Casden Sepulveda Project - LA City Planning Sections... · Final Environmental Impact Report Page i...

Department of City Planning

City Hall • 200 N. Spring Street, Room 601 • Los Angeles, CA 90012

FINAL ENVIRONMENTAL IMPACT REPORT WEST LOS ANGELES COMMUNITY PLAN AREA

Casden Sepulveda Project

Case No. ENV-2008-3989-EIR Council Districts Nos. 5 and 11

Development Project Location: 11122-11150 Pico Boulevard and 2431-2441 South Sepulveda Boulevard, Los Angeles, California 90064 Add Area Project Location: 11240, 11250, 11120, 11160, and 11110 Pico Boulevard, Los Angeles, California 90064 Development Project Description: The Proposed Development Project includes a mixed-use commercial and residential development, with commercial access along Pico and Sepulveda Boulevards and residential access along Sepulveda and Exposition Boulevards. Part of the Metro railroad easement at the southern portion of the site along Exposition Boulevard between Sepulveda Boulevard and Sawtelle Boulevard is planned for use as rail-line-related infrastructure associated with Phase II of the Metro’s Exposition Light Rail Transit Line (the “Expo Line”). The Development Project would provide Expo Line passengers with pedestrian access to both existing and planned bus stops on both Pico and Sepulveda Boulevards. The Development Project would include a total of approximately 266,800 square feet of retail commercial floor area and 538 residential units (of which 59 would be senior-affordable units), including 56 studios, 262 one-bedrooms, 201 two-bedroom units, and 19 three-bedroom units (approximately 518,764 residential square feet). The Development Project would provide a total of approximately 2,029 parking spaces combined for residential, commercial, and guest use, in compliance with Code requirements. These parking stalls would be provided in up to five subterranean parking levels located below the development. Add Area Project Description: The Proposed Add Area Project includes re-designation of three parcels from Light Industrial and Public Facilities to Community Commercial.

APPLICANTS: Development Project: Casden West LA, LLC

Add Area Project: City of Los Angeles

PREPARED BY: CAJA Environmental Services, LLC

November 2012

Casden Sepulveda Project Table of Contents Final Environmental Impact Report Page i

TABLE OF CONTENTS

Section Page

I. INTRODUCTION .........................................................................................................................I-1

II. LIST OF COMMENTERS .......................................................................................................... II-1

III. RESPONSES TO COMMENTS ................................................................................................ III-1

IV. CORRECTIONS AND ADDITIONS TO THE DRAFT EIR .................................................... IV-1

V. MITIGATION MONITORING REPORT PLAN ....................................................................... V-1

City of Los Angeles November 2012

Casden Sepulveda Project Table of Contents Final Environmental Impact Report Page ii

APPENDICES

Appendix A: Comment Letters

Appendix B: Project Trips on Freeways

Appendix C: Building Height Map

Appendix D: Traffic Counts

Appendix E: Supplemental Traffic Analysis

Appendix F: Information Request Letter for LAFD

Appendix G: Existing Cement Plant Traffic Counts

Casden Sepulveda Project I. Introduction Final Environmental Impact Report Page I-1

I. INTRODUCTION

A. INTRODUCTION

Before approving a project, the California Environmental Quality Act (CEQA) requires the lead agency to prepare and certify a Final Environmental Impact Report (Final EIR). The contents of a Final EIR are specified in Section 15132 of the CEQA Statute and Guidelines, as follows:

The Final EIR shall consist of:

(a) The Draft EIR or a revision of the Draft.

(b) Comments and recommendations received on the Revised Draft EIR either verbatim or in summary.

(c) A list of persons, organizations, and public agencies commenting on the Revised Draft EIR.

(d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.

(e) Any other information added by the lead agency.

The lead agency must provide each agency that commented on the Draft EIR with a copy of the lead agency’s proposed response at least 10 days before certifying the Final EIR.

B. BACKGROUND

The original public review period for the Draft EIR for the Casden Sepulveda Project was April 12, 2012 to May 29, 2012. The end of the public review period was extended to June 18, 2012. Several comment letters were submitted on the Draft EIR to the City and are included in Appendix A. Responses to all comments received are provided in Section III of the Final EIR.

C. ORGANIZATION OF FINAL EIR

Together with the Draft EIR, this document constitutes the Final EIR for the Project and includes the following sections:

Section I. Introduction: This section provides an introduction to the Final EIR.

Section II. List of Commenters: This section includes a list of the persons and agencies who submitted comments on the Draft EIR.

Section III. Responses to Comments: This section includes responses to each of the comments submitted by persons and agencies listed in Section II.


Casden Sepulveda Project I. Introduction Final Environmental Impact Report Page I-2

Section IV. Corrections and Additions to the Draft EIR: This section provides corrections and additions to the Draft EIR, based on comments received during and after the public review period and based on staff-initiated text changes.

Section V. Mitigation Monitoring Report Plan: This section includes all of the mitigation measures identified to reduce or avoid environmental impacts of the project and notes the monitoring phase, the enforcement phase, and the applicable department or agency responsible for ensuring that each mitigation measure is implemented.

Appendices: The appendices to this document include copies of all the comments received on the Draft EIR and additional information cited to support the responses to comments.

Casden Sepulveda Project II. List of Commenters Final Environmental Impact Report Page II-1

II. LIST OF COMMENTERS

The agencies and organizations/persons listed below provided written comments on the Draft EIR to the City of Los Angeles (the “City”) during and after the formal public review period from April 12, 2012 to June 18, 2012. Copies of the comments are included in Appendix A to this document.

PUBLIC AGENCIES

Caltrans Diana Watson, IGR/CEQA Program Manager District 7, Office of Regional Planning IGR/CEQA Branch 100 Main Street, MS #16 Los Angeles, CA 90012-3606

Los Angeles City Council Paul Kortez, Councilmember, Fifth District City Hall 200 N. Spring Street, Room 440 Los Angeles, CA 90012

Los Angeles Department of Water and Power Natali Kassis PO Box 51111 Los Angeles, CA 90051-0100

Metro Scott Hartwell, CEQA Review Coordinator One Gateway Plaza Los Angeles, CA 90012-2952

Native American Heritage Commission Dave Singleton, Program Analyst 915 Capitol Mall, Room 364 Sacramento, CA 95814

State Clearinghouse Scott Morgan, Director 1400 10th Street PO Box 3044 Sacramento, CA 95812-3044



PRIVATE AGENCIES/INDIVIDUALS

Elisabeth Abarbanel

Cary Adams

Kenneth Alpern

Deva Anderson

Toby Arenberg

Jack Barnett (sp)

Scott Beber (2329 South Bentley Avenue Homeowners Association)

Michelle Bekey

Adam Bersin

Mirja Bishop

Robert Bishop

Carolyn Broner

Roger Christensen

Demitra Cimiluca

Grant and Lynne Clark

Angela Coccio

Bennett and Marilyn Cohon

Sharon Commins

Jim Conger

Brian Considine (Westside Village Homeowners Association)

Richard Davis

Gerald Davison



Pamela Day

Pierre del Moral

Scott Diamond (Beverlywood Homes Association)

Marjoree Dunn

Peter Edwards

Phyllis Elliot

Pamela Emerson

Gayle Endo

Jennie Fahn

Peter Feit

David Feldman

Judith Fisher

Diana Frank

Sonya Frederick

Andrew Fuligni

Dorothy Garven

Sharon and Robert Georskey

Jeff Gold

Robert Goodman

Roger Goodman

Sarah Hays

Margaret Healy

Steven Heller



John Hensen

Matthew Hetz

Phillips Jamatas

Diane Kageyama

Arthur Kassan

Donald Keller (Brentwood Homeowners Association)

Erica Korody

Goran Lacan

Mark and Laura Lacter

Ryan Lawrence

Peter Leeb

Rodney Liber

Carol Linnell

Lone Logan

Judith Lovejoy

Gay Macdonald

Rose Maly

Doug Martin

Jane M. Mayer

Christopher McKinnon

Patricia McKnight

Michael Millman

Laura Moskowitz



Rae Moss

John Murdock

Tim Murphy

Name Illegible

Name Illegible 2

Name Illegible 3

Name Illegible 4

Ed and Elaine Newman

Anna Nikoltchev

Kathy Nixon

Irene Olavarria (sp)

David Oliver

Dennis Orfirer

Gary Paller

Mary Rose Pasic

Adele Plotkin

Bill Pope (I_ReACT)

Pam Posey

Joyce Purcell

Bita Rahebi

Jan Riechmann

Stephen Resnick

Craig Rich



Debbie Rosenthal

Jane S (sp)

Pari Samuels

Lisa Schechter

Hans Schieder

Sylvia Schiff

Elin Schwartz

Willa Seidenberg

Richard Shaw

Sanjay Sippy

Anne Smith

Keith Solomon

Howard Spector

Milly and Herman Stoller

Nancy Rae Stone

David Strick

Terri Tippit (Homeowners Association Coalition, Westside Neighborhood Council, West of Westwood Homeowners Association)

Pat Tobias

Laney Wald

Richard Wald

Jim Winett

Jae Wu



Jean Marie Wuilates (sp)



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Casden Sepulveda Project III. Responses to Comments Final Environmental Impact Report Page III-1

III. RESPONSES TO COMMENTS

A. INTRODUCTION

This section contains written responses to each of the comments on the Draft EIR received during and the public review period. The responses to comments are arranged by: 1) Responses to Public Agency Comments, and 2) Responses to Public Comments. As stated previously, all comments on the Draft EIR are included in Appendix A to this document and are grouped according to comments provided by government agencies and comments received from private individuals or organizations. The comment letters are then organized in alphabetical order by last name of the commenter. Each letter is identified by the last name of the commenter, and each comment is delineated and numbered. Corrections and additions to the Draft EIR resulting from comments and responses to comments are presented in Section IV (Corrections and Additions) of the Final EIR.

Responses to Public Agency Comments

Comment Letter Caltrans

Response to Comment Caltrans-1

This comment includes statements of fact about trip generation, traffic impacts, and mitigation measures presented in Section IV.N (Transportation/Traffic) of the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The Los Angeles County Congestion Management Program (“CMP”) does not require that freeway ramp operations be evaluated, other than where required as part of an analysis of potential project-related impacts to any CMP arterial monitoring intersection, which may constitute the terminus intersection of such ramps. However, as described in Section IV.N (Transportation/Traffic) of the Draft EIR, some traffic travelling to the Development Project site would use Interstate 405 (the “San Diego Freeway”) and Interstate 10 (the “Santa Monica Freeway”) to reach the general vicinity of the site, and then would exit the freeways via the nearest ramps to the Development Project site. A review of the freeway and surface street networks shown on Figure IV.N-1 on page IV.N-5 shows that these ramps are: the San Diego Freeway southbound off-ramp at Olympic Boulevard/Pico Boulevard (study intersection no. 21), the Santa Monica Freeway eastbound off-ramp at Pico Boulevard/34th Street (intersection no. 24), the San Diego Freeway northbound off-ramp at National Boulevard (intersection no. 46), and the Santa Monica Freeway westbound off-ramp at Overland Avenue/National Boulevard (intersection no. 49). As such, a supplemental evaluation of the operations of the subject off-ramps was prepared in order to identify the



potential for vehicular queuing from these ramps onto the freeway mainline due to Development-Project-related traffic.

Each of the ramps that would be used by Development Project traffic exhibit long deceleration lane lengths, and most provide multiple lanes for considerable distances at their intersections with their respective surface street termini, thereby providing substantial vehicular storage capacities that minimize ramp queuing interference with the freeway mainline travel lanes. The San Diego Freeway southbound off-ramp at Olympic Boulevard/Pico Boulevard exhibits a total vehicular storage capacity of approximately 1,350 feet (including multiple lanes at its terminus with Sawtelle Boulevard), the San Diego Freeway northbound off-ramp at National Boulevard provides a total of approximately 1,100 feet of vehicular storage, the Santa Monica Freeway eastbound off-ramp at Pico Boulevard/34th Street exhibits a total of approximately 1,700 feet of vehicular storage length, and the Santa Monica Freeway westbound off-ramp at Overland Avenue/National Boulevard provides approximately 2,050 feet of vehicle storage.

Although it is acknowledged that use of these ramps can be heavy during both the morning and afternoon peak commute periods, existing storage capacities at each of these locations are adequate, and that no queuing into the mainline freeway lanes typically occurs at any of the subject locations. The Transportation Research Board (TRB) Highway Capacity Manual (HCM) identifies typical minimum ramp lane capacities (for free flow speeds of 20 miles per hour [mph] or less) of approximately 1,800 vehicles per hour (vph) for a one-lane off-ramp, and approximately 3,200 vehicles per hour for a two-lane ramp. Although each of the subject ramps provides multiple lanes at their terminus intersection with their respective surface streets, they only provide a single “diverge” lane from the mainline freeway, and as such, the minimum ramp capacity of 1,800 vph is assumed.

As shown in the Draft EIR (Figures IV.N-25 and IV.N-26), the forecast future “Without Project” peak-hour traffic volumes on these ramps are typically well below this capacity, with the southbound San Diego Freeway off-ramp at Olympic Boulevard/Pico Boulevard exhibiting a forecast demand of approximately 1,032 vph (calculated “demand vs. capacity” ratio, or d/c, equal to 1,032/1,800 = 0.573) during the morning peak hour, and 554 vph (d/c = 0.308) during the afternoon peak hour; the northbound San Diego Freeway off-ramp at National Boulevard exhibits a forecast traffic demand of approximately 1,199 vph (d/c = 0.666) during the morning peak hour and approximately 853 vph (d/c = 0.474) during the afternoon peak hour. Similarly, the eastbound Santa Monica Freeway off-ramp at Pico Boulevard (opposite 34th Street) is forecast to accommodate approximately 773 vph (d/c = 0.429) in the morning peak hour and 332 vph (d/c = 0.184) during the afternoon peak hour, while the westbound Santa Monica Freeway off-ramp at Overland Avenue opposite National Boulevard is forecast to accommodate approximately 691 vph (d/c = 0.384) during the morning peak hour and approximately 1,290 vph (d/c = 0.717) during the afternoon peak hour. As a result, none of these ramps is forecast to exceed 75 percent of its existing capacity (most are forecast to operate at less than 60 percent of their available capacity).

The CMP identifies that relationship between d/c ratios and level of service designations associated with freeway ramp analyses are the same as those used in the Draft EIR for evaluating the study intersections;



LOS A is associated with d/c ratios ranging from 0.000 to 0.600; LOS B equates to d/c values between 0.601 and 0.700; LOS C is for d/c’s from 0.701 to 0.800; LOS D represents a d/c range of 0.801 to 0.900, LOS E reflects a d/c range from 0.901 to 1.00; and LOS F equates to a d/c value of 1.00 or greater. As indicated by the previous calculations, most of the subject ramps are forecast to operate at LOS A or LOS B conditions during both the morning and afternoon peak hours, with the exception of the Santa Monica Freeway westbound off-ramp at Overland Avenue, which exhibits LOS C operations during the afternoon peak hour. (Note that these operational levels are independent of the operations of the ramp terminus intersections, which are fully analyzed in the Draft EIR). Additionally, each of the subject ramps provides substantial vehicular storage capacity (ranging from a minimum of approximately 1,100 feet to approximately 2,050 feet), and as such no vehicular queuing onto the adjacent mainline freeway lanes is expected to occur under the forecast future “Without Project” conditions.

As further shown on Figures IV.N-17 and IV.N-18 on pages IV.79 and IV.N-80 (respectively), Development Project traffic additions to these ramps would be minimal. During the morning peak hour, the Development Project would add approximately 17 vehicles per hour to the San Diego Freeway southbound off-ramp at Olympic Boulevard/Pico Boulevard, approximately 7 vehicles per hour to the San Diego Freeway northbound off-ramp at National Boulevard, approximately 9 vehicles per hour to the Santa Monica Freeway eastbound off-ramp at Pico Boulevard/34th Street, and approximately 24 vehicles per hour to the Santa Monica Freeway westbound off-ramp at Overland Avenue/National Boulevard. Similarly, during the afternoon peak hour, although Development Project traffic additions would be substantially higher than during the morning peak hour, the incremental traffic increases would continue to be relatively nominal, with approximately 58 Development-Project-related vehicles per hour added to the San Diego Freeway southbound off-ramp at Olympic Boulevard/Pico Boulevard, approximately 22 additional vehicles per hour added to the San Diego Freeway northbound off-ramp at National Boulevard, approximately 33 additional vehicles per hour added to the Santa Monica Freeway eastbound off-ramp at Pico Boulevard/34th Street, and approximately 83 additional Development-Project-related vehicles per hour on the Santa Monica Freeway westbound off-ramp at Overland Avenue/National Boulevard.

Based on the minimum lane capacities noted earlier, the addition of these generally nominal Development-Project-related trips would not substantially affect the operations of any of the subject freeway off-ramps. The future forecast “With Project” traffic volumes on these ramps, as shown on Figures IV.N-27 and IV.N-28 in the Draft EIR are approximately 1,049 vph (d/c = 0.583) on the southbound San Diego Freeway off-ramp at Olympic Boulevard/Pico Boulevard during the morning peak hour, and 612 vph (d/c = 0.340) during the afternoon peak hour, while on the northbound San Diego Freeway off-ramp at National Boulevard, future morning peak hour traffic demands are expected to be approximately 1,206 vph (d/c = 0.670), with approximately 875 vph (d/c = 0.486) during the afternoon peak hour. Similarly, the eastbound Santa Monica Freeway off-ramp at Pico Boulevard (opposite 34th Street) is forecast to accommodate a “With Project” traffic demand of approximately 782 vph (d/c = 0.434) in the morning peak hour and 365 vph (d/c = 0.203) during the afternoon peak hour, while the westbound Santa Monica Freeway off-ramp at Overland Avenue opposite National Boulevard is forecast



to accommodate approximately 715 vph (d/c = 0.397) during the morning peak hour and approximately 1,373 vph (d/c = 0.763) during the afternoon peak hour. Again, most of these ramps would continue to utilize less than 60 percent of their available capacity, with a maximum utilization occurring at Santa Monica Freeway westbound off-ramp at Overland Avenue, at just over 76 percent of capacity. Further, each of the ramps is forecast to continue to operate at LOS C or better during both peak hours, even with the addition of new project traffic.

The CMP identifies that a significant impact to a freeway ramp would occur if the traffic associated with a project increases the d/c ratio by 0.020 or more, causing or worsening LOS F conditions. As shown in the preceding calculations, although the Development Project would increase the d/c on several of the ramps by more than 0.020 (+0.032 at the San Diego Freeway northbound off-ramp at National Boulevard, and +0.046 at the Santa Monica Freeway westbound off-ramp at Overland Avenue, both during the afternoon peak hour only), these locations are forecast to operate at better than LOS F conditions, and as such, the Development Project’s incremental traffic additions are not considered under the CMP methodology to be significant. As a result, the anticipated level of additional Development Project traffic on any of the subject freeway off-ramps in the vicinity of the Development Project site would not cause vehicular queuing at any of these locations onto the mainline freeway travel lanes.


The commenter’s statement that “no analysis of potential impacts to I-405 and I-10 was performed [for the Development Project]” is incorrect, since a detailed evaluation of potential project-related traffic impacts to both the San Diego Freeway and the Santa Monica Freeway is contained in Section IV.N (Transportation/Traffic) of the Draft EIR. The discussion of the potential impacts and effects of the Development Project on these two freeways is more detailed than the summary discussed on page IV.N-47 and summarized in the referenced Table IV.N-6. In the subsection titled “CMP Freeway Segment Impacts” beginning on page IV.N-109, the traffic study states that the Development Project’s net traffic additions to either of these facilities are approximately one-half the 150-trip threshold identified in the CMP warranting detailed analyses of potential impacts, and as a result, no significant project impacts to the area freeways would occur based on CMP requirements.

However, the traffic analysis prepared for the Development Project expands on this statement with additional evaluations in order to determine whether any significant impacts would occur as a result of the Development Project, focusing on the freeway segment anticipated to exhibit the highest net project traffic additions; the Santa Monica Freeway east of Overland Avenue (the freeway segment referenced by the commenter). As noted in Section IV.N of the Draft EIR, the Santa Monica Freeway segment east of Overland Avenue generally provides five eastbound and four westbound mainline travel lanes, providing a total directional capacity of approximately 8,000 vehicles per hour for westbound traffic and 10,000 vehicles per hour for eastbound traffic. As such, the maximum Development-Project-related eastbound freeway traffic addition of 72 net trips during the afternoon peak hour would therefore result in an approximate 0.90 percent increase in the mainline demand-to-capacity (d/c) ratio value (d/c value increase



of 0.009), while the westbound Santa Monica Freeway east of Overland Avenue would exhibit potential Development Project impacts of approximately 0.83 percent (d/c increase of 0.0083). These values are substantially below the CMP’s minimum threshold for significant impacts of an increase in the freeway mainline d/c of 0.020.

The traffic analysis conducted for the Development Project also notes that for the segment of the Santa Monica Freeway west of Centinela Avenue, since the Development-Project-related traffic additions to either direction of this segment of the freeway are less than those identified for the eastbound Santa Monica Freeway segment, the impacts to this segment would be less than the maximum 0.90 percent increase noted above. Similarly, the San Diego Freeway south of National Boulevard provides five mainline lanes per direction, while the segment of this freeway north of Tennessee Avenue provides five northbound mainline lanes, and four mainline lanes, plus a high occupancy vehicle (HOV) lane and multiple auxiliary lanes for southbound traffic. Since the Development Project’s traffic additions to either segment of the San Diego Freeway are less than those identified for other freeway segments with similar capacities, the Development Project’s impacts to the San Diego Freeway in either direction would be less than those impacts noted above.

Therefore, as stated in Section IV.N of the Draft EIR, regardless of the existing or future level of service or d/c ratio of the selected freeway segment, the highest anticipated peak hour project traffic additions to the area freeway system would produce an incremental increase of only 0.009 in the mainline d/c ratio of any of the nearby freeways, less than one-half the 0.020 d/c increase defined as significant by the CMP. These impacts represent the highest potential impacts to the regional transportation system, since Development Project traffic would be expected to disperse onto surface streets as it moves farther away from the Development Project site.

Additionally, as described earlier, Caltrans is currently completing construction of new HOV lanes in both directions on the San Diego Freeway south of National Boulevard and is slated to begin work in the near future on a new northbound HOV lane between the Santa Monica Freeway interchange and the US 110 (the “Ventura Freeway”) interchange, in order to address congestion along this key local and regional transportation corridor. These new lanes will add capacity to these study segments, and as a result, the Development Project’s incremental impacts to the Santa Monica Freeway through these segments would be further reduced.

The commenter also questions the Development Project traffic volume estimates shown in Table IV.N-6, noting (correctly) that the Development Project would result in a total of approximately 1,232 net trips (during the afternoon peak hour), and therefore that freeway segment trips should be at least 100 vehicles. The commenter fails to recognize that the 1,232 PM peak hour trips represent the total number of trips in both directions (to and from the Development Project site), and that in actuality, the total directional traffic associated with the Development Project is split relatively evenly (657 inbound trips and 575 outbound trips), therefore reducing the number of trips added to any particular direction of any of the area freeways. The specific project-component trip generations and freeway assignment percentages and



volumes used to evaluate the Development Project’s freeway impacts (as summarized in Table IV.N-6) are contained in a table in Appendix B to the Final EIR.


The CMP, which is consistent with CEQA requirements, does not require a “cumulative” impact analysis for freeway mainline segments, other than for purposes of identifying the potential future levels of service on such facilities in order to determine whether a project’s incremental traffic additions are “significant.” Each of the freeway segments in the study area is already operating at LOS F during peak commute periods (as noted by the commenter), and as such, there is no need to prepare a “cumulative” analysis to determine this condition. The CMP defines a significant impact as an increase in the freeway d/c of 0.02 or more when the facility is operating at, or is caused by project traffic to operate at LOS F (d/c > 1.00). It However, since the Development Project’s incremental traffic impacts to any of the freeway segments in the study area would be below the “significance” threshold (0.02 increase in d/c value), the Development Project’s impacts to any of the area freeways would be less than significant, regardless of the level of service.

The commenter is referred to Response to Comment Caltrans-3. As indicated in both the table in Appendix B to the Final EIR and Table IV.N-6 on page IV.N-47 in Section IV.N (Transportation/Traffic) of the Draft EIR, the maximum directional traffic additions to any segment of the adjacent freeways would be approximately 83 westbound vehicles per hour and 72 eastbound vehicles per hour on the Santa Monica Freeway (east of Overland Avenue), which equates to an increases of about 1.2 to 1.4 new vehicles per minute in either direction of the freeway, spread across the four to five mainline travel lanes. Peak-hour Development-Project-related traffic additions to other segments of the Santa Monica and San Diego Freeways in the vicinity of the Development Project site would be below these levels. Further, as identified in Caltrans’ State Highway traffic volumes data (available on their website), both the Santa Monica and San Diego Freeways in the study area currently (year 2011 data) carry between approximately 10,000 and 13,000 vehicles per direction per hour during the peak morning and afternoon weekday commute periods (approximately 170 to 225 vehicles per minute per direction). As such, the Development Project’s incremental traffic additions would represent less than 1.0 percent of the total existing directional hourly traffic on any of these facilities, which is not statistically significant. (Note that this percentage increase is similar to the d/c-based impacts identified earlier in Response to Comment Caltrans-3). Therefore, as noted in Section IV.N, the incremental Development-Project-related traffic impacts to the area freeways would be nominal and would not add significantly to cumulative traffic increases on these facilities.


The commenter is referred to Response to Comment Caltrans-4. Additionally, as described in Section IV.N (Transportation/Traffic) of the Draft EIR, the Development Project would not result in any significant impacts to any of the area freeway facilities, and as such, no mitigation measures are



warranted. Further, the comment does not identify any cumulative impacts for which mitigation would be required. However, should improvements to the Santa Monica or San Diego Freeways or other regional transportation facilities be identified (prior to the approval of the Development Project), the decision-making bodies could condition the Development Project or otherwise require participation in a “fair-share” funding mechanism, such as a trip fee or other program to contribute to such improvements as are appropriate based on the incremental freeway impacts identified in the Draft EIR.


This comment summarizes Mitigation Measures N-1 and N-3 identified in Section IV.N (Transportation/Traffic) of the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies.


This comment summarizes Mitigation Measure N-2 identified in Section IV.N (Transportation/Traffic) of the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies.


Regarding freeway-related noise at the Project site, the commenter is referred to page IV.K-55 in Section IV.K (Noise) of the Draft EIR that includes an analysis of impacts related to sources of noise (including traffic traveling on the San Diego Freeway) that could affect on-site receptors at the Project site. Mitigation Measure K-5 on page IV.K-65 states the following:

Once detailed architectural plans for the Proposed Project are available, an acoustical study shall be conducted to verify that the interior noise level at all residential units on the Project site shall not exceed the City’s standard of 45 dB CNEL. The design features required to achieve compliance may include one or more of the following elements, as verified by the acoustical study: sound-rated windows and doors, size and orientation of windows relative to the noise sources (streets, freeway, and light rail line), upgraded exterior wall construction, insulation batts, and forced air ventilation/air conditioning. The study shall address both existing and future noise levels.

The Project Applicant would be required to implement this mitigation measure; nothing is expected of the State regarding traffic noise impacts at the Project site.




If the Development Project is approved, the Project Applicant would coordinate Caltrans as necessary during the permitting phase.


The Project Applicant acknowledges the requirement for a transportation permit from Caltrans, if the Project would require the use of state highways by heavy and/or oversized construction equipment/vehicles.


The transportation of construction materials and demolition and excavation hauling typically occurs over an approximately seven-hour workday, beginning at 9:00 AM and ending at 4:00 PM. These hours are generally consistent with the Mayor’s directive to limit construction traffic activities and any construction traffic-related impacts to non-peak travel periods of the day.

Comment Letter City Council (Paul Koretz) A

Response to Comment City Council (Paul Koretz) A-1

The end of the public comment period for the Draft EIR was extended from May 29, 2012 to June 18, 2012.

Comment Letter City Council (Paul Koretz) B

Response to Comment City Council (Paul Koretz) B-1

This comment expresses general concern about the Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


Regarding “an alternate project including industrial, media and office components,” the commenter is referred to page VI-34 in Section VI (Alternatives to the Proposed Project) of the Draft EIR that includes the following description of Alternative C (an alternative to the Project):

Alternative C: Mixed-Use Office/Industrial Development (herein referred to as “Alternative C”) assumes removal of all existing uses from the Development Project site and development of the



site with office and industrial land uses in conformance with standards associated with the existing land use designation and zoning for the portion of the Development Project site zoned M2-1-O. Development would include three buildings: 1) a one-story 50,000-square-foot building for light-industrial/manufacturing purposes; 2) a nine-story (approximately 90 feet in height) 215,000-square-foot office building; and 3) a six-story (approximately 60 feet in height) 212,000-square-foot parking structure, with 530 parking spaces (based on LAMC requirement of 1.0 space per 500 square feet of industrial and office land uses).

Although the description of this alternative in the Draft EIR does not specify “media” land uses, it is possible that the “light-industrial/manufacturing” land uses referenced in the description could incorporate “media” land uses.

The potential environmental impacts associated with Alternative C are discussed on pages VI-34 through VI-53 and on Table VI-50 on page VI-113 in Section VI and are compared to the environmental impacts associated with the Development Project. Also, the commenter is referred to page VI-112 in Section VI that states the following about the selection of Alternative C as the Environmentally Superior Alternative:

In accordance with CEQA Guidelines Section 15126.6(e), if the environmentally superior alternative is the “no project” alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. All of the alternatives would result in a reduction of impacts of the Development Project, due to the reduction in the amount of square footage that would be developed under each alternative. However, as discussed throughout the alternatives analysis and as shown in Table VI-50, Alternatives Comparison, Alternative C would result in reduced impacts when compared to the Development Project. More specifically, the Development Project would result in significant and unavoidable impacts with respect to Air Quality (Construction ROG and NOx and Operational ROG, NOx, and CO), Land Use and Planning (Policy Consistency), Noise (Construction and Operation), and Traffic (Intersection LOS). Alternative C would reduce significant impacts related to Traffic from 24 to 7 impacted intersections under the Existing-With-Alternative C condition and from 27 to 8 impacted intersections under the Future-With-Alternative C condition. Construction-related vibration impacts to the DPSS building would likely be less than significant under this alternative. Alternative C would avoid the Development Project’s significant and unavoidable operational noise impact to exterior areas, because no residential units would be developed as part of this alternative. Also, this alternative would not result in significant and unavoidable impacts related to Air Quality (Construction ROG and NOx) and Land Use and Planning (Policy Consistency), because Alternative C includes development of industrial land uses and would not expose residential land uses to a significant air quality health risk. For these reasons, Alternative C is the environmentally superior alternative.

The remainder of this comments reflects general opposition to the Development Project and its impacts but does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying



and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the statements are acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Responses to Comments City Council (Paul Koretz) B-4 through City Council (Paul Koretz) B-23.


Regarding the height of the Development Project and other buildings in the vicinity, the commenter is referred to Appendix C to the Final EIR, which includes a map showing taller buildings within the Development Project site area. As shown, a 17-story building is located to the west of the Development Project site on Olympic Boulevard, and a 20-story building is located to the north of the site on Santa Monica Boulevard. Also, the commenter is referred to Response to Comment Alpern A-3.

Regarding the commenter’s statement that the Development Project would result in “conversion from a job-producing industrial use to a high-rise residential use adjacent to a freeway,” the commenter is referred to page II-8 in Section II (Project Description) of the Draft EIR that states the Development Project includes approximately 266,800 square feet of retail commercial land uses in addition to the proposed 538 residential units. Also, the commenter is referred to Table IV.L-5 on page IV.L-7 in Section IV.L (Population, Housing, and Employment) of the Draft EIR that shows the existing industrial land uses generate approximately 82 jobs, while the Development Project would generate 597 jobs (a net increase of 515 jobs).

Regarding air quality health risks associated with the Development Project site, as cited in the California Air Resources Board (CARB) Air Quality and Land Use Handbook, several scientific studies have been published that show an increase in the distance between freeways and sensitive receptors, such as residential uses, a corresponding decrease in emission concentrations occurs.1 This issue is discussed in further detail in Section IV.I (Land Use and Planning) of the Draft EIR, beginning on page IV.I-5. Furthermore, consistent with SCAQMD recommendations, the Draft EIR included a detailed health risk assessment (HRA), addressing the potential adverse health impacts associated with the Development Project site’s proximity to the San Diego Freeway. The health effects associated with siting the Project near the San Diego Freeway are disclosed on page IV.I-31 of the Draft EIR. As detailed in Appendix IV.I.2 to the Draft EIR and presented in Section IV.I, the Draft EIR disclosed significant and unavoidable

1 Air Quality and Land Use Handbook: A Community Health Perspective, California Environmental Protection Agency, California Air Resources Board, April 2005.



impacts at the “worst-case” location on the Development Project site (near the freeway) as well as the nearest proposed residence (located approximately 300 feet from the freeway).

Notwithstanding the regional trip reduction benefits associated with the Development Project being developed as a transit oriented development (TOD), the entirety of the Development Project site is located within 1,000 feet of the San Diego Freeway, emissions from which would expose future residents and visitors to unhealthy outdoor ambient air quality. However, no residences would be located within 300 feet of the freeway, approximately 25 percent of the proposed residential areas would be located between 300 and 500 feet from the freeway, and approximately 75 percent of the proposed residential areas would be located farther than 500 feet from the freeway. A southern California study (Zhu, 2002) showed measured concentrations of vehicle-related pollutants, including ultra-fine particles, decreased dramatically within approximately 300 feet of the Long Beach and San Diego Freeways. Another study looked at the validity of using distance from a roadway as a measure of exposure to traffic related air pollution (Knape, 1999). This study showed that concentrations of traffic related pollutants declined with distance from the road, primarily in the first 500 feet. Thus, the available data shows that exposure is greatly reduced at distances of approximately 300 feet and continues to decline at greater distances.

As noted above, the Draft EIR included a tiered analysis disclosing potential impacts at the worst-case location on the Development Project site and at a location of approximately 300 feet from the freeway. In both cases, health impacts would be considered significant and unavoidable. Furthermore, based on the data in the HRA prepared for the Development Project, locating all residences more than 500 feet from the freeway would likely reduce air quality health impacts, but not to a level that would be below the thresholds of significance.

It should further be noted that the Draft EIR has included Mitigation Measure I-3, requiring MERV 13 filtration for all residences located on the Development Project site. Additional feasible strategies presented in the Draft EIR that could be implemented to improve indoor ambient air quality on the Development Project site are presented on pages IV.I-67 through IV.I-69 of the Draft EIR. Such strategies include the following:

• Locate open space areas (courtyards, patios, balconies etc.) as far from the freeway sources as possible;

• Plant vegetation between receptors and freeway sources;

• Consider site plan design minimizing operable windows and building frontages to the freeway;

• Consider options for mechanical and ventilation systems (i.e., supply or exhaust based systems);

• If a supply-based system is proposed (i.e., actively bringing outside air through intake ducts), consider locating intakes as far from the freeway sources as possible.



Although these strategies would not bring health impacts to a less than significant level, the strategies should be considered feasible at improving indoor air quality at the Development Project site.


The commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


The commenter asserts that the Project objectives “have been framed improperly so as to diminish the value of any other alternative.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

The objectives of the Development Project were prepared in conformance with Section 15124(b) of the CEQA Statute and Guidelines and include the following thirteen, as listed on page II-68 in Section II (Project Description) of the Draft EIR:

• To create a high-quality mixed-use development that promotes integrated urban living and furthers SCAG goals of addressing regional housing needs through the development of infill sites;

• To replace uses that are incompatible with mass transit with uses that are complementary to the proposed development of a light rail station and Metro Rapid public transit;

• To address traffic issues on a regional level by increasing density near major mass transit nodes;

• To fully utilize a site consistent with the goals and policies in the WLA Community Plan;

• To construct a development that enhances pedestrian circulation, incorporates high-quality landscaping and aesthetics, and creates a more beautiful and livable neighborhood environment;

• To maximize the City’s affordable housing stock and increase the provision of Senior Low Income and/or Very Low Income housing, thus helping to address the City’s existing affordable housing shortage;

• To provide affordable housing for seniors in a highly desirable, select part of the City;

• To diversify the housing stock in West Los Angeles, and improve the West Los Angeles job-housing balance by maximizing affordable and/or workforce housing development;

• To reduce vehicle miles traveled by constructing retail amenities closer to existing consumers;



• To increase jobs through construction and operation of a new mixed-use development;

• To generate tax revenue for the City with high tax-generating land uses;

• To provide a mixed-use development that is compatible and complementary with surrounding land uses; and

• To provide adequate parking facilities to serve the proposed residential and retail uses.

It should be noted that the commenter references only 8 of the 13 Development Project objectives. Additionally, the commenter is referred to Section VI (Alternatives to the Proposed Project) of the Draft EIR, which discusses the relationship of the Development Project objectives to each of the 6 Alternatives to the Proposed Project addressed in the Draft EIR. In summary, the Draft EIR concludes the following:

Alternative A (No Project, Continuation of Existing Uses) would not meet any of the Development Project objectives.

Alternative B (No Project, Zoning Compliant Industrial Development) would meet 7 of the 13 Development Project objectives.

Alternative C (Mixed-Use, Office and Industrial Development) would meet 8 of the 13 Development Project objectives.

Alternative D (Retail Only Development) would meet 8 of the 13 Development Project objectives.

Alternative E (Residential Only Development) would meet 9 of the 13 Development Project objectives and would partially meet one additional objective.

Alternative F (Reduced Commercial/Residential Mixed-Use Development) would meet all 13 of the Development Project objectives but to a lesser degree than would the Development Project.

Evaluating a full range of alternatives to a project is only one component of an EIR. The purpose of an EIR is to assess and disclose the environmental impacts of a project and to identify ways to reduce or avoid the significant impacts of a project, whether through mitigation or an alternative.


With regard to the commenter’s statement about the Development Project objectives, the commenter is referred to Response to Comment City Council (Paul Koretz) B-6. The EIR makes no assumption about whether the decision-making bodies will approve the requested zone change or not: the EIR addresses and discloses the environmental impacts associated with implementation of the Project, which includes a zone change.




Regarding transit-oriented development (TOD), the purpose of a TOD is to locate land uses of any type near transit hubs/lines to provide people convenient access to alternative forms of transportation other than driving single-occupancy vehicles. The Development Project would meet the purpose of a TOD by developing residential and commercial land uses adjacent to the Expo Phase 2 Project (the “Expo 2 Project”) light-rail station and other existing bus routes.

The commenter cites a principal of SCAG’s Compass Blueprint that is referenced in SCAG’s 2008 RCP. The Development Project would be consistent with this principal by improving jobs-housing balance throughout the Los Angeles region and reducing commute distances and vehicle miles traveled (VMT) by locating housing and employment near transit and other transportation corridors.

Regarding jobs, the commenter is referred to Section IV.L (Population, Housing and Employment) of the Draft EIR that states the Development Project would generate approximately 515 net new jobs at the Project site.


This comment includes statements of opinion about housing and employment, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. Also, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


This comment expresses an opinion regarding the operations and effects of the Development Project’s retail component and is not supported by any data or facts presented by the commenter. The commenter states that the Development Project’s significant traffic impacts are evidence that the retail component of the Development Project would draw customers from “further and further distances and by moving existing customers and traffic from locations in the same vicinity.” This statement is a misinterpretation of the analysis results. First, the new Target store proposed as part of the Development Project would provide a service that is not currently available in the Development Project vicinity. The nearest existing Target store is located at 10861 Weyburn Avenue in Westwood, approximately 2.0 miles from the Development Project site. Additional Target stores are located in Culver City at 10820 Jefferson Boulevard (3.5 miles away), 3535 La Cienega Boulevard (3.6 miles away), and in the Fox Hills Mall at 6000 South Sepulveda Boulevard (4.2 miles away). Note that the distances identified are direct (straight-line) distances and do not reflect actual driving distances, which would be substantially longer in most cases (for instance, the most direct on-street travel route to the Westwood Target from the project site is approximately 2.5 miles, or about 25 percent farther than the straight-line distance). As a result, residents



in the Development Project vicinity, particularly those located to the south of the site, would save substantial travel distance (VMT), as well as travel time, by using the closer Target store provided by the Development Project. The Development Project also would provide new retail facilities within walking distance of many of the area’s residents, again reducing their dependence on vehicular travel for shopping, and eliminating some vehicle trips. Additionally, the provision of a new multi-purpose retailer such as Target along with a new grocery market at the same location, as is proposed, would further reduce VMT by providing an opportunity for one-stop shopping for many residents in the area. As noted by the commenter, it is acknowledged that it is likely that some patrons of existing retail facilities in the Development Project vicinity area could instead patronize the Development Project’s new retail facilities, although this redistribution of existing patronage would not result in new trips to the area, since such trips already travel throughout the area as they patronize existing retail facilities. However, in order to provide a highly conservative analysis of potential traffic impacts that could result from the Development Project, all customers of the proposed new Target store were assumed to be new patronage, thereby producing new trips at the study intersections. This conservative assumption is the primary factor in the estimate of the number of net new trips generated by and therefore, the number of significant traffic impacts associated with the Development Project.


This comment includes statements of speculation regarding the land value of the Add Area Project site, if the requested general plan land use designation change is approved. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts to support these statements. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

The existing land use designations for the Add Area Project site are Light Industrial and Public Facilities, and the Add Area Project site is zoned M2-1-O and PF-1XL. Under the Light Industrial land use designation and M2-1-O zoning, building height is restricted by a 1.5:1 floor area ratio (FAR). Although the Public Facilities land use designation has no height limits, the PF-1XL zoning has a height limit of two stories and no taller than 30 feet. The requested land use designation for the Add Area Project site would change the land use designation from Light Industrial and Public Facilities to Community Commercial, which carries no height limitation but restricts height by a 1.5:1 FAR, similar to the existing Light Industrial land use designation and M2-1-O zoning. No zone changes are requested at this time for the Add Area Project site. Thus, the existing M2-1-O and PF-1XL zoning would continue to apply to the Add Area Project site. The change in the land use designation of the Add Area Project site would not allow for development of 15-story structures, because the height of structures constructed on the Add Area Project site would be restricted by the 1.5:1 FAR associated with the M2-1-O zoning and by the two-story/<30 feet height limitations associated with the PF-1XL zoning. Also, as discussed throughout the Draft EIR, no development of the Add Area Project site is proposed at this time. The characteristics of any future development associated with the Add Area Project site would be developed at the time that an



individual applicant proposes a project to the City. Additionally, the following analysis impacts related to the Add Area Project site is included on page IV.B-39 in Section IV.B (Aesthetics) of the Draft EIR:

The Add Area Project includes re-designation of three properties (bound by West Pico Boulevard to the north, South Sawtelle Boulevard to the west, Exposition Boulevard to the south, and Sepulveda Boulevard to the east) from Light Industrial and Public Facilities to Community Commercial. For the purposes of this EIR, it is assumed that for the foreseeable future, the existing uses on the Add Area Project site (i.e., public storage facility, a County office building, and a maintenance yard) would continue. No specific development is proposed at this time. As such, the aesthetics/visual character of the existing land uses associated with the Add Area Project site would not change, and the aesthetics/visual character within the area would not change as a result of the proposed re-designation of the Add Area Project site. Therefore, no significant impacts related to aesthetics would occur as a result of the Add Area Project.

A similar analysis is provided for each of the environmental issues addressed in the Draft EIR. For these reasons, no further evaluation of impacts related to the Add Area Project site is required.


Regarding lighting impacts of the Development Project on existing single-family residential land uses in the area and drivers on the San Diego Freeway, the commenter is referred to page IV.B-54 in Section IV.B (Aesthetics) of the Draft EIR that includes a discussion of lighting impacts of the Development Project on existing surrounding land uses (which include single-family residential land uses and drivers on the San Diego Freeway).2 As stated in this section, the Development Project would be required to comply with Los Angeles Municipal Code (LAMC) Sec. 93.0117(b), which would preclude the Development Project’s exterior light sources and building materials from causing more than two foot-candles of lighting intensity or generating direct glare onto exterior glazed windows or glass doors on any property containing residential units; elevated habitable porch, deck, or balcony on any property containing residential units; or any ground surface intended for uses such as recreation, barbecue or lawn areas or any other property containing a residential unit or units. Additionally, The Development Project would be designed to support more “street-level program activities” fronting the Development Project site, and as such, would include proposed signage along Pico and Sepulveda Boulevards that would be illuminated to highlight the building’s architectural features and indicate the retail establishments on the

2 The Santa Monica Freeway is approximately one-half mile to the south of the Development Project site. It is possible that some portions of the Development Project could be visible from the Santa Monica Freeway, although it is likely that views of the Development Project would be inhibited by existing development and landscaping found between the Santa Monica Freeway and the Development Project site. However, if any portions of the Development Project would be visible, the Development Project would compose a very small aspect of the overall view from the Santa Monica Freeway.



Development Project site. All proposed lighting would be required to adhere to all applicable City regulations. Signage along the street frontages would not exceed the allowable totals (square feet) within the corresponding zone on each of the streets adjacent to the site. Illumination for building and store identification signs would be directed towards the interior of the building to the extent feasible and all signage would also be illuminated in a manner that conforms to code requirements to minimize light spill-over and glare. The Development Project would use non-reflective glass in all exterior windows and building surfaces. These materials would reduce potential glare from reflected sunlight. In addition, the proposed parking structure would be subterranean and as such would eliminate the reflection potential from parked cars as viewed from surrounding areas. As such, the Development Project would not interfere with the performance of any off-site activity (including driving on the San Diego Freeway), and impacts related to lighting as a result of the Development Project would be less than significant.


Regarding building materials in West Los Angeles, there are various building material retailers in West Los Angeles. Also, there is a cement plant in Santa Monica that is approximately 3.0 miles to the west of the Development Project site. Trip generation related to the transport of cement for new development is associated with the new development and not with the Development Project; the Development Project would not cause those trips or any impacts associated with the trips. In any event, the commenter asserts that removal of the existing cement plant from the Development Project site would “result in new truck trips from the San Fernando Valley.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Regarding the consistency of the Development Project with policy 4.2.5 of the Air Quality Element of the General Plan, consistency with this policy is not based on whether a discretionary project would generate traffic and/or exceed pollutant emissions significance thresholds or traffic generation significance thresholds, but whether a discretionary project incorporates measures/design features to reduce trip generation, such as siting near transit facilities or implementing a transportation demand management (TDM) program. As discussed on Table IV.C-14 on page IV.C-37 in Section IV.C (Air Quality) of the Draft EIR, the Development Project is consistent with policy 4.2.5 of the Air Quality Element for the following reason:

The Development Project is a mixed-use project consisting of residential and commercial uses that would serve the needs of the West Los Angeles community and Greater Los Angeles. The Development Project is located in an area that is served by local-serving bus lines providing multiple stops and convenient localized access to shopping, business, and recreation destinations. As discussed previously, the Development Project would introduce new uses that are complementary to the proposed development of a light rail station and Metro Rapid public transit in the Project site vicinity. In addition, the Development Project is situated within walking



distance to existing retail, restaurant, and other commercial businesses that are located along Sawtelle Boulevard, Pico Boulevard, and Sepulveda Boulevard. Furthermore, the Development Project would construct retail amenities that would serve the proposed residents at the Project site as well as the existing residential uses in the Project site vicinity, which would reduce the VMT by these patrons. Additionally, the Project would be required to prepare and implement a Transportation Demand Management (TDM) program that includes enrollment in metro’s B-Tap pass program (annual group rate discounted transit passes) for all Project residential occupants and retail employees (refer to Mitigation Measure M-2). Thus, the Development Project would be consistent with this policy.

Also, the commenter is referred to Response to Comment City Council (Paul Koretz) B-10.


This comment includes statements of opinion regarding trip reduction and Alternatives B and C, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


Section IV.F (Greenhouse Gas Emissions) of the Draft EIR does not state that vehicle trips or greenhouse gases (GHGs) generated by the Development Project would be reduced as compared to the existing conditions. To the contrary, page IV.F-17 of the Draft EIR discloses that the net increase in GHG emissions generated by the Development Project would be 16,937,23 CO2e million tons per year (MTY) after mitigation. This represents a net increase as compared to the baseline conditions identified on page IV.F-5 of the Draft EIR. The information presented on page IV.F-17 and Table IV.F-5 of the Draft EIR (refer to page IV.F-17) was based on a comparison of two post-development scenarios, a mitigated project scenario and an unmitigated project scenario. The intent of presenting these two scenarios was to illustrate the beneficial impacts of the Development Project being a mixed-use development with trip reduction applied for being a TOD and implementing a Transportation Demand Management Program (TDM) (refer to Mitigation Measure N-2), and for complying with the heightened energy efficiency standards of the LA Green Building Code. The mitigated project scenario included GHG estimates based on the TOD nature of the Development Project, the TDM, design features, and required mitigation measures. The unmitigated scenario provides GHG estimates for a project without these important attributes that contribute to lowering the GHG emissions of the Development Project. As illustrated on Table IV.F-5, an approximate 38.3 percent reduction in GHG emissions would occur as a result of the Development Project’s TOD nature, TDM program, and compliance with the LA Green Building Code, when compared to a scenario in which the Development Project would not implement such GHG-reducing measures.



With respect to the enforceability of the TDM program, the commenter is referred to Section V (Mitigation Monitoring Report Plan) of the Final EIR. The Department of City Planning would be responsible for enforcing the TDM program for the Development Project.


Regarding the consistency of the Development Project with the existing industrial zoning and land use designation for the Development and Add Area Project sites and the Industrial Land Use Policy (ILUP), the commenter is referred to Section IV.I (Land Use and Planning) of the Draft EIR that the following:

The [Development] Project is requesting a General Plan Amendment, which would change the existing land use designations for the entire block on which the Project site is located from Light Industrial and Public Facility to Community Commercial. As the General Plan Amendment would prohibit industrial uses on the project site, is inconsistent with Community Plan policies to preserve industrial land. This would amount to a significant and unavoidable impact.

The re-designation of the Add Area Project site to Community Commercial would create zoning inconsistencies with the existing Light Industrial and Public Facilities zoning for the Add Area Project site as neither M2 nor PF zones are corresponding zones in the Community Commercial land use designation. Additionally, the public storage facility is not permitted in any of the Community Commercial land use designation corresponding zones. Therefore, the public storage facility would be a non-conforming use under the revised General Plan land use designation and impacts related to land use consistency would be significant and unavoidable impact.


This comment includes statements of opinion about alternatives and mitigation measures, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Alternatives to the Development Project are identified and discussed in section VI (Alternatives to the Proposed Project) of the Draft EIR and will be considered by the decision-making bodies.

Regarding employment associated with Alternatives B and C and the Project, as discussed in Section IV.L (Population, Housing and Employment), the Development Project would generate approximately 515 net new jobs, whereas Alternative B would generate approximately 322 net new jobs (refer to Section VI [Alternatives to the Proposed Project]), and Alternative C would generate approximately 805 net new jobs.




Regarding air quality impacts associated with the Development Project, the commenter is referred to Response to Comment Elliot-2.

Regarding “noise impacts that are beyond the 75 dB CNEL that is even ‘Conditionally Acceptable’ to residents,” this impact of the Development Project is disclosed on page IV.K-53 in Section IV.K (Noise) of the Draft EIR and reads as follows:

The Development Project includes a courtyard area in the center of the Development Project site, and the proposed residential structures include outdoor balconies, some of which would face out from the site. As shown in Table IV.K-14, exterior noise levels at the residential facades facing out from the Development Project site would range from 58 dB CNEL to 76 dB CNEL. Outdoor areas within the center of the site would not experience exterior noise levels in excess of what is considered “Normally Acceptable” for residential land uses, considering the attenuation effect of the proposed structures. However, some of the outdoor balcony areas facing out from the Project could experience noise levels in excess of what is considered “Normally Acceptable” or “Conditionally Acceptable” for residential land uses. Therefore, impacts of the Development Project related to exterior noise levels at the Development Project site would be significant.

Regarding the commenter’s statement about mitigating air quality, health, and noise impacts associated with the San Diego Freeway by moving residences away from the freeway, the commenter is referred to Response to Comment City Council (Paul Koretz) B-17.



The commenter should note that regardless of the type or size of land uses developed on the Development Project site, all users of the site would be exposed to the same significant exterior noise levels identified in the Draft EIR. Through compliance with building code standards, the Project would not result in any significant impacts related to interior noise levels.


Regarding the employment figures identified in the Draft EIR, to allow for a commensurable calculation of existing employment and potential future employment associated with the Development Project, existing and future employment were estimated using the same employment factors developed by the same source. The issue of employment loss/generation in an EIR is relative to the determination of whether a project would cause unplanned population growth. Although the types of jobs replaced or created by a project and the quality and benefits of the those jobs are important factors to a community and its decision-making bodies, these factors are only relevant under CEQA when considering the amount



of population growth that could potentially occur as a result of those jobs. In the case of the Development Project and the Draft EIR, the Draft EIR concluded in Section IV.I (Population, Housing, and Employment) that the potential indirect population growth from the 515 net new jobs associated with the Development Project would not result in substantial unplanned growth. Also, the commenter is referred to Responses to Comments City Council (Paul Koretz) B-4 and City Council (Paul Koretz) B-13.

Additionally, the commenter seems to be drawing the conclusion that the existence of the cement plant is what creates economic growth, but this is not necessarily the case. Market demand and the ability to satisfy that demand create growth. The existence of local cement plants is one component that makes it possible to satisfy market demand in a feasible manner. The existence (or not) of this one particular cement plant would not materially affect the growth of the Los Angeles economy.


Although the economic and community benefits are important factors for a community and its decision-making bodies, these factors are not relevant in assessing the environmental impacts of a project under CEQA. This information is not required for the Draft EIR or the Final EIR for the Casden Sepulveda Project. However, these factors may be taken into consideration by the decision-making bodies when determining whether to approve or deny the Project.


Regarding the commenter’s statements about pedestrian conflicts, the commenter is referred to page IV.N-101 in Section IV.N (Transportation/Traffic) of the Draft EIR that includes a discussion of Project impacts related to bicycle, pedestrian, and vehicular safety. As discussed, with implementation of the following safety measures, no significant impacts related to this issue would occur:

• Development of new sidewalks and reconstruction of the sidewalks adjacent to the Development Project site to allow for easier pedestrian flow;

• Installation of caution signage for bicyclists, pedestrians, and drivers at the Development Project driveway;

• Installation of mirrors at the Development Project driveway to allow drivers exiting the site to check for on-coming traffic; and

• Installation of flashing lights at the Development Project driveway to indicate that a car is approaching the exit.


Regarding “neighborhood incursion,” the commenter is referred to Response to Comment Abarbanel-5.




A comparison of the traffic impacts of the Development Project to traffic impacts of Alternatives B and C (in fact, all of the Project Alternatives) is included in the Draft EIR. The commenter is referred to Section VI (Alternatives to the Proposed Project). The remainder of this comment expresses an opinion about traffic generated by “media” land uses.

Comment Letter Los Angeles Department of Water and Power (LADWP)

Response to Comment LADWP-1

The description of the Development Project in the original request for a water supply assessment (WSA) included 538 dwelling units, generally broken down into 269 one-bedroom dwelling units and 269 two-bedroom dwelling units. Based on LADWP water consumption rates and efficiency requirements, this mix of dwelling units would consume approximately 65,251 gallons of water per day. Since preparation of the WSA, the Project Applicant has further defined the 538 dwelling units to include 56 studio dwelling units, 262 one-bedroom dwelling units, 201 two-bedroom dwelling units, and 19 three-bedroom dwelling units. Based on LADWP water consumption rates and efficiency requirements, the mix of dwelling units identified in the Draft EIR would consume approximately 62,894 gallons of water per day, less than the amount of water consumption assumed in the WSA.

Response to Comment LADWP-2

This comment confirms that the amount of water consumption assumed for the Development Project in the Draft EIR is less than the water consumption assumed in the WSA.

Comment Letter Metropolitan Transportation Authority (Metro)

Response to Comment Metro-1

Before the Development Project can be constructed, a number of issues between the Development Project Applicant and Metro will be resolved through on-going coordination and negotiations. The commenter is referred to Response to Comment Metro-2.


If the Development Project were approved, the Project Applicant would coordinate with Metro during the design stage to ensure that the Development Project design and construction would not conflict with any Metro regulations applicable to the Development Project.




The referenced San Diego Freeway widening/HOV project is described in detail in the subsection titled “Future Roadway Improvements” of Section IV.N (Transportation/Traffic) of the Draft EIR, beginning on page IV.N-10. Although the referenced San Diego Freeway improvements will add much needed capacity to the freeway, these improvements are designed to address latent congestion issues on the mainline freeway and will not result in significant additional traffic volumes on the freeway or on the surrounding surface streets. Additionally, the freeway access ramp improvements are designed to generally enhance surface street access to and from the freeway throughout the study area with enhanced freeway/ramp interfaces and/or improved ramp capacities. However, these improvements will not result in additional ramps or relocated ramp locations that would result in changes to travel patterns in the vicinity of the Development Project site. It is of note that these freeway ramp improvements are incorporated into the traffic study prepared for the Development Project as part of the future roadway conditions baseline. Thus, although these improvements are included in the Development Project traffic study, these improvements are not expected to substantially change either traffic flow patterns or overall traffic volume levels in the vicinity of the Development Project and will have a negligible effect on the traffic analysis in the Draft EIR. The referenced San Diego Freeway widening/HOV project is already accounted for in the cumulative traffic analysis of the Draft EIR, and as such, no revisions to Table III-1 are required.

Additionally, as noted by the commenter, the Development Project’s Sawtelle Boulevard driveway would be a single-lane driveway, and its operations would be limited to right-turn only exit-only movements. Therefore, this exit driveway would require only minimal width and would not be substantially affected by either the referenced San Diego Freeway widening/HOV project or Expo 2 Project. However, the final design of this and all Development-Project-related access points will be required to be reviewed and approved by the appropriate City departments (e.g., LADOT, Bureau of Engineering, etc.) prior to construction, and as such, would conform to current City design standards and would be compatible with any ongoing or known future roadway improvements.


Regarding the commenter’s statements about pedestrian/bicycle safety, the commenter is referred to page IV.N-101 in Section IV.N (Transportation/Traffic) of the Draft EIR that includes a discussion of Project impacts related to bicycle, pedestrian, and vehicular safety. As discussed, with implementation of the following safety measures, no significant impacts related to this issue would occur:

• Development of new sidewalks and reconstruction of the sidewalks adjacent to the Development Project site to allow for easier pedestrian flow;

• Installation of caution signage for bicyclists, pedestrians, and drivers at the Development Project driveway;



• Installation of mirrors at the Development Project driveway to allow drivers exiting the site to check for on-coming traffic; and

• Installation of flashing lights at the Development Project driveway to indicate that a car is approaching the exit.

The commenter should note that an Exclusive Negotiation Agreement between Metro and the Development Project Applicant exists and through this agreement, issues related to the Development Project will be resolved.


The removal of 10 to 12 unmetered on-street parking associated with Mitigation Measure N-9 is noted in the Draft EIR on page IV.N-138. The removal of this on-street parking is not considered a significant impact, because the current users of these spaces are primarily people associated with the existing uses at the Development Project site that would be removed as part of the Development Project. As discussed in Section IV.N (Transportation/Traffic) of the Draft EIR, the Development Project would include an adequate number of parking spaces (2,029) to accommodate the parking needs of the Development Project. The commenter is referred to Table IV.N-11 on page IV.N-103 in Section IV.N that shows a detailed calculation of the parking spaces required of the Development Project per the LAMC. Because the number of parking spaces included as part of the Development Project (2,029 spaces) meets the LAMC parking requirements for the Development Project, no significant impacts related to parking would occur.


The commenter is referred to pages IV.N-12 and IV.N-13, which contains the text below that explains the conservative traffic analysis prepared for the Development Project that assumes an at-grade crossing of the Expo 2 Project light-rail line at Sepulveda Boulevard. Based on the text below, no revisions to the traffic analysis are needed.

The traffic analysis prepared for the Development Project that is included in this EIR is conservative, because at the time of preparation of the traffic study for the Development Project, the Final EIR prepared for Phase 2 of the Expo Line assumed that the Sepulveda/Exposition Station of the Expo Line extension would be constructed at-grade, and as such, the rail crossing at Sepulveda Boulevard would also be located at-grade. The current approved Expo Line (Phase 2) configuration is above grade, spanning Sepulveda Boulevard. The traffic impacts associated with the above-grade crossing would be less than those associated with the at-grade crossing. A more detailed discussion follows.

The Expo Line (Phase 2) Final EIR includes analyses indicating that, with the implementation of the recommended roadway improvements to Sepulveda Boulevard and Exposition Boulevard (an



additional southbound through lane on Sepulveda Boulevard, and additional lanes on Exposition Boulevard), no significant impacts to the operation of the intersections of Sepulveda Boulevard and Exposition Boulevard, or to Sepulveda Boulevard and Pico Boulevard are anticipated. Despite these conclusions, due to the anticipated Expo Line train activities (up to 12 trains per hour per direction during peak periods), the effects of the crossing gate closures on the capacities of Sepulveda Boulevard and its intersections with both Exposition Boulevard and Pico Boulevard were evaluated in a more conservative manner in this analysis. For purposes of this report, the planned operations of the Expo Line could produce crossing gate closures on Sepulveda Boulevard of as much as 18 minutes per hour (about 30 percent of the time), with individual gate closures lasting up to 90 seconds every five minutes. Such closures would not effect through traffic movements in either direction on Exposition Boulevard, nor would eastbound right-turns or westbound left turns be precluded, although eastbound left-turns and westbound right-turns would be prohibited. Additionally, during Expo Line train crossings, all southbound Sepulveda Boulevard traffic would be stopped, as would northbound Sepulveda Boulevard through traffic, although northbound left- and right-turn movements may be allowed.

As such, since some traffic moves would still be possible during crossing gate closures, it is unlikely that the intersection of Sepulveda Boulevard and Exposition Boulevard would experience overall capacity reductions equivalent to the complete blockage of the entire intersection during the gate closure periods identified above. However, since Sepulveda Boulevard accommodates the majority of traffic at this intersection (approximately 82 percent of the total morning peak hour and approximately 85 percent of the total PM peak hour “Future With Project” intersection volumes), and in keeping with the conservative direction of this study, it was assumed for “worst case” analysis purposes that this intersection would exhibit an overall reduction in capacity of 30 percent during peak periods.

Similarly, the nearby intersection of Sepulveda Boulevard and Pico Boulevard could also be affected by the Expo Line activity, as vehicles queued on southbound Sepulveda Boulevard north of the Expo Line tracks could prevent normal traffic flows on the southbound through, eastbound right-turn, and westbound left-turn movements (vehicles directed toward southbound Sepulveda Boulevard) at this intersection, which account for between 15 percent (morning peak hour) and 25 percent (afternoon peak hour) of the total forecast “Future With Project” volumes at the intersection. Therefore, the overall capacity of this intersection during both peak hours was reduced by an average of 20 percent to account for the potential effects of the Expo Line crossing gate operations.

The current elevated Expo Line (Phase 2) Exposition Station configuration, including grade separation of the Sepulveda Boulevard crossing identified in the Expo Line (Phase 2) Final EIR exhibits both an elevated Exposition Station and associated grade separated rail crossing Sepulveda Boulevard, and as such, would not affect the operations of the roadway or nearby intersections, since there would be no conflicts between the Expo Line trains and vehicles on



Sepulveda Boulevard or other nearby streets. As a result, the at-grade Expo Line (Phase 2) Exposition Station and at-grade Sepulveda Boulevard crossing scenario analyzed in this analysis will produce a conservative evaluation of future intersection and roadway operations in the Development Project site vicinity, including potential Development Project impacts. Further, the grade-separated alternative Expo Line (Phase 2) alignment will not result in additional or otherwise unidentified impacts as compared to the analyzed at-grade alternative, and as a result, the elevated station/crossing Expo Line (Phase 2) alternative was not evaluated in this traffic analysis.


The discussions referenced by the commenter refer to the description of potential traffic impact mitigation roadway improvements that were investigated as part of the traffic study for the Development Project but were determined to be infeasible by LADOT or others due to various reasons. The specific measures being discussed was the potential addition of the third northbound lane on Sepulveda Boulevard at both Exposition Boulevard and Pico Boulevard and was determined to be infeasible due to lack of sufficient rights-of-way with which to construct this additional lane, and as such, the northbound third through lane was not assumed as part of the Development Project impact analysis nor as a mitigation measure.

However, at the time the Development Project traffic study was approved, the Exposition Phase 2 grade separated crossing at Sepulveda Boulevard had not been approved (as noted by the commenter, this did not occur until March of last year), and as such, the then-current information on the Exposition Phase 2 station at Sepulveda Boulevard and Exposition Boulevard called for an at-grade crossing with an additional (third) southbound through lane on Sepulveda Boulevard as a mitigation measure. This third southbound through lane, as well as improvements to both the eastbound and westbound approaches of Exposition Boulevard, were assumed in the Development Project traffic study, along with associated reductions in intersection capacities at both the intersections of Sepulveda Boulevard and Pico Boulevard, and Sepulveda Boulevard and Exposition Boulevard (despite the Exposition Phase 2 Project EIR’s conclusions that the at-grade crossing would not create significant delays or congestion at these two intersections).

Based on these assumptions, as well as the essentially site-adjacent locations of both intersections, the Development Project exhibits significant impacts during both the morning and afternoon peak hours at both intersections (refer to Table IV.N-14 on page IV.N-123 in Section IV.N [Transportation/Traffic] of the Draft EIR). As described in the Draft EIR, there are no feasible physical mitigation measures available to address these impacts at either intersection, and therefore, these impacts are identified as significant and unavoidable. Since the adoption of the Exposition Phase 2 grade separated crossing configuration at Sepulveda Boulevard, neither the previously-assumed third southbound through lane on Sepulveda Boulevard nor the improvements to Exposition Boulevard will be implemented as part of that project’s construction. The grade-separated crossing configuration also eliminates the previously-assumed reductions in intersection capacities at the two subject intersections. Additionally, as described on page



IV.N-14, since the Development Project already exhibits significant and unavoidable (unmitigated) impacts during both the morning and afternoon peak hours at both intersections with the previous Exposition Phase 2 improvements assumed to be in place, the removal of these improvements would not materially change the conclusions of the Draft EIR or traffic study. With the currently approved Expo Phase 2 light-rail line grade-separated crossing of Sepulveda Boulevard, the Development Project would continue to significantly impact both of these intersections during both the morning and afternoon peak hours, with no feasible mitigation available, although in general, these Development Project impacts would be of lesser magnitude than those identified in the Draft EIR, since there would no longer be any of the street traffic delays at either the intersection of Sepulveda Boulevard/Pico Boulevard or Sepulveda Boulevard/Exposition Boulevard (resulting is the 20 to 30 percent reductions in intersection capacity that were assumed in the original “at-grade” assumption analyses). Note that the Exposition Phase 2 Project roadway improvements apply only the forecast future conditions analyzed in the Draft EIR, since the Exposition Phase 2 Project, including its potential roadway improvements and/or mitigation measures, was not assumed to be completed under the existing conditions evaluated in the Draft EIR.


As noted on page IV.N-13 in Section IV.N (Transportation/Traffic) of the Draft EIR, the potential roadway improvement at Sepulveda Boulevard and National Boulevard was not assumed as part of the traffic impact analysis for the Development Project.


This comment expresses an opinion regarding possible language in the Draft EIR, although the Draft EIR already states that the Development Project’s commercial loading facilities would be accessed by a driveway along Exposition Boulevard (which would provide both entry and exit capability), labeled in Figure II-4 as “Fire Access Entry,” although this driveway is also intended to accommodate delivery and other commercial vehicles, with an additional exit-only, right-turn-only exit on Sawtelle Boulevard. It is acknowledged that both this driveway as well as the residential parking entry/exit driveway farther to the west along Exposition Boulevard would both necessitate crossing beneath the elevated Exposition light rail tracks.


All roadway improvements of the Development Project, both as part of the Development Project itself and/or as mitigation, would be reviewed and approved by LADOT and/or the City Bureau of Engineering prior to installation, and as such would be designed to be consistent with any ongoing or known future roadway improvements.


The commenter is referred to Response to Comment Metro-10.




Prior to the initiation of construction, the Project Applicant would coordinate with Metro regarding the Development Project’s construction schedule to ensure that transit services would not be materially affected.

Comment Letter Native American Heritage Commission (NAHC)

Response to Comment NAHC-1

This comment includes state and federal statutes relating to Native American historic properties, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Section IV.D.2 (Cultural Resources – Archaeological and Paleontological Resources) of the Draft EIR that includes an assessment of Development Project impacts related to archaeological resources. As discussed on page IV.D-14, there are no known archaeological resources on the Development Project site. However, the following mitigation measure is included on page IV.D-16 of the Draft EIR to ensure that no significant impacts to unknown archaeological resources would occur:

D-1. A covenant and agreement shall be recorded between the Development Project and the City of Los Angeles Department of City Planning prior to obtaining a grading permit stating that if any archaeological resources are encountered during Project development, the project shall be halted. The services of an archaeologist shall be secured by contacting the South Central Coastal Information Center (SCCIC) (657-278-5395) located at California State University Fullerton, or a member of the Society of Professional Archaeologist (SOPA) or a SOPA-qualified archaeologist who shall assess the discovered material(s) and prepare a survey, study or report evaluating the impact. The archaeological survey, study or technical report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource. The applicant shall comply with the recommendations of the evaluating archaeologist, as contained in the survey, study or report. Project development activities may resume once copies of the archaeological survey, study or report are submitted to the SCCIS at CSU Fullerton. 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.



Comment Letter State Clearinghouse

Response to Comment State Clearinghouse-1

This comment is the State Clearinghouse forwarding noticing information about the Casden Sepulveda Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Casden Sepulveda Project and ways to reduce or avoid these impacts.

Responses to Private Individuals, Groups, and Associations

Comment Letter Abarbanel

Response to Comment Abarbanel-1

This comment makes a general statement about impacts of the Development Project and asks for the Development Project to be modified, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses opinions about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding use of the Development Project site as a transit center, the commenter is referred to Responses to Comments Alpern A-6 and Alpern A-9 and Response to Comment Arenberg-5.

Regarding parking for the Expo 2 Project light-rail line station spanning Sepulveda Boulevard, parking will be provided in a structure just to the south of the Development Project site.


This comment makes a statement about reducing the size and traffic impacts of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Also, the commenter is referred to Response to Comment Arenberg-5.


Both the intersection traffic volume counts and related projects information used in the traffic study prepared for the Development Project site were considered to represent current traffic conditions in the vicinity of the Development Project at the time the traffic study was initially prepared. LADOT conducted a thorough review of these “baseline” traffic count data contained in the traffic study and agreed that the traffic study adequately described the traffic conditions in the vicinity of the Development Project site (refer to the LADOT Initial Traffic Assessment letter, September 28, 2010 in Appendix IV.N.7 of the Draft EIR). Additionally, it should be noted that the traffic data used in the traffic study was generally collected prior to the beginning of the current economic downturn in late 2008 and early 2009. As demonstrated below, the economic downturn caused a substantial slowing of traffic growth in the region, and in many cases resulted in reductions in the amount of traffic on streets and highways throughout the area as existing workers were laid off or had their work hours reduced, and potential new employees entering the job market could not find work. As a result, typical traffic increases resulting over time, as described in detail in the traffic study for the Development Project, did not occur, or occurred at a substantially reduced rate.

The most current traffic volume data available for the immediate vicinity of the Development Project site (obtained from LADOT’s website) are from February 2010 for Pico Boulevard west of Cotner Avenue (less than one block west of the Development Project site), and from October 2009 for Sepulveda Boulevard south of Richland Avenue (approximately one block south of the Development Project site); a copy of these traffic counts is included in Appendix D to the Final EIR. A review of this count data indicates that Pico Boulevard in the vicinity of the Development Project site carried a total of approximately 3,258 vehicles per hour (total of both directions) during the morning peak hour, and a total of approximately 3,419 vehicles per hour during the afternoon peak hour. However, the “existing” 2009 traffic data used in the Development Project traffic study for that same segment of roadway shows a total traffic volume of approximately 3,840 vehicles per hour during the morning peak hour (nearly 18 percent higher than the 2010 data), and a total of approximately 3,679 vehicles per hour during the afternoon peak hour (approximately 7.6 percent higher than the 2010 data). Similarly, the 2009 traffic count for Sepulveda Boulevard south of the Development Project site shows a total (both directions) of approximately 2,208 vehicles per hour during the morning peak hour, and a total of approximately 2,956 vehicles per hour during the afternoon peak hour. This is compared to the “existing” 2009 traffic data used in the Development Project traffic study, which indicates a total traffic volume of approximately 2,609 vehicles per hour during the morning peak hour (over 18 percent higher than the more recent LADOT data), and a total of approximately 3,146 vehicles per hour during the afternoon peak hour (approximately 6.4 percent higher than the LADOT data). These comparisons clearly indicate that traffic volumes within the immediate vicinity of the Development Project site have decreased from the levels identified in the traffic counts used for the Development Project’s traffic impact analyses. As a result, the traffic data used in the traffic study continues to represent (and in fact, overstates) the current traffic



volumes in the study area, and therefore, result in a conservative evaluation of the Development Project’s potential traffic impacts.

Regarding the use of more current traffic data, it should be noted that Caltrans is currently underway with the construction of the San Diego Freeway widening/HOV project through the area, between the Santa Monica Freeway and the Ventura Freeway. While the work on the mainline on the freeway does not present any significant issues with regard to the collection of current traffic data, the San Diego Freeway project also includes work at or on a number of on and/or off-ramps in the project vicinity, including a three-month long closure of the San Diego Freeway ramps to westbound Wilshire Boulevard (from late June to late September 2012). This ramp construction and modification work can result in substantial vehicle congestion along major corridors, and produces temporary changes in traffic flow patterns throughout their duration. As such, any new traffic data collected at intersections in the vicinity of the Development Project site that are affected by these ramp closures and construction would simply reflect these current but temporary traffic conditions, and would not reflect the typical traffic flow patterns that existed prior to the beginning of the San Diego Freeway improvement project and that will return following its completion. However, the traffic data used in the traffic study for the Development Project is not affected by these construction-related conditions, since the data were collected prior to the initiation of the San Diego Freeway Widening Project in the study area and therefore, accurately reflects the typical traffic flow patterns in the study area.


As described in the traffic study prepared for the Development Project and in Section IV.N (Transportation/Traffic) of the Draft EIR, beginning on page IV.N-91, most of the local/residential streets in the vicinity of the Development Project site are discontinuous due to interruption by the Santa Monica Freeway and/or San Diego Freeway rights-of-way or by other existing developments in the area. As a result, few of the local/residential streets provide convenient alternative routes to the Major and/or Secondary Highways serving the vicinity of the Development Project site, and in fact, few provide connections between such facilities at all. This lack of direct connections would therefore generally require drivers on the Major and/or Secondary Highways to travel out of their way to utilize such routes, unless such trips originate within the local residential areas served by these facilities. Additionally, most of these local/residential streets exhibit numerous STOP sign controlled intersections within the residential neighborhoods themselves, requiring any such cut-through traffic to stop often and repeatedly, thereby reducing the attractiveness of these roadways as “quicker” alternatives to the nearby key arterial streets. As such, few if any of the local/residential streets in the study area would be used as “cut-through” routes either by Development Project traffic or by “non-project” traffic seeking to avoid existing or future congestion on the main thoroughfares such as Pico Boulevard or Sepulveda Boulevard.

However, as also discussed in the Draft EIR, Richland Avenue (south of the Development Project site) provides a connection between Sepulveda Boulevard and the next closest arterial, Westwood Boulevard, although only via its connections to Ayres Avenue and Brookhaven Avenue, two other discontinuous



local/residential streets. Nonetheless, due to this connection, it can be reasonably anticipated that some degree of Development-Project-related traffic could use Richland Avenue as a cut-through route to travel to and from the Development Project site, and a detailed evaluation of these potential Development-Project-specific traffic impacts is included in Section IV.N (Transportation/Traffic), beginning on page IV.N-28, and reads as follows:

Traffic impacts to local/residential streets, unlike intersection impact analyses, are based on daily traffic volumes, with impacts evaluated based on the Development Project’s traffic percentage of the total Future-With-Project ADT volumes. The City of Los Angeles guidelines for the evaluation of Development Project traffic impacts on local/residential streets utilizes a variable scale to determine the significance of potential traffic additions, as outlined in LADOT’s Traffic Impact Analysis Policies and Procedures memorandum. These Policies and Procedures identify that, in general, a significant impact to local/residential streets would not occur if Development Project traffic additions to the street in question are less than 160 vehicles per day (vpd), equivalent to an increase of 16 percent on roadways with 1,000 vpd or fewer; significance thresholds for streets with more than 1,000 vpd are greater than 160 vpd. However, as noted previously in this section, the Development Project is within the jurisdiction of the WLA TIMP, which identifies a minimum traffic addition of 120 vpd as the threshold for a significant impact to local/residential streets.

Based on the Development Project’s assumed trip assignment percentages, Richland Avenue could be expected to experience approximately two percent of the Development Project’s “market” component traffic, as shown previously on Figure IV.N-10. In order to provide for a conservative assessment of potential daily traffic additions to this street, it was assumed that all market-related trips on Richland Avenue would be primary trips, and that the existing Development Project site-related (cement plant) trips do not utilize Richland Avenue to any significant degree. Therefore, for purposes of this analysis, neither pass-by factors nor removal of the existing site uses (as assumed in the analysis of Development Project impacts to the area study intersections) were applied to the estimates of new traffic from the market component. As such, only the internal capture reduction was considered appropriate, resulting in a net market component estimate of approximately 5,279 trips per day.

The assumed two percent Development Project market component utilization of Richland Avenue could potentially add a total of approximately 106 new daily trips, although due to the highly conservative assumptions used for the preliminary assessment of the potential for local/residential Development Project impacts, actual trip additions are expected to be substantially less. Given the local-serving nature of the proposed specialty market component of the development, it is likely that much if not all of this traffic would actually be generated within the neighborhoods surrounding the Development Project site and would naturally use the local streets to access the Development Project site. Although such trips would not necessarily result in



additional traffic on these roadways, for conservative analysis purposes, the trips were considered as new trips that could increase traffic volumes on some of the local access streets.

Thus, based on this assessment, the Development Project’s conservative potential new traffic additions to Richland Avenue or other local/residential streets in the nearby vicinity would be less than the minimum 120 vehicles per day identified in the WLA TIMP and LADOT’s Traffic Study Policies and Procedures memorandum. Therefore, Development Project impacts related to neighborhood intrusion would be less than significant.


As disclosed in Section IV.N (Transportation/Traffic), the Development Project would result in significant and unavoidable impacts at 22 of the study intersections.


The commenter is referred to Response to Comment Abarbanel-6.


This comment expresses opinions about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The study intersections included in the traffic study prepared for the Development Project included Intersection 45 (National Boulevard and San Diego Freeway Northbound On-Ramp) (refer to page IV.N-1 in Section IV.N [Transportation/Traffic] of the Draft EIR for a list of all the study intersections). As shown on Tables IV.N-10 and IV.N-14, the Development Project would not result in a significant impact at this intersection under the Existing-With-Project condition or the Cumulative-With-Project condition, respectively.

Regarding traffic impacts on residential streets, the commenter is referred to Response to Comment Abarbanel-5.


This comment expresses interest in the Expo 2 Project and concern about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these



impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses opposition to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Adams

Response to Comment Adams-1

This comment expresses an opinion about development near transit stations/hubs, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Alpern A

Response to Comment Alpern A-1

This comment is an introduction to the commenter’s opinion about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses concern and opinion about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding air quality health risks associated with the Development Project site, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4 and Response to Comment Elliot-2.



Regarding traffic impacts of the Development Project, as disclosed in Section IV.N (Transportation/Traffic), the Development Project would result in significant and unavoidable impacts at 22 of the study intersections.


Impacts of the Development Project related to visual character of the area are analyzed in Section IV.B (Aesthetics) of the Draft EIR on pages IV.B-25 through IV.B-27. The analysis includes the following text:

The height and massing of the Development Project’s Building Four is proposed to be 17 stories and 206.5 feet above grade, and would be substantially larger than existing low- and mid-rise structures found in the immediate vicinity of the Development Project site and would be visible from off-site locations (refer to Figures IV.B-8 through IV.B-12). The Development Project would be more noticeable from the single-family residential land uses to the south of the Development Project site (refer to the simulated view on Figure IV.B-12). The existing view on Figure IV.B-12 shows that existing buildings at the Development Project site are not visible from this location. However, the additional structural height associated with the Development Project as seen from the residential development to the south of the Development Project site would not constitute a substantial degradation to the visual character of the surrounding area. As shown on Figures IV.B-8 through IV.B-11, the overall function and design of the remaining residential buildings and proposed commercial structure would be consistent with the character of the existing surrounding land uses and with the many other modern developments in the area. Also, the stepped and articulated elements of the design of the upper residential structures along Pico Boulevard and Sepulveda Boulevard would soften the massing of the Development Project as a whole and the overall height, as viewed from a pedestrian level near the Development Project site.

…the Project site is situated in a highly urbanized area characterized by a mix of industrial, commercial, and retail uses and low- to mid-density residential uses. The visual character of the Project area is not defined by one or a limited number of character-defining features (such as design, architecture, land uses, or massing) but comprises a mélange of design, architecture, land uses, and massing that is typical of more recent development along boulevards in West Los Angeles. The Development Project site itself is currently developed with industrial land uses and is surrounded by a mix of commercial and residential land uses. The Development Project would change the land uses on the Development Project site from industrial to a mix of commercial and residential. Although the visual character of the Development Project site and surrounding area would change as a result of the Development Project and buildings at the Development Project would be visible from off-site locations, the change and visibility would not constitute a substantial degradation to the visual character of the site and surrounding area. Therefore, Development Project impacts elated to visual character would be less than significant.




Regarding the Development Project’s traffic impacts and related mitigation measures, the traffic study prepared for the Development Project (which includes an assessment of traffic impacts and identification of mitigation measures to reduce significant traffic impacts) was conducted in consultation with the Los Angeles Department of Transportation (LADOT) (refer to Appendix IV.N of the Draft EIR for LADOTs correspondence related to review of the traffic study for the Development Project) and in accordance with LADOT’s methodology and significance thresholds. Mitigation Measures N-1 through N-8 were identified in the traffic study and in the Draft EIR that would reduce the Development Project’s significant impact at 5 study intersection. However, no feasible mitigation measures are available to reduce the Development Project’s significant impact at 22 study intersections due to (refer to page IV.N-152 in Section IV.N [Transportation/Traffic] of the Draft EIR):

…the lack of adequate rights-of-way to construction meaningful improvements, potential secondary impacts resulting from removals of existing on-street parking, or unavailability of potential roadway and/or traffic signal improvements due to their assignment to other approved or pending developments in the vicinity.

As stated on page IV.N-157 in Section IV.N:

With implementation of Mitigation Measures N-1 through N-8, Development Project impacts to five of the study intersections would be less than significant, while impacts to 22 of the study intersections would be significant and unavoidable (refer to Table IV.N-14).

Regarding parking impacts of the Development Project, the commenter is referred to page IV.N-102 for an analysis of parking impacts of the Development Project. The number of parking spaces that would be provided as part of the Development Project would meet the parking required per the LAMC – 2,029 parking spaces. The commenter is referred to Table IV.N-11 on page IV.N-103 in Section IV.N that shows a detailed calculation of the parking spaces required of the Development Project per the LAMC. Because the number of parking spaces included as part of the Development Project (2,029 spaces) meets the LAMC parking requirements for the Development Project, no significant impacts related to parking would occur.

Additionally, over the course of the planning phase for the Development Project, the representatives of the Development Project Applicant have met on numerous accounts with various neighborhood groups to receive input on all aspects of the Development Project, including mitigation measures.


This comment expresses an opinion about the use of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the



comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about the use of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding “the creation of a Westside Regional Transportation Center,” the Development Project would not preclude or prevent the creation of any such center elsewhere, if one is ever proposed and/or developed.

It should be noted that early on in the planning process, the Development Project Applicant met with Metro and the cities of Culver City and Santa Monica bus operators to discuss the creation of a transportation hub at the Development Project site that would require the relocation of existing bus stops and the creation of a place for bus layover. Although Metro was the most amenable of the three agencies, Metro does not have any bus stops near the Development Project site and would only be able to consider using the site as a layover for their bus drivers; Metro would not be able to pick up passengers at the site. Neither of the cities of Culver City and Santa Monica bus operators was interested in moving their stops. First, the relocation would change existing routes, so that buses would have to circle the block, adding additional costs to operations for the added miles and time for each route. Second, changes to bus routes of the cities of Culver City and Santa Monica in Los Angeles require concurrence with Metro and are not guaranteed.


This comment expresses an opinion about the use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



This comment expresses opposition to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment



is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

The environmental impacts of the Development Project are addressed throughout the Draft EIR and the Final EIR.


The commenter is referred to Section VI (Alternatives to the Proposed Project) that discusses four alternatives to the Development Project (Alternative A [No Project, Continuation of Existing Uses], Alternative B [No Project, Zoning Compliant Industrial Development], Alternative C [Mixed-Use, Office and Industrial Development], and Alternative D [Retail Only Development] that do not include residential land uses

The primary purpose of an alternatives analysis in an EIR is to assess a range of reasonable alternatives to the proposed project that would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant impacts of the project. A “Westside Transportation Center” project would not meet the most important objective of the Development Project that is to develop the site with a mix of residential and commercial land uses. Additionally, these types of transportation facilities can create substantial amounts of traffic, especially if the facilities include a park-and-ride lot or other passenger vehicle parking for transit users). Additionally, the type of transportation facility proposed by the CD11 committee would require re-routing of existing buses to the site, creating additional traffic and depending on the number of buses, would further exacerbate traffic conditions in the area, because buses disrupt traffic flows more than passenger vehicles. Thus, an alternative such as that suggested by the commenter would not lessen any of the significant traffic impacts of the Development Project.

Also, the commenter is referred to Response to Comment Alpern A-6.


Regarding the size of the Development Project and the relationship of the Development Project to neighboring land uses, the commenter is referred to Response to Comment Alpern A-3.

Regarding the “lack of industrial space,” the commenter is referred to Response to Comment City Council (Paul Koretz) B-16.

Regarding open space included as part of the Development Project, the commenter is referred to Response to Comment Murdock-12 and Purcell-4.

Regarding transit amenities, the commenter is referred to Mitigation Measure N-2 on page IV.N-136 in Section IV.N (Transportation/Traffic) of the Draft EIR that includes the following:



N-2: Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall prepare and implement a Transportation Demand Management (TDM) program to the satisfaction of LADOT to reduce traffic impacts of the Development Project encouraging Development Project residents, employees, and patrons to reduce vehicular traffic on the street and freeway system during the most congested time periods of the day. The TDM program shall include implementation of several TDM strategies, including, but not limited to the following:

• On-site Transportation Coordinator, in charge the following:

o Carpool/Vanpool and Rideshare Matching

o Preferential Vanpool/Carpool Parking

o Enrollment in Metro’s B-Tap pass program (annual group rate discounted transit passes) for all onsite residential occupants and retail employees

o Parking Cash-Out

o Flex-Use Vehicles

o Guaranteed Ride Home

• Bicycle Racks and Showers/Lockers

• Flexible Work Hours/Telecommute Opportunities

• Bus/Transit Stop Shelters and/or Amenities

• Wayfinding Information and Signage

Regarding air quality health risks associated with the Development Project, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


The commenter asserts that the Development Project represents “spot zoning.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to this portion of the comment is required. In any event, spot zoning is defined as: 1) The zoning of an isolated parcel in a manner that improperly limits the use of the isolated parcel in the center of a larger unrestricted area, or 2) The zoning of a larger district that is limited or restricted in use,



but additional uses are permitted in one or more “spots” within the district. The Development Project’s requested zone change does not meet the definition of spot zoning.


This comment expresses an opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Alpern B

Response to Comment Alpern B-1

This comment summarizes a CD11 Neighborhood Empowerment Congress Transportation Advisory Committee’s (CD11) presentation and discussion on the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding parking impacts of the Development Project, the commenter is referred to Response to Comment Alpern A-4.


Regarding developing a commuter parking lot, the commenter is referred to Response to Comment Alpern A-9.

Regarding left-turn access to/from the Development Project site, the commenter is referred to Response to Comment Kassan-30.


Regarding related projects and cumulative impacts, Section 15125(a) of the CEQA Statute and Guidelines states, “An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice of preparation is published…” Additionally, Section 15130(b)(1)(A) of the CEQA Statute and Guidelines states that the Draft EIR should consider the potential cumulative impacts that could occur as a result of implementation of the project in conjunction



with other “past, present, and probable future projects producing related or cumulative impacts.” Thus, the list of related projects shown on Table III-1 on page III-13 in Section III (Environmental Setting) of the Draft EIR includes all of the reasonably foreseeable related projects known to the City of Los Angeles at the time the NOP for the Development Project was circulated (June 10, 2009). Also, some of the related projects that were considered in the cumulative analysis in the Draft EIR are no longer moving forward. Additionally, the cumulative analysis in the Draft EIR takes these related projects into consideration. In addition, the cumulative traffic analysis not only considers this related project but also assumes a growth factor of 1.0 percent each year compounded. This growth factor captures other potential development in the Development Project area that could occur but was not reasonably foreseeable at the time of the circulation of the NOP. Thus, revising and recirculating the Draft EIR is not required.

Also, the commenter is referred to Responses to Comments Diamond-5, Diamond-8, and Diamond-9.

Regarding extending the public commenter period for the Draft EIR, the end of the public comment period for the Draft EIR was extended from May 29, 2012 to June 18, 2012.


This comment is the same as Comment Alpern A-3. The commenter is referred to Response to Comment Alpern A-3.















Comment Letter Alpern C

Response to Comment Alpern C-1

This comment is the same as Comment Alpern B-1. The commenter is referred to Response to Comment Alpern B-1.


This comment is the same as Comment Alpern B-2. The commenter is referred to Response to Comment Alpern B-2.

















Comment Letter Anderson

Response to Comment Anderson-1



















Regarding “spot zoning,” the commenter is referred to Response to Comment Alpern A-11.

Comment Letter Arenberg

Response to Comment Arenberg-1


The commenter should note that the cement plant at the Development Project site is still in operation.


The commenter is incorrect in stating that the impacts of the Development Project cannot be mitigated. The commenter is referred to Table I-1 on page I-13 in Section I (Introduction/Summary) of the Draft EIR that includes a summary of all the impacts of the Development Project, a list of all the mitigation measures identified in Section IV (Environmental Impact Analysis) of the Draft EIR, and the level of impact significance after implementation of the mitigation measures. As shown on the table, many of the impacts of the Development Project could be reduced to less than significance with implementation of mitigation.




The commenter asserts that the Development Project would put “quality of life at risk” and that “safety and ability to reach our work, home, schools, medical care facilities, etc. will be forever compromised to the point of danger.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Also, the commenter is referred to Response to Comment Abarbanel-5, Responses to Comments Beber-3 and Beber-14, Response to Comment Diamond-7, and Response to Comment Kassan-19.


Regarding “non-project traffic” and “cut-through traffic,” the commenter is referred to Response to Comment Abarbanel-5.


The commenter asserts that the Development Project would hinder access to the Expo 2 Project light-rail line station and associated parking and would cause “unacceptably long” commutes. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.


Developments that are located in proximity to transit facilities are called transit-oriented developments (TOD). A TOD is not one that provides a transit center, as suggested by the commenter. As discussed throughout the Draft EIR, the Development Project is located adjacent to the future Expo 2 Project light-rail line station. The immediate proximity of these future transit facilities, including both the Expo 2 Project operations themselves as well as the anticipated expansion of Metro and other providers’ bus service to the station location, would allow both Development Project residents and employees/visitors of the on-site commercial and retail uses to use these transit facilities to travel to and from the site without the use of single-occupancy vehicles.

Regarding the “Westside Transit Facility,” the commenter is referred to Response to Comment Alpern A-6 and Alpern A-9.

Regarding parking associated with the Expo 2 Project light-rail line station, the transit station is a Metro project, and thus, Metro is responsible for providing adequate parking for the station. Parking impacts



associated with the Expo 2 Project light-rail line station were addressed in the EIR prepared for the Expo 2 Project (http://www.buildexpo.org/phase-2-eir/).


This comment makes a request of the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




The commenter is referred to Response to Comment City Council (Paul Koretz) B-20. Also, the commenter is referred to Alternative C in Section VI (Alternatives to the Proposed Project) that includes more job-intensive land uses than under the Development Project.


The total proposed retail space in the Development Project is 266,800 square feet. Of this, 54,350 square feet is proposed as a grocery store. The remaining square footage has been characterized as a "big box" tenant in order to assess the potential traffic impacts in the most conservative manner because the traffic trips associated with this type of retail tenant are higher than those for neighborhood-servicing retail. It is anticipated that one or more "big box" retailers would anchor the retail component, but likely at a much smaller size than the 212,650 square feet studied. The actual retail tenants have yet to be identified and could include Target or other retailers.


Regarding left-turn access to/from the Development Project site, the commenter is referred to Response to Comment Kassan-30.


Section 15163 of the CEQA Statute and Guidelines states that a Lead Agency may choose to prepare a supplement to an EIR if the following were to occur:

(1) Any of the conditions described in Section 15162 would require the preparation of a subsequent EIR, and



(2) Only minor additions or changes would be necessary to make the previous EIR adequately apply to the project in the changed situation.

Section 15162 of the CEQA Statute and Guidelines describes the circumstances for when a subsequent EIR or negative declaration is required as follows:

(a) When an EIR has been certified or negative declaration adopted for a project, no subsequent EIR [or negative declaration] shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:

(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

(3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:

(A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;

(B) Significant effects previously examined will be substantially more sever than shown in the previous EIR [or negative declaration];

(C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or

(D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would



substantially reduce one or more is significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

(b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subdivision (a). Otherwise the lead agency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation.

(c) Once a project has been approved, the lead agency’s role in project approval is completed, unless further discretionary approval on that project is required. Information appearing after an approval does not require reopening of that approval. If after the project is approved, any of the conditions described in subdivision (a) occurs, a subsequent EIR or negative declaration shall only be prepared by the public agency which grants the next discretionary approval for the project, if any. In this situation no other responsible agency shall grant an approval for the project until the subsequent EIR has been certified or subsequent negative declaration adopted.

(d) A subsequent EIR or subsequent negative declaration shall be given the same notice and public review as required under Section 15087 or Section 15072. A subsequent EIR or negative declaration shall state where the previous document is available and can be reviewed.

A supplemental or subsequent EIR for the Development Project is not required, because: 1) the EIR for the Development Project has not been certified, and 2) the revisions made to the Draft EIR in Section VI (Corrections and Additions to the Draft EIR) do not meet the requirements of Section 16162 of the CEQA Statute and Guidelines for preparation of a subsequent EIR.

Comment Letter Barnet

The comments in this letter are the same comments as those provided in Comment Letter Arenberg. The commenter is referred to the responses to Comment Letter Arenberg.

Comment Letter Beber

Response to Comment Beber-1

Regarding impacts of the Development Project related to visual character, the commenter is referred to Response to Comment Alpern A-3.



Regarding alternatives to the Development Project that include “fewer stories and much lower density,” the commenter is referred to Section VI (Alternatives to the Proposed Project) of the Draft EIR that includes a discussion of six alternatives that include development of shorter buildings and less overall square footage than the Development Project.




This comment expresses concern about traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Abarbenel-5.


Regarding the comments submitted by the West of Westwood HOA, the commenter is referred to Response to Comment Letter Tippit A.

Regarding the Development Project’s consistency with the West Los Angeles Community Plan, an analysis of the Development Project’s consistency with the applicable policies of the West Los Angeles Community Plan is included in Section IV.I (Land Use and Planning) of the Draft EIR, beginning on page IV.I-46. As disclosed, the Development Project would be partially inconsistent with policies 1-1.1, 1-2.3, and 2-3.1 (refer to Table IV.I-7 on page IV.I-48) of the West Los Angeles Community Plan due to size/density; partially inconsistent with two applicable design guidelines of the West Los Angeles Community Plan (refer to Table IV.I-8 on page IV.I-51); and inconsistent with two applicable design guidelines of the Plan.


It should be noted that the description of a project in an EIR does not have to be exactly as described in the NOP. The commenter is referred to Response to Comment Cohon-17.






This comment describes some of the land uses within West Los Angeles, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Response to Comment Beber-4.


This comment expresses opposition to the Development and Add Area Projects, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment expresses opposition to the Development Project and opinion about construction materials and land use, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



The commenter is referred to Response to Comment City Council (Paul Koretz) B-11. The commenter should note that the tallest building associated with the Development Project is 17 stories, not 19 stories referenced by the commenter.




This comment expresses an opinion about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

In any event, the Commercial zone allows residential land uses, and if the requisite amount of affordable housing is provided and other conditions are met, then a 3:1 FAR is permissible under the Commercial zone, in accordance with the Affordable Housing Ordinance.

Also, the commenter is referred to Response to Comment Commins-3.




This comment expresses an opinion about the Development Project traffic and public safety, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

However, the traffic impacts of the Development Project are fully analyzed and described in in Section IV.N (Transportation/Traffic) of the Draft EIR and supporting traffic study, which conforms to all current (May 2012) LADOT traffic study analysis policies and procedures. The commenter is also referred to Response to Comment Beber-2 and Response to Comment Tippit B-3.


This comment cites information from the Draft EIR and expresses an opinion about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




The Development Project would not require or cause the widening of Pico Boulevard. Regarding pedestrian facilities along the frontage of the Development Project, the commenter is referred to Response to Comment Commins-3.


The comment is based on an invalid premise, since the Development Project does not propose to signalize either the commercial or residential driveways along the Sepulveda Boulevard frontage of the site. It is also of note that the “blind curve” noted by the commenter is primarily the result of the current roadway width along the project frontage of Sepulveda Boulevard, which is not fully improved. The Development Project would widen this portion of the roadway to provide the full 40-foot half-street width required by the City. Additionally, the existing land uses on the Development Project site (the cement plant and building materials supply store) exhibit fences and other sight obstacles immediately adjacent to the street right-of-way, hindering southbound views along Sepulveda Boulevard. As described in the DEIR, the project will remove these existing fences and other on-site materials in order to construct the project, which is proposed to be set back from Sepulveda Boulevard by approximately 30 feet, thereby improving visibility for southbound motorists, and removing the current “blind curve” condition. Also, the commenter is referred to Response to Comment Beber-2 and Response to Comment Abarbanel-5.




One of the discretionary approvals requested by the Project Applicant is approval from the California Public Utilities Commission of encroachments to the Sepulveda Boulevard/Exposition Boulevard intersection crossing. The purpose of this is to allow encroachment under the Expo 2 Project light-rail line tracks for the portion of the Development Project’s plaza/pedestrian area at the northwest corner of Exposition Boulevard and Sepulveda Boulevard. This encroachment would not affect the widths of the streets or cause any traffic “bottlenecks.”


This comment does not appear to address the information in the Draft EIR for the Development Project. Neither Richland Elementary School nor Webster Middle School is identified or discussed in the Pico/Sepulveda project traffic study. Additionally, Webster Middle School is actually closer to the Development Project site (approximately 0.4 mile to the southwest, across Sawtelle Boulevard) than Richland Elementary School (about 0.1 mile further to the west). No enrollment expansions or other improvements to either of these schools are known to be proposed at the current time that would affect



traffic in the study area. Therefore, no response to this comment can be provided. However, it is of note that the traffic study prepared for the Development Project analyzed the existing and forecast conditions at a number of intersections in the area surrounding both of these schools, which are within the traffic study area for the Development Project.


As disclosed in Section IV.C (Air Quality) of the Draft EIR, operation of the Development Project would generate regional pollutant emissions in excess of the South Coast Air Quality Management District’s (SCAQMD) significance thresholds for ROG, NOx, and CO; impacts of the Development Project related to regional emissions were found to be significant and unavoidable (the commenter is referred to page IV.C-47).

Regarding air quality impacts to sensitive receptors (including the Wonder Years preschool), these impacts are addressed in Section IV.C. As stated on page IV.C-22, SCAQMD currently recommends that impacts to sensitive receptors be considered significant when a project generates localized pollutant concentrations of NO2, CO, PM10, or PM2.5 at sensitive receptors near a project site that exceed the localized pollutant concentration thresholds listed above or when a project’s traffic causes CO concentrations at sensitive receptors located near congested intersections to exceed the national or state ambient air quality standards. The roadway CO thresholds would also apply to the contribution of emissions associated with cumulative development.

Localized operational air quality impacts of the Development Project are discussed in Section IV.C, beginning on page IV.C-32. As discussed, operation of the Development Project, including generation of traffic, would not generate localized emissions in excess of SCAQMD’s significance thresholds, and no significant impacts related to sensitive receptors would occur.


This comment restates that the Development Project would result in significant and unavoidable construction-related air quality impacts, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter asserts that the mitigation measures identified in the Draft EIR for air quality impacts of the Development Project are inadequate. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore,



pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Also, the commenter is referred to Response to Comment Beber-24.


The commenter’s recommended mitigation measures AQ-1 through AQ-3 are related to minimizing emissions of PM10 and PM2.5 as a result of construction activities. As discussed on page IV.C-46 in Section IV.C (Air Quality) of the Draft EIR, with implementation of Mitigation Measure C-2, the Development Project would not result in any significant impacts related to these emissions. Thus, no mitigation measures beyond those already identified in the Draft EIR are required for construction-related PM10 and PM2.5 emissions. Additionally, the commenter’s recommended mitigation measures AQ-1 through AQ-3 are substantially similar to SCAQMD Rule 403, which is included as Mitigation Measure C-3 in the Draft EIR.

Regarding the commenter’s recommended mitigation measure AQ-4, a construction-traffic management plan would be a required of the Development Project by LADOT and would address items a through f. Items g through k are substantially consistent with the requirements of Mitigation Measure C-2 identified in the Draft EIR.

Based on this response, the addition of the commenter’s recommended mitigation measures to the Draft EIR is not required.


This comment generally states that the Development Project would result in operational impacts, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.






The commenter is referred to Response to Comment Elliot-2.








Construction-related noise impacts of the Development Project are assessed in Section IV.K (Noise) of the Draft EIR, beginning on page IV.K-40. As discussed on page IV.I-42, Table IV.K-9 shows the peak construction noise levels that would occur at the off-site sensitive uses during construction at the Development Project site compared to the existing daytime ambient noise levels at these sensitive uses. As shown, the peak construction noise levels experienced at the location of the off-site sensitive receptors would range from approximately 64 dBA Leq at the existing multi-family and single-family residences located southeast and south of the Development Project site to approximately 70 dBA Leq at the multi-family residences located southwest of the Development Project site, and would not exceed the City’s threshold of 5 dBA for construction activities lasting more than 10 days in a three-month period. Therefore, impacts of the Development Project related to construction noise would be less than significant.

Construction vibration impacts of the Development Project are assessed on page IV.K-43. As discussed, it is estimated that the annoyance/interference impact threshold of 72 VdB for residential buildings would be exceeded within 82 feet of the equipment. As there are no residential buildings within 82 feet of the Development Project site, this impact is less than significant.

Cumulative construction-related noise impacts are assessed on page IV.K-58. As discussed, due to the proximity of the related project at 11110 West Pico Boulevard (Related Project No. 11) and the Expo 2 Project at the intersection of Sepulveda Boulevard and Exposition Boulevard (Related Project No. 33a), it is anticipated that under the circumstances where construction at these sites were to occur concurrently, the culmination of the construction noise levels from all three sites would result in a substantial increase in ambient noise levels at the nearby sensitive receptors in the general area. Therefore, even with implementation of the proposed mitigation measures, the cumulative noise impact that would occur, should construction of the nearby related projects occur at the same time as the Proposed Project, would be significant and unavoidable and the Proposed Project’s contribution would be cumulatively considerable.

Operational-related noise impacts of the Development Project on off-site receptors are assessed in Section IV.K, beginning on page IV.K-44. As discussed, the Development Project would not generate noise in excess of the City’s significance thresholds at any off-site location, and no significant impacts related to this issue would occur.






Regarding the construction hours for the Development Project outlined in Mitigation Measure K-1, these hours reflect the requirements of LAMC Section 41.40.

Regarding loading dock operations, the commenter is referred to the text on page IV.K-55 in Section IV.K (Noise) of the Draft EIR that states the following about loading dock noise impacts to off-site receptors:

There are no specific noise limits that apply to the unloading of the delivery trucks during the permitted hours of operation. However, the hours of operation at the loading dock would be limited to the daytime hours of 7:00 AM to 10:00 PM, per LAMC Section 114.03. Noise from the delivery vehicles themselves is subject to LAMC Section 114.02. However, this only provides specific noise limits at residential properties and the standard does not apply at the adjacent Public Storage facility. The off-site residential properties nearest to the loading area are located approximately 600 feet to the south on Pearl Street. Taking this distance into account, along with the relatively high ambient noise levels due to traffic on the nearby streets and freeway, sound from delivery vehicles would not be audible at these homes. Therefore, there would be no impact relative to the LAMC at off-site locations.

In order to assess potential noise increases at the Public Storage facility adjacent to the Development Project site, it is necessary to know both the existing CNEL and the future CNEL due to delivery truck activities. As discussed previously, the existing CNEL at the Public Storage facility is approximately 80 dB. To estimate the future delivery truck noise levels, a noise model was constructed using SoundPLAN software. Because both the major retail store and the market are anticipated to sell refrigerated and frozen food it was assumed that up to two refrigerated trucks would occupy the loading area within the same hour and that each truck would run its engine and refrigeration unit for up to 30 minutes while on the Development Project site. Because refrigerated trucks are louder than standard trucks, this was considered to be a worst-case scenario. Noise measurements obtained during a previous study indicate that, while running, a refrigerated truck produces a noise level of 73 dB(A) at a distance of approximately 50 feet. Using this noise level in the SoundPLAN model, it was estimated that the 1-hour Leq at the Public Storage facility due to truck deliveries would be approximately 69 dB(A). Even if this noise level is emitted throughout the entire permitted period of 7:00 AM to 10:00 PM (a conservative estimate), the resulting CNEL associated with the delivery trucks would only be 69 dB, which is lower than the existing noise level (80 dB). Therefore the impact would be less than



significant. Nevertheless, Mitigation Measure K-2 is prescribed to ensure that loading dock activities at the Development Project site shall occur only between 7:00 AM and 10:00 PM.

No revisions to Mitigation Measures K-1 or K-2 are required.

Regarding construction-related noise impacts, the commenter is referred to Response to Comment Beber-31.


Regarding the commenter’s suggested mitigation measure “NOI-1.,” this mitigation measure is similar to the following City Standard Mitigation Measure, which the Project Applicant would be required to comply with:

• The project contractor shall use power construction equipment with state-of-the-art noise shielding and muffling devices.

Regarding the commenter’s suggested mitigation measure “NOI-2.,” the following mitigation measure has been added to page IV.K-65 in Section IV.K (Noise) of the Draft EIR (refer to Section IV [Corrections and Additions to the Draft EIR] and Section V [Mitigation Monitoring Report Plan] of the Final EIR):

K-7. During the construction phase, the Project Contractor shall store and maintain equipment as far away as is reasonably possible from residential areas and noise-sensitive receptors.

Regarding the commenter’s suggested mitigation measure “NOI-3.,” as noted on page IV.K-41 in Section IV.K) Noise of the Draft EIR, the closest noise-sensitive receptor to the Development Project site is the multi-family residential uses located approximately 110 feet southwest of the Development Project site, on the southwest corner of Sawtelle Boulevard and Exposition Boulevard. The San Diego Freeway separates this receptor from the Development Project site. The other closest noise-sensitive receptors noted on page IV.K-41 are located further away and are separated from the Development Project site by existing buildings. The freeway and existing buildings would attenuate construction-related noise associated with the Development Project and would not result in noticeable increases in noise levels (refer to Table IV.K-9 on page IV.K-43). Thus, noise attenuation barriers are not required to reduce construction-related noise levels of the Development Project.






The commenter is referred to Response to Comment Commins-7 and Response to Comment Purcell-4. Both State law and the LAMC allow for the payment of in-lieu fees rather than provision of land to offset impacts to parks and recreational services.


This comment expresses an opinion about the Development Project’s affect on residential “privacy,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. In any event, “privacy” is not an environmental issue of concern under CEQA.




The Development Project would not include billboards, large illuminated signs, and/or flashing signs. The commenter should not that two billboards are currently located on the Development Project site that would be removed as part of the Development Project.


The Development Project’s landscaping would comply with the City’s landscaping requirements. The commenter is referred to Figure II-27 on page II-61 in Section II (Project Description) that shows a preliminary version of the landscaping for the ground floor of the Development Project, and to Figure II-28 on page II-63 that shows the landscaping for the podium level of the Development Project.

The public (including the Westside Neighborhood Council) can provide the City and its decision-making bodies with input on the Development Project at any point in the application process.








Regarding rezoning, the commenter is referred to Response to Comment City Council (Paul Koretz) B-16. Regarding encroachment “issues,” the commenter is referred to Response to Comment Beber-19.


This comment expresses an opinion about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding size of the Development Project and visual character, the commenter is referred to Response to Comment Alpern A-3. Regarding shade/shadow impacts, the commenter is referred to Response to Comment Emerson B-1.


This comment expresses an opinion about variances, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Response to Comment Alpern B-2. The projects listed by the commenter were not reasonably foreseeable projects at the time the NOP was circulated for the Development Project. Of the projects mentioned by the commenter, only the project at 2900 Sepulveda is in the immediate Development Project vicinity (a little over half a mile south of the site), containing 48 apartments and 1,500 square feet of office space would generate (without accounting for removal of any applicable existing site trips) only about 336 total trips per day, including only 26 trips during the morning peak hour and 28 trips during the afternoon peak hour. This level of additional traffic is accounted for within the “ambient growth factor” (1.0 percent annually) assumed in the study. Further, assuming that this project’s traffic disperses throughout the roadway network in a manner similar to the Development Project, less than half of these trips would be expected to travel in any particular direction, resulting in only nominal additional traffic at any of the study intersections. This project would not substantially change any of the results or conclusions of the traffic study prepared for the Development Project. The other two projects referenced (Trammell Crow project at 3400 Pico Boulevard at the southwest corner of Pico/Centinela, and the Wilson project at the northeast corner of Pico/Centinela) are at the far western edge of the study area. The Trammell Crow project would be expected to generate approximately 1,750



net daily trips, including about 110 trips during both the morning and afternoon peak hours, while the Wilson project could produce approximately 500 net trips per day, including only about 40 net morning and 50 net afternoon peak-hour trips. Each of these projects is approximately one mile from the Development Project site, and again, as traffic disperses through the area roadway network, potential additional traffic to any of the study intersections would be nominal, particularly in the immediate vicinity of the Development Project site.

Also, the commenter is referred to Response to Comment Diamond-9.


The commenter is referred to Response to Comment Alpern B-2.


The commenter asserts that the Development Project would “set a precedent and encourage additional overdevelopment of the surrounding area.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required. Regarding the size of the Development Project in relation to the neighboring residential development, the commenter is referred to Response to Comment Alpern A-3.


This comment includes statements of fact about the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about approving an alternative to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.














This comment expresses an opinion about alternatives to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.








The commenter asserts that the Draft EIR “does not adequately analyze a reasonable range of feasible project alternatives.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required. The commenter suggest that “a reduced version of Alternative C” be included as an alternative to the Development Project, but the commenter does not provide any additional details about how such an alternative would substantially reduce the significant impacts of the Development Project while meeting the basic project objectives. It should be noted that Section 15126.6(a) of the CEQA Statute and Guidelines states, “An EIR need not consider every conceivable alternative to a project.”


This comment cites language from CEQA, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Responses to Comments Beber-1 through Beber-60.


The commenter is referred to Responses to Comments Beber-1 through Beber-60. Based on these responses, recirculation of the Draft EIR is not required.

Comment Letter Bekey

Response to Comment Bekey-1

This comment expresses opposition to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.





Comment Letter Bersin

Response to Comment Bersin-1

This comment expresses support for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses support for TOD projects and the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment asks questions and makes statements about alternatives to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Bishop, Mirja

Response to Comment Bishop, Mirja-1




Response to Comment Bishop Mirja-2








Response to Comment Bishop Mirja-5












Comment Letter Bishop, Robert

Response to Comment Bishop, Robert-1

This comment makes a general statement about impacts of the Development Project and asks for the Development Project to be modified and traffic impacts to be reduced, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment is the same as Comment Abarbanel-4. The commenter is referred to Response to Comment Abarbanel-4.


This comment is substantially the same as Comment Abarbanel-5. The commenter is referred to Response to Comment Abarbanel-5.








The commenter is referred to Response to Comment Arenberg-5.



Comment Letter Broner


Comment Letter Christensen

Response to Christensen-1

This comment expresses opposition to comments made by Ken Alpern and the “Mar Vista Neighborhood,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses opposition to comments made by Ken Alpern and the “Mar Vista Neighborhood” about the size and character of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about “overbuilding parking facilities,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses opposition to comments made by Ken Alpern and the “Mar Vista Neighborhood,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment makes suggestions about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Cimiluca


Comment Letter Clark

Response to Comment Clark-1




















Regarding extension of the comment period for the Draft EIR, the commenter is referred to Response to Comment City Council (Paul Koretz) A-1.

Comment Letter Coccio

Response to Comment Coccio-1

This comment expresses opposition the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.






















Regarding visual character impacts associated with the Development Project, the commenter is referred to Response to Comment Alpern A-3.



Comment Letter Cohon

Response to Comment Cohon-1

This comment expresses opposition the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses concern about the loss of land zoned Light Industrial, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


Regarding size of the Development Project and visual character, the commenter is referred to Response to Comment Alpern A-3.


Regarding traffic impacts of the Development Project, the commenter is referred to Response to Comment Alpern A-4.




The Draft EIR discloses the Development Project’s significant and unavoidable impacts at the intersection of Pico Boulevard and Sepulveda Boulevard and at the intersection of Olympic Boulevard and Sepulveda Boulevard (refer to Table IV.N-15 on page IV.N-140 in Section IV.N [Transportation/Traffic] of the Draft EIR and Table IV.N-16 on page IV.N-148).








The project described in the NOP included developing the Development Project site with mixed land uses, including 538 multi-family residential units in four buildings over two stories of commercial land uses (266,800 square feet) and subterranean parking. The project described and analyzed in the Draft EIR meets this description.

Also, the commenter is referred to Response to Comment Cohon-17.


This comment is the same as Comment Bishop, Robert-1. The commenter is referred to Response to Comment Bishop, Robert-1.
















The environmental impacts identified in the Draft EIR for the Casden Sepulveda Project are based on the project details included in Section II (Project Description) of the Draft EIR.


This comment expresses opposition to the Development Project as proposed, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Commins

Response to Comment Commins-1

This comment requests that the Development Project not contain any residential land uses, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment requests that the zoning of the Development Project site remain as Light Industrial, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment requests changes to the design of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



The Development Project site is not adjacent to any residential properties. It should be noted that the Development Project would contain “step backs and setbacks.” The commenter is referred to the following text that is on page IV.B-26 in Section IV.B (Aesthetics) of the Draft EIR:

The stepped and articulated elements of the design of the upper residential structures along Pico Boulevard and Sepulveda Boulevard would soften the massing of the Development Project as a whole and the overall height, as viewed from a pedestrian level near the Project site (refer to Figures II-24, II-25, and IV.B-8 through IV.B-12).

Along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas (refer to Figures II-23 through II-26). The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza area along Sepulveda Boulevard connect to the Development Project’s smaller scale retail environment with neighborhood tenants and outdoor dining (refer to Figures II-24 and II-25). In addition, a portion of the second commercial level on Sepulveda Boulevard would be terraced to allow for additional outdoor dining.


Regarding the Development Project’s inclusion of a parking structure, the commenter is referred to page II-59 of Section II (Project Description) of the Draft EIR that states the Development Project includes 2,029 parking spaces in five subterranean parking levels.

This comment also requests that the Development Project include a bus/rail transfer station, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding the Development Project’s inclusion of pedestrian/bicycle amenities, some of the public pedestrian amenities that are included as part of the Development Project are included in Response to Comment Commins-3. Also, the commenter is referred to the bicycle amenities included as part of Mitigation Measure N-3, which would be implemented as part of the Development Project. Additionally, as part of the Expo 2 Project, Metro would develop a bicycle/pedestrian path at the southern edge of the Development Project site.


This comment requests that the Development Project include a plan for “maintaining long term small business presence along Pico and Sepulveda,” but the comment does not state a specific concern or



question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment implies that the traffic study prepared for the Development Project is not thorough and that the Development Project would result in “regional traffic impacts.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this implication. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Regarding “funding the grade separation for the Expo Line at Sepulveda Blvd.,” the commenter is referred to Mitigation Measure N-3 on page IV.N-136 in Section IV.N (Transportation/Traffic) of the Draft EIR that is as follows:

N-3: The Applicant shall implement a mitigation package in coordination between LADOT and Council District 5, and the surrounding community that shall include the three major components listed below. The determination of the “fair share” cost of this mitigation shall be subject to final approval by Council District 5 and LADOT. Subsequent to this determination, the Applicant shall be responsible for executing the appropriate agreement to guarantee the Development Project’s obligation to said agreement, prior to the issuance of any certificate of occupancy.

1. The Applicant shall provide funding assistance, fair share cost consideration, at the discretion of LADOT, for all aspects of the Expo Light Rail (ELR) Phase 2 – Pico Boulevard/Sepulveda Boulevard Station development including: grade separated station construction, transit station enhancements, parking meter technology upgrades, shuttle / circulator services, etc.

2. The Applicant shall provide funding assistance, fair share cost consideration at the discretion of LADOT, for all applicable aspects of the City’s Mobility Hub concept to the planned ELR Phase 2 Pico/Sepulveda Station including, but not limited to such measures as: secure bicycle parking, bicycle sharing, hourly car rentals, and a folding bike leasing program.

The Applicant shall provide funding assistance, fair share cost consideration at the discretion of LADOT, for all available Capital Improvement projects in the general area surrounding the Development Project site.




This comment requests that the Development Project include a “public park component and/or mitigation funds for regional open space,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

The commenter is referred to Mitigation Measures M-9 and M-10 on page IV.M-47 in Section IV.M (Public Services) of the Draft EIR that are as follows:

M-9. The Development Project Applicant shall pay all required parkland fees pursuant to LAMC Section 21.10.3(a)(1).

M-10. In consultation with the City of Los Angeles Department of Recreation and Parks, the Development Project Applicant shall be required to comply with one or more of the following: 1) dedicate two acres of parkland per 1,000 residents, 2) pay in-lieu fees for any land dedication requirement shortfall, or 3) provide on-site improvements equivalent in value of the in-lieu fees, or any portion thereof.

Also, the commenter is referred to Response to Comment Purcell-4.

Comment Letter Conger

Response to Comment Conger-1


Comment Letter Cosidine

Response to Comment Cosidine-1

This comment is substantially the same as Comment Alpern A-3. The commenter is referred to Response to Comment Alpern A-3.





Comment Letter Davis

Response to Comment Davis-1

Regarding the commenter’s statement about the traffic study for the Development Project being outdated, the commenter is referred to Abarbanel-4. Regarding the commenter’s statement about “non-project traffic,” the commenter is referred to Abarbanel-5.


This comment includes the same statements made in Comment Bishop, Robert-1, Comment Abarbanel-6, Comment Abarbanel-7, and Comment Cohon-6. The commenter is referred to Response to Comment Bishop, Robert-1, Response to Comment Abarbanel-6, Response to Comment Abarbanel-7, and Response to Comment Cohon-6.



Regarding parking for the Expo 2 Project light-rail line station spanning Sepulveda Boulevard, the commenter is referred to Response to Comment Arenberg-5.



Comment Letter Davison

Response to Comment Davison-1

This comment includes statements that are the same as those included in Comments Abarbanel-1 and Abarbanel-3. The commenter is referred to Responses to Comments Abarbanel-1 and Abarbanel-3.




This comment is the same as Comment Abarbanel-2. The commenter is referred to Response to Comment Abarbnel-2.












This comment expresses concern about traffic in West Los Angeles, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Day

Response to Comment Day-1

This comment expresses opposition to comments made by Ken Alpern, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Response to Comment Day-2

In Comment Day-1, the commenter expresses opposition to the attached comment letter submitted by Kenneth Alpern (refer to Comment Letter Alpern A). (Responses to Commenter Letter Alpern A are provided in this document.) However, this comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Del Moral

Response to Comment Del Moral-1




















Comment Letter Diamond

Response to Comment Diamond-1

The commenter will be notified of all “hearings, filings and related events” associated with the Development Project, as provided by the procedural requirements of the LAMC.


This comment includes statements about the commenter’s neighborhood and the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment includes statements about traffic on Beverlywood Street, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses concern about traffic impacts on Beverlywood, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. The commenter is referred to Response to Comment Diamond-5.


The traffic study prepared for the Development Project analyzed a total of 54 signalized intersections (plus 2 unsignalized intersections). The study of those locations indicated that potential impacts could occur at three locations at the outermost boundary of the study area: Wilshire Boulevard and Westwood Boulevard (intersection no. 3), National Boulevard and Westwood Boulevard (intersection no. 48), and Venice Boulevard and Sepulveda Boulevard (intersection no. 54). As a result, in order to assure that the traffic study identified all likely potential traffic impacts of the Development Project, the study area was expanded to include an additional 7 intersections adjacent to but farther away from the Development Project site: Lindbrook Drive and Westwood Boulevard, Wilshire Boulevard and Glendon Avenue, Overland Avenue and National Place, Venice Boulevard and Sawtelle Boulevard, Venice Boulevard and Overland Avenue, Sepulveda Boulevard and San Diego Northbound On/Off-Ramps, and Sepulveda Boulevard and Washington Place. This supplemental analysis is included in Appendix E of the Final EIR.

As shown in the supplemental analysis, the Development Project would not result in any significant traffic impacts to any of the additional intersections, and despite the presence of potential significant Development-Project-related traffic impacts at three of the “outer ring” of the 54 original study intersections, as identified in the “Revised December 2009” traffic study prepared for the Development Project (refer to Appendix IV.N of the Draft EIR), the supplemental analysis confirms that no significant impacts would occur beyond those previously identified in the Draft EIR (i.e., no significant traffic impacts would occur within the Beverlywood Community). Therefore, the original scope and scale of the traffic study contained in the Draft EIR adequately and fully identifies all potential impacts within the surrounding area, and no further analysis is warranted.




This comment includes statements about traffic to and from Century City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. The commenter is referred to Response to Comment Diamond-5, Response to Comment Abarbanel-5, and Response to Comment Beber-14.


This comment expresses an opinion about traffic impacts of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

However, for clarification, as detailed in Section IV.N (Transportation/Traffic) of the Draft EIR, the Development Project would generate a total of approximately 13,713 net new trips per day, not the “over 14,000” trips noted by the commenter. Additionally, as identified in Section IV.N, only about one-half of these anticipated trips would travel through the intersection of Pico Boulevard and Sepulveda Boulevard to enter or exit the Development Project site, with the remainder of the Development Project trips accessing the site from other travel routes. Further, although LADOT’s November 30, 2011 assessment letter of the Development Project’s traffic study (refer to Appendix IV.N.7 of the Draft EIR) indicates that a total of 30 intersections could be significantly impacted by Development-Project-related traffic, that letter also notes that “…three (3) are temporary impacts in that the project would result in a significant traffic impact only when evaluating the ‘existing plus project’ scenario. When these intersections are evaluated in the project’s future horizon year, the intersections are no longer significantly impacted.” Therefore, as noted in Section IV.N, the Development Project would result in a total of 27 significant impacts, prior to mitigation, although no feasible mitigation measures are identified for 22 of these impacted locations, which would exhibit significant and unavoidable impacts.


All of the additional study intersections suggested by the commenter are located outside the study area for the Development Project, with the exception of the intersection of the Santa Monica Freeway and Overland Avenue that is already included as an analyzed study intersection. In fact, both the westbound Santa Monica Freeway on/off-ramps on Overland Avenue opposite National Boulevard and the nearby eastbound Santa Monica Freeway off-ramp at National Place were analyzed in the traffic study prepared for the Development Project, as intersections 49 and 50, respectively. As a result, these suggested



intersection locations are outside the area expected to experience any traffic-related significant impacts from the Development Project. Also, the commenter is referred to Response to Comment Diamond-5.


All of the projects noted by the commenter are located either within the City of Beverly Hills or in Century City or other areas of the City of Los Angeles and are beyond the 1.5-mile related projects study area identified in the traffic study prepared for the Development Project. The 1.5-mile radius for identification of specific related projects is typical for traffic studies prepared in the West Los Angeles area and throughout the region, and was reviewed and approved by LADOT as conforming to its current traffic study policies and procedures. Additionally, a review of the traffic impact analyses for each of these projects indicates that many of the projects noted are relatively nominal “net” trip generators (due primarily to their proposed redevelopment of existing developed sites and the subsequent removals of the existing traffic associated with their individual sites); information regarding the potential trip generation for many of the suggested additional projects can be found on the City’s Planning Department website (www.cityplanning.lacity.org). Further, due to their more distant locations (approximately 2 or more miles to the east of the Development Project site), potential traffic additions from these projects at any of the 61 total intersections (54 originally-analyzed intersections plus the 7 supplemental locations [refer to Response to Comment Diamond-5]) evaluated in the traffic study for the Development Project would be minimal, based on the traffic study information for many of these projects, which are also included in the City Planning Department’s website. As a result, traffic generated by these additional projects would not substantially affect the conclusions of the project traffic study. It is also of note that several of the projects noted by the commenter were proposed after the completion and approval by LADOT of the Development Project traffic study; projects proposed after the date of the Development Project’s NOP (circulated from June 10, 2009 to July 10, 2010) are not required by CEQA to be subsequently added to the environmental analyses for a project. Additionally, the effects of traffic generated by related projects located outside the study area or projects not yet proposed at the time of preparation of the traffic study are assumed to be included in the 1.0 percent annual ambient traffic growth factor described in the traffic study, as described on page IV.N-105 in Section IV.N (Transportation/Traffic) of the Draft EIR and page 73 of the traffic study in Appendix IV.N of the Draft EIR. Also, the commenter is referred to Response to Comment Kassan-3.

It is also important to note that at least one of the related projects already contained in the project traffic study is no longer proposed (Westside Medical Center, aka Bundy Village; related project no. 22), and will no longer add traffic to the study area. This former project, which is located closer to the Development Project site than any of the 10 potential or ongoing developments noted by the commenter, would have produced nearly 20,000 net new trips per day on the surrounding roadway network, including over 750 trips during the morning peak hour and over 1,800 trips during the afternoon peak hour. As a result, the inclusion of traffic generated by this former project, in addition to the conservative “existing” traffic volumes for the study area used in the traffic study for the Development Project (refer to Response to Comment Abarbanel-4) along with the increases in area traffic associated with the conservative 1.0



percent annual ambient traffic growth factor further increased the forecast future traffic volumes and associated levels of service at the intersections examined in the traffic impact analyses for the Development Project, resulting in a highly conservative estimate of future traffic conditions in the vicinity of the Development Project site. The Bundy Village project alone represents approximately 50 percent of the total morning peak-hour trips generated by the commenter’s identified projects (with the exception of the William Morris and Century projects, for which no trip generation data or traffic studies were available) and actually generates more trips than the total of these “additional” projects during the afternoon peak hour. Therefore, the Development Project traffic study includes appropriate estimates of future traffic growth resulting from on-going area development and as such, reasonably represents and identifies the potential traffic impacts of the Development Project.

As described in detail in the traffic study prepared for the Development Project, LADOT’s significance criteria for the evaluation of intersection impacts identifies that intersections with higher traffic volumes (and therefore, generally, higher levels of service) are more sensitive to incremental traffic additions resulting from a project (such as the Development Project), the likelihood of a significant project-related impact occurring an intersection with a higher level of service is greater. Therefore, the traffic analysis contained in the Draft EIR presents a conservative evaluation of potential Development-Project-related impacts in the study area.


The commenter is referred to Response to Comment Tippit B-3.






The commenter is referred to Response to Comment Caltrans-11. Also, the haul route used during the Development Project’s construction period likely would not use residential-neighborhood streets, because such streets do not provide convenient access to the San Diego and Santa Monica Freeways.





Comment Letter Dunn


Comment Letter Edwards

Response to Comment Edwards-1

















This comment includes statements about government decision-making, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Elliot

Response to Comment Elliot-1






As discussed in Section IV.I (Land Use and Planning) of the Draft EIR (refer to page IV.I-31), the California Air Resources Board (ARB) recommends avoiding siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles per day. Based on this recommendation, the Department of City Planning requires that EIRs include a health risk assessment (HRA) to address exposure impacts to sensitive receptors within 500 feet of a freeway. Because the Development Project site is located adjacent to the San Diego Freeway a HRA was prepared for the Development Project to determine its land use compatibility associated with placement of residential land uses near the San Diego Freeway. The HRA concluded that residents of the Development Project would be exposed to a significant outdoor health risk, due to the Development Project site’s proximity to the San Diego Freeway. As disclosed in the Draft EIR (page IV.I-57), the Development Project would be inconsistent with ARB’s siting recommendations, and a significant impact related to this inconsistency would occur.



The remainder of the comment expresses an opinion about the availability of commercial land uses in the Development Project area, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about the commenter’s review of a questionnaire mailed by the Project Applicant, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.






Comment Letter Emerson A

Response to Comment Emerson A-1


Comment Letter Emerson B

Response to Comment Emerson B-1

Regarding traffic mitigation measures for the Development Project, the traffic mitigation measures are identified in the Draft EIR, beginning on page IV.N-137 in Section IV.N (Transportation/Traffic) of the Draft EIR and have been available for public review and comment since April 12, 2012 and will continue to be review until the mitigation measures are implemented (if the Development Project is approved).

Regarding height of the Development Project in relation to surrounding buildings, including the residential land uses to the south of the Development Project site, the commenter is referred to Response to Comment Alpern A-3.

Regarding shade/shadow impacts to land uses to the east of the Development Project site, the commenter is referred to page IV.B-55 in Section IV.B (Aesthetics) that includes a shade/shadow impact analysis for the Development Project. As discussed, the Development Project would not result in any significant shade/shadow impacts to any offsite properties, including those located to the east of the Development Project site.


Regarding traffic impacts of the Development Project, the commenter is referred to Response to Comment Abarbanel-6.


Parking impacts of the Development Project are based on compliance with the LAMC parking requirements. As discussed on page IV.N-102 in Section IV.N (Transportation/Traffic) of the Draft EIR, the Development Project would provide parking in compliance with the LAMC parking requirements. The parking requirements for the various land uses (including those that are part of the Development Project) are defined in LAMC Section 12.21. The parking requirements for residential units also include



reduced parking ratios for low-income and/or senior residential units. Regarding the number of residential parking spaces provided versus the total number of residential units, the Development Project includes a total of 538 apartments (including 479 market rate units [50 studios, 233 1-bedroom, 179 2-bedroom, and 17 3-bedroom or larger]), plus 59 senior affordable units (provided at the same ratio of sizes as for the market rate units). In total, the Development Project provides 827 resident parking spaces, plus 135 guest spaces, for an overall ratio of approximately 1.79 spaces per unit. This ratio is typical of the combined “mixed” parking supplies for most recent projects approved in the City. However, it is of note that the 59 senior affordable units require only 0.5 parking spaces per unit, or a total of about 30 spaces. Therefore, excluding these units, the 479 market rate units would be provided with a total of approximately 932 spaces (827 total spaces less 30 for the senior affordable units plus an additional 135 guest spaces), which is substantially more than the approximately 792 spaces required for such units by the LAMC. This results in an overall average of approximately 1.95 spaces per market rate unit (or about 1.67 resident spaces plus 0.28 guest space per unit). These “actual” provided parking space ratios are adequate, especially in light of the Development Project site’s location immediately adjacent to a key public transit facility (the Expo 2 Project line). Additionally, the commercial portions of the Development Project would provide an additional 1,067 parking spaces (or 4.0 spaces per 1,000 square feet for the approximately 266,800 square feet of total commercial/retail space within the Development Project. Much of this commercial/retail space is expected to be only lightly used or closed during the late evening/nighttime periods, and would be available if additional temporary residential guest parking is needed. For these reasons, no further analysis is required for this issue.

Regarding restriction on the senior units, City Ordinance 179681, which governs the density bonus program, requires a covenant restricting units for at least 30 years from the issuance of the certificate of occupancy. A longer period could be required by other financing or subsidy programs. At this time, the Project Applicant does not know whether any of these other programs with longer restriction periods could be used.

All parking associated with the Development Project would be secured.


The commenter is referred to Response to Comment Emerson B-1.

Comment Letter Endo

Response to Comment Endo-1

Regarding road maintenance, the Development Project would generate tax revenue for the City, a portion of which would go toward building and maintaining roads.

The environmental impacts identified in the Draft EIR for the Casden Sepulveda Project are based on the project details included in Section II (Project Description) of the Draft EIR.



Also, the commenter is referred to Response to Comment Abarbanel-5.




This comment is the same as Comment Abarbanel-4. The commenter is referred to Response to Comment Abarbenel-4.


This comment is substantially the same as Comment Abarbanel-5. The commenter is referred to Response to Comment Abarbenel-5.








This comment expresses an opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Fahn

Response to Comment Fahn-1
















Comment Letter Feit

Response to Comment Feit-1

This comment states that the Development Project would affect the commenter, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

















Comment Letter Feldman

Response to Comment Feldman-1




















Comment Letter Fisher


Comment Letter Frank


Comment Letter Frederick

Response to Comment Frederick-1

The Draft EIR was circulated for review from April 12, 2012 to June 10, 2012, and all interested parties (including the public) was given the opportunity to comment on the Draft EIR (as is evident by this comment).


This comment includes statements that are the same as those included in Comments Abarbanel-1 and Abarbanel-3. The commenter is referred to Responses to Comments Abarbanel-1 and Abarbanel-















Comment Letter Fuligni

Response to Comment Fuligni-1
















Comment Letter Garven

Response to Comment Garven-1

This comment expresses to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Garven-2.






Regarding traffic mitigation measures for the Development Project, the traffic mitigation measures are identified in the Draft EIR, beginning on page IV.N-137 in Section IV.N (Transportation/Traffic) and have been available for public review and comment since April 12, 2012.


This comment expresses opposition to development in general, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

The commenter should note that the Development Project site is already entirely paved. The Development Project would provide publicly-accessible areas with landscaping, trees, and street furniture that currently do not existing on the site.

Comment Letter Georskey


Comment Letter Gold

Response to Comment Gold-1

This comment expresses support for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Goodman, Robert

Response to Comment Goodman, Robert-1

Regarding size of the Development Project in relation to surrounding land uses, the commenter is referred to Response to Comment Alpern A-3.

Regarding the date of the traffic study, the commenter is referred to Response to Comment Abarbanel-4.


The “likely needs of the proposed EXPO Line” is not an environmental issue related to the Development Project. Thus, addressing this topic in the Draft EIR is not required. (An EIR has already been prepared and certified for the Expo 2 Project.)


This comment requests a reduction in the size of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Goodman, Roger

Response to Comment Goodman, Roger-1



The commenter is referred to Response to Comment Goodman, Robert-2 and Response to Comment Abarbanel-3.


Regarding the commenter’s statement that the traffic study for the Development Project is outdated, the commenter is referred to Response to Comment Abarbanel-4. Regarding the commenter’s statement about “non-project traffic on nearby residential streets,” the commenter is referred to Response to Comment Abarbenal-5.





Comment Letter Hays


Comment Letter Healy


Comment Letter Heller

Response to Comment Heller-1



Regarding the commenter’s statement that the traffic study for the Development Project is outdated, the commenter is referred to Response to Comment Abarbanel-4.


This comment expresses an opinion about the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment expresses an opinion about the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Hensen

Response to Comment Hensen-1




















Comment Letter Hetz

Response to Comment Hetz-1

This comment expresses concern about the Development Project and the Metro parking structure, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The parking structure associated with the Expo 2 Project is not part of the Development Project or the Draft EIR. Concerns about the Expo 2 Project parking structure should be directed to Metro.


As discussed in Section IV.N (Transportation/Traffic) of the Draft EIR, the Development Project includes 2,029 parking spaces, which includes 827 “free” parking spaces to serve the 538 residential units plus 135 guest parking spaces and 1,067 parking spaces to serve the retail land uses. The Development Project would include adequate parking to serve the needs of the proposed land uses. Additionally, access to the retail spaces also would be more direct and would allow the use of shopping carts, which would not operate off the Development Project site. Thus, shopping at the Development Project site would be more convenient for people who park at the Development Project site. There is no reason to assume that



parking at the Expo 2 Project parking structure would be more convenient for users of the Development Project.

Comment Letter Illegible Name A


Comment Letter Illegible Name B


Comment Letter Illegible Name C


Comment Letter Jamatas

Response to Comment Jamatas-1




















Comment Letter Kageyama

Response to Comment Kageyama-1

This comment expresses support of comments made by CD11, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.










Comment Letter Kassan

Response to Comment Kassan-1

The commenter is referred to Response to Comment Abarbanel-4 and Response to Comment Diamond-9.




The commenter is referred to Response to Comment Abarbanel-4 and Response to Comment Diamond-9. At the time the traffic study for the Development Project was initially prepared, the assumption that preparation of the traffic study could take three years was a reasonable assumption approved by LADOT. Additionally, the 1.0 percent annual ambient traffic growth factor used in the traffic study for the Development Project already presents a conservative (i.e., “higher”) estimate of potential future traffic growth than is likely to actually occur. As described on page IV.N-105 in Section IV.N (Transportation/Traffic) of the Draft EIR and page 73 of the traffic study (refer to Appendix IV.N), the then-current 2004 CMP, actual anticipated traffic growth in the “Westside” area encompassing and surrounding the study area vicinity was forecast to be approximately 0.80 to 0.85 percent annually (inclusive of both ambient growth and traffic from cumulative area development). As such, use of the assumed 1.0 percent annual growth factor for the 3-year construction and occupancy period assumed in the traffic study for the Development Project would actually equate to traffic growth occurring over an approximately 3.5 to 3.75-year period if the CMP ambient growth rate of 0.80 to 0.85 percent annually was utilized.

In addition, the 2010 CMP document has adjusted the anticipated annual growth rate for the study area downward to approximately 0.14 percent annually (again inclusive of both general ambient traffic growth



and cumulative development traffic), based on newer demographic data and economic information. As a result, the use of the assumed 1.0 percent ambient growth factor alone for the assumed 3-year period would equate to over 21 years of ambient growth using the 2010 CMP growth factor. Again, the commenter is also referred to Response to Comment Abarbanel-4.

Further, as described in the Draft EIR, these baseline ambient traffic growth estimates were then increased by the addition of traffic generated by the 42 identified related projects, which in total are estimated to produce a total of over 53,000 additional daily trips throughout the study area, including over 3,600 new trips during the morning peak hour and over 5,600 new trips during the afternoon peak hour. Therefore, when taken together, the use of the conservative ambient traffic growth factor, plus the addition of traffic from the 42 identified related projects (at least one of which, the former Bundy Village/Medical Park project, related project no. 22) results in a highly conservative forecast of potential future traffic conditions in the study area, and represent levels of future traffic growth well beyond the assumed completion and occupancy year of 2012 of the Development Project (refer to Response to Comment Diamond-9). This highly conservative traffic estimation methodology also assures that all potential Development-Project-related impacts are identified.


The commenter is referred to Response to Comment Metro-7.




This comment repeats information from the Draft EIR about traffic impacts identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment repeats information from the Draft EIR about traffic mitigation measures identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment repeats information from the Draft EIR about the effectiveness of traffic mitigation measures identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment repeats information from the Draft EIR about traffic mitigation measures identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment repeats information from the Draft EIR about traffic mitigation impacts identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter makes an assumption that impacts along Sepulveda Boulevard would not be confined strictly to the study area, but the commenter does not provide any supporting evidence or analysis to support this assumption. As detailed in Section IV.N (Transportation/Traffic) of the Draft EIR, including the expanded analyses to evaluate potential impacts beyond the original 54 study intersections (refer to Appendix E of the Final EIR), the impacts at intersections throughout the west side were evaluated, and the results are presented in the Draft EIR.


As noted by the commenter, there are 5 intersections significantly impacted by the Development Project where potential mitigation measures may be available, Olympic Boulevard and Bundy Drive, Olympic Boulevard and Sepulveda Boulevard, Pico Boulevard and Centinela Avenue, Pico Boulevard and Sawtelle Boulevard, and National Boulevard and Sepulveda Boulevard, although improvements at those locations that could be used as mitigation for Development Project impacts are currently assigned to other projects (the Bundy Village/Medical Park project and another potential development project located at



3115 Sepulveda Boulevard). However, at 2 of those locations, Olympic Boulevard and Sepulveda Boulevard, and Pico Boulevard and Centinela Avenue, no physical roadway improvements are feasible, and the mitigation measures proposed by other area projects for these intersections consisted of implementation of left-turn phasing in one or more directions. While left-turn phasing can nominally improve the operations of some movements at these intersections, the additional signal time needed to implement the potential left-turn phases reduces the amount of “green” signal phase time for other more critical moves, and generally hinders the overall operations of the intersection. As a result, LADOT does not consider installation of left-turn phasing at an intersection to mitigate the impacts of a project. However, such traffic signal operational improvements could be included in the Development Project’s mitigation measures to address existing and potential future operational issues at these two locations, if it is determined by the City that either or both the Bundy Village/Medical Park project or the project at 3115 Sepulveda Boulevard are no longer active, and reassignment of these measures to the Development Project is deemed appropriate by LADOT.

Therefore, there are only 3 locations where potential mitigation measures may be available that would actually be considered to reduce the Development Project’s impacts. However, of these 3 locations, the previously-proposed improvement (installation of a westbound right-turn only lane, proposed by the Bundy Village/Medical Park project) at Pico Boulevard and Centinela Avenue would have no effect on the operations of the subject intersection during either the morning and afternoon peak hours (no change in CMA value or LOS during either period), and would not mitigate to any extent the Development Project’s significant impact at that location. As such, this implementation of this measure would result in unnecessary roadway construction and associated traffic disruptions and delay and therefore, would not be recommended for the Development Project. The potential improvements at the other two locations (installation of dual eastbound left-turn lanes on Olympic Boulevard at Bundy Drive, by the Bundy Village/Medical Park project, and installation of northbound and southbound right-turn only lanes on Sepulveda Boulevard at National Boulevard, proposed by a new development at 3115 Sepulveda Boulevard) would be effective in reducing the Development Project’s impacts at these intersections to less-than-significant levels. If it is determined by the City that either or both the Bundy Village/Medical Park project or the project at 3115 Sepulveda Boulevard are no longer active, the Applicant of the Development Project has indicated that, if acceptable to LADOT, the two mitigation measures currently assigned to these projects could be accepted by the Development Project. However, even if these two additional mitigation measures are assigned to the Development Project, a total of 20 significant and unavoidable (unmitigated) traffic impacts would remain.


The commenter is referred to Response to Comment Kassan-12.




As described on page IV.N-10 in Section IV.N (Transportation/Traffic) of the Draft EIR, due to uncertainties in the actual (State and/or City) funding of future ATCS signal coordination improvements, no future ATCS upgrades were assumed at intersections where the ATCS system has not already been implemented. At the present time, contribution to ATCS installation by individual development projects is being evaluated by LADOT on a case-by-case basis. Although there are 5 study intersections that are significantly impacted where future ATCS installation was not assumed; Olympic Boulevard and Bundy Drive (intersection 14), Olympic Boulevard and Barrington Avenue (intersection 15), Pico Boulevard and Centinela Avenue (intersection 25), Pico Boulevard and Bundy Drive (intersection 26), and Pico Boulevard and Gateway Boulevard (intersection 28), it is important to note that recent conversations with LADOT have indicated that they consider the ATCS installation at these locations to be funded, and therefore, this signal coordination upgrade is not available as Development-Project-related mitigation. However, similar to the reassignment of potential mitigation measures that could be reassigned to the Development Project (refer to Response to Comment Kassan-12), LADOT could further review its earlier opinion regarding the availability of ATCS as a potential traffic mitigation measure for the Development Project (commensurate on funding provided by the proposed project) at some or all of the remaining non-ATCS intersections in the study area (including but not necessarily limited to the five significantly impacted intersections noted above); if allowed as a mitigation measure, the installation of ATCS would reduce the impacts of the Development Project at each of the five subject intersection to less-than-significant levels. Nonetheless, the commenter is correct that the Development Project should not receive any mitigation credit for ATCS installations funded by the City or State, and since ATCS installation is not identified as mitigation for the Development Project, no such mitigation credits are taken in the Draft EIR.


This comment expresses an opinion about the traffic impacts identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about what is considered a traffic impact, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




This comment expresses an opinion about the traffic impacts identified for the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about traffic impacts of the Development Project based on information in the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about impacts of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. The commenter is referred to Response to Comment Abarbanel-5 and Response to Comment Beber-14.

Regarding the potential one-way couplet concept for the Pico/Olympic Plan, the commenter expresses an opinion regarding the effectiveness of the Pico/Olympic Plan. As described in the traffic study for the Development Project, implementation of the initial phase of the program, which is intended to provide additional peak-hour travel capacity along Olympic Boulevard and Pico Boulevard through consistency in the on-street parking restrictions throughout the subject project area, is already underway. The Phase 2 portion of the Plan, involving retiming of the traffic signals along both corridors to provide better traffic flows for the preferred directions of travel on each street (westbound for Olympic Boulevard, eastbound for Pico Boulevard) has experienced delays due to the current economic conditions, and is currently only partially completed. Phase 3, which will occur following a review of the effectiveness of the Phase 1 and Phase 2 program elements, is not yet scheduled. Therefore, the Development Project traffic study properly included those improvements associated with the Pico/Olympic Plan that are currently underway or are reasonably anticipated to be implemented within the study timeline. However, although the improvements associated with the Pico/Olympic Plan will provide additional peak-hour lanes in one or both directions at several of the intersections and roadway segments within the Development Project study area, no conclusions regarding the effectiveness of the Pico/Olympic Plan in addressing future area-wide congestion are drawn.










The recently-adopted City of Los Angeles Bicycle Master Plan identifies Tennessee Avenue thorough the study area (between approximately Federal Avenue on the west and Fox Hills Drive near Century City on the east) as a “bicycle friendly street.” This category of bicycle facility is designed to be used on local and collector streets, and does not provide exclusive bicycle lanes. However, as described in the Bicycle Master Plan document, bicycle friendly streets incorporate a “…combination of at least two traffic calming and intersection treatments, in addition to shared pavement marking and signage, to discourage non-local motor vehicle traffic and make it easier for bicycles and pedestrians to travel on local and collector streets and to cross intersections.” Traffic calming measures identified in the Bicycle Master Plan include additional stop signs at local street intersections, speed humps, mini traffic circles, or “bulb outs” at intersections to slow vehicular traffic, traffic diverters that would allow bicycle traffic (and emergency vehicle) access but prevent motor vehicle traffic, and raised medians at intersections with arterial streets to prevent non-local or cut-through traffic on such streets. Implementation of these measures as part of the City’s Bicycle Master Plan will reduce the potential for conflicts between bicyclists and motor vehicles. Additionally, while no significant future traffic increases on Tennessee Avenue are anticipated, either due to Development-Project-specific trips or from non-project traffic seeking to avoid existing or future congestion on the nearby arterial roadways (refer to Response to Comment Abarbanel-5), such traffic calming measures will act to reduce vehicular speeds on Tennessee Avenue and/or limit motor vehicle accessibility to some or all portions of the street from key arterial roadways, thereby reducing the viability of this street as a cut-through route, and further decreasing the potential for bicycle/motor vehicle conflicts. No additional analysis is warranted.








This comment expresses an opinion about implementation of mitigation, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. The commenter is referred to Response to Comment Kassan-28.


This comment expresses an opinion about implementation of mitigation, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. The commenter is referred to Response to Comment Kassan-28.


The commenter is referred to text on page IV.N-145 in Section IV.N (Transportation/Traffic) of the Draft EIR that states the following about the consideration of the First Mile/Last Mile program by the Development Project Applicant:

… at the time of the preparation of this study, the specifics of such programs were still being evaluated by the applicant, and as such, were not fully identified. Therefore, no detailed assessment of the potential effectiveness of these measures in reducing or mitigating the traffic impacts of the proposed Pico/Sepulveda Mixed-Use project has been included in this analysis. The Development Project Applicant has indicated to LADOT that their participation in such programs is a high priority, and that continued consultation and collaboration with both LADOT and Metro to identify specific measures and programs for the Development Project site would occur.

Additionally, Development Project Plans include bicycle storage near the transit plaza and zip car rental parking accessed at grade from Sepulveda Boulevard behind the retail land uses. Cyclists would be able to walk the short distance from the bicycle storage to the bike path on the south side of the Expo 2 Project light-rail line.

The Development Project Applicant met with the providers of bus services from Metro and the cities of Culver City and Santa Monica; they do not plan to move any of the bus stops.




This comment expresses opinions about use of the Development Project site and the types of land uses that should be included as part of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Additionally, the commenter is referred to Response to Comment Alpern A-6.


The segment of Pico Boulevard adjacent to the Development Project site currently provides an approximately 65-foot long eastbound left-turn lane at Sepulveda Boulevard, plus an approximately 60-foot long “open” space for transition to an existing median two-way left-turn lane that continues approximately another 300 feet to the west (to approximately Cotner Avenue). This two-way left-turn lane provides left-turn access in both directions to Pontius Avenue and several existing driveway on the north side of Pico Boulevard as well as to the existing project site (Cement Plant) and other access driveways on the south side of the street. The length of the two-way left-turn lane between the end of the eastbound left-turn lane “transition area” and the Development Project’s proposed Pico Boulevard driveway (without interfering with eastbound traffic making a left turn from Pico Boulevard onto Pontius Avenue) is approximately 150 feet, which is adequate to accommodate a vehicular queue of approximately 7 vehicles at one time.

A review of the Development Project’s potential (westbound) left-turn demands into the Development Project site from Pico Boulevard (refer to Figure IV.N-21 on page IV.N-97 in Section IV.N [Transportation/Traffic] of the DEIR) shows that this move would be relatively lightly used during the morning and afternoon peak commute periods, primarily due to conflicts with heavy eastbound traffic on Pico Boulevard during these times. As shown on Figure IV.N-21, during the morning peak hour, a total of only about 25 project trips would make this left-turn move, and during the afternoon peak hour, this demand would increase to about 77 trips. These demands equate to a peak arrival rate of less than 1 vehicle per minute during the morning peak hour, and about 2 vehicles per minute during the afternoon peak hour. Both of these values are well within the capacity of the existing two-way left-turn lane noted earlier, and as such, project-related traffic making this left-turn would not significantly affect the traffic flows or operations of Pico Boulevard. Additionally, it is recommended that eastbound Pico Boulevard adjacent to this driveway location exhibit a painted “Do Not Block Driveway” indication on the pavement, along with appropriate signage, such that eastbound vehicles on Pico Boulevard stopped at the Sepulveda Boulevard traffic signal do not queue in front of and block the driveway of the Development Project, in order to allow left-turning vehicles entering the Development Project site to do so during these times. Therefore, Pico Boulevard would provide an adequate on-street storage area for westbound



vehicles turning left into the Development Project site, and no significant disruption of Pico Boulevard traffic operations due to this move would occur.


This comment describes the Development Project’s access at Pico Boulevard, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Kassan-30.


This comment expresses an opinion about Development Project traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Kassan-30.




The commenter is referred to Response to Comment Alpern A-9.


This comment expresses opinions about use of the Development Project site and the types of land uses that should be included as part of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. Also, the commenter is referred to Response to Comment Alpern A-6.








This comment expresses opinions about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The purpose of the Draft EIR is to assess and disclose the environmental impacts of the proposed Development Project; the purpose is not to determine what land uses should or should not be developed; this decision is ultimately determined by the decision-making bodies.


Section VI (Alternatives to the Proposed Project) of the Draft EIR includes six alternatives to the Development Project, including the following:

Alternative A (No Project, Continuation of Existing Uses): Assumes that the Development Project site would remain in its current condition, developed with the California Portland Cement batch plant and West Los Angeles Building Materials facilities.



Alternative B (No Project, Zoning Compliant Industrial Development): Assumes removal of all existing uses from the Development Project site and development of the site with industrial land uses in conformance with standards associated with the existing land use designation and zoning for the portion of the Development Project site zoned M2-1-O.

Alternative C (Mixed-Use, Office and Industrial Development): Assumes removal of all existing uses from the Development Project site and development of the site with office and industrial land uses in conformance with standards associated with the existing land use designation and zoning for the portion of the Development Project site zoned M2-1-O.

Alternative D (Retail Only Development): assumes removal of all of the existing buildings that are currently located on the Development Project site and development of the site with the two stories of retail uses described under the Development Project.

Alternative E (Residential Only Development): Assumes removal of all existing uses from the Development Project site and development of the site with the four residential buildings described under the Development Project.

Alternative F (Reduced Commercial/Residential Mixed-Use Development): Assumes removal of all existing uses from the Development Project site and development of the site in a manner similar to the Development Project but with a smaller commercial component.

The primary purpose of an alternatives analysis in an EIR is to assess a range of reasonable alternatives to the proposed project that would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant impacts of the project. With the exception of Alternative A, all of the alternatives meet most of the objectives of the Development Project (refer to Response to Comment City Council [Paul Koretz] B-6). Additionally, as discussed throughout Section VI of the Draft EIR, all of the alternatives would reduce or avoid some of the significant impacts of the Development Project. Thus, the alternatives included in the Draft EIR compose a “range of reasonable alternatives” to the Development Project, and no additional alternatives are required. Also, it should be noted that Section 15126.6(a) of the CEQA Statute and Guidelines states, “An EIR need not consider every conceivable alternative to a project.”




Regarding alternatives to the Development Project that include land uses that are consistent with the existing Light Industrial zoning for the site, the commenter is referred to Alternatives B and C in Section VI (Alternatives to the Proposed Project) of the Draft EIR.



This comment includes statements about employment and expresses opinions about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about truck/traffic generation associated with industrial land uses, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about implementation of a transit hub at the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Regarding the commenter’s suggestions to include “Alternatives G, H, and I” in the Draft EIR, the commenter is referred to Responses to Comments Kassan-34 through Kassan-44. Additionally, the commenter is referred to the comparison of traffic impacts that would occur under each of the alternatives in Section VI (Alternatives to the Proposed Project) of the Draft EIR to the traffic impacts that would occur under the Development Project. As discussed, each of the alternatives would substantially reduce the significant traffic impacts identified for the Development Project.


The commenter is referred to the responses to comments prepared for Comment Letter Kassan.

Comment Letter Keller

Response to Comment Keller-1

The commenter asserts that the Development Project could impede the “‘Park & Ride’ potential of the critical Sepulveda/Pico station.” However, the commenter does not provide facts, reasonable assumptions



based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.


This comment includes statements about the people of the Brentwood Homeowner’s Association (BHA), but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment requests additional evaluation of the Development Project and makes a general statement about impacts of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. Also, the Commenter is referred to Response to Comment Keller-4.


Regarding traffic impacts of the Development Project, the commenter is referred to Response to Comment Abarbanel-7.

Regarding the size and character of the Development Project, the commenter is referred to Responses to Comments Abarbanel-3 and Alpern A-3.

Regarding the assertion that the Development Project would “impede access to the Expo Line station,” the commenter is referred to Response to Comment Keller-1.

Regarding the project analyzed in the Draft EIR, the commenter is referred to Response to Comment Cohon-17.


This comment includes statements of opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Korody

Response to Comment Korody-1





















This comment expresses opposition to the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Lacan

Response to Comment Lacan-1




















Comment Letter Lacter

Response to Comment Lacter-1

This comment includes the same statements made in Comments Abarbanel-1 and Abarbanel-3. The commenter is referred to Responses to Comments Abarbanel-1 and Abarbanel-3.


This comment is the same as Comment Abarbanel-4. The commenter is referred to Response to Comment Abarenel-4.


This comment is substantially the same as Comment Abarbanel-5. The commenter is referred to Response to Comment Abarenel-5.










This comment includes an opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Lawrence

Response to Comment Lawrence-1

This comment includes statements and questions about the Development Project site area and development near the Expo 2 Project light-rail line, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment repeats some of the requirements outlined in Mitigation Measure N-2, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes an opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts.



However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Leeb

Response to Comment Leeb-1

This comment includes statements about the commenter and commuting the Development Project area, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.






This comment expresses support for “high-volume, mixed-use residential [development] near transit stations,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Liber

Response to Comment Liber-1

This comment is the same as Comment Keller-1. The commenter is referred to Response to Comment Keller-1.











Comment Letter Linell

Response to Comment Linell-1




















Comment Letter Logan

Response to Comment Logan-1

Regarding the comments submitted by the West of Westwood Homeowners Association, the commenter is referred to the responses prepared to Comment Letter Tippit A.

Regarding traffic impacts of cumulative development in the Development Project area, the commenter is referred to page IV.N-105 of Section IV.N (Transportation/Traffic) of the Draft EIR for an analysis of cumulative traffic impacts. Related projects (including the Expo 2 Project) that were assumed in the analysis are shown on Table IV.N-107 and listed on Table IV.N-12 on page IV.N-117. As disclosed, under the Cumulative-With-Project traffic condition, the Development Project would result in significant and unavoidable impacts at 22 study intersections.

Regarding the parking structure associated with the Expo 2 Project, this parking structure is not part of the Development Project and the location of the parking structure is not under the control of the Project Applicant.



Regarding traffic on neighborhood streets, the commenter is referred to Response to Comment Abarbanel-5.

Regarding the closing of the San Diego Freeway ramps at Wilshire Boulevard, these closures are not associated with the Development Project and are temporary. The ramps will be open in Summer 2013, and current traffic congestion related to these closures will be alleviated.


The commenter asserts that the Development Project would “ruin the quality of life” of the commenter’s neighborhood. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

The Development Project includes a pedestrian/bicycle path along the southern edge of the Development Project site that could be used for running.



Comment Letter Lovejoy

Response to Comment Lovejoy-1

This comment is the same as Comment Logan-1. The commenter is referred to Response to Comment Logan-1.




This comment is the same as Comment Logan-3. The commenter is referred to Response to Comment Logan-3.




The commenter is referred to the responses to comments submitted in Comment Letter Tippit A.

Comment Letter Macdonald

Response to Comment Macdonald-1


The commenter should note that the Expo 2 Project light-rail line at Exposition Boulevard and Sepulveda Boulevard will not be an at-grade crossing but will span over Sepulveda Boulevard.

Response to Comment Macdonald-2

Regarding traffic mitigation measures for the Development Project, the commenter is referred to the traffic mitigation measures identified for the Development Project, beginning on page IV.N-137 in Section IV.N (Transportation/Traffic) of the Draft EIR.

The commenter should note that it is not the responsibility of the Development Project to mitigate for existing poor traffic conditions, just the impacts caused by the Development Project.

Regarding air quality mitigation measures for the Development Project, the commenter is referred to the air quality mitigation measures identified for the Development Project, beginning on page IV.C-43 in Section IV.C (Air Quality) of the Draft EIR.

Comment Letter Maly

Response to Comment Maly-1

This comment is substantially the same as Alpern A-3. The commenter is referred to Response to Comment Alpern A-3.



















Comment Letter Martin

Response to Comment Martin-1


Response to Comment Martin -2


















Comment Letter Mayer




Comment Letter McKinnon

Response to Comment McKinnon-1

This comment asks that the existing zoning for the Development Project site to not change, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter McKnight

Response to Comment McKnight-1

This comment includes the same statements included in Comments Abarbanel-1 and Abarbanel-3. The commenter is referred to Responses to Comments Abarbanel-1 and Abarbanel-3.

















Comment Letter Millman

Response to Comment Millman-1

This comment expresses an opinion about mitigation, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding the commenter’s statement about the Project Applicant handling “the costs of overhead transit bridges at Overland and Westwood” as mitigation, it is assumed that the commenter means mitigation for traffic impacts of the Development Project. The commenter provides no evidence of the effectiveness of the suggested mitigation’s ability to reduce significant traffic impacts of the Development Project. Additionally, the commenter shows no nexus between the traffic impacts of the Development Project and the suggested mitigation.


The commenter is referred to Response to Comment Macdonald-1. Additionally, any proposed development at other sites (if the developments are greater than certain size thresholds) would be required to undergo CEQA review.


This comment expresses opinions about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

The Development Project is a TOD, the purpose of which is to provide people convenient access to alternative forms of transportation other than driving single-occupancy vehicles by locating land uses of



any type near transit hubs/lines. Also, the commenter should note that the Development Project includes 59 affordable senior units.

Comment Letter Moskowitz

Response to Comment Moskowitz-1



This comment is the same as Alpern A-4. The commenter is referred to Response to Comment Alpern A-4.

















Comment Letter Moss


Comment Letter Murdock

Response to Comment Murdock-1

The commenter is referred to Responses to Comments Murdock-2 through Murdock-20 and Response to Comment Letter Kassan.


Regarding spot zoning, the commenter is referred to Response to Comment Alpern A-11.

The commenter is incorrect in stating that the Development Project Applicant “is also asking to change and eliminate the General Plan and Community Plan specific policies on preservation of industrial zones and uses.” The Development Project would not change or eliminate any existing policies and does not include any new policies to be adopted. Additionally, the Development Project would not be implemented unless appropriate land modifications to the land use requirements for the Development Project site are adopted. Also, the commenter is referred to Response to Comment Murdock-3.



The commenter is incorrect in stating that the text on page IV.I-6 in Section IV.I (Land Use and Planning) of the Draft EIR states that the Development Project is inconsistent with policies of the Framework Element related to preservation of industrial land; this statement is included in the text on page IV.I-37. The discussion of the Development Project’s consistency with the City’s Industrial Land Use Policy (ILUP) is included on page IV.I-61 and is as follows:

As discussed previously, according to the ILUP, the Development Project site is designated in an IMU District. Planning Staff direction for projects in the IMU is to preserve industrial zoning consistent with West Los Angeles Community Plan, and to evaluate opportunities as part of the Community Plan update for a new mixed use zone that may include industrial, commercial and a limited amount of compatible residential uses, that include a significant job component. As the



General Plan Amendment would prohibit industrial uses on the Development Project site, it is inconsistent with Framework Element policies to preserve industrial land. This would amount to a significant and unavoidable impact.

The decision to adopt a statement of overriding considerations for the Development Project is a matter for the decision-making bodies and not the preparers of the EIR. The commenter is also referred to Response to Comment Murdock-2.



Regarding the Development Project’s request for a General Plan Amendment and consistency with the City’s ILUP, the commenter is referred to Response to Comment Murdock-3.

Regarding job creation, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.



A discussion of the Development Project’s consistency with the WLA Transportation Improvement and Mitigation Specific Plan is included on page IV.I-58 in Section IV.I (Land Use and Planning) of the Draft EIR and includes the following text:

As stated previously, the WLA Transportation Improvement and Mitigation Specific Plan provides an outline for development within the WLA Transportation Improvement and Mitigation Specific Plan area to encourage alternate modes of transportation (i.e., bicycle, mass transit, etc.) as well as implementation of the TIA Fee, which helps fund transportation infrastructure improvement. As the Development Project site is located within the WLA Transportation Improvement and Mitigation Specific Plan area, development of the Development Project would be required to be compliant with any traffic mitigation measures or fees set forth by the Specific Plan. With implementation of required mitigation measures and/or payment of required fees, as determined by the LADOT, potential impacts would be less than significant.

Because no significant impacts related to this issue would occur as a result of the Development Project, no mitigation measures are required.

The “policies” of the WLA Transportation Improvement and Mitigation Specific Plan that the commenter refers to are not actually policies, but are two (of several) purposes of the WLA Transportation Improvement and Mitigation Specific Plan. Consistency of development in commercial, industrial, and



parking zones with the WLA Transportation Improvement and Mitigation Specific Plan is based on payment of a Transportation Impact Assessment Fee. The commenter is referred to page IV.I-16, which includes the following text:

Prior to the issuance of any building, grading or foundation permit, an Applicant shall pay or guarantee a Transportation Impact Assessment (TIA) Fee to the Department of Transportation. The TIA Fee shall be for the purpose of funding the transportation improvements listed in…[the] Specific Plan.

Regarding comments made by Arthur Kassan, the commenter is referred to Response to Comment Letter Kassan.



Regarding the Development Project’s consistency with the goal of the 2008 Regional Comprehensive Plan (the “2008 RCP”) to “Minimize land uses that increase risk of adverse air pollution-related health impacts from exposure to toxic air contaminants, particulates (PM10, PM2.5, ultrafine), and carbon monoxide,” this policy calls for minimizing the development of land uses that generate excessive pollutant emissions that can cause health impacts. As discussed on page IV.I-32 in Section IV.I (Land Use and Planning) of the Draft EIR, the pollutant emissions associated with the Development Project would not create significant health risks. Thus, the Development Project is not inconsistent with the referenced policy.



The commenter should note that the Development Project site is not within the Pico/Westwood Neighborhood Oriented District.

Consistency of the Development Project with Principle 2 of the Compass Growth Vision is included on page IV.I-28 in Section IV.I (Land Use and Planning) of the Draft EIR. As discussed, “The Development Project would create a pedestrian-friendly, mixed-use community combining a residential use with on-site commercial uses, and active and passive open space and other on-site amenities. The Development Project’s public open spaces, landscaping, and ground floor retail would promote pedestrian activity and interaction among residents and visitors.” Additionally, the following text is included on Table IV.I-6 on page IV.I-41 that further supports the Development Project’s consistency with Principal 2:

The stepped and articulated elements of the design of the upper residential structures along Pico Boulevard and Sepulveda Boulevard would soften the massing of the Development Project as a



whole and the overall height, as viewed from a pedestrian level near the Development Project site (refer to Figures IV.B-8 through IV.B-12).

Along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza area along Sepulveda Boulevard connect to the Development Project’s smaller scale retail environment with neighborhood tenants and outdoor dining. In addition, a portion of the second commercial level on Sepulveda Boulevard would be terraced to allow for additional outdoor dining. The leasing office for the Development Project would also be on Sepulveda Boulevard, directly accessible from the street. The plaza areas would be designed to serve as a pedestrian “activation” function, by allowing sufficient room for pedestrian travel and by providing pedestrian access to retail frontage and key site entry points on Pico Boulevard and Sepulveda Boulevard and to the Metro Expo II station access point that will be developed adjacent to the Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard. However, the Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station. Additionally, the Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The commenter asserts that the traffic impacts of the Development Project would “[lead] to the deterioration of neighborhood retail concerns” and “threaten the survival of these smaller retail concerns and the nearby industrial/light manufacturing uses.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.



Regarding “health impacts,” the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


Regarding air quality health risks at the Development Project site, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.




Regarding air quality health risks at the Development Project site, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


Regarding air quality health risks at the Development Project site, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4. Air quality health risks are determined by considering a concentration of certain pollutant emissions and duration of exposure to these emissions over time. Thus, no “separate calculation” can be made for senior residents.


Section 12.21 of the LAMC defines “usable open space” as follows:

[U]sable open space shall mean an area which is designed and intended to be used for active or passive recreation. Usable open space may consist of private and/or common area as further defined and regulated herein. Parking areas, including access aisles, driveways, and required front and side yards, open space areas located above the first habitable room level, except as otherwise provided for herein, shall not qualify as usable open space.

The open space included as part of the Development Project meets this definition.


The commenter is referred to Response to Comments Murdock-14 through Murdock-18.


This comment expresses an opinion about the City coordinating development with public infrastructure, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The state and national economic downturn began approximately in 2008. The analysis in Section IV.M (Public Services) of the Draft EIR of Development Project impacts on public services was prepared in light of the economic downturn. None of the mitigation measures in the Draft EIR require City funding.




This comment expresses an opinion about the City coordinating development with public infrastructure, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Murdock-15. The Development Project Applicant would be required to implement all of the mitigation measures identified in the Draft and Final EIR. The commenter is referred to Section V (Mitigation Monitoring Report Plan) of the Final EIR that identifies each of the mitigation measures required of the Development Project, when the monitoring of the mitigation measures would occur, and which agencies would be required to enforce and monitor the mitigation measures.


The commenter asserts that the Draft EIR did not adequately address “these questions,” but the commenter does not state what the questions are. Thus, no further response to this comment can be provided.


Regarding the commenter’s statement about outdated traffic information, the commenter is referred to Response to Comment Abarbanel-4.

Regarding the population and housing forecast data used in the Draft EIR, the commenter is referred to Section IV.L (Population, Housing, and Employment) of the Draft EIR, specifically to Table IV.L-1 on page IV.L-2 that shows the population and housing forecast data used in the Draft EIR is based on SCAG’s Profile Report of May 2011.


The commenter is referred to Responses to Comments Murdock-1 through Murdock-18.


The commenter is referred to the responses prepared to all other comment letters submitted on the Draft EIR.



Comment Letter Murphy


Comment Letter Newman


Comment Letter Name Illegible A


Comment Letter Name Illegible B


Comment Letter Name Illegible C


Comment Letter Name Illegible D


Comment Letter Nikoltchev

Response to Comment Nikoltchev-1


















Comment Letter Nixon


Comment Letter Olavarria


Comment Letter Oliver A




Comment Letter Oliver B

Response to Comment Oliver B-1

This comment expresses concern about the Development Project, the Draft EIR, and traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.
















This comment expresses an opinion about use the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Orfirer


Comment Letter Paller

Response to Comment Paller-1

This comment expresses concern about “over-development” and traffic in the vicinity of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Pasic A


Comment Letter Pasic B

Response to Comment Pasic B-1


















Comment Letter Plotkin

Response to Comment Plotkin-1

This comment expresses concern about the Development Project’s traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Additionally, the commenter should note that the Expo 2 light-rail line at Exposition Boulevard and Sepulveda Boulevard will not be an at-grade crossing but will span over Sepulveda Boulevard.

Response to Comment Plotkin-2

The “master plan[s]” that govern development of the Development Project area include the City’s General Plan and the West Los Angeles Community Plan (the commenter is referred to Section IV.I [Land Use and Planning] of the Draft EIR).

Comment Letter Pope

Response to Comment Pope-1



The commenter incorrectly states that the trip generation rates used in the Development Project traffic study are based on “congestion-constrained” traffic flows. In fact, the trip generation rates used to estimate traffic generation of the Development Project were generally obtained from the current edition of the institute of transportation engineers (ITE) that are used throughout the southern California region as well as across the country as the recognized standard for estimating traffic associated with a variety of land uses. Additionally, some trip generation data was obtained from the West Los Angeles Transportation Improvement and Mitigation (WLA TIMP) Specific Plan, which provides trip generation rates for various land uses based on data specifically applicable to conditions within the Specific Plan area. Therefore, the trip generation data used in the traffic study for the Development Project are appropriate and are consistent with both LADOT and CEQA requirements.


Regarding traffic mitigation measures for the Development Project, the commenter is referred to Response to Comment Alpern A-4. As of January 1, 2012, the WLA TIMP trip fee is $3,184 (indexed annually). Additionally, the WLA TIMP trip fees should not be compared to the cost of providing additional transit capacity (as suggested by the commenter), since additional public transit capacity typically involves significant infrastructure improvements throughout a large area in order to be effective (such as the approximately 15-mile expo line or additional buses, which can cost upwards of $250,000 each [significantly higher for hybrid-electric buses]), not including the on-going costs of drivers (including salaries and benefits) and maintenance. The amount of the WLA TIMP fees are determined as the cost per unit (additional afternoon peak-hour trip) needed to raise funds to construct a number of specific roadway and/or traffic signal improvements (identified in Appendix C of the WLA TIMP Specific Plan). These improvements are typically one-time costs for improvements of relatively limited



scope that provide additional capacities to specific intersections or short transportation corridors and as such, the trip fees noted in the WLA TIMP are not comparable to the costs of providing additional transit capacity noted by the commenter.

Additionally, the commenter is referred to page IV.N-142 in Section IV.N (Transportation/Traffic) of the Draft EIR that states the following:

The WLA TIMP fees are designed to fund improvements that address cumulative traffic increases throughout the area, including those traffic increases from the Development Project as well as from other ongoing or future development in the WLA TIMP vicinity and throughout the region, through the implementation of both local and regional traffic improvements. However, in addition to payment of the TIMP fees, the City requires that private development projects mitigate their own impacts where feasible, in order to provide more immediate relief for project-specific traffic effects on the surrounding vicinity. Therefore, in order to address the specific Development Project traffic impacts identified in this EIR, Mitigation Measures N-4 through N-8 were identified.


The commenter is referred to Responses to Comments Pope-5 through Pope-12.


LADOT’s significance thresholds for determining project traffic impacts is included in Section IV.N (Transportation/Traffic) on page IV.N-37 and as follows:

The L.A. CEQA Thresholds Guide states that a project would normally have a significant impact on intersection capacity if the project traffic causes an increase in the V/C ratio on the intersection operating conditions after the addition of project traffic of one of the following shown on Table IV.N-4, LADOT Significance Thresholds:

Table IV.N-4 LADOT Significance Thresholds

Intersection Conditions with Project Traffic Project-related Increase

in V/C Ratio LOS V/C C 0.701 - 0.800 Equal to or greater than 0.04 D 0.801 - 0.900 Equal to or greater than 0.02

E, F > 0.900 Equal to or greater than 0.01 Source: LADOT.



As disclosed in Section IV.N, based on LADOT’s significance thresholds, the Development Project would result in significant and unavoidable impacts at 22 of the study intersections.


This comment discusses traffic flow under LOS E conditions or worse, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


LADOT’s assessment letter reflects LADOT’s review of and comments on the traffic study prepared for the Development Project in accordance with LADOT’s standards. The Draft EIR is a document that discloses the environmental impacts of the Development Project. Neither LADOT’s assessment letter nor the Draft EIR “allow” the Development Project to do anything. The Development Project is subject to the discretionary review of the City.


The commenter is referred to Responses to Comments Pope-5 and Pope-7.


This comment expresses an opinion about traffic conditions, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




As disclosed in Section IV.N (Transportation/Traffic), the Development Project would result in significant and unavoidable impacts at the intersection of Olympic Boulevard and Barrington Avenue and at the intersection of Pico Boulevard and Barrington Avenue.






Regarding preserving neighborhood character and maintaining pedestrian-oriented environments, the commenter is referred to Responses to Comments Abarbanel-3 and Murdock-7.

Regarding neighborhood intrusion or “through traffic,” the commenter is referred to Response to Comment Abarbanel-4.


This comment expresses an opinion about approving the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Overriding considerations for approving the Development Project are determined by the decision-making bodies and not the Draft EIR.


As discussed in Section IV.N (Transportation/Traffic) of the Draft EIR and in Response to Comment Abarbanel-5, the Development Project would not result in any significant impacts related to neighborhood intrusion (including in the area of Inglewood Boulevard between and National Boulevard and Venice Boulevard), and as such, no mitigation measures (such as the one suggested by the commenter) are required. Section 15126.4(a)(3) states, “Mitigation measures are not required for effects which are not found to be significant.”


As shown on Table IV.N-16 on page IV.N-149 in Section IV.N (Transportation/Traffic) of the Draft EIR, with implementation of the referenced traffic mitigation measure (Mitigation Measure N-8), Development Project impacts at the intersection of Sepulveda Boulevard and Venice Boulevard would be significant and unavoidable. Regarding the footnote in the comment, the commenter incorrectly evaluates the effectiveness of the proposed mitigation at the intersection of Venice Boulevard and Sepulveda Boulevard that is based on the increase in capacity for the northbound approach to the intersection, not simply a “10% improvement” credit. Additionally, as shown on Table IV.N-16, the subject intersection is forecast to operate at LOS E during both the morning and afternoon peak hours, following implementation of the



mitigation measures identified in Section IV.N, including both trip reduction and physical roadway and/or traffic signal improvements.



Comment Letter Posey

Response to Comment Posey-1




Response to Comment Posey -3














Comment Letter Purcell

Response to Comment Purcell-1

Regarding the scale of the Development Project in relation to surrounding development, the commenter is referred to Response to Comment Alpern A-3.


Regarding “health problems,” it is assumed that the commenter is referring to the air quality health risk associated with the Development Project site. The air quality health risks disclosed in the Draft EIR are based on the following exposure timeframes (refer to Table IV.I-3 on page IV.I-34 in Section IV.I [Land Use and Planning] of the Draft EIR:

70 year (Lifetime Resident Exposure)

9 year (Child Exposure)

30 year (Resident Exposure)

40 Year (Worker Exposure)




This comment expresses opinions about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




As discussed on page IV.M-44 in Section IV.M (Public Services – Parks and Recreation) of the Draft EIR, “The Development Project would include a total of 87,490 square feet of open space, a recreation center, roof terraces, and a courtyard on the podium level.” Also, the proposed building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas, which would be landscaped.


This comment asks for the Development Project to be scaled down, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Rahebi

Response to Comment Rahebi-1








Response to Comment Rahebi -5




Response to Comment Rahebi -6


Comment Letter Reichmann

Response to Comment Reichmann-1







Regarding jobs, the commenter is referred to Section IV.L (Population, Housing and Employment) of the Draft EIR that states the Development Project would generate approximately 515 net new jobs at the Project site.

Also, the commenter is referred to Response to Comment Alpern B-4.


The commenter is referred to Section IV.M (Public Services) and Section IV.O (Utilities) of the Draft EIR that include an analysis of Development Project impacts related to fire and police services and water supply. The analysis concludes that with implementation of the City’s Standard Mitigation Measures, impacts of the Development Project related to these issues would be less than significant.





The commenter asserts that the Development Project “could lead to further dense development.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Regarding lighting impacts of the Development Project, the commenter is referred to Response to Comment City Council (Paul Koretz) B-12.




This comment expresses opinions about impacts of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Regarding noise impacts created by the Development Project that would affect the residents of the Development Project, as disclosed in Section IV.K (Noise) of the Draft EIR, loading dock activities associated with the Development Project would result in significant and unavoidable outdoor noise impacts at the Development Project site. Also, the commenter is referred to Response to Comment Caltrans-8.

Regarding air quality impacts created by the Development Project that would affect the residents of the Development Project, as disclosed in Section IV.C (Air Quality) of the Draft EIR, the Development Project would not create any significant localized air quality impacts.




The commenter is referred to Response to Comment City Council (Paul Koretz) B-22 and Abarbanel-5.





Comment Letter Resnick

Response to Comment Resnick-1

The commenter is referred to Response to Comment Letter Murdock.

Comment Letter Rich

Response to Comment Rich-1

This comment is the same as Comment Arenberg-1. The commenter is referred to Response to Comment Arenberg-1.



























Comment Letter Rosenthal

Response to Comment Rosenthal-1

The commenter is referred to Response to Comment Letter Diamond.

Comment Letter S(sp) Jane


Comment Letter Samuels




Comment Letter Schechter

Response to Comment Schechter-1


















Comment Letter Scheider

Response to Comment Scheider-1



This comment includes statements about existing traffic, pollution, and noise issues, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment Letter Schiff


Comment Letter Schiller

Response to Comment Schiller-1

This comment expresses opposition to the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However,



the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.





















Comment Letter Schwartz

Response to Comment Schwartz-1

This comment expresses concern about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Regarding the traffic study for the Development Project, the commenter is referred to Response to Comment Abarbanel-4.


The commenter is referred to Response to Comment Alpern A-9.


The commenter is referred to Response to Comment City Council (Paul Koretz) B-8 and Response to Comment Arenberg-5.


The commenter is referred to Response to Comment Cohon-17.

Comment Letter Seidenberg

Response to Comment Seidenberg-1

The commenter is referred to Response to Comment City Council (Paul Koretz) B-8, Abarbanel-2



Response to Comment Seidenberg -2

Regarding neighborhood traffic impacts, the commenter is referred to Response to Comment Abarbanel-5.

Regarding the visual character impacts of the Development Project, the commenter is referred to Response to Comment Alpern A-3


The Expo 2 Project garage that will be developed just south of the Development Project site would have a park-and-ride. The Development Project includes a regional bike/pedestrian path along the south side of the Development Project site and bicycle parking/storage and other traffic-reducing measures and bicycle and pedestrian features required in Mitigation Measures N-2 (refer to Response to Comment Alpern A-10) and N-3 (refer to Response to Comment Commins-6).


The commenter is referred to Response to Comment Letters Alpern A and Alpern B.


This comment expresses support for industrial and open space land uses, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes a general statement about development in the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Shaw

Response to Comment Shaw-1

This comment states that the Development Project is too big, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However,





This comment is a statement about existing traffic conditions, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment is a statement about existing traffic conditions, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Regarding parking for the Development Project, the commenter is referred to the last paragraph of Response to Comment Alpern A-4.

















Comment Letter Sippy

Response to Comment Sippy-1


















Comment Letter Smith A


Comment Letter Smith B

Response to Comment Smith B-1



This comment is a statement about the Development Project’s impact, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However,





This comment expresses an opinion about the architectural design of the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about use of the Development Project site, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Solomon

Response to Comment Solomon-1



This comment includes the same statements included in Comments Abarbanel-4, Abarbanel-5, and Abarbanel-6. The commenter is referred to Responses to Comments Abarbanel-4, Abarbanel-5, and Abarbanel-6.









Comment Letter Spector

Response to Comment Spector-1


















Comment Letter Stoller


Comment Letter Stone

Response to Comment Stone-1

This comment includes the same statements included in Comments Abarbanel-1, Abarbanel-3, Abarbanel-4, and Abarbanel-5. The commenter is referred to Responses to Comments Abarbanel-1, Abarbanel-3, Abarbanel-4, and Abarbanel-5.







Comment Letter Strick

Response to Comment Strick-1




Comment Letter Tippit A

Response to Comment Tippit A-1

This comment expresses opinion and concern about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


Regarding alternatives to the Development Project that include “fewer stories and much lower density,” the commenter is referred to Section VI (Alternatives to the Proposed Project) of the Draft EIR that includes a discussion of six alternatives that include development of shorter buildings and less overall square footage than the Development Project.


This comment is substantially the same as Comment Beber-4. The commenter is referred to Response to Comment Beber-4.


This comment is the same as Comment Beber-5. The commenter is referred to Response to Comment Beber-5.




















This comment expresses an opinion about Development Project traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to Response to Comment Beber-14.


This comment expresses an opinion about Development Project traffic, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Regarding signalization of the driveway on Sepulveda Boulevard, the commenter is referred to Response to Comment Beber-17.






This comment is the same as Beber-18. The commenter is referred to Response to Comment Beber-18 and Response to Comment City Council (Paul Koretz) B-2.


This comment is the same as Beber-19. The commenter is referred to Response to Comment Beber-19.


This comment is substantially the same as Beber-20. The commenter is referred to Response to Comment Beber-20














This comment is the same as Comment Beber-26. The commenter is referred to Response to Comment Beber-26 and Response to Comment City Council (Paul Koretz) B-13.




This comment is the same as Comment Beber-28. The commenter is referred to Response to Comment Beber-28 and Response to Comment Elliot-2.


This comment is substantially the same as Comment Beber-29. The commenter is referred to Response to Comment Beber-29 and Response to Comment City Council (Paul Koretz) B-15.






This comment is the same as Comment Beber-32. The commenter is referred to Response to Comment Beber-32 and Response to Comment Beber-31.








This comment is the same as Comment Beber-35. The commenter is referred to Response to Comment Beber-35 and Response to Comment Beber-34.


This comment is the same as Comment Beber-36. The commenter is referred to Response to Comment Beber-36, Response to Comment Commins-7, and Response to Comment Purcell-4.


The first part of this comment is the same as Comment Beber-37. The commenter is referred to Response to Comment Beber-37.

Regarding increasing setbacks along Sepulveda Boulevard to “provide better site line visibility along Sepulveda Boulevard for safety purposes,” the Development Project’s 25-foot setback along Sepulveda Boulevard would provide ample line-of-sight visibility for vehicles exiting the Development Project site onto Sepulveda Boulevard. Thus, the setback does not need to be increased as suggested by the commenter. Additionally, “privacy” is not an environmental issue of concern under CEQA.




















The commenter should note that the Expo 2 Project light-rail line’s crossing of Sepulveda Boulevard will be above grade (over the top of Sepulveda Boulevard). As such, no crossing gates will be used, and traffic flow on Sepulveda Boulevard will not be impeded by the transit line.


This comment is the same as Comment Beber-46. The commenter is referred to Response to Comment Beber-46 and Response to Comment Alpern B-2.




This comment is the same as Comment Beber-47. The commenter is referred to Response to Comment Beber-47 and Alpern B-2.


The commenter asserts that the Development Project would “set a precedent and encourage additional overdevelopment of the surrounding area.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required. Also, the commenter is referred to Response to Comment Millman-2 and Response to Comment Tippit A-9.

Regarding the size of the Development Project in relation to the neighboring residential development, the commenter is referred to Response to Comment Alpern A-3.




























Based on the responses provided for Comments Tippit A-1 through Tippit A-59, no revisions to the Draft EIR are required.


Based on the responses provided for Comments Tippit A-1 through Tippit A-59, no revisions to the Draft EIR are required. Thus, recirculation of the Draft EIR is not required.



Comment Letter Tippit B

Response to Comment Tippit B-1

This comment expresses opinions about the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The Draft EIR assesses and discloses the environmental impacts of Development Project and identifies ways to reduce or avoid the significant impacts of the Development Project. The Draft EIR makes no judgment about whether the Development Project is good or bad.


The assessment of Development Project impacts related to fire protection services discussed in Section IV.M (Public Services) of the Draft is based on information about the Los Angeles Fire Department (LAFD) provided by the LAFD at the time the Draft EIR was prepared. Appendix F to the Final EIR includes a copy of the request for information letter sent by the preparers of the Draft EIR to the LAFD and a copy of LAFD’s response (which is also included in Appendix IV.M to the Draft EIR). The request letter asks, “Would the proposed project result in the need for the expansion of existing or the construction of new fire stations?” (refer to question 6). The LAFD’s response to this question was “No.” As discussed in Section IV.M, the existing and future fire flows, response distance, and emergency access would accommodate the Development Project without necessitating the construction or expansion of any fire stations to maintain acceptable levels of fire protection services (which is the significance threshold for determining significant project impacts). The Applicant of the Development Project would pay all applicable developer and public facility fees to the City to offset the cost of review and compliance with fire code and ordinance requirements. Buildout of the Development Project would have a less than significant impact with respect to fire protection services.



Also, the commenter is referred to Responses to Comments Murdock-15 and Murdock-16.






This comment expresses opinions about projects in general, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding traffic generated by the Development Project, traffic generation associated with the Development Project is discussed in Section IV.N (Transportation/Traffic), beginning on page IV.N-52. As discussed, the Development Project would generate approximately 13,713 net daily traffic trips, 449 net morning peak-hour trips, and 1,232 net afternoon peak-hour trips.

Regarding implementation of mitigation measures identified for the Development Project, the commenter is referred to Response to Comment City Council (Paul Koretz) B-15.


This comment includes statements about reforming CEQA, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment includes statements about CEQA reform and the City enforcing mitigation, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.






The commenter is referred to Response to Comment Tippit B-26 through Comment Tippit-B-56.


The commenter is referred to Response to Comment Tippit B-26 through Comment Tippit-B-56.


The commenter is referred to Response to Comment Elliot-2.




The commenter is referred to Responses to Comments Tippit B-3 and Tippit B-13 and Response to Comment Endo-1.


This comment expresses opinions about the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


Based on the responses provided to Comment Letter Tippit B (and all other comment letters), the Draft EIR meets the requirements of CEQA, and recirculation of the Draft EIR is not required.




This comment expresses an opinion about a Development Project objective, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Regarding the commenter’s statement about “SCAG findings,” the commenter is referred to Response to Comment Tippit B-59 and Response to Comment Murdock-18.



The commenter asserts that the Development Project would block north/south access to the Expo 2 Project light-rail line. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.



The commenter asserts that the Development Project would result in negative impacts to mass transit. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.


This comment expresses an opinion about a Development Project objective, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts.



However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

As disclosed in Section IV.I (Land Use and Planning) of the Draft EIR, the Development Project would be partially inconsistent with the WLA Community Plan, and impacts related to this issue would be significant.





Regarding pedestrian circulation, the commenter is referred to Response to Comment Murdock-7.









The commenter asserts that the Development Project would result in negative impacts to mass transit. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.


Regarding the Development Project’s impacts related to neighborhood character, the commenter is referred to Response to Comment Alpern-3.

Regarding parking, the commenter is referred to Response to Comment Alpern-4.

Regarding “spillover traffic,” the commenter is referred to Response to Comment Abarbanel-5.


The commenter is referred to Response to Comment Murdock-12.


The Development Project would not permanently eliminate industrial zones. The Development Project would only affect the zoning of the Development Project site. Also, the Development Project includes a zone change for the Development Project site to Commercial (C2-1); the proposed residential uses would conform to the Commercial zoning.




The commenter is incorrect in stating that the Draft EIR states that the LAFD’s “infrastructure is incapable of supporting new development.” The commenter is referred to Response to Comment Tippit B-3.






This comment includes statements about the City monitoring and approving projects, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment opinions about the City and the Development Project, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Response to Comment Tippit B-26. Also, the commenter is referred to Table IV.I-7 on page IV.I-48 in Section IV.I (Land Use and Planning) of the Draft EIR that includes a discussion of the Development Project’s consistency with the referenced policy. The Draft EIR concluded that the Development Project would be partially inconsistent with this policy for the following reasons:

The types of land uses included as part of the Development Project (residential and commercial) are similar to those already found in the Development Project area. However, the scale (height and massing) of the Development Project are larger than the scale of other structures in the Development Project area, including the residential structures to the south of the Project site (refer to Figure IV.B-12), although these residential land uses are not located along major roadways where larger-scale developments are often found.


The commenter is referred to Table IV.I-7 on page IV.I-48 in Section IV.I (Land Use and Planning) of the Draft EIR that includes a discussion of the Development Project’s consistency with the referenced policy. The Draft EIR concluded that the Development Project would be partially inconsistent with this policy for the following reasons:



As discussed in Section IV.M, Public Services, and Section IV.O, Utilities, coupled with payment of fees and development of utility infrastructure for the Proposed Project, the Proposed Project’s demand for pubic and utility services could be accommodated by existing infrastructure. As discussed in Section IV.N, Transportation/Traffic, several intersections currently operate as unacceptable levels of service (LOS E and F), and several intersections would continue to operate at unacceptable levels in the future, with or without the Development Project, although development of the Expo Line facilities and station access point will help to alleviate traffic congestion in the Development Project area upon full build out of the facility.


This policy is not applicable to the Development Project, because the Development Project does not contain “planned residential density.” However, consistent with this policy, the Draft EIR considers “factors of neighborhood character and identity, compatibility of land uses, impacts on livability, public services and facilities, and traffic levels.”

This comment expresses an opinion about livability of the Development Project site and states that Development Project impacts on public services are “unacceptable,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Table IV.I-7 on page IV.I-49 in Section IV.I (Land Use and Planning) of the Draft EIR that includes a discussion of the Development Project’s consistency with the referenced policy. The Draft EIR concluded that the Development Project would be consistent with this policy for the following reasons:

The Development Project would develop a mixed-use structure with approximately 538 multi-family residential units and 266,800 square feet of retail uses. With approval of the Development Project the Development Project site would be designated as Community Commercial. Therefore, the Development Project would be consistent with this policy.


The commercial land uses included as part of the Development Project are allowed under the existing zoning for the Development Project site. Also, commercial land uses are located throughout the Development Project area. Thus, the Development Project would be consistent with the referenced policy.




The Development Project would not affect any neighborhood stores and businesses. Also, the residential component of the Development Project would add potential new customers to the area. Thus, the Development Project would be consistent with the referenced policy.


The commenter is referred to Table IV.I-7 on page IV.I-50 in Section IV.I (Land Use and Planning) of the Draft EIR that includes a discussion of the Development Project’s consistency with the referenced policy. The Draft EIR concluded that the Development Project would be inconsistent with this policy for the following reasons:

The Development Project would require a General Plan Amendment (from Light Industrial and Public Facility to Community Commercial) and Zone Change (from M2-1-O PF-1XL to C2-1) that would permanently remove an industrial designated land use.

Also, the commenter is referred to Response to Comment Tippit B-28.






Goals of the WLA Community Plan reflect a broad vision for the City and are not necessarily meant for implementation on a project level. The referenced goal is not applicable to the Development Project.

Regarding the commenter’s statements about “blocking access to the Expo light rail line,” the commenter is referred to Response to Comment Arenberg-4.


The referenced policy is not applicable to the Development Project, because the Development Project is not a transportation facility. However, the Development Project would not inhibit the development of any transportation facility or service elsewhere.

Regarding the commenter’s statements about “blocking access to the Expo light rail line,” the commenter is referred to Response to Comment Arenberg-4.




This policy is not relevant to the Development Project, because the Development Project Applicant is not the City. However, the commenter is referred to Response to Comment Tippit B-26.




The commenter is referred to Response to Comment Endo-1.


Goals of the WLA Community Plan reflect a broad vision for the City and are not necessarily meant for implementation on a project level. The referenced goal is not applicable to the Development Project.


The commenter is referred to Response to Comment Pope-5.


The Development Project is being proposed at a time when the section of the San Diego Freeway adjacent to the Development Project site is being widened and the Expo 2 Project light-rail line (also adjacent to the Development Project site) is being constructed. Thus, the Development Project is consistent with the referenced objective.

Also, the commenter is referred to Response to Comment Tippit B-3.


The commenter is referred to Section II (Project Description) of the Draft EIR that states the Development Project includes a landscaped common courtyard between the residential buildings. Pedestrian entrances would be provided on Sepulveda Boulevard and Pico Boulevard. Also, the commenter is referred to Response to Comment Murdock-12.


This comment includes statements about the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental



impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The referenced policy is not applicable to the Development Project. Assessing and monitoring of the City’s infrastructure falls under the purview of the City, not the Development Project.




A discussion of the consistency of the Development Project with applicable plans, policies, and regulations is included in Section IV.I (Land Use and Planning) of the Draft EIR. Additional discussion of the consistency of the Development Project with other policies is included in Response to Comments Tippit B-26 through Tippit B-54 (the commenter is referred to those responses). No additional consistency analysis is required for the Development Project.


The commenter asserts, “No statement of consistency with the Housing Element can be made without the required reports and mitigation which flows from the reports.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to this portion of the comment is required. Also, a discussion of the Development Project’s consistency with Housing Element is included on Table IV.I-6 on page IV.I-39 in Section IV.I (Land Use and Planning) of the Draft EIR. As discussed the Development Project would be consistent with policy 4.1.1 and objective 4.2 but would be inconsistent with policy 4.1.9.




This comment cites the requirements for preparation of a supplemental EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.








This comment expresses an opinion about forecasts of population, housing, and employment growth, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter states that the City’s current economic status would affect the conclusions made in the Draft EIR related to public services. However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this implication. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to this comment is required. Also, the commenter is referred to Response to Comment Murdock-15.


The purpose of the Draft EIR is to assess and disclose the environmental impacts of the proposed Development Project. The Draft EIR makes not judgment about what impacts are acceptable.

Health care costs and City liability are not environmental impact issues under CEQA, and addressing these issues in the Draft EIR is not required.










The commenter is incorrect in stating that the Draft EIR “confirms that harm will be done to the residents of the project.” The Draft EIR includes a HRA that identifies the potential air quality health risks associated with the Development Project site, based on a concentration of certain pollutant emissions and exposure to these emissions over time. The commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


The commenter’s attached letter does not include comments on the Draft EIR for the Development Project. Thus, no response to the commenter’s letter is required. Also, the commenter is referred to Response to Comment City Council (Paul Koretz) B-4.


This comment cites information from the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


As described in detail on pages IV.N-11 and IV.N-12 in Section IV.N (Transportation/Traffic) of the Draft EIR, only the Phase 1 portion of the Pico/Olympic Plan was assumed in the traffic analysis. Phase 1 of the Plan provides consistency in the on-street parking prohibitions in both directions on both Pico Boulevard and Olympic Boulevard throughout the Pico/Olympic Plan area (generally between Centinela Avenue and Fairfax Avenue), including through the Development Project study area. This portion of the Pico/Olympic Plan is already underway and is continuing, and is anticipated to be completed prior to the completion of the Development Project. However, as also noted in the Draft EIR, the more aggressive Phase 2 and Phase 3 portions of the plan, which propose to modify the traffic signal phasings and timings to provide directional preference for traffic flows (Phase 2), and ultimately convert the directions of some traffic lanes to provide further directional capacity (Phase 3), have been delayed and/or are awaiting review of the effectiveness of the Phase 1 elements of the Pico/Olympic Plan. Therefore, these potential future Pico/Olympic Plan elements were not included in the traffic analysis for the Development Project, and no reanalysis is necessary.


The commenter is referred to Response to Comment Tippit A-44 and Response to Comment Metro-6.




This comment cites information from the Draft EIR, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Response to Comment Tippit A-44.


The commenter asserts that the Development Project would “impact the ability of transit riders to reach light rail.” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to this comment is required.






The conclusion in the Draft EIR that Development Project impacts related to water service would be less than significant is based on a water supply assessment prepared by LADWP. The commenter is referred to Section IV.O (Utilities – Water) of the Draft EIR.


This comment includes a statement about LADWP’s power transmission system, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Also, the commenter is referred to the response letter provided by DWP regarding its ability to provide electricity supply to the Development Project (refer to Appendix IV.O of the Draft EIR). DWP states that



the “Project Applicant may be financially responsible for some of the infrastructure improvements (e.g., installation of electric power facilities or service connections) necessary to serve the proposed project.” As the Development Project moves forward, the Applicant would be required to coordinate with DWP to determine the power and infrastructure needs of the Development Project.


The commenter is referred to Responses to Comments Tippit B-77 and Tippit B-78.


This comment includes a statement about the City, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


This comment expresses an opinion about “consistency in decision-making,” but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.


The commenter is referred to Responses to Comments Tippit B-77 and Tippit-79. Based on these responses, no revisions to the Draft EIR are required.


The commenter is referred to Response to Comment Tippit B-3. Several stations, not just Station 92, provide fire protection service to the Development Project site.












The source of the information in the Draft EIR about LAFD response times is the LAFD. Also, the commenter is referred to Response to Comment Tippit B-3.


Cumulative impacts to fire protection services are addressed on page IV.M-9 in Section IV.M (Public Services – Fire Protection) of the Draft EIR and consider the impacts of the Development Project in conjunction with the related projects (including the Expo 2 Project) identified in Section III (Environmental Setting) of the Draft EIR. As discussed in Section IV.M, “LAFD does not determine the adequacy of fire protection based on response times or number of EMS or fire-related incidents. As discussed previously, for any residential related project more than 1.5 miles from the nearest LAFD Engine or Truck Company, LAMC Section 57.09.06 would require the installation of automatic fire sprinkler systems in order to compensate for the additional response distance. Therefore, each of the related projects would be required to install automatic fire sprinkler systems if located at a distance to the nearest fire station that exceeded the LAFD required response distance.” The Development Project and related projects would be required to comply with all applicable local and state codes related to fire prevention and safety. The analysis concludes that cumulative impacts to fire protection services would be less than significant.


The commenter is referred to page IV.M-18 in Section IV.M (Public Services – Police Protection) of the Draft EIR that discloses the following (consistent with the comment):



LAPD has indicated that the Development Project would impact police services in the West Los Angeles Area.3 The Development Project would potentially decrease the officer-to-population ratio in the area and would require up to an additional two police officers to maintain the current officer-to-population ratios. However, the Development Project would directly and indirectly generate recurring revenue for the City, including sales and property tax that could be used to meet increased demands for additional staffing, equipment, and facilities. Implementation of the City’s Standard Mitigation Measures (refer to Mitigation Measures M-4 through M-6 listed below) is required.

The analysis of Development Project impacts on police services considers construction and operation activities and security features associated with the Development Project; existing and with-project officer-to-population ratios; response times to emergency calls; emergency access to the Development Project site; compliance with LAMC requirements related to security; and implementation of the City’s Standard Mitigation Measures related to police services. Taking all of these factors into consideration, impacts of the Development Project related to police services would be less than significant.


Based on the responses provided to Comments Tippit B-1 through Tippit B-90, the Draft EIR is sufficient, and no revisions are required.

Comment Letter Tippit C

Response to Comment Tippit C-1

The commenter asserts that the Draft EIR “fails in key areas to comply with the California Environmental Quality Act (CEQA).” However, the commenter does not provide facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of this assertion. Therefore, pursuant to Section 15204(c) of the CEQA Statute and Guidelines, no further response to the comment is required.

Also, the commenter is referred to Response to Comment Letter Tippit B.

Comment Letter Tippit D

Response to Comment Tippit D-1

The commenter is referred to Response to Comment City Council (Paul Koretz) A-1.

3 Written correspondence from Officer Marco Jimenez, Officer in Charge, City of Los Angeles Police Department, October 24, 2008, available in Appendix IV.M.



Comment Letter Tobias


Comment Letter Wald, Laney


Comment Letter Wald, Richard


Comment Letter Winett

Response to Comment Winett-1


















Comment Letter Wu

Response to Comment Wu-1

















This comment includes statements about bicycle lanes, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIR in identifying and analyzing the environmental impacts of the Development Project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment Letter Wuilates(sp)


Casden Sepulveda Project IV Correction and Additions to the Draft EIR Final Environmental Impact Report Page IV-1

IV. CORRECTIONS AND ADDITIONS TO THE DRAFT EIR

INTRODUCTION

This section presents corrections and additions that have been made to the text of the Draft EIR. These changes include revisions resulting from responses to comments and others that are necessary to provide clarifications to the project description and analysis and to correct non-substantive errors. The revisions are organized by section and page number as they appear in the Draft EIR. Text deleted from the Draft EIR is shown in strikethrough, and new text is underlined. For corrections resulting from a response to a comment on the documents, references in parentheses refer to the comment letter and comment number.

DRAFT EIR COVER

The address for the Add Area Project site has been edited as follows:

Add Area Project Location: 11240, 11250, 11120, 1160011160, and 11110 Pico Boulevard, Los Angeles, California 90064

The second to the last sentence under the heading “Development Project Description” has been edited as follows:

The Development Project would provide a total of approximately 2,0902,029 parking spaces combined for residential, commercial, and guest use, in compliance with Code requirements.

SECTION I (INTRODUCTION/SUMMARY)

The mitigation measures listed on Table I-1 on page I-33 have been edited as follows:

I-1. The Development Project Applicant shall comply with all applicable zoning requirements of the requested zoning and shall incorporate traffic mitigation measures and/or pay any required fees set forth in the WLA Transportation Improvement and Mitigation Specific Plan, as determined by the LADOT.

I-2. Prior to issuance of building permit, the Development Project shall demonstrate compliance with the applicable portions of both the Commercial Citywide Design Guidelines and the Residential Citywide Design Guidelines at the discretion of the Department of City Planning Urban Design Studio.

I-31. For the residential portion of the Development Project, an air filtration system shall be installed and maintained with filters meeting or exceeding the ASHRAE Standard 52.2


Casden Sepulveda Project IV Corrections and Additions to the Draft EIR Final Environmental Impact Report Page IV-2

Minimum Efficiency Reporting Value (MERV) of 13, to the satisfaction of the Department of Building and Safety.

SECTION II (PROJECT DESCRIPTION)

The third sentence of the second paragraph has been edited as follows:

The Add Area Project site consists of several parcels that encompass approximately 8.86 acres of land and comprises the following addresses: 11240, 11250, 11120, 1160011160, and 11110 Pico Boulevard, and encompasses Assessor Parcel Numbers (APNs) 4256-010-901 and 4256-010-011.

SECTION IV.I (LAND USE AND PLANNING)

The following footnote has been added to the end of the first full paragraph on page IV.I-37:

11 It should be noted, however, that the Development Project’s inconsistency with policies and objectives in the General Plan relating to retention of industrial uses and the siting of new residential uses near sources of air pollution does not necessarily mean that the Development Project is inconsistent with the General Plan itself. State law does not require a perfect match between a proposed project and the applicable land use plan. Thus, state law does not impose a requirement that a proposed project comply with every policy in a land use plan since such policies often try to accommodate a wide range of competing interests. Thus, to be “consistent” with a land use plan itself, the proposed project must only be “in harmony” with the applicable land use plan. (Sequoyah Hills Homeowners Assoc. v. City of Oakland [1993] 23 Cal. App. 4th 704, 717-19.) As discussed in Section IV.I of the Draft EIR, the Development Project is consistent with many of the policies in the General Plan. However, since the threshold for determining a significant land use impact for purposes of CEQA is inconsistency or conflict with any policy in a land use plan (refer to page IV.I-25 of the Draft EIR), the Development Project would cause a significant and unavoidable land use impact due to a conflict with certain policies in the applicable land use plans.

The following footnote has been added to the end of the third paragraph on page IV.I-47:

12 For a discussion of a proposed project’s consistency with a land use plan under state law (other than CEQA), refer to footnote 11 on page IV.I-37.



The last sentence on page IV.I-47 has been edited as follows:

Therefore, the Development Project’s would be partially inconsistent with the WLA Community Plan, and impacts related to this issue would be significant.

The footnote on page IV.I-51 has been edited as follows:

1213 City of Los Angeles Planning Department. West Los Angeles Community Plan. Updated July 27, 1999.

The footnote on page IV.I-59 has been edited as follows:

1314 See LAMC § 12.14.C.2.

The following footnote has been added to the end of the third paragraph on page IV.I-61:

15 For a discussion of a proposed project’s consistency with a land use plan under state law (other than CEQA), refer to footnote 11 on page IV.I-37.

The Corrections and Additions to Section IV.I (Land Use and Planning) of the Draft EIR that are listed below are associated with inaccurate statements included in Section IV.I regarding the access of transit riders exiting the Metro Expo II station at Sepulveda Boulevard/Exposition Boulevard to the commercial component of the Development Project. The Draft EIR incorrectly states the following:

The Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station. Additionally, the Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

As stated in several instances in Section IV.I, the Development Project’s plaza areas along Pico Boulevard and Sepulveda Boulevard would be designed to allow sufficient room for pedestrian travel and



provide pedestrian access to retail tenants, key site entry points, retail frontage, and to the Metro Expo II station access point that will be developed adjacent to the Development Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard. Additionally, the design and construction of the Development Project would be substantially consistent with various applicable design policies and guidelines outlined in the West Los Angeles Community Plan and the Walkability Checklist, including those related to pedestrian connectivity. Further, because the Development Project would provide appropriate pedestrian connectivity to the Metro Expo II station, and no potentially significant impacts related to policy inconsistency associated with design policies would occur, Mitigation Measures I-1 and I-2 identified in Section IV.I are not required for the Development Project. For these reasons, text in Section IV.I has been edited and is reflected below.

The discussion of the Development Project’s consistency with Policy 5.1.2 of the City’s General Plan on Table IV.I-6 on pages IV.I-39 and IV.I-40 has been edited as follows:

Policy 5.1.2: Implement demonstration projects that establish proactive measures to improve neighborhood and community design, and coordinate these activities with the Los Angeles Neighborhood Initiative demonstration projects, Los Angeles County Metropolitan Transportation Authority station area activities, and other City, non-profit and private efforts.

PartiallyConsistent: The Development Project’s may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station. Additionally, the Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects. However, the plaza areas along Pico Boulevard and Sepulveda Boulevard would be designed to allow sufficient room for pedestrian travel and by providing pedestrian access to retail tenants, key site entry points, retail, frontage, and to the Metro Expo II station access point that will be developed adjacent to the Development Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard.

The discussion of the Development Project’s consistency with Policy 5.2.2 of the City’s General Plan on Table IV.I-6 on pages IV.I-40 and IV.I-41 has been edited as follows:

Policy 5.2.2: Encourage the development of centers, districts, and selected corridor/boulevard nodes such that the land uses, scale, and built form allowed and/or encouraged within these areas allow them to function as centers and support transit use, both in daytime and nighttime. Additionally, develop these areas so that they are compatible with surrounding neighborhoods, as

PartiallyConsistent. The existing neighborhood is interconnected with a range of office, hospitality, retail, dining, and other commercial development uses all within proximity to one another. The Development Project would provide a new mixed-use development larger in scale but comparable in character to the existing contemporary architecture in the surrounding area. The Development Project



defined generally by the following building characteristics:

a. Buildings in neighborhood districts generally should be low rise (one- to two-stories), compatible with adjacent housing, and incorporate the pedestrian-oriented design elements defined in policy 5.8.1 and policies 3.16.1 - 3.16.3. They should also be located along sidewalks with appropriate continuous storefronts.

b. Buildings in community centers generally should be two to six stories in height, with the first several stories located along the sidewalk. They should also incorporate the pedestrian-oriented elements defined in policy 5.8.1. Either housing or office space may be located above the ground floor storefronts.

c. The built form of regional centers will vary by location. In areas such as Wilshire and Hollywood Boulevards, buildings will range from low- to mid-rise buildings, with storefronts situated along pedestrian-oriented streets. In areas such as Century City and Warner Center, freestanding high rises that are not pedestrian-oriented characterize portions of these centers. Nevertheless, regional centers should contain pedestrian-oriented areas, and incorporate the pedestrian-oriented design elements defined in policy 5.8.1 and policies3.16.1 - 3.16.3.

Buildings located at activity nodes along mixed-use boulevards generally shall have the same characteristics as either neighborhood districts or community centers, depending on permitted land use intensities. Housing over ground floor storefronts or in place of commercial development shall be encouraged along mixed-use boulevards. (P1, P18, P24, P25)

would introduce higher density residential and commercial uses on an existing industrial property, adjacent to major thoroughfares. Although the Development Project site is not located within a designated center or district identified in the Framework Element Long Range Land Use Diagram, the location of the Development Project adjacent to major Metro bus lines would increase housing opportunities for those wishing to reside near public transportation. Furthermore, the Development Project would be located near the planned Metro Expo 2 station that would span Sepulveda Boulevard, and would further increase housing opportunities in close proximity to mass transit options. Additionally, by combining residential and regional and community-serving commercial uses, the Development Project would increase the range of regional and community-serving commercial land uses in close proximity with residential land uses. The design and architecture of the Development Project would be compatible with other recent developments in the greater Development Project vicinity. As discussed previously, the design of the Development Project is a mixture of contemporary and traditional architectural styles. The lower commercial levels of the Development Project would reflect a more contemporary architectural style, with punched wall openings in a continuous façade, large glazed windows, and pedestrian-level openings (refer to Figure IV.B-9), while the upper residential levels would reflect a more traditional architectural style, accentuated by balconies. The stepped and articulated elements of the design of the upper residential structures along Pico Boulevard and Sepulveda Boulevard would soften the massing of the Development Project as a whole and the overall height, as viewed from a pedestrian level near the Development Project site (refer to Figures IV.B-8 through IV.B-12). Along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component.

http://cityplanning.lacity.org/cwd/framwk/chapters/05/05.htm#pol581

http://cityplanning.lacity.org/cwd/framwk/chapters/03/03211.htm#obj3.16





http://cityplanning.lacity.org/cwd/framwk/chapters/10/10.htm#P1






The plaza area along Sepulveda Boulevard connect to the Development Project’s smaller scale retail environment with neighborhood tenants and outdoor dining. In addition, a portion of the second commercial level on Sepulveda Boulevard would be terraced to allow for additional outdoor dining. The leasing office for the Development Project would also be on Sepulveda Boulevard, directly accessible from the street. The plaza areas would be designed to serve as a pedestrian “activation” function, by allowing sufficient room for pedestrian travel and by providing pedestrian access to retail frontage and key site entry points on Pico Boulevard and Sepulveda Boulevard and to the Metro Expo II station access point that will be developed adjacent to the Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard. However, the Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station. Additionally, the Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects. As such, the Development Project would partially support the policy of creating land uses that support transit use.

The discussion of the Development Project’s consistency with Objective 5.5 of the City’s General Plan on Table IV.I-6 on pages IV.I-42 and IV.I-43 has been edited as follows:

Objective 5.5: Enhance the livability of all neighborhoods by upgrading the quality of development and improving the quality of the public realm.

PartiallyConsistent. The Development Project would replace an industrial use lacking aesthetically pleasing features with a mixed-use development that marries contemporary and traditional architectural design and has extensive landscape amenities. These features would improve the public experience of the Project area and contribute to the Project area’s residential and commercial opportunities. As discussed previously, along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a



double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza area along Sepulveda Boulevard connect to the Development Project’s smaller scale retail environment with neighborhood tenants and outdoor dining. In addition, a portion of the second commercial level on Sepulveda Boulevard would be terraced to allow for additional outdoor dining. The leasing office for the Development Project would also be on Sepulveda Boulevard, directly accessible from the street. The plaza areas would be designed to serve as a pedestrian “activation” function, by allowing sufficient room for pedestrian travel and by providing pedestrian access to retail frontage and key site entry points on Pico Boulevard and Sepulveda Boulevard and to the Metro Expo II station access point that will be developed adjacent to the Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard. However, the Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station and includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The first sentence of the last paragraph on page IV.I-47 has been edited as follows:

As shown in Table IV.I-27, Comparison of West Los Angeles Community Plan Policies to Development Project Characteristics, the Development Project would implement a number of WLA Community Plan policies, thereby assisting the City in meeting many of the WLA Community Plan’s goals and objectives.

The discussion of the Development Project’s consistency with Policy 2-2.1 of the West Los Angeles Community Plan on Table IV.I-7 on page IV.I-49 has been edited as follows:

Policy 2-2.1: Encourage Pedestrian-oriented design in designated areas and in new development.

PartiallyConsistent. Locating residential and retail uses in proximity to each other as well as transit lines reduces the need for auto transit and encourages pedestrianism. Additionally, the Development Project would include streetscape



improvements within the 25- and 30-foot setback areas along Pico and Sepulveda Boulevards along the Development Project site, as well as landscaping and a public water feature, thereby serving to enhance pedestrian activity. However, the Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station. Additionally, the project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment.

The first full paragraph on page IV.I-51 has been edited as follows:

The Development Project would be mostlysubstantially consistent and partially inconsistent with the Community Plan’s applicable urban design policies, which establish the minimum level of design that would be observed. The analysis of the Community Plan’s applicable design policies and guidelines is presented in Table IV.I-28. Applicable urban design policies address commercial uses, individual multi-family projects, and public open space. As discussed in Table IV.I-28, the Development Project’s architectural design would comply with the Community Plan’s urban design policies. With the incorporation of both residential and commercial uses in proximity to compatible land uses and existing and proposed transit options, the Development Project would partially support increased pedestrian activity. However, the Development Project may be found to lack sufficient commercial access from the Metro Expo II station along the frontage closest to the station near the intersection of Sepulveda Boulevard and Exposition Boulevard. Additionally, the project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects ensuring impacts would be mitigated to below level of significance.For these reasons, impacts related to consistency with the applicable urban design policies of the West Los Angeles Community Plan would be less than significant.

The discussion of the Development Project’s consistency with the first design guideline on Table IV.I-8 on pages IV.I-51 and IV.I-52 has been edited as follows:

Minimizing the number of driveways providing access from major or secondary highways.

InconsistentConsistent: The Development Project includes multiple driveways along Sepulveda Blvd. The driveway near the Sepulveda Boulevard and



Exposition Boulevard intersection would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed use projects ensuring impacts would be mitigated to below level of significance. Evaluation of Development Project impacts related to access is evaluated in Section IV.N, Transportation/Traffic, of this Draft EIR. Development Project access impacts were found to be less than significant.

The discussion of the Development Project’s consistency with the first “Community Design and Landscape Guidelines” guideline on pages IV.I-55 and IV.I-56 has been edited as follows:

Entryway Improvements: Provide improvements along principal streets and at major identified intersections and edges which clearly distinguish these as major entries to the community. Such improvements may include elements such as signage, landscaping, vertical pylons and/or distinctive treatments.

PartiallyConsistent. The Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station near the intersection of Sepulveda Boulevard and Exposition Boulevard. Additionally, the Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects ensuring impacts would be mitigated to below level of significance. Along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza area along Sepulveda Boulevard connect to the Project’s smaller scale retail environment with neighborhood tenants and outdoor dining. In addition, a portion of the second commercial level on Sepulveda Boulevard would be terraced to allow for additional outdoor dining. The leasing office for the Development Project would also be on Sepulveda Boulevard, directly accessible from the street.

The last paragraph on page IV.I-61 has been edited as follows:



Although compliance with the guidelines in the Walkability Checklist addressed in Table IV.I-410, Walkability Checklist Applicable Guidelines, is not mandatory, and the guidelines are not a part of the LAMC, incorporating the guidelines to the maximum extent feasible would create a more pedestrian-friendly environment and a higher quality of urban form for the Development Project. Discussion of the Development Project’s consistency with these guidelines is included in Table IV.I-410. As discussed, the Development Project would be not besubstantially consistent with severalmost of the applicable guidelines of the Walkability Checklist, and no significant impacts related to the Development Project’s consistency with the Walkability Checklist would occur. Particularly, the Development Project lacks direct commercial access from the Metro Expo II station along the frontage closest to the station near the intersection of Sepulveda Boulevard and Exposition Boulevard. The Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The discussion of the Development Project’s consistency with the first “Building Orientation” guideline on Table IV.I-10 on page IV.I-62 has been edited as follows:

The primary entrance for pedestrians should be at grade level from the public way and be easily accessible to transit stops, with as direct a path as possible to the transit stop. Retail establishments should maintain at least one entrance from the public way with doors unlocked during regular business hours.

Partially InconsistentConsistent. The primary pedestrian access points for the proposed commercial land uses would be at street level on Sepulveda Boulevard and Pico Boulevard. Pedestrian residential access points would be available at ground level on Pico, Sepulveda, and Exposition Boulevards. However, the Development Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station near the intersection of Sepulveda Boulevard and Exposition Boulevard. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects. As discussed previously, along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza areas would be designed to serve as a pedestrian “activation” function, by allowing sufficient room for pedestrian travel and by



providing pedestrian access to retail frontage and key site entry points on Pico Boulevard and Sepulveda Boulevard and to the Metro Expo II station access point that will be developed adjacent to the Development Project site near the intersection of Sepulveda Boulevard and Exposition Boulevard.

The discussion of the Development Project’s consistency with the fifth “Building Frontage” guideline on Table IV.I-10 on pages IV.I-62 and IV.I-63 has been edited as follows:

At corners, the building frontage should consider building cut-offs in response to any need to accommodate pedestrians and to protect pedestrian safety, security, and enjoyment.

InconsistentConsistent. Along Pico Boulevard and Sepulveda Boulevard, the building would be set back approximately 25 feet and 30 feet (respectively) from the roadways, allowing for development of publicly-accessible plaza areas. The setback areas would include widened sidewalks, a double row of trees, enhanced paving, drainage features, native plantings/landscaping, and a public art component. The plaza area along Sepulveda Boulevard connect to the Project’s smaller scale retail environment with neighborhood tenants and outdoor dining. The plaza areas would be designed to serve as a pedestrian “activation” function, by allowing sufficient room for safe pedestrian travel and by providing pedestrian access to key site entry points on Pico Boulevard and Sepulveda Boulevard. However, the Development Project does not include a cut-off at where the Development Project fronts the Metro Expo II station at the intersection of Sepulveda Boulevard and Exposition Boulevard. Additionally, includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The discussion of the Development Project’s consistency with the third “Off-Street Parking and Driveways” guideline on Table IV.I-10 on page IV.I-64 has been edited as follows:

Alleys should be used to access the parking behind the building. If no alley is available, access should be created from a side street.

Inconsistent: The development does not include any alley access, as all access is taken from Major Highways, Secondary Highway and a local street. The Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard



intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The discussion of the Development Project’s consistency with the fourth “Off-Street Parking and Driveways” guideline on Table IV.I-10 on pages IV.I-64 and IV.I-65 has been edited as follows:

Vehicle access into and from the site should be accommodated with as few driveways as possible to the street; and, where available, the site plan should encourage and accommodate as much vehicle access as possible from side streets and/or alleys.

Inconsistent: The development does not include any alley access, as all access is taken from Major Highways, Secondary Highway and a local street. Specifically two separate access (for commercial and residential parking) points are created along Sepulveda Blvd.Boulevard, one commercial access along Pico Blvd.Boulevard, a commercial parking exit along Sawtelle Blvd.Boulevard, and residential parking access along Exposition BlvdBoulevard. The Development Project includes a driveway near the Sepulveda Boulevard and Exposition Boulevard intersection that would appear to devalue the pedestrian-oriented station environment. Implementation of Mitigation Measure I-2 would ensure compliance with the Citywide Design Guidelines for Commercial and Residential mixed-use projects.

The discussion of the Development Project’s consistency with the second “Sidewalks” guideline on Table IV.I-10 on page IV.I-65 has been edited as follows:

Especially on long blocks, public alleys and/or easements should be used to create mid-block passageways or paseos which facilitate pedestrian movement from the sidewalk through the depth of the block to the front of the next parallel block such that pedestrian need not walk the entire circumference of a block in order to access the middle of the next parallel block or alley or parking behind the block.

Inconsistent. The De4velopment Project does not provide mid-block passageways or paseos which facilitate pedestrian movement from the sidewalk through the depth of the block to the front of the next parallel block..

The mitigation measures listed on page IV.I-67 have been edited as follows:

The following mitigation measures are required for the Development Project:



I-1. The Development Project Applicant shall comply with all applicable zoning requirements of the requested zoning and shall incorporate traffic mitigation measures and/or pay any required fees set forth in the WLA Transportation Improvement and Mitigation Specific Plan, as determined by the LADOT.

I-2. Prior to issuance of building permit, the Development Project shall demonstrate compliance with the applicable portions of both the Commercial Citywide Design Guidelines and the Residential Citywide Design Guidelines at the discretion of the Department of City Planning Urban Design Studio.

The following mitigation measure is required for the Development Project’s impacts related to exposure of ambient TACs:

I-31: For the residential portion of the Development Project, an air filtration system shall be installed and maintained with filters meeting or exceeding the ASHRAE Standard 52.2 Minimum Efficiency Reporting Value (MERV) of 13, to the satisfaction of the Department of Building and Safety.

The last paragraph on page IV.I-67 (extending to page IV.I-68) has been edited as follows:

The Proposed Project may be found to lack sufficient direct commercial access from the Metro Expo II station along the frontage closest to the station and includes a driveway near the Sepulveda Blvd. and Exposition Blvd. intersection that would appear to devalue the pedestrian-oriented station environment. Thus the project would not encourage Pedestrian-oriented design next to the Expo Phase II station. However, implementation of Mitigation Measure I-2 would insure compliance with the Citywide Design Guidelines for Commercial and Residential mixed use projects ensuring impacts would be mitigated to below level of significance.

SECTION IV.K (NOISE)

The following mitigation measure has been added to page IV.K-65 in Section IV.K (Noise) of the Draft EIR (refer to Response to Comment Beber-34 and to Section V [Mitigation Monitoring Report Plan] of the Final EIR):




APPENDIX IV.N (TRAFFIC STUDY)

Page 8 of the Traffic Study included in Appendix IV.N to the Draft EIR states, “The supporting data for the trip generation surveys of the concrete batch plant are contained in the appendices of this report.” However, these surveys were inadvertently omitted from the appendices. Thus, the surveys are included as Appendix G to the Final EIR.

Casden Sepulveda Project V. Mitigation Monitoring Report Plan Final Environmental Impact Report Page V-1

V. MITIGATION MONITORING REPORT PLAN

A. INTRODUCTION

Section 21081.6 of the Public Resources Code requires a Lead Agency to adopt a “reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment” (Mitigation Monitoring Program, Section 15097 of the CEQA Statute and Guidelines provides additional direction on mitigation monitoring or reporting). The City of Los Angeles is the Lead Agency for the Casden Sepulveda Project.

An Environmental Impact Report has been prepared to address the potential environmental impacts of the Project. Where appropriate, this environmental document identified Project design features or recommended mitigation measures to avoid or to reduce potentially significant environmental impacts of the Proposed Project. This Mitigation Monitoring Report Plan (MMRP) is designed to monitor implementation of the mitigation measures identified for the Project. The MMRP is subject to review and approval by the Lead Agency as part of the certification of the EIR and adoption of project conditions. The required mitigation measures are listed and categorized by impact area, as identified in the Draft EIR and Final EIR, with an accompanying identification of the following:

• Monitoring Phase, the phase of the project during which the mitigation measure shall be monitored;

o Pre-Construction, including the design phase o Construction o Pre-Occupancy (prior to issuance of a Certificate of Occupancy) o Occupancy (post-construction)

• Enforcement Agency, the agency with the power to enforce the mitigation measure; and

• Monitoring Agency, the agency to which reports including feasibility, compliance, implementation, and development are made.

The Project Applicant shall be responsible for implementing all mitigation measures unless otherwise noted. The MMRP performance shall be monitored annually to determine the effectiveness of the measures implemented in any given year and reevaluate the mitigation needs for the upcoming year.



B. MMRP

Section IV.A Impacts Found to be Less Than Significant

A-1. The developer shall replace all trees at or greater than 12 diameter at breast height (DBH) at a 1:1 ratio as per the City’s Tentative Tract Map.

Monitoring Phase: Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of City Planning

Section IV.B Aesthetics

B-1. All open areas not used for buildings, driveways, pedestrian amenities or walks shall be attractively landscaped and maintained in accordance with a landscape plan, including an automatic irrigation plan, prepared by a licensed landscape architect.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of Building and Safety

B-2. Every building, structure, or portion thereof, shall be maintained in a safe and sanitary condition and good repair, and free from graffiti, debris, rubbish, garbage, trash, overgrown vegetation or other similar material, pursuant to LAMC Section 91.8104.

Monitoring Phase: Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

B-3. The exterior of all buildings and fences shall be free from graffiti pursuant to LAMC Section 91.8104.15.




B-4. On-site signs shall be limited to the maximum allowable under the LAMC.

Monitoring Phase: Pre-Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

B-5. Multiple temporary signs in the store windows and along the building walls are not permitted.


B-6. A landscape plan shall be prepared by a licensed landscape architect.


B-7. The Applicant shall ensure through appropriate postings and daily visual inspections that no unauthorized materials are posted on any temporary construction barriers or temporary pedestrian walkways, and that such temporary barriers and walkways are maintained in a visually attractive manner throughout the construction period.

Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

B-8. The Applicant shall prepare a street tree plan to be reviewed and approved by the City’s Department of Public Works, Street Tree Division. All plantings in the public right-of-way shall be installed in accordance with the approved street tree plan.

Monitoring Phase: Construction Enforcement Agency: Department of Public Works Monitoring Agency: Department of City Planning



B-9. Outdoor lighting shall be designed and installed with shielding so that the light source cannot be seen from adjacent residential properties.

Monitoring Phase: Operation Enforcement Agency: Department of City Planning Monitoring Agency: Department of City Planning

B-10. All exterior windows and glass used on the building surfaces shall be non-reflective.

Monitoring Phase: Pre-Construction/Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of City Planning

B-11. All new street and pedestrian lighting within the public right-of-way shall be approved by the Bureau of Street Lighting and shall be tested in accordance with the requirements of the Bureau of Street Lighting.

Monitoring Phase: Construction/Operation Enforcement Agency: Bureau of Street Lighting Monitoring Agency: Department of City Planning

B-12. Architectural lighting shall be directed onto the building surfaces and have low reflectivity to minimize glare and limit light onto adjacent properties.

Monitoring Phase: Construction/Operation Enforcement Agency: Department of City Planning Monitoring Agency: Department of City Planning

B-13. Prior to the issuance of a building permit, architectural plans showing building surface materials shall be submitted to the Department of City Planning for review to ensure that specific surfacing materials and trim shall not cause roadway glare.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of City Planning



Section IV.C Air Quality

C-1. The Project Applicant shall implement measures to reduce the emissions of pollutants generated by heavy-duty diesel-powered equipment operating at the Project site throughout the construction of the Development Project. The Project Applicant shall include in the construction contract documents the air quality control measures required and recommended by the SCAQMD. Examples of the types of measures currently required and recommended by SCAQMD include the following:

• Keep all construction equipment in proper tune in accordance with manufacturer’s specifications.

• Use the most current grade of low-emission diesel fuel approved by ARB and available in the South Coast Air Basin for heavy-duty diesel-powered equipment operating and refueling at the Project site.

• Limit truck and equipment idling time to five minutes or less, when equipment is not in active use, as required by ARB.

• Rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion engines wherever possible.


C-2. Consistent with SCAQMD recommendations and to the extent feasible during Project construction, all internal combustion engines/construction equipment operating on the Project site shall meet EPA-Certified Tier 2 emissions standards, or higher according to the following:

• January 1, 2012 to December 31, 2014: All offroad diesel-powered construction equipment greater than 50 hp shall meet Tier 3 offroad emissions standards. In addition, all construction equipment shall be outfitted with BACT devices certified by CARB. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine as defined by CARB regulations.

• Post-January 1, 2015: All offroad diesel-powered construction equipment greater than 50 hp shall meet the Tier 4 emission standards, where available. In addition, all construction equipment shall be outfitted with BACT devices certified by CARB. Any emissions control device used by the contractor shall achieve



emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine as defined by CARB regulations.

Monitoring Phase: Construction Enforcement Agency: SCAQMD Monitoring Agency: Department of Building and Safety

C-3. The Project Applicant shall implement appropriate dust control measures during each phase of development as required by SCAQMD Rule 403—Fugitive Dust. Examples of the types of dust control measures currently required and/or recommended include, but are not limited to, the following:

• Water active grading/excavation sites and unpaved surfaces at least three times daily.

• Cover stockpiles with tarps or apply non-toxic chemical soil binders.

• Limit vehicle speed on unpaved roads to 15 mph.

• Sweep daily (with water sweepers) all paved construction parking areas and staging areas.

• Provide daily clean-up of mud and dirt carried onto paved streets from the site.

• Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site.

• Suspend excavation and grading activity when winds (instantaneous gusts) exceed 15 mph over a 30-minute period or more.

• An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessive fugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt.




Section IV.D Cultural Resources

D-1. A covenant and agreement shall be recorded between the Development Project and the City of Los Angeles Department of City Planning prior to obtaining a grading permit stating that if any archaeological resources are encountered during Project development, the project shall be halted. The services of an archaeologist shall be secured by contacting the South Central Coastal Information Center (SCCIC) (657-278-5395) located at California State University Fullerton, or a member of the Society of Professional Archaeologist (SOPA) or a SOPA-qualified archaeologist who shall assess the discovered material(s) and prepare a survey, study or report evaluating the impact. The archaeological survey, study or technical report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource. The applicant shall comply with the recommendations of the evaluating archaeologist, as contained in the survey, study or report. Project development activities may resume once copies of the archaeological survey, study or report are submitted to the SCCIS at CSU Fullerton. 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.


D-2. A covenant and agreement shall be recorded between the Project and the City of Los Angeles Department of City Planning prior to obtaining a grading permit stating that if any paleontological materials are encountered during the course of the Project development, the Project shall be halted. The services of a qualified paleontologist approved by the City or County of Los Angeles and the Los Angeles County Natural History Museum (LACM) Vertebrate Paleontology Section shall be retained to assess the discovered material(s) and prepare a survey, study or report evaluating the impact. The paleontological survey, study or technical report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource. The applicant shall comply with the recommendations of the evaluating paleontologist, as contained in the survey, study or report. Project development activities may resume once copies of the paleontological survey, study or report are submitted to the LACM. 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.




D-3. If human remains are discovered at the Project site during construction, work at the construction site shall be halted, and the City of L.A. Public Works Department and County Coroner shall be immediately notified. The County Coroner (1104 N. Mission Road, Los Angeles, CA 90033) can be contacted at (323) 343-0512 (8 a.m. to 5 p.m. weekdays) or (323) 343-0714 (after hours, weekends, and holidays). The coroner has two working days to examine human remains after being notified by the responsible person. If the remains are determined by the County Coroner to be Native American, the Coroner has 24 hours to notify Native American Heritage Commission (NAHC). The Native American Heritage Commission will immediately notify the person it believes to be the most likely descendent of the deceased Native American. The most likely descendent 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 goods. If the descendent does not make recommendations within 48 hours, the owner shall reinter the remains in an area of the property secure from further disturbance, or, if the owner does not accept the descendant’s recommendations, the owner or the descendent may request mediation by the NAHC.


Section IV.E Geology and Soils

E-1. The Development Project shall be designed and constructed in accordance with the recommendations provided in the Geotechnical Report, which shall be approved by the Department of Building and Safety prior to issuance of building and grading permits.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety



Section IV.F Greenhouse Gas Emissions

F-1. The Development Project shall meet the requirements of the City of Los Angeles Green Building Code. Specifically, as it relates to the reduction of GHG emissions, the Development Project shall:

• Be designed to exceed Title 24 2008 Standards by 15 percent;

• Reduce potable water consumption by 20 percent through the use of low-flow water fixtures; and

• Each appliance provided and installed shall meet ENERGY STAR if an ENERGY STAR designation is applicable for that appliance.


Section IV.G Hazards and Hazardous Materials

G-1. Prior to issuance of a building permit, the applicant shall obtain a “No Further Action” letter from the Los Angeles County Fire Department (LACFD) that verifies that all identified contaminants have been remediated to below the Maximum Concentration Levels (MCL) appropriate for residential use. The Project Applicant shall also receive verification from the LACFD that all soil to be exported offsite is remediated to the appropriate levels for export.

Monitoring Phase: Pre-Construction Enforcement Agency: Los Angeles County Fire Department Monitoring Agency: Department of Building and Safety

G-2. Prior to issuance of a building permit, the applicant shall selectively remove soils containing elevated arsenic from the site, and shall receive verification from the LACFD that acceptable MCL levels appropriate for residential use are present across the site.

Monitoring Phase: Pre-Construction Enforcement Agency: Los Angeles County Fire Department Monitoring Agency: Department of Building and Safety



G-3. Prior to issuance of a building permit, during site grading activities, environmental monitoring of on-site soils within disturbed areas in the former tank/clarifier areas shall be implemented pursuant to a site specific Soil Management Plan. Specifically, soils must be analyzed for TPH. The environmental monitoring must define the extent of any remaining soil contamination and the Soil Management Plan must identify and classify any contaminated soils encountered during excavation and grading, including appropriate remediation methods and reuse limitations, if any. Prior to issuance of a building permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified abatement consultant that no contaminated soils are present on-site. If any remaining contaminated soils are found to be present, a qualified abatement consultant shall abate the soils in compliance with Department of Building and Safety and other applicable state and federal regulations.


G-4. Prior to issuance of a building permit, the applicant shall provide a letter to the LAFD Underground Storage Tank Division from a qualified UST decommissioning consultant that no USTs are present on-site. If USTs are found to be present, a qualified UST consultant shall decommission the USTs in compliance with LAFD, RWQCB, and DTSC standards. ASTs shall also be decommissioned in compliance with applicable LAFD, RWQCB, and DTSC standards, which are designed to ensure that any residual materials within the tanks are properly removed, contained, and disposed and that no material spillage and resultant impact to soils and water quality results from the tank removal process.

Monitoring Phase: Pre-Construction Enforcement Agency: Los Angeles Fire Department Monitoring Agency: Department of Building and Safety

G-5. Prior to issuance of a demolition permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified PCB abatement consultant that no PCBs are present on-site. If PCBs are found to be present, a qualified abatement consultant shall abate the site in compliance with the applicable city, state and federal rules and regulations. Such abatement will typically consist of removing the PCB containing materials while implementing protective measures to minimize dust



generation, store PCB contaminated materials, regularly clean work areas, and properly dispose of contaminated protective clothing.


G-6. Prior to issuance of a demolition permit, structures at the Development Project site that are to be demolished shall be examined for the presence of suspected ACMs by a qualified asbestos abatement consultant. Suspected ACMs that were not previously sampled shall be sampled and analyzed for asbestos content prior to any disturbance. Prior to issuance of the demolition permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified asbestos abatement consultant that no ACMs are present in the buildings. If additional ACMs are found to be present, a qualified asbestos abatement consultant shall abate the buildings in compliance with the South Coast Air Quality Management District’s Rule 1403 as well as all other applicable state and federal rules and regulations. Asbestos abatement typically consists of sealing the building, removing the asbestos as sections are demolished, and utilizing specially designed vacuums to segregate the asbestos for removal from the site.


G-7. Prior to issuance of a demolition permit, structures at the Development Project site that are to be demolished shall be examined for the presence of LBP by a qualified LBP removal contractor. Any contractor engaged to work in structures containing LBP who may disturb lead containing surfaces shall be notified of the hazard and their requirement to comply with applicable city, state, and federal regulations. Any LBP identified shall be abated by a qualified abatement contractor in accordance with all applicable city, state, and federal regulations. Prior to issuance of the demolition permit, the applicant shall provide a letter to the Department of Building and Safety from a qualified LBP removal consultant that no LBP is present in the buildings.




Section IV.H Hydrology and Water Quality

H-1. The Proposed Development Project shall be designed and constructed in accordance with the recommendations provided in a final geotechnical report, which shall be approved by the Department of Building and Safety prior to issuance of building and grading permits.


H-2. The Applicant of the Development Project shall maintain all structural or treatment control BMPs for the life of the Development Project.


H-3. The Proposed Development Project shall be designed and constructed in accordance with the recommendations provided in a final geotechnical report, which shall be approved by the Department of Building and Safety prior to issuance of building and grading permits. The specific design recommendations presented in the comprehensive geotechnical report shall be incorporated into the design and construction of the Proposed Project.


H.4 Prior to the issuance of demolition and building permits, the applicant shall provide proof to the City that a NOI has been filed with the SWRCB for coverage under the General Construction Permit and a project-specific Risk Assessment, and SWPPP have been prepared. Such evidence shall consist of a copy of the NOI stamped by the SWRCB or Regional Board, or a letter from either agency stating that the NOI has been filed. The SWPPP shall include a menu of BMPs to be selected and implemented based on the phase of construction and the weather conditions to effectively control erosion, sediment, and other construction-related pollutants to meet the Best Available Technology



Economically Achievable and Best Conventional Pollutant Control Technology standards. The BMPs to be implemented during construction shall address the following:

• Erosion Control;

• Sediment Control;

• Waste and Materials Management;

• Non-stormwater Management;

• Training and Education; and

• Maintenance, Monitoring, and Inspections.

As required by the Construction General Permit, during all phases of construction, the Project shall implement BMPs consistent with the Best Available Technology Economically Achievable and Best Conventional Pollutant Control Technology standards. BMPs for reducing erosion and sediment control include site planning considerations, vegetative stabilization, physical stabilization, diversion of runoff, velocity reduction of runoff, and sediment trapping/filtering. In addition to the SWPPP, all earthwork on the Development Project site shall be performed in accordance with the requirements of the City of Los Angeles Building and Safety, the City of Los Angeles Civil Engineer of Record.

Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety/Department of Public Works Monitoring Agency: Department of Building and Safety

H-5. The amount of exposed soils shall be limited and erosion control procedures implemented for those areas that must be exposed.


H-6. Grading activities shall be phased so that graded areas are landscaped or otherwise covered, as quickly as possible after completion of activities.




H-7. Appropriate dust suppression techniques, such as watering or tarping shall be used in areas that must be exposed.


H-8. All waste shall be disposed of properly. Appropriately labeled recycling bins shall be used to recycle construction materials including: solvents, water-based paints, vehicle fluids, broken asphalt and concrete, wood, and vegetation. Non-recyclable materials/wastes shall be taken to an appropriate landfill. Toxic wastes shall be discarded at a licensed regulated disposal site.


H-9. Leaks, drips, and spills shall be cleaned up immediately to prevent contaminated soil on paved surfaces that can be washed away into the storm drains.


H-10. The construction contractors and users of the Development Project site shall not hose down pavement at material spills. Dry cleanup methods shall be used whenever possible.




H-11. Dumpsters shall be covered and maintained. Uncovered dumpsters shall be placed under a roof or cover with tarps or plastic sheeting.


H-12. Truck loads shall be tarped.


H-13. Simple sediment filters shall be constructed at or near the entrances to the municipal storm drain system wherever feasible.

Monitoring Phase: Construction Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety

H-14. Where truck traffic is frequent, gravel approaches shall be used to reduce soil compaction and limit the tracking of sediment into streets.


H-15. All construction areas shall be secured to control off-site migration of pollutants. The Project applicant/developer shall conduct truck-wheel cleaning and truck washing to prevent dirt in storm water.




H-16. All vehicle/equipment maintenance, repair, and washing shall be conducted away from storm drains. All major repairs shall be conducted off-site. Drip pans or drop clothes shall be used to catch drips and spills.


H-17. The Project applicant/developer shall keep vehicles in good working order.


H-18. The Project Applicant shall implement stormwater BMPs to capture and manage 100 percent from a storm event producing ¾ inch of rainfall in a 24-hour period in the following order of priority: infiltration, evapotranspiration, capture and reuse, City approved bio-filtration/retention system BMP or combination of the above. The design of structural BMPs shall be in accordance with the LID Section of the Development Best Management Practices Handbook Part B Planning Activities. If the Bureau of Sanitation Stormwater Protection Division determines that the above 100 percent capture is infeasible, then the Project Applicant shall implement offsite mitigation within the same sub-watershed for the same. Prior to issuance of a building permit, the Applicant shall be required to verify the Stormwater Protection Division’s approval of the LID strategies and submit a signed certificate from a California licensed civil engineer or licensed architect that the proposed BMPs meet this numerical threshold.




H-19. Post-development peak stormwater runoff discharge rates shall not exceed the estimated pre-development rates for developments where increased peak stormwater discharge rate will result in increased potential for downstream erosion.


H-20. The Project Applicant shall utilize trees and other vegetation by planting additional vegetation, clustering tree areas, and promoting the use of native and/or drought tolerant plants.


H-21. Impervious surface area shall be minimized by using permeable pavement materials where appropriate, including: pervious concrete/asphalt; unit pavers, i.e. turf block; and granular materials, i.e. crushed aggregates, cobbles.


H-22. Any connection to the sanitary sewer shall have authorization from the Bureau of Sanitation.

Monitoring Phase: Pre-Construction Enforcement Agency: Bureau of Sanitation Monitoring Agency: Department of Building and Safety



H-23. Toxic wastes shall be discarded at a licensed regulated disposal site. Trash dumpsters shall be stored under cover and with drains routed to the sanitary sewer, or use non-leaking and water-tight dumpsters with lids. Drip pans or absorbent materials shall be used whenever grease containers are emptied. Containers shall be washed in an area with properly connected sanitary sewer.

Monitoring Phase: Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

H-24. Wastes shall be reduced and recycled, including: paper, glass, aluminum, oil, and grease.


H-25. The use of hazardous materials and waste shall be reduced by: using detergent-based or water-based cleaning systems; and avoid chlorinated compounds, petroleum distillates, phenols, and formaldehyde.


H-26. All storm drains inlets and catch basins within the Project area shall be stenciled with prohibitive language (such as “NO DUMPING – DRAINS TO OCEAN”) and/or graphical icons to discourage illegal dumping.

Monitoring Phase: Operation Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety



H-27. Signs and prohibitive language and/or graphical icons, which prohibit illegal dumping, shall be posted at public access points along channels and creeks with the Project area.


H-28. Legibility of stencils and signs shall be maintained.


H-29. Materials with the potential to contaminate stormwater shall be: (1) placed in an enclosure such as, but not limited to, a cabinet, shed, or similar stormwater conveyance system; or (2) protected by secondary containment structures such as berms, dikes, or curbs.


H-30. All storage areas shall be paved and sufficiently impervious to contain leaks and spills.


H-31. All outdoor storage areas shall have a roof or awning to minimize collection of stormwater within the secondary containment area.




H-32. The owner(s) of the properties shall prepare and execute covenant and agreement (Planning Department General form CP-6770) satisfactory to the Planning Department binding the owners to post construction maintenance on the structural BMPs in accordance with the Standard Urban Stormwater Mitigation Plan and/or per manufacturer’s instructions.

Monitoring Phase: Pre-Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

H-33. Appropriate erosion control and drainage devices, such as interceptor terraces, berms, vee-channels, and inlet and outlet structures, shall be incorporated into the Proposed Project as specified by Section 91.7013 of the Building Code. Outlets of culverts, conduits, and channels shall be protected from erosion by discharge velocities by installing a rock outlet protection. Rock outlet protection is a physical device composed of rock, grouted riprap, or concrete rubble placed at the outlet of a pipe. Sediment traps shall be installed below the pipe-outlet. Outlet protection shall be inspected, repaired, and maintained after each significant rain.


Section IV.I Land Use and Planning

I-1. For the residential portion of the Development Project, an air filtration system shall be installed and maintained with filters meeting or exceeding the ASHRAE Standard 52.2 Minimum Efficiency Reporting Value (MERV) of 13, to the satisfaction of the Department of Building and Safety.




Section IV.K Noise

K-1. Construction at the Project site shall occur only between 7:00 AM and 9:00 PM Monday through Friday and between 8:00 AM and 6:00 PM on Saturdays and national holidays. There shall be no construction activities on Sundays.


K-2. Loading dock activities that occur outside at the Project site shall occur only between 7:00 AM and 10:00 PM. Exterior loading dock activities shall not be permitted on site outside of these hours.


K-3. Delivery truck drivers shall minimize acceleration and maintain reduced vehicle speeds while on site. Signs shall be posted instructing delivery truck drivers to turn off their engines in the parking and loading areas (with the exception of refrigerated delivery trucks or other vehicles that require power to safely maintain their cargo), and to maintain quiet operations while on site. This includes turning off radios/stereo systems in the delivery trucks. All delivery trucks shall be required to have properly maintained, factory-approved mufflers.


K-4. There shall be no speed bumps or uneven pavement in the loading dock area or on the driveway serving the loading dock.




K-5. Once detailed architectural plans for the Proposed Project are available, an acoustical study shall be conducted to verify that the interior noise level at all residential units on the Project site shall not exceed the City’s standard of 45 dB CNEL. The design features required to achieve compliance may include one or more of the following elements, as verified by the acoustical study: sound-rated windows and doors, size and orientation of windows relative to the noise sources (streets, freeway, and light rail line), upgraded exterior wall construction, insulation batts, and forced air ventilation/air conditioning. The study shall address both existing and future noise levels.


K-6. Once detailed mechanical plans for the Proposed Project are available, an acoustical study shall be conducted in order to verify that the future noise levels generated by mechanical equipment (air conditioners, elevator equipment, refrigeration equipment, exhaust fans, etc.) at the Project site comply with the City’s noise ordinance standards. The study shall address potential impacts of noise from commercial portions of the Proposed Project on residential portions of the Project Site as well as impacts at off-site receptors. The design features necessary to achieve compliance may include one or more of the following elements, as verified by the acoustical study: selecting quieter equipment, adding or upgrading silencers, improving the design of mechanical penthouses, raising the height of rooftop parapet walls, placing equipment inside a building, and/or installing screen walls around individual equipment items.






Section IV.M Public Services

M-1. The Development Project shall provide for and install a 10-inch water main to serve the Project site to satisfy the required 4,000 gallons-per-minute fire flow.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety

M-2. The Project Applicant shall submit a plot plan to the LAFD prior to occupancy of the Project, for review and approval, which shall provide the capacity of the fire mains serving the Project site. Any required upgrades shall be identified and implemented prior to occupancy of the Project.

Monitoring Phase: Construction Enforcement Agency: Los Angeles Fire Department Monitoring Agency: Department of Building and Safety and Los Angeles Fire Department

M-3. The Development Project shall comply with all fire code and ordinance requirements for building construction, emergency access, water mains, fire flows, and hydrant placement. Prior to the issuance of a certificate of occupancy for any phase of the Project, the Applicant shall implement all fire code and ordinance requirements to the satisfaction of the LAFD.

Monitoring Phase: Pre-Construction/Construction Enforcement Agency: Los Angeles Fire Department Monitoring Agency: Department of Building and Safety and Los Angeles Fire Department

M-4. The design of the Project site shall provide adequate access for LAFD equipment and personnel to the structure.

Monitoring Phase: Pre-Construction Enforcement Agency: Los Angeles Fire Department Monitoring Agency: Department of Building and Safety and Los Angeles Fire Department



M-5. During construction activities, the Development Project developer shall ensure that all on-site areas of active development, material and equipment storage, and vehicle staging, that are adjacent to existing public roadways, be secured to prevent trespass.


M-6. The Development Project design shall address:

• Access control to proposed structures including parking areas;

• Proposed security lighting; and

• Landscaping planning and minimization of dead space to eliminate areas of concealment.


M-7. The Development Project shall comply with The Design Out Crime Guidelines: Crime Prevention Through Environmental Design, published by LAPD. Additionally, all crime prevention features shall be reviewed by the LAPD prior to the issuance of a building permit.

Monitoring Phase: Pre-Construction Enforcement Agency: Los Angeles Police Department Monitoring Agency: Department of Building and Safety

M-8. The Applicant shall be required to pay LAUSD developer school fees to the satisfaction of the administering agency.




M-9. The Development Project Applicant shall pay all required parkland fees pursuant to LAMC Section 21.10.3(a)(1).


M-10. In consultation with the City of Los Angeles Department of Recreation and Parks, the Development Project Applicant shall be required to comply with one or more of the following: 1) dedicate two acres of parkland per 1,000 residents, 2) pay in-lieu fees for any land dedication requirement shortfall, or 3) provide on-site improvements equivalent in value of the in-lieu fees, or any portion thereof.


M-11. The Development Project Applicant shall pay a mitigation fee of $200 per capita based upon the projected residential population generated as a result of the buildout of the proposed development.


Section IV.N Transportation/Traffic

N-1. Prior to issuance of a Building Permit, the Development Project Applicant shall pay traffic impact fees to the City, based on the requirements of the WLA TIMP.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of Transportation Monitoring Agency: Department of Transportation



N-2. Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall prepare and implement a Transportation Demand Management (TDM) program to the satisfaction of LADOT to reduce traffic impacts of the Development Project encouraging Development Project residents, employees, and patrons to reduce vehicular traffic on the street and freeway system during the most congested time periods of the day. The TDM program shall include implementation of several TDM strategies, including, but not limited to the following:

• On-site Transportation Coordinator, in charge the following:

o Carpool/Vanpool and Rideshare Matching

o Preferential Vanpool/Carpool Parking

o Enrollment in Metro’s B-Tap pass program (annual group rate discounted transit passes) for all onsite residential occupants and retail employees

o Parking Cash-Out

o Flex-Use Vehicles

o Guaranteed Ride Home

• Bicycle Racks and Showers/Lockers

• Flexible Work Hours/Telecommute Opportunities

• Bus/Transit Stop Shelters and/or Amenities

• Wayfinding Information and Signage

Monitoring Phase: Construction Enforcement Agency: Department of Transportation Monitoring Agency: Department of Transportation



N-3. The Applicant shall implement a mitigation package in coordination between LADOT and Council District 5, and the surrounding community that shall include the three major components listed below. The determination of the “fair share” cost of this mitigation shall be subject to final approval by Council District 5 and LADOT. Subsequent to this determination, the Applicant shall be responsible for executing the appropriate agreement to guarantee the Development Project’s obligation to said agreement, prior to the issuance of any certificate of occupancy.

1. The Applicant shall provide funding assistance, fair share cost consideration, at the discretion of LADOT, for all aspects of the Expo Light Rail (ELR) Phase 2 – Pico Boulevard/Sepulveda Boulevard Station development including: grade separated station construction, transit station enhancements, parking meter technology upgrades, shuttle / circulator services, etc.

2. The Applicant shall provide funding assistance, fair share cost consideration at the discretion of LADOT, for all applicable aspects of the City’s Mobility Hub concept to the planned ELR Phase 2 Pico/Sepulveda Station including, but not limited to such measures as: secure bicycle parking, bicycle sharing, hourly car rentals, and a folding bike leasing program.

3. The Applicant shall provide funding assistance, fair share cost consideration at the discretion of LADOT, for all available Capital Improvement projects in the general area surrounding the Development Project site.


N-4. Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall widen the northwest corner of the Ohio Avenue and Sepulveda Boulevard intersection within the existing right-of-way to construct a new southbound right-turn only lane on Sepulveda Boulevard at this location.




N-5. Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall restripe the southbound approach of Westwood Boulevard at the intersection of Olympic Boulevard and Westwood Boulevard within the existing roadway width to add a new right-turn-only lane.


N-6. Prior to issuance of a Certificate of Occupancy, at the intersection of Tennessee Avenue/San Diego southbound off-ramp and Sawtelle Boulevard, the Development Project Applicant shall convert the existing through/right-turn lane of the off-ramp to a left-turn/through/right-turn lane, and reconfigure the traffic signal phasing to provide opposed east-west signal indications. (This measure requires review and approval from Caltrans.)


N-7. Prior to issuance of a Certificate of Occupancy, at the intersection of Pico Boulevard and Barrington Avenue, the Development Project Applicant shall increase capacity by implementing the following:

a. Restripe the northbound approach of Barrington Avenue within the existing roadway width to provide an exclusive right-turn-only lane; and

b. Install new left-turn signal phasing (protected/permissive) for both the northbound and southbound approaches of this intersection, consistent with the City’s ongoing left-turn phasing installation program.




N-8. Prior to issuance of a Certificate of Occupancy, at the intersection of Venice Boulevard and Sepulveda Boulevard, the Development Project Applicant shall do the following:

a. Widen the east side of Sepulveda Boulevard north of Venice Boulevard, and restripe the northbound approach to convert the existing right-turn only lane to a shared through/right-turn lane; and

b. Restripe the north leg of Sepulveda Boulevard to provide a third northbound “receiving” lane, which will ultimately transition back to the two existing northbound travel lane configuration.


N-9. Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall install a new eastbound left-turn lane (approximately 50-foot-pocket plus appropriate transitions) and a new westbound right-turn lane (approximately 100-foot-pocket plus appropriate transitions) on Exposition Boulevard.


N-10. Prior to issuance of a Certificate of Occupancy, the Development Project Applicant shall install the following features: a new sidewalks and reconstruction of the sidewalks adjacent to the Development Project site to allow for easier pedestrian flow; a caution signage for bicyclists, pedestrians, and drivers at the Development Project driveway; mirrors at the Development Project driveway to allow drivers exiting the site to check for on-coming traffic; flashing lights at the Development Project driveway to indicate that a car is approaching the exit.




Section IV.O Utilities

O-1. The landscaped irrigation system shall be designed, installed, and tested to provide uniform irrigation coverage for each zone. Sprinkler head patterns shall be adjusted to minimize over spray onto walkways and streets. Each zone (sprinkler valve) shall water plants having similar watering needs (do not mix shrubs, flowers and turf in the same watering zone).

Automatic irrigation timers shall be set to water landscaping during early morning or late evening hours to reduce water losses from evaporation. Irrigation run times shall be adjusted for all zones seasonally, reducing water times and frequency in the cooler months (fall, winter, spring). Sprinkler timer run times shall be adjusted to avoid water runoff, especially when irrigating sloped property.

The irrigation systems shall also meet the following requirements:

• Weather-based irrigation controller with rain shutoff;

• Flow sensor and master valve shutoff (large landscapes);

• Matched precipitation (flow) rates for sprinkler heads;

• Drip/microspray/subsurface irrigation where appropriate;

• Minimum irrigation system distribution uniformity of 75 percent;

• Proper hydro-zoning, turf minimization and use of native/drought tolerant plant materials; and

• Use of landscaping contouring to minimize precipitation runoff.


O-2. Prior to issuance of a building permit, the Applicant of the Development Project shall submit a Landscape Plan that includes the water budget calculations and the estimated total water use (ETWU) of the project’s landscape. The ETWU shall not exceed the Maximum Applied Water Allowance (MAWA) of the State’s Model Water Efficient Landscape Ordinance. The project landscaping shall comply with all other requirements of the State’s Model Water Efficient Landscape Ordinance. In addition, drought-tolerant, low water consuming plant varieties shall be used to reduce irrigation water consumption. For a list of these plant varieties, refer to Sunset Magazine, October 1988, “The Unthirsty 100,” pp. 74-83, or consult a landscape architect.




O-3. The Applicant of the Development Project shall use recycled water (where available) for appropriate end uses (irrigation, cooling towers, sanitary).

Monitoring Phase: Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Public Works

O-4. The Applicant of the Development Project shall install ultra-low-flush high-efficiency toilets (1.28 gallons/flush or less, includes dual flush), ultra-low-flush high-efficiency urinals (0.5 gallons/flush or less, includes waterless), and water-saving showerheads (2.0 gallons/minute or less) in both new construction and when remodeling and limited to one showerhead per shower stall. Low flow faucet aerators shall be installed on all sink faucets with a faucet flow rate of 1.5 gallons/minute or less.

Monitoring Phase: Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-5. Significant opportunities for water savings exist in air conditioning systems that utilize evaporative cooling (i.e. employ cooling towers). Cooling towers shall be operated at a minimum of 5.5 cycles of concentration.


O-6. The Applicant of the Development Project shall install domestic water heating systems located in close proximity to point(s) of use, as feasible. Tank-less and on-demand water heaters shall be used as feasible. Recirculating or point-of-use hot water systems can



reduce water waste in long piping systems where water must be run for considerable periods before heated water reaches the outlet.

Monitoring Phase: Pre-Construction/Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-7. The Applicant of the Development Project shall install high-efficiency clothes washers (water factor of 5.0 or less for residential and 7.5 for commercial) where clothes washers are provided, and high-efficiency dishwashers (Energy Star rated) shall be installed where dishwashers are provided. Water conserving clothes washers and dishwashers are now available from many manufacturers. Water savings also represent energy savings, in that the water saved by these appliances is typically heated.


O-8. The Applicant of the Development Project shall install onsite water recycling systems for wastewater discharge for commercial laundries, dye houses, food processing, certain manufacturing operations, etc. (subject to a payback threshold of five years or less).


O-9. Single-pass cooling shall be prohibited.


O-10. The Applicant of the Development Project shall install metering systems as follows:

• All dwelling units shall have individual metering and billing for water use; and



• All irrigated landscapes of 5,000 square feet or more require separate metering or submetering.

• Monitoring Phase: Pre-Construction/Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-11. Should it be determined that the existing water main infrastructure is unable to accommodate the estimated water consumption for the Development Project site, the Applicant of the Development Project shall make special arrangements with LADWP to enlarge the supply lines.


O-12. Prior to issuance of building permit, the Los Angeles Bureau of Sanitation (LABS) shall verify that sufficient wastewater conveyance capacity exists to accommodate the project’s wastewater. If it is found that the adjacent sewer infrastructure has insufficient capacity for the Proposed Project, the developer shall be required to build another sewer line or additional laterals with direct flow to the nearest, larger line that has the available capacity. Final verification of sufficient capacity shall be demonstrated prior to issuance of any Certificate of Occupancy.

Monitoring Phase: Pre-Construction Enforcement Agency: Bureau of Sanitation Monitoring Agency: Department of Building and Safety

O-13. In compliance with City Ordinance 171,687, the construction contractor shall provide space for recycling containers.

Monitoring Phase: Construction Enforcement Agency: Bureau of Sanitation Monitoring Agency: Department of Building and Safety



O-14. In compliance with AB 939, the construction contractor shall only contract for waste disposal services with a company that recycles construction-related wastes.


O-15. In compliance with AB 939, to facilitate the on-site separation and recycling of construction-related wastes, the construction contractor shall provide temporary waste separation bins on-site during construction.


O-16. All waste shall be disposed of properly. Approximately labeled recycling bins shall be used to recycle construction materials including: solvents, water-based paints, vehicle fluids, broken asphalt and concrete, wood and vegetation. Non-recyclable materials/wastes must be taken to an appropriate landfill. Toxic wastes must be discarded at a licensed regulated disposal site.

Monitoring Phase: Construction/Operation Enforcement Agency: Bureau of Sanitation Monitoring Agency: Department of Building and Safety

O-17. Recycling bins shall be provided at appropriate locations in both residential and retail components to promote recycling of paper, metal, glass, and other recyclable material, including greenwaste. These bins shall be emptied and recycled accordingly in both residential and retail components as a part of the project's regular solid waste disposal program.

Monitoring Phase: Operation Enforcement Agency: Bureau of Sanitation Monitoring Agency: Department of Building and Safety



O-18: Energy Performance. The Development Project shall exceed California Energy Code requirements, based on the 2008 Energy Efficiency Standards, by 15 percent. Using an Alternative Calculation Method (ACM) approved by the California Energy Commission, calculate each building’s TDV energy and CO2 emissions and compare it to the standard or “budget” building.

Monitoring Phase: Pre-Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-19: Green Power. The Development Project shall be required to use 20 percent of the annual residential and commercial building energy demand from green power. The 20 percent usage could be achieved through the Project’s participation in the Los Angeles Department of Water and Power’s Green Power Program.

Monitoring Phase: Pre-Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-20: Built-in appliances, refrigerators, and space-conditioning equipment should exceed the minimum efficiency levels mandated in the California Code of Regulations.


O-21: Install high-efficiency air conditioning controlled by a computerized energy-management system in the retail spaces that provides the following:

• A variable air-volume system that results in minimum energy consumption and avoids hot water energy consumption for terminal reheat;

• A 100-percent outdoor air-economizer cycle to obtain free cooling in appropriate climate zones during dry climatic periods:



• Sequentially staged operation of air-conditioning equipment in accordance with building demands; and

• The isolation of air conditioning to any selected floor or floors.


O-22: Consider the applicability of the use of thermal energy storage to handle cooling loads.

Monitoring Phase: Pre-Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-23: Cascade ventilation air from high-priority areas before being exhausted, thereby decreasing the volume of ventilation air required. For example, air could be cascaded from occupied space to corridors and then to mechanical spaces before being exhausted.


O-24: Recycle lighting system heat for space heating during cool weather. Exhaust lighting-system heat from the buildings via ceiling plenums to reduce cooling loads in warm weather.




O-25: Install low and medium static-pressure terminal units and ductwork to reduce energy consumption by air-distribution systems.

Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-26: Ensure that buildings are well sealed to prevent outside air from infiltrating and increasing interior space-conditioning loads. Where applicable, design building entrances with vestibules to restrict infiltration of unconditioned air and exhausting of conditioned air.


O-27: A performance check of the installed space-conditioning system should be completed by the developer/install prior to issuance of the Certificate of Occupancy to ensure that energy-efficiency measures incorporated into the Development Project operate as designed.


O-28: Finish exterior walls with light-colored materials and high-emissivity characteristics to reduce cooling loads. Finish interior walls with light-colored materials to reflect more light and thus, increase lighting efficiency.




O-29: Use a white reflective material (in lieu of dark-colored materials but not to replace “green” roofing materials) for roofing meeting California standards for reflectivity and emissivity to reject heat.


O-30: Install thermal insulation in walls and ceilings that exceeds requirements established by the California Code of Regulations.


O-31: Design window systems to reduce thermal gain and loss, thus reducing cooling loads during warm weather and heating loads during cool weather.


O-32: Install heat-rejecting window treatments, such as films, blinds, draperies, or others on appropriate exposures.




O-33: Install whenever possible fluorescent and high-intensity-discharge (HID) lamps that give the highest light output per watt of electricity consumed, including all street and parking lighting to reduce electricity consumption. Use reflectors to direct maximum levels of light to work surfaces.


O-34: Install photosensitive controls and dimmable electronic ballasts to maximize the use of natural daylight available and reduce artificial lighting load.


O-35: Install occupant-controlled light switches and thermostats to permit individual adjustment of lighting, heating, and cooling to avoid unnecessary energy consumption.

Monitoring Phase: Pre-Construction/Construction/Operation Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power

O-36: Install time-controlled interior and exterior public area lighting limited to that necessary for safety and security.




O-37: Control mechanical systems (heating, ventilation, and cooling and lighting) in the building with timing systems to prevent accidental or inappropriate conditioning or lighting of unoccupied space.


O-38: Incorporate windowless walls or passive solar inset of windows into the Development Project for appropriate exposures.


O-39: Design the Development Project to focus pedestrian activity within sheltered outdoor areas.


O-40: If applicable, the Applicant of the Development Project shall coordinate with LADWP and fund the installation of the upgraded facilities as needed to maintain an adequate electricity distribution system and/or to connect the Development Project site to the surrounding infrastructure.




O-41: The Applicant shall coordinate with Southern California Gas and fund the installation of the upgraded facilities needed to connect the Proposed Project to the surrounding infrastructure.




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