2019-07-16 CC Agenda Packet - Item #9 - Exhibit A-1 - Final Environmental Impact Report - FEIRExhibit A— l
THIS EXHIBIT IS AVAIL -ABLE
THE CITY 0LERKS
e
Proposed Beach Cities Media Campus Project
Final Environmental Impact Report
State Clearinghouse No.: 2017/21035
PREPARED FOR:
The City of EI Segundo
Planning and Building Safety Department
Planning Division
350 Main Street
EI Segundo, California 90245
PREPARED BY:
EcoTierra Consulting
633 W. 5th Street, 26th Floor
Los Angeles, CA 90071
(213) 235-4770
June 20, 2019
Tierra
TABLE OF CONTENTS
I. INTRODUCTION
1. The CEQA Process and Public Review of the Draft EIR................................ ............ I-1
2. Project Description................................................................................................I-3
3. Summary of Environmental Impacts...............................................................:......I-6
II. RESPONSES TO COMMENTS
1. State, Regional and Local Agencies....................................................................... II -2
2. Organizations and Individuals ................................................ ............................. II -23
3. Comment Letters Received After the Close of the Comment Period ................... II -26
III. REVISIONS, CLARIFICATIONS AND CORRECTIONS ON THE DRAFT EIR........................... III -1
IV. MITIGATION MONITORING AND REPORTING PROGAM
1. Mitigation Monitoring and Reporting Procedures ............................................... IV -1
2. Mitigation Measures and Project Design Features .............................................. IV -2
Beach Cities Media Campus Project Table of Contents
Page i
LIST OF TABLES
Table 1-1, Project Development Summary... ... ............... ........................................ ........... 1-4
Beach Cities Media Campus Project Table of Contents
Page ii
I. INTRODUCTION
Pursuant to the California Environmental Quality Act ("CEQA"), the potential environmental effects of the
Proposed Beach Cities Media Campus Project (the "Project") have been analyzed in a Draft Environmental
Impact Report ("Draft EIR") (SCH No. 2017121035), dated March 2019. This document contains the Final
Environmental Impact Report ("Final EIR"), as prepared by the Lead Agency, which is the City of EI Segundo
Planning Division.
Section 15132 of the State CEQA Guidelines lists the contents of the Final EIR:
a) The Draft EIR or a revision of the Draft EIR.
b) Comments and recommendations received on the 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.
One purpose of the Final EIR is to respond to all comments received by the Lead Agency regarding the
environmental information and analyses contained in the Draft EIR. Additionally, any
clarifications/corrections to the text, tables, figures, and appendices of the Draft EIR generated either
from responses to comments, or independently by the Lead Agency, are stated in the Final EIR in Section
III.
The Responses to Comments (Section II in this Final EIR) include copies of all letters received during and
after the close of the Draft EIR public review period, as described further below, as well as the responses
to all comments received on environmental issues.
Section 15097 of the State CEQA Guidelines states that the Lead Agency shall adopt a program for
monitoring or reporting on the revisions that it has required for the project and the measures it has
imposed to mitigate or avoid significant environmental effects. Section IV, Mitigation Monitoring and
Reporting Program ("MMRP"), describes the mitigation program to be implemented by the Lead Agency.
1. CEQA PROCESS AND PUBLIC REVIEW OF THE DRAFT EIR
The City of EI Segundo initiated the City's CEQA review process for the Project through the issuance of a
Notice of Preparation ("NOP") as required by CEQA Guidelines Section 15082. The NOP for the Project
EIR was prepared by the City, and distributed to the State Clearinghouse, Office of Planning and Research,
responsible agencies, and other interested parties on December 8, 2017. The NOP was also distributed
to owners and occupants of properties located within 500 feet of the Project Site. The NOP solicited
comments from responsible and trustee agencies, as well as interested parties, on the scope of the EIR.
The NOP was circulated for a 30 -day scoping period that ended on January 6, 2018. A public scoping
meeting was held on December 18, 2017.
Upon completion of the Draft EIR, notice of the public review period was given in accordance with Section
15087 of the State CEQA Guidelines. On March 1, 2019, a Notice of Availability ("NOA") of the Draft EIR,
Beach Cities Media Campus Project I. Introduction
Page 1-1
City of EI Segundo June 2019
was prepared and distributed to the State Office of Planning and Research, the Los Angeles County Clerk,
responsible and trustee agencies, organizations, interested parties, and all parties who requested access
to a copy of the Draft EIR in accordance with CECIA. The NOA was also distributed to owners and
occupants of properties located within 500 feet of the Project Site.
The NOA was distributed to the mailing list and email list prepared for the Notice of Preparation ("NOP")
for the scoping stage of the Project before issuance of the Draft EIR, and was augmented to include
individuals requested to be added to the list, as well as individuals who had provided comments on the
NOP. The NOA and Draft EIR were posted on the Lead Agency's website for viewing and downloading at:
httr)s://www.eIsep,undo.orElder)ts/i)Ianningsafetv/planning/
Printed copies of the Draft EIR were made available for public viewing at the following locations:
• City of EI Segundo - Planning and Building Safety Department, 350 Main Street, EI Segundo, CA
90245
• EI Segundo Public Library, 111 West Mariposa Avenue, EI Segundo, CA 90245
In summary, the Lead Agency conducted all required noticing and scoping for the Project in accordance
with the requirements of Section 15083 of the State CEQA Guidelines, and conducted the public review
for the Draft EIR in compliance with the requirements of Section 15087 of the State CEQA Guidelines.
During the comment period, comments on the Draft EIR were received by the Lead Agency. The Lead
Agency has reviewed all comments, and has determined that no substantial new environmental issues
have been raised and that all issues raised in the comments have been adequately addressed in the Draft
EIR and/or in the Responses to Comments; Mitigation Monitoring and Reporting Program; and Revisions,
Clarifications, and Corrections on the Draft EIR.
The Draft EIR concludes that based on the analysis in Section IV (Environmental Impact Analysis) of the
Draft EIR, implementation of the Project would result in significant unavoidable environmental impacts
relative to:
• Population, Housing, and Employment (City and regional population and housing demands), and
Transportation, Traffic and Parking (After applying the mitigation measures, a total of four
significant and unavoidable impacts would remain in Existing plus Project and a total of three
significant and unavoidable impacts would remain in Future plus Project, and cumulative
construction traffic. The traffic impacts of the Project cannot be mitigated below the threshold of
significance).
The Final EIR for the Project, dated June 2019, consists of the following documents:
• Draft EIR and Technical Appendices dated March 2019,
Responses to Comments, Mitigation Monitoring and Reporting Program; and Revisions,
Clarifications, and Corrections on the Draft EIR, which includes:
o A list of all persons, organizations, and public agencies that commented as well as the
verbatim comments received on the Draft EIR; and
o Responses to written comments on the Draft EIR.
Beach Cities Media Campus Project I. Introduction
Page 1-2
City of EI Segundo June 2019
This document includes the State Clearinghouse letter that documents compliance with CEQA review
requirements; comment letters as provided by persons, organizations, and public agencies; and the Lead
Agency's responses to all comments.
Next Procedural Steps
The City of EI Segundo is required to consider and certify a Final EIR only if it exercises its discretion to
approve the Project in the future. The Final EIR, and related documents will be filed, along with the City
staff's recommendations related to the Project, for consideration by the City of EI Segundo Planning
Commission on a future Planning Commission agenda. Consideration of recommendations relating to the
Project will be publicly noticed as required by state law.
Members of the public can view searchable agendas for scheduled Planning Commission meetings and
access agenda -related City information and services directly on the following website:
httos://www.elseizundo.orR/der)ts/planninRsafety/agendas.asp. This site has an email notification service
enrollment process for copies of future Planning Commission agendas. The Final EIR document will be
posted for viewing and download with the previously posted Draft EIR prior to the City's consideration of
the Final EIR and Project recommendations on the same website noted above for the posting of the Draft
EIR: httos://www.elseRundo.orR/dents/i)lanninRsafety/planning/`. Printed copies of the Final EIR will be
provided for public viewing at the same publicly accessible locations used for the distribution of the Draft
EIR.
2. PROJECT DESCRIPTION
The Project Site consists of approximately 6.39 acres bounded by a vacant lot to the north; a parking
structure, surface parking lots, and commercial uses to the east; Rosecrans Avenue, the Kinecta Credit
Union building and parking lot is located directly south of the Project Site to the south; and a surface
parking lot and commercial uses to the west. The Project Site is currently a vacant lot with a screened
chain-link security fence running along the perimeter of the site and along the adjacent roadway. No
plantings or trees occur on the Project Site. Temporary landscaping has been installed along the
Rosecrans perimeter.
Land Use Regulation
RSP4, the Applicant desires to change both the General Plan land use designation and zoning of the
Property from Commercial Center (C-4) to Urban Mixed Use South (MU -S) and develop the Property with
the uses allowed by, and at the development standards set forth in the MU -S zone rather than the C-4
zoning standards, within the development parameters set forth above which will be memorialized in a
Development Agreement. The primary differences in the development standards between the C-4 zone
and the MU -S zone, are the MU -S zone allows greater height (175 feet), greater density (1.3 FAR), and
minor differences in setbacks. The C-4 zone has a height of 65 feet and a density of 0.275 FAR. The total
buildable square footage under the MU -S zone would be 361,844 square feet, however the Development
Agreement limits buildout to 313,00 square feet, limits FAR to 1.13, limits height to 140 feet, and limits or
prohibits certain uses. Additionally, there is a greater variety of uses allowed under the MU -S zone.
Land uses allowed in the C-4 zone include, but are not limited to, the following:
• Animal hospitals and veterinary
services.
■ Day spas.
• Daycare centers
• Farmers' market
• Financial institutions
Beach Cities Media Campus Project I. Introduction
Page 1-3
City of EI Segundo
• Fitness centers (indoors only)
• General offices
• Indoor sale of automobiles,
motorcycles, and motor scooters along
with the sale of accessories and parts as
an accessory use
• Medical and dental offices
• Multi -media offices
June 2019
• Personal services
• Public assembly/assembly halls,
including theaters and museums
• Recreational facilities
• Restaurants and cafes
■ Retail sales uses (excluding off site
alcohol sales
Land uses allowed in the MU -S zone include, but are not limited to, the following:
• Data centers
■ Daycare centers
■ Financial institutions
• Fitness centers
• General offices
• Hotels and motels
• Medical -dental offices or facilities
• Motion picture/television production
facilities (excluding outdoor facilities)
• Research and development
• Restaurants and cafes
• Retail (excluding off site alcohol sales)
and wholesale sales and services
■ Other similar uses approved by the
Director, as provided by Chapter 22 of
this title. (Ord. 1551, 8-15-2017
With the General Plan land use and zoning changes, the Project Site can be developed with a mix of
commercial uses aimed at promoting economic development within the City of EI Segundo in addition to
completing development of the Rosecrans Avenue corridor. A discretionary site plan approval will be
required
A Conceptual Site Plan configuration has been provided for the Beach Cities Media Campus, Figure II -2,
Site Plan. The Project would replace an underutilized vacant lot with a mixed use development that would
improve the urban design and character of the Project Site, and contribute to and complement the
development of the nearby neighboring commercial and office uses.
Proposed Development
The Beach Cities Media Campus Project includes the development of an approximately five -story, 240,000
square foot creative office building with the option to incorporate a roof deck, a one-story, 66,000 square
foot studio and production facilities building, and 7,000 square feet of retail uses in two, one-story
structures. The Project would also include a private event plaza. The Project may be a fully secure
campus. The studio and production facilities would operate 24 hours a day, seven days a week.
Table 1-1, Conceptual Plan Development Summary, summarizes the proposed land uses.
Table 1-1
Project Development SummM
Land Use Square Footage
Office 240,000 gsf
Studio and Production Facilities 66,000 gsf
Retail 7,000 gsf
Beach Cities Media Campus Project I. Introduction
Page 1-4
City of EI Segundo
Table 1-1
Project Development Summary
Land Use'qjT Cage
Total Proposed Project 313,000 gsf
gsf =gross square feet 1
Source: Rosecrans -Sepulveda Partners 4, LLC., August 2017.
June 2019
Parking for the Beach Cities Media Campus Project would be provided in multiple areas of the Property.
Parking would be provided in an up to seven -story parking structure with above grade and semi-subgrade
parking containing 980 parking spaces, a one level below grade structure beneath the office building
containing 120 parking spaces, and in surface parking areas elsewhere on the site.
Vehicular access to the Project Site would be provided by three driveways; these driveways may be gated
to create a secure campus for the Beach Cities Media Campus Project. Two entry/exit driveways would
be located on Rosecrans Avenue and one driveway to the Project Site would be accessed through the rear
of the existing adjacent commercial property to the east that provides access to South Nash Street, as
shown in Figure II -2, Site Plan.
Campus signage opportunities would also be available to the Project. Project signage would be designed
to be aesthetically compatible with the proposed architecture of the Project and other signage in the area.
Proposed signage would include identity signage, including identity signage at Rosecrans Avenue and
South Nash Street, office, retail, and studio tenant signage, and general ground -level and pedestrian
directional/wayfinding signage. In general, new signage would be architecturally integrated into the
design of the building and would establish appropriate identification for the on-site uses. No off -premise
billboard advertising is proposed as part of the Project. Project signage would be illuminated by means
of low-level external lighting, internal halo lighting, or ambient light. The Project would not include
electronic signage or signs with flashing, mechanical, or strobe lights. Project signage would comply with
the ESMC requirements, and any applicable approval processes for signs set forth therein. The character,
placement, size and proportions of the Project's proposed signs would be consistent with the ESMC.
Any development built on the Project Site will incorporate features to support and promote
environmental sustainability and meet or exceed the "Green Building" principles required by the City of
EI Segundo Green Building Program, and CalGreen and other City and State regulations. Additionally, the
landscaping will comply with the City's Water Efficient Landscape Ordinance.
Project Construction
The Project would be constructed over approximately 18 months. Construction would occur five days a
week, Monday through Friday, and may take place on Saturdays. Construction activities would include
site preparation, grading, excavation, and building construction. Site preparation activities are anticipated
to start July 1, 2019. Site Grading activities are anticipated to start August 2019 and end September 2019.
Construction would start late September 2019 and construction completion and occupancy is anticipated
in 2020.
The Project is estimated to require a maximum net export of approximately 35,000 to 49,400 cubic yards
of soil. The likely outbound haul route for the Project would be a left turn from the Project Site to head
east onto Rosecrans Boulevard, then a right turn onto the 405 Freeway. Exported materials would likely
be disposed at Puente Hills Landfill in the City of La Puente. The Project's haul route would be approved
by the City as part of its review and approval of the Project's entitlement requests. The City would also
approve a Construction Traffic Management Plan to be implemented during construction to minimize
potential conflicts between construction activity and through traffic.
Beach Cities Media Campus Project I. Introduction
Page 1-5
City of EI Segundo
Discretionary Actions
June 2019
The City of EI Segundo has the principal responsibility for approving the Project. Approvals required for
the development of the Project may include, but are not limited to the following:
• Certification of an Environmental Impact Report for the Project;
• Discretionary Site Plan Permit;
■ Approval of a Mitigation Monitoring and Reporting Program;
• Amend the Land Use Element of the City's General Plan to change the land use designation of the
Project Site from Commercial Center to Urban Mixed Use -South;
• Amend the City's zoning map to change the zoning of the Project Site from C-4 to MU -S;
• Approval of Development Agreement to detail the Project parameters, standards and conditions
that will govern development of the Project Site;
• Haul route approval (if required); and
• Other permits, ministerial or discretionary, that may be necessary in order to execute and
implement the Project.
The City of EI Segundo is the lead agency for the Project. Responsible agencies may include, without
limitation:
• South Coast Air Quality Management District,
■ Regional Water Quality Control Board,
• City of Manhattan Beach for Traffic Signal; and
• West Basin Municipal Water District
3. SUMMARY OF ENVIRONMENTAL IMPACTS
An Initial Study was prepared for the Project as permitted by CEQA Guidelines Section 15060(d). The Draft
EIR evaluates the environmental impacts associated with Project implementation. Based on the Initial
Study, and agency and public comments in response to the NOP and a review of environmental issues,
the Draft EIR includes analyses of the following environmental topics as set forth in CEQA Guidelines
Appendix G:
Based on a review of environmental issues by the Planning Division, this EIR assesses the following
environmental impact areas:
• Air Quality
• Cultural Resources (Archaeological, Paleontological)
• Geology and Soils
• Greenhouse Gas Emissions
Beach Cities Media Campus Project I. Introduction
Page 1-6
City of EI Segundo
■ Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Noise
■ Population, Housing, and Employment
■ Public Services
■ Transportation, Traffic and Parking
• Cultural Tribal Resources
• Utilities and Service Systems
June 2019
Potential environmental effects in the areas of Agricultural Resources, Biological Resources, and Mineral
Resources, as well as other specific areas related to the topics listed below, were determined to be either
less than significant or no impact, or not applicable, and, therefore, are not evaluated in greater detail in
the EIR. These areas are addressed in Section VII, Effects Not Found to be Significant, of the Draft EIR.
• Aesthetics (all subtopics);
• Agriculture and Forest Resources (all subtopics);
• Air Quality (objectionable odors);
■ Biological Resources (all subtopics);
• Cultural Resources (historical resources);
■ Geology and Soils (seismic -related ground failure, including liquefaction, landslides, and septic
tanks);
• Hazards and Hazardous Materials (proximity to schools, public and private airports, and wildland
fires);
• Hydrology and Water Quality (100 -year flooding and seiche/tsunami/mudflow);
• Land Use and Planning (community division and habitat conservation plans);
• Mineral Resources (all subtopics);
• Noise (public and private airports/airstrips);
■ Population, Housing and Employment (displacement of existing housing or people);
■ Public Services (schools, parks, and public facilities);
■ Recreation (all subtopics);
■ Transportation, Traffic and Parking (air traffic patterns and hazardous design features); and
Beach Cities Media Campus Project I. Introduction
Page 1-7
City of EI Segundo
June 2019
• Utilities and Service Systems (compliance with statutes and regulations).
The Draft EIR analysis in Section IV (Environmental Impact Analysis), indicates that implementation of
Project Design Features, Regulatory Requirements, and Mitigation Measures would result in the Project
having the following impacts reduced to a level of less than significant:
• Paleontological Resources,
Archaeological Resources,
• Greenhouse Gas Emissions,
Hazards and Hazardous Materials,
Hydrology and Water Quality, and
• Tribal Cultural Resources.
Based on the analysis in Section IV (Environmental Impact Analysis) of the Draft EIR, implementation of
the Project would result in significant unavoidable environmental impacts after implementation of
feasible mitigation measures relative to:
■ Population, Housing, and Employment (City and regional population and housing demands), and
• Transportation, Traffic and Parking (After applying the mitigation measures, a total of four
significant and unavoidable impacts would remain in Existing plus Project and a total of three
significant and unavoidable impacts would remain in Future plus Project, and cumulative
construction traffic. The traffic impacts of the Project cannot be mitigated below the threshold of
significance).
Beach Cities Media Campus Project I. Introduction
Page 1-8
II. RESPONSE TO COMMENTS
Upon completion of the Draft EIR, notice of the public review period was given in accordance with Section
15087 of the State CEQA Guidelines. On March 1, 2019, a Notice of Availability ("NOA") of the Draft EIR
was prepared and distributed to the State Office of Planning and Research, the Los Angeles County Clerk,
responsible and trustee agencies, organizations, interested parties, and all parties who requested access
to a copy of the Draft EIR in accordance with CEQA. The NOA was also distributed to owners and
occupants of properties located within 500 feet of the Project Site. The comments on the Draft EIR were
accepted during a 45 -day public review period extending from March 1, 2019 through to April 15, 2019.
The NOA was distributed to the mailing list and email list prepared for the Notice of Preparation ("NOP")
for the scoping stage of the Project before issuance of the Draft EIR, and was augmented to include
individuals requested to be added to the list, as well as individuals who had provided comments on the
NOP. The NOA and Draft EIR were posted on the Lead Agency's website.
Letters commenting on the information and analysis in the Draft EIR were received from various parties
during the 45 -day public review period (i.e., March 1, 2019 through to April 15, 2019). A total of 11
comment letters were received, including four letters from State, four regional and local agencies, and
three letters from organizations and individuals. Four of the comment letters submitted to the City (State
Clearinghouse letter number 2, dated April 29, 2019, the Department of Toxic Substances Control letter
dated April 5, 2019 received to the State Clearinghouse April 29, 2019, the e-mail letter from Lisa Kranitz
dated March 25, 2019, which was added as a comment letter on May 17, 2019; and the letter from Lozeau
Drury LLP dated May 21, 2019) are considered late letters that do not require a written response from the
City.
Under CEQA Guidelines Section 15105, the City was legally required to provide a 45 -day public review
period on the Draft EIR. The public comment period for the Draft EIR began on March 1, 2019, and ended
on April 15, 2019. All comment letters received after expiration of the public review and comment period
ending on August 15, 2019, are considered late comments.
A Lead Agency is required to consider comments on the Draft EIR and to prepare written responses if a
comment is received within the public comment period (Pub. Resources Code, §21091(d); CEQA
Guidelines, §15088). When a comment letter is received after the close of the public comment period,
however, a Lead Agency does not have an obligation to respond (Pub. Resources Code, §21091(d)(1); Pub.
Resources Code, §21092.5(c).). Accordingly, the City is not required to provide a written response to late
comment letters, including: the State Clearinghouse letter number 2, dated April 29, 2019; and the
Department of Toxic Substances Control letter dated April 5, 2019 received to the State Clearinghouse
April 29, 2019, the e-mail letter from Lisa Kranitz dated March 25, 2019, which was added as a comment
letter on May 17, 2019; and the letter from Lozeau Drury LLP dated May 21, 2019 (See, CEQA
Guidelines,§15088(a)).
Nonetheless, for information purposes, the City has elected to respond to these late letters, but without
waiving its position that written responses to late comment letters are not required by law.
The responses to all comments, are provided below. Responses to State, regional, and local agencies are
included in Section 1; responses to organizations and individuals are included in Section 2, and comment
letters that were received by the Lead Agency after the end of the review period and are considered late
are included in Section 3.
Beach Cities Media Campus Project II. Response to Comments
Page II -1
City of EI Segundo June 2019
Section 15088 of the CEQA Guidelines states that "[tjhe lead agency shall evaluate comments on
environmental issues received from persons who reviewed the Draft EIR and shall prepare a written
response. The Lead Agency shall respond to comments received during the noticed comment period and
any extensions and may respond to late comments." The CEQA Guidelines call for responses that contain
a "good faith, reasoned analysis" with statements supported by factual information. Some of the
comments submitted to the Lead Agency, however, were general in nature, stating opinion either in favor
of or in opposition to the Project. In such cases, the comment is made a part of the administrative record
and will be forwarded to the City's decision makers for their consideration.
In accordance with these requirements, this Chapter of the Final EIR provides a good faith, reasoned
analysis and responds to each of the written comments on environmental issues received regarding the
Draft EIR during the comment periods.
Each comment letter is provided first and is bracketed in the right margin, sequentially numbered (e.g., 1,
2). Following the bracketed comment letter, responses are presented in corresponding order to provide
a matching numbered response on the pages following each comment letter.
1. STATE, REGIONAL AND LOCAL AGENCIES
Comment letters from State, regional and local agencies consisted of:
• State of California, Governor's Office of Planning and Research, State Clearinghouse and Planning
Unit, April 16, 2019
■ State of California, Department of Transportation, April 15, 2019
■ South Coast Air Quality Management District, April 10, 2019
• County of Los Angeles, Fire Department, March 28, 2019
• County of Los Angeles, County Sanitation Districts, April 15, 2019
■ City of Manhattan Beach, April 15, 2019
Responses to the comments in these letters are provided below, after each letter.
Beach Cities Media Campus Project II. Response to Comments
Page II -2
Gavin N,:(v.orla
t.ioVicrukir
April 16, 2014
STATE OF CALIFORNIA
Governor',s Office of Planning; alnd Rc. iezivuh ;
St. -ate Cit-ttl•inghouse .and P1.3nning Unit.
Di riwl, n-
rthan E::dwijrt.lc
GI S. pintlu, City at'
3S0 Main Street
El Segundo, CA 90245
�ubjcr(: Pn,pused Bcach Cities IvIeelia CjWua Pro) cl
St:lUl:
2017121035
Dear Hhan I:tlwarck
The Slat; Ulvarla house suhruilwd the above: lutnse d 1 IR lu sAxleel sure abenciey Icor review. Ola the
rn4l,awd VCx:umew Details Rep ml ple:nse ntme that life C'lc.aringhowx has listed ilk .>t�ale: agcncic� that
rcvirn•cd Your document. The review pl:riod cl".d on 4'112619, anti the ciymients ftom Ilse respucxling
4genc). (ie13) iti (am) available on the CV0A tUabasc #eN ylaur rctricv'al and use, if this o.)nirnent packaec ir1
tot in order. p1c.isc nolify the Starc C'ltaliteghausc irnuirdialdy_ i'Icast: rufcr tit the: project's ten -digit Siale
:ir:uirr larluse nuinlxr in Ibiure cmre,: )ndencc sra flan( we may r"N)nd pronsptly.
Meme: Itr)fe: th:1l Set;tiun Ll104(c) orthe Callfinnij Public Ikestaurces Ends state, [hat:
"A rcxpunsibk; ur other pulilic agency--ihall only make suhslxn(M: conunenis regarding t1:
activities involved in a proiect which are within an area of expertise orthe agency or whie i
required to br carried oul or approved by the agency. Thow comments shall ht: suprearte:d lav
+I)eifie d,xzfQsentatian.'
f Ir 'I, Illy ('V0 l !• I'+'t. !'in'r w! rro If"` hi prl fl:frift- a'i!It' lilt it ene•irnnfile it$
IFIL 1"—"W11 r �`rIi'
I ll,,: c4loiUloUm., M! i'CC0111111elid ltial yOil Clalllacl lite agvilcy dirvVil ,
Pus :clter ;i.:l<ifiai ycju have complied wi[li !hr Slaw Clrarulglrrm%c ruviuw mquirelnetti; rof
Iraft : nvir,tnrurfat,ll d-1runwn.[s, OUNUanr to tiff C aI &trnla 1:11vinanmental Quality Act. I'leasc contract this
M i11 P0 4-: 1.061 .� il• vt1t1 I':11'C .ilio e uemioll% fcgarding tlx: ca1'ir(tinvtant:•[ wvi-:--v
taf�,c:�tix.
Sillarfcly.
.fa
l?iw-1-tol, tiwpvi C';cal,llwlv:ww
c(.: )Zesourc;,s Alf acy
I ltif) T1�:NTII STH $,'1•:l' 1, U Iti).� a[i I I S-xCI1,.\.VI- ITU, C ALIl'l.11 NIA 95812,30-11
i'ki_, 1 9 1ii •1 I+r;l('. 13 - t;ll!'xlc,,r Tnl h,,t;t.� :u eq+r,r.(e t m' ww►..apr,e rr.gzw
City of EI Segundo
Comment Letter No. 1
State of California
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit
Scott Morgan, Director, State Clearinghouse
140010th Street
P.O. Box 3044
Sacramento, CA 95812-3044
April 16, 2019
Response to Comment 1-1
June 2019
This comment is a standard response from the State Clearinghouse of Planning and Research
acknowledging the Draft EIR was sent to State agencies for review, and that the Draft EIR is in compliance
with the State Clearinghouse review requirements for draft environmental documents. The comment
asks to check the CEQA database for submitted comments for use in preparing the final environmental
document. The CEQA databases contains one letter from the State of California, Department of
Transportation, District 7, (see Comment Letter No. 2). The comments contained in this letter are
responded to in Responses 2-1 through 2-10.
Beach Cities Media Campus Project II. Response to Comments
Page II -4
STATE OF CALIFORNIA --CALIFORNIA STATE= TRANSPORTATION AGENCY
DEPARTMENT OF TRANSPORTATION
DISTRICT 7
100 S. MAIN STREET, MS16
LOS ANGELES, CA 90012
PHONE (213) 897-6536
FAX (213) 897-1337
TTY 711
www.dot.ca.gov
April 15, 2019
Mr. Ethan Edwards, AICP
City of EI Segundo
350 Main Street
EI Segundo, CA 90245
Dear Mr. Edwards:
Comment Letter No. Z
Gavin Newsom. Governor
Making Conservation
a California Way of Life.
RE: Beach Cities Media Campus Project
Vic. LA-01/PM 23.925, LA-405/PM 19.23
SCH # 2017121035
Ref. GTS # LA -2017 -01260 -NOP
GTS # LA-2017-02346-DEIR
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the above referenced project. The proposed Project
proposes to develop office, retail, and studio and production facilities on an approximately
6.39 -acre site. The Project would include the development of an approximately 240,000
square foot creative office building with the option to incorporate a roof deck, a 66,000
square foot studio and production facilities building, and 7,000 square feet of retail uses.
The Project would also provide 1,100 parking spaces.
The mission of Caltrans is to provide a safe, sustainable, integrated and efficient
transportation system to enhance California's economy and livability. Senate Bill 743
(2013) mandated that CEQA review of transportation impacts of proposed development be
modified by using Vehicle Miles Traveled (VMT) as the primary metric in identifying
transportation impacts for all future development projects. For future project, you may
reference to The Governor's Office of Planning and Research (OPR) for more information.
httr): //o r)r. ca . govlce g a/ u Ddate s/guidelines/
Caltrans is aware of challenges that the region faces in identifying viable solutions to
alleviating congestion on State and Local facilities. With limited room to expand vehicular
capacity, future development should incorporate multi -modal and complete streets
transportation elements that will actively promote alternatives to car use and better manage
existing parking assets. Prioritizing and allocating space to efficient modes of travel such
as bicycling and public transit can allow streets to transport more people in a fixed amount
of right-of-way.
"Provide a safe, sustainable, Integrated and efficient transportation system
to enhance California's economy and livability"
1
3
Mr. Ethan Edwards
April 15, 2019
Page 2
Caltrans supports the implementation of complete streets and pedestrian safety measures
such as road diets and other traffic calming measures. Please note the Federal Highway
Administration (FHWA) recognizes the road diet treatment as a proven safety 4
countermeasure, and the cost of a road diet can be significantly reduced if implemented in
tandem with routine street resurfacing.
We encourage the Lead Agency to integrate transportation and land use in a way that
reduces Vehicle Miles Traveled (VMT) and Greenhouse Gas (GHG) emissions by
facilitating the provision of more proximate goods and services to shorten trip lengths, and
achieve a high level of non -motorized travel and transit use. We also encourage the Lead 5
Agency to evaluate the potential of Transportation Demand Management (TDM) strategies
and Intelligent Transportation System (ITS) applications in order to better manage the
transportation network, as well as transit service and bicycle or pedestrian connectivity
improvements.
After reviewing the Draft Environmental Impact Report for this project based on Level of
Service (LOS), Caltrans has the following comments:
1. From the Proposed Beach Cities Media Campus Project DEIR dated on March 1, 6
2019, it was. stated that the project would generate net 2,833 daily trips and 333/309
AM/PM peak hour trips per Table IV.K-3 Project Trip Generation.
2. Caltrans concurs with the concept of mitigation measure MM K-5 at Intersection 24.
1-405 Northbound on/off-ramps & Rosecrans Avenue shown on page IV.K-48, "This
mitigation involves restriping the northbound off -ramp lanes from two lefts and one 7
right to two left and one shared left/right. The western portion of the intersection has
three receiving lanes for the left -turn movement. The existing median along
Rosecrans Avenue may need to be cut back in order to accommodate the third left
turning movement."
3. A Caltrans encroachment permit will be required to implement the improvement. A
Permit Review Engineering Report (PEER) and intersection operational analysis for 8
the intersection improvement will be required as part of the encroachment permit
application. Any modification must meet all design standard and specifications.
4. Storm water run-off is a sensitive issue for Los Angeles and Ventura counties.
Please be mindful that projects should be designed to discharge clean run-off water. 9
Additionally, discharge of storm water run-off is not permitted onto State highway
facilities without any storm water management plan.
"Provide a safe, sustainable, integrated and efficient transportation system
to enhance California's economy and livability"
Mr. Ethan Edwards
April 15, 2019
Page 3
5. Transportation of heavy construction equipment and/or materials, which requires the
use of oversized -transport vehicles on State highways, will require a transportation
permit from Caltrans. It is recommended that large size truck trips be limited to off-
peak commute periods. 10
If you have any questions, please feel free to contact Alan Lin the project coordinator at
(213) 897-8391 and refer to GTS # 07-LA-2017-02346AL-DEIR.
Sincer ly,
MIYA EDMONSON
IGR/CEQA Branch Chief
cc: Scott Morgan, State Clearinghouse
Provide a safe, sustainable, integrated and efficient transportation system
to enhance California's economy and livability"
City of EI Segundo
Comment Letter No. 2
State of California
Department of Transportation
District 7 -Office of Regional Planning
Miya Edmonson, IGR/CEQA Acting Branch Chief
100 South Main Street, MS 16
Los Angeles, CA 90012
April 15, 2019
Response to Comment 2-1
June 2019
The comment accurately describes the Project as an introduction to the comments on the Draft EIR that
follow.
Response to Comment 2-2
The comment states that the mission of Caltrans is to provide a safe, sustainable, integrated efficient
transportation system to enhance California's economy and livability. The comment also states Senate
Bill 743 (2013) mandated that CEQA review of transportation impacts of proposed development be
modified by using Vehicle Miles Traveled. The comment does not identify any specific shortcomings of
the Draft EIR analysis or mitigation measures, and no specific response is therefore possible or required.
This comment is noted for the administrative record and will be forwarded to the decision -makers for
review and consideration.
Response to Comment 2-3
The comment states that Caltrans is aware of the challenges that the region faces in identifying viable
solutions to alleviating congestion on State and Local facilities. The comment does not identify any
specific shortcomings of the Draft EIR analysis or mitigation measures, and no specific response is
therefore possible or required. This comment is noted for the administrative record and will be forwarded
to the decision -makers for review and consideration.
Response to Comment 2-4
The comment states that Caltrans supports the implementation of complete streets and pedestrian safety
measures such as road diets. The comment does not identify any specific shortcomings of the Draft EIR
analysis or mitigation measures, and no specific response is therefore possible or required. This comment
is noted for the administrative record and will be forwarded to the decision -makers for review and
consideration.
Response to Comment 2-5
The comment states that they encourage the Lead Agency to integrate transportation and land use in a
way that reduces Vehicle Miles Traveled (VTM) and Greenhouse Gas (GHG), and to evaluate the potential
of Transportation Demand Management (TDM) strategies and the Intelligent Transportation System (ITS).
As discussed in Section IV.D, Greenhouse Gas, page IV.D-41 of the Draft EIR, the Project would be
consistent with the 2017 Climate Change Scoping Plan's emission reduction goals which focus on building
efficiency standards and transportation improvements. The Project, which is located in a Transit Priority
Area and near transit opportunities, is within walking distance of nearby retail and entertainment
destinations. Additionally, the Project would provide bicycle storage areas for Project employees. These
Beach Cities Media Campus Project II. Response to Comments
Page II -8
City of EI Segundo June 2019
characteristics would reduce VMTs. In addition, the reduction of VMTs and the increase in energy
efficiency, would reduce greenhouse gas emissions, consistent with the goals outlined in the 2017 Climate
Change Scoping Plan. Furthermore as discussed in Section IV. K, Transportation, Traffic and Parking, page
IV.K-46 of the Draft EIR, the Project would include TDM strategies to discourage single -occupancy vehicle
trips and encourage alternative modes of transportation, thus further reducing VMT's. This comment is
noted for the administrative record and will be forwarded to the decision -makers for review and
consideration.
Response to Comment 2-6
This comment states that the Project would generate net 2,833 daily trips and 333/309 AM/PM peak hour
trips per Table IV.K-3 Project Trip Generation. The commenter accurately describes the Project.
Resoonse to Comment 2-7
The commenter concurs with the concept of mitigation measure MM K-5 at Intersection 24: 1-405
Northbound on/off ramps & Rosecrans Avenue as shown on page IV.K-48 of the Draft EIR. The commenter
accurately describes the mitigation measure.
Response to Comment 2-8
The comment states a Caltrans encroachment permit is required to implement the improvement, and a
Permit Review Engineering Report (PEER) and intersection operational analysis for the intersection
improvement will be required as part of the encroachment permit application. The Project will comply
with any Caltrans permit requirements regarding encroachment.
Response to Comment 2-9
The comment states storm water run-off is a sensitive issue for Los Angeles and Ventura Counties. The
comment states discharge of storm water run-off is not permitted onto State highway facilities without
any storm water management plan. The Project will comply with any Caltrans storm water management
plan.
Response to Comment 2-10
The comment states that transportation of heavy equipment and/or oversized vehicles on State highways
requires a permit from Caltrans and recommends that such activity be limited to off-peak commute
periods. The Project will comply with any Caltrans permit requirements regarding transportation of
equipment or materials.
Beach Cities Media Campus Project II. Response to Comments
Page II -9
Comment Letter No. 3
South Coast
Air Quality Management District
21865 Copley Drive, Diamond Bar, CA 91765-4178
(909) 396-2000 - www.agmd.gov
SENT VIA E-MAIL AND USPS: April 10, 2019
E EdwardsOve lseeundo. o tg
Ethan Edwards, AICP_ Contract Planner
City of El Segundo, Planning and Building Safety Development
Planning Division
350 Main Street
El Segundo, CA 90245
Draft Environmental Irnnaet Rennet (Draft E11R) for the Proposed Beach Cities Media Cam ims
Proiect (SCH No.: 2017121035)
South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to conunent
on the above-mentioned document. The following comments are meant as guidance for the Lead Agency
and should be incorporated into the Final EIR.
SCAQMD Staffs Summan- of Proiect Descrimion
The Lead Agency proposes to construct four buildings with office and retail uses totaling 313,000 square
feet on 6.39 acres (Proposed Project). The Proposed Project is located at 2021 Rosecrans Avenue on the
northeast corner of Rosecrans Avenue and Village Detre in the City of El Segundo. Based on a review of
the Draft EIR, SCAQMD staff found that historically the site was previously developed with an air gas 1
manufacturing plant from 1969 through 20161. As a result of historical usage, soil at the site was found
to be impacted with total petroleum hydrocarbons (TPHs), lead, PCBs, and volatile organic compounds
(VOCs)2. Impacted soil was removed from the site to the levels required for conunercial development..
and a letter of No Further Action was issued in August 20173. Groundwater remedial action appears to be
ongoing'.
Conwilance with SCAQMD Rules &. Permits
Since the Proposed Project includes grading and site preparation activities that might cause residual
TPHs, lead. PCBs_ and VOCs to become airborne during constriction. and in addition to a discussion on
SCAQMD Rule 1166 — Volatile Organic Compounds from Decontamination of Soil. the Lead Agency
should include a discussion to demonstrate compliance with SCAQMD Rule 1466 — Control of
Particulate Emissions from Soils with Toxic Air Contaminants' in the Air Quality Section of the Final
EIR. among the list of other applicable SCAQMD Rules. If on-site groundwater remediation or any on-
site activity would involve equipment or operations, which either emits or controls air pollution,
SCAQMD Engineering and Permitting staff should be consulted in advance to determine whether or not 2
any permits or plans are required to be filed and approved by SCAQMD prior to the start of any remedial
activities or operations. in the event that implementation of the Proposed Project regaures a permit from
SCAQMD_ the Lead Agency should identify SCAQMD as a Responsible Agency for the Proposed
Project in the Final EIR. Emissions from permitted equipment should be quantified and added to the
Proposed Project's construction and operational emissions, where applicable, to determine the level of
significance. Any assumptions in the Air Quality Analysis in the Final EIR will be used as the basis for
Drall I'.IR. Hazards and Ilazardous Materials. Page IV_l:.1 - IV.E 3.
'- !h, id
3 Ibid.
'I Drall EIR Appendices. Appendix F.I _ Phase 1 Environmental Site assessment. Pages 738-786.
5 Soutli Coast Air Quality Management District. Rule 1466 Control of Particulate Emissions from Soils with Toxic Air
Contaminants Accessed al: hllps :►vwn.sumd.uut dncsdelault-soumoruIo-hook,rep -xiwrule-I466.pd
Ethan Edwards April 10, 2019
permit conditions and limits. For more information on permits, please visit SCAQMD's webpage at: 2 cont.
httD://www.aamd.mov/home/hermits. Questions on permits can be directed to SCAQMD's Engineering
and Permitting staff at (909) 396-3385.
Conclusion
Pursuant to California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section
15088(b), SCAQMD staff requests that the Lead Agency provide SCAQMD staff with written responses
to all comments contained herein prior to the certification of the Final EIR. In addition, issues raised in
the comments should be addressed in detail giving reasons why specific comments and suggestions are
not accepted. There should be good faith, reasoned analysis in response. Conclusory statements
unsupported by factual information will not suffice (CEQA Guidelines Section 15088(c)). Conclusory 3
statements do not facilitate the purpose and goal of CEQA on public disclosure and are not meaningful,
informative, or useful to decision makers and to the public who are interested in the Proposed Project.
SCAQMD staff is available to work with the Lead Agency to address any air quality questions that may
arise from this comment letter. Please contact Alina Mullins, Assistant Air Quality Specialist, at
amullins(aaamd.p-ov or (909) 396-2402, should you have any questions.
LS:AM
LAC190305-07
Control Number
Sincerely,
ze# s"
Lijin Sun, J.D.
Program Supervisor, CEQA IGR
Planning, Rule Development & Area Sources
2
City of EI Segundo
Comment Letter No. 3
South Coast Air Quality Management District
Planning, Rule Development & Area Sources
Lijin Sun, J.D. Program Supervisor, CEQA IGR
21865 Copley Drive
Diamond Bar, CA 91765-4178
April 10, 2019
Response to Comment 3-1
June 2019
The comment accurately describes the Project as an introduction to the comments on the Draft EIR that
follow.
Response to Comment 3-2
The commenter states that the Final EIR needs to add SCAQMD Rule 1166—Volatile Organic Compounds
from Decontaminated Soil, and SCAQMD Rule 1466 - Control of Particulate Emissions from Soils with Toxic
Contaminants. The commenter is referred to Section Ill. Revisions, Clarifications and Corrections on the
Draft EIR. W.A. Air Quality, pages IV.A-12 through IV.A-13 have been revised. Inclusion of these revisions
do not affect the analysis or conclusions of the Draft EIR and therefore, recirculation of the Draft EIR is
not required.
The commenter states that the project would be required to comply with SCAQMD Rule 1166 and Rule
1466. This comment is noted. The project applicant would be required to comply with SCAQMD Rule 1166
and Rule 1466 because these are existing regulatory requirements.
The commenter states if on-site groundwater remediation or any on-site activity would involve equipment
or operations which emits or controls air pollution, SCAQMD Engineering and Permitting staff should be
consulted prior to the start of remediation to determine whether or not permits are required by the
SCAQMD. The project applicant would comply with SCAQMD Engineering and Permitting staff. This
comment is noted for the administrative record and will be forwarded to the decision -makers for review
and consideration.
Response to Comment 3-3
The commenter requests the Lead Agency provide SCAQMD with written responses to all comments prior
to the certification of the Final EIR. The Lead Agency will provide the SCAQMD with a copy the responses
to their comments prior to certification of the Final EIR. This comment is noted for the administrative
record and will be forwarded to the decision -makers for review and consideration.
Beach Cities Media Campus Project II. Response to Comments
Page II -12
March 28, 2019
comment Letter No. 4
COUNTY OF LOS ANGELES
FIRE DEPARTMENT
1320 NORTH EASTERN AVENUE
LOS ANGELES, CALIFORNIA 90063-3294
(323) 881-2401
www.f ire.lacounty. gov
"Proud Protectors of Life, Property, and the Environment"
Ethan Edwards, Contract Planner
City of EI Segundo
Planning and Building Safety Department
350 Main Street
EI Segundo, CA 90245
Dear Mr. Edwards:
BOARD OF SUPERVISORS
HILDA L. SOLIS
FIRST DISTRICT
MARK RIDLEY-THOMAS
SECOND DISTRICT
SHEILA KUEHL
THIRD DISTRICT
JANICE HAHN
FOURTH DISTRICT
KATHRYN BARGER
FIFTH DISTRICT
NOTICE OF AVAILABILITY OF AN ENVIRONMENTAL IMPACT REPORT, "BEACH
CITIES MEDIA CAMPUS PROJECT," PROPOSES TO DEVELOP OFFICE, RETAIL, AND
STUDIO AND PRODUCTION FACILITIES ON AN APPROXIMATELY 6.39 -ACRE SITE,
2021 ROSECRANS AVENUE, EL SEGUNDO, FFER 201900019
The Notice of Availability of an Environmental Impact Report has been reviewed by the
Planning Division, Land Development Unit, Forestry Division, and Health Hazardous
Materials Division of the County of Los Angeles Fire Department.
The following are their comments:
PLANNING DIVISION:
The subject property is entirely within the City of EI Segundo, which is not a part of the
emergency response area of the Los Angeles County Fire Department (also known as the
Consolidated Fire Protection District of Los Angeles County). Therefore, this project does not
appear to have any impact on the emergency responsibilities of this Department. 1
For any questions regarding this response, please contact Loretta Bagwell, Planning Analyst,
at (323) 881-2404 or Loretta. Bacwell Qfire. lacountv•gov.
SERVING THE UNINCORPORATED AREAS OF LOS ANGELES COUNTY AND THE CITIES OF:
.GOURA HILLS
CALABASAS
EL MONTE
INDUSTRY
LAWNDALE
FIRE
SIGNAL HILL
,RTESIA
CARSON
GARDENA
INGLEWOOD
p�p�RTM�-r
PICO RIVERA
SOUTH ELMONTE
DARYL L OSBY
CERRITOS
FIRE CHIEF
IRWINDALE
FORESTER 8 FIRE
WARDEN
March 28, 2019
comment Letter No. 4
COUNTY OF LOS ANGELES
FIRE DEPARTMENT
1320 NORTH EASTERN AVENUE
LOS ANGELES, CALIFORNIA 90063-3294
(323) 881-2401
www.f ire.lacounty. gov
"Proud Protectors of Life, Property, and the Environment"
Ethan Edwards, Contract Planner
City of EI Segundo
Planning and Building Safety Department
350 Main Street
EI Segundo, CA 90245
Dear Mr. Edwards:
BOARD OF SUPERVISORS
HILDA L. SOLIS
FIRST DISTRICT
MARK RIDLEY-THOMAS
SECOND DISTRICT
SHEILA KUEHL
THIRD DISTRICT
JANICE HAHN
FOURTH DISTRICT
KATHRYN BARGER
FIFTH DISTRICT
NOTICE OF AVAILABILITY OF AN ENVIRONMENTAL IMPACT REPORT, "BEACH
CITIES MEDIA CAMPUS PROJECT," PROPOSES TO DEVELOP OFFICE, RETAIL, AND
STUDIO AND PRODUCTION FACILITIES ON AN APPROXIMATELY 6.39 -ACRE SITE,
2021 ROSECRANS AVENUE, EL SEGUNDO, FFER 201900019
The Notice of Availability of an Environmental Impact Report has been reviewed by the
Planning Division, Land Development Unit, Forestry Division, and Health Hazardous
Materials Division of the County of Los Angeles Fire Department.
The following are their comments:
PLANNING DIVISION:
The subject property is entirely within the City of EI Segundo, which is not a part of the
emergency response area of the Los Angeles County Fire Department (also known as the
Consolidated Fire Protection District of Los Angeles County). Therefore, this project does not
appear to have any impact on the emergency responsibilities of this Department. 1
For any questions regarding this response, please contact Loretta Bagwell, Planning Analyst,
at (323) 881-2404 or Loretta. Bacwell Qfire. lacountv•gov.
SERVING THE UNINCORPORATED AREAS OF LOS ANGELES COUNTY AND THE CITIES OF:
.GOURA HILLS
CALABASAS
EL MONTE
INDUSTRY
LAWNDALE
PARAMOUNT
SIGNAL HILL
,RTESIA
CARSON
GARDENA
INGLEWOOD
LOMITA
PICO RIVERA
SOUTH ELMONTE
ZUSA
CERRITOS
GLENDORA
IRWINDALE
LYNWOOD
POMONA
SOUTH GATE
ALDWIN PARK
CLAREMONT
HAWAIIAN GARDENS
LACANADA-FLINT RIDGE
MALIBU
RANCHO PALOS VERDES
TEMPLE CITY
.ELL
COMMERCE
HAWTHORNE
LA HABRA
MAYWOOD
ROLLING HILLS
WALNUT
ELL GARDENS
COVINA
HERMOSA BEACH
LA MIRADA
NORWALK
ROLLING HILLS ESTATES
WEST HOLLYWOOD
ELLFLOWER
CUDAHY
HIDDEN HILLS
LA PUENTE
PALMDALE
ROSEMEAD
WESTLAKE VILLAGE
RADBURY
DIAMOND BAR
HUNTINGTON PARK
LAKEWOOD
PALOS VERDES ESTATES
SAN DIMAS
WHITTIER
DUARTE
LANCASTER
SANTA CLARITA
Ethan Edwards, Contract Planner
March 28, 2019
Page 2
LAND DEVELOPMENT UNIT:
This project is located entirely in the City of EI Segundo. Therefore, the City of EI Segundo
Fire Department has jurisdiction concerning this project and will be setting conditions. This
project is located in close proximity to the jurisdictional area of the Los Angeles County Fire
Department. However, this project is unlikely to have an impact that necessitates a comment
concerning general requirements from the Land Development Unit of the Los Angeles County
Fire Department. 2
Should any questions arise regarding subdivision, water systems, or access, please contact
the County of Los Angeles Fire Department Land Development Unit's, Inspector
Nancy Rodeheffer at (323) 890-4243.
The County of Los Angeles Fire Department's Land Development Unit appreciates the
opportunity to comment on this project.
FORESTRY DIVISION — OTHER ENVIRONMENTAL CONCERNS:
The statutory responsibilities of the County of Los Angeles Fire Department's Forestry
Division include erosion control, watershed management, rare and endangered species,
vegetation, fuel modification for Very High Fire Hazard Severity Zones, archeological and
cultural resources, and the County Oak Tree Ordinance. Potential impacts in these areas
should be addressed. 3
The County of Los Angeles Fire Department's Forestry Division has no further comments
regarding this project.
For any questions regarding this response, please contact Forestry Assistant, Kelly Kim at
(818) 890-5719.
HEALTH HAZARDOUS MATERIALS DIVISION:
The Health Hazardous Materials Division of the Los Angeles County Fire Department has no
jurisdiction in the City of EI Segundo.
Please contact HHMD senior typist -clerk, Perla Garcia at (323) 890-4035 or 4
Peda.aarcia@fire.lacountV.gov if you have any questions.
If you have any additional questions, please contact this office at (323) 890-4330.
Ethan Edwards, Contract Planner
March 28, 2019
Page 3
Very truly yours,
MICHAEL Y. TAKESHITA, ACTING CHIEF, FORESTRY DIVISION
PREVENTION SERVICES BUREAU
MYT:ac
City of EI Segundo
Comment Letter No. 4
County of Los Angeles Fire Department
Prevention Services Bureau
Michael Y. Takeshita, Acting Chief, Forestry Division
1320 North Eastern Avenue
Los Angeles, CA 90063-3294
March 28, 2019
Response to Comment 4-1
June 2019
The comment states the Project is located within the City of EI Segundo and is not part of the emergency
area of the Los Angeles County Fire Department. The comment states the project does not appear to
have any impact on the emergency responsibilities of the Department. This comment is noted for the
administrative record and will be forwarded to the decision -makers for review and consideration.
Response to Comment 4-2
The comment states the Project is located within the City of EI Segundo. The comment states the Project
is unlikely to have an impact that necessitates a comment from the Land Development Unit of the Los
Angeles County Fire Department. This comment is noted for the administrative record and will be
forwarded to the decision -makers for review and consideration.
Resnonse to Comment 4-3
The comment states the responsibilities of the County of Los Angeles Fire Department's Forestry Division
include erosion control , watershed management, rare and endangered species, vegetation, fuel
modification for Very High Fire Hazard Severity Zones, archaeological and cultural resources, and the
County Oak Tree Ordinance. The comment states potential impacts in these areas should be addressed.
The commenter is referred to the Draft EIR Sections, IV.B Cultural Resources, IV.F Hydrology and Water
Quality, and Section VII. Effects Not Found to be Significant for a discussion of the above issue areas.
Response to Comment 4-4
The comment states the Health and Hazardous Materials Division of Los Angeles County Fire Department
has no jurisdiction in the City of EI Segundo. This comment is noted for the administrative record and will
be forwarded to the decision -makers for review and consideration.
Beach Cities Media Campus Project II. Response to Comments
Page II -16
scrm w.sTe �■Hwr_ur'�ei
Comment Letter No. 5
COUNTY SANITATION DISTRICTS
OF LOS ANGELES COUNTY
1955 Workman Mill Road, Whittier, CA 90601-1400
Mailing Address: P.O. Box 4998, Whittier, CA 90607-4998
Telephone: (562) 699-7411, FAX: (562) 699-5422
www.locsd.org
Mr. Ethan Edwards, AICP
Contract Planner
Planning Division
City of El Segundo
350 Main Street
EI Segundo, CA 90245
Dear Mr. Edwards:
GRACE ROBINSON HYDE
Chief Engineer and General Manager
April 15, 2019
Ref. Doc. No.: 4949636
DEIR Response to Beach Cities Media Campus Proiect
The Sanitation Districts of Los Angeles County (Districts) received a Draft Environmental Impact
Report (DEIR) for the subject project on March 4, 2019. The proposed project is located within the
jurisdictional boundaries of District No. 5. Previous comments submitted by the Districts in
correspondence dated December 26, 2017 (copy enclosed) still apply to the subject project with the
following updated information: 1
1. Wastewater Treatment Facilities, page IV.AI 21, top of page — The Joint Water Pollution Control
Plant currently processes an average flow of 261.1 million gallons per day (mgd).
2. Operation, page IV.11-25, Table IV.M.21 — Based on the information provided in the table,the 2
expected increase in average wastewater flow from the project is 70,075 gallons per day.
3. All other information concerning Districts' facilities and sewerage service contained inthe 3
document is current.
If you have any questions, please contact the undersigned at (562) 908-4288, extension 2717.
Very truly yours,
driana Raza
Customer Service Specialist
Facilities Planning Department
AR:ar
Enclosure
cc: A. Schmidt
A. Howard
DOC 5015032 D05
-i ...�1_i• nil Yi'-�
COUNTY SANITATION OISTRICTS
OF LOS ANGELES COUNTY
1955 `Plorkrncn Mill Rood, Whittier, CA 90601-1400
Mailing Aodres,,: P.0 Box 4998, Whittier, CA 90607-4998
Telep'-une: (562) 699-7411, FAX: (562) 649-5422
www ocsd.org
Mr. Ethan Edwards, AICP
Contract Planner
Planning Division
City of El Segundo
350 Main Street
EI Segundo, CA 90245
Dear Mr. Edwards:
GRACE ROBINSON HYDE
Chief Engrnt;er cnd General Manager
December 26, 2017
Ref. Doc. No,: 4380003
I'tiOP Resnonse for the Beach Cities Media Campus Project
The Sanitation Districts of Los Angeles County (Districts) received a Notice of Preparation of a
Draft Environmental Impact Report for the subject project on December 11, 2017, The proposed project
is located within the jurisdictional boundaries of District No. 5. We offer the following comments
regarding sewerage service:
The wastewater Flow originating from the proposed project will discharge to a local sewer line,
which is not maintained by the Districts, for conveyance to the Districts' Aviation Boulevard
Relief Trunk Sewer, located in Aviation Boulevard at Rosecrans Avenue. The Districts' 27 -inch
diameter trunk sewer has a capacity of 8.7 million gallons per day (mgd) and conveyed a peak
Flow of 1.6 mgd when last measured in 2011.
The wastewater generated by the proposed project will be treated at the Joint Water Pollution
Control Plant located in the City of Carson, which has a capacity of 400 mgd and currently
produces an average recycled water flow of 253.4 mgd.
The expected increase in average wastewater flow from the project, described in the notice as a
313,000 square -foot media campus, is 62,118 gallons per day, after all structures on the project
site are dernolished. For a copy of the Districts' average wastewater generation factors, go to
ivww.lacsd.org, Wastewater & Sewer Systems, click on Will Serve Program, and click on the
Table 1, Loadines for Each Class o Land terse link.
4. The Districts are empowered by the California Health and Safety Code to charge a fee for the
privilege of connecting (directly or indirectly) to the Districts' Sewerage System for increasing
the strength or quantity of wastewater discharged from connected facilities. This connection fee
is a capital facilities fee that is imposed in an amount sufficient to construct an incremental
expansion of the Sewerage System to accommodate the proposed project. Payment of a
connection fee will be required before a permit to connect to the sewer is issued. For more
information and a copy of the Connection Fee Information Sheet, go to A-ww.Iacsd.ore,
DOC W91659D05
Mr. Ethan Edwards -2- December 26, 2017
Wastewater & Sewer Systems, click on Will Serve Program, and search for the appropriate link.
In determining the impact to the Sewerage System and applicable connection fees, the Districts'
Chief Engineer and General Manager will determine the user category (e.g. Condominium, Single
Family home, etc.) that best represents the actual or anticipated use of the parcel or facilities on
the parcel. For more specific information regarding the connection fee application procedure and
fees, please contact the Connection Fee Counter at (562) 908-4288, extension 2727.
5_ In order for the Districts to conform to the requirements of the Federal Clean Air Act (CAA), the
capacities of the Districts' wastewater treatment facilities are based on the regional growth
forecast adopted by the Southern California Association of Governments (SLAG). Specific
policies included in the development of the SCAG regional growth forecast are incorporated into
clean air plans, which are prepared by the South Coast and Antelope Valley Air Quality
Management Districts in order to improve air quality in the South Coast and Mojave Desert Air
Basins as mandated by the CCA. All expansions of Districts' facilities must be sized and service
phased in a manner that will be consistent with the SCAG regional growth forecast for the
counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial. The
available capacity of die Districts' treatment facilities will, therefore, be limited to levels
associated with the approved growth identified by SCAG. As such, this letter does not constitute
a guarantee of wastewater service, but is to advise you that the Districts intend to provide this
service up to the levels that are legally permitted and to inform you of the currently existing
capacity and any proposed expansion of the Districts' facilities.
If you have any questions, please contact the undersigned at (562) 908-4288, extension 2717.
Very truly yours,
C, 1 4 �
Adriana Raza
Customer Service Specialist
Facilities Planning Department
AR:ar
cc: A. Schmidt
M. Tatalovich
DOC: 1;4391659 D05
City of EI Segundo
Comment Letter No. 5
County Sanitation Districts of Los Angeles County
Facilities Planning Department
Adriana Raza, Customer Service Specialist
1955 Workman Mill Road
Whitter, CA 90601-1400
April 15, 2019
Resnonse to Comment 5-1
June 2019
The comment provides suggested corrections to Section IV.M, Utilities and Service Systems, of the Draft
EIR, page IV.M-21. The correction is included in this Final EIR in Section III Revisions, Clarification, and
Corrections on the Draft EIR. The correction relates to the Joint Water Pollution Control Plant's average
flow of 261.1 million gallons per day. Inclusion of this correction would not change the Draft EIR's
determination that impacts related to wastewater would be less than significant.
Response to Comment 5-2
The comment provides suggested corrections to Section IV.M, Utilities and Service Systems, of the Draft
EIR, page IV.M-25, Table IV.M.2.1. The correction is included in this Final EIR in Section III Revisions,
Clarification, and Corrections on the Draft EIR. The correction relates to the average wastewater flow
from the project of 70,075 gallons per day. Inclusion of this correction would not change the Draft EI R's
determination that impacts related to wastewater would be less than significant.
Resoonse to Comment 5-3
The comment states all other information concerning the Districts facilities and sewerage service
contained in the document is current. This comment is noted for the administrative record and will be
forwarded to the decision -makers for review and consideration.
Beach Cities Media Campus Project II. Response to Comments
Page II -20
Comment Letter No. 6
From: Gena L. Gulsar agenaG@rsgengr,corrcw
Sent Tuesday, April 16, 2019 5:40 AM
To: Jenny Mallhot; Craig Fajnor
Subject: FW; EIR for 2201 Rosecrans Ave
FYI
Gena Gufes. AICP Contract Planner
CAy of Et 59"dc—Pianrr��iry III[low] S -W -IV
Bpriniea beAvoil t 314) 62d
-
a ao'7- rso Of MM
From: Edwards, Ethan caedwards6lels"undo.crg>
Sent Monday, April 15, 2019 9:55 PM
To: Gana L Gulear <genaG@csgengr.corru
Subject Fwd: EIR for 2201 Rosecrans Ave
Ethan Edwards, AICP, Planner
Clty m e Segundo - P1 Ik2uy . dolulr Salcty
PIImllina [11y19ip11 9 Fill 6.
Begin forwarded message:From: Eric A�q {} v
Date: April Hartland2019 et�6.'29:3� PMICST lm
TO! •:...nP19r-15-+ill W100nrla011'eAaft. WW'al8.wa+IknZarra
Cr. Erlh Zatldvliet <aaa311d -vo re .rhrn�
Subject: EIR for 2201 Rsecran
os vo —
HI Ethan,
I have a couple type comments as follows:
• The top paragraph an Page 0.8 uses the phrase "msximum of 25 bicycle spaces , where It appears it should say minimum of 25 bicycle spscas-
• For related projects, the statistics for 1000 N. Sepulveda were confused with 707 N. Sepulveda. and should be per the table below (also an updated number of restaurant seals for
707 N_ Sepulveda)
1
Eric Haaland
Rica [i►[L- PIaonL'1
I - ,1 'n, 7 T AM. Srr1 r•11;' .w2 V$� a T M I ti ro An[L IF 146L SrI.1;
?~h MAnharrnn Pr.ACh Here For you 24/7, use our click and fix it app
Download the mobile app now
=5.'0
2
S,
7+
A
t2
N<IIMny 73lau aSF (Mcalxni6l.`x
�il'remrey
'
I
i
3
L
olllld1n91'•mml
IAE Wd,cv UA,e ruddmu I000N S«Wl-du El
r— (ph—re.y), 1715 r- -1
"W IN- 5"'4
A
95
IW
.4'
16
n1
Iv,J.h r)nnt ?04•.
9"u•1 `JWC'Fle. pn•J[aLr v,Lt
168711 n.; Fo,t
1311
1261
15,111
1321
4211
13
37,500v h. 5urtrm4nre1 wM 26 .'
159A SUp=mteno-r
39
24
63
to
.7
157
SUP -1-
NI5a115 -Incary Sant
m=1-1 rMRMmT C hVOM. n—
LL7lt bank
73
111
�
WV
&:
'-MDJ a7 k117P 10
IAE 797 N SePuv9uu EI
and F•lefla•nl; 6YIbnU
pylal,rnl,r SU aR A'r :rP 9 [+�. nr,.
I Ab•9 Haaeurenl
.0
50
1-0b
3b
11
57
F-1, UPW
7000wrt t—k buldna
(807)aUlarerc
-601
131,
1911
t091
1161
(1251
ca•emlcnan
Eric Haaland
Rica [i►[L- PIaonL'1
I - ,1 'n, 7 T AM. Srr1 r•11;' .w2 V$� a T M I ti ro An[L IF 146L SrI.1;
?~h MAnharrnn Pr.ACh Here For you 24/7, use our click and fix it app
Download the mobile app now
City of EI Segundo
Comment Letter No. 6
City of Manhattan Beach
Eric Haaland, Associate Planner
1400 Highland Avenue
Manhattan Beach, CA 90266
April 15, 2019
Resoonse to Comment 6-1
June 2019
The comment provides suggested corrections to Section II, Project Description, of the Draft EIR, page II -8.
The correction is included in this Final EIR in Section III. Revisions, Clarification, and Corrections on the
Draft EIR. The correction relates to the number of bicycle spaces. Inclusion of this correction would not
change the Draft EIR's determination.
The comment provides suggested corrections to Section III, Environmental Setting, Table III -1, Related
Projects, pages III -11 through III -12, and Appendix H.1, Traffic Study, Table 4 Related Projects Trip
Generation Estimates, page 31 of the Draft EIR. The correction is included in this Final EIR in Section III.
Revisions, Clarification, and Corrections on the Draft EIR. The correction reflects a reduction in the square
footage and intensity of one related project, and a reduction in the number of restaurant seats for a
second related project. These corrections would not affect the traffic analysis, which would conservatively
overstate these related projects' traffic generation as a result. Inclusion of this correction would not
change the Draft EIR's determination. Below is an e-mail from Mr. Steven Keith, the traffic engineer with
Fehr & Peers which provides further response clarification to the City of Manhattan Beach comment.
Steven Keith <S.Keith @fehrandpeers.com>
Mon 4/29, 3:46 PM Jenny Mailhot; Tom Gaul <T.Gaul@fehrandpeers.com>
Hi Jenny,
Thanks for sending over the transportation comments. Below are our responses:
Caltrans --- The developer will comply with the Caltrans requests regarding the proposed
mitigation at Intersection 24:1-405 NB on/off-ramps & Rosecrans Avenue. A Permit Review
Engineering Report (PEER) and intersection operational analysis for the improvement will be
conducted in order to receive a Caltrans encroachment permit and prior to any construction.
Stormwater and heavy construction equipment will also be monitored to comply with Caltrans
standards.
• Manhattan Beach --- The related project comment does not impact any additional tables except
for the one attached. It was just a typo in regards to 1000 N. Sepulveda land uses. This does not
change any of the analysis. I have tracked the changes in the attached table (the red text reflects
the old inputs that are incorrect). I do not think any response is needed beyond a corrections
and additions citation.
Please let us know if you have any questions.
Best,
Steven
Beach Cities Media Campus Project II. Response to Comments
Page II -22
City of EI Segundo June 2019
2. ORGANIZATION AND INDIVIDUALS
Comment letters from community organizations and individuals include:
• Lozeau Drury, LLP, on behalf of Supporters Alliance For Environmental ("SAFER"), April 12, 2019
Responses to the comments in these letters are provided below, after each letter.
Beach Cities Media Campus Project II. Response to Comments
Page II -23
DRURY- T 510,936.4200
F 510.936.4205
Via Email and U.S. Mail
April 12, 2019
Ethan Edwards, Contract Planner
Planning and Building Safety Dept.
Planning Division
City of El Segundo
350 Main Street
El Segundo, CA 90245
eedwards cecelsel?undo.ora
Comment Letter No. 7
1939 Harrison Street, Ste. 150 www lozeaudrury.cern
Oakland, CA 94612 richardiadozeaudrurycorn
Gregg McClain, Planning Manager
Planning and Building Safety Dept.
Planning Division
City of El Segundo
350 Main Street
El Segundo, CA 90245
e niccl ai n (cafe 1 se2undo . orn
Re: Comment on Draft Environmental Impact Report, Beach Cities Media Center Project
aka State Clearinghouse #2017121035 and EA -1201
Dear Mr. Edwards and Mr. McClain:
I am writing on behalf of Supporters Alliance For Environmental ("SAFER") regarding the
Draft Environmental Impact Report ("DEIR') prepared for the Project known as Beach Cities Media
Center Project aka EA -1201 and State Clearinghouse #2017121035, including all actions related or
referring to the proposed development of an approximately five -story, 240,000 square foot office
building, a one-story, 66,000 square foot studio and production facilities building, and 7,000 square
foot of retail uses in two, one-story structures with parking provided in a seven story parking structure
with above grade and below grade parking containing 980 parking spaces, one level below grade
parking in the office building containing 120 parking spaces, in addition to a limited amount of
surface parking located at 2021 Rosecrans Avenue on Assessor Parcel Number (APN) 4138-015-064.
After reviewing the DEIR, we conclude that the DEIR fails as an informational document and
fails to impose all feasible mitigation measures to reduce the Project's impacts. SAFER request that
the Planning Division address these shortcomings in a revised draft environmental impact report
("RDEIR") and recirculate the RDEIR prior to considering approvals for the Project. We reserve the
right to supplement these comments during review of the Final EIR for the Project and at public
hearings concerning the Project. Galante Vineyards v. Monterey Peninsula Water Management Dist.,
60 Cal. App. 4th 1109, 1121 (1997).
Sincerely,
Richard Drury
1
2
City of EI Segundo
Comment Letter No. 7
Lozeau Drury LLP
Richard Drury
on behalf of Supporters Alliance For Environmental ("SAFER") (sic)
1939 Harrison Street, Ste. 150
Oakland, CA 94612
April 12, 2019
Resoonse to Comment 7-1
June 2019
The comment states the letter is written on behalf of Supporters Alliance For Environmental ("SAFER")
(sic). The comment introduces provides a summary description of the Project. This comment is noted for
the administrative record and will be forwarded to the decision makers for review and consideration.
Resoonse to Comment 7-2
The comment suggests the Draft EIR fails as an informational document and fails to impose feasible
mitigation measure to reduce the Project's impacts, but provides no specifics. The comment suggests
that the Planning Division should address the shortcomings in a revised Draft EIR and recirculate the
revised Draft EIR priorto approval. The comment states it reserves the right to supplement the comments
during the review of the Final EIR for the Project and at the public hearings. The comment does not
identify any specific shortcomings of the Draft EIR analysis or mitigation measures, and no specific
response is therefore possible or required. Furthermore, and contrary to the allegation in this comment,
the Draft EIR complied fully with all of CEQA's requirements. The comment presents no substantial
evidence to the contrary about any specific impact area. As provided in Section 15064(f)(5),
unsubstantiated opinion or narrative does not constitute substantial evidence. Since the commenter
provides no substantial evidence regarding the alleged inadequacy of the Draft EIR, the claims contained
in the comment letter would provide no basis for changes to the Draft EIR.
The general allegations in this comment will be forwarded to the decision -makers for consideration.
Beach Cities Media Campus Project II. Response to Comments
Page II -25
City of EI Segundo June 2019
3. COMMENT LETTERS RECEIVED AFTER THE CLOSE OF THE COMMENT PERIOD
Comment letters from the State received after the close of the comment period consisted of:
• State of California, Governor's Office of Planning and Research, State Clearinghouse and Planning
Unit, April 29, 2019
• State of California, Department of Toxic Substances Control, Site Mitigation and Restoration
Program —Chatsworth Office, April 5, 2019, received by State Clearinghouse, April 29, 2019
• Lisa Kranitz, on behalf of Wallin, Kress, Reisman & Kranitz LLP, May 8, 2019
Lozeau Drury, LLP, on behalf of Supporters Alliance For Environmental ("SAFER"), May 21, 2019
Responses to the comments in these letters are provided below, after each letter.
Beach Cities Media Campus Project II. Response to Comments
Page II -26
x,.
Gavin Newsom
Governor
April 29, 2019
Comment Letter No. 8
oFIlk, f P7.1yp��C
STATE OF CALIFORNIA o �
Governor's Office of Planning and Research
s
State Clearinghouse and Planning Unit
OF CAO
Kate Gordon
Director
Ethan Edwards
El Segundo, City of
350 Main Street
El Segundo, CA 90245
Subject: Proposed Beach Cities Media Campus Project
SCH#: 2017121035
Dear Ethan Edwards:
The comment (s) on your EIR was (were) received by the State Clearinghouse after the end of the state
review period, which closed on 4/15/2019. Please check the CEQA database for these comments:
https://ceganet.opr.ca.c,ov/2017121035/2 because they provide information or raise issues that should be
addressed in your final environmental document.
The California Environmental Quality Act does not require Lead Agencies to respond to late comments.
However, we encourage you to incorporate these additional comments into your final environmental
document and to consider them prior to taking final action on the proposed project.
Please contact the State Clearinghouse at (916) 445-0613 if you have any questions concerning the
environmental review process. If you have a question regarding the above-named project, please refer to
the ten -digit State Clearinghouse number (2017121035) when contacting this office.
Sincerely,
`fes
ioan
Director, State Clearinghouse
cc: Resources Agency
1400 TENTH STREET P.O. BOK 3044 SACRAMENTO, CALIFORNIA 95512-3044
TEL 1-916-445-0613 state.clearinghouse@opr.ca.gov www.opr.ca.gov
1
v
Jared Blumenfeld
Secretary for
Environmental Protection
April 5, 2019
Department of Toxic Substances Control 1
Meredith Williams, Ph.D.
Acting Director
9211 Oakdale Avenue
Chatsworth, California 91311
Gavin Newsom
Governor
Ethan Edwards, AICP APR 2 9 2010
Contract Planner S�AT��1.�ARIN�;HQ�DSE
City of EI Segundo, Planning Division
350 Main Street
EI Segundo, California 90245
NOTICE OF.AVAILABILITY OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR
THE BEACH CITIES MEDIA CAMPUS (PROJECT)
Dear Mr. Edwards:
The Department of Toxic Substances Control (DTSC) has received the document for
the above-mentioned project.
Based on the review of the document, the DTSC comments are as follows:
1) The document needs to identify and determine whether current or historic uses at
the project site have resulted in any release of hazardous wastes/substances at the
project area.
2) The document needs to identify any known or potentially contaminated site within
the proposed project area. For all identified sites, the document needs to evaluate
whether conditions at the site pose a threat to human health or the environment.
3) The document should identify the mechanism to initiate any required investigation
and/or remediation for any site that may require remediation, and which government
agency will provide appropriate regulatory oversight.
4) If during construction of the project, soil contamination is suspected, construction in
the area should stop and appropriate health and safety procedures should be
implemented. If it is determined that contaminated soil exists, the document should
identify how any required investigation or remediation will be conducted, and which
government agency will provide appropriate regulatory oversight.
Q Printed on Recycled Paper
Mr. Ethan Edwards
April 5, 2019
Page 2
DTSC provides guidance for Preliminary Endangerment Assessment (PEA) preparation,
and cleanup oversight through the Voluntary Cleanup Program (VCP). For additional
information on the VCP, please visit DTSC's web site at www.dtsc.ca.gov. If you would
like to meet and discuss this matter further, please contact me at (818) 717-6555 or
Pete.Cooke@dtsc.ca.gov.
Sincerei
Pete Cooke
Site Mitigation and Restoration Program - Chatsworth Office
cc: Governor's Office of Planning and Research
State Clearinghouse
P.O. Box 3044
Sacramento, California 95812-3044
Dave Kereazis
Hazardous Waste Management Program, Permitting Division
CEQA Tracking
Department of Toxic Substances Control
P.O. Box 806
Sacramento, California 95812-0806
City of EI Segundo
Comment Letter No. 8
State of California
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit
Scott Morgan, Director, State Clearinghouse
140010th Street
P.O. Box 3044
Sacramento, CA 95812-3044
April 29, 2019
Resoonse to Comment 8-1
June 2019
This comment is a standard response from the State Clearinghouse of Planning and Research
acknowledging that comments on the Draft EIR were received by the State Clearinghouse after the end of
the state review period which closed on April 15, 2019. The comment states CEQA does not require Lead
Agencies to respond to late comment, however the State Clearinghouse encourages the incorporation of
the additional comments into the Final EIR. The State Clearinghouse submitted one letter from the State
of California, Department of Toxic Substance Control (see Comment Letter No. 10). The comments
contained in this letter are responded to in Responses 9-1 through 9-5.
Beach Cities Media Campus Project II. Response to Comments
Page II -30
Z01T1 I- 10
Comment Letter No. 9
_ Department of Toxic Substances Control ill
Meredith Williams, Ph.D. tf A
Jared Blumenfeld Gavin Newsom
Secretary for Acting Director Governor
Environmental Protection 9211 Oakdale Avenue �1
Chatsworth, California 91311
April 5, 2019
301'i ouofPWWn9&F4W9'_Ch
Ethan Edwards, AICP APR 2 9 2019
Contract Planner ST�����RIN�H�SE
City of EI Segundo, Planning Division
350 Main Street
EI Segundo, California 90245
NOTICE OF AVAILABILITY OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR
THE BEACH CITIES MEDIA CAMPUS (PROJECT)
Dear Mr. Edwards:
The Department of Toxic Substances Control (DTSC) has received the document for
the above-mentioned project.
Based on the review of the document, the DTSC comments are as follows: 1
1) The document needs to identify and determine whether current or historic uses at
the project site have resulted in any release of hazardous wastes/substances at the
project area.
2) The document needs to identify any known or potentially contaminated site within
the proposed project area. For all identified sites, the document needs to evaluate 2
whether conditions at the site pose a threat to human health or the environment.
3) The document should identify the mechanism to initiate any required investigation
and/or remediation for any site that may require remediation, and which government 3
agency will provide appropriate regulatory oversight.
4) If during construction of the project, soil contamination is suspected, construction in
the area should stop and appropriate health and safety procedures should be
implemented. If it is determined that contaminated soil exists, the document should 4
identify how any required investigation or remediation will be conducted, and which
government agency will provide appropriate regulatory oversight.
4 Printed on Recycled Paper
Mr. Ethan Edwards
April 5, 2019
Page 2
DTSC provides guidance for Preliminary Endangerment Assessment (PEA) preparation,
and cleanup oversight through the Voluntary Cleanup Program (VCP). For additional
information on the VCP, please visit DTSC's web site at www.dtsc.ca.gov. If you would 5
like to meet and discuss this matter further, please contact me at (818) 717-6555 or
Pete.Cooke@dtsc.ca.gov.
Sincere[
Pete Cooke
Site Mitigation and Restoration Program - Chatsworth Office
cc: Governor's Office of Planning and Research
State Clearinghouse
P.O. Box 3044
Sacramento, California 95812-3044
Dave Kereazis
Hazardous Waste Management Program, Permitting Division
CEQA Tracking
Department of Toxic Substances Control
P.O. Box 806
Sacramento, California 95812-0806
City of EI Segundo
Comment Letter No. 9
State of California
Department of Toxic Substances Control
Site Mitigation and Restoration Program —Chatsworth Office
Pete Cooke
9211 Oakdale Avenue
Chatsworth, California 91311
April 5, 2019
Received by State Clearinghouse April 29, 2019
Response to Comment 9-1
June 2019
This comment states the Department of Toxic Substances Control (DTSC) received the Draft EIR. This
comment also states the Draft EIR needs to identify and determine whether current or historic uses at the
site have resulted in any releases of hazardous wastes/substances at the Project area. The current Project
Site is a vacant lot. It has not released any hazardous wastes or substances at the Project area.
The commenter is referred to Section IV.E Hazards and Hazardous Materials, pages IV.E-2 through IV.E-3.
The Project Site appears to have been vacant through the 1960s. Air Products and Chemicals developed
and operated an air separation facility ("ASF") at the Project Site between 1969 and 2016. Part of the
operations included the installation of four USTs on the southwestern portion of the Project Site in 1970.
In February, 1990, the four USTs were abandoned. In March 1990, the abandoned USTs were replaced
with two 10,000 -gallon diesel USTs and one 1,000 -gallon skim oil UST. In May 2002, the 1,000 -gallon skim
oil UST, was abandoned. On-site operations ceased in 2015 and demolition activities at the Project Site
commenced through 2017. Part of the demolition activities included the abandoning of the two remaining
10,000 -gallon diesel USTs and removal of the on-site oil/water separator.
The commenter is referred to Section IV.E Hazards and Hazardous Materials, page IV.E-5. The USTs were
abandoned in accordance with the workplan submitted to the EI Segundo Fire Department in 2016. After
excavation activities were completed confirmation soil samples were collected. The samples were
analyzed for TPH, VOCs, and methyl tert-butyl ether ("MTBE"). The excavation was backfilled with clean
soil from the Project Site. Liquid waste extracted during the abandonment procedures was disposed off-
site as non-RCRA hazardous waste to Demenno/Kerdoon Facility in Compton, California. Construction
debris from the abandonment process was disposed off-site to WM Simi Valley Landfill in Simi Valley. All
USTs installed by Air Products and Chemicals have been removed from the Project Site.
Response to Comment 9-2
The comment states the document needs to identify any known or potentially contaminated site within
the project area and whether or not these pose a threat to human health or the environment. As stated
above, the commenter is referred the Response to Comment 9-1. The commenter is referred Section IV.E
Hazards and Hazardous Materials, page IV.E-7. According to Air Products and Chemicals, all USTs installed
by Air Products and Chemicals have been removed from the Project Site. Based on the data collected and
work performed by Air Products and Chemicals, the RWQCB issued a NFA determination for the soil on
August 31, 2017, which is included as Appendix E.2 in this Draft EIR. The Regional Water Quality Control
Board has jurisdiction over the Project Site. As indicated in the No Further Action letter from the Board
(Appendix E.2 in this Draft EIR), the site has been cleaned up and abated so as to meet the requirements
for a soil closure letter for commercial use of the site. As further noted in the letter, a covenant and
environmental restriction has been placed on the property limiting the use to commercial applications.
Beach Cities Media Campus Project II. Response to Comments
Page II -33
City of EI Segundo
Response to Comment 9-3
June 2019
The comment states the document should identify the mechanism to initiate any required investigation
and/or remediation for any site that may require remediation, and which the government agency will
provide appropriate regulatory oversight. According to Air Products and Chemicals, all USTs installed by
Air Products and Chemicals have been removed from the Project Site. Based on the data collected and
work performed by Air Products and Chemicals, the RWQCB issued a NFA determination for the soil on
August 31, 2017, which is included as Appendix E.2 in this Draft EIR. As stated in Response to Comment
9-2, the Regional Water Quality Control Board has jurisdiction over the Project Site. As indicated in the
No Further Action letter from the Board, the site has been cleaned up and abated so as to meet the
requirements for a soil closure letter for commercial use of the site. As further noted in the letter, a
covenant and environmental restriction has been placed on the property limiting the use to commercial
applications.
Response to Comment 9-4
The comment states that if during construction of the project, soil contamination is suspected,
construction in the area should stop and appropriate health and safety procedures should be
implemented. The comment also states If contaminated soil exists, the document should identify how
any required investigation or remediation will be conducted and which the government agency will
provide appropriate regulatory oversight. The commenter is referred to Response to Comment 9-3.
Response to Comment 9-5
The comment states DTSC provides guidance for Preliminary Endangerment Assessment (PEA)
preparation, and cleanup oversight through Voluntary Cleanup Program (VCP). The comment also
provides contact information for VCP. The commenter is referred to Response to Comment 9-3. This
comment is noted for the administrative record and will be forwarded to the decision makers for review
and consideration.
Beach Cities Media Campus Project II. Response to Comments
Page II -34
Comment Letter No. 10
Ethan,
On behalf of the applicant, Rosecrans -Sepulveda 4, LLC, we offer the following minor comments on the
DEIR. 1
The analysis of Noise references Mitigation Measures H-1— H-7, but these measures do not exist. (See
pp. IV.H-15 , IV.H-29.) As the EIR concluded that the impact was less than significant without mitigation, 2
we assume that this language may have been left over from a previous document. The Final EIR should
delete these references.
The analysis on cumulative population growth indicates that between 2015 and 2040 the number of
households in the (South Bay) region will increase by 1,468,000. The referenced document does not 3
support this number and the number should be revised to reflect the correct calculation.
In the analysis on Water, there are a number of places where the document states, "Error! Reference
source not found." In looking at the Water Supply Assessment which is included as Appendix J.1, it is
clear that none of the information is missing. Instead, the text should be revised to reflect the
appropriate Table as follows: 4
❑ Page IV.M-2 —reference Figure IV.M.1-1
❑ Page IV.M-4— reference Figure Table IV.M.1-2
❑ Page IV.M-5 (first occurrence) — reference Table IV.M.1-4
❑ Page IV.M-5 (second occurrence) — reference Table IV.M.1-5
❑ Page IV.M-6 —reference Table IV.M.1-7
None of these changes lead to any new significant impacts and do not create a need for recirculation 5
Thank you,
Lisa Kranitz
Wallin, Kress, Reisman & Kranitz, LLP
11355 W. Olympic Boulevard, Suite 300
Los Angeles, California 90064
Phone: 310/450-9582, ext. 215
Cell: 310/962-2049
E-mail: isa�7a.wkrklaw.com
DISCLAIMER - This email and any files, documents or previous emails transmitted with it are
confidential and contain privileged information. You must not present this message to another
party without permission from the sender. If you are not the intended recipient, or a person
responsible for delivering it to the intended recipient, you must not copy, distribute or use this
email or the information contained in it for any purpose other than to notify us. If you have
received this message in error, please notify the sender immediately or call 310-782-2525, and
delete this email from your system. We do not guarantee that this material is free from viruses or
any other defects although due care has been taken to minimize the risk. Any views expressed in
this message are those of the individual sender, except where the views are specifically stated to
be that of Mar Ventures, Inc. [v. I]
City of EI Segundo
Comment Letter No. 10
Lisa Kranitz
Wallin, Kress, Reisman & Kranitz LLP
11355 Olympic Boulevard, Suite 300
Los Angeles, California 90064
March 25, 2019
Response to Comment 10-1
June 2019
This comment states on behalf of the applicant, Rosecrans -Sepulveda 4, LLC, Wallin, Kress, Reisman &
Kranitz LLP has minor comments on the Draft EIR. This comment is noted for the administrative record.
Response to Comment 10-2
This comment states that the analysis of Noise refences Mitigation Measures H-1 through H-7, but these
measures do not exist. The commenter states as the EIR concluded that the impact was less than
significant without mitigation, thus the commenter assumes that this language may have been left over
from a previous document. The commenter states the Final EIR should delete these references. The
correction is included in this Final EIR in Section III. Revisions, Clarification, and Corrections on the Draft
EIR. The correction deletes the referenced mitigation measures. Inclusion of this correction would not
change the Draft EIR's determination.
Response to Comment 10-3
The comment states the cumulative population growth indicates between 2015 and 2040 the number of
households in the South Bay region will increase by 1,468,000, however the referenced document does
not support this number. The correction is included in this Final EIR in Section III. Revisions, Clarification,
and Corrections on the Draft EIR. The correction corrects the number of households in the South Bay
region. Inclusion of this correction would not change the Draft EIR's determination.
Response to Comment 10-4
The comment states in the analysis on Water there are a number of places where the document states
"Error Refence source not found." The commenter states none of the information is missing, the but the
text should be revised to source the correct figures and tables. The correction is included in this Final EIR
in Section III. Revisions, Clarification, and Corrections on the Draft EIR. The correction corrects both the
figure and the table sources. Inclusion of this correction would not change the Draft EIR's determination.
Response to Comment 10-5
The comment states none of these changes lead to any new significant impacts and do not create a need
for recirculation. This comment is noted for the administrative record.
Beach Cities Media Campus Project
Page II -36
II. Response to Comments
DRURY_: T 510.836.4200
BY E-MAIL AND OVERNIGHT MAIL
May 21, 2019
Comment Letter No. 11
1939 Harrison Street, Ste 150 INV, ., u�� ,•
Oakland, CA 94612 rig'
Chairperson Ryan Baldino and Honorable Members of the
City of EI Segundo Planning Commission
Planning and Building Safety Department, Planning Division
350 Main Street
EI Segundo, California 90245
rbaldinoeelseaundoccb.orq; bnewman(5elseaundoccb.orq;
ihoeschlerO,elseaundoccb.ora; mkeldoro(cDelsequndoccb.orq;
cWngate@elsegundoccb.org
Ethan Edwards, AICP, Contract Planner
City of EI Segundo
Planning and Building Safety
350 Main Street
EI Segundo, California 90245
eedwards a().elseaundo.orq
Department, Planning Division
RE: Final EIR for Proposed Beach Cities Media Campus Project
SCN 2017121035
Chairperson Baldino and Members of the Planning Commission:
I am writing on behalf of Supporters Alliance For Environmental Responsibility
("SAFER") regarding the Final Environmental Impact Report ("FEIR") prepared for the
Project known as Beach Cities Media Center Project aka EA -1201 and State
Clearinghouse #2017121035, including all actions related or referring to the proposed
development of an approximately five -story, 240,000 square foot office building, a one-
story, 66,000 square foot studio and production facilities building, and 7,000 square foot
of retail uses in two, one-story structures with parking provided in a seven story parking
structure with above grade and below grade parking containing 980 parking spaces, one
level below grade parking in the office building containing 120 parking spaces, in addition
to a limited amount of surface parking located at 2021 Rosecrans Avenue on Assessor
Parcel Number (APN) 4138-015-064.
1
After reviewing the Project and the FEIR, it is evident that the FEIR contains
numerous errors and omissions that preclude accurate analysis of the Project. As a 2
result of these inadequacies, the FEIR fails as an informational document and fails to
impose all feasible mitigation measures and alternatives to reduce the Project's impacts.
Beach Cities Media Campus
May 21, 2019
Page 2 of 8
Commenters request that the City of EI Segundo ("City") address these shortcomings in a
revised draft environmental impact report ("RDEIR") and recirculate the document prior to
considering approvals for the Project.
1. LEGAL STANDARDS
CEQA requires that an agency analyze the potential environmental impacts of its
proposed actions in an environmental impact report ("EIR") (except in certain limited
circumstances). See, e.g., Pub. Res. Code § 21100. The EIR is the very heart of CEQA.
Dunn -Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652. "The 'foremost principle' in
interpreting CEQA is that the Legislature intended the act to be read so as to afford the
fullest possible protection to the environment within the reasonable scope of the statutory
language." Comm. for a BetterEnv't v. Calif. Resources Agency (2002) 103 Cal. App. 4th
98,109.
CEQA has two primary purposes. First, CEQA is designed to inform decision
makers and the public about the potential, significant environmental effects of a project.
14 Cal. Code Regs. ("CEQA Guidelines") § 15002(a)(1). "Its purpose is to inform the
public and its responsible officials of the environmental consequences of their decisions
before they are made. Thus, the EIR 'protects not only the environment but also informed
self-government."' Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553,
564. The EIR has been described as "an environmental 'alarm bell' whose purpose it is to
alert the public and its responsible officials to environmental changes before they have 2 cont.
reached ecological points of no return." Berkeley Keep Jets Over the Bay v. Bd. of Port
Comm'rs. (2001) 91 Cal. App. 4th 1344, 1354 ("Berkeley Jets"); County oflnyo v. Yorty
(1973) 32 Cal.App.3d 795, 810.
Second, CEQA requires public agencies to avoid or reduce environmental damage
when "feasible" by requiring "environmentally superior" alternatives and all feasible
mitigation measures. CEQA Guidelines § 15002(a)(2) and (3); see also Berkeley Jets, 91
Cal. App. 4th 1344, 1354; Citizens of Goleta Valley v Board of Supervisors (1990) 52
Cal.3d 553, 564. The EIR serves to provide agencies and the public with information
about the environmental impacts of a proposed project and to "identify ways that
environmental damage can be avoided or significantly reduced." CEQA Guidelines
§15002(a)(2). If the project will have a significant effect on the environment, the agency
may approve the project only if it finds that it has "eliminated or substantially lessened all
significant effects on the environment where feasible" and that any unavoidable significant
effects on the environment are "acceptable due to overriding concerns." Pub.Res.Code
("PRC") § 21081; CEQA Guidelines § 15092(b)(2)(A) & (B).
The lead agency must evaluate comment on the draft EIR and prepare written
responses in the final EIR. (PRC §21091(d)) The FEIR must include a "detailed" written
response to all "significant environmental issues" raised by commenters. As the court
stated in City of Long Beach v. LA USD (2009) 176 Cal.App.4th 889, 904:
The requirement of a detailed written response to comments helps to
ensure that the lead agency will fully consider the environmental consequences of
Beach Cities Media Campus
May 21, 2019
Page 3 of 8
a decision before it is made, that the decision is well informed and open to public
scrutiny, and that public participation in the environmental review process is
meaningful.
The FEIR's responses to comments must be detailed and must provide a
reasoned, good faith analysis. (14 CCR §15088(c )) Failure to provide a substantive
response to comment render the EIR legally inadequate. (Rural Land Owners Assoc. v.
City Council (1983) 143 Cal.App.3d 1013, 1020).
The responses to comments on a draft EIR must state reasons for rejecting
suggested mitigation measures and comments on significant environmental issues. 2 cont.
"Conclusory statements unsupported by factual information" are not an adequate
response. (14 CCR §15088(b, c); Cleary v. County of Stanislaus (1981) 118 Cal.App.3rd
348) The need for substantive, detailed response is particularly appropriate when
comments have been raised by experts or other agencies. (Berkeley Keep Jets v. Bd. of
Port Commis (2001) 91 Cal.App.4th 1344, 1367; People v. Kern (1976) 72 Cal.app.3d
761) A reasoned analysis of the issue and references to supporting evidence are
required for substantive comments raised. (Calif. Oak Found. v. Santa Clarita (2005) 133
Cal.App.4th 1219)
The FEIR abjectly fails to meet these legal standards, as it is riddled with
conclusory statements lacking any factual support or analysis.
II. THE CITY HAS PROVIDED INADEQUATE TIME TO REVIEW THE FEIR.
On January 10, 2018, this firm requested written notice of all CEQA documents
related to the Project, pursuant to CEQA section 21092.2. Despite this request, we did
not receive the complete FEIR until May 20, 2019 — only three days prior to the Planning
Commission hearing. We received an incomplete copy of the FEIR on Friday, May 17,
2019, but that document did not include the public comments or responses to comments
which are the heart of the FEIR.
CEQA requires the lead agency to provide the FEIR to all public entities that
commented on the Draft EIR at least 10 days before certifying the EIR. PRC §21092.5.
Many public agencies, as well as SAFER, commented on the DEIR, including CalTrans,
South Coast Air Quality Management District ("SCAQMD"), Department of Toxic 3
Substances Control ("DTSC"), and others. The City was required to provide these entities
with the FEIR at least 10 days prior to the May 23, 2019 Planning Commission hearing —
May 13, 2019. When the City provided the FEIR to the public agencies, it became a
public record. At that time, since this firm requested all CEQA documents pursuant to
CEQA section 21092.2, we should have been provided with the FEIR. However, we did
not receive the document until May 20, 2019 — one week later. Thus, SAFER had only
three days to review the FEIR rather than the required ten days.
We request that the City continue the Planning Commission hearing by at least ten
days to allow the required review period for the FEIR.
Beach Cities Media Campus
May 21, 2019
Page 4 of 8
III. THE FEIR FAILS TO ADEQUATELY RESPOND TO COMMENTS ON THE
DEIR.
A. HAZARDOUS MATERIALS
The SCAQMD and DTSC raised serious concerns about toxic chemical soil
contamination at the Project site. Yet, these concerns are largely ignored in the FEIR.
The DEIR largely ignores soil contamination and the SCAQMD Rules governing soil
contamination, Rules 1166 and 1466. (DEIR, IV.A.10-12).
Due to the historical Air Products and Chemicals operations, Southern California
Edison ("SCE") conducted a limited subsurface investigation in preparation for demolition
and the sale of the Project Site. According to the Phase I ESA, several subsurface
investigations were conducted to assess potential contaminants of concern in the soil and
soil vapor at the Project Site. The majority of these site investigation activities were
conducted between March 2015 and September 2016. Based on these investigations, soil
was found to be impacted with total petroleum hydrocarbons ("TPH"), lead, and PCBs. In
addition, volatile organic compounds ("VOCs") were detected in the shallow soil on the
Project Site. An investigation report and remedial action workplan was prepared on behalf
of Air Products and Chemicals and submitted to the Los Angeles Area Regional Water
Quality Control Board ("RWQCB"). The RWQCB conditionally approved the workplan on
June 29, 2017 with additional excavation areas and sampling requirements. In June 2017, 4
504 cubic yards of impacted soil was reportedly excavated and disposed off-site as non-
hazardous waste at Azusa Land Reclamation, Azusa, California as documented in the
Remedial Completion Report. Five sets of soil gas probes were then installed in July
2017. Confirmation soil and soil vapor samples were collected after excavation activities
were completed per the RWQCB requirements. These results were documented in the
Remedial Completion Report and in the Additional Soil and Soil Vapor Sampling Report.
The analytical results of the soil samples were non-detected for TPH, lead, and PCBs;
and VOCs were detected in soil vapor. Based on the data collected and work performed
by Air Products and Chemicals, the RWQCB issued a No Further Action ("NFA"). The
NFA referenced a recorded Covenant and Environmental Restriction that restricted the
future use of the Project Site to commercial and/or industrial and specifically did not
restrict the Project Site use for commercial purposes. DEIR: (IV.E-3). Despite the known
presence of toxic chemicals in the soil at the Project site, the DEIR and FEIR largely gloss
over this issue.
SCAQMD submitted written comments on the DEIR, pointing out that the EIR fails
entirely to mention compliance with SCAQMD Rule 1166 (Volatile Organic Compounds
from soil) and SCAQMD Rule 1466 (Particulate Matter from soil with Toxic Air
Contaminants). These rules are the primary way that SCAMQD protects construction
workers and future users of the Project from exposure to toxic chemicals.
In response, the FEIR adds a new section on Rules 1166 and 1466. (FEIR, II -12).
However, the City failed to recirculate the FEIR. Recirculation is require when new
mitigation measures are added to a project so the public can assess the adequacy of the
Beach Cities Media Campus
May 21, 2019
Page 5 of 8
proposed mitigation measures. Gentry v. Murrieta, 36 Cal.App.4th 1359, 1392, 1411,
1417. As a leading treatise explains, "in Perley v. Board of Supervisors (1982) 137
Cal.App.3d 424, the court held that the public has a right to review a project described in
a negative declaration in its final form and suggested that a negative declaration must be
recirculated if mitigation measures are added." Kostka & Zishcke, Guide to CEQA at
§7.19.
DTSC filed written comments raising concerns about site contamination. DTSC 4 cont.
recommended a preliminary endangerment assessment and voluntary clean-up plan, but
FEIR rejects both mitigation measures without analysis. (FEIR, II -35). CEQA requires
implementation of all feasible mitigation measures. These measures are clearly feasible,
and the FEIR provides no reason that the measures would be infeasible.
A Recirculated DEIR is required to analyze soil contamination and propose all
feasible mitigation measures to safeguard construction workers and future uses of the
Project site.
B. HEALTH RISK ASSESSMENT
Neither the Draft nor Final EIR contain any health risk assessment (HRA). The
DEIR states that no HRA is required because construction will "only" take place over 18
months. (DEIR IV.A.21.)
California Office of Environmental Health Hazard Assessment ("OEHHA")
guidance makes clear that all short-term projects lasting at least two months be evaluated
for cancer risks to nearby sensitive receptors. OEHHA also recommends a health risk
assessment of a project's operational emissions for projects that will be in place for more 5
than 6 months. (Id.) Projects lasting more than 6 months should be evaluated for the
duration of the project, and an exposure duration of 30 years be used to estimate
individual cancer risk for the maximally exposed individual resident. (Id.) The Project
would last at least 30 years and certainly much longer than six months. Therefore an
HRA is required.
Health risks can often be mitigated by requiring low -emission construction
equipment, such as CARB Tier 4 equipment, limiting idling times, limiting opacity, and
other measures. A RDEIR should be prepared to analyze HRA and to proposed feasible
mitigation measures.
C. GREENHOUSE GAS.
The EIR admits that the Project will have significant greenhouse gas ("GHG") 6
impacts. (FEIR 1-17, 18). The DEIR states, "Proposed Project's unmitigated emissions
are 6,007.71 metric tons of CO2 equivalents per year resulting in 5.82 MTCO2e/SP/year."
(DEIR IV. D-31). This is far above the SCAQMD significance threshold for GHGs of 3,000
MT/year.
Beach Cities Media Campus
May 21, 2019
Page 6 of 8
Despite this admission, the EIR fails to propose all feasible mitigation measures to
reduce GHGs. The only mitigation measures proposed are: (1) sidewalks, (2) energy
Star applicances, (3) LED lighting, and (4) low -flow fixtures. Despite having hundreds of
parking spaces, the EIR proposes only 1 electric vehicle charger. (DEIR IV.D-35). The
EIR fails to propose clearly feasible GHG mitigation measures such as roof -top solar
panels, large numbers of electric vehicle charging stations, exceedance of Title 24 energy
requirements, LEED certification, and many other measures. 6 cont.
The California Attorney General has published a list of feasible GHG mitigation
measures. (Exhibit A). These measures are presumptively feasible. A Revised DEIR
should be prepared to analyze these feasible mitigation measures.
D. TRAFFIC.
CalTrans submitted a comment concerning the Project's significant traffic impacts.
In response the Final EIR proposes a Traffic Demand Management (TDM) plan, but
provides no detail for the TDM plan. (FEIR III -2).
Feasible mitigation measures for significant environmental effects must be set forth
in an EIR for consideration by the lead agency's decision makers and the public before
certification of the EIR and approval of a project. The formulation of mitigation measures
generally cannot be deferred until after certification of the EIR and approval of a project.
Guidelines, section 15126.4(a)(1)(B) states: "Formulation of mitigation measures should
not be deferred until some future time. However, measures may specify performance
standards which would mitigate the significant effect of the project and which may be
accomplished in more than one specified way." "A study conducted after approval of a
project will inevitably have a diminished influence on decisionmaking. Even if the study is
subject to administrative approval, it is analogous to the sort of post hoc rationalization of 7
agency actions that has been repeatedly condemned in decisions construing CEQA."
(Sandstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 307.) "[R]eliance on
tentative plans for future mitigation after completion of the CEQA process significantly
undermines CEQA's goals of full disclosure and informed decisionmaking; and[,]
consequently, these mitigation plans have been overturned on judicial review as
constituting improper deferral of environmental assessment." (Communities for a Better
Environment v. City of Richmond (2010) 184 Cal.App.4th 70, 92 (Communities).)
The FEIR's TDM plan is deferred mitigation prohibited by CEQA. A Revised DEIR
is required to identify the particular measures that will be implemented as part of the TDM
to reduce the Project's traffic impact, and to calculate the amount that those measures will
reduce traffic impacts of the Project.
E. INDOOR AIR QUALITY.
The EIR fails entirely to analyze impacts related to indoor air quality. Such impacts
may be related to soil -vapor intrusion that may result from toxic soil contamination. 8
Indoor air quality may also be affected by formaldehyde emissions from composite wood
products.
Beach Cities Media Campus
May 21, 2019
Page 7 of 8
Formaldehyde is a known human carcinogen. Many composite wood products
typically used in residential and office building construction contain formaldehyde -based
glues which off -gas formaldehyde over a very long time period. The primary source of
formaldehyde indoors is composite wood products manufactured with urea -formaldehyde
resins, such as plywood, medium density fiberboard, and particle board. These materials
are commonly used in residential and office building construction for flooring, cabinetry,
baseboards, window shades, interior doors, and window and door trims. Given the
prominence of materials with formaldehyde -based resins that are likely to be used in
constructing the Project, there is a significant likelihood that the Project's emissions of
formaldehyde to air will result in very significant cancer risks to future workers in the
buildings. Even if the materials used within the buildings comply with the Airborne Toxic
Control Measures (ATCM) of the California Air Resources Board (GARB), significant
emissions of formaldehyde may still occur.
The Project's buildings may have significant impacts on air quality and health risks
by emitting cancer-causing levels of formaldehyde into the air that may expose workers to
cancer risks in excess of SCAQMD's threshold of significance. A 2018 study by Chan et
al. (attached as Exhibit B) measured formaldehyde levels in new structures constructed
after the 2009 CARB rules went into effect. Even though new buildings conforming to
CARB's ATCM had a 30% lower median indoor formaldehyde concentration and cancer
risk than buildings built prior to the enactment of the ATCM, the levels of formaldehyde
may still pose cancer risks greater than 100 in a million, well above the 10 in one million 8 cont.
significance threshold established by the SCAQMD.
Based on published studies, and assuming all the Project's building materials will
be compliant with the California Air Resources Board's formaldehyde airborne toxics
control measure, future employees using the Project may be exposed to a cancer risk
from formaldehyde greater than the SCAQMD's CEQA significance threshold for airborne
cancer risk of 10 per million.
The City has a duty to investigate issues relating to a project's potential
environmental impacts. (See County Sanitation Dist. No. 2 v. County of Kern (2005) 127
Cal.App.4th 1544, 1597-98. ("[U]nder CEQA, the lead agency bears a burden to
investigate potential environmental impacts."].) "If the local agency has failed to study an
area of possible environmental impact, a fair argument may be based on the limited facts
in the record. Deficiencies in the record may actually enlarge the scope of fair argument
by lending a logical plausibility to a wider range of inferences." (Sundstrom v. County of
Mendocino (1988) 202 Cal.App.3d 296, 311.) Given the lack of study conducted by the
City on the health risks posed by emissions of formaldehyde, a fair argument exists that
such emissions from the Project may pose significant health risks. As a result, the City
must prepare an EIR which calculates the health risks that the formaldehyde emissions
may have on future workers and identifies appropriate mitigation measures.
Beach Cities Media Campus
May 21, 2019
Page 8 of 8
IV. CONCLUSION
For the foregoing reasons, the EIR fails to meet the requirements of CEQA. We
urge the City to require preparation of a Revised Draft EIR that addresses the deficiencies
identified in this and other comment letters. Thank you for considering our comments and 9
please include this letter in the administrative record for this matter.
Sincerely,
Richard Drury
ATTACHMENT A
Addressing Climate Change at the Project Level
California Attorney General's Office
fir•="
Under the California Environmental Quality Act (CEQA), local agencies have a very
important role to play in California's fight against global warming — one of the most
serious environmental effects facing the State today. Local agencies can lead by
example in undertaking their own projects, insuring that sustainability is considered at
the earliest stages. Moreover, they can help shape private development. Where a
project as proposed will have significant global warming related effects, local agencies
can require feasible changes or alternatives, and impose enforceable, verifiable,
feasible mitigation to substantially lessen those effects. By the sum of their actions and
decisions, local agencies will help to move the State away from "business as usual" and
toward a low -carbon future.
Included in this document are various measures that may reduce the global warming
related impacts at the individual project level. (For more information on actions that
local governments can take at the program and general plan level, please visit the
Attorney General's webpage, "CEQA, Global Warming, and General Plans" at
htto://aa. ca.aov/alobalwarmincVicecia/cieneralDlans. r)hr). )
As appropriate, the measures can be included as design features of a project, required
as changes to the project, or imposed as mitigation (whether undertaken directly by the
project proponent or funded by mitigation fees). The measures set forth in this package
are examples; the list is not intended to be exhaustive. Moreover, the measures cited
may not be appropriate for every project. The decision of whether to approve a project
— as proposed or with required changes or mitigation — is for the local agency,
exercising its informed judgment in compliance with the law and balancing a variety of
public objectives.
Mitiaation Measures by Cateaory
Energy Efficiency
Incorporate green The California Department of Housing and Community Development's Green
building practices and Building & Sustainability Resources handbook provides extensive links to
design elements. green building resources. The handbook is available at
htto://www.hcd.ca.govlhpd/green build.pd€.
The American Institute of Architects (AIA) has compiled fifty readily available
strategies for reducing fossil fuel use in buildings by fifty percent. AIA "50 to
50" plan is presented in both guidebook and wiki format at
htt p: //wi ki . a i a .o rafW i k i %20 Pa ges1H o me .a s px.
AGO, Project Level Mitigation Measures Page 1
[Rev. 1/6/2010]
Available at http:llaq.ca.pov/globalwarming/pdf/GW mitigation measures.odf,
Meet recognized green For example, an ENERGY STAR -qualified building uses less energy,
building and energy is less expensive to operate, and causes fewer greenhouse gas
efficiency benchmarks. emissions than comparable, conventional buildings.
htto Wwww. eneraysta r. oovlindex. cfm?c=business. bus index.
California has over 1600 ENERGY STAR -qualified school, commercial
and industrial buildings. View U.S. EPA's list of Energy Star non-
residential buildings at
httr3:l/www.enerovstar.covhndex.cfm?fuseaction=labeled buildinas.loc
ator. Los Angeles and San Francisco top the list of U.S. cities with the
most ENERGY STAR non-residential buildings.
htto://www.enerovstar-aov/ialbusiness/downloads/2008 Top 25 cities
chart.pdf.
Qualified ENERGY STAR homes must surpass the state's Title 24
energy efficiency building code by at least 15%. Los Angeles,
Sacramento, San Diego, and San Francisco -Oakland are among the
top 20 markets for ENERGY STAR homes nationwide.
htto://www.enerovstar.aov/ia/new homes/mil homes/ton 20 markets.
html. Builders of ENERGY STAR homes can be more competitive in a
tight market by providing a higher quality, more desirable product. See
htto:llwww. eneraystar.00v/ialgartners/manuf res/Horton. odf.
There are a variety of private and non-profit green building certification
programs in use in the U.S. See U.S. EPA's Green Building / Frequently
Asked Questions website, htto://www.er>a.covlareenbuildinci/Dubs/fags.htm.
Public -Private Partnership for Advancing Housing Technology maintains a list
of national and state Green Building Certification Programs for housing. See
htto:/Iwww.pathnet.ora/sp.aso?id=20978. These include the national
Leadership in Energy and Environmental Design (LEED) program, and, at the
state level, Build it Green's GreenPoint Rated system and the California Green
Builder program.
Other organizations may provide other relevant benchmarks.
Install energy efficient Information about ENERGY STAR -certified products in over 60 categories is
lighting (e.g., light
available at htto//www.energvstar.gav/index.cfm?fuseaction=find a product,
emitting diodes
(LEDs)), heating and
The California Energy Commission maintains a database of all appliances
cooling systems,
meeting either federal efficiency standards or, where there are no federal
appliances, equipment,
efficiency standards, California's appliance efficiency standards. See
and control systems.
htto://www.aoDliences.enerav,ca.aov/.
The Electronic Product Environmental Assessment Tool (EPEAT) ranks
computer products based on a set of environmental criteria, including energy
efficiency. See htto://www,er)eat.net/AboutEPEAT.asr)x.
The nonprofit American Council for an Energy Efficient Economy maintains an
Online Guide to Energy Efficient Commercial Equipment, available at
htto://www.aceee.orcVogeece/ohl index.htm.
Utilities offer many incentives for efficient appliances, lighting, heating and
cooling To search for available residential and commercial incentives, visit
Flex Your Power's website at htto:llwww fvpower.orq/.
AGO, Project Level Mitigation Measures Page 2
[Rev. 1/6/20101
Available at htto://aa.ca.aov/aiobalwarmina/Ddf/GW mitigation measures-odF
Use passive solar
See U.S. Department of Energy, Passive Solar Design (website)
design, e.g., orient
htto:!/www.enerovsavers.cov/vcur home/desionina remodel inohndex. cfm/mvt.
buildings and
ooic=10250.
incorporate landscaping
to maximize passive
See also California Energy Commission, Consumer Energy Center, Passive
solar heating during
Solar Design (website)
cool seasons, minimize
htto:Ilwww.consumereneravicenter.oro/home/construction/soiardesian/index.ht,
solar heat gain during
ml.
hot seasons, and
enhance natural
Lawrence Berkeley National Laboratories' Building Technologies Department
ventilation. Design
is working to develop innovative building construction and design techniques.
buildings to take
Information and publications on energy efficient buildings, including lighting,
advantage of sunlight
windows, and daylighting strategies, are available at the Department's website
at htto://btech.lbl.Qov.
Install light colored A white or light colored roof can reduce surface temperatures by up to 100
"cool" roofs and cool degrees Fahrenheit, which also reduces the heat transferred into the building
pavements. below. This can reduce the building's cooling costs, save energy and reduce
associated greenhouse gas emissions, and extend the life of the roof. Cool
roofs can also reduce the temperature of surrounding areas, which can
improve local air quality. See California Energy Commission, Consumer
Energy Center, Cool Roofs (webpage) at
httD://www.consumerenerQvoenter.oralcoolroof/.
See also Lawrence Berkeley National Laboratories, Heat Island Group
(webpage) at htto./leetd.lbl.aov/Heatlsland/.
Install efficient lighting, LED lighting is substantially more energy efficient than conventional lighting
(including LEDs) for and can save money. See
traffic, street and other htto://www.enerov ca.gov/efficiency/oartnershio/case studies/TechAsstCity.rx#f,
outdoor lighting. (noting that installing LED traffic signals saved the City of Westlake about
$34,000 per year).
As of 2005, only about a quarter of California's cities and counties were using
100% LEDs in traffic signals. See California Energy Commission (CEC), Light
Emitting Diode Traffic Signal Survey (2005) at p. 15, available at
htto:l/www.eneray.ca,aov/2005oublications/CEC 400 2005 003/CEC 400 2005
003. PDF.
The California Energy Commission's Energy Partnership Program can help
local governments take advantage of energy saving technology, including, but
not limited to, LED traffic signals. See
hftp://www.enerov.ca.,-Qovlefficiencv/oartnership/.
Reduce unnecessary See California Energy Commission, Reduction of Outdoor Lighting (webpage)
outdoor lighting. at httr)'l/www.enercty.ca.aov/efficiencv/liclhtino/outdoor reduction.html.
AGO, Project Level Mitigation Measures Page 3
[Rev. 1/6/2010]
Available at htto://ao.ca.aov/alobalwarmino/odflGW mitigation measures.odf
Use automatic covers, During the summer, a traditional backyard California pool can use enough
efficient pumps and energy to power an entire home for three months. Efficiency measures can
motors, and solar substantially reduce this waste of energy and money. See California Energy
heating for pools and Commission, Consumer Energy Center, Pools and Spas (webpage) at
spas. htt❑:llwww.consumereneraviceriter.ora/home/outside/000ls_snas.html,.
See also Sacramento Municipal Utilities District, Pool and Spa Efficiency
Program (webpage) at htto://www.smud.ora/en/residential/savina-,
ene rav/Paaes/000lspa. asox.
Provide education on Many cities and counties provide energy efficiency education See, for
energy efficiency to example, the City of Stockton's Energy Efficiency website at
residents, customers httr):l/www.stocktonaav.comleneraysavino/index.cfm. See also "Green County
and/or tenants. San Bernardino," htto://www.areencountvsb.com at pp. 4-6.
Businesses and development projects may also provide education. For
example, a homeowners' association (HOA) could provide information to
residents on energy-efficient mortgages and energy saving measures. See
The Villas of Calvera Hills, Easy Energy Saving Tips to Help Save Electricity at
htto://www.theviilashoa.orofareenlenergvl. An HOA might also consider
providing energy audits to its residents on a regular basis.
Renewable Energy and Energy Storage
Meet "reach" goals for A "zero net energy" building combines building energy efficiency and
building energy renewable energy generation so that, on an annual basis, any
efficiency and purchases of electricity or natural gas are offset by clean, renewable
renewable energy use. energy generation, either on-site or nearby. Both the California Energy
Commission (CEC) and the California Public Utilities Commission
(CPUC) have stated that residential buildings should be zero net
energy by 2020, and commercial buildings by 2030. See CEC, 2009
Integrated Energy Policy Report (Dec. 2009) at p. 226, available at
htto:l/www. eneray. ca. aov/2009oubl ications/CEC-100-2009-003/CEC-
900-2009-003-CMF.PDF; CPUC, Long Term Energy Efficiency
Strategic Plan (Sept. 2008), available at
htto:llwww. couc_ca.LIoviPUCIenefavlEnerQv+Efficiencvleesp/.
Install solar, wind, and The California Public Utilities Commission (CPUC) approved the California
geothermal power Solar Initiative on January 12, 2006. The initiative creates a $3.3 billion, ten -
systems and solar hot year program to install solar panels on one million roofs in the State. Visit the
water heaters. one-stop GoSolar website at htto://www.aflsolarcalifornia.oral. As mitigation, a
developer could, for example, agree to participate in the New Solar Homes
program. See httr)://www.aosolarcalifornia.orcilbuilderslindex.htmi.
The CPUC is in the process of establishing a program to provide solar
water heating incentives under the California Solar Initiative. For more
information, visit the CPUC's website at
http:llwww. couc.ca.ciovli)uc/enerc v/sola r/sw h. htm.
To search for available residential and commercial renewable energy
incentives, visit Flex Your Power's website at htto://www.fvDower.ora/.
AGO, Project Level Mitigation Measures Page 4
[Rev. 1/6/2010]
Available at htto:llaa.ca.cov/alobalwarmina/Ddf/GW mitigation measures.Ddf,,
Install solar panels on In 2008 Southern California Edison (SCE) launched the nation's largest
unused roof and ground installation of photovoltaic power generation modules. The utility plans to cover
space and over 65 million square feet of unused commercial rooftops with 250 megawatts of
carports and parking solar technology — generating enough energy to meet the needs of
areas. approximately 162,000 homes. Learn more about SCE's Solar Rooftop
Program at htto:/lwww.sce.com/solarleadershio/solar-rooftop-prooram/aeneral-
fa tm.
In 2009, Walmart announced its commitment to expand the company's
solar power program in California. The company plans to add solar
panels on 10 to 20 additional Walmart facilities in the near term.
These new systems will be in addition to the 18 solar arrays currently
installed at Walmart facilities in California. See
httD:!/walmartstores.com/FactsNews/NewsRoom/9091. asgx.
Alameda County has installed two solar tracking carports, each generating 250
kilowatts. By 2005, the County had installed eight photovoltaic systems
totaling over 2.3 megawatts. The County is able to meet 6 percent of its
electricity needs through solar power. See
htto:llwww. acoov. ❑rolosa/Alameda °/n20Co unto °/020-
%20SoIa r%20Case%20Studv_ ❑df.
In 2007, California State University, Fresno installed at 1.1 -megawatt
photovoltaic (PV) -paneled parking installation. The University expects to save
more than $13 million in avoided utility costs over the project's 30 -year
lifespan. htta://www.fresnostatenews. com/2007/11 /solarwraouo2. htm..
Where solar systems U.S. Department of Energy, A Homebuilder's Guide to Going Solar (brochure)
cannot feasibly be (2008), available at httc)://www.eere.enerov.aov/solar/odfs/43076.adf.
incorporated into the
project at the outset,
build "solar ready"
structures.
Incorporate wind and Wind energy can be a valuable crop for farmers and ranchers. Wind turbines
solar energy systems can generate energy to be used on-site, reducing electricity bills, or they can
into agricultural projects yield lease revenues (as much as $4000 per turbine per year). Wind turbines
where appropriate. generally are compatible with rural land uses, since crops can be grown and
livestock can be grazed up to the base of the turbine. See National
Renewable Energy Laboratory, Wind Powering America Fact Sheet Series,
Wind Energy Benefits, available at
htto://www.nrel.qovidocs/fvO5osti/37602.i)df.
Solar PV is not just for urban rooftops. For example, the Scott Brothers' dairy
in San Jacinto, California, has installed a 55 -kilowatt solar array on its
commodity barn, with plans to do more in the coming years. See
http://www.dairvherd.com/directories.asi)?PaID=724&ed id=8409, (additional
California examples are included in article.)
AGO, Project Level Mitigation Measures Page 5
[Rev. 1/6/2010]
Available at htto://aci.ca-aov/alobalwarminc Ddf/GW mitioation measures.pdf.
Include energy storage See National Renewable Energy Laboratory, Energy Storage Basics
where appropriate to (webpage) at htto://www.nrel.aovllearnina/eds energv storaae.html.
optimize renewable
energy generation California Energy Storage Alliance (webpage) at
systems and avoid httol/storaaealliance.oralabout.html.
peak energy use.
Storage is not just for large, utility scale projects, but can be part of smaller
industrial, commercial and residential projects. For example, Ice Storage Air
Conditioning (ISAC) systems, designed for residential and nonresidential
buildings, produce ice at night and use it during peak periods for cooling. See
California Energy Commission, Staff Report, Ice Storage Air Conditioners,
Compliance Options Application (May 2006), available at
htto:l/www. energv. ca. gov/2006Rubi ications/CEC-400-2006-006/CEC-400
2006 -006 -SF. PDF.
Use on-site generated At the Hilarides Dairy in Lindsay, California, an anaerobic -lagoon digester
biogas, including processes the run-off of nearly 10,000 cows, generating 226,000 cubic feet of
methane, in appropriate biogas per day and enough fuel to run two heavy duty trucks. This has reduced
applications. the dairy's diesel consumption by 650 gallons a day, saving the dairy money
and improving local air quality. See
htto://www.arb.ca.ciov/newsrel/nrO2llO9b.htm; see also Public Interest Energy
Research Program, Dairy Power Production Program, Dairy Methane Digester
System, 90 -Day Evaluation Report, Eden Vale Dairy (Dec. 2006) at
htto//www_energv.ca.aov/2006oublications/CEC 500 2006 083/CEC 500 2006
083.PDF.
Landfill gas is a current and potential source of substantial energy in
California. See Tom Frankiewicz, Program Manager, U.S. EPA
Landfill Methane Outreach Program, Landfill Gas Energy Potential in
California, available at
htto://www.enerav_ca.aov/2009 eneravoolicv/documents/2009-04
21 workshop/presentations/05-SCS Engineers Presentation.gdf
There are many current and emerging technologies for converting landfill
methane that would otherwise be released as a greenhouse gas into clean
energy. See California Integrated Waste Management Board, Emerging
Technologies, Landfill Gas -to -Energy (webpage) at
htto://www. ciwmb.ca_aoviLEACentra l/TechServices/Eme raingTech/defa uit. htm,
AGO, Project Level Mitigation Measures Page 6
[Rev. 1/6/2010]
Available at htto://aa.ca.raov/alobalwarmina/Ddf/GW mitiaation measures.od.
Use combined heat and Many commercial, industrial, and campus -type facilities (such as hospitals,
power (CHP) in universities and prisons) use fuel to produce steam and heat for their own
appropriate operations and processes. Unless captured, much of this heat is wasted.
applications. CHP captures waste heat and re -uses it, e.g., for residential or commercial
space heating or to generate electricity. See U S. EPA, Catalog of CHP
Technologies at
htto://w�v�v.eoa.ciov/chDYdoctu-nents/catalog of %20chD tech entire.pdf and
California Energy Commission, Distributed Energy Resource Guide, Combined
Heat and Power (webpage) at
http://www.energv-Ca. gov/distgen/egUlpment/cho/chp- htmi.
The average efficiency of fossil -fueled power plants in the United States is 33
percent. By using waste heat recovery technology, CHP systems typically
achieve total system efficiencies of 60 to 80 percent. CHP can also
substantially reduce emissions of carbon dioxide.
httt)://www.er)a.ciov/chQ/basic/efficienov. html,
Currently, CHP in California has a capacity of over 9 million kilowatts. See list
of California CHP facilities at httr)://www.eea-ine.corrnlchr_�data/States/CA. html.
The Waste Heat and Carbon Emissions Reduction Act (Assembly Bill 1613
(2007), amended by Assembly Bill 2791 (2008)) is designed to encourage the
development of new CHP systems in California with a generating capacity of
not more than 20 megawatts. Among other things, the Act requires the
California Public Utilities Commission to establish (1) a standard tariff allowing
CHP generators to sell electricity for delivery to the grid and (2) a "pay as you
save" pilot program requiring electricity corporations to finance the installation
of qualifying CHP systems by nonprofit and government entities. For more
information, see htto.1/www.energv.ca.govMasteheat/.
Water Conservation and Efficiency
Incorporate water-
According to the California Energy Commission, water -related energy use —
reducing features into
which includes conveyance, storage, treatment, distribution, wastewater
building and landscape
collection, treatment, and discharge — consumes about 19 percent of the
design.
State's electricity, 30 percent of its natural gas, and 88 billion gallons of diesel
fuel every year. See httollwww.enerav.ca.cov/2007oublications/CEC 999
2007 008/CEC 999 2007 008.PDF. Reducing water use and improving water
efficiency can help reduce energy use and greenhouse gas emissions.
Create water -efficient The California Department of Water Resources' updated Model Water Efficient
landscapes. Landscape Ordinance (Sept. 2009) is available at
htto:l/www.water.ca. govhniateruseefficiencv/iandscaneordinance/technical.cfm..
A landscape can be designed from the beginning to use little or no water, and
to generate little or no waste. See California Integrated Waste Management
Board, Xeriscaping (webpage) at
htto: //www. ciwmb. ca. gov/organics/Xerisca p[ng/.
AGO, Project Level Mitigation Measures Page 7
[Rev. 1/6/2010]
Available at htto:!/aa.ca.cov/alobalwarminci/odf/GW mitigation measures.pdf
Install water-efficient U.S. Department of Energy, Best Management Practice: Water-Efficient
irrigation systems and Irrigation (webpage) at
devices, such as soil htto llwww'1.eere.eneray.aovlfemp/proaram/waterefficiencv bmp5.html
moisture-based
irrigation controls and California Department of Water Resources, Landscape Water Use Efficiency
use water-efficient (webpage) at htto://www.water_ca.aov/wateruseefficiencv/landscape/.
irrigation methods.
Pacific Institute, More with Less: Agricultural Water Conservation and
Efficiency in California (2008), available at
http:/lwww.oacinst.oralreparts/more with less deltalindex.htm.
Make effective use of
California Building Standards Commission, 2008 California Green Building
graywater. (Graywater
Standards Code, Section 604, pp. 31-32, available at
is untreated household
http:llwww. documents. das.ca.govlbsc120091part11 2008 caiareen codc.pdf.
waste water from
bathtubs, showers,
California Department of Water Resources, Dual Plumbing Code (webpage) at
bathroom wash basins,
htto://www.water.ca.qov/reovolinci/DualPlumbinoCode/.
and water from clothes
htto://www.coastal.ca.aov/n Ds/lid-factsheet.odf.
washing machines.
See also Ahwahnee Water Principles, Principle 6, at
Graywater to be used
httt):llwww.lac.ora/ahwahneelh2o princioles.html. The Ahwahnee Water
for landscape
Principles have been adopted by City of Willits, Town of Windsor, Menlo Park,
irrigation.)
Morgan Hill, Palo Alto, Petaluma, Port Hueneme, Richmond, Rohnert Park,
Rolling Hills Estates, San Luis Obispo, Santa Paula, Santa Rosa, City of
Sunnyvale, City of Ukiah, Ventura, Marin County, Marin Municipal Water
District, and Ventura County.
Implement low -impact
Retaining storm water runoff on-site can drastically reduce the need for
development practices
energy -intensive imported water at the site. See U.S. EPA, Low Impact
that maintain the
Development (webpage) at htto://www,er)a.govinpsllidl.
existing hydrology of
the site to manage
Office of Environmental Health Hazard Assessment and the California Water
storm water and protect
and Land Use Partnership, Low Impact Development at
the environment.
htto://www.coastal.ca.aov/n Ds/lid-factsheet.odf.
Devise a The strategy may include many of the specific items listed above, plus other
comprehensive water innovative measures that are appropriate to the specific project.
conservation strategy
appropriate for the
project and location.
Design buildings to be Department of General Services, Best Practices Manual, Water -Efficient
water -efficient. Install Fixtures and Appliances (website) at
water -efficient fixtures httn:llwww.oreen.ca.00v/EPP/buildinq/SaveH2O.htm.
and appliances.
Many ENERGY STAR products have achieved their certification because of
water efficiency. See California Energy Commission's database, available at
htto:llwww. a ❑pi iances. eneray. ca.aov/.
AGO, Project Level Mitigation Measures Page 8
[Rev. 1/6/2010]
Available at htto://aa.ca-aov/alobalwarmina/Ddf/GW mitigation measures.pdf.
Offset water demand For example, the City of Lompoc has a policy requiring new development to
from new projects so offset new water demand with savings from existing water users. See
that there is no net httD://www.citvoflomDoe.com/utilitieslpdf/2005 uwmo final.odf at p. 29.
increase in water use.
Provide education See, for example, the City of Santa Cruz, Water Conservation Office at
about water http/lwww.ei.santa-cruz.ca.usfindex.aspx?page=395; Santa Clara Valley
conservation and Water District, Water Conservation at
available programs and htto:llwww.vallevwater.ora/conservationAndex.shtm; and Metropolitan Water
incentives. District and the Family of Southern California Water Agencies, Be Water Wise
at htto:1Anrww_bewaterwise.com. Private projects may provide or fund similar
education.
Solid Waste Measures
Reuse and recycle
Construction and demolition materials account for almost 22 percent of the
construction and
waste stream in California. Reusing and recycling these materials not only
demolition waste
conserves natural resources and energy, but can also save money. For a list
(including, but not
of best practices and other resources, see California Integrated Waste
limited to, soil,
Management Board, Construction and Demolition Debris Recycling (webpage)
vegetation, concrete,
at httv://www.ciwmb.ca.aovlcondemol.
lumber, metal, and
devising an education project. See
cardboard).
httpllwww.ciwmb.ca.govlPublicationsldefault.aso?cat-13. Private projects
Integrate reuse and Tips on developing a successful recycling program, and opportunities for cost -
recycling into residential effective recycling, are available on the California Integrated Waste
industrial, institutional Management Board's Zero Waste California website. See
and commercial httollzerowaste.ca_aov1.
projects.
The Institute for Local Government's Waste Reduction & Recycling webpage
contains examples of "best practices" for reducing greenhouse gas emissions,
organized around waste reduction and recycling goals and additional examples
and resources. See htto:llwww.ca-ila.ora/wastereduction.
Provide easy and Tips on developing a successful recycling program, and opportunities for cost
convenient recycling effective recycling, are available on the California Integrated Waste
opportunities for Management Board's Zero Waste California website. See
residents, the public, htto:/lzerowaste.ca.aov/.
and tenant businesses.
Provide education and
Many cities and counties provide information on waste reduction and recycling.
publicity about reducing
See, for example, the Butte County Guide to Recycling at
waste and available
htto:llwww. recvclebutte.net.
recycling services.
The California Integrated Waste Management Board's website contains
numerous publications on recycling and waste reduction that may be helpful in
devising an education project. See
httpllwww.ciwmb.ca.govlPublicationsldefault.aso?cat-13. Private projects
may also provide waste and recycling education directly, or fund education.
AGO, Project Level Mitigation Measures Page 9
[Rev. 11612010]
Available at htto:l/aa.ca.aov/olobalwarminalodf/GW mitiaatton measures.odf,
Land Use Measures
Ensure consistency
with "smart growth"
principles —
mixed-use, infill, and
higher density projects
that provide
alternatives to individual
vehicle travel and
promote the efficient
delivery of services and
goods.
U.S. EPA maintains an extensive Smart Growth webpage with links to
examples, literature and technical assistance, and financial resources. See
htt[)://www.eDa-aov/smartctrowtNindex-htm.
The National Oceanic and Atmospheric Administration's webpage provides
smart growth recommendations for communities located near water. See
Coastal & Waterfront Smart Growth (webpage) at
htto:!/coastalsmartorowth.noaa.00v/. The webpage includes case studies from
California.
The California Energy Commission has recognized the important role that land
use can play in meeting our greenhouse gas and energy efficiency goals. The
agency's website, Smart Growth & Land Use Planning, contains useful
information and links to relevant studies, reports, and other resources. See
httD://www.enerciv.ca.Qovllanduse/.
The Metropolitan Transportation Commission's webpage, Smart Growth /
Transportation for Livable Communities, includes resources that may be useful
to communities in the San Francisco Bay Area and beyond. See
htto:/lwww.mtc.ca.00v/olannino/smart growth/.
The Sacramento Area Council of Governments (SACOG) has published
examples of smart growth in action in its region. See Examples from the
Sacramento Region of the Seven Principles of Smart Growth / Better Ways to
Grow, available at htto://www.sacoa.ora/recionalfundina/betterways.pdf.
Meet recognized "smart For example, the LEED for Neighborhood Development (LEED-ND) rating
growth" benchmarks. system integrates the principles of smart growth, urbanism and green building
into the first national system for neighborhood design. LEED-ND is a
collaboration among the U.S. Green Building Council, Congress for the New
Urbanism, and the Natural Resources Defense Council. For more information,
see htta://www.usabc.ora/Disr)iavPaae.asr)x?CMSPaaelD=148.
Educate the public See, for example, U.S. EPA, Growing Smarter, Living Healthier: A Guide to
about the many benefits Smart Growth and Active Aging (webpage), discussing how compact, walkable
of well-designed, higher communities can provide benefits to seniors. See
density development. htto://www.eraa.aov/aaina/bhc/auideCndex.html.
U.S. EPA, Environmental Benefits of Smart Growth (webpage) at
htto://www.epa.ciov/dced/tooics/eb.htm (noting local air and water quality
improvements).
Centers for Disease Control and Prevention (CDC), Designing and Building
Healthy Places (webpage), at htto://www.cdc.aov/heaithvplacesl. The CDC's
website discusses the links between walkable communities and public health
and includes numerous links to educational materials.
California Department of Housing and Community Development, Myths and
Facts About Affordable and High Density Housing (2002), available at
httq:l/www, hcd. ca. aovlhpd/mvthsnfa cts. odf.
AGO, Project Level Mitigation Measures Page 10
[Rev. 116/2010]
Available at http:flap.ca.aov/piobalwarmina/rdf/GW mitigation measures.odfdf.
Incorporate public Federal Transit Administration, Transit -Oriented Development (TOD)
transit into the project's (webpage) at htto://www.fi:a.dot.cov/i)lanninalolannina environment 6932_htmi.
design. (describing the benefits of TOD as "social, environmental, and fiscal.")
California Department of Transportation (Caltrans), Statewide Transit -Oriented
Development Study: Factors for Success in California (2002), available at
htto://transitori enteddevelooment. dot. ca. govlmiscell aneous/StatewideTOD. htm
Caltrans, California Transit -Oriented Development Searchable Database
(includes detailed information on numerous TODs), available at
htto : /It ra nsitori e me ddeve l o oment. dot. ca . g ov/m i sce l l a n e ou s/N ewH o me. i s p
California Department of Housing and Community Development, Transit
Oriented Development (TOD) Resources (Aug. 2009), available at
httr)://www.hcd.ca.aovlhr)d/tod.odf.
Preserve and create U.S. EPA, Smart Growth and Open Space Conservation (webpage) at
open space and parks. http://www.ei)a,aovldced/agensoace.htm,
Preserve existing trees,
and plant replacement
trees at a set ratio.
Develop "brownfields" U.S. EPA, Smart Growth and Brownfields (webpage) at
and other underused or http://www.epa.aovldced/brownfieIds.htm.
defunct properties near
existing public For example, as set forth in the Local Government Commission's case study,
transportation and jobs. the Town of Hercules, California reclaimed a 426 -acre brownfield site,
transforming it into a transit -friendly, walkable neighborhood. See
http:llwww.lac.orcVfreepubldoes/community design/fact sheetsler case studi
es. ipdf.
For financial resources that can assist in brownfield development, see Center
for Creative Land Recycling, Financial Resources for California Brownfields
(July 2008), available at http-//www.cclr.ora/media/oublications/8-
Financial Resources 2008.odf.
Include pedestrian and See U.S. Department of Transportation, Federal Highway Administration,
bicycle facilities within Bicycle and Pedestrian Program (webpage) at
projects and ensure htto:l/www.fhwa.dot.aov/environmentlbikeoedl.
that existing non -
motorized routes are Caltrans, Pedestrian and Bicycle Facilities in California / A Technical
maintained and Reference and Technology Transfer Synthesis for
enhanced. Caltrans Planners and Engineers (July 2005), available at
htto:llwww. dot- ca. aov/ho/traffor)s/survev/DedpstrianFfR MAYn4f 9, .Q f. This
reference includes standard and innovative practices for pedestrian facilities
and traffic calming.
AGO, Project Level Mitigation Measures Page 11
[Rev. 1/6/2010]
Available at http://aa.ca.aov/alobalwarminWDdf/GW mitigation measures.pdf.
Transportation and Motor Vehicles
Meet an identified A logical benchmark might be related to vehicles miles traveled (VMT), e.g.,
transportation -related average VMT per capita, per household, or per employee. As the California
benchmark. Energy Commission has noted, VMT by California residents increased "a rate
of more than 3 percent a year between 1975 and 2004, markedly faster than
the population growth rate over the same period, which was less than 2
percent. This increase in VMT correlates to an increase in petroleum use and
GHG production and has led to the transportation sector tieing responsible for
41 percent of the state's GHG emissions in 2004." CEC, The Role of Land
Use in Meeting California's Energy and Climate Change Goals (Aug. 2007) at
p. 9, available at http:/fwww.eneray.ca.cov/2007oublications/CEC-600-2007-
008/CEC-600-2007-008-SF. PD F.
Even with regulations designed to increase vehicle efficiency and lower the
carbon content of fuel, "reduced VMT growth will be required to meet GHG
reductions goals." /d. at p. 18.
Adopt a comprehensive
For example, reduce parking for private vehicles while increasing options for
parking policy that
alternative transportation; eliminate minimum parking requirements for new
discourages private
buildings; "unbundle" parking (require that parking is paid for separately and is
vehicle use and
not included in rent for residential or commercial space); and set appropriate
encourages the use of
pricing for parking.
alternative
transportation.
See U.S. EPA, Parking Spaces / Community Places, Finding the Balance
Through Smart Growth Solutions (Jan. 2006), available at
http://www. a oa. aovldced/DdflEPAParkinQSgaces06. pdf_
Reforming Parking Policies to Support Smart Growth, Metropolitan
Transportation Commission (June 2007) at
http://www.mtc.ca_gov/plannina/smart growth/parkina seminar/Toolbox.
Handbook. pdf.
See also the City of Ventura's Downtown Parking and Mobility Plan, available
at
http://www.citvofventura.netloommunity development/resources/mobility parki.
no olan.pdf, and Ventura's Downtown Parking Management Program,
available at
htto://www.ci_ventura.ca.us/deDts/comm dev/downtownolanlchaoters.asp.
Build or fund a major "'Major transit stop' means a site containing an existing rail transit station, a
transit stop within or ferry terminal served by either a bus or rail transit service, or the intersection of
near the development. two or more major bus routes with a frequency of service interval of 15 minutes
or less during the morning and afternoon peak commute periods." (Pub. Res.
Code, § 21064.3.)
Transit Oriented Development (TOD) is a moderate to higher density
development located within an easy walk of a major transit stop.
htto:/Itransitorienteddevelor)ment, dot. ca. aov/miscellaneous/NewWhatisTOD. ht
M.
By building or funding a major transit stop, an otherwise ordinary development
can become a TOD.
AGO, Project Level Mitigation Measures Page 12
[Rev. 1/6/2010]
Available at httr3:l/aa,ca.aov/alobalwarmincYDdf/GW mitigation measures.gdf.
Provide public transit See U.S Department of Transportation and U S. EPA, Commuter Choice
incentives such as free Primer / An Employer's Guide to Implementing Effective Commuter Choice
or low-cost monthly Programs, available at
transit passes to htto;//www.its.dot.cov/JPODOCS/REPTS P13/13669.1-itml.
employees, or free ride
areas to residents and The Emery Go Round shuttle is a private transportation service funded by
customers. commercial property owners in the citywide transportation business
improvement district. The shuttle links a local shopping district to a Bay Area
Rapid Transit stop. See htto://www.ernervcioround.com/.
Seattle, Washington maintains a public transportation "ride free" zone in its
downtown from 6:00 a.m. to 7:00 p.m. daily. See
httu.//transit,metrokc.aov/tops/accessible/r)accessible maq.htmi#fare.
Promote "least Promoting "least polluting" methods of moving people and goods is part of a
polluting" ways to larger, integrated `sustainable streets" strategy now being explored at U. C.
connect people and Davis's Sustainable Transportation Center. Resources and links are available
goods to their at the Center's website, htto://stc.ucdavis.eduloutreach/ssp.php.
destinations.
Incorporate bicycle Bicycling can have a profound impact on transportation choices and air
lanes, routes and pollution reduction. The City of Davis has the highest rate of bicycling in the
facilities into street nation. Among its 64,000 residents, 17 percent travel to work by bicycle and
systems, new 41 percent consider the bicycle their primary mode of transportation. See Air
subdivisions, and large Resources Board, Bicycle Awareness Program, Bicycle Fact Sheet, available
developments. at htto:/1www.arb.ca.oav/plannino/tsaa/bicvde/factsht.htm.
For recommendations on best practices, see the many resources listed at the
U.S. Department of Transportation, Federal Highway Administration's Bicycle
and Pedestrian website at
htto://www.fhwa.dot aov/environment/bikeoed/publications.htm.
See also Caltrans Division of Research and Innovation, Designing Highway
Facilities To Encourage Walking, Biking and Transit (Preliminary Investigation)
(March 2009), available at
htto:/lwww.dot.ca-aov/research/researchreiDorts/oreliminary investigations/doc
sloi-desion for walking %20bikina and transit%20final.odf.
Require amenities for According to local and national surveys of potential bicycle commuters, secure
non -motorized bicycle parking and workplace changing facilities are important complements
transportation, such as to safe and convenient routes of travel. See Air Resources Board, Bicycle
secure and convenient Awareness Program, Bicycle Fact Sheet, available at
bicycle parking. httn://www.arb.ca.cov/planning/tsaa/bicvcle/factsht.htm.
AGO, Project Level Mitigation Measures Page 13
[Rev. 1/6/2010]
Available at htto://aq.ca.aov/globalwarmina/pdf/GW mitigation measures.pdf.
Ensure that the project See, e.g., U.S. EPA's list of transit -related "smart growth" publications at
enhances, and does not littp:llwvvw.eoa.aov/dcedlpublications.htm#air., including Pedestrian and
disrupt or create Transit -Friendly Design: A Primer for Smart Growth (1999), available at
barriers to, non- www.eoa.aav/dceci/r)df/r)tfd orimer.pdf.
motorized
transportation. See also Toolkit for Improving Walkability in Alameda County, available at
httc:l/www.acta2002,cam/ned toolkit/ped toolkit print. pdf.
Pursuant to the California Complete Streets Act of 2008 (AB 1358, Gov. Code,
§§ 65040.2 and 65302), commencing January 1, 2011, upon any substantive
revision of the circulation element of the general plan, a city or county will be
required to modify the circulation element to plan for a balanced, multimodal
transportation network that meets the needs of all users.
Connect parks and
Walk Score ranks the "walkability" of neighborhoods in the largest 40 U.S.
open space through
cities, including seven California cities. Scores are based on the distance to
shared pedestrian/bike
nearby amenities. Explore Walk Score at httiD1/www.wa1kscore.c0ml.
paths and trails to
Programs to create safe routes to schools can break this harmful cycle. See
encourage walking and
In many markets, homes in walkable neighborhoods are worth more than
bicycling.
similar properties where walking is more difficult. See Hoak, Walk appeal/
Create bicycle lanes
Homes in walkable neighborhoods sell for more. study, Wall Street Journal
and walking paths
(Aug. 18, 2009), available at http.11www,marketwatch.com/story/hares-in-
directed to the location
walkable-neiahborhocds-sell-for-more-2009-08-18.
of schools, parks and
httD://www.eDa-aov/doed/schools.htm.
other destination points.
By creating walkable neighborhoods with more transportation choices,
Californians could save $31 million and cut greenhouse gas emissions by 34
percent, according to a study released by Transform, a coalition of unions and
nonprofits. See Windfall for All / How Connected, Convenient Neighborhoods
Can Protect Our Climate and Safeguard California's Economy (Nov. 2009),
available at htto://transformca.oralwindfall-for-all#dowriload-report.
Work with the school
In some communities, twenty to twenty-five percent of morning traffic is due to
districts to improve
parents driving their children to school. Increased traffic congestion around
pedestrian and bike
schools in turn prompts even more parents to drive their children to school,
access to schools and
Programs to create safe routes to schools can break this harmful cycle. See
to restore or expand
California Department of Public Health, Safe Routes to School (webpage) and
school bus service
associated links at
using lower -emitting
http://www.cdoh.ca.aovlHealthlnfo/iniviosaflPaaes/SafeRoutestoSchool.asDx.
vehicles.
See also U.S. EPA, Smart Growth and Schools (webpage), available at
httD://www.eDa-aov/doed/schools.htm.
California Center for Physical Activity, California Walk to School (website) at
httpl/www. caws I ktoschool. cam
Regular school bus service (using lower -emitting buses) for children who
cannot bike or walk to school could substantially reduce private vehicle
congestion and air pollution around schools. See Air Resources Board, Lower
Emissions School Bus Program (webpage) at
htto://www. arb. ca. aovlrnsoroo/schoolbuslschoolbus. htm.
AGO, Project Level Mitigation Measures Page 14
[Rev. 1/6/2010]
Available at htto.11aa.ca aov1o1cbalwarmina/Ddf1GW mitigation measures. pdf,
Institute
There are numerous sites on the web with resources for employers seeking to
teleconferencing,
establish telework or flexible work programs. These include U.S. EPA's
telecommute and/or
Mobility Management Strategies: Commuter Programs website at
flexible work hour
htto://www.eDa.aov/otaa/stateresources/rellinkslmms commoroorams.htm;
programs to reduce
and Telework, the federal government's telework website, at
unnecessary employee
htto://www.telework.aov/.
transportation.
Through a continuing FlexWork Implementation Program, the Traffic Solutions
division of the Santa Barbara County Association of Governments sponsors
flexwork consulting, training and implementation services to a limited number
of Santa Barbara County organizations that want to create or expand flexwork
programs for the benefit of their organizations, employees and the community.
See htto://www.flexworksb.comlread more about the fSBP.htrnl. Other local
government entities provide similar services.
Provide information on
alternative
transportation options
for consumers,
residents, tenants and
employees to reduce
transportation -related
emissions.
Educate consumers,
residents, tenants and
the public about options
for reducing motor
vehicle -related
greenhouse gas
emissions. Include
information on trip
reduction; trip linking;
vehicle performance
and efficiency (e.g.,
keeping tires inflated);
and low or zero -
emission vehicles.
Purchase, or create
incentives for
purchasing, low or zero -
emission vehicles.
Many types of projects may provide opportunities for delivering more tailored
transportation information. For example, a homeowner's association could
provide information on its website, or an employer might create a
Transportation Coordinator position as part of a larger Employee Commute
Reduction Program. See, e.g., South Coast Air Quality Management District,
Transportation Coordinator training, at htto://www.aamd.povltrans/traina.html,
See, for example U.S. EPA, SmartWay Transport Partnership: Innovative
Carrier Strategies (webpage) at htto:/ANww.et a.gov/smartwav/transporUwhat-
smartwav/carrier-strategies. htm. This webpage includes recommendations for
actions that truck and rail fleets can take to make ground freight more efficient
and cleaner.
The Air Resources Board's Drive Clean website is a resource for car buyers to
find clean and efficient vehicles. The web site is designed to educate
Californians that pollution levels range greatly between vehicles. See
httr)://www.driveclean.ca-qov/.
The Oregon Department of Transportation and other public and private
partners launched the Drive Less/Save More campaign. The comprehensive
website contains fact sheets and educational materials to help people drive
more efficiently. See htto://www. driveiesssavemore.com/.
See Air Resources Board, Low -Emission Vehicle Program (webpage) at
httD:llwww-arb-ca.aov/rmoroo/levr)roci/levDroq.htm.
Air Resource Board, Zero Emission Vehicle Program (webpage) at
httr)://www.arb.ca.Qov/msi)roa/zevproq/zevproQ.ht[-n.
All new cars sold in California are now required to display an Environmental
Performance (EP) Label, which scores a vehicle's global warming and smog
emissions from 1 (dirtiest) to 10 (cleanest). To search and compare vehicle
EP Labels, visit www.DriveClean.ca.00v.
AGO, Project Level Mitigation Measures Page 15
[Rev. 1/6/2010]
Available at htto)/aa.ca.aov/alot>aiwarmina/odf/GW mitigation measures.gdf,
Create a ride sharing
program. Promote
existing ride sharing
programs e.g., by
designating a certain
percentage of parking
spaces for ride sharing
vehicles, designating
adequate passenger
loading and unloading
for ride sharing
vehicles, and providing
a web site or message
board for coordinating
rides.
Create or
accommodate car
sharing programs, e.g.,
provide parking spaces
for car share vehicles at
convenient locations
accessible by public
transportation.
For example, the 511 Regional Rideshare Program is operated by the
Metropolitan Transportation Commission (MTC) and is funded by grants from
the Federal Highway Administration, U.S. Department of Transportation, the
Metropolitan Transportation Commission, the Bay Area Air Quality
Management District and county congestion management agencies. For more
information, see httr) //rides ha re. 511.ora1.
As another example, San Bernardino Associated Governments works directly
with large and small employers, as well as providing support to commuters
who wish to share rides or use alternative forms of transportation. See
htto Jhrnaiw.sanbaca. ca. ciov/commuter/ridesha re. html.
Valleyrides.com is a ridesharing resource available to anyone commuting to
and from Fresno and Tulare Counties and surrounding communities. See
htto://www vallevrides com/. There are many other similar websites throughout
the state.
There are many existing car sharing companies in California. These include
City CarShare (San Francisco Bay Area), see htto://www.citvcarshare orq/;
and Zipcar, see htto://wvvw.zrvcar.caml. Car sharing programs are being
successfully used on many California campuses.
Provide a vanpool for Many local Transportation Management Agencies can assist in forming
employees. vanpools. See, for example, Sacramento Transportation Management
Association, Check out Vanpooling (webpage) at httoJ/www.sacramento-
tma . oralva n000l. htm I .
Create local "light See California Energy Commission, Consumer Energy Center, Urban Options
vehicle" networks, such - Neighborhood Electric Vehicles (NEVs) (webpage) at
as neighborhood httr)://www.consumerenerovicenter.Ora/transr)ortationiurban oQtions/nev.html.
electric vehicle
systems. The City of Lincoln has an innovative NEV program. See
htto7 //www.lincolnev.comlindex html.
Enforce and follow Under existing law, diesel -fueled motor vehicles with a gross vehicle weight
limits idling time for rating greater than 10,000 pounds are prohibited from idling for more than 5
commercial vehicles, minutes at any location. The minimum penalty for an idling violation is now
including delivery and $300 per violation. See httn.//www.arb.ca.00v/enf/comr)laints/idling cv htm
construction vehicles.
Provide the necessary For a list of existing alternative fuel stations in California, visit
facilities and htto://www.cleai-icanrraps.coml.
infrastructure to
encourage the use of See, e.g., Baker, Charging -station network built along 101, S.F. Chron.
low or zero -emission (9/23109), available at httol/articles.sfoate com/2009-09-
vehicles. 23/news/17207424 1 recharoino-solar-arrav-tesla-motors.
AGO, Project Level Mitigation Measures Page 16f
[Rev. 1/6/2010]
Available at httr)://ao.ca.(7avlolobalwarmina/odf/GW mitrQation measures.r)df.
Agriculture and Forestry (additional strategies noted above)
Require best
Air Resources Board (ARB), Economic Sectors Portal, Agriculture (webpage)
management practices
athttD://www.arb-ca-aovfcc/ahasectors/ahosectors.html. ARB's webpage
in agriculture and
includes information on emissions from manure management, nitrogen
animal operations to
fertilizer, agricultural offroad equipment, and agricultural engines.
reduce emissions,
conservation tillage practices on agricultural lands; (3) substituting bio -
conserve energy and
"A full 90% of an agricultural business' electricity bill is likely associated with
water, and utilize
water use. In addition, the 8 million acres in California devoted to crops
alternative energy
consume 80% of the total water pumped in the state." See Flex Your Power,
sources, including
Agricultural Sector (webpage) at htto:l/www.fvr)ower.orq/agri/.
biogas, wind and solar.
htto://www.eoa.covlseouestration/faa.htmi..
Flex Your Power, Best Practice Guide / Food and Beverage Growers and
Processors, available at
htto:l/www.fvDower.ora/boo/index. html?b=food and bev.
Antle et al., Pew Center on Global Climate Change, Agriculture's Role in
Greenhouse Gas Mitigation (2006), available at
httD://www.oewcli mate. oraldocUoloads/Aari culture's%20Role °/n20in°/n20GHG°!n
20 M itioation. odf.
Preserve forested
"There are three general means by which agricultural and forestry
areas, agricultural
practices can reduce greenhouse gases: (1) avoiding emissions by
lands, wildlife habitat
maintaining existing carbon storage in trees and soils, (2) increasing
and corridors, wetlands,
carbon storage by, e.g., tree planting, conversion from conventional to
watersheds,
conservation tillage practices on agricultural lands; (3) substituting bio -
groundwater recharge
based fuels and products for fossil fuels, such as coal and oil, and
areas and other open
energy -intensive products that generate greater quantities of CO2
space that provide
when used." U.S. EPA, Carbon Sequestration in Agriculture and
carbon sequestration
Forestry, Frequently Asked Questions (webpage) at
benefits.
htto://www.eoa.covlseouestration/faa.htmi..
Air Resources Board, Economic Sectors Portal, Forestry (webpage) at
htto.,//www.arb.ca.ciovioc/qhcisectors/cihosectors.htm.
Protect existing trees Tree preservation and planting is not just for rural areas of the state; suburban
and encourage the and urban forests can also serve as carbon sinks. See Cal Fire, Urban and
planting of new trees. Community Forestry (webpage) at
Adopt a tree protection htto:l/www.fire_ca.Qovlresource motlresource mgt urbanforestrv.r)hp.
and replacement
ordinance.
Off -Site Mitiatation
If, after analyzing and requiring all reasonable and feasible on-site mitigation measures
for avoiding or reducing greenhouse gas -related impacts, the lead agency determines
that additional mitigation is required, the agency may consider additional off-site
mitigation. The project proponent could, for example, fund off-site mitigation projects
that will reduce carbon emissions, conduct an audit of its other existing operations and
agree to retrofit, or purchase verifiable carbon "credits" from another entity that will
undertake mitigation.
AGO, Project Level Mitigation Measures Page 17
[Rev. 116/2010]
Available at htto:llao.ca.Qovlolobaiwarmina/odf/GW mitioation measures -pd.
The topic of off-site mitigation can be complicated. A full discussion is outside the
scope of this summary document. Issues that the lead agency should consider include:
The location of the off-site mitigation. (If the off-site mitigation is far from the
project, any additional, non -climate related co -benefits of the mitigation may be
lost to the local community.)
Whether the emissions reductions from off-site mitigation can be quantified and
verified. (The California Registry has developed a number of protocols for
calculating, reporting and verifying greenhouse gas emissions. Currently,
industry -specific protocols are available for the cement sector, power/utility
sector, forest sector and local government operations. For more information, visit
the California Registry's website at httt)://www.climatereaistrv.oral.)
• Whether the mitigation ratio should be greater than 1:1 to reflect any uncertainty
about the effectiveness of the off-site mitigation.
Offsite mitigation measures that could be funded through mitigation fees include, but are
not limited to, the following:
■ Energy efficiency audits of existing buildings.
• Energy efficiency upgrades to existing buildings not otherwise required by law,
including heating, ventilation, air conditioning, lighting, water heating equipment,
insulation and weatherization (perhaps targeted to specific communities, such as
low-income or senior residents).
• Programs to encourage the purchase and use of energy efficient vehicles,
appliances, equipment and lighting.
• Programs that create incentives to replace or retire polluting vehicles and
engines.
Programs to expand the use of renewable energy and energy storage.
• Preservation and/or enhancement of existing natural areas (e.g., forested areas,
agricultural lands, wildlife habitat and corridors, wetlands, watersheds, and
groundwater recharge areas) that provide carbon sequestration benefits.
• Improvement and expansion of public transit and low- and zero -carbon
transportation alternatives.
AGO, Project Level Mitigation Measures Page 18
[Rev 1/6/2010]
Available at htto.//aa,ca.aov/alobalwarmina/ndf/GW mitigation measures.bdf.
ATTACHMENT B
Indoor Air Quality in New California Homes with Mechanical Ventilation
Wanyu Chan',*, Yang-Seon Kim', Brett Singer', Iain Walker'
' Lawrence Berkeley National Laboratory, Berkeley, USA
*Corresponding emaid:wrchan@lbl.gov
SUMMARY
The Healthy Efficient New Gas Homes (HENGH) study measured indoor air quality and
mechanical ventilation use in 70 new California homes. This paper summarizes preliminary
results collected from 42 homes. In addition to measurements of formaldehyde, nitrogen
dioxide (NO2), and PM2.5 that are discussed here, HENGH also monitored other indoor
environmental parameters (e.g., CO2) and indoor activities (e.g., cooking, fan use) using
sensors and occupant logs. Each home was monitored for one week. Diagnostic tests were
performed to characterize building envelope and duct leakage, and mechanical system airflow.
Comparisons of indoor fonnaldehyde, NO2, and PM2.5 with a prior California New Home
Study (CNHS) (Offerma.nn, 2009) suggest that contaminant levels are lower than measured
from about 10 years ago. The role of mechanical ventilation on indoor contaminant levels will
be evaluated.
KEYWORDS
Formaldehyde; nitrogen dioxide; particles; home performance; field study
1 INTRODUCTION
The HENGH field study (2016-2018) aimed to measure indoor air quality in 70 new
California homes that have mechanical ventilation. Eligible houses were built in 2011 or later;
had an operable whole -dwelling mechanical ventilation system; used natural gas for space
heating, water heating, and/or cooking; and had no smoking in the home. Study participants
were asked to rely on mechanical ventilation and avoid window use during the one-week
monitoring period. All homes had a venting kitchen range hood or over the range microwave
and bathroom exhaust fans. This paper presents summary results of formaldehyde, NO2, and
PM2.5 measurements in 42 homes. The full dataset is expected to be available in summer
2018.
2 METHODS
Integrated one-week concentrations of formaldehyde and NOx were measured using SKC
UMEx-100 and Ogawa passive samplers. Formaldehyde samplers were deployed in the main
living space, master bedroom, and outdoors. PM2.5 were measured using a pair of photometers
(ES-642BT-645, MetOne Instruments) indoor in the main living space and outdoors. PM25
filter samples were collected using a co -located pDR-1500 (ThermoFisher) in a subset of the
homes and time -resolved photometer data were adjusted using the gravimetric measurements.
Results are compared with a prior field study CNHS (2007-2008) (Offermann, 2009) that
monitored for contaminant concentrations over a 24-hour period in 108 homes built between
2002 and 2004, including a subset of 26 homes with whole -dwelling mechanical ventilation.
3 RESULTS
Figure 1 compares the indoor concentrations of formaldehyde, NO2, and PM2.5 measured by
the two studies. Results of HENGH are one-week averaged concentrations, whereas CHNS
are 24-hour averages. HENGH measured lower indoor concentrations of formaldehyde and
PM2.5, compared to CNHS. For NO2, the indoor concentrations measured by the two studies
are similar. Summary statistics of indoor and outdoor contaminant concentrations (mean and
median concentrations; N=number of homes with available data) are presented in Table 1.
Q C3 0
LL
m
E
Q -
n_
�H
A CANH
❑ 20 49 so S❑ 169 126
Formaldehyde (ppb)
C3 -
0
i[1 15
NO2 (ppb)
t 8-
lL
is
U
o-
n to 2D 310
PM2.5 (ughn3)
Figure 1. Comparisons of indoor contaminant concentrations measured by two studies.
Table 1. Summary statistics of indoor and outdoor contaminant concentrations.
HENGH - Indoor
CNHS - Indoor
HENGH - Outdoor
CNHS - Outdoor
N Median Mean
N Median Mean
N Median Mean
N Median Mean
Formaldehyde (ppb) 39 20.0 20.6
104 29.5 36.3
38 2.0 2.0
43 1.8 2.8
NO2 (ppb) 40 3.7 4.4
29 3.2 5.4
40 3.0 3.1
11 3.1 3.5
PM2_; (ug/m3) 41 4.7 5.8
28 10.4 13.3
42 5.9 7.7
11 8.7 7.9
4 DISCUSSION
The lower formaldehyde concentrations measured by HENGH in comparison to CNHS, may
be attributable to California's regulation to limit formaldehyde emissions from composite
wood products that came into effect between the two studies. Gas cooking is a significant
source of indoor NO2 (Mullen et al., 2016). Even though NO2 concentrations measured by
HENGH are similar to levels found in CNHS, the two studies differed in that HENGH homes
all use gas for cookin& whereas almost all homes (98%) from the prior study used electric
ranges. More analysis is needed to determine the effectiveness of source control, such as
range hood use during cooking, on indoor concentrations of cooking emissions such as NO2
and PM2.5. Lower PM2.5 indoors measured by HENGH compared to CNHS may be explained
from a combination of lower outdoor PM2.5 levels, reduced particle penetration due to tighter
building envelopes (Stephens and Siegel, 2012) combined with exhaust ventilation, and use of
medium efficiency air filter (MERV 11 or better) in some HENGH homes. Further analysis of
the data will evaluate the role of mechanical ventilation, including local exhaust and whole -
dwelling ventilation system, on measured indoor contaminant levels.
5 CONCLUSIONS
New California homes now have lower indoor formaldehyde levels than previously measured,
likely as a result of California's formaldehyde emission standards. Indoor concentrations of
NO2 and PM2 5 measured are also low compared to a prior study of new homes in California.
ACKNOWLEDGEMENT
LBNL work on the project was supported by the California Energy Commission. Field data
collection was performed by the Gas Technology Institute. Support for field teams was
provided by Pacific Gas & Electric and the Southern California Gas Company.
6 REFERENCES
Mullen NA et al 2016 Indoor Air 26(2):231-245.
Offermann FJ. 2009. California Air Resource Board and California Energy Commission
Report CEC-500-2009-085.
Stephens B. Siegel JA. 201217door.9ir 22(6):501-513.
City of EI Segundo
Comment Letter No. 11
Lozeau Drury LLP
Richard Drury
on behalf of Supporters Alliance For Environmental ("SAFER") (sic)
1939 Harrison Street, Ste. 150
Oakland, CA 94612
May 21, 2019
Response to Comment 11-1
June 2019
The comment states the letter is written on behalf of Supporters Alliance For Environmental ("SAFER")
(sic). The comment introduces provides a summary description of the Project. This comment is noted for
the administrative record and will be forwarded to the decision makers for review and consideration.
Response to Comment 11-2
The comment suggests the Final EIR contains numerous errors and omissions. Furthermore, the comment
suggests the Final EIR fails as an informational document and fails to impose feasible mitigation measure
to reduce the Project's impacts, but provides no specifics. The comment suggests that the City of EI
Segundo should address the shortcomings in a revised Draft EIR and recirculate the revised Draft EIR prior
to approval. The comment also suggests the Final EIR fails to provide a reasoned and good faith analysis
and fails to meet the legal standards, but provides no specifics. The comment also suggest the response
to comments on a Draft EIR must state reasons for rejecting suggested mitigation measures and
comments on significant environmental issues. While this comment does not identify any specific
shortcomings of the Final EIR analysis or mitigation measures, the follow-on comments identify specific
issues related to the Draft EIR. Responses to those comments are provided individually. As such, no
specific response to this comment is possible or required. Furthermore, as outlined in the responses
below, the Final EIR complied fully with all of CEQA's requirements.
The comment will be forwarded to the decision -makers for consideration.
Response to Comment 11-3
The comment suggests that CEQA requires the Lead Agency provide the Final EIR to all public entities that
commented on the Draft EIR at least 10 days before certifying the EIR. The requirement to provide
proposed responses to comments to agencies that commented on the Draft EIR 10 days prior to certifying
the EIR (Public Resources Code 21092.5) did not apply at the time the comment letter was submitted
because the EIR was not considered for certification at the May 23, 2019 Planning Commission meeting.
Certification of the EIR will take place at a City Council meeting at a later date to be determined. Proposed
responses to comments will be provided to commenting agencies (and the public) at least 10 days before
this date. The comment will be forwarded to the decision -makers for consideration.
Response to Comment 11-4
The commenter states the SCAQMD and DTSC raise serious concerns about the toxic chemical soil
contamination. The commenter suggest these concerns are largely ignored in the Final EIR and the Draft
EIR ignores the soil contamination and the SCAQMD Rules governing the soil contamination, Rules 1166
and 1466 (Draft EIR IV.A.10-12). References to these rules (Rule 1166 —Volatile Organic Compounds from
Decontaminated Soil, and SCAQMD Rule 1466 - Control of Particulate Emissions from Soils with Toxic
Contaminants) were added to the regulatory requirements section in the Final EIR. The project applicant
would be required to comply with SCAQMD Rule 1166 and Rule 1466 because these are existing regulatory
Beach Cities Media Campus Project II. Response to Comments
Page II -68
City of EI Segundo June 2019
requirements. Even though the references were added to SCAQMD Rules 1166 and 1466 in the Final EIR,
they are not mitigation measures. Recirculation of the Draft EIR would not be necessitated by this
addition. Further, as indicated in the Draft EIR (page IV.E-24), while a Phase I report identified concerns
with regard to TPH, lead and PCBs, a soil remediation plan was developed and implemented which
resulted in the removal and proper off-site disposal of 504 cubic yards of impacted soil. Based on the data
collected and work performed by the previous owner (Air Products and Chemicals), the Regional Water
Quality Control Board, which has jurisdiction over the project site, issued a No Further Action
determination for the project site soils on August 31, 2017, which was included as Appendix E.2 to the
Draft EIR. As indicated in the No Further Action letter, the site has been cleaned up and abated so as to
meet the requirements for a soil closure letter for commercial use of the site. As further noted in the
letter, a covenant and environmental restriction has been placed on the property limiting the use to
commercial applications.
Further, as discussed in Response to Comment 9-2, all USTs installed by the prior occupant of the site have
been removed from the Project Site. The NFA letter establishes that no residual hazards related to
contaminated soil or toxic contaminants are currently present on the project site. Since the project has
been properly remediated to the satisfaction of the Regional Water Quality Control Board, a preliminary
endangerment assessment and voluntary clean-up plan is not required, and no mitigation is required. The
Draft EIR correctly concludes that impacts would be less than significant.
Furthermore, the Phase I Environmental Site Assessment Report prepared on September 22, 2017, after
the No Further Action letter, determined that there were no Recognized Environmental Conditions (Rec's)
located on the Project Site.
Response to Comment 11-5
The commenter states neither the Draft nor Final EIR contain any health risk assessment (HRA). The Draft
EIR states that no HRA is required fortoxic contaminants associated with construction equipment because
construction will take place over 18 months. (DEIR IV.A.21.). An HRA is a technical study that evaluates
how toxic emissions are released from a facility, how they disperse throughout the community, and the
potential for those toxic pollutants to impact long-term human health. Determination of risk from
construction emissions over a 30 -year exposure period would not be appropriate since construction
activities would be limited to a period of approximately 18 months. Thus, duration of construction
activities would represent a fraction of the 30 -year exposure period used as the basis for assessing the
significance of carcinogenic risk exposure and, therefore, would not represent a source of sustained toxic
emissions. Accordingly, the SCAQMD does not require preparation of a health risk assessment for
construction emissions. Therefore, exposure to toxic emissions during construction would be less than
significant. Furthermore, there are no sensitive receptors adjacent to the project site that would be
potentially impacted by construction emissions.
The commenter purports to provide a description of the California Office of Environmental Health Hazard
Assessment ("OEHHA") guidance on HRAs. The commenter suggests that this guidance mandates that
all short-term projects lasting at least two months be evaluated for cancer risks to nearby sensitive
receptors. The commenter provides no specific reference for this requirement. According to the "Air
Toxic Hot Spots Program: Risk Assessment Guidelines, Guidance Manual for Preparation of Health Risk
Assessments, prepared by OEHHA, and adopted in March 2015, page 1-3, Section 1.3, Who Is Required to
Conduct a Risk Assessment:
"The Hot Spots Act requires that each local Air Pollution Control District or Air Quality
Management District (hereinafter referred to as District) determine which facilities will prepare
Beach Cities Media Campus Project II. Response to Comments
Page II -69
City of EI Segundo
June 2019
an HRA. As defined under the Hot Spots Act, an HRA includes a comprehensive analysis of the
dispersion of hazardous substances in the environment, their potential for human exposure, and
a quantitative assessment of both individual and population -wide health risks associated with
those levels of exposure.
Districts are to determine which facilities will prepare an HRA based on a prioritization process
outlined in the law. The process by which Districts identify priority facilities for risk assessment
involves consideration of potency, toxicity, quantity of emissions, and proximity to sensitive
receptors such as hospitals, daycare centers, schools, work -sites, and residences. The District may
also consider other factors that may contribute to an increased potential for significant risk to
human receptors. As part of this process Districts categorize facilities as high, intermediate, or
low priority. (emphasis added)"
High priority facilities are required to prepare an HRA and submit to the SCAQMD for review and approval.
As noted above, the SCAQMD has not established any requirement to prepare an HRA for construction
activity. Moreover, there are no sensitive receptors adjacent to the project site that could potentially be
impacted by the construction emissions. Closest receptors are the multi -family residential dwelling units
located approximately 0.18 miles (-290 meters) southwest and the multi -family attached and single-
family detached residential dwelling units located approximately 0.2 miles (-322 meters) south of the
Project Site. After construction is complete, the Project itself would not be not a source of toxic emissions
and therefore it not required to provide a health risk assessment for its operations. The comment
provides no substantial evidence of a health risk from either project construction or project operations,
therefore no HRA or mitigation measures are required.
Response to Comment 11-6
The commenter states that the EIR admits that the Project will have significant greenhouse gas ("GHG")
impacts. (FEIR 1-17, 18), "Proposed Project's unmitigated emissions are 6,007.71 metric tons of CO2
equivalents per year resulting in 5.82 MTCO2e/SP/year." (DEIR IV.D-31). The commenter states this is far
above the SCAQMD significance threshold for GHGs of 3,000 MT/year. While the Draft EIR acknowledges
that the Proposed Project's unmitigated emissions would exceed both the SCAQMD Tier 3 and Tier 4
thresholds, the mitigation measures identified in the Draft EIR, MM D-1 through MM D-4 together with
the reductions from the CAPCOA-based reduction measures, would reduce emissions to a level of 3.88
MTCO2e/SP/year, which is below the SCAQMD Tier 4 threshold of 4.8 MTCO2e/SP/year for projects (Draft
EIR, page IV.D-41). The exceedance of the 3,000 MTCO2e threshold is irrelevant because this is a
screening threshold that merely pushes the analysis to the Tier 4 threshold. Furthermore, the Project is
not required to incorporate all mitigation measures, just sufficient measures that will reduce the impact
to less than significant. This is established in the CaIEEMod analysis provided in the Draft EIR and no
substantial evidence is presented that would call this conclusion into question.
Response to Comment 11-7
The commenter states CalTrans submitted a comment concerning the Project's significant traffic impacts.
The commenter also states, in response the Final EIR proposes a Traffic Demand Management (TDM) plan,
but provides no detail for the TDM plan. The commenter states the Final EIR's TDM plan is deferred
mitigation prohibited by CEQA. The commenter is referred to Section IV.K. Transportation, Traffic and
Parking, page IV. K-46 which provides Mitigation Measure MM -K-1, which is the Transportation Demand
Management Program. These measures would need to reflect the characteristics of the Project as finally
constructed and occupied that cannot be presently known. Therefore, the Final EIR includes the
requirement that the City must approve the TDM plan prior to project opening.
Beach Cities Media Campus Project II. Response to Comments
Page II -70
City of EI Segundo
Response to Comment 11-8
June 2019
The commenter states the EIR fails to analyze impacts of indoor air quality. The commenter suggests such
impacts may be related to soil -vapor intrusion from toxic soil contamination. However, as noted above,
no residual soil vapor impacts would result from Project Site conditions since the site was previously
remediated to the satisfaction of the RWQCB. The commenter suggests that formaldehyde is present in
residential and office building construction materials. These materials are regulated by the California Air
Resources Board to minimize such emissions. No thresholds have been adopted by any regulatory agency
as to what levels of such emissions would result in health impacts and no substantial evidence is provided
that construction materials used in project construction would pose any health hazards to future
occupants. Moreover, the study cited in the comment merely concludes that contaminant levels
measured inside homes have declined from levels identified in a previous study conducted in 2009. This
study makes no attempt to assess whether measured levels of formaldehyde, NOz or PM2.s exceed any
established regulatory levels or pose any health risk to occupants. As provided in CEQA Guidelines Section
15064(f)(5), unsubstantiated opinion or narrative does not constitute substantial evidence. Since the
commenter provides no substantial evidence regarding the alleged inadequacy of the EIR, the claims
contained in the comment letter would provide no basis for changes to the Draft EIR or the Final EIR.
Restionse to Comment 11-9
The commenter states for the forgoing reasons the EIR fails to meet the requirements of CEQA. The
commenter urges the City to require preparation of a Revised Draft EIR that addresses the identified
deficiencies. As noted above, none of the issues identified in the comment letter provide substantial
evidence that the Project would result in a new significant impact or substantial increase in severity of an
impact previously identified in the Draft EIR. In addition, the commenter provides no substantial evidence
that a feasible alternative or mitigation measure considerably different from others previously analyzed
would clearly lessen the environmental impacts of the project, but the project's proponents decline to
adopt it, or the Draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded. As provided in CEQA Guidelines Section
15064(f)(5), unsubstantiated opinion or narrative does not constitute substantial evidence. Since the
commenter provides no substantial evidence regarding the alleged inadequacy of the Draft or Final EIR,
the claims contained in the comment letter would provide no basis for requiring recirculation of the Draft
EIR under CEQA Guidelines Section 15088.5.
Beach Cities Media Campus Project II. Response to Comments
Page II -71
III. REVISIONS, CLARIFICATIONS AND CORRECTIONS ON THE
DRAFT EIR
This section of the Final EIR provides changes to the Draft EIR that have been made to clarify, correct, or
add to the environmental impact analysis for the Project. Such changes are a result of public and agency
comments received in response to the Draft EIR and/or new information which clarifies, amplifies, or
insignificantly modifies language in the Draft EIR that has become available since publication of the Draft
EIR. These changes to the Draft EIR are indicated in this section under the appropriate Draft EIR section
or appendix heading. Deletions are shown with strikethrough and additions are shown with underline.
The changes described in this section do not require recirculation of the Draft EIR because they do not
result in any new or increased significant environmental impacts of the Project. CEQA requires
recirculation of a Draft EIR only when "significant new information" is added to a Draft EIR after public
notice of the availability of the Draft EIR has occurred (refer to California Public Resources Code Section
21092.1 and CEQA Guidelines Section 15088.5), but before the EIR is certified. Section 15088.5 of the
CEQA Guidelines specifically states: "New information added to an EIR is not 'significant' unless the EIR is
changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial
adverse environmental effect of the project or a feasible wayto mitigate oravoid such an effect (including
a feasible project alternative) that the project's proponents have declined to implement. 'Significant new
information' requiring recirculation includes, for example, a disclosure showing that:
■ A new significant environmental impact would result from the project or from a new mitigation
measure proposed to be implemented.
• A substantial increase in the severity of an environmental impact would result unless mitigation
measures are adopted to reduce the impact to a level of insignificance.
• A feasible project alternative or mitigation measure considerably different from others previously
analyzed would clearly lessen the significant environmental impacts of the project, but the
project's proponents decline to adopt it.
• The draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded."
As demonstrated in this Final EIR, neither the comments submitted on the Draft EIR, the responses to
these comments, nor the revisions presented in this section, meet the above criteria for recirculation.
I. INTRODUCTION AND SUMMARY
Section 1. Introduction and Summary, page 1-21, MM E-1 and MM E-2, revise as follows:
Construction - The Phase I ESA noted that all structures have been removed from the existing Project Site,
and no asbestos or ACMs were found in the soil. Therefore, the potential for the presence of asbestos or
ACMs to be located in the soil of the Project Site is considered to be low. However, based on these
investigations, on-site soil was found to be impacted with TPH, lead, and PCBs. As stated above, an
investigation report and remedial action workplan was prepared on behalf of Air Products and Chemicals
and submitted to the RWQCB, and 504 cubic yards of impacted soil was reportedly excavated and
disposed off-site as non -hazardous waste at Azusa Land Reclamation, Azusa, California. Based on the data
collected and work performed by Air Products and Chemicals, the RWQCB issued a NFA determination for
soil on August 31, 2017.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -1
City of EI Segundo June 2019
1R ace "Lr/,-& wit"��a►la+i: � ragvirer /2-4A, pr:::r ti lnc:: "!CZ Aril ►till �o NtrrTIAicd " a"'ClyXi fes'
TPS., IiNel �vto_0 MEA, V'XAS ill T�111, %i c', ori 11' .Soule ✓ rcrn%w2 ..�n cggerdow;C v.44
awin!;lc ✓eoificzlly, 521 ?SKA. hag e0i5;4+v_4 lir-AW of aitrAv-:To tw 1210,
een'oi: --_' ir. d-zs i or?- fiimse *=-.dgh Cnli1k— nia Ccac of fla, ►��:igr�, Title R, launw
nta .4ed d_bric Victgc rust tiry to r zn::Z::' _-,rd :'igpvccd if in caaNrt4r„*e-A4tR
a ii[ l V c►4si0A: aJ *Z C-011-7\4 40tk =IA faf"y Citi F-'AAh1W'4:'i, any mnteriiai WAr"to "e
ac�hi TPH-ef4LOB! rra�t �,c : r���� f-ai die���c' kn ►►qty cll appii=t" c IcN-I, &Wr- w,d
�icrcl rarilotiens : ,��,,.,:� e,..t rrt lirni%A f. &wi: `'coli if 15.31 *tiar;c, Titic 22, =4 :171, I.Q CFR -
With ttr � ;�lori� Yf ti►n_si �ig►1c*i�r! rcc,�%r.�rx�+a enAI;rnpIc: "_ A2iiar. if M:41,An PAM
E-4, Thus impacts from the release of hazardous materials into the environment would be less than,
sienificant.
There is a Standard Oil Company and Standard Gasoline Company pipe line easement located along the
Project Site frontage. The easement, recorded on December 27, 1968, was to construct, maintain,
operate, repair, add to and remove one or more pipelines as well as overhead wires, conductors, cables
and conduits, and appurtenances thereof, into the easement. The easement covers a strip of land 43
feet wide, and runs the entire length of the Project Site. The easement includes an existing 3” Chevron
oil line and an existing 4" Chevron oil line. Furthermore, there is an easement that runs along the backside
of the Project Site, parallel with the railroad tracks. This easement contains a 16" crude oil pipeline for
the Four Corners Pipe Line company and was recorded on March 21, 1958. Thus, excavation of the Project
could result in the accidental release of oil from one of the pipelines, which would result in potentially
significant impacts. However, with the implementation of Mitigation Measure MM E-21 impacts would
be reduced to a level of less than significant.
Section 1. Introduction and Summary, page 1-21, MM E-1 and MM E-2, revise as follows:
AAAA -G 1, Ir. %%q*. -,ViEr IC t113i►V-i;a:. s!11 e.Z:ll h= ^irr,�led atm
....c1•r ::! for T IH, ler.fd *r.oi f��^iL ^►ring r� twaa►.icr cri! i:[�a�i�ian if We Ncjiat, the
Pe, Nl :rt ih=i1 neil fy theAO1"1VIA- �r �i.stal�.:� cel"aril "Y_ c ica \Nwtie r -i am T14fL,
�UW, i` PCE: ::-Z CrAV.,4► L'Fed in the sell and, ,..ff8undwateF ElUr%r/A
MM E-21: Prior to the issuance of grading permits, the Applicant shall submitfinal design plans and a design -level
geotechnical engineering report to the City of EI Segundo Building and Safety Division for review and
approval. The design -level geotechnical engineering report shall provide the location of the Standard
Oil Company and Standard Gasoline Company pipe line easement.
Section 1. Introduction and Summary, page 1-46, MM K-1, revise as follows:
MM K-1: Transportation Demand Management Program. A TDM orogram will be
implemented as part of the mitieation oackase for the Proiect. Several TDM,
oroeram elements are oro iect design features that are currently proposed for.
implementation. Other TDM program elements would be developed as part,
of Preparation of a detailed TDM Plan, to be approved by City of El Segundo.
prior to approval of a final certificate of occupancv for the Proiect..
TDM strategies are aimed at discouraging single -occupancy vehicle trips and
encouraging alternative modes of transportation such as carpooling, taking
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -2
City of EI Segundo
June 2019
transit, walking, and biking. Strategies that are suggested as appropriate for
this site, as targeted for the office land use, include:
• Commuter Trip Reduction (CTR) Program, Voluntary —The Project could
implement a CTR program that encourages alternative modes of
transportation such as carpooling, taking transit, walking, and biking. The
voluntary program does not require monitoring and reporting and no
performance standards are established. The CTR program would provide
employees with assistance in the following.
• Carpool encouragement,
■ Ride -matching assistance,
■ Preferential carpool parking,
■ Flexible work schedules for carpools,
• Half time transportation coordinator; and
Is Vanpool assistance.
• Due to the importance of information sharing and marketing,
marketing strategies to reduce commute trips would be included as
part of the CTR Program. Some marketing strategies may include:
• New employee orientation of trip reduction and alternative mode
options,
■ Event promotions; and
• Publications.
• Car Share Program —This Project could implement a car -sharing program
to allow people to have on -demand access to a shared fleet of vehicles
on an as -needed basis. User costs are typically determined through
mileage or hourly rates, with deposits and/or annual membership fees.
The car -sharing program could be created through a local partnership or
through one of many existing car -share companies. Employer -based
programs provide a means for business/day trips for alternative mode
commuters and provide a guaranteed ride home option.
• Site Design — Project site will be designed to encourage walking, biking,
and transit. Amenities could include new, wider sidewalks and street
trees along the site perimeter and bicycle parking, showers, and secure
lockers.
II. PROJECT DESCRIPTION
Section II. Project Description, page II -8, revise as follows:
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -3
City of EI Segundo
June 2019
Per the ESMC, the number of bicycle spaces required is a minimum of four spaces for buildings up to
15,000 square feet, plus a minimum of five percent of the required vehicle spaces for the portion above
15,000 square feet. Per the ESMC, a Fmaximum minimum of 25 bicycle spaces is required. The Project
would meet or exceed these requirements. In addition, as part of the Project, bicycle racks would be
installed in accordance with the ESMC and CalGreen requirements.
III. ENVIRONMENTAL SETTING
Section III. Environmental Setting, Table III -1, Related Projects, pages III -11 through III -12, revise as
follows:
No. �' Address,
1. 540 East Imperial Avenueb
2. 201 North Douglas Streetb
3, 400 Duley Road
4. 123 Nevada Streetb
5. 2125 Campus Drive
6. 2130 East Maple Drive and 725
Campus Square Westb
7. 140 Sheldon Streetb
8. 740 North Sepulveda Boulevard
9. 1492 Hermosa Avenue'
10. 2101 Pacific Coast Highway'
11. 8241St Street'
12. 707 North Sepulveda Boulevard'
13. 1800 Manhattan Beach Boulevard'
14. 2205 North Sepulveda Boulevard'
15. 1762 Manhattan Beach Boulevard'
16. 757 Manhattan Beach Boulevard'
17. 1101 Manhattan Beach Boulevard'
18. 1100 Manhattan Beach Boulevard'
19. 2100 East EI Segundo Boulevard'
20. 500 South Douglas and 2330 Utah
Avenue
21. 2171-2191 Rosecrans Avenue
22. 2516-2520 Nelson Avenue
23. 2430 Marine Avenue'
24. 305 South Sepulveda Boulevard,
330 South Sepulveda Boulevard, and
Hermosa Beach Sites"
Table III -1
Related Projects
ll.anrd lUse
Residential
High School
Medical Office
Office
Office
Hotel
Office
Office/Warehouse
Drive through Restaurant
Hotel
Office
Office
Supermarket
Restaurant
Bank
General Office
General Office
Medical Office
Apartment
Condominium
Medical Office
Retail
Office
Warehouse
Industrial
Retail
General Office
Restaurant
Condominium
Hotel
Design Center
Executive Offices
Coffee Shop
General Office
Site
58 du
1,200 stu
63,540 sf
15,000 sf
153,530 sf
180 room
22,670 sf
7,120 sf
5,000 sf
30 rm
10,120 sf
3,000 sf
27,500 sf
§4 28 seats
7,000 sf
3,000 sf
4,700 sf
1,800 sf
1 du
5 du
5,000 sf
13,000 sf
1,751,920 sf
73,580 sf
168,000 sf
148,960 sf
78,000 sf
13,570 sf
9 du
121 rm
100,300 sf
19,210 sf
1,000 sf
57,500 sf
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -4
du = dwelling units
sf =square feet
rm = rooms
stu = students
a. Related Project information provided by Erik Zandvliet City of Manhattan Beach, November 6, 2017.
b• Related Project information provided by Ethan Edwards, City of EI Segundo, January 23, 2018.
C. Related Project information provided by City of Hawthorne, January 18, 2018.
Source: Fehr and Peers, LLC., November 2018.
N.A. AIR QUALITY
Section IV.A. Air Quality, pages IV.A-12 through IV.A-13, revise as follows:
13) SCAQMD Rule 2202
On -Road Motor Vehicle Mitigation Options, is to provide employers with a menu of options to reduce
mobile source emissions generated from employee commutes, to comply with federal and state Clean Air
Act requirements, Health & Safety Code Section 40458, and Section 182(d)(1)(B) of the federal Clean Air
Act. It applies to any employer who employs 250 or more employees on a full or part-time basis at a
worksite for a consecutive six-month period calculated as a monthly average.
Although the SCAQMD is responsible for regional air quality planning efforts, it does not have the
authority to directly regulate air quality issues associated with plans and new development projects
throughout the South Coast Air Basin. Instead, this is controlled through local jurisdictions in accordance
with the CEQA. In order to assist local jurisdictions with air quality compliance issues the CEQA Air Quality
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -5
City of EI Segundo
June 2019
Table III -1
Related Projects
No.
Address.
Land Use
Size
25.
1700 East Imperial Avenue
Office
86,520 sf
26.
750 South Douglas Street'
Industrial
4,990 sf
27.
1133 Artesia Boulevard'
Grocery Store
12,000 sf
28.
865 Manhattan Beach Boulevard'
General Office
15,000 sf
Deli
700 sf
29.
1000 North Sepulveda Boulevard'
�Medicai Off ice
z-699 23,050 sf
flc2ts►r4ri- Pharrnac_v
62,,999 665 sf
Rank Coffee Shop
4BB9-Z 715 sf
30.
445 North Douglas Streetb
Office y
155,660 sf
31.
455 Continental Boulevard and 1995
Office
300,000 sf
East Grand Avenue
32.
2420 Pacific Coast Highway'
New Church
32,190 sf
Supermarket
30,080 sf
33.
3200-3600 North Sepulveda
Shopping Center
110,000 sf
Boulevard'
34.
535 Indiana Streetb
Residential
4 du
35.
700-860 South Sepulveda Boulevard,
Shopping Center
18,850 sf
2001-2015 East Park Place, and
700-740 Allied Way Boulevard
36.
14500 Aviation Boulevard`
Credit Union
3,600 sf
37.
1301 EI Segundo Boulevard
Office
6,270 sf
Warehouse
5,880 sf
du = dwelling units
sf =square feet
rm = rooms
stu = students
a. Related Project information provided by Erik Zandvliet City of Manhattan Beach, November 6, 2017.
b• Related Project information provided by Ethan Edwards, City of EI Segundo, January 23, 2018.
C. Related Project information provided by City of Hawthorne, January 18, 2018.
Source: Fehr and Peers, LLC., November 2018.
N.A. AIR QUALITY
Section IV.A. Air Quality, pages IV.A-12 through IV.A-13, revise as follows:
13) SCAQMD Rule 2202
On -Road Motor Vehicle Mitigation Options, is to provide employers with a menu of options to reduce
mobile source emissions generated from employee commutes, to comply with federal and state Clean Air
Act requirements, Health & Safety Code Section 40458, and Section 182(d)(1)(B) of the federal Clean Air
Act. It applies to any employer who employs 250 or more employees on a full or part-time basis at a
worksite for a consecutive six-month period calculated as a monthly average.
Although the SCAQMD is responsible for regional air quality planning efforts, it does not have the
authority to directly regulate air quality issues associated with plans and new development projects
throughout the South Coast Air Basin. Instead, this is controlled through local jurisdictions in accordance
with the CEQA. In order to assist local jurisdictions with air quality compliance issues the CEQA Air Quality
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -5
City of EI Segundo June 2019
Handbook (SCAQMD CEQA Handbook) prepared by the SCAQMD (1993) with the most current updates
found at htto://www.aamd.eov/ceoa/hdbk.html, was developed in accordance with the projections and
programs of the AQMP. The purpose of the SCAQMD CEQA Handbook is to assist Lead Agencies, as well
as consultants, project proponents, and other interested parties in evaluating a Proposed Project's
potential air quality impacts. Specifically, the SCAQMD CEQA Handbook explains the procedures that the
SCAQMD recommends be followed for the environmental review process required by CEQA. The
SCAQMD CEQA Handbook provides direction on how to evaluate potential air quality impacts, how to
determine whether these impacts are significant, and how to mitigate these impacts. SCAQMD is in the
process of developing an "Air Quality Analysis Guidance Handbook" to replace the CEQA Air Quality
Handbook approved by the AQMD Governing Board in 1993. The 1993 CEQA Air Quality Handbook is still
available but not online. In addition, there are sections of the 1993 Handbook that are obsolete. In order
to assist the CEQA practitioner in conducting an air quality analysis while the new Handbook is being
prepared, supplemental information regarding: significance thresholds and analysis, emissions factors,
cumulative impacts emissions analysis, and other useful subjects, are available at the SCAQMD websites.
14) SCAQMD Rule 1166
This rule sets requirements to control the emission of Volatile Organic Compounds fVOC) from excavating,
grading. handling and treating VOC-contaminated soil as a result of leakage from storage or transfer
operations, accidental spillage, or other deposition.
151 SCAQMD Rule 1466
The purpose of this rule is to minimize the amount of off-site fugitive dust emissions containing toxic air.
contaminants by reducine particulate emissions in the ambient air as a result of earth -moving activities,.
including. excavating, grading, handling, treating, stockpiling, transferring, and removing soil that contains.
applicable toxic air contaminants from sites that meet the applicability requirements of subdivision (b).,
444 16) Southern California Association of Governments
The SCAG is the regional planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino and
Imperial Counties and addresses regional issues relating to transportation, the economy, community
development and the environment. SCAG is the Federally designated MPO for the majority of the
southern California region and is the largest MPO in the nation. With respect to air quality planning, SCAG
has prepared the Regional Transportation Plan and Regional Transportation Improvement Plan ("RTIP"),
which addresses regional development and growth forecasts. These plans form the basis for the land use
and transportation components of the AQMP, which are utilized in the preparation of air quality forecasts
and in the consistency analysis included in the AQMP. The Regional Transportation Plan, Regional
Transportation Improvement Plan, and AQMP are based on projections originating within the City and
County General Plans.
IV.E.HAZARDS AND HAZARDOUS MATERIALS
Section IV.E. Hazards and Hazardous Materials, pages IV.E-24 through IV.E-25, revise as follows:
' http://www.agmd.gov/home/regulations/cego/air-quality-analysis-handbook.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -6
City of EI Segundo June 2019
Threshold (b): The Project could have a significant impact if were to create a significant hazard to the
public or the environment through reasonably foreseeable upset and accident conditions involving the
release of hazardous materials into the environment.
Impact (b): Construction of the Project would not create a significant hazard to the public or the
environment through release of hazardous materials into the environment. Impacts would be less than
significant. However, construction of the Project could release any potentially existing subsurface
hazardous substances to the environment, which would result in potentially significant impacts.
Mitigation Measures E-1 and 6 would reduce the impacts to less than significant. Operation of the
Project would not expose future occupants or site users to hazardous materials and impacts would be
less than significant.
0 Construction
As previously discussed, the Phase I ESA noted that all structures have been removed from the existing
Project Site, and no asbestos or ACMs were found in the soil. Therefore, the potential for the presence
of asbestos or ACMs to be located in the soil of the Project Site is considered to be low. However, based
on these investigations, on-site soil was found to be impacted with TPH, lead, and PCBs. As stated above,
an investigation report and remedial action workplan was prepared on behalf of Air Products and
Chemicals and submitted to the RWQCB, and 504 cubic yards of impacted soil was reportedly excavated
and disposed off-site as non -hazardous waste at Azusa Land Reclamation, Azusa, California. Based on the
data collected and work performed by Air Products and Chemicals, the RWQCB issued a NFA
determination for soil on August 31, 2017. Thus imoacts from the release of hazardous materials into the
environment would be less than significant.
art ,am- w-foruo . ' auY: / ram-iFeme , pici - }-_ cn9sv_—t::n ccii :!/All bc3 7^il erilyzc-' ic-
TW, �'✓i =A IlSs-.-' all TPP, rand, 3,.d PG135 :TSV- WC rernz-vad 't►. Ylie*
aWi-Alrl■ rcjA1_NNc\1• feria. >kf-+c +cak?, fil Of/. IA laic UPni& of Ij*4 a rx is Ica
;/. ' %stt -.Nn f/77.m '_h,,%-A1h OsrIC of Regv%lIerx, Title Q, %[/'J i �r nrm"� h
pfeydac fc- ziipssur: li:ritc, c*peawrr .:r✓ritaiit Z!P?- ir% r^n�r•�� rood/
�� Nrrati�■ ` / �rrr��!r� s� 3� ^
]:r -_d, -t'+trwl�.�.i �i- r Arrr..�� - at Src_tsct r4Sk
ef-a&@vv_ Lt2l tont ..,,,ina;ed ar t c;,?- ■*r_-;r--v;2wN4w r -/At w$v_ irs rcnojlca or/d
dsapzsad of in 4pkra c V,--vWme cf Oji_ Csli#er-niaWti! -nid rl--fV-y Ctslc.
n,c�ti arL "~i1 : i�{s `_�r� is cc �ttir. TPn �c �►►at ">! r ...cv�i0"'�vi in "ccr: sn,s
With cll wpl akls Iszal, Sx-1 X?- fc��-sl rsg:1rn4in1c noluding, �W not lkRked is 0&64 cf
Regulat+ei-i, Tills R'_, cry IM K V,7 Y.— ith the eor+p4ar:ar ci `y�►f_ r���ilzti n rUryUr�
+ Icr c,tatiar. If 11Iitidciiera--hfaasU�X' MM1, +4r,FMc •r_teald-bc rc%.osd -m _ I^ticJ cf [Etc
sigRifleaRt.
As stated above, there is a Standard Oil Company and Standard Gasoline Company pipe line easement
located along the Project Site frontage. The easement, recorded on December 27, 1968, was to construct,
maintain, operate, repair, add to and remove a single line of poles and overhead wires, conductors, cables
and conduits, and appurtenances thereof, into the easement. The easement covers a strip of land 43
feet wide, and runs the entire length of the Project Site. The easement includes an existing 3" Chevron
oil line and an existing 4" Chevron oil line. Furthermore, there is an easement that runs along the backside
of the Project Site, parallel with the railroad tracks. This easement contains a 16" crude oil pipeline for
the Four Corners Pipe Line company and was recorded on March 21, 1958. Thus, excavation of the Project
could result in the accidental release of oil from one of the pipelines, which would result in potentially
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -7
City of EI Segundo June 2019
significant impacts. However, with the implementation of Mitigation Measure MPA -E EMM E-1, impacts
would be reduced to a level of less than significant.
Section 1V.E. Hazards and Hazardous Materials, pages IV.E-28 through IV.E-29, revise as follows:
4. CUMULATIVE IMPACTS
The geographical scope of the cumulative hazards and hazardous materials analysis is the Project vicinity.
Adverse effects of hazards and hazardous materials tend to be localized; therefore, the area near the
Project Site would be most affected by project activities (generally within a 500 -foot radius).
Development of the Project in conjunction with the development of the related projects has the potential
to increase the risk for accidental release of hazardous materials. The nearest related projects to the
Project Site include related project numbers 14, 17, 19, 20, 21, 26, 33, 35, and 36. These related projects
in combination with the Project would intensify the land usage in the immediate project area. However,
mitigation measure MM E-1 and "�„�-,, M F 2 would reduce the potential impacts associated with the Project
to a less than significant level. Furthermore, each of the related projects would require evaluation for
potential threats to public safety, including those associated with the accidental release of hazardous
materials into the environment during construction and operation, transport/use/disposal of hazardous
materials, and hazards to sensitive receptors (including schools). Because hazardous materials and risk of
upset conditions are largely site-specific, this would occur on a case-by-case basis for each individual
project affected, in conjunction with the development proposals on these properties. In addition, each
related project would be required to follow local, State, and federal laws regarding hazardous materials.
With mitigation, the Project would have less than significant impacts. Therefore, the Project, in
conjunction with the related projects and other planned and/or approved projects, would not have a
cumulatively considerable impact on hazards and hazardous materials, and cumulative impacts would be
less than significant.
S. MITIGATION MEASURES
crzr.V, ;tic: to cii_
lead, eF P-85 are eneabiFiteFed in the •l aAd d • d g ccr/'t, Uei.arr 3��
MM E-21: Prior to the issuance of grading permits, the Applicant shall submit final design plans and a
design -level geotechnical engineering report to the City of EI Segundo Building and Safety
Division for review and approval. The design -level geotechnical engineering report shall
provide the location of the Standard Oil Company and Standard Gasoline Company pipe line
easement.
6. LEVEL OF SIGNIFICANCE AFTER MITIGATION
With the implementation of the Mitigation Measures MM E-1 anaMM E ,i, listed above, Project -level and
cumulative hazards impacts would be reduced to a less -than -significant level.
IV.H.NOISE
Section IV.H. Noise, page IV.H-15, revise as follows:
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -8
City of EI Segundo June 2019
Threshold (a): The Project would have a significant impact on noise if it would expose persons to or
generate of noise levels in excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies.
Impact (a): Construction noise will have a temporary or periodic increase in the ambient noise levels.
However, no residential uses are located in close nroximlty to the Proiect Site, the site is surrounded by
commercial uses. Construction -related noise impacts are considered to be less than
sianificant.
„i ..., „+. a .„ .s „.:+:..,+:.. ARA��+ +►,. ...�.� nerte �► Operation of the Project would not
expose persons to or generate noise levels in excess of standards established by the City and the
operational impact of the Project would be less than significant.
Section IV.H. Noise, page IV.H-29, revise as follows:
Threshold (d): The Project would have a significant impact on noise if it would result in a substantial
temporary or periodic increase in ambient noise levels in the Project vicinity above levels existing without
the Project.
Impact (d): Construction noise will have a temporary or periodic increase in the ambient noise levels.
However, no residential uses are located in close proximity to the Proiect Site, the site is surrounded bv.
commercial uses. Construction -related noise impacts are considered to be less than significant.
IV.I.POPULATION, HOUSING AND EMPLOYMENT
Section IV. I. Population, Housing and Employment, Section 4.Cumulative Impacts, pages IV.I-10 through
IV.I-13, revise as follows:
The geographic scope of the cumulative employment analysis is the City of EI Segundo. Table IV.I-3
presents the estimated increase in employment, housing, and population associated with the 37 related
projects identified in Section III, Environmental Setting, of this EIR. As shown in Table IV.I-3, the Project
in conjunction with the related projects would result in an increase in employment of approximately
15,709 15,680 jobs, an increase of 77 residential units and a population increase of 196 people.
Employment projections contained in the SCAG forecasts are based upon land uses designated in the
General Plan. The related projects and other potential development projects that may occur throughout
the City of EI Segundo are expected to be largely consistent with their respective General Plan land use
designations. According to projections extrapolated from the adopted 2016 growth forecast, the City is
projected to increase in employment opportunities by approximately 3,700 jobs from 2012 to 2020 (8.8
percent growth) and increase by approximately 7,000 jobs from 2012 to 2040 (15.4 percent growth).
Implementation of the Project in conjunction with the various related projects identified in Section III.
Environmental Setting would further increase employment opportunities in the City of EI Segundo and
surrounding areas. As indicated in Table IV.I-3, the Project in conjunction with the related projects would
cumulatively generate approximately 9 C� 15.680 new jobs;-witF. 7,W a
FAiRUS the RFepased PFE�ee} je'-s) Icc:1c� k1fi-mauht CW'1, _f E! Segun e. Job growth is considered a
beneficial effect, and while the project's incremental contribution to regional job growth would be
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -9
City of EI Segundo June 2019
considered cumulatively considerable, such job growth would not be considered an adverse cumulative
impact, as discussed below.
Based upon the foregoing, SCAG employment forecasts clearly underestimate the potential employment
growth in the City of EI Segundo, and to a lesser extent, in the South Bay Cities Subregion as well. While
the provision of employment is generally considered a beneficial effect of a project, this discrepancy in
employment forecasts may adversely affect SCAG's regional planning efforts. SCAG's regional forecast
"maintains the balance between employment, population, and households due to their interrelationship,
assuming that employment growth is a driving force of regional population and household growth".'
Table IV.I-3
Cumulative Population, Housing and Employment
ID Type of Use Size Employment Total Total Population Total
Generation Employment Housing Generation Population
Factora Factorb
(per 1,000 sf) (per unit)
1. Residential 58 du - 58 du 2.53 147
2. High School 1,200 stu - - - -
3. Medical Office 63,540 sf 0.00427 271
4. Office 15,000 sf 0.00479 72
5. Office 153,530 sf 0.00479 735
6. Hotel 180 rmd 0.00113 81
Office 22,670 sf 0.00479 109
7. Office/ 7,120 sf 0.00135 10 -
Warehouse
8. Drive through 5,000 sf 0.00153 S
Restaurant
1 9. Hotel 30 rmd 0.00113 14
1 10. Office 10,120 sf 0.00479 48 -
11. Office 3,000 sf 0.00479 14
12. Supermarket 27,500 sf 0.00153 42
Restaurant &228seats` 0.00153 3-
z SCAG Regional Forecast Overview, website:
htto://www.scoa.co.aovIDatcAndTooislPaaesIGrowthForecastina.osrox, accessed March 22, 2018,
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -10
City of EI Segundo June 2019
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -11
Bank
7,000 sf
0.00283
20
13.
General Office
3,000 sf
0.00479
14 -
14.
General Office
4,700 sf
0.00479
23 -
15.
Medical Office
1,800 sf
0.00427
8 -
Apartment
1 du
-
- 1 du 2.53 3
16.
Condominium
5 du
-
- 5 du 2.53 13
17.
Medical Office
5,000 sf
0.00427
21 -
18.
Retail
13,000 sf
0.00153
20 -
19.
Office
1,751,920 sf
0.00479
8,392
Warehouse
73,580 sf
0.00135
99
Industrial
168,000 sf
0.00135
227 -
Retail
148,960 sf
0.00153
228 -
20.
General Office
78,000 sf
0.00479
374 -
21.
Restaurant
13,570 sf
0.00153
21 -
22.
Condominium
9 du
-
- 9 du 2.53 23
23.
Hotel
121 rmd
0.00113
55 -
24.
Design Center
100,300 sf
0.00269
270
Executive
19,210 sf
0.00269
52 -
Offices
Coffee Shop
1,000 sf
0.00153
2
General Office
57,500 sf
0.00479
275 -
25.
Office
86,520 sf
0.00479
414 -
26.
Industrial
4,990 sf
0.00135
7
27.
Grocery Store
12,000 sf
0.00153
18
28.
General Office
15,000 sf
0.00479
72 -
Deli
700 sf
0.00153
1 -
29.
5 w p a r!-=•_
7,599 23.050
9:90353-0.00479
42110
Medical Office
sf
o,.sta W FB M
62,9995#
0.00153
890 -
Pharmacv
0.665 Seats
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -11
City of EI Segundo
35. Shopping
Center
36. Credit Union
37, Office
Warehouse
z;AA9-5
1,715s
155,660 sf
300,000 sf
32,190 sf
30,080 sf
110,000 sf
4 du
18,850 sf
3,600 sf
6,270 sf
5,880 sf
June 2019
9.99283 00153 293
0.00479
aRIf Coffee
0.00479
Shop
30.
Office
31.
Office
32.
New Church
Supermarket
33.
Shopping
Center
34.
Residential
35. Shopping
Center
36. Credit Union
37, Office
Warehouse
z;AA9-5
1,715s
155,660 sf
300,000 sf
32,190 sf
30,080 sf
110,000 sf
4 du
18,850 sf
3,600 sf
6,270 sf
5,880 sf
June 2019
9.99283 00153 293
0.00479
746 -
0.00479
1,437 -
0.00153
49 -
0.00153
46
0.00153
168
0.00153
0.00153
0.00479
0.00135
Cumulative Total
Project Total
Cumulative and Project Total
- 4 du 2.53
29
6
30
8
964,676
14,647
1,033
;699
15,680
77
77
10
196
196
Notes: sf = square feet
a Source for generation rate: Los Angeles Unified School District, Level 1— Developer Fee Justification Study, Table 14, March 2017.
b• U.S. Census Bureau, City of El Segundo, Persons per Household, 2012-2016, website:
httos://www.census.00vlauickfoctslfoctltable/eiseaundocitvcoliforn atPPST045216
accessed March 13, 2018.
Based on an estimate of 8 sf/seat.
d Based on an estimate of 400sf/room.
Source: EcoTierra Consulting, Inc. March 2018.
To the extent that employment forecasts are used by SCAG to implement the regions' growth policies,
underestimates of future employment in the City of EI Segundo and the South Bay Cities Subregion may
hinder planning for the timing, financing, and location of public facilities, utility systems, and
transportation systems. However, the Regional Comprehensive Plan is to be periodically reviewed, and
those sections that are found to be out of date are to be updated as needed. Furthermore, SCAG utilizes
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -12
City of EI Segundo June 2019
the "employment -population -household ("E PH") forecast framework which is the basis for developing the
regional growth forecast for the SCAG region". Therefore, the self-correcting nature of the forecasts
would ensure that ongoing infrastructure planning efforts will remain consistent with regional growth
trends.
In addition, as discussed in Section IV.G, Land Use and Planning, the Project would be consistent with the
applicable City of EI Segundo General Plan policies and would not include inappropriate uses for the
Project Site nor would any inconsistency regarding cumulative growth occur. Based upon this consistency,
the Project and other cumulative growth within the City of EI Segundo have been accounted for in the
City's long range planning. Furthermore, because SCAG's regional planning incorporates the City of EI
Segundo's General Plan into its growth forecasts, this cumulative growth may be deemed consistent with
SCAG's forecasts and growth policies. Therefore, no significant impacts to the City of EI Segundo (or to
SCAG's regional planning) due to cumulative employment growth are anticipated.
The employment generated by the Project in conjunction with the related projects would have the
potential to increase the resident population in the City of EI Segundo, the South Bay Cities Subregion and
surrounding areas, and consequently, the City and subregional demand for housing. As can be seen from
Table IV.I-1, both population and employment in the City and South Bay Cities Subregion and surrounding
area are expected to rise faster than housing between the years 2012 and 2040. This suggests that
housing availability will become increasingly tight, and the average number of residents per dwelling can
be expected to increase. A review of the related projects listed in Table IV.I-3, confirms the projections
for slow housing growth in the region; only 77 new housing units are currently proposed. In addition,
approximately 35,7A915,690 lobs would be created by the same list of cumulative projects. However,
between 2015 and 2040, the number of households in the South Bav Cities Subregion fegien will increase
by',�^ 23,532 households.3 Based on the substantial disparity between projected job growth and
housing construction locally, it is concluded that there will be a significant cumulative impact on
population growth and housing demand. However, because the type of jobs that would be generated by
the Project are of a similar nature to jobs found in the area, the Project would not likely result in the
relocation and addition of permanent residents to fill the jobs generated by the Project, the incremental
contribution of the Project would not contribute substantially to this significant impact.
IV.K.TRANSPORTATION, TRAFFIC AND PARKING
Section IV.K, Transportation, Traffic and Parking, page IV.K-46, MM K-1, revise as follows:
MM K-1: Transportation Demand Management Program. A TDM program will be
implemented as hart of the mitigation nackapee for the Proiect. Several TDM
program elements are nroiect design features that are currently proposed for
implementation. Other TDM Drop ram elements would be deveIooed as ❑art,
of preparation of a detailed TQM plan, to be approved by City of El Segundo,
prior to aDDroval of a final certificate of occuoancv for the Proiect.. CSC
approval will be contingent upon submission of an accomDanvine analvsis.
based on CAPCOA and latest available relevant research confirming that the,
3 Southern California Association of Governments, 2016-2040 Regional Transportation Plan/Sustainable
Communities Strategies, Final Growth Forecast by Jurisdiction website:
http://www.scog.ca.gov/Documents/2016 204ORTPSCS FinalGrowthForecostbyJurisdiction.pdf, accessed:
December 6, 2018.
Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections on the Draft EIR
Page III -13
City of EI Segundo
June 2019
elements in the TDM plan will yield the intended 6.5% reduction in weekday
peak hour trips that the traffic analvsis was based on.,
TDM strategies are aimed at discouraging single -occupancy vehicle trips and
encouraging alternative modes of transportation such as carpooling, taking
transit, walking, and biking. Strategies that are suggested as appropriate for
this site, as targeted for the office land use, include:
• Commuter Trip Reduction (CTR) Program, Voluntary —The Project could
implement a CTR program that encourages alternative modes of
transportation such as carpooling, taking transit, walking, and biking. The
voluntary program does not require monitoring and reporting and no
performance standards are established. The CTR program would provide
employees with assistance in the following.
■ Carpool encouragement,
■ Ride -matching assistance,
■ Preferential carpool parking,
■ Flexible work schedules for carpools,
■ Half time transportation coordinator; and
■ Vanpool assistance.
It Due to the importance of information sharing and marketing,
marketing strategies to reduce commute trips would be included as
part of the CTR Program. Some marketing strategies may include:
• New employee orientation of trip reduction and alternative mode
options,
• Event promotions; and
• Publications.
■ Car Share Program—This Project could implement car -sharing program
to allow people to have on -demand access to a shared fleet of vehicles
on an as -needed basis. User costs are typically determined through
mileage or hourly rates, with deposits and/or annual membership fees.
The car -sharing program could be created through a local partnership or
through one of many existing car -share companies. Employer -based
programs provide a means for business/day trips for alternative mode
commuters and provide a guaranteed ride home option.
• Site Design — Project site will be designed to encourage walking, biking,
and transit. Amenities could include new, wider sidewalks and street
trees along the site perimeter and bicycle parking, showers, and secure
lockers.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -14
City of EI Segundo June 2019
IV.M.1 UTILITIES AND SERVICE SYSTEMS, WATER
Section IV.M.1, Utilities and Service Systems, Water, page IV.M-2, revise as follows:
The City does not currently serve recycled water to the Project Site. Recycled water use for irrigation at
the Project Site is proposed—the recycle water demand is estimated at 16.5 AFY. As shown in irreri
Rcfcrar4e v-vli pct 2-r.r/Y� Fieure IV.M.1-1, Recycled Water Pipe Network, the Project area is directly
adjacent to an existing recycled water pipeline.
Section IV.M.1, Utilities and Service Systems, Water, page IV.M-4, revise as follows:
The average annual potable water supply to the City of EI Segundo in 2015 was 17,463 acre-feet. The 2015
UWMP used years 2001 through 2003 as a basis for dry -year conditions. Therefore, the increased demand
determined during these dry years would be served by increasing the supply from WBMWD, as shown in
EFFer° °e{� tv�: tetx ee :moi f:—.\,;,A—.Table IV.M.1-2. Current Supply -Normal and Multiole Dry Year.
Section IV.M.1, Utilities and Service Systems, Water, page IV.M-5, revise as follows:
The single dry year demands were estimated based on a 4 -percent increase in water demand from normal
year conditions. WBMWD anticipates meeting single dry year demands by increasing supplies. WBMWD
can meet the increased demands because of the surplus in supply that has been planned for in previous
years to ensure WBMWD can meet customer demands with varied climate conditions. Total retail water
agencies' water supply was projected by WBMWD for Year 2035. FFF90 Rem Fene. iau7mt nct f -.4
Table IV.M.1-4, Supply and Demand — Single Dry Year, provides a summary of projected water deliveries
(supply) and demand conditions under single dry year conditions for years 2020 to 2040 on a five-year
basis.
Section IV.M.1, Utilities and Service Systems, Water, page IV.M-5, revise as follows:
To estimate multiple -dry -year supply and demand quantities for 2035 and 2040, data from 2020, 2025,
and 2030 were extrapolated based on a linear trend. The extrapolations are shown in EFFOO Rete.,,,^�
uzrrx Table IV.M.1-S,Supply and Demand — Multiple Dry Year.
Section W.M.1, Utilities and Service Systems, Water, page IV.M-6, revise as follows:
, Table IV.M.1-7, Water Use Prohibitions by Rationing Stage, outlines
mandatory prohibitions on water uses based on the rationing stages.
IV.M.2 UTILITIES AND SERVICE SYSTEMS, WASTEWATER
Section IV.M.2, Utilities and Service Systems, Wastewater, page IV.M-21, revise as follows:
ii) Wastewater Treatment Facilities
The Project Site is served by JWPCP located in the City of Carson, approximately 9 miles southeast of the
Project Site.4 The JWPCP is one of the largest wastewater treatment plants in the world, and the largest
Sanitation Districts of Los Angeles County, Wastewater Treatment Facilities Map, available at:
h ttp://www.lacsd. org/wastewa ter/wwfacili ties/default. asp#map.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -15
City of EI Segundo June 2019
of the LACSDs' wastewater treatment plants, serving approximately 3.5 million.' The facility provides both
primary and secondary treatment and has a total permitted capacity of 400 mgd. Currently, the plant
treats approximately 2544 261.1 mgd of wastewater and is operating at approximately 64 65 percent of
capacity.6
Section IV.M.2, Utilities and Service Systems, Wastewater, page IV.M-25, revise as follows:
The JWPCP currently treats approximately 254.1 261.1 million gpd of wastewater, and has a total
permitted capacity of 400 million gpd. Thus, the plant is currently operating at approximately 64 65
percent of capacity and has approximately 146.9 138.9 million gpd of available capacity. The Project's net
increase in wastewater of 70,075 gpd would represent approximately 8.G5 0.03 percent of this available
capacity. Accordingly, adequate available sewage treatment capacity exists at the JWPCP to serve the
Project. The operation of the Project would not require or result in the construction or of new or the
expansion of existing wastewater treatment facilities.
Section IV.M.2, Utilities and Service Systems, Wastewater, page IV.M-26, revise as follows:
The response to this Impact would be similar to the response to Impact (b) above. As described there, an
increase in wastewater flow from the Project Site during construction would be negligible and temporary.
The operational increase in wastewater of 70,075 gpd would represent approximately 9:95-0.03 percent
of the available capacity of JWPCP. Accordingly, adequate available sewage treatment capacity exists at
the JWPCP to serve the Project. As such, the Project would have a less than significant impact on the
capacity of the wastewater treatment provider.
IV.M.1 UTILITIES AND SERVICE SYSTEMS, SOLID WASTE
Section IV.M.1, Utilities and Service Systems, Solid Waste, page IV.M-33, revise as follows:
i) Construction
Project development would generate minor amounts of construction debris compared to most
construction project, as the site is currently an undeveloped dirt lot. Solid waste produced during
construction would primarily be due to daily operations. In accordance with PDF M-4, the Project would
be required to implement a construction waste management plan. Much of this material would be
recycled and salvaged to the maximum extent feasible from the landfill. The Countywide Integrated
Management Plan 2016 Annual Report concludes that there is current capacity of 56.34 million tons
available throughout the County for the disposal of inert waste.' Therefore, the minor amount of Project -
generated demolition debris and construction waste would represent a very small percentage of the inert
waste disposal capacity in the region. All solid waste-eeneratinP activities within the Citv. includine the
Proiect. would continue to be subiect to the requirements set forth in CALGreen Building Code which
requires a 65 percent construction waste diversion from landfills. Therefore, the Project would not create
5 Sanitation Districts of Los Angeles County, Joint Water Pollution Control Plant (JWPCP), available at:
http://Www.locsd. org/wastewaterlwwfacilitiesljwpcpldefaul t. asp.
6 City of EI Segundo, Continental Grand Campus Specific Plan Draft EIR, September 2017, page 4. K.2-2.
' County of Los Angeles Department of Public Works, Countywide Integrated Management Plan 2016 Annual
Report, December 2017, Appendix E-2, Table 1.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -16
City of EI Segundo June 2019
a need for additional solid waste disposal facilities to adequately handle project construction -generated
inert waste and impacts would be less than significant.
VI. ALTERNATIVES
Section VI. Alternatives, Alternative 2, pages VI -14 through VI -15, revise as follows:
Similar to the Project, during excavation, on-site grading, building construction and operation of the
Alternative, hazardous materials, such as fuel, and oils associated with construction equipment, as well as
coatings, paints, adhesives, and caustic or acidic cleaners, would be used. Therefore, hazardous materials
would require proper handling and management and, in some cases, disposal. With compliance with
relevant regulations and requirements, construction and operational activities associated with the
Alternative would not expose people to a substantial risk resulting from the release or explosion of a
hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore,
impacts associated with hazardous waste management during construction and operation would be less
than significant fellewing 84itigatiern, similar to the Project.
Under this Alternative, dUFPRg�ir�� nt�r. vII TPH lead, apElEl PGBs would be Ferneved 'A aeeeFd - with
Flo regOtttrf �� aireme rts—�AR+th •ti ee :� �,~�e ;f CNzae-reg�Ltar/ ;cq{►i`�:�rt�, impacts
associated with the accidental release of a hazardous material would be less than significant, similar to
the Project.
Section VI. Alternatives, Alternative 3, pages VI -32 through VI -33, revise as follows:
Similar to the Project, during excavation, on-site grading, building construction and operation of the
Alternative 3 , hazardous materials, such as fuel, and oils associated with construction equipment, as well
as coatings, paints, adhesives, and caustic or acidic cleaners, would be used. Therefore, hazardous
materials would require proper handling and management and, in some cases, disposal. With compliance
with relevant regulations and requirements, construction and operational activities associated with the
Alternative would not expose people to a substantial risk resulting from the release or explosion of a
hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore,
impacts associated with hazardous waste management during construction and operation would be less
than significant fellewi+n� :ti�etun►, similar to the Project.
Under this Alternative,
, impacts
associated with the accidental release of a hazardous material would be less than significant fellewing
Fn it+gat+er7 similar to the Project.
Section VI. Alternatives, Alternative 4, pages VI -70 through VI -71, revise as follows:
Similar to the Project, during excavation, on-site grading, building construction and operation of the
Alternative 4, hazardous materials, such as fuel, and oils associated with construction equipment, as well
as coatings, paints, adhesives, and caustic or acidic cleaners, would be used. Therefore, hazardous
materials would require proper handling and management and, in some cases, disposal. With compliance
with relevant regulations and requirements, construction and operational activities associated with the
Alternative would not expose people to a substantial risk resulting from the release or explosion of a
hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore,
impacts associated with hazardous waste management during construction and operation would be less
than significant felle iRg .,. i4ig.,t , similar to the Project.
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -17
FIPM
29.
City of EI Segundo June 2019
Under this Alternative, &xinZ, zii:avctir- all Tf 4I, _W_ f GSs-wetrdg Itc nerc::va� �n N -4h
app?/;cz-z�d►Oz �:imrnvr v. wit). tVr- ccr Ajay■ --i 9nass r -,ilyrar/ �.quiFeFPeets impacts
associated with the accidental release of a hazardous material would be less than significant fediewing
-, similar to the Project.
Section VI. Alternatives, Alternative 5, pages VI -108 through VI -109, revise as follows:
Similar to the Project, during excavation, on-site grading, building construction and operation of the
Alternative 5, hazardous materials, such as fuel, and oils associated with construction equipment, as well
as coatings, paints, adhesives, and caustic or acidic cleaners, would be used. Therefore, hazardous
materials would require proper handling and management and, in some cases, disposal. With compliance
with relevant regulations and requirements, construction and operational activities associated with the
Alternative would not expose people to a substantial risk resulting from the release or explosion of a
hazardous material, or from exposure to a health hazard, in excess of regulatory standards. Therefore,
impacts associated with hazardous waste management during construction and operation would be less
than significantfe4ewing similar to the Project.
Under this Alternative, dv-ir.8 avra•,v do cdl Tr4l, Itzi, =_ N4 v "v -zr. Ovid a,%::Lvcc :n,,%- vM4
a di z!:1z -2t,,412�3: / 11. ith >ti mf ttL1_ impacts
associated with the accidental release of a hazardous material would be less than significant fedlewieg
wee, similar to the Project.
APPENDICES
Appendix H. 1 Traffic Study, page 31, Table 4, Related Projects Trip Generation Estimates, Row 12 and
Row 29, revise as follows:
707 North Sepulveda Boulevard Supermarket
27.50 ksf
Restaurant
§a 28 seats
Bank
7.0 ksf
1000 North Sepulveda Boulevard S••pe ffitet Medicai Office
SAA 23.05 ksf
RestawanR Pharmacy
52,999 0.665 ksf
BeFik Coffee Shoo
x;98&7..715 ksf
Beach Cities Media Campus Project III. Revisions, Clarifications and Corrections on the Draft EIR
Page III -18
IV. MITIGATION MONITORING AND REPORTING PROGRAM
1. MITIGATION MONITORING AND REPORTING PROCEDURES
Section 21081.6 of the Public Resources Code requires a Lead Agency to adopt a "reporting or monitoring
program for the changes to the project or conditions of project approval, adopted in order to mitigate or
avoid significant effects on the environment" (Mitigation Monitoring Program, Section 15097 of the CEQA
Guidelines provides additional direction on mitigation monitoring or reporting). The Planning and Building
Safety Department for the City of EI Segundo is the Lead Agency for the Beach Cities Media Campus
Project.
An Environmental Impact Report has been prepared to address the potential environmental impacts of
the Proposed Project. Where appropriate, this environmental document identified project design
features or recommended mitigation measures to avoid orto reduce potentially significant environmental
impacts of the Project. This Mitigation Monitoring and Reporting Program (MMRP) is designed to monitor
implementation of mitigation measures identified for the Project. The required mitigation measures are
listed separately and categorized by impact area, with an accompanying identification of the following:
• Monitoring Phase, the phase of the Project during which the mitigation measure
must be monitored;
- Pre -Construction, including the design phase
- Construction
- Post -Construction
■ The Implementing Party, the agency with the power to implement the mitigation
measure;
• The Enforcement Agency, the agency with the power to enforce the mitigation
measure, and
■ The Monitoring Agency, the agency to which reports involving feasibility,
compliance, implementation and development are made.
The MMRP for the Proposed Beach Cities Media Project will be in place throughout all phases of the
Project. The 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 MMRP 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 Planning and Building Safety
Department shall be at the discretion of the Planning and Building Safety Department. Generally, each
report will be submitted to the Planning and Building Safety 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 and Building
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -1
City of EI Segundo
June 2019
Safety Department in conjunction with the Applicant shall assure that Project construction occurs in
accordance with the MMRP. 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 EI Segundo unless otherwise
noted.
2. MITIGATION MEASURES AND PROJECT DESIGN FEATURES
A. Aesthetics
No specific Project Design Features are proposed with regard to aesthetics. No mitigation
measures are required.
B. Agricultural and Forestry Resources
No specific Project Design Features are proposed with regard to agricultural and forestry
resources. No mitigation measures are required.
C. Air Quality
No specific Project Design Features are proposed with regard to air quality. No mitigation
measures are required.
D. Biological Resources
No specific Project Design Features are proposed with regard to biological resources. No
mitigation measures are required.
E. Cultural Resources
i) Project Design Features
No specific Project Design Features are proposed with regard to cultural resources.
ii) Mitigation Measures
MM B-1: A qualified paleontologist shall be retained to perform periodic inspections
of excavation and grading activities at the Project Site. The frequency of
inspections shall be based on consultation with the paleontologist and shall
depend on the rate of excavation and grading activities, the materials being
excavated, and if found, the abundance and type of fossils encountered. If
paleontological materials are encountered, the paleontologist shall
temporarily divert or redirect grading and excavation activities in the area of
the exposed materials to facilitate evaluation and, if necessary, salvage. The
paleontologist shall then assess the discovered material(s) and prepare a
survey, study or report evaluating the impact. The Project Applicant shall
then comply with the recommendations of the evaluating paleontologist, and
a copy of the paleontological survey report shall be submitted to the Los
Angeles County Natural History Museum. Ground -disturbing activities may
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -2
City of EI Segundo
F.
June 2019
resume once the paleontologist's recommendations have been implemented
to the satisfaction of the paleontologist.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
MM B-2: A qualified professional archaeologist shall monitor all ground disturbing
activities of the Project. If buried unique archaeological resources are
discovered during ground -disturbing activities, work shall cease within 50
feet of the find until a qualified archaeologist can assess the significance of
the find and, if necessary, invoke appropriate treatment measures. Such
measure(s) may include avoidance, preservation in place, Phase III data
recovery and associated documentation, or other appropriate measures. The
City shall determine the appropriate and feasible measure(s) that will be
necessary to mitigate impacts, in consideration of the measure(s)
recommended by the Monitor. The Applicant shall implement all measure(s)
that the City determines necessary, appropriate and feasible. Within 60 days
after grading activities are completed, the Monitor shall prepare and submit
a final report to the City and the State Office of Historic Preservation. The
report shall include documentation of any recovered unique archaeological
resources, the significance of the resources, and the treatment of the
recovered resources. In addition, the Monitor shall submit the monitoring
log and photo documentation, accompanied by a photo key, to the City.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
Geology and Soils
i) Project Design Features
PDF C-1: A Project design -specific geotechnical and engineering report is required to
be prepared by a California -licensed geotechnical engineer, California -
certified engineering geologist, and civil engineer with expertise in
geotechnical issues registered in the State of California during Project design
and prior to Project construction in compliance with the most current City of
EI Segundo Department of Public Works guidelines. The investigation is
required to address the proposed Project foundation and structure design to
minimize effects from adverse soil conditions including any liquefiable or
otherwise unstable/consolidation-prone soils; bedrock characteristics;
subsidence; earthquake ground shaking; slope instability; subsurface gas;
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -3
City of EI Segundo
G.
June 2019
groundwater; and/or other geotechnical and engineering geologic hazards.
The design and construction recommendations will be incorporated into the
foundation and structural design of Proposed Project components,
implemented in accordance with the design, and subjected to on-going
inspection by the relevant entities/agencies. Prior to Grading Plan approval
and issuance of permits, all construction/development plans will be approved
by the City for construction of such improvements. Construction will occur in
accordance with the approved plans.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
ii) Mitigation Measures
No mitigation measures are required.
Greenhouse Gas Emissions
i) Project Design Features
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department, Public Works Department
Planning and Building Safety
Department, Public Works Department
No specific Project Design Features are proposed with regard to greenhouse gas
emissions.
ii) Mitigation Measures
MM D-1: The Project applicant shall provide sidewalks within the Project boundary
connecting off-site.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
MM D-2: The Project applicant shall require that all faucets, toilets and showers
installed in the proposed structures utilize low -flow fixtures that would
reduce indoor water demand by 20% per CalGreen Standards.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IVA
City of EI Segundo
June 2019
MM D-3: The Project applicant shall require that ENERGY STAR -compliant appliances
are installed wherever appliances are required on-site.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction
Applicant
Planning and
Department
Planning and
Department
Building Safety
Building Safety
MM D-4: The Project applicant shall require that high -efficiency lighting (such as LED
lighting that is 34 percent more efficient than fluorescent lighting) be
installed within buildings on-site.
Monitoring Phase:
Construction
Implementation Party:
Applicant
Enforcement Agency:
Planning and Building Safety
Department
Monitoring Agency:
Planning and Building Safety
Department
Hazards and Hazardous Materials
i) Project Design Features
No specific Project Design Features are proposed with regard to hazards and hazardous
materials.
ii) Mitigation Measures
MM E-1: Prior to the issuance of grading permits, the Applicant shall submit final
design plans and a design -level geotechnical engineering report to the City of
EI Segundo Building and Safety Division for review and approval. The design -
level geotechnical engineering report shall provide the location of the
Standard Oil Company and Standard Gasoline Company pipe line easement.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Hydrology/Water Quality
i) Project Design Features
Pre- Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
PDF F-1: Construction BMPs will be designed and maintained as part of the
implementation of the local SWPPP (which includes an Erosion Control Plan)
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -5
City of EI Segundo
PDF F-2:
June 2019
in compliance with the General Permit. The Erosion Control Plan shall be
implemented when construction commences and before any site clearing or
demolition activity. During construction, the Erosion Control Plan will be
referred to regularly and amended as changes occur throughout the
construction process.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction, Post -Construction
Applicant
Planning and Building Safety
Department, Public Works Department
Planning and Building Safety
Department, Public Works Department
The Project shall implement the following construction -specific BMPs:
• Disposing of waste in accordance with all applicable laws and regulations;
• Cleaning up leaks, drips, and spills immediately;
■ Conducting street sweeping during construction activities;
• Limiting the amount of soil exposed at any given time;
• Covering trucks;
• Keeping construction equipment in good working order; and
• Installing sediment filters during construction activities.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction, Post Construction
Applicant
Planning and Building Safety
Department, Public Works Department
Planning and Building Safety
Department, Public Works Department
PDF F-3: The Project shall meet the applicable requirements of the SUSMP adopted by
the Los Angeles Regional Water Quality Control Board through the
preparation and implementation of a Project -specific SUSMP.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction, Post Construction
Applicant
Planning and Building Safety
Department, Los Angeles Regional
Water Quality Control Board
Planning and Building Safety
Department, Los Angeles Regional
Water Quality Control Board
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -6
City of EI Segundo
PDF F-4:
June 2019
The Project shall comply with all NPDES Permit and waste discharge
requirements.
Monitoring Phase:
Construction, Post Construction
Department, Los Angeles
Implementation Party:
Applicant
Enforcement Agency:
Planning and Building
Safety
Regional
Department, Los Angeles
Regional
Water Quality Control Board
Monitoring Agency:
Planning and Building
Safety
Department, Los Angeles
Regional
Water Quality Control Board
PDF F-5: The Project shall comply with the requirements of the Los Angeles County
MS4 Permit, which controls quality of runoff entering municipal storm drains
in Los Angeles County.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction, Post Construction
Applicant
Planning and Building
Safety
Department, Los Angeles
Regional
Water Quality Control Board
Planning and Building
Safety
Department, Los Angeles
Regional
Water Quality Control Board
PDF F-6: The Project shall comply with City grading permit regulations, which require
necessary measures, plans (including a wet weather erosion control plan if
construction occurs during the rainy season), and inspection to reduce
sedimentation and erosion.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Construction, Post Construction
Applicant
Planning and Building Safety
Department, Los Angeles Regional
Water Quality Control Board
Planning and Building Safety
Department, Los Angeles Regional
Water Quality Control Board
PDF F-7: The Project shall comply with all applicable federal, state, and local
requirements concerning the handling, storage and disposal of hazardous
waste.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -7
City of EI Segundo
PDF F-8:
ii)
June 2019
All trash facilities shall be covered and isolated from stormwater runoff.
Monitoring Phase:
implementation Party:
Enforcement Agency:
Monitoring Agency:
Mitigation Measures
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
MM F-1: The applicant must prepare a hydrology study of the development on the
Project Site. Such study must be reviewed and approved by the City of EI
Segundo and any other applicable agency.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
MM F-2: The applicant must prepare runoff studies for the development on the Project
Site so that the runoff from the Project area would not flow onto another
area without the owner's consent. Such studies must be reviewed and
approved by the City of EI Segundo and any other applicable agency.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
MM F-3: The applicant must prepare a master drainage plan for the development on
the Project Site. This plan must include detailed hydrology/hydraulic
calculations and drainage improvements, showing quantitatively how the
Project will eliminate the potential for downstream flooding due to increased
storm water runoff. This plan will also identify the proposed BMPs to be
implemented in compliance with the requirements of the Standard Urban
Storm Water Mitigation Plan and the ESMC. Such plan must be reviewed and
approved by the City of EI Segundo and the Los Angeles County Department
of Public Works.
Monitoring Phase: Pre -Construction, Construction
Implementation Parry: Applicant
Enforcement Agency: Planning and Building Safety
Department, Los Angeles County
Department of Public Works
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -8
City of EI Segundo
Monitoring Agency:
June 2019
Planning and Building Safety
Department, Los Angeles County
Department of Public Works
MM F-4: The applicant must design a conveyance and detainment system to meet the
Los Angeles County Department of Public Works limits on the storm drains
that would convey the Project Site's discharge for the development on the
Project Site.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building
Safety
Department, Los Angeles
County
Department of Public Works
Planning and Building
Safety
Department, Los Angeles
County
Department of Public Works
MM F-5: The Project must comply with City of EI Segundo Ordinance No. 1347 and No.
1348, which establishes storm water and urban pollution controls.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
MM F-6: The Project owner/developer must maintain all structural or treatment
control BMPs for the life of the project.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
J. Land Use/Planning
Construction, Post -Construction
Applicant
Planning and Building Safety
Department, Public Works Department
Planning and Building Safety
Department, Public Works Department
No specific Project Design Features are proposed with regard to land use/planning. No mitigation
measures are required.
K. Mineral Resources
No specific Project Design Features are proposed with regard to mineral resources. No mitigation
measures are required.
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -9
City of EI Segundo
L. Noise
June 2019
No specific Project Design Features are proposed with regard to noise. No mitigation measures
are required.
M. Population, Housing, and Employment
No specific Project Design Features are proposed with regard to population, housing, and
employment. No mitigation measures are required.
N. Public Services
i) Fire Protection
1) Proiect Design Features
PDF J-1: The Project shall implement a Construction Management Plan
("CMP") that would include street closure information, a detour
plan, haul routes and a staging plan. The CMP would formalize
how construction would be carried out and identify specific
actions that would be required to reduce effects on the
surrounding community. The CMP shall be based on the nature
and timing of the specific construction activities and other
projects in the vicinity of the Project Site and shall include, but
not be limited to: prohibition of construction worker parking on
nearby residential streets; worker parking would be provided on-
site or in designated off-site public parking areas; temporary
traffic control during all construction activities adjacent to public
rights-of-way to improve traffic flow on public roadways (e.g.,
flag men); scheduling of construction -related deliveries, haul
trips, etc., so as to occur outside the commuter peak hours to the
extent feasible, to reduce the effect on traffic flow on
surrounding streets; construction -related vehicles shall not park
on surrounding public streets; and safety precautions for
pedestrians and bicyclists through such measures as alternate
routing and protection barriers as appropriate, especially as it
pertains to maintaining safe routes to schools.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Public Works Department
Monitoring Agency: Planning and Building Safety
Department
PDF J-2: Provide an automatic fire sprinkler system throughout each
office/studio building, installed in accordance with California Fire
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -10
City of EI Segundo
June 2019
Code Chapter 9 and the currently adopted edition of the NFPA
13.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Fire Department
Monitoring Agency: Planning and Building Safety
Department
PDF J-3: Provide a manual fire alarm system throughout each building,
installed in accordance with California Fire Code Chapter 9 and
the currently adopted edition of NFPA 72.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Fire Department
Monitoring Agency: Planning and Building Safety
Department
PDF J-4: Provide a manual standpipe system in each stairwell of the
proposed parking garage, installed in accordance with California
Fire Code Chapter 9 and the currently adopted edition of NFPA
14.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
21 Mitigation Measures
No mitigation measures are required.
Police Protection
Pre -Construction, Construction
Applicant
Fire Department
Planning and Building Safety
Department
No specific Project Design Features are proposed with regard to police protection. No
mitigation measures are required.
iii) Schools
No specific Project Design Features are proposed with regard to schools. No mitigation
measures are required.
iv) Parks
No specific Project Design Features are proposed with regard to parks. No mitigation
measures are required.
Beach Cities Media Campus Project
Page IV -11
IV. Mitigation Monitoring and Reporting Program
City of EI Segundo June 2019
v) Other Public Facilities
No specific Project Design Features are proposed with regard to other public facilities. No
mitigation measures are required.
O. Recreation
No specific Project Design Features are proposed with regard to recreation. No mitigation
measures are required.
P. Transportation/Traffic
i) Project Design Features
PDF K-1: Prior to the start of construction, the Project Applicant shall prepare a
Construction Traffic Management Plan and submit it to the City of EI Segundo
Traffic Division for review and approval. The Construction Management Plan
shall include a Worksite Traffic Control Plan, which will facilitate traffic and
pedestrian movement, and minimize the potential conflicts between
construction activities, street traffic, bicyclists, and pedestrians.
Furthermore, the Construction Traffic Management Plan and Worksite Traffic
Control Plan shall include, but not be limited to, the following measures:
• Maintain access for land uses in the vicinity of the Project Site during
construction;
• Schedule construction material deliveries during off-peak periods to the
extent practical;
• Minimize obstruction of traffic lanes adjacent to the Project Site to the
extent feasible;
■ Organize Project Site deliveries and the staging of all equipment and
materials in the most efficient manner possible, and on-site where
possible, to avoid an impact to the surrounding roadways;
• Coordinate truck activity and deliveries to ensure trucks do not wait to
unload or load at the Project Site and impact roadway traffic, and if
needed, utilize an organized off-site staging area;
• Control truck and vehicle access to the Project Site with flagmen;
• Prepare a haul truck route program that specifies the construction truck
routes to and from the Project Site;
• Limit sidewalk and lane closures to the maximum extent possible, and
avoid peak hours to the extent possible. Where such closures are
necessary, the Project's Worksite Traffic Control Plan will identify the
location of any sidewalk or lane closures and identify all traffic control
measures, signs, delineators, and work instructions to be implemented
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -12
City of EI Segundo
June 2019
by the construction contractor through the duration of demolition and
construction activity; and/or
• Parking for construction workers will be provided either on-site or at off-
site, off-street locations.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Public Works Department, Traffic
Division
Monitoring Agency: Planning and Building Safety
Department
ii) Mitigation Measures
MM K-1: Transportation Demand Management Program. A TDM program will be
implemented as part of the mitigation package for the Project. Several TDM
program elements are project design features that are currently proposed for
implementation. Other TDM program elements would be developed as part
of preparation of a detailed TDM plan, to be approved by City of EI Segundo
prior to approval of a final certificate of occupancy for the Project. City
approval will be contingent upon submission of an accompanying analysis
based on CAPCOA and latest available relevant research confirming that the
elements in the TDM plan will yield the intended 6.5% reduction in weekday
peak hour trips that the traffic analysis was based on.
TDM strategies are aimed at discouraging single -occupancy vehicle trips and
encouraging alternative modes of transportation such as carpooling, taking
transit, walking, and biking. Strategies that are suggested as appropriate for
this site, as targeted for the office land use, include:
• Commuter Trip Reduction (CTR) Program, Voluntary —The Project could
implement a CTR program that encourages alternative modes of
transportation such as carpooling, taking transit, walking, and biking. The
voluntary program does not require monitoring and reporting and no
performance standards are established. The CTR program would provide
employees with assistance in the following.
• Carpool encouragement,
• Ride -matching assistance,
• Preferential carpool parking,
• Flexible work schedules for carpools,
■ Half time transportation coordinator; and
• Vanpool assistance.
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -13
City of EI Segundo
June 2019
• Due to the importance of information sharing and marketing,
marketing strategies to reduce commute trips would be included as
part of the CTR Program. Some marketing strategies may include:
■ New employee orientation of trip reduction and alternative mode
options,
■ Event promotions; and
• Publications.
• Car Share Program —This Project could implement a car -sharing program
to allow people to have on -demand access to a shared fleet of vehicles
on an as -needed basis. User costs are typically determined through
mileage or hourly rates, with deposits and/or annual membership fees.
The car -sharing program could be created through a local partnership or
through one of many existing car -share companies. Employer -based
programs provide a means for business/day trips for alternative mode
commuters and provide a guaranteed ride home option.
• Site Design — Project site will be designed to encourage walking, biking,
and transit. Amenities could include new, wider sidewalks and street
trees along the site perimeter and bicycle parking, showers, and secure
lockers.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Public Works Department
Monitoring Agency: Planning and Building Safety
Department
MM K-2: Driveway 1. A proposed mitigation for the Project is to signalize Driveway 1.
Currently proposed as a full -access unsignalized intersection, adding a signal
will improve operations and increase safety (see the site access analysis in
Chapter 6 of the Traffic Study). The intersection would remain full access, but
the installation of a signal would allow for more controlled and efficient
movements. Installation of the signal would require approval from both the
City of EI Segundo and City of Manhattan Beach.
With the proposed mitigation of a signal at Driveway 1, Project related
vehicular traffic would shift. Intersections directly affected by this shift would
include those in close proximity to Driveway 3, such as Intersection 11: Nash
Street & Park Place and Intersection 16: Nash Street & Rosecrans Avenue.
Other intersections east of the Project Site would see minor changes in
vehicular volume due to the shifting of Project traffic from primarily using
Driveway 3 to access the site and instead using Driveway 1. The mitigation
analysis takes into account this shift in traffic due to the proposed signal.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -14
City of EI Segundo
June 2019
Enforcement Agency: Public Works Department, City of
Manhattan Beach Public Works
Department
Monitoring Agency: Public Works Department, City of
Manhattan Beach Public Works
Department
MM K-3: Intersection 12. Douglas Street & Park Place. The mitigation involves
signalizing the intersection that is currently stop -controlled. Special attention
would be needed in the signal design for the westbound movement, which
currently consists of two separate driveways. Signals may be needed that
accommodate two separate westbound phases, or coordination with the
private property owners may be needed to consolidate the two driveways.
The measure would mitigate the significant impact under Existing and Future
plus Project conditions. Installation of the signal would require approval from
the City of EI Segundo.
Monitoring Phase:
Pre -Construction, Construction
Implementation Party:
Applicant
Enforcement Agency:
Public Works Department
Monitoring Agency:
Public Works Department
MM K-4: Intersection 21. Isis Avenue & Rosecrans Avenue. This mitigation involves
restriping the southbound lanes from one shared through left and one right
to a left -only lane and a shared through/right lane. The southern portion of
the intersection has one receiving through lane. This intersection is in the City
of Hawthorne and the improvement would require approval of Hawthorne.
The measure would mitigate the significant impact under Existing and Future
plus Project conditions.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Public Works Department, City of
Hawthorne Public Works Department
Monitoring Agency: Public Works Department, City of
Hawthorne Public Works Department
MM K-5: Intersection 24.1-405 Northbound On -/Off -Ramps & Rosecrans Avenue. This
mitigation involves restriping the northbound off -ramp lanes from two lefts
and one right to two left and one shared left/right. The western portion of
the intersection has three receiving lanes for the left -turn movement. The
existing median along Rosecrans Avenue may need to be cut back in order to
accommodate the third left turning movement. This intersection is under
Caltrans jurisdiction and the improvement would require approval of
Caltrans. The measure would mitigate the significant impact under Existing
and Future plus Project conditions.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -15
City of EI Segundo
Enforcement Agency:
Monitoring Agency:
Q. Tribal Cultural Resources
iJ Project Design Features
June 2019
Public Works Department, Caltrans
Public Works Department, Caltrans
No specific Project Design Features are proposed with regard to tribal cultural resources.
ii) Mitigation Measures
MM L-1: Prior to issuance of a grading permit, the Applicant shall retain a qualified
Native American Monitor (Monitor) from the Gabrieleno Band of Mission
Indians-Kizh Nation to monitor all grading and excavation activities within the
Project Site. The Monitor shall photo -document the grading and excavation
activities and maintain a daily monitoring log that contains descriptions of the
daily construction activities, locations and mappings of the graded areas,
soils, and documentation of any identified tribal cultural resources. On-site
monitoring shall end when the Project Site grading and excavation activities
are completed, or when the Tribal Representatives and Monitor have
indicated that the Project Site has a low potential for archaeological
resources. If tribal cultural resources are encountered during monitoring, all
ground -disturbing activities within 50 feet of the find shall cease and the
Monitor shall evaluate the significance of the find, and if significant,
recommend a formal treatment plan and appropriate measure(s) to mitigate
impacts. Such measure(s) may include avoidance, preservation in place,
archaeological data recovery and associated laboratory documentation, or
other appropriate measures. The City shall determine the appropriate and
feasible measure(s) that will be necessary to mitigate impacts, in
consideration of the measure(s) recommended by the Monitor. The
Applicant shall implement all measure(s) that the City determined necessary,
appropriate and feasible. Within 60 days after grading and excavation
activities are completed, the Monitor shall prepare and submit a final report
to the City and the California Native American Heritage Commission. The
report shall include documentation of any recovered tribal cultural resources,
the significance of the resources, and the treatment of the recovered
resources. In addition, the Monitor shall submit the monitoring log and photo
documentation, accompanied by a photo key, to the City.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -16
City of EI Segundo
June 2019
R. Utilities/Service Systems
iJ Water
11 Proiect Design Features
PDF M.1-1: Any existing water meters, potable water service connections,
fire backflow devices and potable water backflow devices shall
be upgraded to current City Water Division standards. These
devices shall be placed or relocated onto private property. In
addition, any unused water laterals shall be abandoned and
properly capped at the City main. The Contractor shall obtain
necessary permits and licenses, and provide traffic control plans
and shoring plans.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
21 Mitigation Measures
No mitigation measures are required.
ii) Wastewater
11 Proiect Design Features
Pre -Construction, Construction
Applicant
Public Works Department
Planning and Building Safety
Department
PDF M.24: The Project Applicant shall submit a Utility Plan to the City of EI
Segundo Public Works Department for review and approval. The
Utility Plan shall show all existing and proposed utility
improvements (sewer, water, gas, storm drain, electrical, etc.),
their sizes and associated easements around the Project Site, and
traffic control plans for work in the public right-of-way.
Monitoring Phase: Pre -Construction, Construction
Implementation Party: Applicant
Enforcement Agency: Public Works Department
Monitoring Agency: Planning and Building Safety
Department
PDF M.2-2: The Project Applicant shall submit a Sewer Study to the City
Engineer for review and approval. Any capacity deficiencies
identified in the Sewer Study shall be addressed through
upgrades. In addition, any unused sanitary sewer laterals shall be
abandoned and properly capped at the City main. The Contractor
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -17
City of EI Segundo
June 2019
shall obtain necessary permits and licenses, and provide traffic
control plans and shoring plans.
Monitoring Phase:
Implementation Party:
Enforcement Agency:
Monitoring Agency:
2) Miti ation Measures
No mitigation measures are required.
iii) Solid Waste
1) Proiect Design Features
Pre -Construction, Construction
Applicant
Public Works Department
Planning and Building Safety
Department
PDF M.3-1: During construction, the Project would implement a construction
waste management plan to recycle non -hazardous construction
debris. Off-site recycling centers, such as asphalt or concrete
crushers, would be utilized to provide crushed materials for
roadbed base.
Monitoring Phase:
Implementation Parry:
Enforcement Agency:
Monitoring Agency:
Pre -Construction, Construction
Applicant
Planning and Building Safety
Department
Planning and Building Safety
Department
PDF M.3-2: All structures constructed or uses established within any part of
the Project shall be designed to be permanently equipped with
clearly marked, durable, source sorted recycling bins at all times
to facilitate the separation and deposit of recyclable materials.
Monitoring Phase:
Construction
Implementation Party:
Applicant
Enforcement Agency:
Planning and Building Safety
Department
Monitoring Agency:
Planning and Building Safety
Department
PDF M.3-3: Primary collection bins shall be designed to facilitate mechanized
collection of such recyclable wastes for transport to on- or off-
site recycling facilities.
Monitoring Phase: Construction, Operation
Implementation Party: Applicant
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -18
City of EI Segundo
June 2019
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
PDF M.3-4: The Applicant or its successor shall continuously maintain in good
order clearly marked, durable, and separate recycling bins on the
same lot or parcel to facilitate the deposit of recyclable or
commingled waste metal, cardboard, paper, glass, and plastic
therein; maintain accessibility to such bins at all times for the
collection of such wastes for transport to on- or off-site recycling
plants; and require waste haulers to utilize local or regional
material recovery facilities as feasible and appropriate.
Monitoring Phase: Construction, Operation
Implementation Party: Applicant
Enforcement Agency: Planning and Building Safety
Department
Monitoring Agency: Planning and Building Safety
Department
J, Mitiaation Measures
No mitigation measures are required.
iv) Energy
No specific Project Design Features are proposed with regard to energy. No mitigation
measures are required.
Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program
Page IV -19