environmental review section...the draft eir. on april 30, 2009, the city released the draft eir for...

Environmental Review SectionCity Hall � 200 N. Spring Street, Room 750 � Los Angeles, CA 90012

ENVIRONMENTAL IMPACT REPORT (FINAL)WEST LOS ANGELES COMMUNITY PLAN AREA

Bundy Village and Medical Park Case No. ENV-2006-3125-EIR

SCH No. 2006111106

Council District No. 11 THIS DOCUMENT COMPRISES THE FINAL ENVIRONMENTAL IMPACT REPORT AS REQUIRED

UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT

Project Address:1901 South Bundy Drive; 1925 South Bundy Drive;

1933 South Bundy Drive; and 12333 West Olympic Boulevard

Project Description: Zone Change from M2-1 to RAS3-1, General Plan Amendment to change the land use designation from Light Industrial to General Commercial in Parcel A, Conditional Use Permit to allow medical offices in M2-1 zone in Parcel B, Vesting Tentative Tract Map, Site Plan Review findings, Haul Route approval, and any other actions as may be determined necessary. The proposed project would involve the demolition of all on-site uses and the development of a mixed-use project and medical offices with associated parking on a 11.55-acre site. The proposed project would include 385 dwelling units, 119,838 square feet of retail space (including approximately 9,500 square feet of restaurant space) on Parcel A, and the development of 384,735 square feet of medical offices on Parcel B.

PREPARED FOR: City of Los Angeles Department of City Planning

Environmental Review Section 200 North Spring Street, Room 750

Los Angeles, California 90012

APPLICANT:Westside Medical Park, LLC

PREPARED BY: Christopher A. Joseph & Associates

October 6, 2009

BUNDY VILLAGE AND MEDICAL PARK

FINAL ENVIRONMENTAL IMPACT REPORT

PREPARED FOR: The City of Los Angeles

Department of City Planning Environmental Review Unit

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

APPLICANT:Westside Medical Park, LLC

1801 Century Park East, 23rd Floor Los Angeles, CA 90067

PREPARED BY: Christopher A. Joseph & Associates

523 W. 6th Street, Suite 1134 Los Angeles, CA 90014

October 6, 2009

This document is prepared on paper with 30% recycled content.

Bundy Village and Medical Park Table of Contents Final Environmental Impact Report Page i

TABLE OF CONTENTS

Page

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

A. Summary of the Proposed Project.............................................................................I-1

B. Environmental Review Process ................................................................................I-2

C. Organization of the Final EIR...................................................................................I-2

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

A. State Agencies......................................................................................................... II-1

B. Regional Agencies .................................................................................................. II-1

C. City Agencies and Organizations............................................................................ II-1

D. Individuals and Businesses ..................................................................................... II-2

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

A. Introduction............................................................................................................ III-1

B. Responses to Agency Comments........................................................................... III-2

C. Responses to Public Comments ........................................................................... III-72

IV. CORRECTIONS AND ADDITIONS ........................................................................... IV-1

A. Introduction............................................................................................................ IV-1

B. Corrections and Additions to the Draft EIR .......................................................... IV-1

V. MITIGATION MONITORING PROGRAM................................................................. V-1

APPENDICES

Appendix A: Comment Letters

Appendix B: Supplemental Traffic Data

Appendix C: Revised Air Quality Calculations

Bundy Village and Medical Park Table of Contents Final Environmental Impact Report Page ii

LIST OF FIGURES AND TABLES

Page

Figures

Figure IV.K-10 Driveway Trip AM Peak Hour .................................................................... IV-13

Figure IV.K-11 Driveway Trip PM Peak Hour ..................................................................... IV-14

Tables

Table III-1 Critical Movement Analysis Summary Existing (2006) vs. Existing (2007) Conditions ........................................................................................ III-39

Bundy Village and Medical Park I. Introduction Final Environmental Impact Report Page I-1

I. INTRODUCTION

A. SUMMARY OF THE PROPOSED PROJECT

The proposed project involves the development of a mixed-use retail/commercial and residential project with associated parking on Parcel A, which fronts Bundy Drive, and medical offices and associated parking on Parcel B, which fronts Olympic Boulevard.

Parcel A (5.6 acres) would include the development of approximately 385 dwelling units (comprised of approximately 146 market-rate senior units, 62 affordable senior units, and 177 market-rate units), and approximately 119,838 square feet of retail/commercial space (including approximately 9,500 square feet of restaurant space). The ground floor is intended for neighborhood-serving retail uses, such as markets, shops, and restaurants. Overall, a total of 3,276 parking spaces would be provided throughout the project site. Parcel A would provide 1,419 parking spaces in one to two levels of subterranean parking, which would include one subterranean level throughout Parcel A and two subterranean levels in only a portion of Parcel A. Of the 1,419 parking spaces, approximately 737 parking spaces would be provided for the proposed residences and approximately 682 parking spaces would be provided for the proposed retail and restaurant uses. Access to Parcel A would be provided from two driveways along Bundy Drive.

Parcel B (5.9 acres) would include approximately 384,735 square feet of medical offices, including approximately 1,857 parking spaces (with the capacity for 1,976 spaces with valet parking). Parking would be provided in a five-level (plus rooftop parking) parking structure. Access to Parcel B would be primarily provided from Olympic Boulevard, near the Centinela Avenue intersection.

Overall, approximately 40 percent of the project site would be dedicated to open space and landscaped areas. Landscaping and open space would be located throughout the project site, including areas between the proposed buildings, along the internal roadways and walkways, external roadway frontages, and residential rooftop gardens. Parcel A would feature a landscaped promenade between Buildings A and B; Building C would have a landscaped plaza fronting the promenade as well as a landscaped outdoor courtyard area adjacent to the proposed restaurant. Landscaping in Parcel B would feature expanses of grass and vegetation interspersed with walking and sitting areas. Pedestrians would access the entire project site via promenades and landscaped open spaces that foster a safe walking experience.

The project Applicant is requesting the following discretionary approvals as part of the proposed project: Zone Change on Parcel A from M2-1 to RAS3-1 (Residential/Accessory) to authorize residential use; General Plan Amendment for Parcel A to change the land use designation from Light Industrial to General Commercial; Conditional Use Permit for Parcel B to authorize medical office development in excess of 100,000 square feet in an M2-1 zone; Vesting Tentative Tract Map for subdivision and condominium purposes; Site Plan Review findings; Haul Route approval; and any additional actions as may be determined necessary to implement the project.

City of Los Angeles October 2009


B. ENVIRONMENTAL REVIEW PROCESS

The proposed project was reviewed by the Los Angeles Department of City Planning (the “Planning Department”), Environmental Review Unit, which determined that the proposed project required the preparation of an Environmental Impact Report (EIR).

Comments from identified responsible and trustee agencies, as well as from interested parties regarding the scope of the Draft EIR, were solicited through a Notice of Preparation (NOP) process. The NOP for the Draft EIR was circulated for a 30-day review period starting on November 20, 2006 and ending on December 20, 2006. Refer to Appendix A to the Draft EIR for a copy of the NOP as well as written comments submitted to the Planning Department in response to the NOP. All NOP comments relating to the EIR were reviewed and the issues raised in those comments were addressed, to the extent feasible, in the Draft EIR.

On April 30, 2009, the City released the Draft EIR for public comment. The comment period was 45 calendar days, ending on June 15, 2009, which is the length of the public comment period required under California Environmental Quality Act (CEQA).

Before approving a project, the 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 State CEQA 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 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.

C. ORGANIZATION OF THE FINAL EIR

This document, together with the Draft EIR for the proposed project and the Technical Appendices to the Draft EIR, constitute the “Final EIR” for the proposed project. The Draft EIR consisted of the following:



� The Draft EIR, which included the environmental analysis for the proposed project; and

� Technical Appendices, which included:

o Appendix A: Notice of Preparation and Responses to the NOP

o Appendix B: Historic Resources Report

o Appendix C: Air Quality Calculation Worksheets

o Appendix D: Geotechnical Report

o Appendix E, Part 1: Phase I Environmental Site Assessment

o Appendix E, Part 2: Phase II Site Investigation

o Appendix E, Part 3: Phase II Addendum

o Appendix E, Part 4: Remedial Action Plan

o Appendix E, Part 5: System Progress Report

o Appendix E, Part 6: Asbestos Operations and Maintenance Program

o Appendix E, Part 7: Asbestos Sampling Report

o Appendix E, Part 8: Asbestos Survey Report

o Appendix E, Part 9: Lead Survey Report

o Appendix E, Part 10: RWQCB Soils Letter

o Appendix F: Noise Calculation Worksheets

o Appendix G: Letters from Public Service and Utility Agencies

o Appendix H: Traffic Impact Analysis Report

This Final EIR is organized in the following sections:

I. Introduction

This section is intended to provide a brief overview of the proposed project description, CEQA requirements, and EIR history for the proposed project.



II. List of Commenters

This section includes a list of public agencies and private individuals who submitted comments on the Draft EIR.

III. Responses to Comments

This section includes detailed responses to the comment letters submitted to the City in response to the Draft EIR. Copies of the original comments letters are included in Appendix A to this Final EIR.

IV. Corrections and Additions

This section provides a complete overview of the corrections and additions that have been incorporated into the Draft EIR in response to the comments submitted during the public review period.

V. Mitigation Monitoring Program

This section includes a list of the required mitigation measures and includes detailed information with respect to the City’s policies and procedures for implementation of the recommended mitigation measures. This Mitigation Monitoring Program (MMP) identifies the monitoring phase, the enforcement phase and the applicable department or agency responsible for ensuring that each recommended mitigation measure is implemented.

Technical Appendices to the Final EIR

Appendix A: Comment Letters

Appendix B: Supplemental Traffic Data

Appendix C: Revised Air Quality Calculations

Bundy Village and Medical Park II. List of Commenters Final Environmental Impact Report Page II-1

II. LIST OF COMMENTERS

The following agencies, organizations, and individuals provided written comments on the Draft EIR to the Los Angeles Department of City Planning during the formal 45-day public review period from April 30, 2009 through June 15, 2009:

A. STATE AGENCIES

1. Elmer Alvarez, IGR/CEQA Program Manager State of California Department of Transportation District 7, Office of Public Transportation and Regional Planning 100 South Main Street Los Angeles, CA 90012

2. Terry Roberts State of California Governor’s Office of Planning and Research State Clearinghouse and Planning Unit 1400 10th Street, P.O. Box 3044 Sacramento, CA 95812-3044

3. Dave Singleton, Program Analyst State of California Native American Heritage Commission 915 Capitol Mall, Room 364 Sacramento, CA 95814

B. REGIONAL AGENCIES

4. Jacob Lieb, Manager, Assessment, Housing & EIR Southern California Association of Governments

818 West Seventh Street, 12th Floor Los Angeles, CA 90017

C. CITY AGENCIES AND ORGANIZATIONS

5. Brent Lorscheider, Division Manager City of Los Angeles Bureau of Sanitation Wastewater Engineering Services Division City of Los Angeles 2714 Media Center Drive Los Angeles, CA 90065

6. Eileen Fogarty, Director City of Santa Monica Department of Planning & Community Development 1685 Main Street, Room 212



Santa Monica, CA 90401

7. Rob Kadota, Chair Mar Vista Community Council Board of Directors P.O Box 66871

Mar Vista, CA 90066

8. Tim Dagodag, Chairman West Los Angeles Neighborhood Council Planning and Land Use Management Committee 1645 Corinth Avenue, Suite 201 Los Angeles, CA 90025

D. INDIVIDUALS AND BUSINESSES

9. Ellen Carol DuBois [No Address Provided]

10. Lisa R. Rafferty, Vice President Legal Affairs Fox Television Stations, Inc.1999 South Bundy Drive Los Angeles, CA 90025

11. Aric Gregson and Xochitl Gonzalez 1726 Amherst Avenue Los Angeles, CA 90025

12. John T. Fucci Senior Vice President, Asset Management Kilroy Realty Corporation 12200 W. Olympic Boulevard, Suite 200 Los Angeles, CA 90064

13. Dana R. Martin Martin Cadillac12101 West Olympic Boulevard Los Angeles, CA 90064

14. Tom Meyer 1560 S. Carmelina Ave. Los Angeles, CA 90025

15. Fred Salenger, Trustee Salenger Family Trust 4245 Clear Valley Drive Encino, CA 91436



16. John Hubacher Board of Directors Siddha Yoga Meditation Center of Los Angeles 1845 S. Bundy Avenue Los Angeles, CA 90025

17. Nancy Tominaga 1740 Amherst Ave. Los Angeles, CA 90025

Chester J. Fukai1744 Amherst Ave. Los Angeles, CA 90025

Bill and Molly Takahashi 1745 Amherst Ave. Los Angeles, CA 90025

Jeffery Levin and Bonnie Powers 1749 Amherst Ave. Los Angeles, CA 90025

Shinobu Shimomaye 1750 Amherst Ave. Los Angeles, CA 90025

Adelaida and Frank Macias 1755 Amherst Ave. Los Angeles, CA 90025

Keizo and Jane Suyenaga 1756 Amherst Ave. Los Angeles, CA 90025

Steve J. Stevens1757 Amherst Ave. Los Angeles, CA 90025

Aiko and John Tsuboi 1758 Amherst Ave. Los Angeles, CA 90025

18. John Williams 1629 Amherst Ave. Los Angeles, CA 90025

Bundy Village and Medical Park 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 the public review period. All the comment letters are included in Appendix A to this document and are arranged by (1) responses to State, regional, and city agencies (in order of jurisdictional hierarchy and alphabetical order) and (2) responses to public (alphabetical order). Each letter is identified by a number and each comment is delineated and numbered. The text of the individual comments is included below and is followed by a response to the comments. Corrections and additions resulting from comments on the Draft EIR are presented in Section IV, Corrections and Additions. A comprehensive list of comment letters is provided in Section II, List of Commenters.



B. RESPONSES TO AGENCY COMMENTS

COMMENT LETTER NO. 1

Elmer Alvarez IGR/CEQA Program Manager Office of Regional Planning Department of Transportation District 7, Office of Public Transportation and Regional Planning IGR/CEQA Branch 100 South Main Street Los Angeles, CA 90012

Comment No. 1-1

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the Draft Environmental Impact Report (DEIR) for the Bundy Village and Medical Park Project. The proposed project would include the development of 119, 838 sq. ft. of retail/commercial uses including a 9,500 sq. ft. restaurant, 385 residential units and 384,735 sq. ft. of medical office uses. The proposed project would generate approximately 20,073 net new daily trips including approximately 833 new AM peak hour trips and 1879 PM peak hour trips. Based on the information received, we have the following comments:

Response to Comment No. 1-1

This comment addresses the land uses and resulting daily trips associated with the proposed project, as discussed in the Draft EIR. As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.

Comment No. 1-2

Preliminary Mitigation Package (for State Highways)

K-4: Santa Monica Boulevard and Bundy Drive

Restripe the eastbound approach of the intersection to install an exclusive right-turn only lane on Santa Monica Boulevard. Additionally, install new North-South left-turn phasing at this intersection to allow for more capacity for these left turn moves. Additionally, contribute to the installation of a new ATSAC traffic monitoring camera at this location.

Since Santa Monica Boulevard (State Route 2) is still a State Highway at this location and has not yet been relinquished to the City, this measure would require a Caltrans Encroachment Permit.




The Applicant will be required to coordinate with and process any required approvals for proposed improvements to State and Local Highways through the appropriate agencies as a condition of approval. As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.

Comment No. 1-3

K-5: Santa Monica Boulevard and Barrington Avenue

It is recommended that the project install new North-South left-turn signal phasing protected/permissive at this intersection to improve the operating capacity of the Barrington Avenue approaches.

Since Santa Monica Boulevard (State Route 2) is still a State Highway at this location and has not yet been relinquished to the City, this measure would require a Caltrans Encroachment Permit.


The Applicant will be required to coordinate with and process any required approvals for proposed improvements to State and Local Highways through the appropriate agencies as a condition of approval. As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.

Comment No. 1-4

K-12: Centinela Avenue and I-10 Westbound on/off-ramps

Reduce the existing sidewalk width on the north/east of Centinela Avenue to eight feet and widen the roadway north of the freeway ramps to install a second southbound through lane in addition to the existing single southbound through lane and right-turn only lane onto the I-10 Westbound on-ramp. Modify the signal operations and equipment and restripe both the freeway off-ramp and the south leg of the intersection as necessary to accommodate the improvement.

A Caltrans Encroachment Permit will be needed for this measure. A traffic study along with engineering plans, lane-striping plans, turn movements, and signal modifications will be needed for Caltrans review and approval.


The Applicant will be required to coordinate with and process any required approvals for proposed improvements to State and Local Highways through the appropriate agencies as a condition of approval. For roadway improvements involving substantial physical and/or signal improvements, Caltrans typically requires, in addition to the Traffic Impact Analysis Report (the “project traffic study”) (Appendix H to the



Draft EIR), preparation of a separate Project Study Report (PSR) and/or Project Engineering Evaluation Report (PEER), which supplements the project traffic study with additional improvement-specific analyses and detailed engineering drawings of the proposed improvements, along with evaluation of one or more potential alternative measures. The project Applicant has already contacted Caltrans senior staff regarding several of the Caltrans-related mitigation measures proposed in the Draft EIR, and will continue to coordinate with all appropriate agencies in the design, approval, and implementation of the recommended improvements. As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.

Comment No. 1-5

K-14: Pico Boulevard and Bundy Drive

Restripe the southbound approach of Bundy Drive at Pico Boulevard to convert the existing right-turn only lane to a shared through/right turn lane. Additionally, widen the west side of Bundy Drive south of Pico Boulevard between Pico Boulevard and the I-10 westbound-to-southbound Bundy Drive off-ramp to provide an additional southbound receiving lane with the innermost lane striped and signed as a trapped lane for the new dual left-turn lane at the eastbound on-ramps. This improvement is part of the comprehensive improvement of the Bundy Drive/I-10 westbound off-ramp and eastbound on-ramp interchange.

Caltrans does not agree with the proposed comprehensive improvement of the Bundy Drive/I-10 westbound off-ramp and eastbound on-ramp interchange. We request the lead agency coordinate all proposed improvements with Caltrans.


The project Applicant has already contacted Caltrans senior staff regarding this improvement, and has received preliminary approval of the conceptual designs prior to including this proposal as a project mitigation measure. Preliminary review by Caltrans was also required by the LADOT prior to LADOT approval of the proposed mitigation measures. LADOT staff was also consulted prior to release of the Draft EIR and the project traffic study (Appendix H to the Draft EIR), and preliminary coordination between LADOT and Caltrans staffs regarding the proposed improvement has occurred. The Applicant will be required to coordinate with and process any required approvals for proposed improvements with all appropriate agencies, including Caltrans. Please also refer to Response to Comment 1-4.

Comment No. 1-6

K-15: Bundy Drive and I-10 Westbound Off-ramp

Widen the existing freeway to northbound Bundy Drive off-ramp to provide two lanes after the divergence from the mainline I-10 Freeway flair the ramp terminus at Bundy Drive to provide three lanes including a left turn lane, a center shared left-turn/right-turn lane one right-turn only lane and realign the ramp approach so that it intersects Bundy Drive at an approximately 90-



degree angle. Install a new traffic signal at this location to control the new westbound I-10 freeway off-ramp to both directions of Bundy Drive. This signal shall be coordinated with the existing signal at the intersections of both Bundy Drive and Pico Boulevard to the north and at Bundy Drive and I-10 Freeway eastbound on-ramp to the south of this location. Additionally, in order to improve traffic flows along northbound Bundy Drive and reduce the existing conflict with merging off-ramp traffic, right-turn on red movements should be prohibited. Remove the existing westbound I-10 freeway-to-southbound Bundy Drive loop ramp allowing the widening along the west side of Bundy Drive. LADOT has indicated that this measure is conceptually acceptable but will require Caltrans approval.

We concur that comprehensive improvements are needed at this interchange, however, other mitigation alternatives need to be considered. As described, the current improvements do not appear to benefit freeway or ramp operations, therefore, Caltrans does not agree with them. Further analysis is needed such as synchro or micro-simulation to determine appropriate improvements. We request the lead agency coordinate all proposed improvements with Caltrans.


Please refer to Responses to Comments 1-4 and 1-5. With respect to the commenter’s request for synchro or micro-simulation, such additional analyses would typically be performed as needed as part of the preparation of the PSR and PEER reports for the Caltrans improvements (as described in Response to Comment 1-4).

Comment No. 1-7

K-16: Bundy Drive and I-10 Eastbound On-ramp

Restripe Bundy Drive south of Pico Boulevard to provide dual southbound left-turn lanes onto the I-10 eastbound on-ramp. In addition to the existing two through lanes in that direction, the innermost through lane on southbound Bundy Drive will become a dedicated lane for the outermost of the dual left-turn lanes. The second inner left-turn lane should begin at the south

Side of the new westbound I-10 off-ramp described above. Additionally, the on-ramp should be widened if possible to provide an additional lane preserving the existing high occupancy vehicle (HOV) bypass lane and increasing the storage capacity of the ramp to minimize potential vehicle queue spillover onto Bundy Drive. This spillover is a primary cause of the current congestion experienced at the intersection of Pico Boulevard and Bundy Drive as ramp-bound traffic cannot access the ramp and the southbound Bundy Drive left turn queue exceed the pocket length and block southbound Bundy Drive through traffic. As with the other associated Bundy Drive/I-10 Freeway ramp improvements described previously, LADOT has indicated that this measure is conceptually acceptable although final review and approval under Caltrans jurisdiction due to the proposed widening of the freeway on-ramp.



Since Caltrans does not agree with the proposed comprehensive improvement of the Bundy Drive/I-10 westbound off-ramp and eastbound on-ramp interchange improvements, this measure likewise may not be acceptable.


Please refer to Responses to Comments 1-4 and 1-5.

Comment No. 1-8

K-19: Centinela Avenue and I-10 Eastbound On-ramp

Widen both sides of Centinela Avenue both north and south of on-ramp as necessary to install a second southbound left-turn lane onto the on-ramp. Modify and/or replace the existing traffic signal equipment as necessary to accommodate the proposed improvement.

A Caltrans Encroachment Permit will be needed for this measure. A traffic study along with engineering plans, lane-striping plans, turn movements, and signal modifications will be needed for Caltrans review and approval.


Please refer to Response to Comment 1-4.

Comment No. 1-9

K-25: Restripe Lincoln Boulevard to the north such that a right-turn only lane is established.

Since Lincoln Boulevard (State Route 1) is a State Highway, a Caltrans Encroachment Permit will be needed for this measure.



Comment No. 1-10

Cumulative Traffic Impacts

The cumulative effects of the project along with all other proposed projects in the area have the potential to have a significant impact on the State Transportation System. Both the I-10 and I-405 freeways operate at poor conditions during peak commute periods which last for several hours each weekday. The project is projected to add over 150 trips on I-10 and over 100 to I-405. The 58 related projects listed add up to a total of 5654 AM peak hour trips and 8443 PM peak hour trips. Thus, the project's cumulative impacts have the potential to be considerable.




Project impacts to the area freeway system were evaluated in detail in the Draft EIR (Section IV.K, Traffic and Transportation), which included cumulative effects as part of the future baseline, and no significant impacts were identified. This comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 1-11

Page 109 states that the CMP defines project impacts as significant if the demand-to-capacity ratio increases by 0.020 or more, and the final, "With Project" level of service is LOS "F" or worse. Then it claims by referring to Table 18, the incremental project traffic volumes on the freeway segments will not produce any significant impacts to any of the I-10 or I-405 segments analyzed and no project-specific freeway impact mitigation measures are warranted.

However, CEQA guidelines (article 5, section l5064h), states that cumulative effects also need to be considered. Given that project trips would be added to already deficient operating conditions and potentially resulting in extending duration of peak period congestion on I-10 and I-405, the incremental effect of the project, combined with the effects of other past, present and reasonably foreseeable future projects, would be cumulatively considerable. Since it appears that cumulative transportation impacts are likely, appropriate mitigation measures should be considered such as contributions to a traffic impact fee program, specifically the West Los Angeles Transportation Improvement and Mitigation Specific Plan (WLA-TIMP). Other mitigation alternatives may include fair-share contributions towards pre-established or future improvements on I-10 and I-405 freeways. We understand that the project will contribute towards the improvements at the I-10/Bundy Drive interchange. The project's cumulative effects may be less than cumulatively considerable if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative effects.


The analyses contained in the project traffic study (Appendix H to the Draft EIR) and summarized in Section IV.K (Traffic and Transportation) of the Draft EIR (see Pages IV.K-119 through IV.K-125 in the Draft EIR) include the effects of cumulative traffic increases on the selected freeway study segments, and follows the appropriate analysis procedures to evaluate project-related impacts as identified in the current CMP document. The analyses were conducted in accordance with the CMP, and the results of the analyses indicate that the project’s incremental cumulative effect would be less-than-significant impacts to area freeways.

As discussed in Section IV.K (Traffic and Transportation) of the Draft EIR, of the 40 impacted study intersections, 12 of these locations exhibit no acceptable physical mitigation per LADOT’s review of the preliminary proposals. Therefore, only 28 of the impacted locations are proposed to receive any physical



and/or traffic signal improvements as part of the project’s mitigation package. Table IV.K-18, Critical Movement Analysis Summary: Study Intersections Future (2011) Plus Physical/Traffic Signal Mitigation Conditions, indicates that with implementation of the recommended physical and/or signal improvements, the project’s potential traffic impacts at 19 of the impacted intersections would be reduced to less-than-significant levels. As noted by the commenter and described in the Draft EIR, mitigation measures associated with the proposed project include regionally-significant improvements to the area freeways, which are intended to address both project-specific and cumulative traffic impacts, including payment of nearly $5,000,000 in WLA TIMP fees, plus an additional developer contribution of $2,200,000 toward regional and local transportation improvements identified by the LADOT in the area. Further, the project proposes to implement a project-specific Transportation Demand Management (TDM) program to reduce project-related traffic, as well as spearhead the formation of an area-wide Transportation Management Organization (TMO) program, intended to coordinate and consolidate traffic reduction programs for nearby developments in order to encourage increased transit, carpool/rideshare, and alternative transportation usage throughout the immediate project area to further reduce both local and regional traffic. Please also refer to Responses to Comments 1-4 and 1-5.

Comment No. 1-12

Construction Traffic

To minimize any potential demolition, excavation and construction traffic impacts, we recommend that construction related truck trips on State highways be limited to off-peak commute periods.


This comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Nonetheless, as discussed on Pages IV.K-29 and IV.K-125 in the Draft EIR, construction materials transport, and demolition and excavation/import hauling would occur typically over an approximately seven-hour work day, beginning at 9:00 AM and ending at 4:00 PM and, therefore, limited to off-peak commute periods. These hours are consistent with the Mayor’s directive to limit construction traffic impacts to non-peak travel periods of the day.

Comment No. 1-13

The contractor should also avoid platooning of truck trips on mainline freeways, on freeway on/off-ramps and at freeway ramp intersections.




The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Nonetheless, the operations of the project’s construction traffic, including demolition material and soil haul trucks, are not expected to produce vehicle platoons. Such vehicles would generally stage on-site, and would depart the project site individually as they are filled, and return to the site following their trip to the designated landfill or other haul material destination location. Such vehicles typically require several minutes to fill and, as such, haul vehicle departures are anticipated to occur at various intervals throughout the construction phases of the proposed project. No significant haul vehicle platooning is expected.

Comment No. 1-14

Transport of over-size or over-weight vehicles On State highways will need a Caltrans Transportation Permit.

If you have any questions, you may reach me at (213) 897-6696 and please refer to our record number 090502/CS.


It is anticipated that most of the construction-related vehicles would not require over-weight or over-size permits. However, if such vehicles are required during the project construction, the project contractors would be required to obtain all applicable permits from the necessary agencies.




Terry Roberts Director, State Clearinghouse State of California Governor’s Office of Planning and Research State Clearinghouse and Planning Unit 1400 10th Street P.O. Box 3044 Sacramento, California 95812-3044

Comment No. 2-1

The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on June 15, 2009, and the comments from the responding agency (ies) is (are) enclosed. If this comment package is not in order, please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly.

Please note that Section 211 04(c) of the California Public Resources Code states that:

“A responsible or other public agency shall only make substantive comments regarding those activities involved in a project which are within an area of expertise of the agency or which are required to be carried out or approved by the agency. Those comments shall be supported by specific documentation.”

These comments are forwarded for use in preparing your final environmental document. Should you need more information or clarification of the enclosed comments, we recommend that you contact the commenting agency directly.

This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process.


The comment acknowledges that the lead agency has satisfied CEQA requirements with respect to distributing the Draft EIR to State agencies for a 45-day public review period. The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.




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

Comment No. 3-1

The Native American Heritage Commission (NAHC) is the state ‘trustee agency' pursuant to Public Resources Code §21070 designated to protect California's Native American Cultural Resources. The California Environmental Quality Act (CEQA) requires that any project that causes a substantial adverse change in the significance of an historical resource, that includes archaeological resources, is a ‘significant effect’ requiring the preparation of an Environmental Impact Report (EIR) per the California Code of Regulations §15064.5(b)(c)(f) CEQA guidelines). Section 15382 of the 2007 CEQA Guidelines defines a significant impact on the environment as "a substantial, or potentially substantial, adverse change in any of physical conditions within an area affected by the proposed project including ... objects of historic or aesthetic significance." In order to comply with this provision, the lead agency is required to assess whether the project will have an adverse impact on these resources within the 'area of potential effect (APE)', and if so, to mitigate that effect. To adequately assess the project-related impacts on historical resources, the Commission recommends the following action:

� Contact the appropriate California Historic Resources Information Center (CHRIS) for possible 'recorded sites' in locations where the development will or might occur.. Contact information for the Information Center nearest you is available from the State Office of Historic Preservation (916/653-7278)/ http://www.ohp.parks.ca.gov. The record search will determine:

� If a part or the entire APE has been previously surveyed for cultural resources.

� If any known cultural resources have already been recorded in or adjacent to the APE.

� If the probability is low, moderate, or high that cultural resources are located in the APE.

� If a survey is required to determine whether previously unrecorded cultural resources are present.


The recommended action has already been completed. The Olympic and Bundy Historic Resource Report, included as Appendix B to the Draft EIR, addresses the proposed project’s potential impacts to cultural resources. As discussed on page 1 of this report, none of the potential historic resources on the project site were included in the California Historical Resources Information System (CHRIS). See also Pages IV.A-4 through IV.A-6 in the Draft EIR for additional discussion and analysis.



Comment No. 3-2

� If an archaeological inventory survey is required, the final stage is the preparation of a professional report detailing the findings and recommendations of the records search and field survey.

� The final report containing site forms, site significance, and mitigation measurers should be submitted immediately to the planning department. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum, and not be made available for pubic disclosure.

� The final written report should be submitted within 3 months after work has been completed to the appropriate regional archaeological Information Center.


The Draft EIR addresses potential impacts to archaeological resources of the proposed project on Pages IV.A-4 through IV.A-5. As discussed therein, an archaeological records search was conducted by the South Central Coastal Information Center at California State University, Fullerton and no archaeological resources have been identified on the project site, or within a one-half mile radius of the project site. Furthermore, Mitigation Measure A-1 was included in the Draft EIR to ensure that potential impacts associated with any unknown archaeological resources, if found during excavation activities, are less than significant. Mitigation Measure A-1 includes the engagement of an archaeologist to ensure that any archaeological resources that are found are dealt with in accordance with all applicable laws and guidelines. The Department of City Planning would serve as the monitoring agency for Mitigation Measure A-1 (see Section V, Mitigation Monitoring Program, of this Final EIR) and, as such, would be informed of any archaeological discoveries and subsequent archaeological reports.

Comment No. 3-3

� The Native American Heritage Commission (NAHC) performed:

* A Sacred Lands File (SLF) search of the project 'area of potential effect (APE)'; The results; Noknown Native American Cultural Resources were identified within one-half mile of the 'area of potential effect (APE); However, there are Native American cultural resources in close proximity to the APE. The NAHC urges caution with any ground-breaking activity. Also, the NAHC SLF is not exhaustive and local tribal contacts should be consulted from the attached list and the there are Native American cultural resources in close proximity.

� The NAHC advises the use of Native American Monitors; also, when professional archaeologists or the equivalent are employed by project proponents, in order to ensure proper identification and care given cultural resources that may be discovered. The NAHC, FURTHER, recommends that contact be made with Native American Contacts on the attached list to get their input on potential IMPACT of the project (APE) on cultural resources.. In some cases, the existence of a Native American cultural resources may be known only to a local tribe(s) or Native American individuals or elders.




The first part of this comment reiterates the conclusion in the Draft EIR that the proposed project’s impact on cultural resources would be less than significant. As this comment is consistent with the discussion in the Draft EIR, no further response is required.

The second part of this comment recommends that a Native American monitor be used when professional archeologists are employed and that Native American contacts be informed of the proposed project. All persons listed on the Native American Contacts list provided by the NAHC were notified of the proposed project. Furthermore, as stated in Mitigation Measures A-1 through A-3 (see Section V, Mitigation Monitoring Program, in this Final EIR), should any cultural resources be encountered during the course of project development, construction shall be halted, and necessary steps shall be taken to ensure that potential impacts associated with cultural resources are less than significant. Please also refer to Response to Comment 3-2.

Comment No. 3-4

� � Lack of surface evidence of archeological resources does not preclude their subsurface existence.

� Lead agencies should include in their mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, per California Environmental Quality Act (CEQA) §15064.5 (f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground-disturbing activities.

� Again, a culturally-affiliated Native American tribe may be the only source of information about a Sacred Site/Native American cultural resource.

� Lead agencies should include in their mitigation plan provisions for the disposition of recovered artifacts, in consultation with culturally affiliated Native Americans.


Mitigation Measure A-1 on Pages IV.A-4 through IV.A-5 of the Draft EIR (and Section V of this Final EIR) includes the recommendations in this comment regarding the identification and evaluation of any recovered archeological resources. Regarding the discovery of Native American human remains, Mitigation Measure A-3 states that “the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains.”

Comment No. 3-5

� Lead agencies should include provisions for discovery of Native American human remains or unmarked cemeteries in their mitigation plans.



* CEQA Guidelines, Section 15064.5(d) requires the lead agency to work with the Native Americans identified by this Commission if the initial Study identifies the presence or likely presence of Native American human remains within the APE. CEQA Guidelines provide for agreements with Native American, identified by the NAHC, to assure the appropriate and dignified treatment of Native American human remains and any associated grave liens.


As discussed on Pages IV.A-5 through IV.A-6 of the Draft EIR, it is not expected that any human remains are present on the project site because the site has been previously developed and the underlying soil has been previously disturbed. Nonetheless, Mitigation Measure A-3 is recommended in the event that previously unknown human remains are discovered during construction activities (see Section V, Mitigation Monitoring Program, in this Final EIR). As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.

Comment No. 3-6

� Health and Safety Code §7050.5, Public Resources Code §5097.98 and Sec. §15064.5 (d) of the California Code of Regulations (CEQA Guidelines) mandate procedures to be followed, including that construction or excavation be stopped in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery until the county coroner or medical examiner can determine whether the remains are those of a Native American. Note that §7052 of the Health & Safety Code states that disturbance of Native American cemeteries is a felony.



Comment No. 3-7

� Lead agencies should consider avoidance as defined in §15370 of the California Code of Regulations (CEQA Guidelines), when significant cultural resources are discovered during the course of project planning and implementation


The Draft EIR addresses the proposed project’s potential impacts to cultural resources on Pages IV.A-4 through IV.A-6. As discussed therein, it is not expected that any archeological, paleontological, or cultural resources are present on the project site. However, Mitigation Measures A-1 through A-3 state that should any previously unknown cultural resources be encountered during the course of project development, construction shall be halted, and necessary steps shall be taken to ensure that potential impacts associated with cultural resources are less than significant (see Section V, Mitigation Monitoring Program, in this Final EIR). As this comment does not state a concern or question regarding the adequacy of the analysis in the Draft EIR, no further response is required.




Jacob Lieb, Manager Assessment, Housing & EIR Southern California Association of Governments 818 West Seventh Street, 12th Floor Los Angeles, California 90017-3435

Comment No. 4-1

Thank you for submitting the Draft Environmental Impact Report for Bundy Village and Medical Park [SCAG No. 120090219] to the Southern California Association of Governments (SCAG) for review and comment. SCAG is the authorized regional agency for Inter-Governmental Review of Programs proposed for federal financial assistance and direct development activities, pursuant to Presidential Executive Order 12372 (replacing A-95 Review). Additionally, pursuant to Public Resources Code Section 21083(d) SCAG reviews Environmental Impacts Reports of projects of regional significance for consistency with regional plans per the California Environmental Quality Act Guidelines, Sections 15125(d) and 15206(a)(1). SCAG is also the designated Regional Transportation Planning Agency and as such is responsible for both preparation of the Regional Transportation Plan (RTP) and Regional Transportation Improvement Program (RTIP) under California Government Code Section 65080 and 65082. As the clearinghouse for regionally significant projects per Executive Order 12372, SCAG reviews the consistency of local plans, projects, and programs with regional plans. This activity is based on SCAG's responsibilities as a regional planning organization pursuant to state and federal laws and regulations. Guidance provided by these reviews is intended to assist local agencies and project sponsors to take actions that contribute to the attainment of regional goals and policies.

SCAG staff has reviewed this project and determined that the proposed project is regionally significant per California Environmental Quality Act (CEQA) Guidelines, Sections 15125 and/or 15206. The proposed project, located on approximately 12 acres, would consist of approximately 385 residential units, approximately 120,000 square feet of retail/commercial space, and approximately 385,000 square feet of medical office space.

We have evaluated this project based on the policies of SCAG's Regional Transportation Plan (RTP) and Compass Growth Vision (CGV) that may be applicable to your project. The RTP and CGV can be found on the SCAG web site at: http://scag.ca.gov/igr. The attached detailed comments are meant to provide guidance for considering the proposed project within the context of our regional goals and policies. We also encourage the use of the SCAG List of Mitigation Measures extracted from the RTP to aid with demonstrating consistency with regional plans and policies. Please provide a copy of the Final Environmental Impact Report (FEIR) for our review. If you have any questions regarding the attached comments, please contact Bernard Lee at (213) 236-1800. Thank you.




This comment indicates that the proposed project is considered to be regionally significant per the Southern California Association of Governments’ (SCAG) Intergovernmental Review Criteria and State CEQA Guidelines. Regarding SCAG’s Regional Transportation Plan (RTP), please refer to Responses to Comments 4-3 and 4-4. Regarding SCAG’s Compass Growth Vision, please refer to Responses to Comments 4-5 through 4-8.

In addition, this comment requests that a copy of the Final EIR be provided to SCAG. SCAG has received a copy of the Draft EIR and will be provided a copy of the Final EIR, as requested. The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a further response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 4-2

PROJECT LOCATION

The 11.55 acre project site is located in the West Los Angeles area of the City of Los Angeles. It is located approximately one mile west of Interstate 405 and one-half mile north of Interstate 10. The project site's addresses are 1901, 1925,1933 South Bundy Drive, Los Angeles, CA 90025; and 12333 West Olympic Boulevard, Los Angeles, CA 90064.

PROJECT DESCRIPTION

The proposed project has two components: a mixed-use residential and retail development with associated parking on Parcel A, which fronts Bundy Drive, and medical offices with associated parking on Parcel B, which fronts Olympic Boulevard.

� Parcel A would include the development of approximately 385 dwelling units (comprised of approximately 146 market-rate units for seniors, 62 affordable (moderate income) units for seniors, and 177 unrestricted market-rate units), and approximately 119,838 square feet of retail/commercial space (including approximately 9,500 square feet of restaurant space). Approximately 737 parking spaces would be provided for the proposed residences and approximately 682 parking spaces would be provided for the proposed retail/commercial component for a total of1 ,419 spaces for Parcel A land uses. Two access points would be provided from Bundy Drive, one near the Missouri Avenue intersection and the other towards La Grange Avenue.

� Parcel B would include approximately 384,735 square feet of medical offices including approximately 1,857 parking spaces. Access to this parcel would be provided from Olympic Boulevard near Centinela Avenue.



The project site is developed with four structures and a surface parking area. The existing structures include a 166,283-square-foot office, manufacturing, and distribution facility and three single-story office buildings that occupy approximately 30,000, 20,000, and 34,000 square feet.

The surrounding land uses are generally commercial in nature. A City of Los Angeles Department of Water and Power facility is west of the project site. North of the project site along Bundy Drive sits a vacant building as well as recreational and commercial facilities. Northeast of the project site are multifamily residences, a fitness facility, and commercial buildings. An office building and car dealership are south of the project site. Single-family residences are northwest of the project site.

The following summarizes discretionary actions and permits being sought by the project from the City of Los Angeles and/or other agencies:

� Zone Change on Parcel A from M2-1 to RAS3-1 (Residential/Accessory) to authorize residential use;

� General Plan Amendment for Parcel A to change the land use designation from Light Industrial to General Commercial;

� Conditional Use Permit for Parcel B to authorize medical office development in excess of 100,000 square feet in an M2-1 zone;

� Vesting Tentative Tract Map for subdivision and condominium purposes;

� Site Plan Review findings;

� Haul Route approval; and

� Any additional actions that may be determined necessary.


This comment summarizes the project location and project description, as stated in the Draft EIR. The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 4-3

CONSISTENCY WITH REGIONAL TRANSPORTATION PLAN



Regional Growth Forecasts

The Draft Environmental Impact Report (DEIR) should reflect the most current SCAG forecasts, which are the 2008 Regional Transportation Plan (RTP) Population, Household and Employment forecasts (adopted May 2008). The forecasts for your region and subregion/city are as follows:

Adopted SCAG Regionwide Forecasts1

2010 2015 2020 2025 2030 2035

Population 19,418,344 20,465,830 21,468,948 22,395,121 23,255,377 24,057,286

Households 6,086,986 6,474,074 6,840,328 7,156,645 7,449,484 7,710,722

Employment 8,349,453 8,811,406 9,183,029 9,546,773 9,913,376 10,287,125

Adopted City of Los Angeles Subregion Forecasts1

2010 2015 2020 2025 2030 2035

Population 4,140,516 4,214,082 4,292,139 4,367,538 4,440,017 4,509,435

Households 1,386,658 1,445,177 1,506,564 1,554,478 1,600,754 1,638,823

Employment 1,860,672 1,905,337 1,933,860 1,967,393 2,003,196 2,037,472

1. The 2008 RTP growth forecast at the regional, subregional, and city levels was adopted by the Regional Council in May. 2008.

SCAG Staff Comments:

The DEIR does not utilize the 2008 RTP growth forecasts. The Final EIR should incorporate growth forecasts from the 2008 RTP.


This comment states that the Final EIR should incorporate growth forecasts from the 2008 Regional Transportation Plan (RTP). Pursuant to the Section 15125 of the State CEQA Guidelines, the environmental baseline utilized in the Draft EIR is prior to the publication of the 2008 RTP and, therefore, the Draft EIR was not required to include an analysis of the 2008 RTP. Although it is not



required, the 2008 RTP forecasts have been considered in the Final EIR (see Section IV, Corrections and Additions, of this Final EIR). However, while SCAG provides updated information for households contained in the 2008 RTP as part of this comment, no update is provided for the number of housing units. The Draft EIR focuses on the number of housing units rather than households as this is a more accurate indicator of the amount of new housing that may be introduced to the City of Los Angeles Subregion in future years, because households only include occupied housing units rather than all housing units. Therefore, no changes were made to Table IV.I-2 regarding the number of housing units. The changes to Table IV.I-2 (see Section IV of this Final EIR) do not change the Draft EIR analysis or conclusion with respect to this issue.

Comment No. 4-4

The 2008 Regional Transportation Plan (RTP) also has goals and policies that are pertinent to this proposed project. This RTP links the goal of sustaining mobility with the goals of fostering economic development, enhancing the environment, reducing energy consumption, promoting transportation" friendly development patterns, and encouraging fair and equitable access to residents affected by socioeconomic, geographic and commercial limitations. The RTP continues to support all applicable federal and state laws in implementing the proposed project. Among the relevant goals and policies of the RTP are the following:

Regional Transportation Plan Goals:

RTP G1 Maximize mobility and accessibility for all people and goods in the region.

RTP G2 Ensure travel safety and reliability for all people and goods in the region.

RTP G3 Preserve and ensure a sustainable regional transportation system.

RTP G4 Maximize the productivity of our transportation system.

RTP G5 Protect the environment, improve air quality and promote energy efficiency.

RTP G6 Encourage land use and growth patterns that complement our transportation investments.

RTP G7 Maximize the security of our transportation system through improved system monitoring, rapid recovery planning, and coordination with other security agencies.


SCAG staff finds the project meets consistency with RTP G6, partial consistency with RTP G1, and cannot determine consistency with RTP G4 and G5. RTP G2, G3, and G7 are not applicable to this project.

The proposed project meets partial consistency with RTP G1. Mobility pertains to the speed at which one may travel and the delay, or difference between the actual travel time and travel time



that would be experienced if a person traveled at the legal speed limit. Accessibility measures how well the transportation system provides people access to opportunities, such as jobs, education, shopping, recreation, and medical care. Table IV.K-18 (Critical Movement Analysis Summary: Study Intersections Future (2011) Plus Physical/Signal Mitigation Conditions) indicates that several intersections will be below a Level of Service (LOS) D, which is an acceptable LOS for an urban area, after mitigation measures have been applied. With regard to accessibility, the proposed project is located close to both Interstate 405 and Interstate 10, providing regional access. Also, the proposed project is located near employment, retail, and services.

SCAG staff cannot determine consistency with RTP G4. Productivity is a system efficiency measure that reflects the degree to which the transportation system performs during peak demand conditions. As mentioned previously, the proposed project is expected to impair performance at several intersections near the project site.

SCAG staff cannot determine consistency with RTP G5. Per page IV.C-64 in the Air Quality section, "the operational emissions associated with the proposed project would exceed the established SCAQMD threshold levels for ROG, NOx, CO, and PM10 during both the summertime (smog season) and wintertime (non-smog season). This is primarily due to the increase in motor vehicles traveling to and from the project site. As there is no feasible mitigation to reduce emissions from these motor vehicles, this impact would be significant and unavoidable."

The proposed project meets consistency with RTP G6. The project site is located in close proximity to regional transportation infrastructure (Interstates 405 and 10), is served by public transit, and offers local access via major roadways (Olympic Boulevard and Bundy Drive).


SCAG indicates that the proposed project would be consistent with RTP Goal G6 partially consistent with RTP Goal G1, and that the proposed project’s consistency with RTP Goals G4 and G5 cannot be determined. Additionally, SCAG determined that RTP Goals G2, G3, and G7 are not applicable to the proposed project.

The environmental baseline in the Draft EIR is prior to the publication of the 2008 RTP and, therefore, the Draft EIR was not required to include the 2008 RTP. Although it is not required, an analysis of the proposed project’s consistency with the applicable 2008 RTP goals has been added to the Draft EIR (see Section IV, Corrections and Additions, of this Final EIR). As shown therein, the proposed project would be consistent with the applicable 2008 RTP goals, and impacts associated with this issue would be less than significant. This additional information is consistent with the analysis finding in the Draft EIR, which states that the proposed project would not result in a significant impact with respect to consistency with existing land use policies.



Comment No. 4-5

GROWTH VISIONING

The fundamental goal of the Compass Growth Visioning effort is to make the SCAG region a better place to live, work and play for all residents regardless of race, ethnicity or income class. Thus, decisions regarding growth, transportation, land use, and economic development should be made to promote and sustain for future generations the region's mobility, livability and prosperity. The following "Regional Growth Principles" are proposed to provide a framework for local and regional decision making that improves the quality of life for all SCAG residents. Each principle is followed by a specific set of strategies intended to achieve this goal.

Principle 1: Improve mobility for all residents.

GV P1.1 Encourage transportation investments and land use decisions that are mutually supportive.

GV P1.2 Locate new housing near existing jobs and new jobs near existing housing.

GV P1.3 Encourage transit-oriented development.

GV P1.4 Promote a variety of travel choices


The proposed project meets consistency with Growth Visioning Principle 1.

The proposed project meets consistency with GV P1.1. It is located in close proximity to Interstates 405 and 10, which provide regional access, has frontage along Olympic Boulevard and Bundy Drive, which are major roadways in the area, and is served by two bus lines.

The proposed project meets consistency with GV P1.2 as it provides housing in close proximity to nearby employment centers in West Los Angeles and Santa Monica. Also, the project intends to create both housing and employment opportunities on-site.

The proposed project meets consistency with GV P1.3. Per page IV.K-8, the project is served by two bus lines currently. The project site is within walking distance of the potential future Expo Line Phase 2 stop, located along Bundy Drive, south of Olympic Boulevard. Per pages IV.K-132 and IV.K-133, the project applicant intends to contribute an additional $2 million beyond the required West Los Angeles Transportation Improvement and Mitigation Specific Plan fees which may be applied towards transit improvements such as improved bus stops, information kiosks, and wayfinding and connectivity signage.

The proposed project meets consistency with GV P1.4. Per Table IV.C-10 (Project Consistency with Applicable Policies of the General Plan Air Quality Element), Policy 2.1.1, the project



intends to incorporate various modes of transportation in order to get employees, patients, residents, and shoppers to and from the project site.


SCAG indicates that the proposed project would be consistent with the strategies of Compass Growth Vision Principle 1. The environmental baseline in the Draft EIR is prior to the publication of the Compass Growth Vision and, therefore, the Draft EIR was not required to include the Compass Growth Vision. Although it is not required, an analysis of the proposed project’s consistency with the applicable principals of the Compass Growth Vision has been added to the Draft EIR (see Section IV, Corrections and Additions, of this Final EIR). The addition of the information regarding the proposed project’s consistency with the Compass Growth Vision Principle 1 does not constitute a substantial change to the analysis and conclusions of the Draft EIR with respect to consistency with existing land use policies.

Comment No. 4-6

Principle 2: Foster livability in all communities.

GV P2.1 Promote infill development and redevelopment to revitalize existing communities.

GV P2.2 Promote developments, which provide a mix of uses.

GV P2.3 Promote "people scaled," walkable communities.

GV P2.4 Support the preservation of stable, single-family neighborhoods.


Where applicable, the proposed project meets consistency with Growth Visioning Principle 2. GV P2.4 is not applicable since there are no single-family residences on the project site.

The proposed project meets consistency with GV P2.1, since it is an already developed site within West Los Angeles.

The proposed project meets consistency with regard to GV P2.2 and P2.3. Table IV.G-5 (Project Consistency with Applicable West Los Angeles Community Plan Policies), Objective 2-2, discusses the mixed-use and walkable nature of the proposed project.


SCAG indicates that the proposed project would be consistent with the applicable strategies of Compass Growth Principle 2. The environmental baseline in the Draft EIR is prior to the publication of the Compass Growth Vision and, therefore, the Draft EIR was not required to include the Compass Growth Vision. Although it is not required, an analysis of the proposed project’s consistency with the applicable principals of the Compass Growth Vision has been added to the Draft EIR (see Section IV, Corrections and Additions, of this Final EIR). As shown therein, the proposed project would be consistent with



Compass Growth Vision Principle 2. The addition of the information regarding the proposed project’s consistency with the Compass Growth Vision Principle 2 does not constitute a substantial change to the analysis and conclusions of the Draft EIR with respect to consistency with existing land use policies.

Comment No. 4-7

Principle 3: Enable prosperity for all people.

GV P3.1 Provide, in each community, a variety of housing types to meet the housing needs of all income levels.

GV P3.2 Support educational opportunities that promote balanced growth.

GV P3.3 Ensure environmental justice regardless of race, ethnicity or income class.

GV P3.4 Support local and state fiscal policies that encourage balanced growth

GV P3.5 Encourage civic engagement.


Where applicable, the proposed project meets partial consistency with Growth Visioning Principle 3, or SCAG staff is unable to determine. GV P3.2 and 3.5 are not applicable.

With regard to GV P3.1, the proposed project meets partial consistency. The proposed project plans to include a senior housing component that would be affordable to those in the moderate income range. However, it does not appear as if the project will include any housing affordable to lower income households.

SCAG staff is unable to determine whether the proposed project is consistent with GV P3.3 and P3.4, since these topics are not addressed anywhere in the DEIR.


SCAG indicates that the proposed project would be partially consistent with Principle 3 of the Compass Growth Visioning. However, SCAG was unable to determine the proposed project’s consistency with two of the strategies that make up Principle 3. The environmental baseline in the Draft EIR is prior to the publication of the Compass Growth Vision and, therefore, the Draft EIR was not required to include the Compass Growth Vision. Although it is not required, an analysis of the proposed project’s consistency with the applicable principals of the Compass Growth Vision has been added to the Draft EIR (see Section IV, Corrections and Additions, of this Final EIR). As shown therein, the proposed project would be consistent with Compass Growth Vision Principle 3. The addition of the information regarding the proposed project’s consistency with the Compass Growth Vision Principle 3 does not constitute a substantial change to the analysis and conclusions of the Draft EIR with respect to consistency with existing land use policies.



Comment No. 4-8

Principle 4: Promote sustainability for future generations.

GV P4.1 Preserve rural, agricultural, recreational, and environmentally sensitive areas

GV P4.2 Focus development in urban centers and existing cities.

GV P4.3 Develop strategies to accommodate growth that uses resources efficiently, eliminate pollution and significantly reduce waste.

GV P4.4 Utilize "green" development techniques


Where applicable, the project meets consistency with Growth Visioning Principle 4. GV P4.1 does not apply.

As mentioned previously, the proposed project may be characterized as an infill development and therefore meets consistency with GV P4.2.

The proposed project meets consistency with GV P4.3. Table IV.C-12 (Project Consistency with 2006 CAT Report Greenhouse gas Emission Reduction Strategies) discusses the various ways that the proposed project intends to reduce pollution and waste, and to utilize resources more efficiently.

The proposed project meets consistency with GV P4.4. Per page IV.D-7, the proposed project would be in full compliance of the City of Los Angeles Green Building Ordinance.


SCAG has indicated that the proposed project would be consistent with all of the applicable strategies under Principle 4. The environmental baseline in the Draft EIR is prior to the publication of the Compass Growth Vision and, therefore, the Draft EIR was not required to include the Compass Growth Vision. Although it is not required, an analysis of the proposed project’s consistency with the applicable principals of the Compass Growth Vision has been added to the Draft EIR (see Section IV, Corrections and Additions, of this Final EIR). As shown therein, the proposed project would be consistent with Compass Growth Vision Principle 4. The addition of the information regarding the proposed project’s consistency with the Compass Growth Vision Principle 4 does not constitute a substantial change to the analysis and conclusions of the Draft EIR with respect to consistency with existing land use policies.



Comment No. 4-9

CONCLUSION

Overall, the proposed project partially meets consistency with SCAG Regional Transportation Plan Goals and Growth Visioning Principles.

All feasible measures needed to mitigate any potentially negative regional impacts associated with the proposed project should be implemented and monitored, as required by CEQA. Refer to the SCAG List of Mitigation Measures for additional guidance, which may be found here: http://www.scag.ca.gov/igr/documents/SCAG_IGRMMRP_2008.pdf

When a project is of statewide, regional, or areawide significance, transportation information generated by a required monitoring or reporting program shall be submitted to SCAG as such information becomes reasonably available, in accordance with CEQA, Public Resource Code Section 21018.7, and CEQA Guidelines Section 15097 (g).


SCAG indicates that, overall, the proposed project is at least partially consistent with the goals of the 2008 RTP and the principles of the Compass Growth Vision. In this comment, SCAG requests that all feasible mitigation measures necessary to mitigate any potentially negative impacts be implemented and monitored as required by CEQA. The mitigation measures in SCAG’s List of Mitigation Measures have been reviewed, and the Lead Agency has determined that no additional mitigation measures are warranted. Furthermore, this Final EIR includes a Mitigation Monitoring Program (MMP) pursuant to Public Resources Code Section 21081.6, for all mitigation measures recommended in the Draft EIR. As SCAG will receive a copy of the Final EIR, they will also receive a copy of the MMP.




Brent Lorscheider, Division Manager Wastewater Engineering Services Division Bureau of Sanitation City of Los Angeles Inter-Departmental Correspondence

Comment No. 5-1

SUBJECT: Bundy Village and Medical Park - Draft EIR

This is in response to your April 30, 2009 letter requesting a review of your proposed project. The Bureau of Sanitation has conducted a preliminary evaluation of the potential impacts to the wastewater and stormwater systems for the proposed project.

WASTEWATER REQUIREMENT

The Bureau of Sanitation, Wastewater Engineering Services Division (WESD) is charged with the task of evaluating the local sewer conditions and to determine if available wastewater capacity exists for future developments. The evaluation will determine cumulative sewer impacts and guide the planning process for any future sewer improvements projects needed to provide future capacity as the City grows and develops.

Projected Wastewater Discharges for the Proposed Project:

Type Description Average Daily Flow per Type Description IGPD/UNIT)

Proposed No. of Units

Average Daily Flow (GPO)

Existing

Office 150 GPD/1000 SQ.FT 113,600 SQ.FT (17,040)

Research/Development Space

80 GPD/1000 SQ.FT 42,942 SQ.FT (3,435)

Manufacturing 80 GPD/1000 SQ.FT 93,741 SQ.FT (7,499)

Proposed

Residential Units 160 GPD/DU 385 DU 61,600

Retail 80 GPD/1000 SQ.FT 110,338 SQ.FT 8,827

Restaurant 300 GPD/1000 SQ.FT 9,500 SQ.FT 2,850

Medical Offices 250 GPD/1000 SQ.FT 384,735 SQ.FT 96,184

Total 141,487




The information provided in this comment varies slightly from the analysis in the Draft EIR with respect to the wastewater generation rate for office land uses. The Draft EIR (Page IV.L-8) utilizes a wastewater generation rate for office land uses of 200 gallons per 1,000 square feet per day (0.2 gallons per square foot), while this comment utilizes a wastewater generation rate of 150 gallons per 1,000 square feet per day (0.15 gallons per square foot). However, the generation rates used in the Draft EIR were provided by the Bureau of Sanitation in a previous letter, dated January 31, 2007, which is included in Appendix G to the Draft EIR. Despite minor differences in the wastewater generation rate for office land uses, both this comment and the January 31, 2007 letter conclude that the proposed project is expected to be adequately served by existing wastewater infrastructure.

Comment No. 5-2

SEWER AVAILABILITY

The sewer infrastructure in the vicinity of the proposed project includes the existing 18-inch line in Bundy Dr and existing 8-inch line in Olympic Blvd. The sewage from the existing 8-inch line flows into a 24-inch pipe in Carmelina Ave Alley. The flow then connects with the sewage from the existing 18-inch line in Bundy Ave into a 24-inch line in Bundy Dr Alley before discharging into a 30-inch pipe in Granville Ave.

Based on our existing gauging information, the current approximate flow level (d/D) and the design capacities at d/D of 50% in the sewer system are as follows:

Pipe Diameter (in)

Pipe Location Current Gauging d/D (%) 50% Design Capacity

8 Olympic Blvd * 229,323 GPO 18 Bundy Dr 42 2.60 MGD 24 Carmelina Ave Alley 45 2.72 MGD 24 Bundy Dr Alley 43 3.04 MGD 30 Granville Ave 52 9.61 MGD

* No gauging available

Based on the estimated flows, it appears the sewer system might be able to accommodate the total flow for your proposed project. Further detailed gauging and evaluation will be needed as part of the permit process to identify a sewer connection point. If the public sewer has insufficient capacity then the developer will be required to build sewer lines to a point in the sewer system with sufficient capacity. A final approval for sewer capacity and connection permit will be made at that time. Ultimately, this sewage flow will be conveyed to the Hyperion Treatment Plant, which has sufficient capacity for the project.

If you have any questions, please call Abdul Danishwar of my staff at (323) 342-6220.




The Bureau of Sanitation provides information regarding the sewer infrastructure and design capacity surrounding the project site. The information provided in this comment varies slightly from the analysis in the Draft EIR. Page IV.L-3 in the Draft EIR states that the current flow of the 18-inch line in Bundy Drive is approximately 50 percent full, 55 percent full in the 24-inch line in Carmelina Avenue, 45 percent full in the 24-inch line in Bundy Drive, and approximately 53 percent full in the 30-inch lines. In comparison, this comment states that the current flow of the 18-inch line in Bundy Drive is approximately 42 percent full, 45 percent full in the 24-inch line in Carmelina Avenue, 43 percent full in the 24-inch line in Bundy Drive, and approximately 52 percent full in the 30-inch lines. However, the flow levels used in the Draft EIR were provided by the Bureau of Sanitation in a previous letter dated January 31, 2007, which is included in Appendix G to the Draft EIR. The flow levels listed for each of the sewer lines serving the project site in the 2007 letter were reported as greater than the flow levels in the letter from 2009. As such, the wastewater infrastructure analysis in the Draft EIR is based on more conservative values for the remaining capacities of the sewer lines serving the project site. Furthermore, both letters reiterate the conclusion in the Draft EIR that the proposed project is expected to be served by existing infrastructure. As discussed on Page IV.L-9 of the Draft EIR, further detailed gauging and evaluation of line capacity will be included as part of the permitting process. If it is determined that the adjacent sewer infrastructure has insufficient capacity for the proposed project, the developer would be required to build sewer lines to sufficient capacity as part of the permitting process. This comment does not identify a greater or an additional significant impact arising from the proposed project related to wastewater or substantially alter the determinations in the Draft EIR and, therefore, impacts related to wastewater infrastructure would be less than significant.

Comment No. 5-3

STORMWATER REQUIREMENTS

The Bureau of Sanitation, Watershed Protection Division is charged with enforcement of the provisions of the National Pollutant Discharge Elimination System (NPDES) permit.

SUSMP AND STORM WATER INFILTRATION

The proposed project is subjected to Standard Urban Stormwater Mitigation Plan (SUSMP) regulations. The proposed project is required to incorporate measures to mitigate the impact of stormwater runoff as outlined in the guidance manuals titled "Development Best Management Practices Handbook - Part B: Planning Activities". In addition the "SUSMP Infiltration Requirements and Guidelines" prioritizes the use of infiltration and bio-filtration systems as the preferred methods to comply with SUSMP requirements. These documents can be found at:

www.lastormwater.org/Siteorg/businesses/susmp/susmpintro.htm.




This comment includes general information regarding the Standard Urban Stormwater Mitigation Plan (SUSMP) regulations, and requires project compliance of the SUSMP. As discussed on Page IV.A-7 in the Draft EIR, the proposed project would be required to comply with water quality standards and wastewater discharge requirements set forth by the SUSMP for Los Angeles County and Cities in Los Angeles County. Further, the Draft EIR includes Mitigation Measures A-4 through A-6 on Page IV.A-8 and Mitigation Measure L-19 on Page IV.L-28, which require compliance with all SUSMP requirements, recommend City approval of post development peak stormwater runoff discharge, and encourage the implementation of BMPs that have stormwater recharge or reuse benefits (see also Section V, Mitigation Monitoring Program, in this Final EIR).

Comment No. 5-4

GREEN STREETS

The City is developing a Green Street Initiative that will require projects to implement Green Street elements in the parkway areas between the roadway and sidewalk of the public right-of-way to capture and retain stormwater and urban runoff to mitigate the impact of stormwater runoff and other environmental concerns. If the proposed project includes public right-of-way improvements and presents an opportunity to include Green Street elements as part of the project. The goals of the Green Street elements are to improve the water quality of stormwater runoff, recharge local ground water basins, improve air quality, reduce the heat island effect of street pavement, enhance pedestrian use of sidewalks, and encourage alternate means of transportation. The Green Street elements may include infiltration systems, biofiltration swales, and permeable pavements where stormwater can be easily directed from the streets into the parkways. For more information regarding implementation of Green Street elements, please call Wing Tam at (213) 485-3985.


This comment does not identify a greater or additional significant impact arising from the proposed project related to stormwater quality and does not recommend the components of the Green Streets Program as mitigation, but refers to the Green Streets Program as an opportunity. As discussed in Section IV.A, Impacts Found to be Less Than Significant, of the Draft EIR, the proposed project would not result in significant impacts related to stormwater runoff. Nonetheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.



Comment No. 5-5

WET WEATHER EROSION CONTROL

A Wet Weather Erosion Control Plan is required for construction during the rainy season (between October 1 and April 15 per Los Angeles Building Code, Sec. 7002). For more information, please see attached Wet Weather Erosion Control Guidelines.


As discussed on Page IV.A-6 in the Draft EIR, construction activities for the proposed project would be required to conform to City Building Code Sections 91.7000 through 91.7016, which include construction requirements for grading, excavation, and use of fill, which would reduce the potential for wind or waterborne erosion. In addition, the City Building Code requires an erosion control plan to be reviewed by the Department of Building and Safety prior to construction if grading exceeds 200 cubic yards and occurs during the rainy season (between November 1 and April 15). The proposed project would be required to comply with the City Building Code, including the implementation of an erosion control plan.

Comment No. 5-6

STORM WATER POLLUTION PREVENTION PLAN

A Storm Water Pollution Prevention Plan (SWPPP) is required for land disturbance activities over one acre. The SWPPP must be maintained on-site during the duration of construction. WPD staff is available at your request to provide guidance on stormwater issues. Should you have any questions, please contact Meher Irani of my staff at (213) 485-0584.


A Stormwater Pollution prevention Plan (SWPPP) is required as part of the National Pollution Discharge Elimination System (NPDES). As discussed on Pages IV.A-7 through IV.A-8 in the Draft EIR, the proposed project would be required to comply with water quality standards and wastewater discharge requirements related to project design, construction, and operation under the SUSMP and, therefore, would be required to prepare a SWPPP as part of the permit process.

Comment No. 5-7

SOLID RESOURCE REQUIREMENTS

The City has a standard requirement that apply to all proposed residential developments of four or more units or where the addition of floor areas is 25 percent or more, and all other development projects where the addition of floor area is 30 percent or more. Such developments must set aside a recycling area or room for onsite recycling activities. For more details of this requirement, please contact Special Projects Division.



Special Projects staff is available at your request to provide guidance on solid resource issues. Should you have any questions, please contact Daniel Hackney at (213)485-3684.


This comment states that the proposed project is required to provide a recycling area or room for onsite recycling activities. Mitigation Measure L-23 on Page IV.L-40 in the Draft EIR (and Section V, Mitigation Monitoring Program, of this Final EIR) recommends implementation of a residential recycling program. The proposed project would incorporate space for the residential recycling program into the project design in compliance with Mitigation Measure L-23.




Eileen Fogarty, Director Planning & Community Development Department City of Santa Monica 1685 Main Street P.O. Box 2200 Santa Monica, CA 90407-2200

Comment No. 6-1

Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) prepared for the Bundy Village and Medical Park project located at 1901. 1925, and 1933 South Bundy and 12333 Olympic Boulevard in the City of Los Angeles. This letter constitutes the City of Santa Monica's comments on the environmental analysis prepared for the project. The City's comments are solely related to the traffic analysis section of the report.

The City of Santa Monica is deeply concerned about the Impacts of this project on Santa Monica streets. Based on the City of Los Angeles (LADOT) impact criteria. 15 out of the 25 intersections within or bordering on the City of Santa Monica are significantly impacted. These intersections include:

1. Colorado Avenue/Stewart Street

2. Olympic Boulevard/20th Street

3. Olympic Boulevard/Cloverfield Boulevard

4. Olympic Boulevard/26th Street

5. Olympic Boulevard /Stewart Street

6. Olympic Boulevard/Centinela Avenue. (north leg)

7. Olympic Boulevard/Centinela Avenue (south leg)

8. Centinela Avenue/I-10 WB On-/Off-Ramps

9. Pico Boulevard/23rd Street

10. Pico Boulevard/Cloverfield Boulevard

11. Pico Boulevard/I-10 EB Off-Ramp

12. Pico boulevard [sic]/Centinela Avenue

13: Centinela Avenue/I-10 EB On-Ramp

14. Ocean Park Boulevard/23rd Street

15. Ocean Park Boulevard/Centinela Avenue



An additional 2 intersections would be impacted under the Critical Movement Analysis, according to LADOT significance criteria:

1. Santa Monica Boulevard/Cloverfield Boulevard

2. Pico Boulevard/Lincoln Boulevard


Section IV.K (Traffic and Transportation) of the Draft EIR and the project traffic study (Appendix H to the Draft EIR) identify a total of 13 intersections operating under the exclusive control of the City of Santa Monica, including nine of the locations noted by the commenter (Study Intersection Nos. 1 through 5, 9 through 11, and 14); the remaining six listed intersections are under shared jurisdiction,1 and are at least 50 percent under the jurisdiction of the City of Los Angeles and, therefore, for purposes of the analyses, were assumed to be “City of Los Angeles” intersections. The two additional locations noted are outside the immediate study area, but are analyzed in detail as “Congestion Management Program” arterial monitoring intersections; as described in the project traffic study, the LADOT impact criteria was applied to these more distant locations in order to provide a conservative analysis, although neither of these locations would be significantly impacted using the applicable CMP criteria.

Comment No. 6-2

The document characterizes the City of Santa Monica's methodology and impact criteria as the same as that for the City of Los Angeles, which is mistaken. The City of Santa Monica's criteria are provided for your reference in Attachment A. It is unclear whether there would be additional or more severe impacts using the City of Santa Monica's criteria because the intersection volume-to-capacity (V/C) and average vehicle delay data are not provided in the document we received. Finally, the trip generation methodology provides a credit for medical office as being neighborhood serving. The City does not agree with this assumption.


CEQA permits the lead reviewing jurisdiction of any project (the LADOT, in this case) to establish reasonable methods for analysis and evaluation of potential project impacts, regardless of jurisdictional boundaries. The CMA traffic analysis methodology utilized by the City of Los Angeles is a widely accepted basis for the evaluation of traffic conditions, and is used by many jurisdictions throughout Southern California.

Additionally, the “significance” criteria used by the LADOT is among the most stringent in the region, and is also used by a number of outside agencies and other jurisdictions. Therefore, the application of the

1 An intersection with a shared jurisdiction is an intersection with one or more approaches that lie within a

different jurisdiction than the remainder of the approaches. The various jurisdictions are typically responsible for maintenance and/or configurations of their respective approaches, but generally the traffic signal operations are under the jurisdiction of only one of the locations.



LADOT CMA analysis methodology and City of Los Angeles significance criteria is both appropriate and reasonable in the determination of project traffic impacts. CEQA does not require a lead agency to apply thresholds adopted or implemented by neighboring jurisdictions. The consistent application of the lead agency’s methodologies and assumptions to the study area results in a consistent evaluation of the potential impacts of the project, as required under CEQA, across jurisdictional lines. As such, the traffic impact analyses and identification of potential project impacts, regardless of whether the intersection is located within the City of Los Angeles or within the City of Santa Monica, is based on the lead agency’s analysis and provides the decision-makers with complete and comparable information regarding the potential impacts of the proposed project. All cross-jurisdictional project impacts are adequately evaluated and identified using the lead agency’s adopted guidelines and policies.

Of the 13 intersections identified in the project traffic study as belonging solely to the City of Santa Monica, the project traffic study identifies significant project impacts at nine of those locations and, as such, those locations are considered to be adequately analyzed and evaluated. Additionally, as detailed in the project traffic study, each of the four locations where no significant project impacts were identified (20th Street and I-10 westbound On-ramp; 20th Street and I-10 eastbound Off-ramp; Pico Boulevard and Stewart Street/28th Street; and Ocean Park Boulevard and Cloverfield Boulevard) is forecast to operate at LOS C or better during both the AM and PM peak hours, with the exception of Pico Boulevard and Stewart Street/28th Street, and Ocean Park Boulevard and Cloverfield Boulevard, which are both forecast to operate at LOS D during the AM peak hour. However, the City of Santa Monica’s traffic impact criteria, which is the same for “arterial intersections” throughout the range from LOS A to LOS D, indicates the recognition that there is substantial available capacity at intersections operating at these levels of service, as does the LADOT impact criteria utilized in the traffic study, and as such, the LADOT criteria for evaluation of potential project traffic impacts as these locations is considered to be appropriate. Further, identification of significant impacts at those intersections would result in unnecessary improvements at locations capable of accommodating additional traffic, and would be contrary to the assumed intent of the City of Santa Monica to refrain from unnecessary roadway improvements. Please also refer to Response to Comment 7-3c.

Furthermore, of 12 additional intersections located on the boundary between the two cities (assumed to be under the primary operational jurisdiction of the City of Los Angeles), the project traffic study identifies that significant impacts could occur at eight of those locations. Therefore, the traffic study analyzed a total of 25 intersections either wholly or partially under the jurisdiction of the City of Santa Monica, and identified significant impacts at a total of 17 locations.

Comment No. 6-3

The proposed mitigation measures at the border intersections deteriorate the built environment for pedestrians, transit riders and residents and are not acceptable to the City of Santa Monica. Any proposed mitigations in or at the border of the City of Santa Monica need to be discussed and agreed to by the City of Santa Monica. The document also refers to compensation by the developer for "fair share" impacts. The "fair share" methodology needs to be clarified and the City of Santa Monica needs to agree.




The proposed traffic mitigation measures recommended for the “border” intersections were reviewed by the LADOT in the context of both improvements to roadway capacity and secondary impacts to pedestrian and/or transit operations, and are considered to be acceptable. As described in detail in the project traffic study (Appendix H to the Draft EIR), a number of proposed mitigation measures were rejected by the LADOT due to potential secondary impacts to on-street parking, reductions in pedestrian capacity or amenities, or their effects on transit operations and, therefore, the remaining improvements are not anticipated to result in significant secondary impacts. Additionally, Section IV.K (Traffic and Transportation) of the Draft EIR and the project traffic study recommend continued coordination between the City of Los Angeles and the City of Santa Monica in the identification of appropriate “fair share” contributions to mitigation measures proposed for the City of Santa Monica intersections, including installation of new signal coordination measures. It is also important to note that the signal coordination mitigation measures recommended for the nine significantly impacted intersections in the City of Santa Monica are expected to not only reduce all project impacts within that jurisdiction to less-than-significant levels, they would also improve intersection operations to better than forecast “Without Project” conditions during both peak hours at all of these locations; thereby, “overmitigating” project-specific impacts and providing surplus additional capacity at these locations beyond that utilized by the incremental project traffic additions. (See Table 20 on Pages 121 through 124 in the project traffic study, and Table IV.K-18 on Pages IV.K-139 through IV.K-142 in the Draft EIR.)

Comment No. 6-4

Finally, although the Exposition Boulevard/Centinela Avenue intersection was not analyzed in the DEIR, the City is requesting signalization.


The intersection of Exposition Boulevard and Centinela Avenue is unsignalized, and is STOP sign controlled along the minor approach (Centinela Avenue does not stop at this location). The LADOT’s current standard approach to traffic impact analysis provides that unsignalized intersections should be evaluated to identify whether such intersections are appropriate for installation of traffic signals. A review of the suggested location indicates that signalization would not be recommended; the intersection of Centinela Avenue and Exposition Boulevard is located immediately adjacent to the proposed Expo Line at-grade crossing of Centinela Avenue and, as such, due to the required crossing equipment and train/automobile access controls for such an at-grade crossing, signal installation at this location is infeasible. Therefore, this location was not considered to be appropriate for signal installation and, based on the LADOT’s analysis criteria, a detailed analysis of the intersection was not warranted.

Comment No. 6-5

Please refer to Attachment B, which provides the City's detailed comments regarding the analysis for intersections and right-of-way within or bordering on the City of Santa Monica. One issue we are particularly concerned with is that the preferred haul route is identified as entirely on Centinela Avenue to


the I-10 Freeway (adjacent to our residents) and avoids the reality that Bundy Drive has the most street frontage and will be the destination/origination of at least some of the trucking activity. The Bundy entrance to the I-10 Freeway should also be identified.

If-you have questions, need clarification or would like to discuss our comments, please contact Sam Morrissey, Principal Transportation Engineer at: [email protected] or Beth Rolandson Principal Transportation Planner at: [email protected]. Both of them can also be reached by calling (310) 458-8291.


Refer to Responses to Comments 6-6 through 6-34 regarding the City’s Attachment B information. Additionally, the project haul route proposed in the Draft EIR was fully evaluated regarding potential traffic impacts. Centinela Avenue was selected as the primary and preferred haul route due to its relatively light traffic volumes as compared with Bundy Drive, which currently exhibits substantial traffic congestion, particularly at the access locations for the Santa Monica Freeway (I-10). The proposed haul route for the project’s construction traffic utilizes Centinela Avenue as the shortest route to and from the nearby Santa Monica Freeway. A detailed traffic impact analysis was prepared to identify potential construction-related impacts, and appropriate mitigation measures were proposed. As previously discussed, if the Expo Line – Phase 2 project is completed prior to development of the proposed project, the use of Centinela Avenue as the primary haul route would still be considered to be viable because the Expo Line Draft EIR indicated no significant impacts to the operations of Centinela Avenue.

Comment No. 6-6





Comment No. 6-7


This comment is not accurate. Wilshire Boulevard through the study area does not currently exhibit bus-only lanes in either direction during peak hours. Also, the roadway descriptions contained in the project traffic study (Appendix H to the Draft EIR) and in Section IV.K (Traffic and Transportation) of the Draft EIR are for general information purposes only, and do not affect the specific details of the traffic impact analyses. Furthermore, as discussed in the project traffic study, on-street parking is prohibited along those segments within the study area within the City of Santa Monica where Pico Boulevard is developed with a raised median island, which precludes on-street parking.



Comment No. 6-8


The roadway descriptions contained in the project traffic study (Appendix H to the Draft EIR) and in Section IV.K (Traffic and Transportation) of the Draft EIR are for general information purposes only, and do not affect the specific details of the traffic impact analyses.

Comment No. 6-9


A review of the data table referred to by the commenter indicates that, while some of the specific traffic moves at the “correlation” intersections exhibit notable increases in volumes between the 2006 and 2007 count dates, it is also important that at such locations, the “conflicting” traffic flows have generally decreased, resulting in approximately equivalent overall CMA and LOS values between the 2006 and 2007 data at the correlation intersections (see Table III-1 below). Additionally, as indicated in Table III-1, and as shown in the correlation data table in the project traffic study (Appendix H to the Draft EIR), the overall traffic volumes at each of the correlation intersections was generally reduced between the 2006 and 2007 counts and, as such, the 2006 data tended to produce the more conservative analysis result; only the intersection of Colorado Avenue/Idaho Avenue and Centinela Avenue exhibited any notable change in CMA/LOS value between the 2006 and 2007 data (during the AM peak hour only; PM peak hour conditions using the 2006 data remained higher than using the 2007 correlation count data). However, this change would not affect the results or conclusions of the project traffic study, since a significant impact is already noted to occur at this intersection during the PM peak hour. However, the approximately 10.2 percent increase in the AM CMA value for existing conditions (resulting in an change from the LOS B conditions identified in the traffic study to LOS C, as shown in Table III-1, below) would result in this intersection exhibiting a forecast “Future (2011)” level of service of LOS D, rather than the forecast LOS C conditions identified in the traffic study. However, the project’s incremental impact would remain at +0.012 during this time period, which is not significant under the LADOT’s impact criteria. As such, the supporting CMA calculations are attached (see Appendix B to this Final EIR). Therefore, no change in conclusions to the Draft EIR and project traffic study would occur, as no new impacts would result, and no additional mitigation would be necessary. As such, the 2006 data used in



the traffic impact analyses does produce reasonable assessments of current traffic conditions in the project study area. Please also refer to Response to Comment 12-3.

Table III-1 Critical Movement Analysis Summary

Existing (2006) vs. Existing (2007) Conditions Existing (2006)

Existing (2007) Int.

No. Intersection PeakHour CMA LOS CMA LOS Change

PercentChange

8 Santa Monica Boulevard and AM 0.697 B 0.609 B -0.088 -12.6% Bundy Drive PM 0.780 C 0.760 C -0.020 -2.6%

11 Santa Monica Boulevard and AM 0.727 C 0.747 C 0.020 2.8% Barrington Avenue PM 0.803 D 0.751 C -0.052 -6.5%

19 Colorado Avenue/Idaho Avenue and AM 0.687 B 0.757 C 0.070 10.2% Centinela Avenue PM 0.853 D 0.833 D -0.020 -2.3%

31 Olympic Boulevard and AM 0.788 C 0.831 D 0.043 5.5% Stewart Street PM 1.051 F 1.028 F -0.023 -2.2%

33 Olympic Boulevard and AM 0.582 A 0.494 A -0.088 -15.1% Centinela Avenue (south leg)/Project Driveway PM 0.656 B 0.601 B -0.055 -8.4%

34 Olympic Boulevard and AM 0.926 E 0.954 E 0.028 3.0% Bundy Drive PM 0.924 E 0.881 D -0.043 -4.7%

35 Olympic Boulevard and AM 0.879 D 0.827 D -0.052 -5.9% Barrington Avenue PM 0.915 E 0.924 E 0.009 1.0%

43 Centinela Avenue and AM 0.872 D 0.858 D -0.014 -1.6% I-10 WB On/Off-Ramps PM 1.125 F 1.079 F -0.046 -4.1%

47 Pico Boulevard and AM 0.735 C 0.665 B -0.070 -9.5% I-10 EB Off-Ramp/34th Street PM 0.727 C 0.671 B -0.056 -7.7%

49 Pico Boulevard and AM 1.074 F 1.050 F -0.024 -2.2% Bundy Drive PM 1.149 F 1.048 F -0.101 -8.8%

51 Pico Boulevard and AM 0.873 D 0.889 D 0.016 1.8% Gateway Avenue PM 0.929 E 0.944 E 0.015 1.6%

Source: Hirsch/Green Transportation Consulting, Inc., July 2009.

Comment No. 6-10





Comment No. 6-11


There are approximately six residences, fronting on the west side of Centinela Avenue, between Exposition Boulevard and the I-10 On-ramps (all located between Exposition Boulevard and the I-10 westbound On-ramp). Conversely, there are nearly three times this amount of residences along both sides of Bundy Drive between Exposition Boulevard and the Santa Monica Freeway (I-10) ramps. Therefore, use of Bundy Drive would increase the number of area residents experiencing potential construction impacts. The use of Centinela Avenue as a haul route would result in reduced impacts to residential properties as compared to the use of Bundy Drive. Please also refer to Responses to Comments 6-5 and 12-7. (See Pages IV.K-29 through IV.K-34 in the Draft EIR for a discussion of the proposed project’s haul route.)

Comment No. 6-12


The project trip generation estimates were derived using either the average trip rates or the fitted regression equations presented in the ITE Trip Generation publication; use of either the rates or equations are acceptable, and are determined by the lead agency, in this case the LADOT. The average trip generation rates requested by the commenter were used for the estimation of the project’s retail market, restaurant, medical office, and residential components. The fitted regression equations were utilized only for the “retail” and “general office” components, since these types of uses typically show relevant reductions in “per unit” trip generation characteristics as the floor area increases. As such, the ITE fitted equations are considered to be the more accurate methodology for calculating trip generation estimates for these uses.



Comment No. 6-13


As discussed in the project traffic study (Appendix H to the Draft EIR), the internal capture assumptions utilized in the analyses assume only nominal capture of on-site trips; as indicated in the trip generation table (see Table IV.K-6 on Page IV.K-42 in the Draft EIR), internal discounts are assumed to result in an approximately 5 percent reduction in retail, market, and medical office uses, and a 10 percent reduction in restaurant trips. Overall, these discounts result in reductions of approximately 1,400 daily trips, including 73 AM peak hour and 141 PM peak hour trips; these values represent a reduction of only approximately 5 percent of the daily and peak hour trips as compared to the gross project trips, or between 7 and 9 percent of the net project trips. It is unclear how the commenter arrived at their substantially higher internal trip capture values of “between 25% to 48%.”

Comment No. 6-14


The medical office component was not assumed as a “neighborhood serving” use. However, due to the presence of both on-site residents and nearby residential neighborhoods which would supply patrons for the medical office complex, it is appropriate to consider some nominal level of trip reduction as a result of this factor. As such, a conservative five percent “internal capture” factor, which includes use of the medical office by both residents of the site as well as potential “walk-in” patronage from nearby residential neighborhoods, was assumed. Please also refer to Responses to Comments 6-2 and 6-13.

Comment No. 6-15




The proposed project is intended to be pedestrian friendly and neighborhood serving. The Applicant has consulted with the Department of City Planning regarding compliance with the City’s Walkability Guidelines (see also Pages IV.G-52 through IV.G-57 in the Draft EIR), especially within the site itself; a substantial pedestrian promenade on the Bundy Drive project site, as well as a large landscaped open area along the Olympic Boulevard frontage of the project site. This comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, further response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 6-16


The project traffic study (Appendix H to the Draft EIR) trip distribution/assignments (discussed in detail on page 15 of the traffic study, and shown in Figures 4(a) and 4(b)) were based on reviews of the area traffic operations and travel patterns, socio-economic data for both the local vicinity and the larger regional area, and data from other recent studies. Additionally, the trip distribution/assignment assumptions were reviewed by LADOT staff, including local staff familiar with the area travel patterns, and were found to be reasonable estimates of potential project traffic patterns.

Comment No. 6-17


As described in detail in the project traffic study (Appendix H to the Draft EIR), the total project driveway volumes are anticipated to be approximately 950 inbound and 415 outbound trips during the AM peak hour, and 1,018 inbound and 1,650 outbound trips during the PM peak hour. The figures noted by the commenter do exhibit minor typographical errors, however, resulting in slight corrections to the presentation of the total project driveway volumes: the outbound right-turn volume from the southernmost project driveway on Bundy Drive shown in Figure IV.K-10 (AM peak hour) should indicate “60” vehicles rather than the 49 vehicles shown, while Figure IV.K-11 (PM peak hour) should indicate “56” right-turning vehicles from southbound Bundy Drive into the southernmost driveway, rather than the 53 vehicles shown. Therefore, corrections to Figures IV.K-10 and IV.K-11 are provided in Section IV,



Corrections and Additions, of this Final EIR. These nominal discrepancies are typographical errors only, and do not affect the conclusions in the analyses in the Draft EIR or project traffic study.

Comment No. 6-18


The forecast future study year (end of 2011) represents a timeline of approximately 30 months from the current time. As identified in the Draft EIR, the total project construction timeline is approximately 27 months (4 months for demolition, 3 months for excavation, and 20 months for construction). Therefore, with completion of the project’s approvals and subsequent groundbreaking anticipated for later this year, the forecast year 2011 timeline is considered appropriate. It is also of note that the forecast future 2011 traffic conditions are considered to be conservative with respect to estimates of future traffic volumes and intersection/roadway operations (due to conservative assumptions regarding ambient traffic growth and inclusion of “worst case” estimates of trips generated by related projects), and would be expected to adequately represent traffic conditions beyond the assumed 2011 timeframe.

Comment No. 6-19


The justification for the 1.0 percent annual traffic increase assumption are fully discussed on Pages 55 and 56 in the project traffic study (Appendix H to the Draft EIR), which states the following:

Bundy Village and Medical Park III. Responses to Comments

Based on analyses of the trends in traffic growth in the study area over the last several years, as documented in the Los Angeles County Congestion Management Program (CMP), LADOT determined that an annual traffic growth factor of 1.0 percent is reasonable. In fact, as documented in the Los Angeles County Congestion Management Program (CMP), actual anticipated traffic growth in the “Westside” area encompassing and surrounding the study vicinity, is forecast to be approximately 0.80 to 0.85 percent annually, inclusive of both ambient growth and traffic from cumulative area development, and as such, the assumed 1.0 percent annual growth factor is expected to be quite conservative. This “ambient traffic growth factor” is used to account for expected increases in traffic resulting from general ambient traffic growth in the study vicinity due to ongoing regional population growth, or from potential development projects not yet proposed or outside of the study area. The ambient growth factor, compounded annually, was applied to the 2006 traffic volumes to develop estimates of the future traffic volumes for the future year 2011 baseline conditions.

Final Environmental Impact Report Page III-43


The CMP forecast traffic growth factors are identified in Appendix B, Exhibit B-1, of the 2004 Los Angeles County Congestion Management Program document.

Comment No. 6-20


The current status of the “Olympic West – Pico East Initiative” (the “Olympic/Pico plan”) can be found on LADOT’s website (http://ladot.lacity.org/index.htm). Based on the recently completed Initial Study (dated March 2009) for the Olympic/Pico plan, all notifications and public comments on the Notice of Preparation were scheduled to be completed by the end of April 2009, and preparation of the project Draft EIR was slated to begin. Specific timing of the Draft EIR is not provided, but is expected before the end of 2010. As the described Phase One portion of the Olympic/Pico plan simply coordinates the existing on-street parking restrictions throughout the lengths of the study area for both streets, implementation of this portion of the plan does not involve significant infrastructure improvements, and is anticipated by the end of 2011. It is also of note that the City of Los Angeles passed a motion on June 26, 2009 authorizing funding for the implementation of the Olympic/Pico plan.

Comment No. 6-21



Comment No. 6-22


Bundy Village and Medical Park III. Responses to Comments

The project traffic study (Appendix H to the Draft EIR) analysis methodology and results follow the LADOT’s current Traffic Study Policies and Procedures (dated March 2002), including the evaluation of

Final Environmental Impact Report Page III-44


project-specific impacts and the inclusion of traffic effects from related projects (“cumulative development”). The effects and impacts of potential cumulative development are included in the traffic impact analyses for the proposed project, as well as project-specific contributions to the overall cumulative conditions (see Section IV.K, Traffic and Transportation, of the Draft EIR).

Comment No. 6-23



Comment No. 6-24



Comment No. 6-25


A conceptual drawing of the recommended mitigation at the intersection of Centinela Avenue and Colorado Avenue/Idaho Avenue is shown in Figure C-3 of the project traffic study (Appendix H to the Draft EIR). As identified in this figure, the proposed mitigation improvement can be accommodated within the existing paved roadway width of the eastbound approach of Colorado Avenue/Idaho Avenue. Additionally, the proposed lane widths are typical of urban conditions throughout the region, including within the City of Santa Monica. The commenter notes that the proposal would “likely” be unacceptable to the City of Santa Monica, but provides no details regarding acceptable configurations/lane widths. Furthermore, as discussed in the project traffic study, “formalization” of the eastbound right-turn




nd to be unacceptable or infeasible, significant and unavoidable impacts would result at such locations.

Comment No. 6-26

movement does not mean that this location operates efficiently under its existing configuration (please refer to Response to Comment 7-4a). Lastly, although the recommended improvement would reduce the project impacts at this location to less-than-significant levels, the Draft EIR notes that, should the recommended mitigation measures at any of the study intersections be fou


tions and geometries. The final disposition regarding this improvement rests with the decision-makers.

Comment No. 6-27

The original mitigation concept for this intersection (Olympic Boulevard and Centinela Avenue south leg) recommended the removal of the on-street parking spaces in order to implement the proposed new lane configurations, but the LADOT’s initial reviews of the recommendation indicated their preference to widen the roadway instead, in order to minimize impacts to on-street parking supplies in the area. However, either measure (removal of on-street parking or roadway widening) results in the ability to provide the recommended roadway configura


no roadway widening and no reductions in sidewalk width on either side of the roadway are anticipated.

The concept for this improvement at Centinela Avenue and the Santa Monica Freeway (I-10) westbound ON/Off-ramps was suggested by the LADOT, and originally contemplated a reduction in sidewalk width as a means to provide the additional southbound travel lane; the recommended reduction in sidewalk width would occur solely within the City of Los Angeles. However, as shown in Figure C-8 in the appendix to the project traffic study (Appendix H to the Draft EIR), the conceptual mitigation drawing for this improvement indicates that


Comment No. 6-28


As shown in Figure C-9 in the project traffic study (Appendix H to the Draft EIR), the recommended reduction in sidewalk width at this location (Pico Boulevard and Centinela Avenue) occurs only within the City of Los Angeles, on the north side of Pico Boulevard between Wellesley Avenue and Centinela Avenue. However, despite the proposed reduction in sidewalk width, the sidewalk would be maintained at a width of 10 feet, which is the standard sidewalk width throughout the City of Los Angeles, and is sufficient to accommodate the existing bus stop/shelter.

Comment No. 6-29


As shown in Figure C-12 in the appendix to the project traffic study (Appendix H to the Draft EIR), the conceptual mitigation drawing for this improvement (at Centinela Avenue and the eastbound I-10 On-ramp), the proposed widening would be expected to occur within the existing rights-of-way, and would result in the reduction in sidewalk width from 12 feet to 10 feet only along the east side (City of Los Angeles) of the roadway between the On-ramp and Pico Boulevard.



Comment No. 6-30


The analysis of the recommended mitigation measure includes the assumption of north/south opposed signal phasing, and as indicated in Table IV.K-18 on Page IV.K-139 in the Draft EIR, even with the additional signal cycle length anticipated as a result of the opposed phasing operations, the capacity enhancements realized through the addition of a second (shared) southbound left-turn lane would result in operations of this intersection at better than forecast “Without Project” conditions. Also, the additional left-turn capacity would allow for a reduction in the length of the southbound signal cycle, as more left-turning vehicles (the critical southbound move) can be accommodated simultaneously with the dual left-turn configuration, offsetting the cycle length increases necessary to implement the opposed phasing. As such, pedestrians are not anticipated to experience any additional delays as a result of this improvement, and no impacts to the intersection’s ability to accommodate pedestrian demands are expected.

Comment No. 6-31


Please refer to Response to Comment 6-1, 6-2, and 6-3. Additionally, a review of the locations of the City of Los Angeles/City of Santa Monica border indicates that most of the “border” intersection locations identified for mitigation improvements (Intersection Nos. 19, 33, 43, 48, 54, and 61) exhibit approaches affected by the mitigation measures that are wholly within Los Angeles (City boundary runs along the west property line of Centinela Avenue). All of the proposed mitigation improvements are located on approaches within the City of Los Angeles, with the exception of the eastbound right-turn lane proposed at Centinela Avenue/Idaho Avenue, and a minor portion of the restriping improvement on southbound Centinela Avenue at Ocean Park Boulevard.



Comment No. 6-32


The determination of “fair share” contributions is dependent on the amount of cumulative development and the project’s specific contribution to cumulative traffic impacts. The issue of “fair share contribution” is a jurisdictional consideration between the cities of Santa Monica and Los Angeles, which would need to coordinate on and study the issues as to reasonable fair share contribution calculations between jurisdictions. It is not within the authority or power of the Applicant or lead agency to determine this cross-jurisdictional issue for a single project; nor does there appear to be a precedent for this calculation. Please also refer to Response to Comment 6-3.

Comment No. 6-33


Although, as noted by the commenter, “portions of Lincoln Boulevard function as six-lane facilities” as a result of peak hour or daily on-street parking restrictions, the proposed location (northbound Lincoln Boulevard at Pico Boulevard) is not one of them, and sufficient roadway width exists to implement the recommended mitigation measure. The proposed project traffic study (Appendix H to the Draft EIR) and Section IV.K (Traffic and Transportation) of the Draft EIR incorporated all known and/or reasonable foreseeable roadway and transit improvements into the analyses; although the Lincoln Boulevard bus-only lanes have been discussed, there is no timeline for implementation of such a program and, therefore, it was considered speculative and not included in the analyses. However, coordination between the project Applicant, the LADOT, the City of Santa Monica, and Caltrans is recommended in the development of mitigation measures that may be necessary outside the jurisdiction of the City of Los Angeles.



Comment No. 6-34







Rob Kadota, Chair Mar Vista Community Council Board of Directors P.O. Box 66871 Mar Vista, CA 90066

Comment No. 7-1

The Mar Vista Community Council has the following concerns regarding the Draft Environmental Impact Report published for the Bundy Village and Medical Park:

WATER SUPPLY

The DEIR states that “According to a Water Supply Assessment performed for the proposed project adequate water supplies would be available to meet the water demands of the proposed project. The LADWP anticipates that the projected water demands from the proposed project could be met during normal, single-dry, and multiple-dry water years, in addition to the existing and planned future demands on the LADWP. As such, no new or expanded water supplies would be necessary for the operation of the proposed project and a less-than-significant impact would occur.”

The MVCC requests that this Water Supply Assessment be re-evaluated. In light of the fact that the City of Los Angeles in April of 2009 approved “shortage year rates” for all Los Angeles Department of Water and Power (LADWP) water customers effective June 1, 2009, citing reduced water supplies due to drought and regulatory restrictions, it is imperative that a new Water Supply Assessment be conducted, and that the issue of insufficient water supplies be addressed. Clearly any increase in the population density of the area will only worsen and prolong the water crisis currently facing the City of Los Angeles. The Water Supply Assessment should examine water availability for increases in population contemplated not only by the West Los Angeles Community Plan, but all adjacent Community Plans. It should address long term regional cumulative impacts upon all residents. The MVCC recommends that no density-increasing development project be approved so long as “shortage year water rates” are in effect, and unless the City has signed contracts guaranteeing at least a twenty year water supply for existing Los Angeles residents plus the density increase effectuated by the proposed land development project.


The Water Supply Assessment (WSA) prepared for the proposed project continues to remain adequate in accordance with Sections 10910 through 10915 of the California Water Code. According to the California Water Code, the goal of a WSA is to evaluate whether the water agency’s “total projected water supplies available during normal, single-dry, and multiple-dry water years during a 20-year projection are sufficient to meet the projected water demand associated with the proposed project, in addition to the water agency’s existing and planned future uses, including agricultural and manufacturing uses.” Additionally, the current 2005 Urban Water Management Plan (2005 UWMP), which examines



water supply and demand for the City of Los Angeles as a whole, was used as a basis for the analysis found in the WSA. Therefore, all community plan areas within the City of Los Angeles were considered in the WSA for the proposed project (in Appendix G to the Draft EIR).

The current “shortage year water rates” are a reflection of drought conditions that currently affect water supply in the City of Los Angeles. The WSA has taken such a condition into consideration by reflecting multiple-dry years. Additionally, use of such rates is a recognized water demand management tool

The water usage rates in the 2005 UWMP did not take into account the type of water conservation programs proposed by the project. The proposed project would be designed to achieve LEED Silver Certification, as designated by the U.S. Green Building Council, and would result in 14 percent savings or 36 acre-feet of water annually. As noted on Page IV.L-22 in the Draft EIR, proposed water conservation features include, but are not limited to, the following:

� Water Efficient Landscaping;

� Innovative Wastewater Technologies;

� High Efficiency Clothes Washers;

� Faucet Flow Restrictors;

� Cooling Water Tower Treatment; and

� High Efficiency Toilets (for commercial uses).

According to California Water Code Section 10911(b)-(c), a WSA serves as a tool for decisionmakers during the environmental review process; it does not serve as a determination, but rather as an analysis. Upon approval by the City of Los Angeles Department of Water and Power (LADWP), the WSA was submitted to the lead agency for inclusion in the EIR, wherein the lead agency determined, based on the entire record, whether the projected water supplies would be sufficient for the proposed project in addition to existing and planned future uses. The lead agency will make this determination in the final stages of the EIR process.

Furthermore, according to a document entitled Securing L.A.’s Water Supply, published in May 2008 by the LADWP, projections for future water demand remain consistent with the 2005 UWMP. Projections of the City’s growth show that Los Angeles’ total water demand will increase about 0.4 percent annually from just under 670,000 in 2006 to 776,000 acre-feet per year (AFY) in 2030.2 The WSA also concluded, based on the 2005 UWMP, that water demand would reach 776,000 acre-feet by 2030.3

2 City of Los Angeles Water Supply Action Plan, Securing L.A.’s Water Supply, City of Los Angeles Department

of Water and Power, May 2008. 3 Water Supply Assessment for the Bundy Village and Medical Park Draft Project, City of Los Angeles

Department of Water and Power, Water Resources Division, April 26, 2007.



the proposed project.

Comment No. 7-2

Figure 4, Los Angeles Historical Water Supply Sources, found in Securing L.A.’s Water Supply, andTable II, LADWP Water Supply, found in the WSA for the proposed project, indicate that water supplied to the City of Los Angeles continues to remain consistent with water supply projections found in both the 2005 UWMP and WSA.4 5 The WSA concluded that the LADWP has adequate supplies to serve the proposed project. As such, the WSA continues to accurately project future water supplies and demand for

TRAFFIC

073 Daily Trips and 1879 Peak Hour Trips to Bundy Drive-Centinela Avenue and Olympic Boulevard,

mpic Boulevard cannot help but make what is already a very badly congested traffic situation even worse.


The DEIR states that the project is expected to add 20,

1. The MVCC is concerned that this massive increase in Daily Trips on these two major roadways in West Los Angeles, and the impact this increase will have on the intersection of Bundy Drive and Oly

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

Comment No. 7-3

Table IV.K-18, Critical Movement Analysis Summary: Study Intersections Future (2011) Plus Physical/Traffic Signal Mitigation Conditions, in Section IV.K (Traffic and Transportation) of the Draft EIR, indicates that the LOS at both the Olympic Boulevard/Bundy Drive intersection and the Bundy Drive/Centinela Avenue intersection would remain unchanged with the implementation of the proposed project. The Olympic Boulevard/Bundy Drive intersection would operate at LOS F during the AM and PM peak hours, and the Bundy Drive/Centinela Avenue intersection would operate at LOS E during the AM peak hour and LOS F during the PM peak hour. The comment reiterates the number of trips anticipated to result from the operation of the proposed project and expresses an opinion regarding the number of trips. It does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledg

vement and Mitigation Specific Plan allowed the developer to make the following invalid assumptions:

2. The MVCC believes the traffic impacts described in the DEIR and accompanying Traffic Impact Analysis Report (Appendix H of the DEIR) are understated because LADOT’s Traffic Study Policies and Procedures and the West L.A. Transportation Impro

4 Ibid. 5 2005 Urban Water Management Plan, City of Los Angeles Department of Water and Power.



lation as CEQA requires impacts to be measured under the worst conditions, which would be that all condo residents commute during the Peak Traffic Hour.

rrent baseline remaining-capacity ratings that are higher than realistic.

e. The East Bound I-10 will accommodate the project’s additional PM Peak Hour trips without

f. Too much credit was given for Pass-By trips. (See Exhibit 4.)

If real-world assumptions are used, the MVCC believes that Total Daily Trips will be closer to 23,098

Res

a. Only one-quarter of non-senior condo residents will commute during the Peak Traffic Hour. This is a CEQA vio

b. Only one in twenty-five residents over 62 will drive a vehicle to or from the project during the Peak Traffic Hour

c. Intersections will accommodate up to 75% more traffic than their physical capacity allows. (See Exhibit 1.) The over-allocations should have been spread back to prior intersections and the resulting impacts mitigated. (See Exhibit 2.)

d. Current congestion-constrained flows were mis-interpreted as current Demand on an intersection or roadway. Consequently intersections and freeways were given cu

impacting existing upstream traffic west of the Centinela on-ramp. (See Exhibit 3.)

than 20,073, and PM Peak Hour Trip will be closer to2,495 than 1879.

ponse to Comment No. 7-3

The trip generation rates utilized in the project traffic study (Appendix H to the Draft EIR) were obtained directly from nationally-recognized Institute of Transportation Engineers (ITE) data, or from the applicable WLA TIMP (for PM peak hour conditions). The ITE and WLA TIMP data is utilized throughout the study area, and the ITE data is the basis for trip generation estimates for most projects within the City of Los Angeles and nearly all other Southern California jurisdictions and throughout the United States. The ITE data are based on actual trip generation surveys of nearly 100 residential apartment developments, and are considered to accurately reflect the trip-making characteristics of such developments; no additional reductions or adjustments to the ITE/WLA TIMP data were incorporated for the residential uses. Additionally, CEQA does not require impacts to be measured under speculative “worst conditions” such as those described by the commenter, but rather, requires that all environmental impacts (including traffic) be evaluated based on reasonably foreseeable conditions; the use of the ITE/WLA TIMP trip generation data adheres to the CEQA mandate to evaluate proj

a.

ect trip generation in a manner consistent with the best available information. It is also of note that these trip rates agree with those provided by the San Diego Association of Governments, which undertook a study of regional and city-specific trip generation factors in the late 1990s and early 2000s, and as such, the trip rates used for the proposed project traffic analysis reflect local conditions.



c.

ctions, which cause much of the current congestion on the Bundy Drive corridor throughout the study area, as well as on cross streets such as

d.

n conditions in the project traffic study (Appendix H to the Draft EIR) relied on both technical analyses and visual observations within the study area to

e.n on the Santa Monica

Freeway (I-10) currently exists, and will be exacerbated by ongoing traffic growth in the future.

f.

b. Trip generation estimates for the proposed senior residential units were also based on ITE/WLA TIMP information, with no additional trip discounts or adjustments. Please also refer to Response to Comment 7-3a.

The commenter’s suggested approach is inappropriate for forecasting of future traffic conditions, and is not based on current traffic impact analysis guidelines. The current LADOT impact analysis methodology, which was used for the traffic analysis in the Draft EIR, and is similar to the methodologies used throughout the United States, is a widely-recognized planning tool that identifies those locations within a roadway network where traffic congestion issues are present (such as insufficient capacity) and should be addressed. The “spreading out” of over capacity intersection demands to upstream intersections in one or more directions results in identification of potential impacts where no real impacts or insufficient capacity issues exist, and would result in the unnecessary implementation of ineffective roadway improvements at non-impacted locations. The use of the planning methodology for forecasting traffic conditions within the area identifies those “bottleneck” intersections creating upstream congestion, and appropriate measures can be implemented to address the cause of the congestion. This approach is evident in the proposed improvements to the Bundy Drive/I-10 ramp interse

Olympic Boulevard and Pico Boulevard. Unnecessarily identifying impacts to non-critical intersections and implementing improvements at such locations would not result in improved traffic flows. Please also refer to Response to Comment 12-8.

No “mis-interpretation” of traffic volumes or intersection conditions is present in the project traffic study. Although the formation of vehicle queues along key travel corridors was observed, the evaluation of roadway and intersectio

accurately identify appropriate intersection levels of service and/or factors producing reduced capacities at the study intersections. The existing conditions analyses accurately reflect current traffic flow operations within the study area.

The project traffic study (Appendix H to the Draft EIR) and Section IV.K (Traffic and Transportation) of the Draft EIR acknowledge that significant congestio

However, the proposed project would not produce sufficient additional traffic loads to the Santa Monica Freeway to produce a significant impact as defined by the LADOT and the Los Angeles County Congestion Management Program, which is consistent with CEQA.

The pass-by trip adjustments were based on the LADOT’s current Traffic Study Policies and Procedures, which are in turn based on data contained in the ITE Trip Generation publication, and are generally more conservative (i.e., lower) than the ITE recommendations; the pass-by reductions for the restaurant (20%) and medical office (10%) are obtained directly from the LADOT recommendations, while the pass-by adjustments for the retail and supermarket components (30% each) are lower than the 40% adjustment allowed by the LADOT. The use of the conservative trip



the LADOT prior to initiation of the project traffic study, result in the estimates of daily and peak hour trips used to analyze the impacts of the proposed project. The values

mmenter are not appropriate for use in the evaluation of project impacts, and do not

Comment N

reduction assumptions described in the project traffic study (Appendix H to the Draft EIR), which were reviewed and approved by

noted by the corecognize the effects of documented trip reduction factors such as internal interaction and pass-by traffic.

o. 7-4

ore, the MVCC believes the effectiveness of proposed mitigations are overstated for the g reasons:

Furthermfollowin

et type mitigations.

other proposed mitigation may theoretically calculate out as providing a

Res

a. Motorist already perform the capacity-enhancing behavior intended by the Right Turn Pocket mitigations at the intersections where such measures are proposed. Therefore no mitigation credit should be given for Right-Turn Pock

b. Although many of the capacity increase at an individual intersection, subsequent unmitigatable downstream congestion negates the benefit. (See Exhibit 5.)


It is likely that some motorists can accomplish right-turn movements at these intersections under the current configurations, but such movement is not guaranteed, since a single “through” oriented vehicle stopped in a shared through/right-turn lane can effectively prohibit right-turns. More importantly, a right-turning vehicle that is delayed by pedestrians crossing the side street can block the higher volume through traffic at an intersection, creating substantial delays for the through traffic movement; the implementation of right-turn only lanes is an effective and recognized solution to these issues. It is also important to note that only four of the impacted inters

a.

ections are proposed for right-turn only lanes, and in no case is right-turn striping alone considered to be adequate mitigation

e and Colorado Avenue); all locations where right-turn include additional improvements such as traffic signal improvements,

ng, closed circuit TV camera installation, or other measures.

Comme

(except for the intersection of Idaho Avenulanes are proposed also roadway wideni

b. Please refer to Response to Comment 7-3c.

nt No. 7-5

Even using t

igations, including unmitigatable impacts to the following Mar Vista community intersections:

lvd./Gateway Blvd. and Bundy Drive (14% to 16% over capacity)

he under-estimated impacts and over-stated mitigation benefits, the proposed project would:

a. Leave eighteen (18) intersections at Level of Service “F” after proposed mit

� Ocean Park B



Major Highways and business districts. (The actual number of LOS “F” intersections will be closer to 60 as a result of the

b. Cause Bundy-Centinela commuters to divert to the Mar Vista residential streets of Palms oulevard and McLaughlin to reach Barrington Avenue; and divert to

Res

� National Blvd. and Bundy Dr./Centinela Av (24% over capacity AM)

This is unacceptable.

It also violates both the West Los Angeles Community Plan and the Palms-Mar Vista-Del Rey Community Plans, which state that Levels of Service are to be maintained at the Satisfactory Level Of Service of LOS “D” on Secondary Highways, or “E” on

proposed and related projects. This would have been shown in the Traffic Study if the traffic that cannot be accommodated at the eighteen over-allocated intersection had been properly shown as backing to prior intersections as in the real-world. See Exhibit 2.)

Boulevard, Inglewood BPalms Boulevard, Beethoven Street and Rose Avenue to reach 23rd Street as alternate routes to avoid Bundy Drive-Centinela Avenue.


This comment expra. esses an opinion regarding the traffic impacts resulting from the operation of the proposed project. It does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Nonetheless, Section IV.K (Traffic and Transportation) of the Draft EIR and project traffic study (Appendix H to the Draft EIR) clearly identify that a total of 18 intersections would remain at LOS F following the development of the proposed project and implementation of its recommended mitigation measures. However, 17 of these intersections (and 18 total) are forecast to exhibit LOS F conditions prior to completion of the proposed project; the project itself would only create one LOS F intersection, Olympic Boulevard and Centinela Avenue/project driveway – which would change from forecast LOS C to LOS F conditions with the addition of project traffic. However, neither CEQA, the LADOT, nor the referenced community plans require that a project improve traffic conditions that are

or LOS E, but rather require that a project reduce its ess-than-significant levels, where feasible. Additionally, refer to

mment 7-3c.

below the community plan levels to LOS Dimpacts at such locations to lResponse to Co

b. Please refer to Response to Comment 7-3c.

Comment No. 7-6

3. The Traffic Impact Analysis cited in DEIR Appendix H states that LADOT discussed downscaling the project as a “possible means to reduce the traffic impacts of the project to below significant levels. However, the applicant indicated the scope of the project is required due to the sizable demand for



re a proven fact that there is a sizable demand for additional medical services on the Westside of Los Angeles (and the MVCC has seen

ase), this would still not justify the negative traffic impacts that will be

additional medical services on the Westside of Los Angeles, particularly medical services adjacent to affordable and senior housing” The MVCC believes that even if it we

no study showing this to be the cfelt by all of the communities surrounding this development, and would not justify the negative impact on the quality-of-life of all the residents of these surrounding communities.


CEQA requires an EIR to assess a reasonable range of alternatives to the proposed project, and the project Draft EIR assesses and compares impacts associated with a range of project alternatives: Alternative A (No Project), Alternative B (Reduced Density), Alternative C (Medical), Alternative D (Industrial) and Alternative E (Reconfigured Mixed-Use). A consideration of feasibility and the ability to achieve the project objectives is also a key component of an alternatives analysis. The Reduced Density Alternative (Alternative B) reduces the proposed project development by approximately 30 percent. Yet, even with this reduction, a significant and unavoidable “operational” traffic impact following project build-out would still occur. Similarly, both Alternative C (Medical Alternative) and Alternative D (Industrial Alternative) would reduce operational traffic impacts and result in significant and unavoidable impacts.

tive that would “downscale” the project to a point that would reduce traffic impacts sis in

Proposing an alternato below significant levels, therefore, would not be result in a feasible project alternative for analythe EIR nor would it satisfy the project objectives.

Comment No. 7-7

IN CONCLUSION, the MVCC recommends that the City take the following actions:

1. Redo the Tbe acco

2. Require m

ons and roadways at Community Plan specified Satisfactory

e all project traffic with no increase in Volume demand to Capacity n 0.00, or

that requirements a. or b. can be met, or

raffic Impact Analysis using gravity-flow modeling for trips generated and those which can mmodated based on the principles of sound traffic engineering.

itigation of the newly discovered impacts that will either:

a. leave all project-used intersectiLevels of Service, or

b. completely accommodat(V/C) Ratios greater tha

c. downsize the project so

d. disallow the project.


While “gravity flow” modeling can be beneficial in replicating existing conditions on a roadway network, it does not, as noted by the commenter, assign new traffic to a roadway system based on congestion or



ince in order to calibrate the models, the side street or residential streets exhibit significant traffic “friction” factors in order to keep the

etailed reviews of the area traffic operations and travel patterns, as well as data reflecting the socio-economic characteristics of both the local vicinity and the larger

Further, there is no basis for requiring this or any project to have “zero” effect on the roadway system; all other local jurisdictions, recognize the applicability of “less than significant”

delay, or forecast future traffic operations or conditions at study intersections in this manner. Gravity-based traffic assignment models assign trips based on the locations of trip origins and destinations for any particular use (or project), and select a travel path between those two points, generally based either on the shortest path, or the shortest time (on a comparative basis) with other possible travel paths. Such models also typically do not assign “cut-through” traffic to residential streets, s

existing conditions model runs within reasonable tolerances of the actual traffic conditions. As a result, the model-based delays associated with use of residential streets generally preclude their viability as alternative travel routes. Please also refer to Response to Comment 7-3c.

However, once these travel paths are determined, neither of these assignment approaches diverts traffic from the major roadways so that intersections do not exceed their theoretical capacities – such models routinely identify intersections with higher than 1.00 V/C ratios – nor do they “spread out” the congestion to upstream locations as suggested. These models simply select an anticipated travel path for the subject new trips and assign traffic accordingly. It is important to emphasize that this is the same methodology used to assign project traffic for the project traffic study (Appendix H to the Draft EIR), except that the proposed project analysis uses a “manual” approach to the traffic assignments. However, the project traffic study methodology incorporates d

regional area to identify reasonable geographic trip distributions and discrete project traffic assignments to the area roadways. It is unlikely that a traffic model would produce substantially different results than are identified in the project traffic study.

CEQA, as well as designations regarding impacts as a criteria for analyzing potential project environmental impacts, whether they are from traffic, or other factors.

Comment No. 7-8

If the above is not done, then in order to protect MVCC residential neighborhoods from the traffic impacts that will clearly occur, the MVCC must request the Bundy Village and Medical Park project developer to make a voluntary contribution to a Mar Vista Neighborhood Traffic Management Escrow Fund to be established at the Los Angeles Department of Transportation for the development and implementation of an effective “neighborhood traffic intrusion reduction program” for Mar Vistaresidential streets (similar to the contribution to be made by the developer for such a plan for Nebraska

. The contribution should be of sufficient amount to cover full Avenue and Missouri Avenue)implementation of the developed traffic management program. This program would be developed and monitored by the developer, LADOT, CD11 Councilmember, and the Mar Vista Community Council.



ent No. 7-8Response to Comm

As described in the Draft EIR, the project would contribute an additional $200,000 to a Neighborhood Traffic Management Plan fund to identify and address both project-specific and existing/future traffic intrusion issues in the nearby residential neighborhoods. The fund would be administered by the City of Los Angeles, and specific applications of the funds are beyond the control of the project Applicant.


Comment No. 7-9




nt No. 7-9Response to Comme



Comment No. 7-10




nt No. 7-10Response to Comme


Comment No. 7-11

Exhibit 3. Trip Distribution Assignment

Even though the applicant claims that downsizing the project is not an option, “due to the sizable demand for additional medical services on the Westside”, the applicant’s traffic study assigned 35% of their traffic to reach and depart from the project via the I-10 Santa Monica Freeway. Under current City Traffic Mitigation rules, once a developer gets their traffic to a freeway, no further mitigations are required by the City.

However, the mitigations requiredfreeway cannot accommodate that additional traffic.

to get a project’s traffic to a freeway will be of no consequence if the

Although this picture of Eastbound I-10 was taken from the 14th Street Santa Monica overpass, these

y On-ramps in the PM and Off-ramps in the AM where the proposed project’s traffic would enter or exit the freeway. I-10 simply cannot accommodate this project’s traffic without further

uters back at this end of the stream.

bumper-to-bumper, 6 MPH creeping traffic conditions exist all the way to I-405. They sometimes exist as far back as Lincoln to far east of the 405, if not all the way to downtown. They always exist at the Centinela and Bund

adversely impacting existing comm


Please refer to Response to Comment 7-3e.



Comment No. 7-12

Exhibit 4. Credits for Existing and “Pass-By” Trips

The project was giving an Existing Use Trips Credit of 2,509 daily trips for offsetting trips supposedly being currently generated by Teledyne. Although the West Los Angeles Transportation Improvement and Mitigation Plan (TIMP) allows offsetting credit for trips generated by the previous usage of a site within the last four years, Teledyne was not generating any trips at the time the existing baseline trip counts were taken. Therefore the proposed project should not have been given credit for trips it will not offset. (This is another example of how Specific Plans, purportedly created to address the Westside’s elevated traffic congestion problem, actually makes it worse. In other parts of the City, Existing Trip Credits are given only when such trips existed within the last year. Another example is the fact that residential projects in the TIMP area are exempt from paying Traffic Impact Assessment Fees.)


The comment states that the Teledyne facilities were not in operation at the time the project traffic study (Appendix H to the Draft EIR) was prepared. The Teledyne facilities were in full operation at the time the traffic counts used in the analyses were conducted and, as such, credits for the removal of these existing trips are appropriate. Please also refer to Responses to Comments 7-3a and 7-3b.

Comment No. 7-13

More Trip Reduction Credits were given for “pass by” trips than seems realistic. These are shown in the table below along with my estimate of more realistic credits derived from my personal experience.

Credits Given More Realistic Credits % Pass-By Trips Trips Reduced % Pass-By Trips Trips Reduced

Medical Offices 10% 1,474 3% 465 Retail Center 30% 1,378 10% 484 Restaurant 20% 217 5% 60Supermarket 30% 1,487 10% 522

Totals 4,556 1531 Trips underestimated 3025

Therefore the Total Daily Trips to be generated by the proposed project should be assumed to be 25,607, not 20,073, or about 25% more trips that reported in the applicant’s Draft EIR and in LADOT’s Traffic Assessment Letter.


Please refer to Response to Comment 7-3f.


Comment No. 7-14





The commenter is exprrecommended mitigation measuresincluded in the project traffic study (Aimprovement drawings, and the effectiveness of each of project traffic study, us

essing an opinion regarding the feasibility and/or effectiveness of the . The feasibility of each of the proposed mitigation measures is

ppendix H to the Draft EIR) in the form of conceptual the measures is thoroughly documented in the

ing accepted traffic impact analysis techniques and evaluation thresholds. Please also refer to Responses to Comments 7-3, 7-4, and 7-5. The LADOT performed an extensive review of

ended mitigation measures, and approved those improvements identified in the Draft EIR (see the LADOT Initial Traffic Assessment letter, April 3, 2009, in Appendix H to the Draft EIR). each of the recomm



R NO. 8

TimPlanning and Land Use Committee West Los ACertified by De

COMMENT LETTE

Dagodag, Chairman

ngeles Neighborhood Council pt. of Neighborhood Empowerment: 2005

President: Jay Handal

Comment No. 8-1

Motion: The Chairman requests the BOD approve a Resolution supporting the following conditions for the Bundy Medical Village, a proposal for medical office/surgical center, senior housing (including affordable), retail and parking on the northwest corner of Olympic and Bundy.

Facts and background:

1. The large scale of the project will create many impacts that cannot be mitigated, specifically traffic.


cific concern or question regarding the adequacy of the analysis conacknowconsideration.

Comment N

The comment does not state a spetained in the Draft EIR. Therefore, a response is not required. However, the comment is

ledged for the record and will be forwarded to the decision-making bodies for their review and

o. 8-2

2. The traffic section of the draft EIR is considered incorrect and unsuitable as the basis for nd mitigations. appropriate analysis a

a. Actual traffic counts should be used instead of standards formulas.

i. Several of the neighborhood streets may have their actual current use overstated.


Traffic data for the area intersections and roadways analyzed in the Draft EIR were obtained from direct, physical counts at the subject locations, and did not rely on any “standard formulas.” As such, existing roadway use is not overstated. The methodology and details regarding the traffic study count data collection is discussed in detail beginning on Page 40 in the project traffic study (Appendix H to the Draft EIR) and Page IV.K-12 in the Draft EIR.



Comment No. 8-3

b. Traffic generation rates are based on ITE, which are not accurate for Los Angeles.

i. West L.A. is an expensive community that requires 2 employed residents per unit and as many as 1.8 car trips per rush hour (not 0.8).


area; these rates are based on a number of studies conducted throughout the United States, including California in general and Los Angeles

riety of communities throughout the socio-economic spectrum. Also, trip generation rates for the PM peak hour are based on the information contained in the WLA TIMP, which identifies trip eles-specifictrip generatioand, therefosite, and are co Responses to Comments 7-3a

The commenter is expressing an opinion that is not supported by any specific data. The use of the ITE trip generation rates is considered appropriate for the study

specifically, in a va

generation for residential (and other) uses within its boundaries. These West Los Angn rates were developed based on actual traffic counts conducted by the City and other parties

re, reflect the specific trip generation characteristics of the community surrounding the project nsidered applicable to the project itself. Please also refer to

and 7-3b.

Comment No. 8-4

c. Substitute mitigation options must be analyzed and approved as part of the EIR, to replace any mitigations that must be approved by outside agencies (specifically CalTrans [sic] and freeway approaches/exits) and may not be approved.

i. This must be done in advance, instead of approving an EIR with mitigations that may not be able to be implemented.


CE eaccepted and identify s Initial Traffic Assessment l f the mitigation measures

been reviewed and approved by the LADOT. Comments from other nica and Caltrans) are addressed in this Final EIR.

QA does not require a lead agency to identify which mitigation improvements, if any, may not b speculative alternate mitigation in advance. As noted in LADOT’

etter of April 3, 2009 (see Appendix H to the Draft EIR), all oidentified in the Draft EIR haveaffected jurisdictions (such as the City of Santa MoThe project traffic mitigation measures have been extensively analyzed for feasibility and effectiveness by the LADOT, as well as preliminarily reviewed and found conceptually acceptable by Caltrans. The Applicant will be required to coordinate the final designs and implementation of the traffic improvements with the relevant jurisdictions.



Comment No. 8-5

d. LOS designations for intersections that are 1 block apart are extremely varied (A to D, B to F, etc.). The EIR should re-analyze all intersections to determine the cause of this

or discrepancy and correct it. maj


The operations of individual intersections along a travel corridor do not necessarily need to be of similar er for the analyses to be accurate, and no corrections to the analyses are

necessary. Please also refer to Response to Comment 7-3c. magnitude (i.e., same LOS) in ord

Comment No. 8-6

e. Intersections shall be limited to 100% capacity when allocating traffic flow.

itigate the project's effect. i. The EIR should re-analyze its intersections and cap them at 100%, instead of

adding extra traffic to m


The intent of the statement that “adding extra traffic to mitigate the project’s effect” seems to be a misinterpretation of the analysis methodology; project impacts are not evaluated based on the project’s percentage of additional (future) traffic added to intersections, but rather on the incremental effects of project traffic alone on the future traffic baseline. In fact, since project impact significance thresholds decrease as baseline traffic volumes (and associated LOS) increase, the addition of additional non-project

ion makes it more likely that a project would produce a significant impact at that

Co

traffic at an intersectlocation, not less likely. Please also refer to Responses to Comments 7-3c, 7-3d, and 7-7.

mment No. 8-7

f. The fee for traffic improvements should accurately reflect the cost of those mitigations.

i. The fee of $5,000,000 may be as high as $20,000,000.


The project’s trip fees were calculated by the LADOT under the methodologies and requirements identified in the West Los Angeles Transportation Improvement and Mitigation Specific Plan (WLA TIMP); these calculations and the applicable methodologies and assumptions used are discussed in detail beginning on Page 111 in the project traffic study, and are summarized in Table 19 on Page 112 in the project traffic study (Appendix H to the Draft EIR).

Furthermore, the commenter is expressing an opinion regarding fees. The comment does not state a specific concern or question regarding the adequacy of the analysis contained in the Draft EIR.



ent is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration. Please also refer to Therefore, a response is not required. However, the comm

Response to Comment 11-3.

Comment No. 8-8

the EIR3. The disposal of hazardous waste produced by the medical project should be documented in

.

ent No. 8-8Response to Comm

The disposal of hazardous waste generated by operation of the medical component of the proposed project is addressed on Pages IV.F-26 through IV.F-27 in the Draft EIR.

Comment No. 8-9

4. In the air quality section, the EIR should study the effect of "ultrafine" particles, along with its analysis of the typical particles.


The proposed project is not a distribution center or warehouse where heavy trucks typically idle for long periods of time. Therefore, an analysis of ultrafine particulates is not required. Additionally, analysis of ultrafine particulates is typically reserved for Health Risk Assessments (HRA). Given the nature of the proposed project, an HRA is not necessary for the proposed project.

Comment No. 8-10

5. In the noise section, the effect of locating buildings close to the street should be analyzed. Traffic noise will reflect off the buildings and intrude into adjacent residential areas.


The Draft EIR analyzes off-site vehicular noise in Section IV.N, Noise. As discussed therein, none of the analyzed roadway segments in the project vicinity would exceed the City’s noise threshold pertaining to traffic-related operational noise. Further, the noise levels experienced at these roadway segments would not represent a substantial permanent increase in ambient noise levels (see Pages IV.N-25 through IV.N-

6 in the Draft EIR).2



IC COMMENTS

UCLA

C. RESPONSES TO PUBL


Ellen Carol DuBois Professor of History

[email protected]

Comment No. 9-1

I live in the small neighborhood between Bundy and Centinela, Olympic and Ohio. We have been protesting against the proposed medical center at the corner of Bundy and Olympic for several years. Now we find that, without any notice to our community, the "last notice" about this project has been posted. We object. Our tiny neighborhood is already overwhelmed by construction to the west In Santa Monica and by a series of big box stores to the east on Olympic. As it is, we can barely leave our neighborhood In the late afternoon. Please do not permit this construction.


According to Section 15087 of the State CEQA Guidelines, notice shall be mailed to owners and

in the comment is not the last notice about the proposed project, but rather the final notice regarding the Draft EIR. There will be further opportunity for public comment

detailed analysis of the proposed project’s construction-related traffic impacts. Refer to Pages IV.K-138 through IV.K-146

occupants of properties contiguous to the parcel or parcels on which the project is located. The standard procedure of the Department of City Planning (the Lead Agency) is to distribute project notices to owners and occupants of properties within 500-foot radius of the project site as well as anyone who requests notification. Without a mailing address, it is not possible to verify whether or not the commenter is on the distribution list.

In addition, the notice referenced

during the public hearings, which take place prior to the decision making process. Notice of these public hearings shall be mailed to owners and occupants of properties within a 500-foot radius of the project site.

Regarding construction, refer to Pages IV.K-29 through IV.K-39 in the Draft EIR for a

in the Draft EIR for a discussion on the proposed project’s traffic-related impacts after mitigation.



Fox Television Stations, Inc.

Los Angeles, CA 90025-5235


Lisa R. Rafferty, Vice President Legal Affairs

1999 South Bundy Drive

Comment No. 10-1

On behalf of Fox Television Stations, Inc. ("Fox"), we submit for your consideration the following comments to the Draft Environmental Impact Report (the "Draft EIR") submitted for the above-referenced project (the "Project") by Westside Medical Park, LLC ("Applicant"). Fox currently operates television stations KTTV and KCOP at a facility located at 1999 South Bundy Drive (the "Fox Television

partment of City Planning dated December 12, 2006, a copy of which is ;attached hereto, and these concerns have not yet

inary.

Facility"), which is bordered by the proposed Project to the north and to the west.

Fox set forth a complete summary of its concerns about the Project in its letter to the De

been resolved. Prior to submitting this letter, Fox had an initial meeting with the Applicant to discuss the potential problems that the Project raised for the Fox Television Facility. Given the early stage of the Project at the time, however, the meeting was very prelim

In addressing the impact on Fox and the Fox Television Facility, the Draft EIR says "The Applicant is working with the owners of the television facility to resolve these potential issues." See Draft EIR, p. IV.G-28. However, Fox has had no meetings or other communication with the Applicant other than the one meeting in 2006. Fox would welcome the opportunity to resolve these matters with the Applicant; however, this simply has not yet occurred.


ative to determine location of

A Scoping Meeting for the proposed project that was held on November 30, 2006, and a letter dated December 12, 2006 from commenter was received and considered by the Department of City Planning during preparation of the Draft EIR. The Applicant has also indicated that it had several meetings and telephone communications with Fox Television Stations, Inc. (Fox) in 2007, as follows:6

� January 11, 2007 – Telephone call with Fox KTTV representative to set up meeting to discuss December 12, 2006 letter.

� January 17, 2007 – Telephone call with Fox KTTV representmeeting.

6 Letter correspondence to Diana Kitching, Department of City Planning, from Lori Garcia, Vice President, Westside Medical Park, LLC, September 30, 2009.



pplicant met with commenter’s Vice President (Real Estate) and commenter’s attorneys. Applicant agreed to follow-up meeting with Applicant’s architect to

7 – Applicant sent follow-up letter to commenter’s Vice President (Engineering & Operations) regarding follow-up meeting with commenter’s New York senior technical staff.

Los Angeles.

� January 17, 2007 – A

further review and resolve technical issues raised.

� February 14, 2007 – Scheduled meeting postponed and rescheduled for April 5.

� April 5, 2007 – Applicant and Applicant’s architect met with commenter to discuss technical issues, including potential interruptions in microwave transmission due to building heights and traffic-related access issues. Applicant proposed a variety of feasible mitigation measures, including transmission studies, possible relocation of transmission equipment on roof of proposed project, and internal driveway access. Applicant agreed to follow-up meeting with commenter’s senior technical staff during week of April 30.

� May 23, 200

Applicant also requested commenter to identify remaining issues to be resolved.

� June 25, 2007 – Applicant received letter from commenter, which included a copy of their letter dated December 12, 2006. Meeting with Fox senior technical staff did not occur during week senior staff was scheduled to be in

Therefore, at the time that the Draft EIR was being prepared (in 2007), the Applicant was continuing to work with commenter on potential land use compatibility issues and the text referred to in this comment on Page IV.G-28 in the Draft EIR is accurate. Further, the Applicant has indicated a willingness to resume communications on any outstanding issues that have yet to be resolved with the commenter.

Comment No. 10-2

The Draft EIR only acknowledges one of the concerns Fox raised in its December 12, 2006, letter; it has failed to address the first and most important issue, i.e., that the proposed Project would interfere with the

e look forward to working with the City and the Applicant to ensure that these concerns are addressed as the Project moves forward.

microwave and satellite equipment on the roof of the Fox Television Facility. KTTV and KCOP are both licensed by the Federal Communications Commission ("FCC"), whose mission is to "promot[e] safety of life and property through the use of wire and radio communications." 47 U.S.C. § 151. To this end, FCC-licensed stations transmit critical information to the general population, particularly in times of crisis. The proposed Project could block approximately 40% of Fox's microwave signals, preventing operation of these stations' critical information gathering activities. Currently, the Draft EIR fails to address this significant issue directly affecting the entire population of Los Angeles.

Thank you for the opportunity to respond to the Draft EIR. W




Page IV.G-28 in the Draft EIR addresses a potential land use compatibility impact due to the potential interference with satellite transmission equipment operations and the television facility with the proposed project’s use of medical equipment in Buildings D and E (Parcel B), or vice versa. In addition, the Draft EIR addresses a potential land use compatibility impact between the operation of the televisiontransmission equipment and the operation of electronic devices (e.g., satellite television, Internet, or other

posed residential units. The Draft EIR concludes that proposed project is not anticipated to result in a significant impact with respect to land use compatibility with the adjacent

-1 and G-2 are recommended to reduce potential land use ween the proposed project and the adjacent television facility (see Page IV.G-58

ection V, Mitigation Monitoring Program, in this Final EIR).

transmission equipment) in the pro

use. Nonetheless, Mitigation Measures Gcompatibility issues betin the Draft EIR and S

Comment No. 10-3

On behalf of Fox Television Stations, Inc. ("Fox"), we submit the following comments for consideration as part of the scoping process for the preparation of the environmental impact report ("EIR") of the

ox currently operates television stations KTTV and KCOP at a ("Fox Television Facility"), which is bordered by the proposed

d Project will essentially surround the Fox Television Facility, Fox is naturally al environmental impacts of the proposed Project. Thus, Fox requests that the

above-referenced project ("Project"). Ffacility located at 1999 S. Bundy DriveProject on the north as well as to the west.

Because the proposeconcerned with the potentiproposed Project's EIR specifically respond to Fox's environmental concerns, which include but are not limited to the issues set forth below. Because of Fox's proximity to the Project and the nature of Fox's business at the Fox Television Facility--unique among surrounding landowners--there are several issues that are of particular concern to Fox.


The Draft EIR addresses and, in some cases, fully mitigates potential impacts that would affect the area ell as the surrounding region. The various analyses contained in the

o the Fox Television Facility as well as other land uses in the surrounding the project site as wDraft EIR consider potential impacts timmediate and surrounding areas. Specific issues brought up in this letter and in the comment letter submitted by the commenter during the Notice of Preparation review period are addressed throughout the Draft EIR, and are addressed in the responses below. For example, Page IV.G-28 in the Draft EIR addresses a potential land use compatibility impact due to the potential interference with satellite transmission equipment operations and the television facility with the proposed project’s use of medical equipment in Buildings D and E (Parcel B), or vice versa.

Comment No. 10-4

Operations.



ox's send and receive microwave capacity will be blocked by the Project. This will interfere with Fox's ability

1. The Fox Television Facility is three stories tall, with microwave and satellite equipment on the roof. Because of the proposed height and proximity of the Project, it is likely that approximately 40% of F

to utilize these FCC-licensed facilities and to engage in newsgathering and dissemination activities that are an essential part of its mission as a broadcaster. An illustration showing the projected impact of the Project on this essential aspect of Fox's operations, prepared by Fox's engineering staff, is attached.



Comment No. 10-5

2. Similarly, the operation of medical equipment that is operated by tenants of the Project may interfere with the signals being transmitted or received by Fox's rooftop microwave equipment. An impact can also be expected on satellite reception, satellite, news van communications radios, wireless microphones, and intercoms that Fox operates in and around the Fox Television Facility.



Comment No. 10-6

his is particularly critical in the case of news vans that are being dispatched stations at the Fox Television Facility were purposely located

e reasonable expectation behind choosing this location was that news

3. Increased traffic related to the Project (both during construction and, more importantly, once the Project is in operation) will have an adverse impact on the ingress and egress of employees and visitors to the Fox Television Facility. Tto the scene of breaking stories. The news near the 405 and 10 freeways. Thvehicles could depart, access major highways and roadways, and return with news materials all in the timely manner 'that the business of news coverage requires.


With respect to potential construction-traffic impacts, the Draft EIR includes an analysis of potential impacts during all construction phases of the proposed project on Pages IV.K-29 through -3 IV.K 9. As discussed therein, construction of the proposed project would result in less-than-significant impacts to

ity are Study Intersection No. 24, Missouri Avenue/Project Driveway and Bundy rsection No. 25, La Grange Avenue and Bundy Drive (see Figure IV.K-1, Locations

Study Segments, in the Draft EIR). As shown in Table IV.K-18, Critical nalysis Summary: Study Intersections Future (2011) Plus Physical/Signal Mitigation

traffic and transportation during all three phases (i.e., demolition, excavation, and construction). With respect to potential operational traffic impacts, Section IV.K, Traffic and Transportation, of the Draft EIR includes an analysis of potential impacts to 64 study intersections. The closest study intersections to the Fox Television FacilDrive, and Study Inteof Study Intersections andMovement A



th study intersections would be less than significant.

With respect to specific traffic-related impacts on the Fox television facility, it should be noted that

Measures, on Page IV.K-140 in the Draft EIR, Study Intersection Nos. 24 and 25 would both experience significant impacts following the implementation of mitigation measures during the PM peak hour.

With respect to access to the Santa Monica Freeway (I-10) and San Diego (I-405) Freeway, the Draft EIR includes an analysis of two intersections associated with Santa Monica Freeway, Study Intersection No. 55, Bundy Drive (northbound) and I-10 WB Off-Ramp, and Study Intersection No. 56, Bundy Drive and I-10 EB On-Ramp. As shown in Table IV.K-18 in the Draft EIR, following mitigation, impacts to bo

neither State nor local law provides that the rights of one private landowner prevail over the rights of another private landowner, except in accordance with uniformly applied standards and policies in the City’s General Plan and Zoning Code. Moreover, CEQA requires analysis of whether the project will affect the environment of persons in general, not whether a project will affect particular persons. While CEQA does require analysis of sensitive receptors, which for air quality analyses include children, the elderly, and the acutely and chronically ill, employees and visitors are not considered to fall within this category. The commenter’s concerns regarding potential project impacts at intersections potentially utilized by commenter’s news vans have been studied and discussed in the Draft EIR and project traffic study, as cited herein.

Comment No. 10-7

4. During the construction period for the Project, it is likely that dirt and debris, noise, and vibration will have negative effects on Fox's operations. Noise and vibration are likely to interfere with live broadcast operations, and dirt and debris can damage the large amounts of sophisticated and sensitive electronic equipment operated by Fox.


This comment addresses potential dirt, debris, and noise and vibration impacts that may affect the Fox Television Facility during construction of the proposed project. With respect to potential dirt and debris construction impacts, the Draft EIR includes mitigation measures that are recommended pursuant to requirements under SCAQMD Rule 403. Pages IV.C-61 through IV.C-62 in the Draft EIR includes

mitigation measures are otential vibration impacts at the Fox Television Facility, the impacts would be

Mitigation Measures C-1 through C-11 and Mitigation Measure C-13, which would reduce potential dirt and debris impacts (see also Section V, Mitigation Monitoring Program, in this Final EIR).

With respect to potential noise and vibration construction impacts, the Draft EIR addresses potential impacts to the Fox Television Facility on Page IV.H-25. While no feasibleavailable to reduce ptemporary in nature.

Comment No. 10-8

Construction



sinesses. These include the potential impacts of traffic, noise, air quality (caused by both debris and construction vehicles), emergency response, and parking. Consideration

effect of the construction process on the soil and geological stability of

s.


Fox has additional concerns regarding the construction period for the Project, presumably similar to those of other nearby residents and bu

should be given in the EIR to the the area surrounding the Project. Construction could also lead to interruptions with electrical service and domestic water and fire flow conveyance. Excavation and remediation of hazardous materials at the proposed Project site during construction could cause potential health issues to Fox's staff and visitor

The Draft EIR addresses potential traffic and parking impacts in Section IV.K, Traffic and Transportation, potential noise impacts in Section IV.H, Noise, potential air quality impacts in Section IV.C-21, Air Quality, and potential emergency response impacts in Section IV.J, Public Services. With respect to construction of the proposed project and geologic stability of the area, as stated on Page IV.E-9 in the Draft EIR, the proposed project would be required to be constructed in accordance with City of Los Angeles building regulations as well as any site specific recommendations of the Department of Building and Safety. Additionally, Page IV.E-9 in the Draft EIR indicates that construction of the proposed project would implement the recommendations of the Preliminary Geotechnical Investigation, Proposed Medical Office Buildings and Mixed-Use Development, 12333 Olympic Boulevard and 1901 to 1933 Bundy Drive, Los Angeles, CA and the Geotechnical Engineering Investigation, Proposed Medical Park 12333 Olympic Boulevard and 1901 to 1933 Bundy Drive, Los Angeles prepared by Geotechnologies, Inc on February 7, 2007 and May 23, 2008, respectively. Both reports, which are included in Appendix D to the Draft EIR, include site-specific construction recommendations to address potential impacts to geology and soils during construction activities.

The Draft EIR indicates (in Section IV.D, Energy, and Section IV.L, Utilities) that construction of the proposed project would not interfere with electrical service or domestic water or fire flow conveyance. Furthermore, the Water Operations Division of the LADWP will perform a fire flow study at the time of permit review in order to ascertain whether further water system or site-specific improvements would be necessary (see Page IV.J-8 in the Draft EIR). With respect to electricity, the LADWP has indicated that it would be able to accommodate the proposed project’s demand for electricity supplies (see Pages IV.D-3 through IV.D-4 in the Draft EIR).

With respect to hazardous materials, as discussed in Section IV.F, Hazards and Hazardous Materials, of the Draft EIR, hazards and hazardous materials impacts during project construction would be less than significant with the implementation of mitigation measures (to ensure that there is no accidental release of soil contaminants, asbestos, lead-based paint, and polychlorinated biphenyls).

Comment No. 10-9

We thank you for this opportunity to comment on the scope of the proposed Project's EIR. We look forward to seeing these and all other areas of possible environmental impact adequately addressed in the



f any and all future public correspondence or notices from the City regarding the proposed Project.

o. 10-9

EIR. Please provide us with copies o

Response to Comment N

ent of City Planning, as the lead agency for the proposed project, shall continue to provide Fox Television Station, Inc. with all future public notices regarding the proposed project. The Los Angeles Departm




Aric Gregson, MD Xochitl Gonzalez, MFA 1726 Amherst Avenue Los Angeles, CA 90025

Comment No. 11-1

Enclosed is our letter describing our serious concerns regarding the impact on our neighborhood of the Subject line referenced project. This is our second letter in regards to this project and the negative impact it will have upon our neighborhood.

Thank you for your consideration.

We are writing in regards to the proposed project "Bundy Village and Medical Park" and the EIR No. ENV-2006-3125-EIR. The project Site Location is given as 1901, 1925, 1933 S. Bundy Drive and 12333 W. Olympic Blvd in Los Angeles. The project, as proposed, will completely destroy our low density, single-family detached, largely owner occupied neighborhood. Our neighborhood is located immediately north of the proposed project and is bordered by Nebraska Avenue to the south, S. Bundy Drive to the east, Idaho Avenue to the north and Centine1a Avenue to the west.

The proposed project will 1) increase shortcut car traffic onto our quiet residential streets, 2) flood our streets with overflow parking for both the residences and the retail/commercial use, 3) create a dense cluster of market-rate rental units to undermine the quality of life and property-values of our single-family detached, owner-occupied neighborhood, 4) markedly increase traffic on S. Bundy Avenue which already suffers from some of the worst traffic congestion in West Los Angeles. 5) increase noise and air pollution from retail/commercial and residential traffic and over-flow parking. and 6) increase noise from high density, multifamily residential and retail/commercial space.


With respect to the comment that states, “The project, as proposed, will completely destroy our low

mited to: existing single-family residential neighborhoods from out-of-scale

le uses”; and Policy 1-1.3, which states “Provide for adequate multi-

density, single-family, detached, largely owner occupied neighborhood,” as demonstrated in Table IV.G-5 in Section IV.G, Land Use and Planning, of the Draft EIR, the proposed project would be consistent with applicable land use policies of the West Los Angeles Community Plan including, but not liPolicy 1-1.1, which states “Protectdevelopment and other incompatibfamily residential development.” Furthermore, the adjacent residential areas to the north and east of the project site are buffered from light industrial land uses by the proposed mixed-use building on Bundy Drive, which includes compatible multi-family residences.

As discussed on Pages IV.K-51 through IV.K-57 in the Draft EIR, the proposed project would provide more parking (158 spaces, with valet) than is currently required by City of Los Angeles Municipal Code



h reduced parking is provided for the proposed senior residential units, as allowed by the LAMC, it should be noted that overall, the project provides an average of more than 1.7 parking

The project traffic study, in Appendix H to the Draft EIR, and summarized in Section IV.K, Traffic and

e traffic analysis mpacts to Amherst Avenue are anticipated. Additionally, the Draft EIR and

dy note that the project access to and from Nebraska Avenue would be controlled

cts (see Page IV.H-32). With respect to air with the proposed project, this issue is discussed in Section IV.C, Air V.C-49 in the Draft EIR).

(LAMC) and City Advisory Agency (3,111 total spaces required versus 3,395 total spaces provided). Additionally, althoug

spaces for each residential unit. As such, all project parking demands for both the residential and commercial components of the project can be accommodated within the project site, and off-site parking within the nearby residential neighborhoods is not anticipated.

Transportation, of the Draft EIR, investigates not only the access-related elements of the project’s traffic, but also its impacts on the surrounding streets and highways as well, including an analysis of potential traffic impacts on nearby local/residential streets, including Nebraska Avenue north of the project site (between Bundy Drive and Centinela Avenue), and Amherst Avenue. The results of thindicate that no significant ithe project traffic stuand limited to emergency vehicles only and will not be open for general traffic egress or ingress. Further, mitigation measures to address potential project impacts to Nebraska Avenue and other local/residential streets in the area are identified, including a additional $200,000 Neighborhood Traffic Management Plan fund to identify and address both project-specific and existing/future traffic intrusion issues in the nearby residential neighborhoods. Please also refer to Responses to Comments 7-7 and 7-8.

With respect to the undermining of the quality of life in the area, as discussed above, the Draft EIR demonstrates the proposed project’s consistency with applicable land use policies of the West Los Angeles Community Plan. With respect to a reduction in property values, this comment is not considered to be an environmental issue that is subject to analysis under CEQA. With respect to increased traffic along South Bundy Boulevard, this issue is analyzed in Section IV.K, Traffic and Transportation, of the Draft EIR. With respect to an increase in operational noise, this issue was analyzed in Section IV.H, Noise, and concluded to result in less than significant impapollution from land uses associatedQuality, of the Draft EIR (see Page I

Comment No. 11-2

We applaud the idea of development that combines affordable housing, retail and commercial space, but the proposal here was developed without the least regard for the surrounding neighborhood. As such, the safety, quality of life and property values of our neighborhood are jeopardized by this proposal.


Regarding safety, refer to Pages IV. J-11 and IV.J-20 in the Draft EIR, which conclude that the proposed project’s impacts on fire and police protection services would be less than significant. Refer also to Page IV.F-26 in the Draft EIR, which concludes that the proposed project’s impacts associated with hazards and hazardous materials would be reduced to less-than-significant levels with implementation of the Mitigation Measures F-1 through F-9, and Page IV.F-59 in the Draft EIR, which concludes that the



iated with exposure to electromagnetic fields would be less than significant.proposed project’s impacts assoc

With respect to potential environmental impacts on the surrounding neighborhood, the Draft EIR analyzes these impacts throughout the relevant sections, including, but not limited to: Section IV.B, Aesthetics; Section IV.C, Air Quality; Section IV.F, Hazards and Hazardous Materials; Section IV.G, Land Use and Planning; Section IV.H, Noise; and Section IV.K, Traffic and Transportation.

The remainder of the comment refers to concerns that are not subject to environmental review under CEQA, and does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 11-3

The traffic flow into and out of the project was not considered by the planners except for ease of circulation within the project. The proposal lacks any concern for the traffic considerations outside of its boundaries, a position the City of LA can no longer find tenable given the atrocious traffic conditions in

f most concern to our neighborhood is the direct exit from the north of the project herst Avenue. The placement of an exit onto Nebraska/Amherst will

West Los Angeles. Oonto Nebraska Avenue at Amencourage traffic to use the two blocks of Amherst as a short-cut to avoid Bundy Drive at peak traffic times. This will have a lasting impact, as drivers accustomed to using the exit during congested times will continue to use it at all other times as well. This will dramatically increase traffic on Amherst Avenue. The outlet from Amherst Avenue to Ohio Avenue is a single lane with poor visibility in an area where children routinely play and ride their hikes. Adults walk the sidewalks and streets of this neighborhood precisely because there is little traffic through it. Our neighborhood is a very unique and precious resource in this highly congested area of West Los Angeles.


With respect to short-cut traffic, please refer to Response 11-1.

Comment No. 11-4

Car exits onto Bundy Drive are placed at 1) Missouri Avenue/Bundy Drive, which is presently a signal ) another 100 yards (?) south of this signal in the middle of the

d, it turns into a 50 mph speedway, on which the

without traffic entering from the west, 2block and 3) a further 150 yards (?) south at the lower third of the block, about 15 yards before the signal at La Grange Avenue/Bundy Drive. It is difficult to imagine having the congested Bundy Drive take three further traffic merges, two of them without signals and within the space of one block between two existing signals. When Bundy Drive is not congesteLAPD fails to patrol and adequately enforce the speed limit (35 mph along single-family detached housing and a narrow sidewalk). Having more non-signaled traffic pull onto this speedway is dangerous. The only exits that should be allowed are/he exits along Bundy Drive at existing signals (Missouri and La Grange Avenues) and the exit at Olympic Avenue at the Centinela Avenue/Olympic Blvd signal.




The project proposes only two vehicular access locations on Bundy Drive, one at the currently signalized ssouri Avenue, and the other at the project’s southern boundary just north of La

Grange Avenue. This southern access driveway is unsignalized, and as described in detail in the project

enter is a pedestrian promenade, which prohibits emergency vehicles. No new vehicular access points along Bundy

ested by the commenter, the only project access locations (with the

intersection with Mi

traffic study (Appendix H to the Draft EIR), would be restricted to right-turn exits only; a two-way median left-turn lane would be provided to accommodate northbound left-turn traffic into the project site, so that such project-related traffic does not block northbound through traffic on Bundy Drive. Also, this southernmost driveway currently exists, and provides access to the existing large surface parking lot formerly used by both the Teledyne and office developments to be removed by the project, as well as to the existing surface parking facilities for those existing commercial developments to the north of the project site. The third “access point” noted by the commvehicular access with the exception ofDrive are proposed, and as suggexception of the Nebraska Avenue emergency vehicle access) would be on Bundy Drive at Missouri Avenue, near La Grange Avenue, and on Olympic Boulevard opposite the southern leg of Centinela Avenue.

Comment No. 11-5

Parking will be an issue for the project, it is unrealistic to imagine otherwise. With ample free, two-hour parking in our neighborhood and easy access to the project from Nebraska and Amherst Avenues who will pay for parking within the project? Who will fight with the Bundy and Olympic traffic to get to the provided parking structures? Closure of the car exit onto Nebraska Avenue from the north of the project

but will do nothing to prevent parking on our blocks es from persons walking into the retail, commercial and residential areas of the

will do much to decrease traffic in our neighborhood, in front of our homproposal. Our block allows overnight parking, thus persons that need to stay overnight as guests, but cannot park within the project because of insufficient spaces or because of cost/convenience, will park in our neighborhood. It is unrealistic to say that there will not be overnight guests that park in our neighborhood. We will bear the brunt of unattended car alarms, persons walking back and forth to their cars at all hours of the morning and night creating noise. If bars and restaurants are eventually permitted within the project we will hear the noise pollution from drunk guests walking back to their parked cars. Solutions that prevent this from happening must be in place before the project is allowed to proceed.


As discussed in Response to Comment 11-1, the proposed project would provide more parking (158 spaces, with valet) than is currently required by City of LAMC and the City Advisory Agency (3,237 total spaces required versus 3,395 total spaces provided).

With respect to noise, the proposed project would comply with the City’s noise ordinance (Chapter XI of the LAMC), which sets forth sound measurement and criteria, maximum ambient noise levels for different land use zoning classifications, sound emission levels for specific uses, hours of operation for



certain uses, standards for determining when noise is deemed to be a disturbance to the peace, and legal remedies for violations.

Comment No. 11-6

On paper the parking allotments meet code given the percentage of senior housing. However, how will the percentage of senior housing be enforced once the project is permitted? Does the city have a guarantee that the housing will only ever be made available to seniors? Over the years it is likely that the number of market-rate units will increase to maximize profitability. The required 1.25 parking spaces for senior housing will not be adequate if the 208 units designated for senior use are later converted to market-rate apartments. Even if it remains 54% senior units, adult children cannot be prevented from moving back in and then the 1.25 parking/senior unit will be inadequate.


The commenter’s concern regarding the prospect of converting senior housing to unrestricted housing is considered to be speculative, and does not need to be incorporated into the analysis presented in the Draft EIR for the proposed project. If the project Applicant desires to convert senior housing into unrestricted housing in the future, this action would be subject to additional discretionary review, and action to assure that all project traffic mitigation and on-site parking supplies are adequate to accommodate such changes. However, as noted in the Draft EIR and project traffic study (Appendix H to the Draft EIR), the proposed project provides substantially more parking (both overall and for project residents) than is required and, therefore, some changes in residential use (from senior to unrestricted housing) could be accommodated without parking deficiencies. Please also refer to Response to Comment 11-1.

Comment No. 11-7

There is no way to get around Wepersons feel comfortable enough to rid

st Los Angeles other than by car. The bus service is horrible and few e their bikes on the congested streets that nearly all lack bicycle

lanes. However, to encourage alternative transportation methods for the project, dedicated bus stops with turn-outs off of Bundy and Olympic must be provided along both of these streets. Additionally, adequate and highly visible bicycle parking must he made available to encourage biking to and from this project. The City should do its best to encourage alternative means of transportations to ease the traffic before a project is built, not after.


The Draft EIR includes mitigation measures to encourage alternate forms of transportation, including bicycle riding and the use of public transit (see Section IV.K, Traffic and Transportation, in the Draft EIR). Furthermore, the project proposes a number of trip reduction measures, both project-specific and area-wide, in order to promote increased use of transit and/or alternative transportation modes throughout the project vicinity and the Westside of Los Angeles, including an additional developer contribution of $1,000,000 to the Expo Line light rail project and/or other transit improvements in the area, as part of the



ditional developer contribution to overall transportation improvements in the project vicinity. This additional developer contribution is not part of the $5,000,000 in WLA TIMP fees.

agement (TDM) program as well as coordinate the formation of an area wide Transportation Management Organization (TMO) program,

rip reduction strategies for member developments in the local project

ment No. 11-8

overall $2,200,000 ad

In addition, in order to promote reduction in traffic volumes and congestion within the project vicinity through ridesharing and carpool/vanpool utilization as well as increased transit ridership, the project will implement both a project-specific Transportation Demand Man

which will develop and oversee tarea. Mitigation Measure K-23 would implement a TDM program, which would include, but not be limited to, carpool incentives, ride share matching, bicycle racks and lockers, and variable work shifts (see Section V, Mitigation Monitoring Program, in this Final EIR).

Com

not be any car exit north of the project onto Nebraska Avenue into our neighborhood. urthermore, overflow parking must be absolutely prevented in our neighborhood. Our neighborhood

should not bear any of that burden. To best keep traffic along Nebraska Avenue to a minimum and to prevent Nebraska from becoming a shortcut from Centinela and Bundy to the project, there must be no exit to Nebraska from the project Drivers already use the two blocks of Amherst Avenue as a shortcut from Idaho/Santa Monica to lower Bundy Drive. Once this project is allowed such traffic will increase enormously and in fact will be encouraged by the project exit onto Nebraska Avenue. To encourage reduced speed along our block from the increased Bundy shortcut traffic that arises from this proposal, a landscaped median should be placed down the middle of the 1700 block of Amherst Avenue along with speed bumps. The only potential alternative to prohibiting exit onto Nebraska Avenue from within the project is to block car traffic from the 1700 block of Amherst onto Nebraska with a landscaped walkway. This will prevent shortcut traffic along our block.


There must F

Amherst Avenue is currently developed with a roadway width of approximately 40 feet; installation of the suggested median island would likely reduce the useable roadway width such that existing on-street parking would need to be removed, resulting in unnecessary secondary impacts to the residents of this street. Additionally, the LAFD requires that roadways maintain a minimum clear roadway path of 20 feet. The installation of a median island would reduce the usable roadway width below this requirement, and would, therefore, not be recommended. Further, while the installation of speed humps is an effective means of reducing travel speeds on local streets, this measure is not designed to reduce traffic volumes on such roadways. Additionally, installation of speed humps requires a petition signed by at least 75 percent of the residents whose homes front on the affected segments of roadways proposed for the installation of such devices. As noted in the project traffic study (Appendix H to the Draft EIR) and Section IV.K, Traffic and Transportation, of the Draft EIR, the proposed project is not expected to result in significant impacts to Amherst Avenue. However, installation of speed humps, if approved by the local residents, could be part of the neighborhood traffic intrusion reduction program proposed by the project.



Comment No. 11-9

Again, our neighborhood is a where neighbors walk daily and children rits taxes rather than commutbe allowed to negatively impact the benefi

single-family residence, owner-occupied area with a high quality of life ide their bikes and play. We choose to live in the City and pay

e because of the benefits this neighborhood offered. This project should not ts of this neighborhood.





COMM

John T.Senior VKilroy R12200 W. Olympic Boulevard, Suite 200

ENT LETTER NO. 12

Fucci, CPM, RPA ice President Asset Management ealty Corporation

Los Angeles, CA 90064

Comment No. 12-1

Kilroy Realty Corporation ("Kilroy"), a publicly traded Real Estate Investment Trust (NYSE:KRC), is the owner of 135 properties in Southern California, totaling over 12.5 million square feet. Of those properties, Kilroy owns office buildings in West Los Angeles directly across the street from the proposed Bundy Village and Medical Park project.

� 12312 West Olympic Boulevard 78,000 square feet

12100 West Olympic Boulevard 150,167 square feet

� 12200 West Olympic Boulevard 150,302 square feet

�

The above three buildings owned by Kilroy, bounded by Olympic Boulevard, Bundy Drive, Exposition Boulevard right-of-way, and Centinela Avenue, are known as "Westside Media Center", which is a creative-arts office campus serving film, television and music industry clients, totaling 376,469 square feet.


The comment does not state a concern or question regarding the adequacy of the analysis contained in the required. However, the comment is acknowledged for the record

to the decision-making bodies for their review and consideration.

Comme

Draft EIR. Therefore, a response is not and will be forwarded

nt No. 12-2

ts to the Draft EIR for the Bundy Village & Medical Park project are as follows:

The nearby streets, intersections, area freeways and roadway network near this Project cannot handle an additional 20,073 net new daily traffic trips that the Project would generate. The intersection of Olympic and Bundy is already projected, per the DEIR, to deteriorate to a Level of Service "F"

Our commen

1.

during both AM and PM peak in 2011 (less than 2 years from now) without the Project ever being developed. The DEIR concludes that with the Project and even with mitigations, this intersection will still be at Level of Service "F" in both the AM and PM peaks once the Project is operating.



lternative, studied in the EIR, or an even smaller project, should be developed instead, that generates significantly less traffic, in order to prevent what will otherwise The "Reduced Density" a

result in traffic gridlock in this area. It is unfair to burden existing area property owners, both commercial and residential, with a Project that will bring a staggering 10-fold increase in traffic to this area of Los Angeles.


Current project traffic impact and mitigation procedures applicable to both local (LADOT) and regional conditions do not require that a project reduce intersection levels of service to acceptable (LOS D or better) at locations that are currently or are forecast to operate at unacceptable (LOS E or LOS F) conditions prior to the development of the project, but rather require the project to mitigate, to the extent feasible, its specific impacts to subject intersections. The project proposes a number of both local and

vements to address to the extent possible its own impacts. Please also refer to Response to Comment 1-11.

The commenproposed pro(Appendix H

As discDensity impact would be experienced by the study intersections, which would be similar to the proposed project. The proposed project would have

ns after mitigation, while the reduced Density Alternative would have

regional traffic impro

ter’s statements regarding the “10-fold increase in traffic” in the area as a result of the ject are opinion, and are not supported by the analyses contained in the project traffic study to the Draft EIR) or Section IV-K, Traffic and Transportation, of the Draft EIR.

ussed in Section VI, Alternatives to the Proposed Project, of the Draft EIR, under the Reduced Alternative, a significant and unavoidable traffic

significant impacts at 21 intersectiosignificant impacts at 16 intersections after mitigation (see Page VI-28 in the Draft EIR). Furthermore, impacts associated with local/neighborhood streets, Congestion Management Program consistency, project access, and parking, under the Reduced Density Alternative would all be similar to the proposed project.

Comment No. 12-3

2. Traffic counts, which were the basis for the traffic study, were taken over three (3) years ago - in March and April 2006, for 64 intersections. (Recounts were taken during 2007 of only 12 of the 64 intersections.) Those old traffic counts, for example, show the intersection of Olympic & Bundy as being at LOS "E" in both the AM and PM peak travel times as "existing conditions". A visit to this intersection during either peak travel times today would reveal a much worse Level of Service. Other than a brief window of time during the middle of the day, Monday through Friday, this intersection is already in a complete failure or gridlock situation.

Fresh traffic counts should have been taken prior to the DEIR being circulated. Instead, the DEIR is relying on out-of- date counts. New counts should be taken before the EIR is finalized.




The use of the traffic count data contained in the project traffic study (Appendix H to the Draft EIR) is parison of this data with current traffic volume7 information collected at several key

intersections in the study area which reflect the overall traffic conditions in the vicinity. As identified in the project trtraffic impacalong severalin the 2006 tcontained in the project v ix H to the

supported by the com

affic study, these “correlation” counts indicate that the traffic data utilized in the project t analyses accurately represent current conditions and, in fact, show that traffic volumes of the transportation corridors in the project vicinity were reduced from the levels exhibited raffic data. The LADOT conducted a thorough review of the “baseline” traffic count data the project traffic study, and indicated that it adequately describes the traffic conditions in icinity (see LADOT Initial Traffic Assessment letter, April 3, 2009, in Append

Draft EIR).

Comment No. 12-4

3. Likewise, the Bundy Drive and I-10 Eastbound on ramp intersection is shown in the DEIR as having a Level of Service "B" in both the AM and PM peak. Again, a visit to this intersection during either peak travel times today would reveal a much worse Level of

o. 12-4

Service - certainly closer to Level of Service "F" in both the AM and PM peak periods.

Fresh traffic counts in 2009 should have been taken prior to the DEIR being circulated. New counts should be taken before the EIR is finalized.

Response to Comment N

The comBundy Dat this location and, inde y area, as

ct traffic study (Appendix H to the Draft EIR) and in Section IV.K, Traffic and Transportation, of the Draft EIR. Further, it is important to note that, despite the identified

ironmental baseline utilized in the

menter is expressing an opinion regarding the appropriate level of service of operation of the rive/I-10 eastbound on-ramp. Nonetheless, it is acknowledged that substantial congestion occurs

ed, along the entire Bundy Drive corridor throughout the studextensively described in the proje

LOS, this condition does not affect the outcome of the project traffic impact evaluation, which identifies a significant project-related impact at this location (i.e., a significant project traffic impact at this intersection was not “avoided” due to the lower “existing” LOS noted in the project traffic study). As described in the project traffic study, a total of 40 of the 64 analyzed intersections were identified as experiencing significant impacts and, as such, the analyses accurately reflect the potential traffic effects of the proposed project and imposes all feasible mitigation measures to lessen or fully mitigate these impacts as discussed in the project traffic study and Section IV.K in the Draft EIR.

Pursuant to the Section 15125(a) of the State CEQA Guidelines, the envDraft EIR reflects the physical environmental conditions in the vicinity of the project site at the time that the Notice of Preparation was published. Furthermore, as discussed in Response to Comment 12-3, the traffic analysis included “correlation” traffic counts, which indicate that the traffic data utilized in the 7 Collected in November 2007.



project traffic impact analyses accurately represent current conditions. Please also refer to Response to Comment 12-3.

Comment No. 12-5

4. For the medical complex component of the proposed Project - aka "Parcel B", with frontage onto Olympic Boulevard - the DEIR traffic study shows that medical office trips will be 13,267 trips per day. Since most activity related to medical use occurs during the hours of 8:00 a.m. to 5:00 p.m., Monday through Friday, this will put a staggering number of new vehicle trips traversing Olympic Boulevard daily that are competing for the road during the same hours as the tenants of existing office buildings and businesses in the area.

Comment No. 12-5Response to

This comment expresses an opinion regarding the traffic impacts associated with the proposed project and does noTherefoforward

The proincreasehighest

Comme

t state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. re, a response is not required. However, the comment is acknowledged for the record and will be ed to the decision-making bodies for their review and consideration.

ject traffic study (Appendix H to the Draft EIR) examined the effects of the potential traffic s resulting from the proposed project during the AM and PM peak hours, which reflect the one-hour traffic conditions between approximately 7:00 to 10:00 AM and 3:00 to 6:00 PM.

nt No. 12-6

As a mitigation measure, monument and directional signs should be placed at the two Bundy Drive entrances to the Project, to try to mitigate the traffic impacts from every driver trying to access the medical office area exclusively from the Olympic Boulevard driveway.

se to CommRespon ent No. 12-6

As descproposeOlympiBouleva dy Drive frontage) components of the proposed project, and it is anticipated that some “cross over” traffic between the two access locations would occur. However, in order toBundy oulevard and Bundy Drive corridors themselassume

Directiooffice bwhile the proposed project is designed to provide high-visibility access to the medical office portion of the site via the Olympic Boulevard driveway, the provision of limited internal vehicular circulation within

ribed in the project traffic study (Appendix H to the Draft EIR), although primary access to the d medical office buildings and their associated parking facilities is anticipated to occur from c Boulevard, the site is designed to provide internal access between the medical office (Olympic rd frontage) and the mixed-use (Bun

provide the most conservative analysis of the potential project impacts to the intersection of Drive and Olympic Boulevard, and to the Olympic Bves, most access to the medical office and mixed-use components of the proposed project were d to occur at the driveways along their primary frontage streets.

n signage at the site’s Bundy Drive access locations indicating project access or the medical uildings on Olympic Boulevard is not recommended, as it may confuse drivers. Additionally,



the siteimpacts traffic s

Comme

between the Bundy Drive and Olympic Boulevard driveways would reduce potential project at the intersection of Olympic Boulevard and Bundy Drive, as described in detail in the project

tudy.

nt No. 12-7

5. The DEIR gave almost no recognition or analysis of the fact that the MTA's Expo Authority is planning to extend the Exposition Line through this area of West Los Angeles, and to develop a train station on Exposition Boulevard (one block south of the subject Project) between Bundy Drive and Centinela Avenue. A comprehensive Draft EIR related to the Expo Line project and the Expo/Bundy station was circulated in February 2009, over four months ago. Yet, the DEIR for the Bundy Village and Medical Park states that with regard to the Expo project: "its environmental analyses and documentation [is] not yet completed." This is a major oversight and flaw to the Bundy Village DEIR.

The Expo train will run in an east-west direction along Exposition Boulevard's right of way, with three rail cars per train, with the frequency of trains running every 2½ minutes, 21 hours per day between 4:00 a.m. and 1:00 a.m. The station, as stated before, will be only several hundred yards away from the proposed Bundy Village Project- and will bring parking, vehicular circulation and pedestrian movement challenges to the immediate area - yet there is no acknowledgement whatsoever in the Bundy Village DEIR of how the Expo rail transit project and the Bundy Project will relate to each other.

Further, the Expo project contemplates an at-grade crossing at Centinela Avenue and Exposition Boulevard. Yet, the major driveway to the medical office component of the Bundy project (accommodating 13,267 new medical office-related daily traffic trips) is at Centinela, including two inbound and two outbound lanes on Centinela. The EIR for the Bundy Village project never studies these traffic conflicts as related to ingress and egress at its Centinela driveway.

A mitigation measure of the Bundythe roadway [Centinela]

Village Project related to the Centinela driveway is to "widen by four feet" and "provide dual left turn lanes plus one shared

and Exposition. This lack of analysis and material omission makes the Bundy Village DEIR

through/right turn lane" and "install new left-turn signal phasing for the north/south ....approaches at this intersection".

What we would suggest is that northbound Centinela provide one exclusive left turn lane, one shared left turn/through lane, and one right turn only lane.

What is baffling is how the circulation is going to work, so that a vehicle can have ingress or egress to the Project’s Centinela & Olympic driveway entrance, if Expo Line Phase 2 trains are running every 2½ minutes, 21 hours a day, and have to traverse an at-grade crossing at Centinela

flawed and inadequate.



Also, as an example of one of the dis-connects that results because the Bundy Village DEIR did

se 2 project and Expo/Bundy train station is this: If the Expo/Bundy train station is developed first, with the at-grade crossing across Centinela

-grade crossing at Centinela Avenue and Exposition Boulevard, and to ensure that appropriate and

Specifically, how are vehicles going to effectively circulate northbound or southbound on Centinela Avenue, if every 2½ minutes a train passes, and the protective crossing gate or arm comes down parallel to the at-grade train tracks, preventing motor vehicle movement?

not take into account the Expo Line Phase 2 project and Expo/Bundy train station, is this: One of the existing Mitigation Measures in the Bundy Village DEIR would be to "reduce the existing sidewalk width ...along Centinela Avenue south of Olympic..." Yet, if there are going to be hundreds, or perhaps thousands of commuters a day spilling out from the Expo/Bundy train station to walk to their jobs, residences or to a business in the area, are these pedestrians (train riders) going to be walking on more narrow (substandard; inconsistent with Code) sidewalks? Is that really a wise Mitigation Measure to impose?

As an example of another dis-connect that results because the Bundy Village DEIR did not take into account the Expo Line Pha

Avenue and trains coming every 2½ minutes, then how will Centinela Avenue be an effective haul route for the demolition, excavation and construction activity that will go on for an estimated 27 months (to build the Bundy Village Project), which includes hauling away over 200,000 cubic net yards of export (dirt)? It will be impractical to use Centinela as a haul route, meaning that Bundy Drive could get 100% of the burden of the materials being hauled to and from the site over a 2+ year demolition, excavation and construction period.

A supplemental traffic & circulation study should be done before the Bundy Village EIR is finalized, to ensure that the traffic and circulation impacts of the Bundy Village project are accurately reflected in the context of the Expo Line Phase 2 project (whose DEIR was circulated 4 months ago) including the analysis of the impacts of the Expo/Bundy train station and the at

achievable Mitigation Measures are imposed.


As described in detail in the Metro Expo Line Phase 2 Draft EIR, with the Metro’s proposed 5-minute headways, the average vehicular delay ranges from 7.5 seconds to 12.5 seconds. With 10-minute headways, the average vehicular delay ranges from 3.8 seconds to 6.2 seconds.8 This analysis is based on the fact that in any given hour, based on the timing of vehicular arrivals, some vehicles will never experience any delays due to the trains, and some vehicles will experience the entire total gate down time period of 42 seconds (per Metro Grade Crossing Policy for Light Rail Transit, December 2003). Should an inbound and outbound train approach a crossing less than 30 seconds apart from one another, the total gate down time for that particular crossing event could last as long as 82 seconds. However, this delay

8 Exposition Corridor Transit Project Phase 2 DEIR, Chapter 3, Section 2, Transportation/Traffic January 2009,

page 3.2-31.



Avenue would be approximately 10.56 seconds during the AM peak hour, and 9.53 seconds during the PM peak hour, assuming 5-minute headways. With 10-minute headways, the average delay at

ould be reduced to 5.28 and 4.77 seconds during the AM and PM peak hours, respectively. These delays represent approximately the mid-range of potential average delays anticipated at the propos etroDraft EIR, with the reco on Boulevard (elimination ard), “…there would be less-than-significant i d the proposed project would not substantially

It is alsproject,entitledstation, case” traffic im ne is intendedreductioagain reproposepotentia e proposed development, and assure that all project traffic impacts are identified without the beneficial trip reduction credits that would occur if the Expo Line – Phase 2 were assumed.

As discussed above, the Draft EIR for the proposed Expo Line – Phase 2 extension includes detailed

itigation measure are included in the appendix to the project traffic study, and indicate that the measure is feasible, and is acceptable to the City of Los Angeles.

would not occur simultaneously at adjacent crossings due to the spacing of the trains and, in the event that such an extended delay were to occur at a particular crossing, it would be offset by the extended period for which the gates would then remain up until the next train crossing. Thus, there would be no change in the average delay under these particular conditions.

Under normal train operations, according to Table 3.2-9 in the Metro Draft EIR, the average delays on Centinela

Centinela Avenue w

ed at-grade crossing locations. However, as further discussed on Page 3.2-34 in the Mmmended roadway improvements at Centinela Avenue and Expositi

of the existing southbound left-turn to Exposition Boulevmpacts at the at-grade crossings and nearby intersections, an disrupt traffic operations….”

o of note that, due to the proximity of the proposed Expo Line Bundy Station to the proposed if Phase 2 of the Expo Line were assumed to be completed, the proposed project would be to additional trip generation discounts appropriate for projects within one-quarter mile of a transit further reducing potential net new project trips, and resulting in reductions to the “worst

pacts identified in the project traffic study and Draft EIR. Additionally, the Expo Li to provide convenient transit opportunities for local and area residents, and the associated n in overall area traffic would be expected to reduce traffic congestion throughout the study area, ducing the potential for traffic impacts associated with the proposed project. As a result, the d project Draft EIR and project traffic study present a highly conservative assessment of the l impacts of th

impact and vehicular queuing analyses for key intersections surrounding its station locations and along the route itself, including at-grade crossing analyses for Centinela Avenue and other locations. A review of the analyses provided in the Expo Line – Phase 2 Draft EIR indicates that the proposed transit project would not have significant impacts to the operations of Centinela Avenue and, as such, even though the proposed project traffic analyses did not include these specific analyses, the proposed project traffic study is consistent with the findings in the Expo Line Draft EIR regarding traffic operations in the vicinity.

The noted project mitigation measure to widen the Centinela Avenue approach of the Olympic Boulevard/Centinela Avenue intersection would provide an acceptable eight-foot sidewalk width, which as reviewed by the LADOT in the approved Traffic Impact Analysis Report. The commenter’s recommendations regarding proposed lane configurations for the improvement are noted and will be forwarded to the decision-making bodies for their review and consideration. Conceptual drawings of the proposed m



0). A detailed traffic impact analysis was prepared to identify potential construction-related impacts, and appropriate mitigation measures were

bove, even if the Expo Line – Phase 2 project is completed prior to development of the proposed be viabl nAvenue.

Comment N

The proposed haul route for proposed project’s construction traffic utilizes Centinela Avenue as the shortest route to and from the nearby Santa Monica Freeway (I-1

proposed. As noted aproject, the use of Centinela Avenue as the primary haul route would still be considered to

e, si ce the Expo Line Draft EIR indicated no significant impacts to the operations of Centinela

o. 12-8

Of the 64 intersections analyzed in the Bundy Village DEIR, the DEIR did not analyze:

. Bundy Drive & Exposition Boulevard intersection, or

. Centinela Avenue & Exposition Boulevard intersection

6.

a

b

inutes, 21 hours per day -- theomissio

A suppVillageProject analy

the Bundy Village project if its Centinela Avenue driveway is essential to the Project.

With the extension and development of the future Expo Line into the immediate area, and the corresponding Expo/Bundy train station's development between Centinela Avenue and Bundy Drive, coupled with the at-grade crossing at Centinela Avenue and Exposition Boulevard, and the fact that there will be trains criss-crossing this area every 2½ m

n of studying these intersections is an inadequacy of the Bundy Village DEIR.

lemental study should be undertaken to analyze both intersections before the Bundy EIR is finalized, to ensure that these intersections are studied, in terms of the "with

sis, plus "with Expo Line station", and that sufficient and achievable Mitigation Measures are imposed on


The intersections noted by the commenter are both unsignalized intersections, and are STOP sign controlled along their minor approaches (neither Centinela Avenue nor Bundy Drive stop at these locations). The LADOT’s current traffic impact analysis policy provides that unsignalized intersections should be evaluated to identify whether such intersections are appropriate for installation of traffic signals. A review of the two suggested locations indicates that signalization of either location would not be recommended; the intersection of Bundy Drive and Exposition Boulevard is located too close to its adjacent intersections of Bundy Drive/Olympic Boulevard and Bundy Drive and Pico Boulevard for

crossing, signal installation at this location is infeasible. Therefore, neither of these locations was considered appropriate for signal installation, and a detailed analysis of these intersections was not warranted.

signal installation. Additionally, the intersection of Centinela Avenue and Exposition Boulevard is located immediately adjacent to the proposed Expo Line at-grade crossing of Centinela Avenue and, as such, due to the required crossing equipment and train/automobile access controls for such an at-grade



ial traffic congestion at the proposed Expo Line at-grade crossing at Centinela and Exposition Boulevard, please refer to Response to Comment 12-7.

Comment N

With respect to potent

o. 12-9

It is important to the ongoing viability of Kilroy's Westside Media Center complex of almost 380,000 square feet that vehicular access to and from its subterranean parking garage entrance and exit on Bundy Drive

7.

not be impacted by the development of the Bundy Village & Medical Park Project. Today, vehicular traffic for tenants and visitors accessing Westside

tenants' ability to enter and exit the parking garage.

Drive and stripe the area to the center median of eastbound Olympic Blvd. in front of Westside Media Center’s


Media Center includes a left turn pocket for ingress into the underground parking garage, as well as an exit from the garage onto Bundy Drive. With the Bundy Village Project estimated to bring over 20,000 net new daily trips to the immediate area, there should be a Mitigation Measure in the Bundy Village EIR that protects existing property owners and businesses from the significant queuing of vehicles that may occur, especially along Bundy Drive, which could impact existing

Kilroy requests that the following Mitigation Measure be imposed on the Bundy Village project to preserve the ability of Westside Media Center’s tenants to access WMC’s Bundy Drive and Olympic Blvd. entrances and exits to avoid traffic collisions.

MM: Stripe the area to the center median of southbound Bundy

driveways, with the words: "KEEP CLEAR" to protect existing tenant’s ability to access or leave the Westside Media Center property.

The project traffic study (Appendix H to the Draft EIR) and Section IV.K (Traffic and Transportation) of

street through traffic movements. It should be noted that such signage is not generally considered to be appropriate for installation at individual project driveways.

the Draft EIR evaluated the potential impacts of the proposed project on both Olympic Boulevard and Bundy Drive, and recommends appropriate mitigation measures to reduce, to the extent possible, the impacts of the project. The proposed improvements to the intersections of Bundy Drive and the I-10 ramps, south of the project site, are anticipated to provide substantial new roadway capacity, and eliminate the primary cause of the existing vehicular queuing on Bundy Drive between the I-10 and Olympic Boulevard. The commenter’s suggested roadway striping measures along Olympic Boulevard and Bundy Drive are noted and will be forwarded to the decision-making bodies for their review and consideration.

The suggested “Keep Clear” signage/striping is generally applicable only to street intersection locations where vehicular queuing could disrupt cross



Comment No. 12-10

Kilroy's Westside Media Center, and particularly the 12312 Olympic Boulevard building (near Centinela Avenue) which is known as "Westside Media Ce

8. nter Studios, contains

entertainment studio companies, with tenants who are involved in television broadcasts,

Soumaterials to/from the proposed Project site, and the actual construction at the Bundy

equipment. Because of the existing uses at 12312 Olympic Boulevard, the broadcast and recording studio businesses are

No noise contour map could be found in the DEIR or its Technical Appendices, which seemed a

sound, and music production companies. The 12312 Olympic Boulevard building is directly across the street from the Centinela driveway entrance to the proposed Project, and nearest geographically to the Project’s "Building D" and "Building E".

nd and groundborne vibration impacts from 2+ years of demolition, excavation, hauling

Village Project will be significant and impactful to these existing businesses which have TV, film and music recording uses, with sensitive sound and recording

effectively "sensitive receptors."

Yet, the Bundy Village DEIR never studied or identified any impacts from construction-related noise and vibration, except on properties to the north and east of the Bundy Village site. Westside Media Center, directly across the street from the proposed Project to the south, was completely ignored, even though noise and groundborne vibration from the Project’s construction could effectively put these tenants of Westside Media Center out of business.

curious omission. However, from a review of the text, the only sensitive receptors identified were north or east of Parcel A.


The Draft EIR discusses potential vibration impacts on nearby receptors that utilize recording equipment on Page IV.H-25. Furthermore, as discussed on Page IV.H-25 in the Draft EIR, while recording studios are not considered to be sensitive receptors, due to the proximity of sensitive recording equipment that could be affected during the demolition and excavation phases of the proposed project, these uses were included in the analysis. The Draft EIR concludes that noise and vibration impacts to these uses would be significant and unavoidable. With respect to the comment regarding noise contour maps, noise contour maps are not required to perform an adequate noise impact analysis for this type of project. Rather, as discussed in Section IV.H (Noise) of the Draft EIR, construction noise levels were calculated using data published by the United States Environmental Protection Agency. Groundborne vibration levels resulting from construction activities were estimated by utilizing data published by Harris Miller Miller & Hanson Inc. for the Federal Transit Administration.

Comment No. 12-11

A supplemental noise and ground borne vibration impact study should be conducted before the Bundy Village EIR is finalized, to analyze:



the 27 months of demolition, excavation (where over 200,000 cubic net yards of dirt will be exported) and construction.

a. Noise and groundborne vibration impacts from the Bundy Village Project to properties south of the Project, particularly involving demolition, excavation and construction activities in connection with Building D and Building E of the proposed Project, which buildings will be constructed directly across the street from 12312 Olympic Boulevard.

b. Noise and groundborne vibration impacts from the Bundy Village Project, particularly involving the planned haul routes on Centinela Avenue and on Bundy Drive, from trucks lumbering up and down Centinela and Bundy at the rate (per the EIR) of 10 trucks per hour, Monday through Friday, from 9:00 a.m. to 4:00 pm, for

Appropriate and achievable Mitigation Measures should be imposed on the Project to protect existing broadcast and recording tenants at Westside Media Center.


With respect to the first part (a) of this comment, as discussed on Page IV.H-25 in the Draft EIR, due to the close proximity of recording equipment that could be affected during the demolition and excavation phases of the proposed project, this use was addressed in this analysis. As no feasible mitigation is available to fully reduce the vibration impacts at these off-site receptors to below the FTA’s thresholds of 65 VdB where vibration may interfere with interior operations, vibration impacts were determined to be significant and unavoidable.

In addition, as discussed on Page IV.H-35 in the Drdevices and techniqu

aft EIR, with the implementation of noise reduction es during construction at the project site, construction-related noise impacts

associatbecause consmore than 10noise impacts

With respect Draft EIR, fuDrive are calfuture conditi rucks that would be transporfuture dF to theSouth Bund proposed project, 0.7% of all vehicle trips would be heavy

hauling excavated soil. Further, approximately 89.10% of those trips would occur during the daytime hours; the same time that excavation would occur. Therefore, given that

trips would be heavy truck trips.

ed with the proposed project would be reduced to the maximum extent feasible. Nevertheless, truction noise levels would exceed existing ambient noise levels by more than 5 dBA for days in a three-month period and by more than 10 dBA for more than one day, construction would be significant and unavoidable.

to the second part (b) of this comment, as shown in Table IV.H-11 on Page IV.H-27 in the ture noise levels for the roadway segment of Olympic Boulevard, west of South Bundy

culated to be 70.1 dBA CNEL, or 1.9 dBA over existing calculated noise levels. While this on does not necessarily take into account the actual construction-related t

ting the excavated material off-site, it does take into account additional truck trips associated with evelopment in the study area during the operation of the proposed project. As shown in Appendix Draft EIR, of the total number of vehicle trips forecast to utilize Olympic Boulevard west of

y Drive during the operation of the truck trips such as the type used for

the existing number of trips on this roadway segment has been shown to be 3,318 vehicle trips per hour, in the project traffic study (Appendix H to the Draft EIR), it can be assumed that 232 of those vehicle



As discussed on Page IV.H-15 in the Draft EIR, trucks typically generate groundborne vibration velocity

, the number of trucks required for hauling excavated soil off-site would be less then the forecasted future increase in truck trips

out of all cumulative development in the area and vibration levels associated with hauling would, therefore, Page IVbe below thsignificant. TOlympic Bou ation levels beyond what is forecast for future build-ou

Comme

As shown in Appendix F, the future plus project scenario is forecast to generate 5,186 vehicle trips per hour for this roadway segment when all area development has been built and the proposed project is fully operational. Similar to existing traffic volumes, 0.7% of these trips, or 363 trips, would be heavy truck trips resulting in an increase of 91 truck trips per hour as compared to the future plus project scenario. The Draft EIR indicates that 10 trucks per hour, or one truck every ten minutes, would be required for hauling soil during the site excavation phase. This would be less than the increase in cumulative heavy truck trips forecast in the project traffic study for this roadway segment at full project build-out. Therefore, the number of heavy trucks per day needed for excavation of the project site would be less then the forecasted future increase in truck trips when the project would be fully operational.

levels of around 63 VdB, when measured at 25 feet. Since vibrations from heavy trucks are generated by sound waves traveling through the earth and into a given space, on-road vibration levels from heavy trucks are directly correlated to the amount of noise they generate. As stated above

associated with build-be less then the forecasted truck trip increase. As shown in Table IV.H-11 on

.H-27 in the Draft EIR, noise levels are predicted to increase by 1.9 dBA and were determined to e 3.0 dBA, or minimal perceptible level, and impacts were determined to be less then herefore, vibrations from trucks associated with hauling of excavated soil and utilizing levard would not increase noise and vibr

t of the proposed project and all cumulative development in the area.

nt No. 12-12

9. Kilroy's Class-A office buildings at 12200 and 12100 Olympic Boulevard (closer to Bundy oadcasts, sound, and music

he DEIR for the Bundy borne vibration impacts

during the Project’s construction on either of these properties. To the extent the haul route

Response to

Drive) also have tenants who are involved in television brproduction. These existing tenants are "sensitive receptors." TVillage Project does not appear to have analyzed noise or ground

selected for the Bundy Village Project is Bundy Drive, trucks lumbering up and down Bundy Drive, carrying materials to and away from the Project site, could have noise and vibration impacts to the 12200 and 12100 Olympic Boulevard buildings

The supplemental noise and ground borne vibration impact study, requested above, should analyze impacts to 12200 and 12100 Olympic Boulevard as well, including appropriate Mitigation Measures to be imposed.

Comment No. 12-12

With respect to noise and groundborne vibration impacts, please refer to Response to Comment 12-10 and ment 12-11. In addition, the Draft EIR addresses potential noise and groundborne vibration impacts Com



on recepbuilding age IV.H-3 in the Draft EIR, noise levels from a particular source decline as distance to the receptor increases. The Draft EIR identifies significant and

oise and groundborne vibration impacts on the closest receptors.

g Bundy in the Draft EIR, construction trucks would utilize

Santa Monica Freeway (I-10).

tors with sensitive recording equipment9 that are located closer to the proposed project than the s referenced in this comment. As discussed on P

unavoidable construction-related nTherefore, receptors located further from the project site than the specific receptors discussed in the Draft EIR would experience lower levels of noise and groundborne vibration. Nonetheless, the Draft EIR concludes that there is no feasible mitigation available to reduce construction-related noise and groundborne vibration and impacts would be significant and unavoidable. This comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

With respect to noise and vibration impacts generated by construction trucks traveling alonDrive, as shown in Figure IV.K-5, Local Haul Route,Centinela Avenue (not Bundy Drive) to access the

Comment No. 12-13

10. Using the City of LA Planning Department’s ZIMAS website, the distance from Westside Media Center's property line on Olympic Boulevard in front of 12312 Olympic (Westside Media Studios) across the street to the proposed Project’s property line, measures only 110 feet from property line to property line.

Noise chapter of tThe he DEIR reveals that there will be three primary instances of significant

feet away that will experience significant noise imp ildingD o t. Yet, ther xisting faci ect’s boundaries, from Project construction. Since the Westside Media Center's buildings include existing occupancies by tenants who operate broadcast & recording studios, which studios contain sensitive sound equipment, the lack of noise and groundborne vibration analysis from Project construction on the Westside Media Center

noise and/or vibration impacts from the Project during construction:

1) One within 50 feet, which is Fox Studios

2) One within 85 feet to the east, which is multi-family residential

3) One within 380 feet to the north, which is single family residential

Certainly, the single family residential at 380 acts, is a much greater distance than the distance from Westside Media Studios to Buf the proposed project (adjacent to Olympic & Centinela), which distance is 110 feee was no analysis in the DEIR of the noise or groundborne vibration impacts to elities to the south of the Proj

As discussed on Page IV.H-25 in the Draft EIR, even though recording studios are generally not considered to be sensitive receptors, due to the close proximity of sensitive recording equipment that could be affected during the demolition and excavation phases of the proposed project, this use is discussed in the noise and vibration analyses.

9



mission and inadequacy of the DEIR - and as stated above, should require further study before the EIR is finalized. properties is a significant o


As discussed in Response to Comment 12-12, the Draft EIR addresses potential noise and groundborne vibration impacts on receptors with sensitive recording equipment10 that are located closer to the proposed project than the buildings referenced in this comment. As discussed on Page IV.H-3 in the Draft EIR, noise levels from a particular source decline as distance to the receptor increases. The Draft EIR identifies significant and unavoidable construction-related noise and groundborne vibration impacts on the closest receptors. Therefore, receptors located further from the project site than the specific receptors discussed in the Draft EIR would experience lower levels of noise and groundborne vibration.

Please also refer to Response to Comment 12-10.

Comment No. 12-14

11. Air quality and fugitive dust emissions from the proposed Project are anticipated to be voidable, per the EIR. Over 200,000 cubic net yards of dirt will be

exported from the site, directly across from Kilroy's Westside Media Center's almost tertainment tenants. Especially

during Project construction and particularly during excavation, the fugitive dust will be

In a R, and due to the sensitive

a [sic] MIE "mini RAM", model PDR 1000 (or equivalent , fugitive dust particles in the air shall be monitored during

significant and una

380,000 square feet of existing space for office, media and en

quite significant.

ddition to the Mitigation Measures already reflected in the Draft EIsound and recording equipment that many of Westside Media Center's studio and entertainment tenants operate, we request that fugitive dust and particulate monitoring equipment be in stalled on the Bundy Village Project site, and that such monitoring equipment be used on a constant basis during the demolition, excavation and construction stages, so that these activities can cease during periods of high dust/particulates in the air. As a specific example of such a Mitigation Measure, we would suggest

MM: Through the use of monitoring equipment)construction, with construction and excavation activities ceasing during periods of high dust/particulate matter.

10 As discussed on Page IV.H-25 in the Draft EIR, even though recording studios are generally not considered to

be sensitive receptors, due to the close proximity of sensitive recording equipment that could be affected during the demolition and excavation phases of the proposed project, this use is discussed in the noise and vibration analyses. The L.A. CEQA Thresholds Guide defines noise-sensitive uses as residences, transient lodgings, schools, libraries, churches, hospitals, nursing homes, auditoriums, concert halls, amphitheaters, playgrounds, and parks.




The Draft EIR includes mitigation measures that are recommended pursuant to requirements under SCAQMD Rule 403. Pages IV.C-61 through IV.C-62 in the Draft EIR include Mitigation Measures C-1

igation Measure C-13, which would reduce potential dirt and debris to a less than significant level (see also Section V, Mitigation Monitoring Program, in this Final EIR). Specifically, Mitigatactivities shaso as to prevsame result a

Furthermore,generated fro what is presented in the Draft EIR. The corrected calculations are presented in Section IV, Corrections and Additions, in this

his Final EIR).

through C-11 and Mit

ion Measure C-13 states the following: “All clearing, grading, earth moving, or excavation ll be discontinued during periods of high winds (i.e., greater than 15 miles per hour [mph]), ent excessive amounts of dust.” Mitigation Measure C-13 would effectively achieve the s the intent of the mitigation measure suggested in this comment.

upon further review of the air quality calculations, it has been determined that the dust m the construction of the proposed project would actually be less than

Final EIR (see also Appendix C to t

Comment No. 12-15

12. The DEIR reflects:

a. Demolition activity is anticipated to occur over 4 months

b. Excavation activity is anticipated to occur over 3 months

c. Construction is activity is anticipated to occur over 20 months

For a massive project of 6 buildings totaling over 1,000,000 (conservative estimate) square feet of building space including parking structure, it is unrealistically aggressive for the EIR to reflect only a 27-month total demo/excavation/construction schedule. It is likely to be a much longer build-out than 27 months. Therefore, construction-related environmental impacts that cannot be fully mitigated will actually go on for longer than the DEIR states. A more realistic construction time frame should be analyzed before the EIR is finalized.


As discussed in Section II, Project Description, of the Draft EIR, construction activities are anticipated to occur over the course of approximately 2.5 years, with full project buildout anticipated for late 2011. Construction of the proposed project would occur over three phases, including demolition, grading/excavation, and construction of the proposed structures. The demolition phase would occur over approximately four months, and would include the removal of all existing onsite structures, concrete, and asphalt. The grading/excavation phase would occur over approximately three months and would include approximately 221,400 cubic yards of excavation to allow for the subterranean parking levels and building foundations. The construction phase would occur over an approximately 20-month period. The comment that refers to this time frame as unrealistically aggressive is considered to be speculative, and



to the analysis presented in the Draft EIR for the proposed project. comment is acknowledged for the record and will be forwarded to the decision-making

consideration.

does not need to be incorporated inNonetheless, thisbodies for their review and

Comment No. 12-16

13. The Mitigation Measures related to traffic and circulation should reflect a prohibition on any construction-related vehicle from using the center medians on Olympic or on Bundy for

when such parking would interfere with ingress or egress to Westside Media Center's


parking. The local roadways and intersections are already at or near a failure Level of Service, and any such center median parking by construction related vehicles - especially

parking entrances mid-block on Olympic and on Bundy - would significantly impact traffic and circulation for existing property owners and businesses in the area.

feasible,

It is anticipated that all construction vehicles would stage on-site. However, the developer and project contractors would work with the LADOT and Department of Building and Safety (the agency responsible for approving haul route and other construction vehicle related items) to minimize, to the extentpotential construction-related traffic impacts. However, while discouraged, the use of roadway median lanes is typical of construction activity throughout the City, and is generally permitted in such instances where access to adjacent developments is not significantly obstructed by such operations.




Dana R. Martin Martin Automotive Group 12101 West Olympic Boulevard Los Angeles, CA 90064

Comment No. 13-1

Since the office of the Department of City Planning has requested my comments in their letter dated April 30, 2009 following my review of the Draft EIR referenced above, I am, respectfully, submitting the following.

I am the owner (Philena Properties, LP) of the parcel of property at 12101 West Olympic Boulevard more commonly known as "Martin Cadillac". I am also the owner of the operating company (Martin Automotive Group) that owns Martin Cadillac-Pontiac-GMC.

What concerns me is the impact this project will have on my five acre site should I decide to develop it in the future due to General Motors failure to successfully restructure its business. I am afraid of an excessive FAR entitlement "grab" by the Bundy Village & Medical Park developer and severe additional traffic generation that will compromise my ability to develop my site to its highest and best use.

I believe West Los Angeles and the surrounding neighborhoods have benefited greatly from Martin Cadillac's use of my site with .5 FAR improvements, low traffic generation and significant tax revenue

r Los Angeles since 1975. It would be patently unfair if we are "punished" in the future with entitlement urtailments and restrictions because of prior surrounding developments if a higher-best use project

becomes necessary here.


foc


Comment No. 13-2

I think it is wise to insist that the Bundy Village & Medical Park, as well as the Martin Cadillac site, be considered in terms of its traffic impact, at the same time. I anticipate a mixed-use development of approximately 650,000 square feet, which may include office, hotel and ground floor retail including automobile sales requiring a minimum of 3 cars per 1,000 square feet.

I am available for any questions or comments the City Planning office may have at (310) 477-7069.


With regard to related projects (or cumulative development) in the project area, Section 15125(a) of the State CEQA Guidelines states the following: “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….” The cumulative analysis in the Draft EIR considers the potential cumulative impacts that could occur as a result of implementation of the proposed project in conjunction with other “past, present,



cing related or cumulative impacts,” in accordance with Section 15130(b)(1)(A) of the State CEQA Guidelines. The cumulative development known to the City of Los

e time the NOP for the proposed project was published (October 15, 2007) in the vicinity of uded in the list of related projects in the Draft EIR. At the time the Notice of project was circulated, the Martin Cadillac project was not one of the related

y.

Any proposed development on the Martin Cadillac property would need to include the proposed project in

artin Cadillac

. Therefore, the mixed-use development described in this comment is considered to be ot need to be incorporated into the analysis presented in the EIR for the

proposed project. The Martin Cadillac project, if and when proposed, would be required to submit its

and probable future projects produ

Angeles at ththe project site were inclPreparation (NOP) for theprojects listed by the Cit

its cumulative impact analysis, since the proposed project’s entitlement process commenced prior to any potential project on the Martin Cadillac property. Thus, cumulative impacts related to the two projects would be studied and disclosed during the Martin Cadillac environmental review process.

In addition, prior to the receipt of this letter, the Department of City Planning, Department of Transportation, and the general public were unaware of any proposed development on the Mproperty. At the time of the preparation of this Final EIR, no documents had been filed with the City and no public notice had been made (by the City or media) regarding any potential development on the Martin Cadillac propertyspeculative at this time, and does n

own environmental impact documentation in compliance with CEQA, and is not part of the current project analyzed in this EIR.



Tom Meyer e.

Los Angeles, CA 90025

14-1


1560 S. Carmelina Av

Comment No.

IR for Bundy Village and Medical Park. I am hoping you will accept my comment as it will arrive in your email prior to midnight on Monday, June 15th which is technically

d.

e early meetings when the Project was announced to the community and am familiar

I am writing regarding the Draft E

still June 15. I was not apprised of the comment time period although some of the neighbors in the area were and informed me. I am in the 1500 block of South Carmelina (within two blocks of the proposed complex and am surprised that neither myself or my neighbors on this block were notifie

I did attend one of thwith the project.


According to Section 15087 of the State CEQA Guidelines, notice shall be mailed to owners and occupants of properties contiguous to the parcel or parcels on which the project is located. The standard

e Department of City Planning is to distribute project notices to owners and occupants of pro e project site as well as anyone who requests notification. The address provided by he 500-foot radius of the project site. How any future public notification regarding the proposed project.

Comment No. 14-2

procedure of thperties within 500-foot radius of th

the Commenter is not located within tever, it has been added to the distribution list for

I am vehemently opposed to this project for a very simple reason. The transportation infrastructure of the surr specially the 10 freeways) is incapable of accommodating the increased traffic. No amount of traffic mitigation measures (either those that are pro ridlock nor the future MAJOR gridlock brought on by this project. All it takes is to spend some time on Bundy or Olympic streets during rush hour to kno g laws for a reason and to change them to

ounding area (surface streets and the 405 and e

posed for Centinela, etc.) will alleviate the existing g

w that this project is not feasible. We have zoninaccommodate a massive project is both ill-advised and short-sighted.


Refer to Section IV.K, Traffic and Transportation, of the Draft EIR for an analysis of the proposed ndicated therein, implementation of the recommended physical and/or project’s impacts on traffic. As i

signal improvements would reduce the potential traffic impacts of the project to less-than-significant levels at many, but not all, of the impacted intersections. Mitigation Measures K-1 through K-25 would



affic impacts to the maximum extent feasible (see also Section V, Mitigation Monitoring Program, in this Final EIR). Also, please refer to Response to Comment 7-5. mitigate potential tr

Comment No. 14-3

By the way, the proposed Exposition rail project is not enough to solve the problems in this neighborhood.


The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record

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

Comment No. 14-4

While it is very nice for the developer to make the project more palatable by suggesting that a Whole Foods market will be part of the project, it is not a certainty that Whole Foods will participate.

- Trader Joe's (soon to open at Barrington & Olympic)

- Von's (Barrington and Santa Monica Blvd.)

- Ralph's (Bundy and Wilshire)

- Smart & Final (Santa Monica Blvd. and Wellesley)

- Ralph's (Cloverfield and Olympic - Santa Monica)

- Trader Joe's (Pico and approx 33rd - Santa Monica)

And in fact, as far as Whole Foods locations are concerned, there are 5 stores within 3 to 5 miles. 3 are in Santa Monica, 1 in Venice and the other at 11666 National Blvd, Los Angeles, CA - ONLY 2 miles from the proposed new one at Bundy Village!


Furthermore, the concentration of major supermarkets in an approximately 2 mile radius is almost ridiculous.

For example:

- Ralph's (Barrington & Olympic)




Comment No. 14-5

I could go on about numI will leave it with the o

Lastly, as a manager

erous other issues that make this project a negative one for the neighborhood but ne issue that cannot be solved - traffic.

of a small business in the neighborhood of Centinela and Exposition (almost ground I believe this will also have deleterious effects on my business. zero for this project),



Comment No. 14-6

Thank you for accepting my comment on the Draft EIR.

I would also respectfully request an extension to the comment period and better notification (at least within a mile radius) of the opportunity to comment on the Draft EIR.

If necessary, I can be reached at the above email address or via phone at 310.920.3069 or my home address below.






Fred Salenger, Trustee Salenger Family Trust 4245 Clear Valley Drive Encino, CA 91436

Comment No. 15-1

Our parcel is on the West side of the alley between the medical park site and Nebraska Avenue and on the

s well as on Bundy and Olympic. I residents and their guests will inundate what is now a very quiet e that vendors, residents and other frequent visitors to the medical park

e a few minutes off their rk and will turn the Nebraska residential neighborhood street and the light industrial

alley into a mini-Bundy Avenue as well as a short cut for deliveries and pedestrians. The alley is very

North side of the North portion of the medical park site. It is my understanding that the medical park site has an easement for ingress and egress along the alley, but the extent of its rights to use the alley (e.g. limits on its use) are not clear to me.

I fear that the medical park will vastly increase traffic on Nebraska afear that trucks, ambulances andindustrial alley. It seems clear to mwill quickly figure out that the Nebraska/alley "backdoor" will be a way to shavtrip to the medical pa

narrow and will not easily accommodate two-way traffic, especially if delivery trucks or ambulances are involved. At a minimum, I ask that the alley not be used by the medical park site except for emergency service ingress and egress (police, fire and ambulances) and closed to pedestrians to mitigate these concerns.


As discussed in the Draft EIR and the project traffic study (Appendix H to the Draft EIR), project access to and from Nebraska Avenue would be physically restricted and limited to emergency vehicles only. Please also refer to Response to Comment 11-4.

Comment No. 15-2

I am also concerned about the impact the change in zoning and increased density will do to the adjacent parcels. One has to imagine that retail in the development will bring traffic, noise, loitering, litter and crime. This is not speculation; it's just some of the standard retail development problems encountered by your office everyday. Now the area is light industrial and is primarily used only during the daylight hours with employees making a single trip to the area in the morning and leaving in the early evening. As proposed the area will be used day and night, with traffic at all hours of the day and night. As Bundy is already well over capacity, I do not know how the area can accommodate additional trips that the retail and residential components will generate.


The proposed project’s impacts on noise and crime are analyzed in the Draft EIR in Sections IV.H, Noise, and IV.J.2, Police Protection.

With respect to traffic, Section IV.K, Traffic and Transportation, of the Draft EIR and the project traffic study (Appendix H to the Draft EIR) present the potential impacts of the proposed project during the



critical weekday AM and PM peak hours, when area traffic volumes and congestion are at its highest levels. Additionally, although the proposed retail and restaurant uses would be active during the day and evening periods, as shown in the project trip generation calculations, the greatest single trip generator for the proposed project is the medical office component, which produces approximately 60 percent of the project’s net daily and PM peak hour trips, and about 75 percent of the AM peak hour trips. The proposed medical office facilities would operate in a manner typical of other medical office facilities, and would be generally closed or operating at substantially reduced levels after about 6:00 PM.

Comment No. 15-3

We currently have limited parking for the use of our parcel. It is not hard to imagine that users of the medical park will attempt to take our parking places. We do not currently have a security officer or other ways to police the use of our parking. If the proposal goes through, the city, or the developer must take steps to ensure that the developments patrons do not use our parking.


With respect to parking, please refer to Responses to Comments 11-5 and 11-6.

Comment No. 15-4

While I do not speak for the homeowners on Nebraska and to the north, I fear they too will fight the change in character being proposed. And, if they fight the medical park development and lose, they will be more aggressive in fighting any new proposal we might make to change the character of our parcel at some time in the future. They will see commercial creep coming from the medical park parcel toward

em through our parcel. Accordingly, the city should consider what the impact would be in possible hanges to our parcel's zoning at the same time as changes to the zoning of the medical park development

ur parcel is not adversely affected by the city's decisions under consideration now.


thcare considered so that o

With respect to related projects (or cumulative development) in the project area, Section 15125(a) of the State CEQA Guidelines states the following: “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…” The cumulative analysis in the Draft EIR considers the potential cumulative impacts that could occur as a result of implementation of the proposed project in conjunction with other “past, present, and probable future projects producing related or cumulative impacts,” in accordance with Section 15130(b)(1)(A) of the State CEQA Guidelines. Cumulative development, in the vicinity of the project site, known to the City of Los Angeles at the time the NOP for the proposed project was published (October 15, 2007) was included in the list of related projects in the Draft EIR. At the time the Notice of Preparation (NOP) for the project was circulated, no project on the parcel that includes the address 12210 Nebraska Avenue was included on the related projects listed by the City.

Furthermore, any future project proposed for the parcel mentioned above would likely include the proposed project in its cumulative impact analysis, as the proposed project’s entitlement process commenced prior to any potential project on the adjacent parcel. Thus, potential cumulative impacts generated by the two projects would be studied and disclosed during the environmental review process for any projects on this parcel.



of this letter, the Department of City Planning, Department of Transportation, and the general public were unaware of any potential development on the parcel including

e of the preparation of this Final EIR, no documents had y and no public notice had been made (by the City or media) regarding any

this parcel. Therefore, the potential development described in this comment is e at this time, and does not need to be incorporated into the analysis presented

posed project. Nonetheless, this comment is acknowledged for the record and will

Additionally, prior to the receipt

the address 12210 Nebraska Avenue. At the timbeen filed with the Citpotential development on considered to be speculativin the EIR for the probe forwarded to the decision-making bodies for their review and consideration.

Comment No. 15-5

Since it is unclear at this point whether the medical park development will proceed, I have not retained

unreasonable to me.

ich I should take to articulate more fully my concerns and work with your office to mitigate them.

land use counsel to assist me with the formulation or expression of these concerns. If the project appears to gather momentum, I will have no choice as a fiduciary for the beneficiaries of the trust but to retain counsel and fight those aspects of the development, which appear commercially

Please let me know next steps, wh


The comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record

aking bodies for their review and consideration. and will be forwarded to the decision-m




Siddha Yoga Meditation Center of Los Angeles 1845 S. Bundy Avenue Los Angeles, CA 90025

Comment No. 16-1

Enclosed are copies of the previous letters that we sent to the City of Los Angeles dated February 5, 2007 and October 23, 2003. We do appreciate the fact that several of the issues we mentioned have been addressed and as indicated in the EIR Report, other issues are unresolved.

We welcome the resources that will be provided by this new project (i.e., retail and the senior housing units as a number of our members are in that age bracket).


The comment does not state a specific concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. 16-2

One of the items mentioned in our previous letters that we would like to reiterate concerns the access road that goes by our property and ends at Nebraska Street. This could be a major public safety and health problem as a number of our members walk to our facility and there are also a number of families with children of all ages that walk on this access street. Even though it is labeled as "limited access", once the project is built people in the new complex will use this to avoid the Bundy and Olympic congestion problem that perhaps may become even worse than it is now.

Since the access road is not a part of the development property we would certainly like the City of Los Angeles to consider a method of "limited access" to this street, and some ideas have already been mentioned in the EIR. We would like to have something where there is actually a walking space so that people can walk or walk down the side of the street. From our viewpoint and public safety viewpoint we would like to see a walking space by the street as our major entrance to our complex is off this access street. We do not enter off of Bundy.


This comment discusses concerns that the proposed limited access driveway from Nebraska Avenue would be used by residents of the proposed project to avoid traffic congestion along Bundy Drive and Olympic Boulevard. As stated on Page II-29 in the Draft EIR, the driveway would only be used by emergency vehicles (i.e., fire services and police services).



equest that the existing access road adjacent to the commenter’s property be improved to provide pedestrian access, this comment does not state a concern or question

ned in the Draft EIR. Therefore, a response is not required. ged for the record and will be forwarded to the decision-making

With respect to the commenter’s r

regarding the adequacy of the analysis contaiHowever, the comment is acknowledbodies for their consideration.

Comment No. 16-3

We are a meditation center and the idea of cand noise. We are concerned aboutconcerned about construction period of t

onstruction traffic has us very concerned about disruptions traffic noise and general density of autos in this area. We are

he project especially done in phases. We assume that during construction materials and equipment would be going down that access street and again the problem of

s is of foremost concern. We would prefer that the access street off of Nebraska not be used for construction access. safety of our member

Thank you in advance for your consideration of these concerns.


Potential noise impacts to nearby receptors are addressed in Section IV.H, Noise, of the Draft EIR. With respect to construction noise, the Draft EIR concludes that while potentially short-term construction noise impacts would occur, these impacts would be temporary in nature, and would not generate continuously high noise levels throughout the day (see Page IV.H-22 in the Draft EIR). As discussed in the Draft EIR,

asures H-1 through H-5 (see Pages IV.H-32 through IV.H-33) would reduce noise levels associated with construction to the maximum extent that is technically feasible (see implementation of Mitigation Me

also Section V, Mitigation Monitoring Program, in this Final EIR). Furthermore, no construction traffic would be allowed along Nebraska Avenue.



COMMEN

Nancy Tominaga 1740 Amherst Ave. 90025 e.

Bill &Molly Takahashi 1745 Amherst Ave.

& Frank Macias 1755 Amherst Ave. ga 1756 Amherst Ave. Amherst Ave.

Aiko & John

Comment N

T LETTER NO. 17

Chester J. Fukai 1744 Amherst Av

Jeffery Levin & Bonnie Powers 1749 Amherst Ave. Shinobu Shimomaye 1750 Amherst Ave. AdelaidaKeizo & Jane SuyenaSteve J. Stevens 1757

Tsuboi 1758 Amherst Ave.

o. 17-1

We the undersigned homeownerssevere negative impact on our neig

believe the proposed Bundy Village project will have nothing but hborhood environment. Building 385 condos including 77 senior units

to Comment No. 17-1

with retail and a restaurant along narrowest section of Bundy Drive will not enhance livelihood or improve our environment, only cause more traffic accidents and endanger lives. We are concerned by impacts to the environment including air quality, noise and especially traffic. Traffic has gotten much heavier on Bundy Drive since 2006 when the project was first proposed. When Trader Joes and Walgreens open next month a few blocks away on Olympic Boulevard, traffic would become even heavier on Bundy Drive.

Response

velihood, this comment does not state a concern or question arequired. Homaking bodie

With respect Sections IV.CEIR analyzesprojects on Pa

With respect to the comments regarding enhanced li reg rding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not

wever, the comment is acknowledged for the record and will be forwarded to the decision-s for their consideration.

to impacts to air quality, noise, and traffic, these issues were analyzed in the Draft EIR in , Air Quality, IV.H, Noise and IV.K, Traffic and Transportation. Additionally, the Draft the potential traffic impacts of the proposed project when combined with the related ge IV.K-125 under “Cumulative Impacts.”

Comment No. 17-2

Our objections are as follows:

1. Often even before rush hour starts, driving north on Bundy Drive and attempting to make a left turn onto Nebraska Avenue, south bound traffic lanes are backed up beyond Iowa Avenue. Bundy Drive is 10 feet narrower between Nebraska Avenue on the north and just north of La Grange Avenue where the proposed village's southern entrance/exit is located,




than north or south of this section. This section has no parallel parking space in event of an emergency.

As described in the Draft EIR, the project would be required to dedicate by 15 feet and widen by 12 feet the west side of Bundy Drive along its frontage, from approximately Missouri Avenue to La Grange Avenue.

Comment No. 17-3

2. The southern entrance is extremely dangerous. It has less than a vehicle length of left turn lane into the proposed village. It would be impossible to make a left turn onto Bundy Drive from this access during rush hour.


The Bundy Drive roadway widening (refer to Response to Comment 17-2) would allow the installation of a northbound two-way left-turn lane on Bundy Drive north of La Grange Avenue to address left-turns into

ecommended roadway improvements to Bundy Drive south of this location (at Olympic Boulevard, Pico Boulevard, and the Santa Monica Freeway ramps) are expected to the project site. Additionally, r

alleviate some of the existing congestion along Bundy Drive adjacent to the project site, allowing for improved access into and out of the project site as well as to other businesses along this portion of the roadway.

Comment No. 17-4

3. Twenty feet wide road north of the project (extension of Amherst avenue) connects ,to Nebraska Avenue. When we questioned Ron Hirst, one of the officers of the project on the road's use at the November 2006 meeting, he stated it is for emergency vehicles only. But because of heavy traffic on Bundy Drive, we are certain this road will become the main access to the village. Traffic will converge at the entrance from east and west on Nebraska Avenue as well as north from Amherst Avenue, all attempting to enter the village thru this road. Also there will be those attempting to exit creating a huge traffic jam.


Please refer to Responses to Comments 11-3 and 11-4.

Comment No. 17-5

4. We reside near or at the comer of Nebraska and Amherst where the narrow road leads to the proposed village. Most of us are retirees who have lived here over 40 years enjoying the quiet environment. We take pleasure in walking and driving safely in out neighborhood. If the project is approved we would not be ble to back out of our driveway or return home a



lty and we would be faced with excess delays due to increased traffic. We would be forced to hear the traffic noise 24-7, mixed at times with ambulance sirens,

enter or exit this narrow road.


safely without difficu

and auto horns all competing to

With respect to traffic, please refer to Responses to Comments 11-1 and 11-4. With respect to traffic noise, please refer to Response to Comment 8-10.

Comment No. 17-6

Please disapprove this Bundy Village proposal. If you do approve, we are seriously interested in your reasoning. Please inform us in writing. The project proposes to build 385 condos along the busiest and narrowest section of Bundy Drive. Senior citizens living in those condo units would worry even more about their safety when entering or exiting the south access to Bundy Drive. This project does not contribute to the well-being or safety of the condo dwellers, residents at south end of Amherst Avenue, or the surrounding area, but only destroys and introduces danger to our quiet environment that we cherish so much.



Comment No. 17-7



John Williams


1629 Amherst Ave. Los Angeles, CA 90025

Comment No. 18-1

Regarding the information in the letter you sent regarding the Bundy Village and Medical Complex, the main impact will be on the already overburdened streets in the neighborhood. During rush hour, and early fternoons, the traffic on Bundy Drive is often at a standstill or moving extremely slow. Having lived in

the neighborhood for nineteen years, the traffic has gotten increasingly congested on all the surface treets. It is sometimes hazardous to cross the streets during peak traffic hours as frantic drivers leave eir workplaces.

esponse to Comment No. 18-1

a

sth

R

raffic impacts are analyzed in the Draft EIR in Section IV.K, Traffic and Transportation. The Draft EIR oncludes that following the implementation of mitigation measures impacts to some of the study

intersections would remain significant and unavoidable. With respect to pedestrian safety, the Draft EIR addresses the potential for the proposed project to increase traffic hazards due to a design feature such as sharp curves or design features. No significant impacts associated with this issue are identified in the Draft EIR.

Comment No. 18-2

Tc

The current use of the area included in the medical/residential proposal is light industrial/commercial which makes little impact on the quiet of the daytime hours in the neighborhood. Additionally, the increase of 375 residential units will have a severe impact on the parking situation and street traffic in our normally quiet day time streets. During rush hours, the streets are being used as short cuts for the busy streets, having 375 more residential units in a concentrated area will further deteriorate the quality of life for this area.


The Draft EIR analyzes off-site vehicular noise in Section IV.N, Noise. As discussed therein, none of the analyzed roadway segments in the project vicinity would exceed the City’s noise threshold pertaining to traffic-related operational noise. Further, the noise levels experienced at these roadway segments would not represent a substantial permanent increase in ambient noise levels (see Pages IV.N-25 through IV.N-26 in the Draft EIR).

With respect to the comments regarding impacts to area parking, Section IV.K, Traffic and Transportation, of the Draft EIR includes an analysis of the potential for the proposed project to result in inadequate parking capacity. As discussed therein, the proposed project would provide adequate parking



for the various uses associated with the proposed project. In fact, the proposed project would provide more parking spaces than required by the LAMC.

With respect to the deterioration of the quality of life for the area, this comment does not state a concern or question regarding the adequacy of the analysis contained in the Draft EIR. Therefore, a response is not required. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Bundy Village and Medical Park IV. Corrections and Additions Final Environmental Impact Report Page IV-1

IV. CORRECTIONS AND ADDITIONS

A. 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 staff-initiated text changes 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 double underlined. For corrections resulting from a response to a comment on the documents, references in parentheses refer to the comment letter and comment number.

B. CORRECTIONS AND ADDITIONS TO THE DRAFT EIR

Section I, Introduction/Summary

Page I-11 of the Draft EIR, last three paragraphs, revise as follows:

Based on the URBEMIS 2007 computer model analysis, construction-related daily emissions would exceed SCAQMD significance thresholds for NOx during the demolition and site grading phases, while the peak daily emissions of the other four construction-related emissions (ROG, CO, SOx, and PM10)would not exceed SCAQMD significance thresholds. In addition, PM10 and PM2.5 would exceed thresholds during grading, and construction-related daily emissions would exceed SCAQMD significance thresholds for ROG during the building construction phase.

The exceedance of SCAQMD significance thresholds for NOx during the site demolition phase would mainly be generated from on-road diesel emissions associated with the hauling of demolition waste from the project site. As such, this would be a significant impact. Since no feasible mitigation is available to reduce the peak daily construction emissions of NOx to below the thresholds of significance recommended by the SCAQMD, this impact would be significant and unavoidable.

The exceedance of the SCAQMD PM10 and PM2.5 thresholds would be caused by the handling of soils during the grading phases of construction. Mitigation Measure C-1 (Rule 403) would reduce these emissions, and is included in the analysis since implementation of Rule 403 is a requirement for the contractor. Mitigation Measures C-2 through C-12 would reduce the dust emissions more but many are inclusive in Rule 403 and, therefore, already included in the emissions. The remaining PM10 and PM2.5

mitigation measures would reduce the emissions even more but given that the PM10 and PM2.5 emissions are double the thresholds it is very unlikely that these significant impacts can be overcome. There for the particulate emissions from the project would still exceed the SCAQMD thresholds after the implementation of Mitigation Measures C-1 through C-12. The PM10 and PM2.5 emissions after mitigation would be considered significant and unavoidable.



Section IV.C, Air Quality

Page IV.C-29 of the Draft EIR, first paragraph under the subheading Trucks, revise as follows:

As discussed above, the existing commercial and retail uses would be demolished as a part of the proposed project. This would entail the removal of approximately 16,000 cubic yards of waste.Demolition of the existing buildings would require approximately 25.7 12 truck trips (round trips) per day with each truck hauling 15 cubic yards of waste for a total of 88 days. Trips were assumed to average 30 miles each way.

In addition, this analysis assumes that approximately 203,200 cubic yards of soil would be exported during excavation of the subterranean parking facility.1 This would require approximately 174 205 truck trips (truck round trips) per day with each truck hauling 15 cubic yards of soil for a total of 66 days. Trips were assumed to average 20 miles each way.

Page IV.C-30 of the Draft EIR, first paragraph under the subheading Construction Emissions, revise as follows:

As shown in Table IV.C-6, Peak Mass Daily Construction Emissions, construction-related daily emissions are estimated to exceed SCAQMD significance thresholds for NOx during the grading phase, and for ROG during the construction phase. Therefore, the potential air quality impact associated with the construction of the proposed project would be potentially significant for NOx and ROG and emissions. All other emission would be below the SCAQMD significance threshold and would, therefore, be considered less than significant.

Table IV.C-6 on Pages IV.C-30 and IV.C-31 of the Draft EIR, revise as follows:

Table IV.C-6 Peak Mass Daily Construction Emissions

Peak Day Emissions in Pounds per Day Emissions Source ROG NOx CO SOx PM10 PM2.5 CO2

Existing Building Demolition Fugitive Dust 0.00 0.00 0.00 0.00 8.27 1.72 0.00

Off-Road Diesel 0.008.47 0.0.28 0.0035.53 0.00 26.253.2

55.452.9

90.005,596

.53

On-Road Diesel 9.430.99 77.5113.27

38.995.19 0.000.01 3.620.63 3.330.5

56,616.491,544.90

Worker Trips 0.10 0.19 3.03 0.00 0...02 0.01 311.22

Total Emissions 11.899.56

109.3081.74

54.3743.75 0.040.01 31.3912.

1710.105.

2710,606.817,452.65

1 The proposed project would include a total of approximately 221,400 cubic yards of excavation, including

approximately 203,200 cubic yards of material to be exported and approximately 16,600 cubic yards of material to be reused on-site.





SCAQMD Thresholds 75.0 100.0 550.0 150.0 150.0 55.0 N/A Significant Impact? NO YESNO NO NO NO NO N/A

Mass Grading

Fugitive Dust 0.00 0.00 0.00 0.00 379.60120.00

79.2825.06 0.00

Off-Road Diesel 6.285.35 49.1846.99

25.1521.90 0.00 2.872.21 2.642.0

33,963.893,898.88

On-Road Diesel 8.5311.38

113.84151.79

44.4959.32 0.120.17 5.407.20 4.716.2

713,249.8917,666.52

Worker Trips 0.0706 0.1311 2.121.82 0.00 0.020.01 0.01 217.85186.73


163.15198.89

71.7683.04

0.0130.17

387.89129.42

86.6333.37

17,431.6321,752.13

Dust Control Measures 0.00 0.00 0.00 0.00 (57.83) (12.08) 0.00Total Emissions after Dust Control Measures 16.79 198.89 83.04 0.17 71.59 21.29 21,752.13

SCAQMD Thresholds 75.0 100.0 550.0 150.0 150.0 55.0 N/A Significant Impact? NO YES NO NO YESNo YESNo N/A

Fine Grading

Fugitive Dust 0.00 0.00 0.00 0.00 382.49120.00

81.8325.06

4,181.740.00

Off-Road Diesel 6.285.35 49.1846.99

25.1521.90 0.00 2.872.21 2.642.0

33,963.893,898.88

On-Road Diesel 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Worker Trips 0.0706 0.1311 2.121.82 0.00 0.020.01 0.01 217.85186.73

Total Emissions 6.355.41 49.3147.10

27.2823.72 0.00 382.491

22.2281.9327.10

4,181.744,085.61

SCAQMD Thresholds 75.0 100.0 550.0 150.0 150.0 55.0 N/ASignificant Impact? NO NO NO NO YESNo YESNo N/A

Trenching

Fugitive DustOff-Road Diesel 2.333.01 20.1224.24

8.4610.81 0.00 1.001.38 0.921.2

71,714.612,042.10

Worker Trips 0.04 0.07 1.21 0.00 0.01 0.00 124.49


9.6812.02 0.00 1.011.39 0.921.2

71,839.122,166.59

SCAQMD Thresholds 75.0 100.0 550.0 150.0 150.0 55.0 N/ASignificant Impact? NO NO NO NO NO NO N/A

Building Construction

Off-Road Diesel 4.6560 26.2534.55

14.9918.73 0.00 1.911.92 1.751.7

72,259.282,781.50

Vendor Trips 1.52 17.8481 13.8886 0.03 0.88 0.75 2,848843.7264

Worker Trips 3.002.99 5.565.55 91.1290.92 0.10 0.68 0.36 9,354335.

8712


119.98123.51 0.13 3.473.48 2.872.8

814,462.8814,960.26


PavingPaving Off-Gas 4.970.52 0.00 0.00 0.00 0.00 0.00 0.00





Paving Off Road Diesel 3.213.94 18.8923.21

9.6111.82 0.00 1.632.00 1.501.8

41,272.411,568.12

Paving On Road Diesel 1.860.20 24.812.61 9.701.02 0.030.00 1.180.12 1.030.1

12,887.703

04.29Paving Worker Trips 0.05 0.09 1.52 0.00 0.01 0.01 155.61


43.8025.91

20.8214.36 0.030.00 2.822.13 2.531.9

64,315.722,028.02


Architectural Coatings

Architectural Coating 735733.9025 0.00 0.00 0.00 0.00 0.00 0.00

Coating Worker Trips 0.55 1.0302 17.1309 0.02 0.14 0.08 1,890886.7488

Total Emissions 736.45733.80 1.031.02 17.1317.

09 0.02 0.14 0.08 1,890886.7488

SCAQMD Thresholds 75.0 100.0 550.0 150.0 150.0 55.0 N/ASignificant Impact? YES NO NO NO NO NO N/A Source: URBEMIS 2007. Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix C to the Final EIR.

Page IV.C-63 of the Draft EIR, the first two paragraphs under the subheading Construction-Related Project Impacts, revise as follows:

The proposed project’s impacts on regional air quality resulting from construction activities would be potentially significant for ROG, and NOx, PM10 and PM2.5 specifically during the 2009 demolition and sitegrading/excavation phases, and would be significant for NOx, PM10 and PM2.5, and for ROG would be potentially significant during the building construction phase, specifically during the 2010 construction phase as previously outlined in Table IV.C-6.

The exceedance of the SCAQMD PM10 and PM2.5 thresholds would be caused by the handling of soils during the grading phases of construction. The mitigation measures C-1 (Rule 403) would reduce these emissions and is included in the analysis since implementation of Rule 403 is a requirement for the contractor. Mitigation Measures C-2 through C-12 would reduce the dust emissions more but many are inclusive in rule 403 and, therefore, already included in the emissions. The remaining PM10 and PM2.5

mitigation measures would reduce the emissions even more but given that the PM10 and PM2.5 emissions are double the thresholds it is very unlikely that these significant impacts can be overcome. There for the particulate emissions from the project would still exceed the SCAQMD thresholds after the implementation of Mitigation Measures C-1 through C-12. The PM10 and PM2.5 emissions after mitigation would be considered significant and unavoidable.



Page IV.C-65 of the Draft EIR, first paragraph under the subheading Cumulative Construction Impacts, revise as follows:

As previously discussed, while construction of the proposed project would not exceed the SCAQMD thresholds for CO, and SOx, PM10, and PM2.5, construction activities would exceed the SCAQMD threshold for ROG, and NOx, PM10 and PM2.5. Even after implementation of Mitigation Measures C-1 through C-20, the peak daily construction emissions of these pollutants are still anticipated to exceed the threshold of significance recommended by the SCAQMD. As no additional feasible mitigation is available to reduce these emissions, construction-related ROG, and NOx, PM10 and PM2.5 impacts would be significant and unavoidable. Consequently, the daily construction emissions generated by the proposed project would be cumulatively considerable. Therefore, the cumulative impact of the proposed project for ROG, and NOx, PM10 and PM2.5 construction emissions would remain significant and unavoidable.

Table IV.C-8 on Pages IV.C-49 of the Draft EIR, revise as follows:

Table IV.C-8 Estimated Future (2011) Daily Operational Emissions

Emissions in Pounds per Day Emissions Source ROG NOx CO SOx PM10 PM2.5

Summertime (Smog Season) Emissions Future With Project Emissions Water and Space Heating, and Cooking Appliances 0.67 8.85 5.31 0.00 0.02 0.02

Landscape Maintenance Equipment 2.292.42 0.210.23 17.0118.

56 0.00 0.050.06 0.06

Consumer Products 19.75 0.00-- 0.00-- 0.00-- 0.00-- --Architectural Coatings 4.01 0.00-- 0.00-- 0.00-- 0.00-- --

Mobile (Vehicle) Sources 126.32143.29

183.63130.48

1,642.021,533.70 1.991.54 326.732

67.27 51.02


192.69139.56

1,664.341,557.57 1.991.54 326.752

67.35 51.10

SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00Significant Impact? Yes Yes Yes No YesFuture Without Project EmissionsWater and Space Heating, and Cooking Appliances 0.13 1.75 1.47 0.00 0.00 0.00

Landscape Maintenance Equipment 0.37 0.06 4.64 0.00 0.02 0.02

Architectural Coatings 1.38 -- -- -- -- --Mobile (Vehicle) Sources 19.07 19.87 235.75 0.25 43.10 8.22Total Emissions 20.95 21.68 241.86 0.25 43.12 8.24Total Project Net Emissions 149.19 117.88 1,315.71 1.29 224.23 42.78SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00Significant Impact? Yes Yes Yes No Yes No

Wintertime (Non-Smog Season) EmissionsFuture With Project EmissionsWater and Space Heating, and Cooking Appliances 0.67 8.85 5.31 0.00 0.02 0.02



Table IV.C-8 Estimated Future (2011) Daily Operational Emissions

Emissions in Pounds per Day Emissions Source ROG NOx CO SOx PM10 PM2.5

Consumer Products 19.75 0.00-- 0.00-- 0.00-- 0.00-- --Architectural Coatings 4.01 0.00-- 0.00-- 0.00-- 0.00-- --

Mobile (Vehicle) Sources 141.18165.19

221.06159.86

1,574.011,510.52 1.641.23 326.732

67.27 51.02


229.91168.71

1,579.321,515.83 1.641.23 326.752

67.29 51.04

Future Without Project EmissionsSCAQMD Thresholds55.0055.00550.00150.00150.00Water and Space Heating, and Cooking AppliancesSignificant Impact?

0.13Yes Yes1.75 Yes1.47 No0.00 Yes0.00 0.00

Architectural Coatings 1.38 -- -- -- -- --Mobile (Vehicle) Sources 20.81 24.45 225.25 0.20 43.10 8.22Total Emissions 22.32 26.20 226.72 0.20 43.10 8.22Total Project Net Emissions 167.30 142.51 1,289.11 1.03 224.19 42.82SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00Significant Impact? Yes Yes Yes No Yes NoSource: Christopher A. Joseph & Associates, 2009. Calculation sheets are provided in Appendix C to the Final EIR.

Section IV.G, Land Use and Planning

Page IV.G-3 of the Draft EIR, the top of the page above the subheading City of Los Angeles General Plan insert the following text:

Making the Connections: 2008 Regional Transportation Plan

Making the Connections is the 2008 Regional Transportation Plan (RTP) for the SCAG region. The RTP is a multi-modal plan to address the region’s transportation system and growth pattern beyond the year 2038. The RTP provides the basic policy and program framework for long-term investment in the SCAG region’s transportation system. The goals of the RTP are to maximize mobility and accessibility, ensure safety and reliability, preserve the existing transportation system, maximize productivity of the transportation system, protect the environment, and encourage land use and growth patterns that complement the transportation system. The RTP also includes policies which reflect the transportation priorities for the SCAG region, and serve to guide plan development. The 2008 RTP ended its public comment period, which commenced in December 2007 and ended on February 19, 2008. The Final 2008 RTP was adopted by the Regional Council on May 8, 2008.2

2 SCAG, Making the Connections: 2008 Regional Transportation Plan, website: http://www.scag.ca.gov/rtp2008,

May 2008.



Page IV.G-31 of the Draft EIR, bottom of the page, insert the following text:

As previously discussed, since the proposed project is considered to be regionally significant, it must adhere to the goals and policies of the 2008 RTP. There are seven relevant goals of the 2008 RTP that apply to the proposed project:

� RTP Goal 1: Maximize mobility and accessibility for all people and goods in the region;

� RTP Goal 2: Ensure travel safety and reliability for all people and goods in the region;

� RTP Goal 3: Preserve and ensure a sustainable regional transportation system;

� RTP Goal 4: Maximize the productivity of our transportation system;

� RTP Goal 5: Protect the environment, improve air quality and promote energy efficiency;

� RTP Goal 6: Encourage land use and growth patterns that complement our transportation investments; and

� RTP Goal 7: Maximize the security of our transportation system through improved system monitoring, rapid recovery planning, and coordination with other security agencies.

As indicated by SCAG, RTP Goals 2, 3, and 7 are not applicable to then proposed project because they are regional issues that do not apply to a project-level analysis.3 With respect to RTP Goal 1, mobility refers to the speed at which a vehicle travels and the delay or difference between the actual travel time and travel time that would be experienced if a vehicle traveled at the legal speed limit. Accessibility measures the degree in which a transportation system provides access to opportunities including, but not limited to, jobs, education, shopping, recreation, and medical care. As shown in Table IV.K-18, Critical Movement Analysis Summary: Study Intersections Future (2011) Plus Physical/Signal Mitigation Conditions several of the study intersections would be below LOS D following mitigation. According to SCAG, this is an acceptable LOS in an urban area.4 With respect to RTP Goal 4, productivity is a measure of a transportation system’s efficiency that reflects the degree in which a transportation system performs during peak traffic conditions. Operation of the proposed project would impair productivity at several intersections proximate to the project site. However, according to SCAG, this does not present enough evidence to determine if the proposed project is consistent with this goal of the 2008 RTP.5 With respect to RTP Goal 5, as discussed in Section IV.C, Air Quality, the proposed project would exceed the established SCAQMD threshold levels for ROG, NOx, CO, and PM10 during the both the summertime (smog season) and the winter time (non-smog season). This would be primarily due to the increase in

3 Written correspondence from Jacob Lieb, Manager Assessment, Housing & EIR, SCAG, June 10, 2009. 4 Ibid. 5 Ibid.



motor vehicles travelling to and from the project site. As this would be a significant and unavoidable impact, the proposed project would not be consistent with RTP Goal 5. With respect to RTP Goal 6, the proposed project would be located proximate to regional transportation infrastructure including I-405 and I-10, would be served by adequate public transportation, and would offer access to various local roads that facilitate regional transportation including, but not limited to, Olympic Boulevard and Bundy Drive. Therefore, the proposed project would be consistent with RTP Goal 6.

Overall, the proposed project would be consistent with the majority of the applicable 2008 RTP Goals. Therefore, impacts associated with the proposed project’s consistency with the 2008 RTP would be less than significant.

Page IV.G-3 of the Draft EIR, the top of the page, above the subheading City of Los Angeles General Plan, insert the following text:

Compass Growth Vision

The Compass Growth Vision Report6 provides a comprehensive planning vision for the six-county SCAG region. In the short term, SCAG’s growth visioning process has been incorporated into immediate housing allocation and transportation planning decisions. In the long term, the Growth Vision Report is a framework designed to help local jurisdictions address growth management cooperatively and to help coordinate regional land use and transportation planning.

The underlying goal of the Growth Vision Report is to make the SCAG region a better place to live, work, and play for all residents regardless of race, ethnicity or income. To organize strategies for improving the quality of life in the SCAG region, the following four principles are identified: mobility, livability, prosperity and sustainability. Decisions regarding growth, transportation, land use, and economic development should support and be guided by these principles. The Growth Vision Report also provides policy and planning strategies as a way to achieve each of its principles. The following four principles serve as the foundation for the Growth Vision Report and its planning strategies:

� Improve mobility for all residents;

� Foster livability in all communities;

� Enable prosperity for all people; and

� Promote sustainability for future generations.

Several areas throughout the SCAG region have been identified as strategic opportunity areas for the application of the above-listed principles. These areas are referred to as the “Compass 2% Strategy Opportunity Areas.” The Compass 2% Strategy Opportunity Areas represent key areas of the SCAG

6 Southern California Association of Governments, Growth Vision Report, Southern California Compass, June 2004.



region with a high potential to implement projects, plans and/or policies consistent with the principles defined in the Compass Growth Vision report. The project site is located within a Compass 2% Strategy Opportunity Area.

Page IV.G-32 of the Draft EIR, top of the page, insert the following text:

As demonstrated below in Table IV.G-4, Project Consistency with the Applicable Strategies of the Compass Growth Vision, the proposed project would be consistent with most of the strategies of the Compass Growth Vision. Therefore, impacts associated with the proposed project’s consistency with the Compass Growth Vision would be less than significant.

Table IV.G-4 Project Consistency with the Applicable Strategies of the Compass Growth Vision

Principle Strategy Consistency AnalysisGV P1.1: Encourage transportation investments and land use decisions that are mutually supportive.

Consistent. The project site is located proximate to I-405 and I-10, which are both major highways that provide regional access. Additionally, the project site has frontages along Olympic Boulevard and Bundy Drive, which are major roadways that provide local and regional access. Furthermore, the project site would be served by two Santa Monica Big Blue Bus lines (BBB 5 and BBB 14). Therefore, the proposed project would be consistent with this strategy.

GV P1.2: Locate new housing near existing jobs and new jobs near existing housing.

Consistent. The proposed project would place housing near existing employment centers located in the West Los Angeles community. Furthermore, the proposed project would generate approximately 853 net new employees. Therefore, the proposed project would be consistent with this strategy.

Principle 1: Improve mobility for all residents.

GV P1.3: Encourage transit-oriented development.

Consistent. As discussed in Section IV.K, Traffic and Transportation, the project site is served by two Santa Monica Big Blue Bus lines. In addition, the project site is within walking distance of the planned Metro Expo Line train station. Moreover, the Applicant intends to voluntarily contribute an additional two million dollars




Principle Strategy Consistency Analysisbeyond the required West Los Angeles Transportation Improvement and Mitigation Specific Plan fees, which could be applied towards transit improvements such as improved bus stops, transit information kiosks, and maps/connectivity signage. Therefore, the proposed project would be consistent with this strategy.

GV P1.4: Promote a variety of travel choices.

Consistent. As shown in Table IV.C-10, Project Consistency with Applicable Policies of the General Plan Air Quality Element, the proposed project would be consistent with applicable policies of the General Plan Air Quality pertaining to the promotion or encouragement of a variety of travel choices. Therefore, the proposed project would be consistent with this strategy.

GV P2.1: Promote infill development and redevelopment to revitalize existing communities.

Consistent. The project site is currently developed with four structures and a surface parking area. The existing structures include an office, manufacturing and distribution facility and three single-story office buildings. The proposed project would redevelop the project site with a mixed-use residential and retail development and medical offices. Therefore, the proposed project would be consistent with this strategy.

GV P2.2: Promote developments, which provide a mix of uses.

Consistent. The proposed projectwould include a mix of land uses including residential, retail, and medical offices. Therefore, the proposed project would be consistent with this strategy.

Principle 2: Foster livability in all communities.

GV P2.3: Promote “people scaled,” walkable communities.

Consistent. As demonstrated in Table IV.G-8, Project Consistency with Applicable Walkability Checklist Strategies, the proposed project would be consistent with the strategies in




Principle Strategy Consistency Analysisthe City of Los Angeles Walkability Checklist: Guidance for Entitlement Review. Therefore, the proposed project would be consistent with this strategy.

GV P2.4: Support the preservation of stable, single-family neighborhoods.

Consistent. As discussed in Section IV.G, Land Use and Planning, the proposed project would not remove any single-family residences. Therefore, the proposed project would be consistent with this strategy.

Principle 3: Enable prosperity for all people.

GV P3.1: Provide, in each community, a variety of housing types to meet the housing needs of all income levels.

Partially Consistent. The proposed project would include approximately 385 dwelling units comprised of 146 market-rate units for seniors, 62 affordable (moderate income) units for seniors, and 177 unrestricted market-rate units. However, as the proposed project would not include any low-income dwelling units, it would be partially consistent with this strategy.

GV P4.2: Focus development in urban centers and existing cities.

Consistent. The project site is located in the urbanized West Los Angeles community of the City of Los Angeles. Therefore, the proposed project would be consistent with this strategy.

Principle 4: Promote sustainability for future generations.

GV P4.3: Develop strategies to accommodate growth that uses resources efficiently, eliminate pollution and significantly reduce waste.

Consistent. As demonstrated in Table IV.C-12, Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies, the proposed project would be consistent with all feasible and applicable strategies to reduce pollution and waste, as well as promote the efficient use of resources in California. Therefore, the proposed project would be consistent with this strategy.

GV P4.4: Utilize “green” development strategies.

Consistent. As discussed in Section IV.D, Energy, the proposed project shall be in full compliance with the policies of




Principle Strategy Consistency Analysisthe City of Los Angeles Green Building Ordinance. Therefore, the proposed project would be consistent with this strategy.

Source: Southern California Association of Governments, Compass Growth Vision, June 2004; and Christopher A. Joseph & Associates, June 2009.

Section IV.I, Population and Housing

Page IV.I-2 of the Draft EIR, Table IV.I-2, revise as follows:

Table IV.I-2 SCAG Population and Housing Forecasts

for the City of Los Angeles

Year Population Housing Units2005 3,955,392 1,369,590 2015 4,128,1254,124,082 1,493,244

10-year Increase 172,733 (4.4%)168,690 (4.3%) 123,654 (9.0 %)

Source: Southern California Association of Governments, Integrated Growth Forecast, Adopted RTP Growth Forecast,http://www.scag.ca.gov/forecast/index.htm, August 27, 2008; and Javier Vasquez Southern California Association of Governments, Information Technology Division, July 2007.

Page IV.I-5 of the Draft EIR, first paragraph, revise as follows:

According to SCAG, there were 3,955,392 persons and 1,369,590 housing units in the City of Los Angeles in the year 2005.7 Since the U.S. Census does not publish population projection data, the analysis in this section will rely on the population referenced in the SCAG data. By the year 2015, SCAG forecasts the City of Los Angeles population will increase to 4,128,125 4,124,082 persons (a 4.4 4.3 percent increase), and 1,493,244 residences (a 9.0 percent increase). SCAG’s growth projections for the City of Los Angeles are in Table IV.I-2, SCAG Population and Housing Projections Forecasts for the City of Los Angeles.

7 Southern California Association of Governments, Integrated Growth Forecast, Adopted RTP Growth Forecast,http://www.scag.ca.gov/forecast/index.htm, August 27, 2008.



Section IV.K, Traffic and Transportation

Figure IV.K-10 on Page IV.K-59 of the Draft EIR, revise as follows:



Figure IV.K-11 on Page IV.K-61 of the Draft EIR, revise as follows:



Page IV.K-51 of the Draft EIR, 4th paragraph, revise as follows:

The LAMC requires “medical office” developments to provide a minimum of 5.0 parking spaces for each 1,000 square feet of floor area, while typical retail uses, including “specialty market” use, require a minimum of 4.05.0 parking spaces per 1,000 square feet of floor area, and restaurant use requires a minimum of 10.0 parking spaces for each 1,000 square feet of floor area. These ratios would require a total of 1,924 spaces for the proposed 384,735-square-foot medical office component. As noted above, a total of approximately 1,976 spaces (including valet) would be provided for the medical office component. The commercial (retail, restaurant, and specialty market) facilities would require approximately 204 spaces for the 51,021 square foot specialty market, a total of approximately 237552 spaces for the 59,317110,338 square feet of retail usescomponents, and an additional 95 spaces for the anticipated 9,500 square feet of restaurant uses, for a total commercial component parking requirement of approximately 536647 spaces. The project proposes to provide a total of approximately 682 parking spaces for these commercial uses within the subterranean levels of the Parcel A parking garage.

Page IV.K-57, second paragraph, revise as follows:

Although the exact mix of units (e.g., number of bedrooms per unit) has not been established for the market-rate residential units, for purposes of this analysis, it was assumed that each of the market-rate residential units would require the maximum parking identified by the Advisory Agency recommendations, while each of the senior units (both market-rate and affordable) would be subject to the reduced requirements identified in the LAMC. Based on these requirements, the project’s 177 market-rate residential units would be required to provide resident parking of 2.0 spaces per unit plus guest parking of 0.5 spaces per unit, for a total of approximately 354 resident and 89 guest spaces, or 443 total spaces. The 208 senior residential units (including 62 affordable units) would provide 1.5 spaces per unit, for a total requirement of require an additional 208312 parking spaces., for a total Combined, the proposed project’s residential parking requirement ofwould be approximately 651666 spaces. The proposed project includes a total of approximately 737 residential parking spaces.

Page IV.K-125 of the Draft EIR, top of the page, insert the following text:

Alternative Transportation

A project could have a significant impact on alternative transportation if it conflicted with adopted policies, plans, or programs designed to support alternative transportation. Local public transportation in the project area is provided by BBB. As discussed earlier in this section, BBB Line 5 operates between downtown Santa Monica and the Rimpau Transit Center, and BBB Line 24 operates between Moraga Drive/Sepulveda Boulevard to the north, and the community of Mar Vista to the south traveling by way of Barrington Avenue, Bundy Drive, and Centinela Avenue, serving the community of Brentwood and the Santa Monica Airport along the way.

The proposed project would result in an increase in the number of employees and patrons at the projectsite compared to existing conditions. While it is anticipated that the primary travel choice for most of these employees and visitors would be private automobile, the proposed project would in no way conflict



with adopted policies designed to support alternative transportation. Additionally, implementation of Mitigation Measure K-23 would encourage and facilitate the use of alternative transportation through programs that would include, but not be limited to, carpooling, transit passes or subsidies, flex-use vehicles, and bicycle racks and showers/lockers. Therefore, impacts associated with this issue would be less than significant.

Section IV.L, Utilities

Page IV.L-40 of the Draft EIR, Mitigation Measure L-23, revise as follows:

(L-2322) To support recycling of operational wastes, the proposed project shall include a residential recycling program.

Section VI, Alternatives to the Proposed Project

Page VI-18 of the Draft EIR, last paragraph, revise as follows:

Construction activities under Alternative B would be similar to the proposed project, although at a lesser level than those associated with the proposed project because this alternative would involve less floor area and parking spaces. However, demolition activities under Alternative B would be identical to the proposed project, as the same number and type of structures would be demolished. Similar to the proposed project, construction-related daily emissions under Alternative B would exceed SCAQMD significance thresholds for NOx during initial demolition and grading activities, for PM10 and PM2.5

during grading, and for ROG during the construction phase. With respect to localized construction emissions, the proposed project would exceed SCAQMD significance thresholds for NOx, whereas the localized emissions of CO, PM10, and PM2.5 would not exceed SCAQMD significance thresholds. As no feasible mitigation is available to reduce peak levels of NOx, this impact would be significant and unavoidable. Furthermore, although this alternative would involve roughly 30 percent less floor area than the proposed project, it is estimated that construction-related emissions would still exceed SCAQMD significant thresholds for ROG during construction, similar to the proposed project. As a result, the potential air quality impacts associated with the construction of Alternative B would be significant and unavoidable, which is similar to the proposed project.

Page VI-37 of the Draft EIR, paragraph under subheading Construction Emissions, revise as follows:

Construction activities under Alternative C would be similar to the proposed project, although at a greater level than those associated with the proposed project because this alternative would involve additional floor area and parking spaces. However, demolition activities under Alternative B would be identical to the proposed project, as the same number and type of structures would be demolished. Similar to the proposed project, construction-related daily emissions under Alternative C may exceed SCAQMD significance thresholds for NOx during demolition and grading activities, for PM10 and PM2.5 during grading, and for ROG during the construction phase. With respect to localized construction emissions,



the proposed project would exceed SCAQMD significance thresholds for NOx, whereas the localized emissions of CO, PM10, and PM2.5 would not exceed SCAQMD significance thresholds. As no feasible mitigation is available to reduce peak levels of NOx, this impact would be significant and unavoidable. Similar to the proposed project, the potential air quality impact associated with the construction of Alternative C would be significant and unavoidable.


Construction activities under Alternative D would be similar to the proposed project, although at a greater level than the proposed project because it would involve additional floor area and parking. Demolition activities under Alternative D would be identical to the proposed project, as the same number and type of structures would be demolished. Similar to the proposed project, construction-related daily emissions under Alternative D may exceed SCAQMD significance thresholds for NOx during demolition andgrading activities, for PM10 and PM2.5 during grading, and for ROG during the construction phase. With respect to localized construction emissions, the proposed project would exceed SCAQMD significance thresholds for NOx, whereas the localized emissions of CO, PM10, and PM2.5 would not exceed SCAQMD significance thresholds. As no feasible mitigation is available to reduce peak levels of NOx, this impact would be significant and unavoidable. Similar to the proposed project, the potential air quality impact associated with the construction of Alternative D would be significant and unavoidable. Thus, the significant and unavoidable construction air quality impact under Alternative D would be similar to the significant and unavoidable impact under the proposed project. As such, Alternative D would not avoid the significant and unavoidable construction air quality impact.


Construction activities under Alternative E would be similar to the proposed project, although at a slightly greater level than those under the proposed project because this alternative would involve additional floor area and parking spaces. However, demolition activities under Alternative B would be identical to the proposed project, as the same number and type of structures would be demolished. Similar to the proposed project, construction-related daily emissions under Alternative E may exceed SCAQMD significance thresholds for NOx during demolition and grading activities, for PM10 and PM2.5 during grading, and for ROG during the construction phase. Similar to the proposed project, the potential air quality impact associated with the construction of Alternative E would be significant and unavoidable, although slightly greater due to the additional construction. Thus, the significant and unavoidable construction air quality impact under Alternative E would be similar to the significant and unavoidable impact under the proposed project.

Bundy Village and Medical Park V. Mitigation Monitoring Program Final Environmental Impact Report Page V-1

V. MITIGATION MONITORING PROGRAM

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 State CEQA Guidelines provides additional direction on mitigation monitoring or reporting). The Los Angeles Department of City Planning (the “Planning Department”) is the Lead Agency for the proposed project.

An EIR has been prepared to address the potential environmental impacts of the proposed project. Where appropriate, the EIR includes recommended mitigation measures to avoid or substantially lessen the significant environmental impacts associated with the proposed project. The EIR includes other recommended mitigation measures that would reduce further non-significant environmental impacts associated with the proposed project. The mitigation measures are listed and categorized by impact area, 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 Occupancy (post-construction).

� Enforcement Agency, the agency with the power to enforce the mitigation measure.

� Monitoring Agency, the agency to which reports involving feasibility, compliance, implementation and development are made.

The MMP for the proposed project will be in place throughout all phases of the project. The project applicant shall be responsible for implementing all mitigation measures unless otherwise noted. The applicant shall also be obligated to provide certification, as identified below, to the appropriate monitoring agency and the appropriate enforcement agency that compliance with the required mitigation measure has been implemented. The City’s existing planning, engineering, review, and inspection processes will be used as the basic foundation for the MMP procedures and will also serve to provide the documentation for the reporting program.

The substance and timing of each certification report that is submitted to the Planning Department shall be at the discretion of the Planning Department. Generally, each report will be submitted to the Planning Department in a timely manner following completion/implementation of the applicable mitigation measure and shall include sufficient information to reasonably determine whether the intent of the measure has been satisfied. The Planning Department in conjunction with the project Applicant shall assure that project construction occurs in accordance with the MMP. The South Coast Air Quality



Management District (SCAQMD) shall be responsible for the implementation of corrective actions relative to violations of SCAQMD rules associated with mitigation. Departments listed below are all departments of the City of Los Angeles unless otherwise noted.

A. IMPACTS FOUND TO BE LESS THAN SIGNIFICANT

(A-1) A covenant and agreement shall be recorded prior to obtaining a grading permit stating that if any archaeological materials are encountered during the course of project development, construction shall be halted. The services of an archaeologist shall be secured by contacting the Center for Public Archaeology - Cal State University Fullerton, or a member of the Society of Professional Archaeologist (SOPA) or a SOPA-qualified archaeologist to assess the resources, evaluate the potential impact (if any), and prescribe an appropriate method for preserving the resource either by removing the resource from where it is found or by documenting the resource before construction may again commence. Copies of the archaeological survey, study or report shall be submitted to the South Central Coastal Information Center at California State University Fullerton, Department of Anthropology.

Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

(A-2) A covenant and agreement shall be recorded prior to obtaining a grading permit stating that if any paleontological materials are encountered during the course of the project development, construction shall be halted. The services of a paleontologist shall be secured by contacting the Center for Public Paleontology - USC, UCLA, Cal State Los Angeles, Cal State Long Beach, or the Natural History Museum of Los Angeles County to assess the resources, evaluate the potential impact (if any), and prescribe an appropriate method for preserving the resource either by removing the resource from where it is found or by documenting the resource found before construction may again commence. Copies of the paleontological survey, study or report shall be submitted to the Natural History Museum of Los Angeles County.


(A-3) If human remains are discovered at the project site during construction, work at the specific construction site at which the remains have been uncovered shall be suspended, and the City of L.A. Department of Building and Safety and County Coroner shall be immediately notified. If the remains are determined by the County Coroner to be Native American, the Native American Heritage Commission (NAHC) shall be notified within 24 hours, and the guidelines of the NAHC shall be adhered to in the treatment and disposition of the remains.




(A-4) The Applicant shall comply with and implement applicable requirements of the Standard Urban Stormwater Mitigation Plan (SUSMP) approved by the Los Angeles Regional Water Control Board for managing stormwater run-off from the site during construction and operations.

Monitoring Phase: ConstructionEnforcement Agency: Department of Public Works Monitoring Agency: Department of Public Works, Regional Water Quality Control Board

(A-5) The Applicant shall implement all applicable and feasible stormwater BMPs, including but not limited to structural BMPs, in accordance with best management practices.

Monitoring Phase: ConstructionEnforcement Agency: Department of Public Works Monitoring Agency: Department of Public Works, Regional Water Quality Control Board

(A-6) Post development peak stormwater runoff discharge rates shall be approved by the City of Los Angeles where the estimated peak stormwater discharge rate will not result in significant increased potential for downstream erosion.

Monitoring Phase: ConstructionEnforcement Agency: Department of Public Works, Department of Building and SafetyMonitoring Agency: Department of Public Works, Department of Building and Safety

B. AESTHETICS

The proposed project would have a less-than-significant impact with respect to aesthetics. Therefore, no mitigation measures are recommended.

C. AIR QUALITY

(C-1) All unpaved demolition and construction areas shall be wetted at least twice daily during excavation and construction, and temporary dust covers shall be used to reduce dust emissions and meet SCAQMD District Rule 403.



Monitoring Phase: ConstructionEnforcement Agency: Department of Building and Safety, South Coast Air Quality Management DistrictMonitoring Agency: Department of Building and Safety, South Coast Air Quality Management District

(C-2) The owner or contractor shall keep the construction area sufficiently dampened to control dust caused by grading and hauling, and at all times provide reasonable control of dust caused by wind.


(C-3) All loads shall be secured by trimming, watering, or other appropriate means to prevent spillage and dust.


(C-4) All materials transported off-site shall be either sufficiently watered or securely covered to prevent excessive amounts of dust.


(C-5) All trucks hauling dirt, sand, soil, or other loose materials shall be covered and shall maintain at least two feet of freeboard (between the top of the load and the top of the trailer) in accordance with CVC Section 23114.




(C-6) Following daily construction activities, adjacent paved streets found to contain visible soil material that carried over from the project site shall be swept.


(C-7) Soil stabilizers shall be applied to inactive construction areas as necessary.


(C-8) Ground cover in disturbed areas shall be quickly replaced.


(C-9) All haul roads shall be watered twice daily while in use during construction activities.


(C-10) All stock piles of debris, dirt, or rusty materials shall be covered with a tarp to prevent the release of fugitive dust.


(C-11) Vehicle speed on unpaved roads shall be reduced to less than 15 miles per hour (mph).




(C-12) The Project Developer shall provide temporary traffic control during all phases of construction to assist with the improvement of traffic flow.


(C-13) All clearing, grading, earth moving, or excavation activities shall be discontinued during periods of high winds (i.e., greater than 15 miles per hour [mph]), so as to prevent excessive amounts of dust.


(C-14) The Project Developer shall require by contract specifications that construction-related equipment, including heavy-duty equipment, motor vehicles, and portable equipment, shall be turned off when not in use for an extended period of time (i.e., 5 minutes or longer).


(C-15) The Project Developer shall require by contract specifications that construction operations rely on the electricity infrastructure surrounding the construction site rather than electrical generators powered by internal combustion engines to the extent feasible.

Monitoring Phase: ConstructionEnforcement Agency: Department of Building and Safety, South Coast Air Quality Management District



Monitoring Agency: Department of Building and Safety, South Coast Air Quality Management District

(C-16) The Project Developer shall require by contract specifications that all diesel-powered construction equipment and haul trucks used would be retrofitted with after-treatment products (e.g., engine catalysts) to the extent that it is economically feasible and readily available in the South Coast Air Basin.


(C-17) The Project Developer shall require by contract specifications that all heavy-duty diesel-powered equipment operating and refueling at the project site as well as haul trucks would use low- NOx

diesel fuel to the extent that it is readily available and cost effective (up to 125 percent of the cost of California ARB diesel) in the South Coast Air Basin.


(C-18) The Project Developer shall require by contract specifications that alternative fuel construction equipment (i.e., compressed natural gas, liquid petroleum gas, and unleaded gasoline) would be utilized to the extent that it is economically feasible and the equipment is readily available in the South Coast Air Basin.


(C-19) The Project Developer shall install air filters capable of achieving a Minimum Efficiency Rating Value (MERV) of at least 11 or better in order to reduce the effects of diminished air quality on the occupants of the project.

Monitoring Phase: ConstructionEnforcement Agency: Department of City Planning, South Coast Air Quality Management District



Monitoring Agency: Department of Building and Safety, South Coast Air Quality Management District

(C-20) The Project Developer shall utilize low-VOC paints on all portions of the proposed structures.


D. ENERGY

(D-1) The proposed project shall be in full compliance with the policies of the City Los Angeles Green Building Ordinance.

Monitoring Phase: ConstructionEnforcement Agency: Department of City Planning, Department of Building and SafetyMonitoring Agency: Department of Building and Safety, Department of Building and Safety

E. GEOLOGY AND SOILS

(E-1) Construction of the proposed project shall comply with recommendations set forth in the Preliminary Geotechnical Investigation, Proposed Medical Office Buildings and Mixed-Use Development, 12333 Olympic Boulevard and 1901 to 1933 Bundy Drive, Los Angeles, California prepared by Geotechnologies, Inc., dated February 7, 2007 and the GeotechnicalEngineering Investigation, Proposed Medical Park 12333 Olympic Boulevard and 1901 to 1933 Bundy Drive, Los Angeles, California prepared by Geotechnologies, Inc., dated May 23, 2008 (see also Appendix D to this Draft EIR) to the extent feasible.

Monitoring Phase: Pre-Construction and ConstructionEnforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety

F. HAZARDS

(F-1) Prior to the issuance of a demolition permit for any existing on-site structure, the structure shall undergo survey to document the presence of any potential polychlorinated biphenyls (PCBs) within the structure. Any PCBs identified as part of this survey shall be properly disposed of in accordance with all applicable City, State, and federal regulations.



Monitoring Phase: ConstructionEnforcement Agency: South Coast Air Quality Management District, Department of Building and SafetyMonitoring Agency: Department of Building and Safety

(F-2) The proposed project shall comply fully with the Asbestos Operations & Maintenance Program,1901, 1925 and 1933 S. Bundy Drive, Los Angeles, California, prepared by Allstate Services Environmental, Inc., November 17, 2005. In addition, prior to the issuance of a demolition permit for any existing on-site structure not previously surveyed, the structure shall undergo an asbestos survey to document the presence of any potential asbestos-containing materials (ACMs) within the structure. Any ACMs identified as part of this survey shall be abated in accordance with South Coast Air Quality Management District Rule 1403 as well as any other applicable City, State, and federal regulations.


(F-3) A California-licensed and registered asbestos abatement contractor shall remove the ACMs that would be disturbed as a result of planned or other renovations to the subject building(s). The contractor would comply with asbestos consultant specifications for the abatement of these regulated materials in compliance with local, State, and federal regulations.

Monitoring Phase: ConstructionEnforcement Agency: South Coast Air Quality Management District,

Department of Building and SafetyMonitoring Agency: Department of Building and Safety

(F-4) All construction work where an employee may be occupationally exposed to lead must comply with Cal/OSHA requirements set forth in 8 CCR 1532.1. This regulation requires initial employee exposure monitoring to evaluate worker exposure during work that disturbs lead-containing materials (lead present in any detectable concentration).

Monitoring Phase: ConstructionEnforcement Agency: Department of Building and SafetyMonitoring Agency: Department of Building and Safety

(F-5) All construction workers shall be required to utilize personal protective equipment (including respiratory protection if deemed necessary) during all demolition activities or any activities that would potentially expose workers to lead impacted dust.




(F-6) Lead abatement specifications by a Lead Project Monitor/Designer are required for all demolition activities to prevent further contamination of lead dust and OSHA requirements.


(F-7) Waste items generated during demolition and abatement procedures shall be properly sampled and profiled to determine the final disposition of the waste.


(F-8) Prior to the issuance of a demolition permit for any existing on-site structure, the structure shall undergo a lead-based paint (LBP) survey to document the presence of any potential LBP within the structure. Any LBP identified as part of this survey shall be abated in accordance with all applicable City, State, and federal regulations.


(F-9) The Applicant shall comply with all of the conditions set forth in the May 27, 2008 letter from the California RWQCB which determined that no further action is required for soil remediation at the project site. Among the conditions of the letter is the requirement that should soil contamination be detected during future activities at the project site, the RWQCB shall be notified within 72 hours and a health and safety plan shall be implemented to reduce the contamination to an acceptable level.


(F-10) The proposed project shall comply with all City, State, and federal regulations governing the proper regulation, use, and disposal of biohazardous materials. Pursuant to Section 57.08 of the City of Los Angeles Municipal Code (LAMC), the Applicant shall file a Hazardous Materials Release Response Plan (HMRRP) and Inventory Program for all businesses that handle in excess of 500 pounds or 55 gallons of hazardous materials at any one time during the year. Such



businesses shall also prepare and submit a Business Plan to the City of Los Angeles Fire Department (LAFD) which provides an inventory of hazardous materials used, establishes emergency response procedures, and sets forth a training program.

Monitoring Phase: Pre-Construction and OccupancyEnforcement Agency: Los Angeles Fire Department,


(F-11) The project Applicant shall provide an electric and magnetic field (EMF) information and disclosure statement to each prospective buyer for all proposed residential units. Such statement shall include, but not be limited to, the following:

� The location of the neighboring City of Los Angeles Department of Water and Power (LADWP) electrical distribution yard with respect to the project site;

� A statement that this subject has been addressed in the EIR for the proposed project and that the EIR is on file with the City of Los Angeles Department of City Planning.

� A statement that additional information regarding the potential health effects from EMF exposure may be obtained by viewing available information posted on the California Department of Health Services’ (DHS) official internet site at http://www.dhs.ca.gov/ehib/emf/RiskEvaluation/riskeval.html or by contacting the LADWP EMF inquiry line at (213) 367-2616.

Monitoring Phase: OccupancyEnforcement Agency: Department of Building and SafetyMonitoring Agency: Department of Building and Safety

G. LAND USE AND PLANNING

(G-1) The Applicant shall coordinate with the adjacent television facility to ensure that medical equipment and/or the proposed development do not interfere with microwave and satellite transmission operations at the existing television facility.


(G-2) The Applicant shall coordinate with the adjacent television facility to ensure that microwave and satellite transmission operations at the television facility do not interfere with the operation of the proposed project.




H. NOISE

(H-1) The project shall comply with the City of Los Angeles Noise Ordinance Nos. 144,331 and 161,574, and any subsequent ordinances, which prohibit the emission or creation of noise beyond certain levels at adjacent uses unless technically infeasible.


(H-2) In Parcel A, construction and demolition shall be restricted to the hours of 7:00 AM to 6:00 PM Monday through Friday, and 8:00 AM to 6:00 PM on Saturday, and prohibited on all Sundays and federal holidays.


(H-3) Noise and groundborne vibration construction activities whose specific location on the project site may be flexible (e.g., operation of compressors and generators, cement mixing, general truck idling) shall be conducted as far as possible from the nearest noise- and vibration-sensitive land uses;


(H-4) Barriers such as plywood structures or flexible sound control curtains shall be erected along the northern project boundary to the adjacent uses and along the southern project boundary to the adjacent uses to minimize the amount of noise to the maximum extent feasible during construction.


(H-5) An information sign shall be posted at the entrance to the construction site that identifies the permitted construction hours and provides a dedicated telephone number to receive information about the construction process and to report complaints regarding excessive noise levels. An



ongoing log of calls received shall be maintained as part of the mitigation monitoring and reporting program.


(H-6) All new mechanical equipment associated with the proposed project shall comply with Section 112.02 of the City of Los Angeles Municipal Code, which prohibits noise from air conditioning, refrigeration, heating, pumping, and filtering equipment from exceeding existing ambient noise levels on the premises of other occupied properties by more than five decibels.

Monitoring Phase: OccupancyEnforcement Agency: Department of City Planning, Department of Building and SafetyMonitoring Agency: Department of Building and Safety

(H-7) The Project Applicant shall comply with the Noise Insulation Standards of Title 24 of the California Code Regulations, which ensure an acceptable interior noise environment.


(H-8) All exterior windows within the residential units at the project site shall be constructed with double-pane glass and use exterior wall construction which provides a Sound Transmission Class of 50 or greater as defined in UBC No. 35-1, 1979 edition or any amendment thereto. The applicant, as an alternative, may retain an acoustical engineer to submit evidence, along with the application for a building permit, any alternative means of sound insulation sufficient to mitigate interior noise levels below a CNEL of 45 dBA in any habitable residential room.


(H-9) Construction and demolition activities shall be scheduled so as to avoid operating several pieces of equipment simultaneously, which causes high noise levels.


(H-10) The project contractor shall use power construction equipment with noise shielding and muffling



devices.


(H-11) The project shall comply with the Noise Insulation Standards of Title 24 of the California Code Regulations, which insure an acceptable interior noise environment.

Monitoring Phase: ConstructionEnforcement Agency: Department of City Planning,


I. POPULATION AND HOUSING

The proposed project would have a less-than-significant impact with respect to population and housing. Therefore, no mitigation measures are recommended.

J. PUBLIC SERVICES

(J-1) During the plot plan review, the project applicant shall consult with the LAFD regarding the installation of private fire hydrants, sprinklers, and/or other fire protection features within the proposed project. All required fire protection features shall be installed to the satisfaction of the LAFD.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Fire Department, Department of Building and SafetyMonitoring Agency: Los Angeles Fire Department

(J-2) If the proposed project includes any new public streets, the applicant shall consult with the LAFD regarding the potential installation of public fire hydrants. Any required public fire hydrants shall be installed to the satisfaction of the LAFD.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Fire Department,

Department of Building and SafetyMonitoring Agency: Los Angeles Fire Department

(J-3) The length of the fire lane shall not exceed 700 feet without secondary access.1

1 E-mail correspondence from Michael Theule, Fire Inspector II, Hydrant and Access Unit, City of Los Angeles Fire Department, January 29, 2007.



Monitoring Phase: ConstructionEnforcement Agency: Los Angeles Fire Department,

Department of Building and SafetyMonitoring Agency: Los Angeles Fire Department

(J-4) The proposed project shall include a 28-foot designated fire lane with a through street-to-street connection.2

Monitoring Phase: ConstructionEnforcement Agency: Los Angeles Fire Department, Department of Building and SafetyMonitoring Agency: Los Angeles Fire Department

(J-5) The Applicant shall contact the Crime Prevention Unit within the Community Relations Section for advisement on crime prevention features appropriate for the design of the property.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Police DepartmentMonitoring Agency: Los Angeles Police Department

(J-6) The Applicant shall provide the West Los Angeles Area Commanding Officer with a diagram of each portion of the property. The diagram would include access routes and any additional information that might facilitate police response.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Police DepartmentMonitoring Agency: Los Angeles Police Department

(J-7) The project applicant shall pay all applicable school fees to the Los Angeles Unified School District to offset the impact of additional student enrollment at schools serving the project area.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Unified School DistrictMonitoring Agency: Los Angeles Unified School District

(J-8) To the extent feasible, the proposed project shall include the development of recreational and park amenities within the proposed site; and the project applicant shall pay Quimby and/or Park fees for any remaining mitigation deficit for project impacts on parks and recreational facilities in the project.

2 Ibid.



Monitoring Phase: Pre-ConstructionEnforcement Agency: Department of Recreation and ParksMonitoring Agency: Department of City Planning

(J-9) To the extent feasible, the proposed project shall include the development of approximately 373.5 square feet of library space within the proposed site; and the project applicant shall pay negotiated fees with LAPL for any remaining mitigation deficit for project impacts on library facilities in the project.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Los Angeles Public Library Monitoring Agency: Los Angeles Public Library

K. TRAFFIC AND TRANSPORTATION

(K-1) The project Applicant shall pay all applicable fees in accordance with the West Los Angeles Transportation Improvement and Mitigation (WLA TIMP) Specific Plan.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Department of City Planning,

Department of TransportationMonitoring Agency: Department of City Planning,

Department of Transportation

(K-2) Wilshire Boulevard and Barrington Avenue – Although no physical roadway improvements were identified for this location, it is recommended that the project install new north-south left-turn signal phasing (protected/permissive) at this intersection to improve the operating capacity of the Barrington Avenue approaches, and reduce the existing congestion on both Barrington Avenue approaches; currently, north and southbound left-turning vehicles can queue past the end of the existing left-turn pockets and block through traffic in both direction. The installation of the recommended signal phases will allow for more capacity for these left-turn moves, reducing the incidences of through lane interference and providing more “throughput” on Barrington Avenue. This measure is consistent with the City’s ongoing left-turn phasing installation program.

Monitoring Phase: ConstructionEnforcement Agency: Department of TransportationMonitoring Agency: Department of Transportation

(K-3) Texas Avenue and Bundy Drive – Widen the west side of Bundy Drive within the existing right-of-way, and restripe the northbound and southbound approaches of Bundy Drive to provide exclusive left-turn pockets in both directions at Texas Avenue. This improvement is identified in the WLA TIMP as part of overall improvements to the Bundy Drive corridor in



the project vicinity to address congestion caused at this intersection and throughout the corridor by left-turning vehicles blocking through vehicle traffic.


(K-4) Santa Monica Boulevard and Bundy Drive – Restripe the eastbound approach of the intersection to install an exclusive right-turn only lane on Santa Monica Boulevard. This measure would require the elimination of approximately four to five commercial parking spaces along the south side of Santa Monica Boulevard west of Bundy Drive during this time period. Additionally, install new north-south left-turn phasing at this intersection, to allow for more capacity for these left-turn moves, reducing the incidences of interference with southbound left-turn vehicles queuing past the end of the left-turn pocket and interfering with through traffic on Bundy Drive. Additionally, contribute to the installation of a new ATSAC traffic monitoring camera at this location.


(K-5) Santa Monica Boulevard and Barrington Avenue – Although no physical roadway improvements were identified for this location, it is recommended that the project install new north-south left-turn signal phasing (protected/permissive) at this intersection, to improve the operating capacity of the Barrington Avenue approaches, and reduce the existing congestion on both Barrington Avenue approaches; currently, north and southbound left-turning vehicles can queue past the end of the existing left-turn pockets and block through traffic in both direction. The installation of the recommended signal phases will allow for more capacity for these left-turn moves, reducing the incidences of through lane interference and providing more through capacity on Barrington Avenue. This measure is consistent with the City’s ongoing left-turn phasing installation program.


(K-6) Colorado Avenue/Idaho Avenue and Centinela Avenue – Restripe the existing eastbound approach of Idaho Avenue to install a new right-turn only lane; this approach of the intersection currently operates in this manner, with a wide curb lane that allows for a de-facto right-turn lane. However, this move should be “formalized” with the recommended striping configuration. Note that, although LADOT has reviewed and conceptually accepted



this proposed improvement, this intersection is shared with the City of Santa Monica, and will require review and approval by that jurisdiction.


(K-7) Missouri Avenue/Project Driveway and Bundy Drive – The project site’s driveway (eastbound approach) is proposed to provide a total of four lanes, including two inbound and two outbound lanes. This configuration is adequate to accommodate the project’s anticipated traffic flows. Additionally, restripe the westbound approach of Missouri Avenue to install a left turn lane, plus a shared through/right turn lane. Further, convert the existing two-way left-turn center lane on Bundy Drive south of Missouri Avenue to a new northbound left-turn lane to provide access to the new project driveway.


(K-8) La Grange Avenue and Bundy Drive – Install a third southbound through lane on Bundy Drive between Missouri Avenue and Olympic Boulevard, as part of the required dedication and roadway widenings identified previously in the description of the “Bundy Drive Dedication and Widening” improvement.


(K-9) Olympic Boulevard and Centinela Avenue (south leg) – The project driveway (southbound approach) is proposed to provide a total of four lanes, including two inbound and two outbound lanes. This configuration is adequate to accommodate the project’s anticipated traffic flows. Additionally, reduce the existing sidewalk width along the west side of Centinela Avenue south of Olympic Boulevard to eight feet and widen the roadway by approximately four feet. Restripe the northbound approach of Centinela Avenue to provide dual left turn lanes plus one shared through/right turn lane. In addition to these improvements, install new left-turn signal phasing (protected/permissive) for the north-south, and westbound approaches at this intersection.


(K-10) Olympic Boulevard and Bundy Drive – Widen both sides of Olympic Boulevard west of Bundy Drive by approximately two feet, and restripe the eastbound approach of Olympic



Boulevard to install dual left-turn lanes, in addition to three through lanes and a right-turn only lane; restriping of the westbound approach may also be necessary to provide appropriate lane alignments and transitions across the intersection. Additionally, contribute to the installation of an ATSAC traffic monitoring camera at this intersection.


(K-11) Olympic Boulevard and Sepulveda Boulevard – Although no physical roadway improvements were identified for this location, it is recommended that the project install new left-turn signal phasing (protected/permissive) on both the northbound and southbound approaches of this intersection. This improvement will help reduce the existing congestion on the Sepulveda Boulevard approaches; currently, left-turning vehicles in both directions can queue past the end of the existing left-turn pockets and block through traffic. The installation of the recommended signal phases will allow for more capacity for these left-turn moves, reducing the incidences of through lane interference and providing more through capacity on Sepulveda Boulevard. This measure is consistent with the City’s ongoing left-turn phasing installation program.


(K-12) Centinela Avenue and I-10 Westbound On/Off-Ramps – Reduce the existing sidewalk width on the north/east side of Centinela Avenue to eight feet and widen the roadway north of the freeway ramps to install a second southbound through lane, in addition to the existing single southbound through lane and right-turn only lane (onto the I-10 westbound on-ramp). Modify the traffic signal operations and equipment, and restripe both the freeway off-ramp and the south leg of the intersection as necessary to accommodate the improvement.


(K-13) Pico Boulevard and Centinela Avenue – Reduce the width of the sidewalk and widen the north side of Pico Boulevard, and restripe the westbound approach of the intersection to provide an exclusive right-turn only lane, in addition to the existing left-turn and two through lanes. Modify the existing signal equipment as necessary to implement this measure.




(K-14) Pico Boulevard and Bundy Drive – Restripe the southbound approach of Bundy Drive at Pico Boulevard to convert the existing right-turn only lane to a shared through/right turn lane. Additionally, widen the west side of Bundy Drive south of Pico Boulevard (between Pico Boulevard and the I-10 Westbound-to-Southbound Bundy Drive off-ramp), to provide an additional southbound “receiving” lane, with the innermost lane striped and signed as a “trap” lane for the new dual left-turn lanes at the I-10 Eastbound on-ramps. This improvement is part of the comprehensive improvement of the Bundy Drive/I-10 Westbound on- and off-ramp interchange, as described in more detail in the discussion of the recommended improvements for the “Bundy Drive and I-10 Westbound Off-Ramp” and the “Bundy Drive and I-10 Eastbound On-Ramp” locations, below. Additionally, contribute to the installation of an ATSAC traffic monitoring camera. Although LADOT has indicated that this measure is conceptually acceptable, the improvement will require Caltrans approval due to the proposed widening on Caltrans property along the west side of Bundy Drive.


(K-15) Bundy Drive and I-10 Westbound Off-Ramp – Widen the existing westbound I-10 Freeway-to-northbound Bundy Drive off-ramp to provide two lanes after the divergence from the mainline I-10 Freeway. Flare the ramp terminus at Bundy Drive to provide three lanes, including a left-turn lane, a center shared left-turn/right-turn lane, and one right-turn only lane, and realign the ramp approach so that it intersects Bundy Drive at an approximately 90-degree angle. Remove the existing westbound I-10 Freeway-to-southbound Bundy Drive “loop” ramp (allowing the widening along the west side of Bundy Drive, as described in the improvement for “Pico Boulevard and Bundy Drive”, above), and install a new traffic signal at this location to control the new westbound I-10 Freeway off-ramp to both directions of Bundy Drive. This signal shall be coordinated with the existing signals at the intersections of both Bundy Drive and Pico Boulevard to the north, and at Bundy Drive and I-10 Freeway eastbound on-ramp to the south of this location. Additionally, in order to improve traffic flows along northbound Bundy Drive and reduce the existing conflicts with merging off-ramp traffic, right-turn on red movements should be prohibited from the off-ramp. LADOT has indicated that this measure is conceptually acceptable, but will require Caltrans approval.


(K-16) Bundy Drive and I-10 Eastbound On-Ramp – Restripe Bundy Drive south of Pico Boulevard to provide dual southbound left turn lanes onto the I-10 eastbound on-ramp, in addition to the existing two through lanes in that direction. The innermost “through” lane on



southbound Bundy Drive will become a dedicated lane for the outermost of the dual left-turn lanes; the second, inner left-turn lane should begin at the south side of the new westbound I-10 off-ramp described above. Additionally, the on-ramp should be widened if possible to provide an additional lane, preserving the existing high occupancy vehicle (HOV) bypass lane and increasing the storage capacity of the ramp to minimize potential vehicle queue “spillover” onto Bundy Drive. This spillover is a primary cause of the current congestion experienced at the intersection of Pico Boulevard and Bundy Drive, as ramp-bound traffic cannot access the ramp, and the southbound Bundy Drive left-turn queue exceeds the pocket length and blocks southbound Bundy Drive through traffic. As with the other associated Bundy Drive/I-10 Freeway ramp improvements described previously, LADOT has indicated that this measure is conceptually acceptable, although final review and approval is under Caltrans’ jurisdiction due to the proposed widening of the freeway on-ramp.


(K-17) Pico Boulevard and Barrington Avenue – Restripe the northbound approach of Barrington Avenue at this intersection to provide an exclusive right-turn only lane. Additionally install new left-turn signal phasing (protected/permissive) for both the northbound and southbound approaches of this intersection, in order to provide much-needed turning capacity through the high-volume northbound and southbound “through” traffic on Barrington Avenue. The installation of the recommended signal phases is consistent with the City’s ongoing left-turn phasing installation program.


(K-18) Pico Boulevard and Sawtelle Boulevard – Although no physical roadway improvements were identified for this location, it is recommended that the project install new left-turn signal phasing (protected/permissive) on the northbound approach of this intersection, to mirror the existing southbound left-turn phase. This improvement will help reduce the existing congestion on the Sawtelle Boulevard approaches, particularly in the northbound direction; currently, left-turning vehicles in both directions can queue past the end of the left-turn pockets and block through traffic. The installation of the recommended signal phases is consistent with the City’s ongoing left-turn phasing installation program and will allow for more capacity for these left-turn moves, reducing the incidences of through lane interference and providing more through capacity on Sawtelle Boulevard.




(K-19) Centinela Avenue and I-10 Eastbound On-Ramp – Widen both sides of Centinela Avenue both north and south of the on-ramp as necessary to install a second southbound left-turn lane onto the on-ramp. Modify and/or replace the existing traffic signal equipment as necessary to accommodate the proposed improvement.


(K-20) Ocean Park Boulevard and Centinela Avenue – Restripe the southbound approach of Centinela Avenue at this intersection to convert the existing through lane to operate as a shared through/left-turn lane. Modify the existing traffic signal operation to install “opposed” phasing on both the northbound and southbound approaches of this intersection to allow the addition of the shared left-turn/through lane.


(K-21) Traffic Signal Coordination – The project shall coordinate with the City of Santa Monica to promote the development, design, and installation of a new traffic signal coordination system, similar to the City of Los Angeles’ ATSAC traffic signal control system, within the City of Santa Monica. Such a signal coordination system could be installed as an extension of the existing City of Los Angeles ATSAC/ATCS signal coordination system. It is not proposed that the proposed project install the actual system, since such a system would require funding and construction capability outside the ability of any single project to implement. Rather it is envisioned that the proposed project would contribute “fair share” funding to the development of such a system, along with other ongoing or proposed developments within both the cities of Santa Monica and Los Angeles, in a cooperative approach between those jurisdictions to extend the current ATSAC system outside the City of Los Angeles to improve traffic flow throughout the entire study area.


Department of Transportation Monitoring Agency: Department of City Planning,


(K-22) The Applicant agreed to provide a voluntary contribution of $2,000,000, beyond the required WLA TIMP fee amount, to provide for additional transportation-related improvements in the project area beyond those assignable to the TIMP fees. It is envisioned that a portion of the voluntary contributions would be used to facilitate the immediate implementation of the ATCS signal coordination upgrades in the study area. Although the ATCS improvement



program is assumed to be funded, the timing and availability of such funding for its installation is currently uncertain. While the implementation of ATCS is not a project mitigation improvement, the voluntary contribution by the project toward its near-term operations will assure that the additional roadway and intersection capacities resulting from the signal coordination upgrades will be in place at the time the additional traffic demands generated by the project would occur, effectively offsetting many of the potential project traffic impacts described earlier in this document.




(K-23) The project shall implement a TDM program to reduce both daily and peak hour trips to and from the project site. This program shall be available to employees, residents, visitors, and patrons of the project. The program shall be overseen by an on-site TDM coordinator, who will assist with the development, operation, and implementation of the various programs, including but not limited to carpool incentives, ride share matching, bicycle lockers, and variable work shifts. A menu of items to be included in the project’s TDM program developed specifically for the proposed project or taken from the City’s Transportation Demand Management Ordinance (Section 98.0411 of the LAMC). However, it should be noted that not all of these elements would apply to all of the project site’s component uses.

On-site Transportation Coordinator, in charge of:

� Carpool/Vanpool and Rideshare Matching;

� Preferential Vanpool/Carpool Parking;

� Transit Passes or Subsidies;

� Parking Cash-Out;

� Flex-Use Vehicles;

� Guaranteed Ride Home;

� Bicycle Racks and Showers/Lockers; and

� Flexible Work Hours/Telecommute Opportunities.

Monitoring Phase: OccupancyEnforcement Agency: Department of City Planning,





(K-24) Local/Residential Traffic Intrusion Protection Program – The proposed project, in coordination with LADOT, shall develop a program to reduce or prevent traffic intrusion into the neighborhoods surrounding the project site. The program may include physical measures such as additional STOP signs and/or speed humps, or access control measures like full or partial cul-de-sacs, chokers, or other barriers, or restriction of turning movements at the project’s driveways or to/from major streets. It is recommended that the project Applicant make a voluntary contribution of $200,000 to establish a fund from which detailed studies and recommendations regarding specific program elements and locations for their implementation.

Monitoring Phase: OccupancyEnforcement Agency: Department of TransportationMonitoring Agency: Department of Transportation

(K-25) Restripe Lincoln Boulevard to the north such that a right-turn only lane is established.

Monitoring Phase: Pre-ConstructionEnforcement Agency: Department of TransportationMonitoring Agency: Department of Transportation

L. UTILITIES

(L-1) The project developer shall ensure that the landscape irrigation system be designed, installed and tested to provide uniform irrigation coverage. Sprinkler head patterns shall be adjusted to minimize over spray onto walkways and streets.

Monitoring Phase: Pre-Construction, and Construction Enforcement Agency: Department of Water and PowerMonitoring Agency: Department of Water and Power

(L-2) The project developer shall install either a “smart sprinkler” system to provide irrigation for the landscaped areas or, at a minimum, set automatic irrigation timers to water landscaping during early morning or late evening hours to reduce water losses from evaporation. Irrigation run times for all zones shall be adjusted 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.

Monitoring Phase: Construction and Occupancy Enforcement Agency: Department of Water and PowerMonitoring Agency: Department of Water and Power



(L-3) The project developer shall select and use drought-tolerant, low-water-consuming plant varieties to reduce irrigation water consumption.

Monitoring Phase: Pre-Construction, and Construction Enforcement Agency: Department of Water and Power,

Department of Building and Safety Monitoring Agency: Department of Water and Power,

Department of Building and Safety

(L-4) The project developer shall install low-flush water toilets and water-saving showerheads in new construction. Low-flow faucet aerators should be installed on all sink faucets.

Monitoring Phase: Construction Enforcement Agency: Department of Water and PowerMonitoring Agency: Department of Water and Power

(L-5) High efficiency toilets (1.28 gallons per flush or less, includes dual flush).

Monitoring Phase: Construction Enforcement Agency: Department of Water and Power,



(L-6) High efficiency urinals (0.5 gallons per flush or less, includes waterless).




(L-7) Restroom faucet flow rate of 1.5 gallons per minute or less.




(L-8) Public restroom self-closing faucets.





Monitoring Agency: Department of Water and Power, Department of Building and Safety

(L-9) Showerhead flow rate of 2.0 gallons per minute or less.




(L-10) Limit of one showerhead per shower stall.




(L-11) High efficiency clothes washers (water factor 6.0 or less).




(L-12) High efficiency dishwashers (Energy Star rated).




(L-13) Domestic water heating system located in close proximity to point(s) of use, as feasible; use of tankless and on-demand water heaters as feasible.




(L-14) Cooling towers shall be operated at a minimum of 5.5 cycles of concentration;






(L-15) Onsite water recycling systems shall be required for wastewater discharge from commercial laundries, dye houses, food processing, and certain manufacturing operations (subject to a payback threshold of five years or less); all water recycling system for all new car wash facilities shall be mandated.;




(L-16) Irrigation system requirements:

(a) Weather-based irrigation controller with rain shutoff;

(b) Flow sensor and master valve shutoff (large landscapes);

(c) Matched precipitation (flow) rates for sprinkler heads;

(d) Drip/microspray/subsurface irrigation where appropriate;

(e) Minimum irrigation system distribution uniformity of 75 percent;

(f) Proper hydro-zoning, turf minimization and use of native/drought tolerant plant materials; and

(g) Use of landscape contouring to minimize precipitation runoff.




(L-17) Metering requirements:

(a) All dwelling units/commercial spaces shall include individual meters and billing for water use; and



(b) All irrigated landscapes of 5,000 square feet or more shall include separate meters or submeters.




(L-18) Mandated use of recycled water (where available) for appropriate end uses (irrigation, cooling towers, sanitary).




(L-19) Required compliance with all City of Los Angeles SUSMP requirements, and encouraging the implementation of BMPs that have stormwater recharge or reuse benefits.

Monitoring Phase: Pre-Construction, and ConstructionEnforcement Agency: Department of City Planning, Department of Building and SafetyMonitoring Agency: Department of City Planning, Department of Building and Safety

(L-20) The contractor shall contract for waste disposal services with a company that recycles construction-related wastes.

Monitoring Phase: Construction Enforcement Agency: Department of City Planning, Bureau of SanitationMonitoring Agency: Bureau of Sanitation

(L-21) 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.

Monitoring Phase: Construction Enforcement Agency: Bureau of Sanitation,

Department of Building and SafetyMonitoring Agency: Bureau of Sanitation,




(L-22) To support recycling of operational wastes, the proposed project shall include a residential recycling program.

Monitoring Phase: Occupancy Enforcement Agency: Department of City Planning, Bureau of SanitationMonitoring Agency: Bureau of Sanitation,


environmental review section...the draft eir. on april 30, 2009, the city released the draft eir for...

Documents