air Quality Management District, CEQA Air Quality Handbook, Figure 5-1, April 1993.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than Significant

Impact No Impact

IV. Biological Resources. Would the project:

a. Have a substantial adverse effect, either directly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in the City or regional plans, policies, regulations by the California Department of Fish and Game or U.S. Fish and Wildlife Service?

c. Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

e. Conflict with any local policies or ordinances protecting biological resources, such as tree preservation policy or ordinance (e.g., oak trees or California walnut woodlands)?

f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

Response a:

A significant impact would occur if a project would remove or modify habitat for any species identified or designated as a candidate, sensitive, or special status species in local or regional plans, policies, or regulation, or by the State or federal regulatory agencies cited above.



The Project Site is located in an urbanized area of West Los Angeles and is currently developed with buildings, paving, and minimal landscaping.

The Project Site does not contain any natural open spaces, act as a wildlife corridor, nor likely possess any areas of significant biological resource value. No hydrological features are present on the Site and there are likely no sensitive habitats present. Due to the lack of biotic resources, no candidate, sensitive, or special status species identified in local plans, policies, regulations, by the California Department of Fish and Game (CDFG), the California Native Plant Society (CNPS), or the U.S. Fish and Wildlife Service (USFWS) would be expected to occur on the Project Site.

The Project Site has minimal landscaping, nearly entirely on the outer perimeter along the sidewalk. This includes a grass area at the intersection of Bundy Drive and Olympic Boulevard with a few ornamental trees and shrubs in front of the showroom building, and a shrubbery boundary along the sidewalks on Bundy Drive and Olympic Boulevard. Due to the developed history of the Site and lack of native or substantial vegetation, the likelihood of a listed species being onsite is negligible.

Therefore, a less than significant impact would occur. Further evaluation of this issue in an EIR is not required.

Response b:

A significant impact would occur if riparian habitat or any other sensitive natural community identified locally, regionally, or by the State and federal regulatory agencies cited would be adversely modified by a project. No riparian or other sensitive habitat areas are located on or adjacent to the Project Site.7 Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Response c:

A significant impact would occur if federally protected wetlands, as defined by Section 404 of the Clean Water Act, would be modified or removed by a project.

Review of the National Wetlands Inventory identified no wetlands or water features on the Project Site.8 Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Response d:

A significant impact would occur if a project would interfere or remove access to a migratory wildlife corridor or impede the use of native wildlife nursery sites.

7 http://navigatela.lacity.org/index01.cfm, Water, Lakes, and Streams layer; October 15, 2012. 8U.S. Fish & Wildlife Service, National Wetlands Inventory, website:

http://107.20.228.18/Wetlands/WetlandsMapper.html#, October 15, 2012..



The Project Site is currently developed with buildings, paving, and minimal landscaping and would not interfere substantially with the movement of any native resident or migratory birds.

The Project Site has minimal landscaping, nearly entirely on the outer perimeter along the sidewalk. This includes a grass area at the intersection of Bundy Drive and Olympic Boulevard with a few ornamental trees and shrubs in front of the showroom building, and a shrubbery boundary along the sidewalks on Bundy Drive and Olympic Boulevard. Due to the developed history of the Site and lack of native or substantial vegetation, the likelihood of a migratory species being onsite is negligible. In addition, no bodies of water exist onsite to provide habitat for fish.

As such, Project implementation would neither interfere with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors nor impede the use of native wildlife nursery sites. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Response e:

A significant adverse impact would occur if a project were inconsistent with local regulations pertaining to biological resources.

The Project would be confined to the previously developed Site and would not involve substantial changes in the existing environment.

Local ordinances protecting biological resources are limited to the City of Los Angeles Protected Tree Ordinance, as modified by Ordinance 177404. The amended Protected Tree Ordinance provides guidelines for the preservation of all Oak trees indigenous to California (excluding the Scrub Oak or Quercus dumosa). as well as the following tree species: Southern California Black Walnut (Juglans californica var. californica); Western Sycamore (Platanus racemosa); and California Bay (Umbellularia californica).9

The Site contains several trees in front of the showroom building at the corner of Bundy Drive and Olympic Boulevard. Any removed tree would need to comply with the ordinance. Therefore, a less than significant impact would occur. Further evaluation of this issue in an EIR is not required.

Response f:

A significant impact would occur if a project would be inconsistent with policies in any draft or adopted conservation plan.

9 City of Los Angeles, Ordinance 177404, approved March 13, 2006 and effective April 23, 2006.




The Site is not located in or adjacent to an existing City or County Significant Ecological Area.10 Additionally, there is no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan that applies to the Project Site.

Implementation of the Project would not conflict with any habitat conservation plans. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

V. Cultural Resources: Would the project:

a. Cause a substantial adverse change in significance of a historical resource as defined in State CEQA Section 15064.5?

b. Cause a substantial adverse change in significance of an archaeological resource pursuant to State CEQA Section 15064.5?

c. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

d. Disturb any human remains, including those interred outside of formal cemeteries?

Response a:

Section 15064.5 of the State CEQA Guidelines defines an historical resource as:

1) a resource listed in or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources;

2) a resource listed in a local register of historical resources or identified as significant in an historical resource survey meeting certain state guidelines; or

3) an object, building, structure, site, area, place, record or manuscript which a lead agency determines to be significant in the architectural, engineering, scientific, economic, agricultural,

10 http://navigatela.lacity.org/index01.cfm, Significant Ecological Area layer; October 15, 2012.



educational, social, political, military, or cultural annals of California, provided that the lead agency’s determination is supported by substantial evidence in light of the whole record.

A project-related significant adverse effect would occur if the Proposed Project were to adversely affect a historical resource meeting one of the above definitions.

The State Office of Historic Preservation recommends that properties over 45 years of age be evaluated for their potential as historic resources.

The buildings are approximately 38 years old. None of the existing buildings are listed or expected to be listed in an historical register.

The nearest Los Angeles Historic Cultural Monuments (LA HCM) and Santa Monica (SM) are:11

Sierra Springs (SM #522), 11800 Texas Avenue, 4,220 feet northeast of the Project Site;

Jones & Emmons Building (LA HCM #696), 12248 Santa Monica Blvd., 1 mile north of the Site;

Durham House (LA HCM #745), 1851 Kelton Avenue, 1.36 miles northeast of the Site;

Pengelly House (LA HCM #746), 1845 Kelton Avenue, 1.36 miles northeast of the Site; and

Siple House (LA HCM #747), 1841 Kelton Avenue, 1.36 miles northeast of the Site.

None of these historic resources would be impacted by the Project.

Therefore, a less than significant impact would occur. Further evaluation of this issue in an EIR is not required.

Response b:

Section 15064.5 of the State CEQA Guidelines defines significant archaeological resources as resources which met the criteria for historical resources, as discussed above, or resources which constitute unique archaeological resources. A project-related significant adverse effect could occur if the Project were to affect archaeological resources which fall under either of these categories. According to the South Central Coastal Information Center (letter included as Appendix A to this Initial Study), there are no known

11 Los Angeles Historic-Cultural Monuments in the West Los Angeles Community Plan: http://cityplanning.lacity.org/complan/HCM/dsp_hcm_result.cfm?community=West%20Los%20Angeles%20-%20Century%20City%20-%20Rancho%20Park



archaeological resources within the Project Site.12 However, the excavation for the subterranean parking levels has the potential to affect unknown archaeological resources. Implementation of the following standard City mitigation measure would ensure that impacts with respect to archaeological resources are less than significant. Therefore, further analysis of this issue in the EIR is not required.

Mitigation Measure

V-1 If any archaeological materials are encountered during the course of Project development, all further development activity shall be halted and: a. The services of an archaeologist shall then be secured by contacting the South Central

Coastal Information Center located at California State University Fullerton, or a member of the Society of Professional Archaeologists (SOPA), or a SOPA-qualified archaeologist, who shall assess the discovered material(s) and prepare a survey, study, or report evaluating the impact.

b. The archaeologist’s survey, study, or report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource.

c. The applicant shall comply with the recommendations of the evaluating archaeologist, as contained in the survey, study, or report.

d. Project development activities may resume once copies of the archaeological survey, study, or report are submitted to the South Central Coastal Information Center at California State University Fullerton.

e. Prior to the issuance of any building permit, the applicant shall submit a letter to the case file indicating what, if any, archaeological reports have been submitted, or a statement indicating that no material was discovered.

f. A covenant and agreement binding the applicant to this condition shall be recorded prior to issuance of a grading permit.

Response c:

A project-related significant adverse effect could occur if grading or excavation activities associated with the Proposed Project would disturb paleontological resources or geologic features which presently exist within the Project Site. According to the Natural History Museum of Los Angeles County (letter included as Appendix A to this Initial Study), there are no known paleontological resources within the Project Site.13 However, the excavation for the subterranean parking levels has the potential to affect unknown paleontological resources. Implementation of the following standard City mitigation measure would ensure that impacts with respect to paleontological resources are less than significant. Therefore, further analysis of this issue in the EIR is not required.

12 South Central Coastal Information Center, California State University, Fullerton, letter dated November 27, 2012, included as Appendix A to this Initial Study.

13 Natural History Museum of Los Angeles County, letter dated December 20, 2012, included as Appendix A to this Initial Study.



Mitigation Measure

V-2 If any paleontological materials are encountered during the course of Project development, all further development activities shall halt and: a. The services of a paleontologist shall then be secured by contacting the Center for Public

Paleontology –USC, UCLA, California State University Los Angeles, California State University Long Beach, or the Los Angeles County Natural History Museum – who shall assess the discovered material(s) and prepare a survey, study, or report evaluating the impact.

b. The paleontologist’s survey, study, or report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource.

c. The applicant shall comply with the recommendations of the evaluating paleontologist, as contained in the survey, study, or report.

d. Project development activities may resume once copies of the paleontological survey, study, or report are submitted to the Los Angeles County Natural History Museum.

e. Prior to the issuance of any building permit, the applicant shall submit a letter to the case file indicating what, if any, paleontological reports have been submitted, or a statement indicating that no material was discovered.

f. A covenant and agreement binding the applicant to this condition shall be recorded prior to the issuance of a grading permit.

Response d:

A project-related significant adverse effect could occur if grading or excavation activities associated with the proposed project would disturb previously interred human remains. The Project Site is located in a heavily urbanized area, and is currently developed with an auto dealership and service center. The likelihood of encountering human remains on the Site is minimal. According to the Native American Heritage Commission (letter included as Appendix A to this Initial Study), the Sacred Lands File search did not indicate the presence of any resources within the Project Site.14 However, during the construction and excavation of the Project Site, there is a possibility that human remains could be encountered. Implementation of the following standard City mitigation measure would ensure that impacts with respect to human remains are less than significant. Therefore, further analysis of this issue in the EIR is not required.

Mitigation Measure

V-3 In the event that human remains are discovered during excavation activities, the following procedure shall be observed: a. Stop immediately and contact the County Coroner.

14 Native American Heritage Commission, Sacred Lands File Search, letter dated November 26, 2012, included as Appendix A to this Initial Study.



b. The coroner has two working days to examine human remains after being notified by the responsible person. If the remains are Native American, the coroner has 24 hours to notify the Native American Heritage Commission.

c. The Native American Heritage Commission will immediately notify the person it believes to be the most likely descendant of the deceased Native American.

d. The most likely descendant has 48 hours to make recommendations to the owner, or representative, for the treatment or disposition, with proper dignity, of the human remains and grave gods.

e. If the descendant does not make recommendations within 48 hours, the owner shall reinter the remains in an area of the property secure from further disturbance.

f. If the owner does not accept the descendant’s recommendations, the owner or the descendant may request mediation by the Native American Heritage Commission.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

VI. Geology and Soils. Would the project:

a. Exposure of people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving :

i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

ii. Strong seismic ground shaking?

iii. Seismic-related ground failure, including liquefaction?

iv. Landslides?

b. Result in substantial soil erosion or the loss of topsoil?

c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potential result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?

d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property?



Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?

Response a.i:

Fault rupture is defined as the surface displacement that occurs along the surface of a fault during an earthquake. Based on criteria established by the California Geological Survey (CGS), faults can be classified as active, potentially active, or inactive. Active faults may be designated as Earthquake Fault Zones under the Alquist-Priolo Earthquake Fault Zoning Act, which includes standards regulating development adjacent to active faults. In addition, the City of Los Angeles designates Fault Rupture Study Zones on each side of active and potentially active faults to establish areas of hazard potential.

There are several principal active faults in the metropolitan region. The greatest of these is the San Andreas Fault, approximately 35 miles (55 kilometers) northwest of downtown Los Angeles, on the other side of the San Gabriel Mountains. Several other important active faults lie closer to and even within the populated area of greater Los Angeles. These include the Sierra Madre fault zone, which runs through parts of Altadena and other foothills communities, the Raymond Fault in San Marino, and the Hollywood and Santa Monica Faults along the southern edge of the Hollywood Hills and Santa Monica Mountains.

The City of Los Angeles Seismic Safety Element does not include the Project Site within an Alquist-Priolo Special Study Zone or Fault Rupture Study Area (although the Site is very near the approximate boundaries of the Fault Rupture Study Area in West Los Angeles).15 The nearest fault, the Santa Monica Fault, is 1.09 km away.16

The Project would comply with the CGS Special Publications 117, Guidelines for Evaluating and Mitigating Seismic Hazards in California (1997), which provides guidance for the evaluation and mitigation of earthquake-related hazards, and with the seismic safety requirements in the UBC and the LAMC. Further, the 2010 City of Los Angeles Building Code, with which the Project would be required to comply, contains construction requirements to ensure that structures are built to a level such that they can withstand acceptable seismic risk.

Therefore, the Project would not expose people or structures to substantial adverse effects associated with fault rupture, and impacts would be less than significant. Additional analysis in the EIR is not required.

15 City of Los Angeles, Safety Element, Exhibit A, Alquist-Priolo Special Study Zones & Fault Rupture Study Areas in the City of Los Angeles, http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, October 15, 2012.

16 City of Los Angeles, ZIMAS Parcel Profile Reports, website: http://zimas.lacity.org, October 15, 20122.



Response a.ii:

A significant impact may occur if a project represents an increased risk to public safety or destruction of property by exposing people, property or infrastructure to seismically induced ground shaking hazards that are greater than the average risk associated with locations in the Southern California region. Southern California is active seismic region (UBC Seismic Zone IV).

Although the Project Site is not within an Alquist-Priolo Zone, as with all properties in the seismically active Southern California region, the Site is susceptible to ground shaking during a seismic event. The main seismic hazard affecting the Project Site is moderate to strong ground shaking on one of the local regional faults. As the Site is located in a seismically active region, the Project would conform to all applicable provisions of the City Building Code, California Building Code, and the UBC with respect to new construction. Adherence to current building codes and engineering practices would ensure that the Project would not expose people, property or infrastructure to seismically induced ground shaking hazards that are greater than the average risk associated with locations in the Southern California region and would minimize the potential to expose people or structures to substantial risk, loss, or injury. Therefore, impacts related to seismic ground shaking would be less than significant. Further evaluation of this issue in the EIR is not required.

Response a.iii:

Liquefaction is a form of earthquake-induced ground failure that occurs primarily in relatively shallow, loose, granular, water-saturated soils. Liquefaction can occur when these types of soils lose their inherent shear strength due to excess water pressure that builds up during repeated movement from seismic activity. Low groundwater table and the presence of loose to medium dense sand and silty sand are factors that could contribute to the potential for liquefaction.

The Project Site is identified by ZIMAS and the State Seismic Hazard Zone Map as being within a liquefaction zone.1718 However, the City of Los Angeles Seismic Safety Element identifies the Project Site as being located outside a potentially liquefiable area.19 Because of the discrepancy, and the fact that ZIMAS has more current data than the 1996 adopted Element, it is assumed that the Project is in a liquefaction zone. Therefore, this issue will be analyzed further in an EIR.

17 City of Los Angeles, ZIMAS Parcel Profile Report, website: http://zimas.lacity.org,October 15, 2012. 18 California Geologic Survey, Seismic Hazard Zones, Beverly Hills Quadrangle:

http://gmw.consrv.ca.gov/shmp/download/pdf/ozn_bevh.pdf, October 15, 2012. 19 City of Los Angeles, Safety Element, Exhibit B,, Areas Susceptible to Liquefaction in the City of Los Angele:,

http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, accessed October 15, 2012.



Response a.iv:

A significant adverse effect may occur if a project is located in a hillside area with soil conditions that would suggest high potential for sliding. Landslides can occur on slopes under normal gravitational forces and during earthquakes when strong ground motion can cause failure. Landslides tend to occur in loosely consolidated, wet soil, and/or rock on unstable sloping terrain.

The Project Site is relatively flat and not near any hillside areas. The Project Site is not classified as a landslide hazard zone in the State Seismic Hazard Zones Map.20 The Project Site is also not identified by ZIMAS as being within a landslide hazard zone.21 Finally, the City of Los Angeles Seismic Safety Element shows that the Site is not within a landslide area.22 Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Response b:

A significant impact may occur if a project exposes large areas to the erosional effects of wind or water for a protracted period of time. The Project Site located in an urbanized portion of West Los Angeles and is completely paved and developed with an auto dealership and service center. Any topsoil that may exist on the Site was previously blended with other on-site soils during previous Site preparation/grading activities. As such, development of the Project would not result in substantial loss of topsoil.

Construction activities such as grading and excavation could create the potential for soil erosion. The potential for soil erosion on the Site is low due to the generally level topography of the Site and the presence of existing off-site drainage facilities. Project construction would require the removal of existing pavement and grading earth and excavation. Conformance with City Building Code Sections 91.7000 through 91.7016, which include construction requirements for grading, excavation, and use of fill, would reduce the potential for wind or waterborne erosion.

In addition, the Los Angeles Building Code requires an erosion control plan to be reviewed by the Department of Building and Safety prior to construction if grading exceeds 200 cubic yards and occurs during the rainy season (between November 1 and April 15). Therefore, Project impacts related to soil erosion during construction, with the inclusion of the Code-based design features, are anticipated to be minimal.

The potential for soil erosion during Project operation would be relatively low due to the urban nature of the Project area and the generally level topography of the Project Site. The Project would develop the

20 California Geologic Survey, Seismic Hazard Zones, Beverly Hills Quadrangle: http://gmw.consrv.ca.gov/shmp/download/pdf/ozn_bevh.pdf, October 15, 2012.

21 City of Los Angeles, ZIMAS Parcel Profile Reports, website: http://zimas.lacity.org, October 15, 2012. 22 City of Los Angeles, Safety Element, Exhibit C, Landslide Inventory & Hillside Areas in the City of Los

Angeles: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, October 15, 2012.



entire Site with new buildings, paving, and surface treatments. Therefore, a less than significant impact would occur. Further evaluation of this issue in an EIR is not required.

Response c:

A significant impact may occur if a project is built in an unstable area without proper site preparation or design features to provide adequate foundations for project buildings, thus posing a hazard to life and property. The Project Site is generally level, located in an urbanized portion of West Los Angeles, and is completely paved and developed with an auto dealership and service center.

The Site is not within a hillside area.23 However, the Site is identified by ZIMAS and the State Seismic Hazard Zones Map as being within a liquefaction zone.24

Earthquake-induced volumetric strain and dissipation of pore pressure in saturated silts and sands after liquefaction can result in settlement. Since the Project Site does not contain free-faces or slopes, the potential for lateral spreading to occur is low.

Subsidence is a localized mass movement that involves the gradual downward settling or sinking of the ground, resulting from the extraction of mineral resources, subsurface oil, groundwater, or other subsurface liquids, such as oil and natural gas. The Project Site is not in any major oil drilling area or boundary of State-designated oil fields. 25 However, Project construction may require additional analysis of the Site conditions to accommodate the subterranean parking. Therefore, this issue will be analyzed further in an EIR.

Response d:

A significant impact may occur if a project is built on expansive soils without proper site preparation or design features to provide adequate foundations for project buildings, thus, posing a hazard to life and property. Expansive soils are clay-based soils that tend to expand (increase in volume) as they absorb water and shrink as water is drawn away. If soils below the development consist of expansive clays within a zone where the water content can fluctuate, foundation movement and/or damage can occur.

Although the Project must comply with building regulations set forth by the California Building Code, the potential for an impact still exists. Therefore, this issue will be analyzed further in an EIR.

23 City of Los Angeles, ZIMAS Parcel Profile Reports, website: http://zimas.lacity.org, October 16, 2012. 24 California Geologic Survey, Seismic Hazard Zones, Beverly Hills Quadrangle:

http://gmw.consrv.ca.gov/shmp/download/pdf/ozn_bevh.pdf, October 16, 2012. 25 City of Los Angeles, Safety Element, Exhibit E, Oil Field and Oil Drilling Areas in the City of Los Angeles:

http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, October 15, 2012.



Response e:

A significant impact may occur if a project is located in an area not served by an existing sewer system. The Project Site is located in a developed area of the City of Los Angeles, which is served by a wastewater collection, conveyance, and treatment system operated by the City. No septic tanks or alternative disposal systems are necessary, nor are they proposed. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

VII. Greenhouse Gas Emissions. Would the project:

a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact upon the environment?

b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?

Responses a and b:

Construction and operation of the Project has the potential to generate greenhouse gas emissions, either directly or indirectly, which may have a significant impact on the environment. In addition, the Project will need to be fully evaluated for consistency with all applicable plans, policies, and regulations for the purpose of reducing the emissions of greenhouse gases.

Federal

The US EPA has historically not regulated GHGs because it determined the Clean Air Act did not authorize it to regulate emissions that addressed climate change. In 2007, the US Supreme Court found that GHGs could be considered within the Clean Air Act’s definition of a pollutant.26 In December 2009, US EPA issued an endangerment finding for GHGs under the Clean Air Act, setting the stage for future regulation. In September 2009, the National Highway Traffic Safety Administration and U.S. EPA announced a joint rule that would tie fuel economy to GHG emission reduction requirements. By 2016, this could equate to an overall light-duty vehicle fleet average fuel economy of 35.5 miles per gallon.

26 Massachusetts v. Environmental Protection Agency et al (127 S. Ct. 1438 (2007))



State

California has adopted a series of laws and programs to reduce emissions of GHGs into the atmosphere. Assembly Bill (AB) 1493 was enacted in September 2003 and requires regulations to achieve “the maximum feasible reduction of greenhouse gases” emitted by vehicles used for personal transportation. On June 1, 2005, Governor Schwarzenegger issued Executive Order S-3-05, which set the following GHG emission reduction targets: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; and by 2050, reduce GHG emissions to 80 percent below 1990 levels. The California Environmental Protection Agency formed a Climate Action Team that recommended strategies that can be implemented by State agencies to meet GHG targets.

In September 2006, AB 32 was signed into law by Governor Arnold Schwarzenegger, focusing on achieving GHG emissions equivalent to statewide levels in 1990 by 2020. It mandates that CARB establish a quantified emissions cap, institute a schedule to meet the cap, implement regulations to reduce statewide GHG emissions from stationary sources, and develop tracking, reporting, and enforcement mechanisms to ensure that reductions are achieved. A companion bill, Senate Bill (SB) 1368, requires the California Public Utilities Commission and the California Energy Commission to establish GHG emission performance standards for the generation of electricity. These standards will also apply to power that is generated outside of California and imported into the State.

AB 32 charges CARB with the responsibility to monitor and regulate sources of GHG emissions. On June 1, 2007, CARB adopted three early action measures: setting a low carbon fuel standard, reducing refrigerant loss from motor vehicle air conditioning maintenance, and increasing methane capture from landfills.27 On October 25, 2007, CARB approved measures improving truck efficiency (i.e., reducing aerodynamic drag), electrifying port equipment, reducing PFCs from the semiconductor industry, reducing propellants in consumer products, promoting proper tire inflation in vehicles, and reducing sulfur hexaflouride emissions from the non-electricity sector. CARB determined that the total statewide aggregated GHG 1990 emissions level and 2020 emissions limit is 427 million metric tons of CO2e. The 2020 target reductions are currently estimated to be 174 million metric tons of CO2e.

CARB developed an AB 32 Scoping Plan that contains strategies to achieve the 2020 emissions cap. These include direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, and market-based mechanisms such as a cap-and-trade system. CARB also developed a mandatory reporting program on January 1, 2008 for large stationary combustion sources that emit more than 25,000 metric tons of CO2 per year and make up 94 percent of the point source CO2 emissions in California.

27California Air Resources Board, Proposed Early Action Measures to Mitigate Climate Change in California, April 20, 2007.



In response to SB 97, the Governor’s Office of Planning and Research (OPR) adopted CEQA guidelines that became effective on March 18, 2010. The amendments provide guidance to public agencies on analysis and mitigation of the effects of GHG emissions in CEQA documents, including:

Lead agencies should quantify all relevant GHG emissions and consider the full range of project features that may increase or decrease GHG emissions as compared to the existing setting;

Consistency with the CARB Scoping Plan is not a sufficient basis to determine that a project’s GHG emissions would not be cumulatively considerable;

A lead agency may appropriately look to thresholds developed by other public agencies, including the CARB’s recommended CEQA thresholds;

To qualify as mitigation, specific measures from an existing plan must be identified and incorporated into the project. General compliance with a plan, by itself, is not mitigation;

The effects of GHG emissions are cumulative and should be analyzed in the context of CEQA’s requirements for cumulative impact analysis; and

Given that impacts resulting from GHG emissions are cumulative, significant advantages may result from analyzing such impacts on a programmatic level. If analyzed properly, later projects may tier, incorporate by reference, or otherwise rely on the programmatic analysis.

On September 30, 2008, SB 375 was instituted to help achieve AB 32 goals through regulation of cars and light trucks. SB 375 aligns three policy areas of importance to local government: (1) regional long-range transportation plans and investments; (2) regional allocation of the obligation for cities and counties to zone for housing; and (3) a process to achieve greenhouse gas emissions reductions targets for the transportation sector. It establishes a process for CARB to develop GHG emissions reductions targets for each region (as opposed to individual local governments or households). SB 375 also requires MPOs to prepare a Sustainable Communities Strategy (SCS) within the Regional Transportation Plan (RTP) that guides growth while taking into account the transportation, housing, environmental, and economic needs of the region. SB 375 uses CEQA streamlining as an incentive to encourage residential projects, which help achieve AB 32 goals to reduce GHG emissions. While SB 375 does not prevent CARB from adopting additional regulations, such actions are not anticipated in the foreseeable future.28

On October 24, 2008, CARB published draft guidance for setting interim GHG significance thresholds. This was the first step toward developing the recommended Statewide interim thresholds of significance for GHG emissions that may be adopted by local agencies for their own use. The guidance does not

28American Planning Association, California Chapter, Analysis of SB 375, http://www.calapa.org/-en/cms/?2841, accessed March 30, 2009.



attempt to address every type of project that may be subject to CEQA, but instead focuses on common project types that are responsible for substantial GHG emissions (i.e., industrial, residential, and commercial projects). CARB believes that thresholds in these sectors will advance climate objectives, streamline project review, and encourage in CEQA analyses of GHG emissions throughout the State.

Regional

The SCAQMD has convened a GHG CEQA Significance Threshold Working Group to provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents. Members of the working group include government agencies implementing CEQA and representatives from stakeholder groups that will provide input to the SCAQMD staff on developing GHG CEQA significance thresholds. On December 5, 2008, the SCAQMD Governing Board adopted interim GHG significance threshold for projects where the SCAQMD is lead agency. The SCAQMD has not adopted guidance for CEQA projects under other lead agencies.

Local

The City of Los Angeles has adopted its LA Green Plan that outlines goals and actions to reduce the generation of GHGs to 35 percent below 1990 levels. Key strategies include increasing the generation of renewable energy, improving energy conservation and efficiency, and changing land use patterns to reduce dependence on autos.

The City also adopted a Green Building Ordinance in April 2008 that calls for reduction of the use of natural resources for new development. Larger projects must be certified by the Leadership in Energy and Environmental Design (LEED), including:

New non-residential building or structure of 50,000 gross square feet or more of floor area;

New mixed-use or residential building of 50,000 gross square feet or more in excess of six stores;

New mixed-use or residential building of six or fewer stories consisting of at least 50 dwelling units in a building, which has at least 50,000 gross square feet of floor area, and in which at least 80 percent of the building’s floor area is dedicated to residential units;

The alteration or rehabilitation of 50,000 gross square feet or more of floor area in an existing non-residential building for which construction costs exceed a valuation of 50 percent of the replacement cost of the existing building;

The alteration of at least 50 dwelling units in an existing mixed-use or residential building, which has at least 50,000 gross square feet of floor area, for which construction costs exceed a valuation of 50 percent of the replacement cost of the existing building.



As construction and operation of the Project has the potential to generate greenhouse gas emissions, the Project’s generation of greenhouse gas emissions and consistency with plans will be analyzed in the EIR.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

VIII. Hazards and Hazardous Materials. Would the project:

a. Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials

b. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?

c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

d. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?

f. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for the people residing or working in the area?



Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

g. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

h. Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

Response a:

A significant impact may occur if a project involves use or disposal of hazardous materials as part of its routine operations and would have the potential to generate toxic or otherwise hazardous emissions that could adversely affect sensitive receptors.

The construction activities are anticipated to use typical, although potentially hazardous, construction materials, including vehicle fuels, paints, mastics, solvents, and other acidic and alkaline solutions that would require special handling, transport, and disposal. During operation, residential, retail, and office uses would store and use maintenance products, such as cleaning materials. Since the Project would require the transport, use, and disposal of hazardous materials, the potential for an impact exists. Therefore, this issue will be analyzed further in an EIR.

Response b:

A significant impact may occur if a project could potentially pose a hazard to nearby sensitive receptors by releasing hazardous materials into the environment through accident or upset conditions.

The buildings on the Site are approximately 38 years old and they may likely contain asbestos-containing-materials (ACMs) as well as lead-based-paint (LBP). Overhead electrical transmission and distribution lines and pole-mounted transformers that may contain polychlorinated biphenyls (PCBs) are also located on the Project Site. As an auto dealership and service center, hazardous petroleum products are also located on-site.

Therefore, construction activities may have the potential to expose construction workers and sensitive receptors in the Project area to hazards associated with accidental exposure to ACMs, LBP, PCBs, and/or petroleum products. Therefore, this issue will be analyzed further in an EIR.



Response c:

A significant adverse effect may occur if a project site is located within one-quarter mile of an existing or proposed school site and is projected to release toxic emissions which pose a health hazard beyond regulatory thresholds. The Project Site is located within 0.25 mile of the following schools:

Wildwood Middle School (private), 11811 West Olympic Boulevard (950 feet away)

Westview School (private), 11801 Mississippi Avenue (1,050 feet away)

The Project would use, at most, minimal amounts of hazardous materials for routine cleaning and maintenance. Since the Project would require the transport, use, and disposal of hazardous materials, the potential for an impact exists. Therefore, further analysis of this issue in an EIR is required.

Response d:

California Government Code Section 65962.5 requires various State agencies to compile lists of hazardous waste disposal facilities, unauthorized releases from underground storage tanks, contaminated drinking water wells and solid waste facilities where there is known migration of hazardous waste and submit such information to the Secretary for Environmental Protection on at least an annual basis.

A significant impact may occur if a project site is included on any of the above lists and poses an environmental hazard to surrounding sensitive uses. Because the types of land uses on the Project Site (auto dealership and service center) include the use and dispose of auto-related hazardous chemicals and processes, it is likely that the Project Site could be listed according to Government Code Section 65962.5. Therefore, this issue will be analyzed further in an EIR.

Responses e and f:

A significant impact may occur if a project is located within two miles of a public airport, and subject to a safety hazard or within the vicinity of a private airstrip. Santa Monica Airport is approximately 5,000 feet south of the Site and Los Angeles International Airport (LAX) is approximately 6 miles south of the Site. The Project is not located in the vicinity of a private airstrip.

Although the Project is within two miles of the Santa Monica Airport, there are substantial and varied land uses and other urban infrastructure (including the I-10 Santa Monica Freeway) between the airport and the Site to ensure that there would be no potential hazard. There are buildings in the area that are equivalent in height as the Project. Further, the airport’s runway layout (east-west) would ensure the flight



paths do not cross over the Site. Finally, the Project is not within an Airport Hazard area.29 Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Response g:

A significant impact may occur if a project were to interfere with roadway operations used in conjunction with an emergency response plan or emergency evacuation plan or would generate traffic congestion that would interfere with the execution of such a plan. The construction activities have the potential to impede public access or travel upon public rights-of-way as well as interfere with any adopted emergency response or evacuation plan. Therefore, this issue will be analyzed further in an EIR.

Response h:

A significant impact may occur if a project is located in proximity to wildland areas and poses a potential fire hazard, which could affect persons or structures in the area in the event of a fire.

The Project Site is not located in a Very High Fire Hazard Severity Zone.30 The Project Site is not located within a designated Fire Buffer Zone or Mountain Fire District.31 The nearest potential area for fire hazard is the base of the Santa Monica Mountains along Sunset Boulevard, approximately 2 miles north of the Site. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

IX. Hydrology And Water Quality. Would the project:

a. Violate any water quality standards or waste discharge requirements?

b. Substantially deplete groundwater supplies or interfere with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned land uses for which permits have been granted)?

29 City of Los Angeles, ZIMAS Parcel Profile Report, website: http://zimas.lacity.org,October 15, 2012. 30 City of Los Angeles, ZIMAS Parcel Profile Reports, website: http://zimas.lacity.org, October 16, 2012. 31 City of Los Angeles, Safety Element, Exhibit D, Selected Wildfire Hazard Areas in the City of Los Angeles:




Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site?

d. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off site?

e. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

f. Otherwise substantially degrade water quality?

g. Place housing within a 100-year flood plain as mapped on federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?

h. Place within a 100-year flood plain structures which would impede or redirect flood flows?

i. Expose people or structures to a significant risk of loss, inquiry or death involving flooding, including flooding as a result of the failure of a levee or dam?

j. Inundation by seiche, tsunami, or mudflow?

Response a:

A significant impact may occur if a project discharges water that does not meet the quality standards of agencies that regulate surface water quality and water discharge into stormwater drainage systems. Significant impacts would also occur if a project does not comply with all applicable regulations with regard to surface water quality as governed by the State Water Resources Control Board (SWRCB). These regulations include compliance with the Standard Urban Storm Water Mitigation Plan (SUSMP) requirements to reduce potential water quality impacts.



The Project involves the development of residential, retail, and office uses on land that is currently developed with an auto dealership and service center. Development of the Project has the potential to alter the existing surface water runoff drainage pattern and rainfall absorption, causing a net increase of rates of storm water discharge. The Project’s potential to violate any water quality standards or waste discharge requirements will be further analyzed in an EIR.

Response b:

A significant impact may occur if a project includes deep excavations which have the potential to interfere with groundwater movement, or includes withdrawal of groundwater or paving of existing permeable surfaces that are important to groundwater recharge.

The Project does not propose any permanent groundwater wells or pumping activities. All water supplied to the Site would be derived from the City’s existing water supply and infrastructure. The Site is currently completely paved and impervious surfaces are minimal, mainly around the outer boundary along the sidewalks and at the corner of Bundy Drive and Olympic Boulevard.

The Project has the potential to include more landscaping and pervious surfaces than the existing uses. The construction of the Project would include excavation and could possibly require dewatering. The EIR will provide additional analysis to assess the Project’s potential to result in hydrology and water quality impacts, including the need for dewatering the Site, and any required mitigation measures.

Response c:

A significant impact may occur if a project would substantially alter drainage patterns resulting in a significant increase in erosion or siltation during construction or operation of a project. There are no natural watercourses on the Project sites.

The Project Site is developed and has minimal ornamental trees and landscaping. Grading and construction activities may temporarily alter the existing drainage patterns of the Site. If not properly designed, the Project could result in erosion and siltation during construction and operation. The EIR will provide additional analysis to assess the Project’s potential to result in hydrology and water quality impacts, including analysis of increases in siltation, the adequacy of the proposed drainage plans, and the use of best management practices during construction.

Response d:

A significant impact may occur if a project results in increased runoff volumes during construction or operation of the project would result in flooding conditions affecting the project site or nearby properties.

Grading and construction activities on the Project Site may temporarily alter the existing drainage patterns and reduce off-site flows. The EIR will provide additional analysis to assess the Project’s potential to



result in hydrology and water quality impacts, including the changes in on-site drainage patterns, any changes in runoff volumes, the available storm drain system capacity off-site, and the adequacy of the proposed grading and drainage plan.

Response e:

A significant impact may occur if a project would increase the volume of storm water runoff to a level which exceeds the capacity of the storm drain system serving a project site, or if the Proposed Project would introduce substantial new sources of polluted runoff.

As with any construction project, construction of the Project could contribute to the degradation of existing surface water quality conditions primarily due to: 1) potential erosion and sedimentation during the grading phase; 2) particulate matter from dirt and dust generated on the sites; and 3) construction activities and equipment. The EIR will provide additional analysis to assess the Project’s potential to result in hydrology and water quality impacts, including the adequacy of the proposed drainage plan, best management practices (BMPs), as well as existing water quality regulations and standards.

Response f:

The Project could involve the use of contaminants (typically used for residential and retail/office cleaning) that could potentially degrade water quality if not properly handled and stored. Therefore, the EIR will provide additional analysis to assess the Project’s potential to result in hydrology and water quality impacts.

Response g-h:

The Project Site is not located within an area identified by Federal Emergency Management Agency (FEMA) as potentially subject to 100-year floods.32

The Project Site is not located within a City-designated 100-year or 500-year flood plain. The nearest City designated flood plain is along Bundy Drive, from Wilshire Boulevard to San Vicente Boulevard, and along Santa Monica Boulevard, from Veteran Avenue to the City of Beverly Hills city limits.33

The Project would not introduce people or structures to an area of high flood risk. Therefore, the Project would not contain any significant risks of flooding and would not have the potential to impede or redirect floodwater flows. No impact would occur and no further analysis of this issue is required.

32 FEMA, Flood Maps, #: 06037C1590F: https://msc.fema.gov/webapp/wcs/stores/servlet/CategoryDisplay, accessed October 16, 2012.

33 City of Los Angeles, Safety Element, Exhibit F, 100-Year & 500-Year Flood Plains in the City of Los Angeles: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, accessed October 16, 2012.



Response i:

A significant impact may occur if a project were located in an area where flooding, including flooding associated with dam or levee failure, would expose people or structures to a significant risk of loss, injury, or death. The Project Site is located approximately 5 miles southwest of the Stone Canyon Reservoir. The Project Site is within the City-designated potential inundation area of the Reservoir, as is much of west Los Angeles around the I-405 and I-10 freeways.34 As such, the EIR will further analyze impacts related to potential inundation from the failure of a levee or dam.

Response j:

A significant impact may occur if a project is sufficiently close to the ocean or other water body to be potentially at risk of the effects of seismically-induced tidal phenomena (i.e., seiche and tsunami) or if the project site is located adjacent to a hillside area with soil characteristics that would indicate potential susceptibility to mudslides or mudflows.

The Project Site is not located in a Tsunami Hazard Area,35 Tsunami Inundation Zone,36 and is located approximately three miles inland from the Pacific Ocean and is not near any other major water bodies.

Therefore, risks associated with seiches or tsunamis would be considered extremely low at the Project Site. The Site is also not in or near a hillside area that could become a mudflow.37 No impact would occur and no further analysis of this issue is required

Potentially

Significant Impact


Mitigation

Incorporated

Less Than


X. Land Use And Planning. Would the project:

a. Physically divide an established community?

b. Conflict with applicable land use plan, policy or regulation of an agency with jurisdiction over the project (including but not limited to the general plan, specific plan, coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental

34 City of Los Angeles, Safety Element, Exhibit G, Inundation & Tsunami Hazard Areas in the City of Los Angeles: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, accessed October 16, 2012.

35 City of Los Angeles, Safety Element, Exhibit G, Inundation & Tsunami Hazard Areas in the City of Los Angeles: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf, accessed October 16, 2012.

36 City of Los Angeles, ZIMAS Parcel Profile Report, website: http://zimas.lacity.org/, accessed October 16, 2012. 37 City of Los Angeles, ZIMAS Parcel Profile Reports, website: http://zimas.lacity.org/, accessed October 16, 2012.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


effect?

c. Conflict with any applicable habitat conservation plan or natural community conservation plan?

Response a:

A significant impact may occur if a project is sufficiently large enough or otherwise configured in such a way as to create a physical barrier within an established community (a typical example would be a project which involved a continuous right-of-way such as a roadway which would divide a community and impede access between parts of the community).

The Project would not create a physical barrier in an established community, but would instead convert a single-use land parcel (auto dealership), into a multi-use area consisting of residential, retail, and office uses. No impact would occur and no further analysis of this issue is required

Response b:

A significant impact may occur if a project is inconsistent with the General Plan or zoning designations currently applicable to the Project Site and would cause adverse environmental effects, which the General Plan and zoning ordinance are designed to avoid or mitigate. The Project is inconsistent with the General Plan and zoning designations for the Project Site and would therefore require several discretionary actions by the City, including a zone change from M2-1 to C2-2D and a General Plan Amendment from “Light Industrial” to “General Commercial,” to allow for development of the Project. As such, the EIR will further analyze the land use impacts of the Proposed Project.

The Project will include a Land Use Equivalency Program (LUEP) to allow development flexibility of the Project’s land uses and floor areas so that the Project could, if necessary, respond to the changing needs of the Southern California economy. The LUEP will define a framework within which a mix of land uses could be modified within the development envelope defined by the approved entitlements without resulting in any new significant impacts. Therefore, the Site Plan, included as Figure 3, represents a “concept plan,” but the timing and nature of actual development would respond to market conditions and be subject to the allowances and limitations set forth by the LUEP.

As such, the Project has the potential to conflict with applicable land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. The EIR will provide additional analysis to assess the Project’s consistency with applicable General Plan policies, zoning code restrictions, Southern California Association of Governments (SCAG) policies, any other applicable City plans, and any required mitigation measures.



Response c:

A significant impact may occur if a project is inconsistent with policies in any draft or adopted conservation plan.


The Site is not located in or adjacent to an existing City or County Significant Ecological Area.38 Additionally, there is no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan that applies to the Project Site. Implementation of the Project would not conflict with any habitat conservation plans. Therefore, no impact would occur. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XI. Mineral Resources. Would the project:

a. Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?

b. Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan?

Response a:

A significant impact may occur if a project is located in an area used or available for extraction of a regionally-important mineral resource, and if the Project converted an existing or potential future regionally-important mineral extraction use to another use, or if the Project affected access to a site used or potentially available for regionally-important mineral resource extraction.

The Project Site is not located within a City-designated oil field or oil drilling area,39 or a City-designated Mineral Resource Zone 2 Area (MRZ-2). The Project would have no impact with respect to loss of availability of a known regionally-important mineral resource. Therefore, no impact would occur and no mitigation measures would be required. Further evaluation of this issue in an EIR is not required.

38 http://navigatela.lacity.org/index01.cfm, Significant Ecological Area layer; October 15, 2012. 39 City of Los Angeles, Safety Element, Exhibit E, Oil Fields and Oil Drilling Areas in the City of Los Angeles:




Response b:

A significant impact may occur if a project is located in an area used or available for extraction of a locally-important mineral resource extraction, and if the Project converted an existing or potential future locally-important mineral extraction use to another use, or if the Project affected access to a site used or potentially available for locally-important mineral resource extraction. Government Code Section 65302(d) states that a conservation element of the general plan shall address “minerals and other natural resources.”

According to the Conservation Element of the City of Los Angeles General Plan, sites that contain potentially significant sand and gravel deposits which are to be conserved follow the Los Angeles River flood plain, coastal plain, and other water bodies and courses and lie along the flood plain from the San Fernando Valley through downtown Los Angeles. Much of the area identified has been developed with structures and is inaccessible for mining extraction.40

Furthermore, the Project Site is presently developed and is located in an urbanized area. Development of the Project would not result in impacts associated with the loss or availability of a known mineral resource that would be of value to the region and the residents of the state. Therefore, no impact would occur and no mitigation measures would be required. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XII. Noise. Would the project:

a. Exposure of persons to or generation of noise in level in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?

b. Exposure of people to or generation of excessive groundborne vibration or groundborne noise levels?

c. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

d. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?

40 City of Los Angeles, Conservation Element of the City of Los Angeles General Plan, September 16, 2001; pg II-57.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?

f. For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels?

Response a:

A significant impact may occur if the Project would generate excess noise that would cause the ambient noise environment at the Project Site to exceed noise level standards set forth in the City of Los Angeles General Plan Noise Element (Noise Element) and the City of Los Angeles Noise Ordinance (Noise Ordinance). Construction of the Project would require the use of construction equipment during grading, excavation, hauling, establishing building foundations, and other construction activities. The concurrent use of construction equipment and machinery has the potential to increase noise levels above the applicable standards of the City’s Noise Ordinance.

Existing on-site noise sources include vehicles going for service and the related auto dealership uses. Development of the Project would change and potentially increase the activities that would occur on the Project Site by including residential uses along with retail and office uses. Noise levels from on-site sources also have the potential to increase during Project operation. In addition, the traffic attributable to the Project has the potential to cause noise levels to exceed City Noise Ordinance standards. Therefore, this issue will be analyzed further in an EIR.

Response b:

A significant impact would occur if the Project were to generate or expose people to excessive groundborne vibration or groundborne noise levels. Construction of the Project would require the use of heavy construction equipment during grading, excavation, hauling, establishing building foundations, and other construction activities. The concurrent use of earthmoving equipment and machinery has the potential to cause groundborne vibration and noise.

During Project operation, ground-borne vibration may also emanate from increased road traffic or other on-site activities. Therefore, this issue will be analyzed further in an EIR.



Response c:

A significant impact may occur if the operation of the Project would introduce substantial new sources of noise or would substantially add to existing sources of noise within the vicinity of the Project Site. Traffic and human activity associated with the Project has the potential to increase ambient noise levels above existing levels. Therefore, this issue will be analyzed further in an EIR.

Response d:

A significant impact may occur if a project were to introduce substantial new sources of noise or substantially add to existing sources of noise within or in the vicinity of the Project Site during construction of the Project or on a periodic basis during the operation of the Proposed Project.

Construction activity attributable to the Project has the potential to temporarily or periodically increase ambient noise levels above existing levels. In addition, the increase in on-site uses may also result in periodic increases in noise levels. Therefore, this issue will be analyzed further in an EIR.

Response e:

A significant impact may occur if a project is located within an airport land use plan and would introduce substantial new sources of noise or substantially add to existing sources of noise within or in the vicinity of the Project Site during construction of the Proposed Project.

Santa Monica Airport is approximately 5,000 feet south of the Site and Los Angeles International Airport (LAX) is approximately 6 miles south of the Site. The Project is not located in the vicinity of a private airstrip.

Although the Project is within two miles of the Santa Monica Airport, there are substantial and varied land uses and other urban infrastructure (including the I-10 Santa Monica Freeway) between the airport and the Site to ensure that there would be no potential hazard. There are buildings in the area that are equivalent in height as the Project.

Due to the distance, and other intervening uses, including the Santa Monica Freeway, development of the Project is not expected to expose people residing or working in the Project area to excessive noise levels from an airport use. However, this issue will be analyzed further in an EIR.

Response f:

This question would apply to a project only if it were in the vicinity of a private airstrip and would subject area residents and workers to a safety hazard. There are no private airstrips in the vicinity of the Project Site. Development of the Project would not expose people residing or working in the Project area to



excessive noise levels from an airport use. Therefore, no impact would occur and no mitigation measures would be required. Further evaluation of this issue in an EIR is not required.

Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XIII. Population And Housing. Would the project:

a. Induce substantial population growth in an area either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?

b. Displace substantial numbers of existing housing necessitating the construction of replacement housing elsewhere?

c. Displace substantial numbers of people necessitating the construction of replacement housing elsewhere?

Response a:

A significant impact may occur if a project would locate new development such as homes, businesses, or infrastructure, with the effect of substantially inducing population growth that would otherwise not have occurred as rapidly or in as great a magnitude. The Project includes new residential units to a Site that currently has no residential uses. The Project would result in the generation of jobs (both for construction and operation) and would also result in an increased residential population at the Site. Therefore, this issue will be further analyzed in an EIR.

Response b:

A significant impact may occur if a project would result in displacement of a substantial number of existing housing units, necessitating construction of replacement housing elsewhere. The Project Site does not include existing residential uses and would not displace substantial number of existing housing. Therefore, no impact would occur and further evaluation of this issue in an EIR is not required.

Response c:

A significant impact may occur if a project would result in displacement of existing residents, necessitating the construction of replacement housing elsewhere. The Project Site does not include existing residential uses and would not displace substantial number of people. Therefore, no impact would occur and further evaluation of this issue in an EIR is not required.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XIV. Public Services. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:

a. Fire protection?

b. Police protection?

c. Schools?

d. Parks?

e. Other governmental services (including roads)?

Response a:

A significant impact may occur if the City of Los Angeles Fire Department (LAFD) could not adequately serve the Project based upon response time, access, or fire hydrant/water availability, necessitating the construction of a new or physically altered facility.

The Project is served by LAFD Station No. 59, located at 11505 West Olympic Boulevard,41 approximately 3,400 feet east. The potential impact of the Project on fire protection services will be analyzed in the EIR.

Response b:

A significant impact may occur of the City of Los Angeles Police Department (LAPD) could not adequately serve the Project, necessitating a new or physically altered station. If existing service capacities are exceeded, new facilities, equipment and/or personnel may be required to maintain acceptable response times and service levels.

41 LAFD, station: http://lafd.org/fs59.htm, accessed October 16, 2012.



The Project is served by the LAPD West Los Angeles Community Police Station, located at 1663 Butler Avenue,42 approximately 1.05 miles northeast. The potential impacts of the Project on police protection services will be analyzed in the EIR.

Response c:

A significant impact may occur if a project includes substantial employment or population growth, which could generate a demand for school facilities that would exceed the capacity of the Los Angeles Unified School District (LAUSD). The Project would directly impact local schools by providing new residential units, and indirectly impact schools by providing jobs that may cause employees with families to relocate to an area. Thus, the potential impact of the Project on school facilities will be analyzed in the EIR.

Response d:

A significant impact would occur if the available City of Los Angeles Department of Recreation and Parks (LADRP) recreation and park services could not accommodate a project, necessitating new or physically altered facilities, the construction of which could cause significant environmental impacts.

The Project includes residential uses that have the potential to impact parks since they generate a permanent increase in residential population. The EIR will evaluate the Project’s on-site open space and recreational amenities and will determine the Project’s impacts upon public park facilities.

Response e:

A significant impact may occur if a project includes substantial employment or population growth that could generate a demand for other public facilities (such as libraries), which would exceed the capacity available to serve the Project Site, necessitating a new or physically altered library, the construction of which would have significant physical impacts on the environment. The Project Site is served by the Los Angeles Public Library (LAPL). Residential developments typically have the greatest potential to result in impacts to libraries since they generate a permanent increase in residential population. The EIR will evaluate the Project’s impacts upon library facilities.

42 LAPD station: http://www.lapdonline.org/west_la_community_police_station, accessed October 16, 2012.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XV. Recreation.

a. Would the project 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?

b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?

Response a:

A significant impact may occur if the Project would include substantial employment or population growth that could generate an increased demand for public park facilities which exceeds the capacities of existing parks and/or cause premature deterioration of the park facilities. The Project involves the construction of new residential uses that could increase the demand for neighborhood and regional parks and recreational facilities in the area. While on-site open space and recreational amenities will be included within the Project designs, there is the potential to increase demands upon several public park facilities located within the Project area. The EIR will evaluate the potential of the Project to cause an increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur will be analyzed in the EIR.

Response b:

The Project does not include any public recreational facilities. However, the development of the Project has the potential to increase demands upon recreational facilities that may require the construction of new facilities or the expansion of existing facilities. The construction of these facilities may have an adverse physical effect on the environment. Therefore, the potential of such facilities to have an adverse effect on the environment will be analyzed in the EIR.



Potentially

Significant Impact


Mitigation

Incorporated

Less Than


XVI. Transportation/Traffic.

Would the project:

a. Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit?

b. Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways?

c. Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks?

d. Substantially increase hazards to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

e. Result in inadequate emergency access?

f. Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities?

Response a:

A significant impact would occur if the Project generated traffic at each study intersection would exceed City of Los Angeles Department of Transportation (LADOT) standards. The Project is very near the boundary with the City of Santa Monica, and there is the potential that some study intersections would be located within this neighboring jurisdiction.

According to LADOT policy, a significant project impact would occur when the Critical Movement Analysis (CMA) value increases by 0.010 or more when the final Level of Service (LOS) at a given study intersection is E or F, by 0.020 or more when the final LOS is D, or by 0.040 or more when the final LOS is C.



The City of Santa Monica prefers to evaluate the operations of signalized intersections within its jurisdiction based on the signalized intersection analysis methodologies described in the Highway Capacity Manual (HCM)

The Project is within the jurisdiction of the West Los Angeles Transportation Improvement and Mitigation Specific Plan. The potential impacts of the Project would be evaluated in accordance with the assumptions, methodology, and procedures approved by LADOT. It is unknown at this time whether the Project may result in a potentially significant traffic impact during operation and construction. Therefore, this issue will be analyzed further in an EIR.

Response b:

A significant impact may occur if adopted California Department of Transportation (Caltrans) and County of Los Angeles Metropolitan Transit Authority (Metro) thresholds are exceeded. The Congestion Management Program (CMP) was adopted to regulate and monitor regional traffic growth and transportation improvement programs. The CMP designates a transportation network which includes all state highways and some arterials within the County of Los Angeles. If the level of service standard deteriorates on the CMP network, then local jurisdictions must prepare a deficiency plan that is in conformance with the Los Angeles County CMP. The intent of the CMP is to provide information to decision makers to assist in the allocation of transportation funds through the State Transportation Improvement Program (STIP) process.

A CMP traffic impact analysis is required if a project would add 150 or more trips to the freeway, in either direction during either the AM or PM weekday peak hour. An analysis is also required at all CMP monitoring intersections where a project would add 50 or more peak hour trips. The local CMP requires that all CMP monitoring intersections be analyzed where a project would likely add 50 or more trips during the peak hours. It is unknown at this time whether the Project would result in a potentially significant traffic impact at any CMP monitoring locations. Therefore, this issue will be analyzed further in an EIR.

Response c:

A significant impact would occur if a proposed project included an aviation-related use and would result in safety risks associated with such use. The Project does not include any aviation-related uses. While the Project is within two miles of an airport (the Santa Monica Airport), it is not within an Airport Hazard area.43 Safety risks associated with a change in air traffic patterns would not occur. Therefore, no impact would occur and no mitigation measures would be required. Further evaluation of this issue in an EIR is not required.

43 City of Los Angeles, ZIMAS Parcel Profile Report, website: http://zimas.lacity.org,October 15, 2012.



Response d:

A significant impact may occur if a project includes new roadway design or introduces a new land use or project features into an area with specific transportation requirements, characteristics, or project access or other features designed in such a way as to create hazardous conditions. It is unknown at this time whether the Project may increase hazards due to a design feature or incompatible uses. Therefore, this issue will be analyzed further in an EIR.

Response e:

A significant impact may occur if a project design does not provide emergency access meeting the requirements of the LAFD or in any other way threatens the ability of emergency vehicles to access and serve the project site or adjacent uses. The increased traffic and population due to the residential units and the retail and office uses on-site could obstruct emergency vehicle access to the Project Site. Therefore, the EIR will provide additional analysis to assess the Project’s potential to result in traffic impacts.

Response f:

A significant impact may occur if a project would conflict with adopted policies or involve modification to existing alternative transportation facilities located on- or off-site. The potential of the Project to conflict with adopted policies, plans, and programs supporting alternative transportation will be analyzed in the EIR.

Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

XVII. Utilities and Service Systems. Would the project:

a. Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?

b. Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

c. Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

d. Have sufficient water supplies available to serve the project from existing entitlements and resource, or are new or expanded entitlements needed?



Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

e. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

f. Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?

g. Comply with federal, state, and local statutes and regulations related to solid waste?

Response a:

A significant impact would occur if a project exceeds wastewater treatment requirements of the applicable Regional Water Quality Control Board. The City of Los Angeles Department of Public Works provides wastewater services for the Project Site. Wastewater discharges are conveyed to the Hyperion Treatment Plant (HTP), which is a public facility and is therefore subject to the State’s wastewater treatment requirements which, in the Project area, are enforced by the LARWQCB. The HTP has a current capacity of 450 million gallons per day (mgd). The potential of the Project to exceed wastewater treatment requirements of the LARWQCB will be analyzed in the EIR.

Response b:

A significant impact may occur if a project would increase water consumption or wastewater generation to such a degree that the capacity of facilities currently serving the site would be exceeded. The Project is assumed to increase water usage and wastewater generated as compared to the existing uses on the Project Site. Therefore, the Project may result in a significant impact with respect to the capacity of the water and wastewater treatment plants and the existing water and sewer lines. Potential impacts to the public water and wastewater infrastructure system will be analyzed within the scope of the EIR.

Response c:

A significant impact may occur if the volume of stormwater runoff were to increase to a level exceeding the capacity of the storm drain system serving the Project Site, to the extent that existing facilities would need to be expanded. The potential of the Project to result in the construction of new or expanded stormwater facilities will be analyzed in the EIR.

Response d:

A significant impact may occur if a project were to increase water consumption to such a degree that new



water sources would need to be identified, or that existing resources would be consumed at a pace greater than planned for by purveyors, distributors, and service providers.

The Project is assumed to consume an increase in water as compared to the existing developments on the Project Site. Therefore, the Project may result in a significant impact with respect to water supply. As such, impacts with respect to water supply will be analyzed within the scope of the EIR.

Response e:

A significant impact may occur if a project would increase wastewater generation to such a degree that the capacity of facilities currently serving the Project Site would be exceeded. The Project is assumed to generate an increase in wastewater as compared to the existing development on the Project Site. Therefore, the Project may result in a significant impact with respect to the capacity of the wastewater treatment plant serving the Project Site. Therefore, potential impacts related to wastewater treatment plant capacity and availability will be analyzed within the scope of the EIR.

Response f:

A significant impact may occur if a project were to increase solid waste generation to a degree such that the existing and projected landfill capacity would be insufficient to accommodate the additional solid waste. The potential impacts associated with the ability of the local landfills to serve the Project will be analyzed in the EIR.

Response g:

Solid waste management is guided by the California Integrated Waste Management Act of 1989, which emphasizes resource conservation through reduction, recycling, and reuse of solid waste. The Act requires that localities conduct a Solid Waste Generation Study (SWGS) and develop a Source Reduction Recycling Element (SRRE). The City of Los Angeles prepared a Solid Waste Management Policy Plan that was adopted by the City Council in 1994.

Solid waste generated on-site by the Project would be disposed of in accordance with all applicable federal, state, and local regulations and policies related to solid waste, including (but not limited to) AB 939, CiSWMPP, SRRE, Ordinance No. 171687 and the Framework Element of the General Plan. The Project developer would provide clearly marked, durable, source sorted recycling bins throughout the Project Site to facilitate recycling in accordance with Ordinance No. 171687. The Project would comply with federal, state, and local statutes and regulations related to solid waste. Therefore, a less than significant impact would occur and no mitigation measures would be required. Further evaluation of this issue in an EIR is not required.



Potentially

Significant Impact


Mitigation

Incorporated


Impact No Impact

XVIII. Mandatory Findings Of Significance.

a. Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

b. Does the project have impacts which are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects).

c. Does the project have environmental effect is which cause substantial adverse effects on human beings, either directly or indirectly?

Response a:

Based on the analysis contained in this Initial Study, the Project has the potential to result in significant impacts with regard to the issues addressed herein. Therefore, the Project has the potential to degrade the quality of the environment. An EIR will be prepared to analyze and document these potentially significant impacts. All feasible mitigation measures will be identified to reduce the identified significant impacts.

Response b:

The potential for cumulative impacts occurs when the independent impacts of the project are combined with the impacts of related projects in proximity to the Project Site such that impacts occur that are greater than the impacts of the Project alone. Located within the vicinity of the Project Site are other past, current, and/or reasonably foreseeable projects whose development, in conjunction with that of the Project, may contribute to potential cumulative impacts. Impacts of the Project on both an individual and cumulative basis will be addressed in an EIR.



Therefore, the potential for cumulative impacts related to aesthetics, air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services and recreation, transportation and traffic, and utilities and service systems resulting from the Project in conjunction with the applicable related projects will be analyzed and documented in an EIR.

The potential for significant cumulative impacts from the other environmental issues that are not to be evaluated and documented in the EIR can be assessed at this time. Cumulative impacts are concluded to be less than significant for those issues for which it has been determined that the project’s incremental contribution would be less than significant. Therefore, only those potential impacts of the project to be analyzed and documented in an EIR are concluded to have the potential for significant cumulative impacts

Response c:

Construction and operation of the Project could result in environmental effects that could have substantial adverse effects on human beings, either directly or indirectly. As a result, these potential effects will be analyzed further in an EIR.

DISCUSSION OF THE ENVIRONMENTAL EVALUATION (Attach additional sheets if necessary)

As noted above, the lead agency has determined that the proposed project may result in a significant effect on the environment, and an

environmental impact report is required.

PREPARED BY

Diana Kitching

TITLE

Planning Assistant

TELEPHONE

213-978-1342

DATE

Appendix A:

Cultural Resource Letters

South Central Coastal Information Center California State University, Fullerton Department of Anthropology MH-426 800 North State College Boulevard

Fullerton, CA 92834-6846 657.278.5395 / FAX 657.278.5542

anthro.fullerton.edu/sccic.html - [email protected] California Historical Resources Information System

Orange, Los Angeles, and Ventura Counties _______________________________________________________________________ November 27, 2012 SCCIC #12759.9492

Mr. Seth Wulkan CAJA Environmental Services 11990 West San Vicente Blvd., Ste.200 Los Angeles, CA 90049 (310) 469-6704

RE: Martin Expo Town Center Project

Dear Mr. Wulkan,

As per your request received on November 26, 2012, a records search was conducted for the above referenced project. The search includes a review of all recorded archaeological sites within a ½-mile radius of the project site as well as a review of cultural resource reports on file. In addition, the California Points of Historical Interest (SPHI), the California Historical Landmarks (SHL), the California Register of Historical Resources (CAL REG), the National Register of Historic Places (NRHP), the California State Historic Resources Inventory (HRI), and the City of Los Angeles Historic-Cultural Monuments (LAHCM) listings were reviewed for the above referenced project site. The following is a discussion of the findings.

Due to the sensitive nature of cultural resources, archaeological site locations are

not released.

Beverly Hills, CA USGS 7.5’ Quadrangle ARCHAEOLOGICAL RESOURCES:

One archaeological site (19-003803) has been identified on our maps within a

½-mile radius of the project site. No sites are located within the project site. This does not preclude the potential for archaeological sites to be identified during project activities. No isolates have been identified within a ½-mile radius of the project site. No isolates are located within the project site.

HISTORIC BUILT-ENVIRONMENT RESOURCES:

Four above-ground historic resources (19-189757, 19-189767, 19-189768, and

19-190027) have been identified on our maps within a ½-mile radius of the project site. No above-ground historic resources are located within the project site.

mailto:[email protected]

ADDITIONAL CULTURAL RESOURCE LISTINGS: The California Historic Resources Inventory (HRI) lists four properties that

have been evaluated for historical significance within a ½-mile radius of the project site (see enclosed list). These are additional resources that are listed in the Historic Properties Data file and are located either within the project site or within the search radius.

The California Point of Historical Interest (SPHI) of the Office of Historic

Preservation, Department of Parks and Recreation, lists no properties within a ½-mile radius of the project site.

The California Historical Landmarks (SHL) of the Office of Historic

Preservation, Department of Parks and Recreation, lists no properties within a ½-mile radius of the project site.

The California Register of Historical Resources (CAL REG) lists no properties within a ½-mile radius of the project site. These are properties determined to have a National Register of Historic Places Status of 1 or 2, a California Historical Landmark numbering 770 and higher, or a Point of Historical Interest listed after 1/1/1998.

The National Register of Historic Places (NRHP) lists no properties within a

½-mile radius of the project site.

The City of Los Angeles Historic-Cultural Monuments (LAHCM) lists no properties within the project site.

HISTORIC MAP REVIEW

Santa Monica, CA (1902 & 1921) 15’ USGS - indicated that in 1902, there was little to no visible development at the project site. There were two roads and one intermittent stream within the vicinity of the project area. The Southern Pacific Railroad (Santa Monica Branch) line ran south of the project site. In 1921, there was still little to no visible development at the project site; however, there was a significant amount of development within the vicinity of the project area. The project site was located within a dense urban environment with numerous roads and buildings present. The Southern Pacific Railroad was still present to the south of the project site and historic place names nearby included Sawtelle and Santa Monica. PREVIOUS CULTURAL RESOURCES INVESTIGATIONS:

Eleven studies (LA3729, LA4549, LA5031, LA5036, LA6505, LA9414, LA9453,

LA11114, LA11184, LA11305, and LA11793) have been conducted within a ½-mile radius of the project site. Of these, none are located within the project site. There are nineteen additional investigations located on the Beverly Hills, CA 7.5’ USGS Quadrangle that are potentially within a ½-mile radius of the project site. The reports are not mapped due to insufficient locational information.

RECOMMENDATIONS

Current surface conditions do not appear to allow for an adequate surface survey

of the project area. Based on the results of the records search and the project description, a halt-work condition should be in place for all ground disturbing activities. In the event that any pre-historic or historic cultural resources are found, all work within the vicinity of the find should stop until a qualified consultant can assess the finds and make recommendations. It is also recommended that any historic properties (45 years and older) in the area of potential effect be identified, recorded, and evaluated for local, state, or national significance prior to the approval of project plans. Finally, the Native American Heritage Commission should be consulted to identify if any additional traditional cultural properties or other sacred sites are known to be in the area.

The professional consultant you retain may request the records search map,

archaeological site records, and bibliography from the Information Center referencing the SCCIC number listed above for a fee (per the fee schedule). Any resulting reports by the qualified consultant should be submitted to the South Central Coastal Information Center as soon as possible.

If you have any questions regarding the results presented herein, please

contact the office at 657.278.5395 Monday through Thursday 9:00 am to 3:30 pm. Should you require any additional information for the above referenced project,

reference the SCCIC number listed above when making inquiries. Requests made after initial invoicing will result in the preparation of a separate invoice.

Sincerely, SCCIC

Lindsey Noyes Lead Staff Researcher

Enclosures:

(X) HRI – 2 pages (X) National Register Status Codes – 1 page (X) Invoice #12759.9492

California Historical Resource Status Codes

Properties listed in the National Register (NR) or the California Register (CR)1D Contributor to a district or multiple resOurce property listed in NR by the Keeper. Listed in the CR.iS Individual property listed in NR by the Keeper. Listed in the CR.

lCD Listed in the CR as a contributor to a district or multiple resource property by the SHRC1CS Listed in the CR as individual property by the SHRC.1CL Automatically listed in the California Register — Includes State Historical Landmarks 770 and above and Points of Historical

Interest nominated after December 1997 and recommended for listing by the SHRC.

2 PropertIes determined eligible for listing in the National Register (NR) or the California Register (CRy2B Determined eligible for NR as an individual property and as a contributor to an eligible district in a federal regulatory process.

Listed in the CR.2D Contributor to a district determined eligible for NR by the Keeper. Listed in the CR.2D2 Contributor to a district determined eligible for NR by consensus through Section 106 process. Listed in the CR.2D3 Contributor to a district determined eligible for NR by Part I Tax Certification. Listed in the CR.2D4 Contributor to a district determined eligible for NR pursuant to Section 106 without review by SHPO. Listed in the CR.25 Individual property’determined eligible for NR by the Keeper. Listed in the CR.2S2 Individual property determined eligible for NR by a consensus through Section 106 process. Listed in the CR.253 Individual property determined eligible for NR by Part I Tax Certification. Listed in the CR.2S4 Individual property determined eligible for NR pursuant to Section 106 without review by SHPO. Listed in the CR.

2CR Determined eligible for CR as an individual property arid as a contributor to an eligible district by the SHRC.2CD Contributor to a district determined eligible for listing in the CR by the SHRC.2CS Individual property determined eligible for listing in the CR by the SHRC.

3 Appe eligib1ei’r Ntsn gist R iF(ist€r (CR) hiuhSqvey Ealuatioi3B Appears eligible for NR both indMdually and as a contributor to a NR eligible district through survey evaluation.3D Appears eligible for NR as a contributor to a NR eligible district through survey evaluation.3S Appears eligible for NR as an individual property through survey evaluation.

3CR Appears eligible for CR both individually and as a contributor to a CR eligible district through a survey evaluation.3C0 Appears eligible for CR as a contributor to a CR eligible district through a survey evaluation.3CS Appears eligible for CR as an individual property through survey evaluation.

4 Appear ehg,bte for Natidnal Regisej(NFJ aJionReister (CR) tirougljother eialuaton4CM Master List - State Owned Properties — PRC 55024.

5 Properties Recognized aHistorIcalIy SnifiLct6yiocal 6overnment5D1 Contributor to a district that is listed or designated locally,5D2 Contributor to a district that is eligible for local listing or designation.5D3 Appears to be a contributor to a district that appears eligible for local listing or designation through survey evaluation.

5S1 Individual property that is listed or designated locally.5S2 Individual property that Is eligible for local listing or designation.5S3 Appears to be individually eligible for local listing or designation through survey evaluation.

58 Locally significant both individually (listed, eligible, or appears eligible) and as a contributor to a district that is locally listed,designated, determined eligible or appears eligible through survey evaluation.

6.6C Determined ineligible for or removed from California Register by SHRC.6] Landmarks or Points of Interest found ineligible for designation by SHRC.6L Determined ineligible for local listing or designation through local government review process; may warrant special consideration

in local planning.6T Determined ineligible for NR through Part I Tax Certification process.6U Determined ineligible for NR pursuant to Section 106 without review by SHPO.6W Removed from NR by the Keeper.6X Determined ineligible for the NR by SHRC or Keeper.6Y Determined ineligible for NR by consensus through Section 106 process — Not evaluated for CR or Local Listing.6Z Found ineligible for NR, CR or Local designation through survey evaluation.

7 Not Evaluated for National Register (NR) or California Register (CR) or Needs Revaluation7] Received by OHP for evaluation or action but not yet evaluated.7K Resubmitted to OHP for action but not reevaluated.7L State Historical Landmarks 1-769 and Points of Historical Interest designated prior to January 1998 — Needs to be reevaluated

using current standards.7M Submitted to CHP but not evaluated - referred to NPS.7N Needs to be reevaluated (Formerly NR Status Code 4)7N1 Needs to be reevaluated (Formerly NR SC4) — may become eligible for NR vJrestoration or when meets other specific conditions.7R Identified in Reconnaissance Level Suniey: Not evaluated.7W Submitted to OHP for action — withdrawn,

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Vertebrate Paleontology SectionTelephone: (213) 763-3325

Fax: (213) 746-7431e-mail: [email protected]

20 December 2012

CAJA Environmental Services, LLC11990 West San Vicente Boulevard, Suite 200Los Angeles, CA 90049

Attn: Seth Wulkan, Assistant Project Manager

re: Paleontological resources for the proposed Martin Expo Town Center Project, in the Cityof Los Angeles, Los Angeles County, project area

Dear Seth:

I have conducted a thorough search of our paleontology collection records for the localityand specimen data for the proposed Martin Expo Town Center Project, in the City of LosAngeles, Los Angeles County, project area as outlined on the portion of the Beverly Hills USGStopographic quadrangle map that you sent to me via e-mail on 26 November 2012. We do nothave any vertebrate fossil localities that lie within the proposed project site boundaries, but we dohave localities nearby from the same deposits as occur subsurface in the proposed project area.

The surficial deposits in the proposed project area consist of younger QuaternaryAlluvium beneath soil, primarily as alluvial fan deposits derived from the Santa MonicaMountains to the north. These deposits usually do not contain significant vertebrate fossils, atleast in the uppermost layers, but there are older Quaternary deposits exposed to the north andthey probably occur at relatively shallow depth in the proposed project area. Our closestvertebrate fossil locality in these older Quaternary deposits is LACM 5462, west-southwest of theproposed project area along Michigan Avenue east of Cloverfield Boulevard between OlympicBoulevard and the Santa Monica Freeway (I-10), and is particularly noteworthy because aspecimen of extinct lion, Felis atrox, was recovered from this locality at a depth of only six feet. Our next closest vertebrate fossil locality from the older Quaternary deposits is LACM 7879, justwest of south of the proposed project area at the Penmar Golf Course, that produced fossilsspecimens of horse, Equus, and ground sloth, Paramylodon, at 12 feet and 28 feet respectively

below the surface. Our next closest fossil vertebrate localities in older Quaternary deposits areLACM 5833, northeast of the proposed project area south of Wilshire Boulevard between Thayerand Westholme Avenues, that produced fossil specimens of horse, Equus, kangaroo rat,Dipodomys, wood rat, Neotoma, meadow vole, Microtus, and pocket gopher, Thomomys, andLACM 5501, east-northeast of the proposed project area south of Olympic Boulevard betweenAvenue of the Stars and Century Park East, that produced fossil specimens of pond turtle,Clemmys marmorata, dog, Canis, and horse, Equus, at shallow but unstated depth. Farther eastwe have numerous localities in the older Quaternary sediments that have produced fossilspecimens typical of the fauna from the Rancho La Brea asphalt deposits, that itself is about eightmiles east of the proposed project area.

Surface grading or very shallow excavations in the proposed project area probably willnot uncover significant vertebrate fossils. Deeper excavations that extend down below about fivefeet, however, may well encounter significant fossil vertebrate remains. Any substantialexcavations below the uppermost layers in the proposed project area, therefore, should bemonitored closely to quickly and professionally recover any fossil remains discovered while notimpeding development. Any fossils recovered during mitigation should be deposited in anaccredited and permanent scientific institution for the benefit of current and future generations.

This records search covers only the vertebrate paleontology records of the Natural HistoryMuseum of Los Angeles County. It is not intended to be a thorough paleontological survey ofthe proposed project area covering other institutional records, a literature survey, or any potentialon-site survey.

Sincerely,

Samuel A. McLeod, Ph.D.Vertebrate Paleontology

enclosure: invoice

martin expo town center initial study

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