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CC RESOLUTION 5159RESOLUTION NO. 5159 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL SEGUNDO CERTIFYING THE ENVIRONMENTAL IMPACT REPORT (ENVIRONMENTAL ASSESSMENT NO. EA -1201) FOR THE BEACH CITIES MEDIA CAMPUS PROJECT; MAKING FINDINGS OF FACT AND ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS; AND ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM. The City Council of the City of EI Segundo does resolve as follows: SECTION 1: The City Council finds and declares that: A. On September 15, 2017, Rosecrans -Sepulveda Partners 4, LLC ("RSP4"), filed an application for Environmental Assessment No. EA -1201 for a General Plan Amendment and General Plan Map Amendment, Zone Change and Development Agreement to develop office, retail, and studio and production facilities on an approximately 6.39 -acre site located at 2021 Rosecrans Avenue (the "Property"); B. The applications were reviewed by the City of EI Segundo Planning and Building Safety Department for, in part, consistency with the General Plan and conformity with the EI Segundo Municipal Code ("ESMC"); C. The City analyzed the project's potential environmental impacts in accordance with the California Environmental Quality Act (Public Resources Code§§ 21000, et seq., "CEQA") and the regulations promulgated thereunder (14 Cal. Code of Regulations §§15000, et seq., the "CEQA Guidelines") and an environmental impact report ("EIR") was prepared; D. The Planning and Building Safety Department completed its review and scheduled a public hearing regarding the application before the Planning Commission for May 23, 2019. On May 23, 2019, the Planning Commission conducted a public hearing on the proposed project. Following the public hearing the Planning Commission adopted Resolution No. 2861 recommending that the City Council certify the Project's EIR, adopt the General Plan Amendment and General Plan Map Amendment, adopt the Zone Change and Zoning Map Amendment, and approve the draft Development Agreement; E. On July 16, 2019, the City Council scheduled a duly advertised public hearing, which was continued to August 6, 2019. On August 6, 2019, the City Council held a duly advertised public hearing in the Council Chamber of the EI Segundo City Hall, 350 Main Street to receive public testimony and other evidence regarding the applications including, without limitation, information provided to the Council by City Staff, members of the public, and representatives of RSP4. F. This Resolution and its findings are made based upon the totality of the evidence in the record. SECTION 2: Factual Findings and Conclusions. The Council finds that the following facts exist: A. The Property is a 6.39 -acre multi -use site located on the north side of Rosecrans Avenue, between Continental Boulevard and Nash Street at 2021 Rosecrans Avenue. B. The property is currently a vacant lot with a screened chain-link security fence running along the perimeter of the site and along the adjacent roadway. C. The General Plan land use designation and zoning of the Property will be amended from Commercial Center (C-4) to Urban Mixed Use South (MU -S). D. The Beach Cities Media Campus (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. E. The applicant is seeking a 10 -year Development Agreement which would vest the applicant's right to develop the Beach Cities Media Campus or any of the alternatives described therein and analyzed in the EIR in accordance with the zoning regulations in effect as of the date the project is approved by the City. The alternatives analyzed in the EIR include the following: Alternative 3: Mixed Use Alternative with Studio and Production Facilities; Alternative 4: Mixed Use Alternative with Research and Development; Alternative 5: All Creative Office Space Alternative. F. In exchange for the vested land use regulations, the Development Agreement would limit the maximum allowable development envelope that could be built upon the Project Site. The MU -S zone permits a maximum floor area ratio (FAR) of 1.3, 361,844 square feet of floor area and a maximum height of 175 feet. However, the Project Development Agreement will limit the FAR to 1.13, the floor area to 313,000 square feet and the height to 140 feet. Furthermore, the Development Agreement will provide that the following uses are prohibited: (i) drive-through restaurants; (ii) adult businesses; (iii) catering services/flight kitchens; (iv) freight forwarding; and (v) service stations. G. Project parking for the would be provided in multiple areas, including the following: 980 parking spaces in a seven -story above grade parking structure; 120 executive parking spaces in one semi -subterranean level beneath the Office Building; and in surface parking areas elsewhere on the site. RESOLUTION NO. 5159 PAGE 2 of 6 H. Approval of a subsequent Site Plan Review is necessary to accommodate the proposed project or any of the alternatives. SECTION 3: Exhibits. There are three exhibits attached to this Resolution: Exhibit A-1 (Final Impact Report ("FEIR")); Exhibit A-2 (Findings of Fact and Statement of Overriding Considerations); and Exhibit A-3 (Mitigation Monitoring and Reporting Program ("MMRP")). These exhibits are incorporated into this Resolution by reference. SECTION 4: Environmental Assessment. The City Council makes the following findings based on the whole of the administrative record: A. Pursuant to CEQA Guidelines Sections 15064 and 15081, and based upon information contained in the Initial Study, the City ordered the preparation of an Environmental Impact Report ("EIR") for the Project. The City contracted with independent consultants for the preparation of the technical studies for the EIR and on December 5, 2017, prepared and sent a Notice of Preparation of the EIR to responsible, trustee, and other interested agencies and persons in accordance with Guidelines Section 15082(a). Comments on the Notice of Preparation were accepted during the 30 -day comment period ending on January 3, 2018. During the scoping period, the City held an advertised public meeting on December 18, 2017, to facilitate public input regarding the scope of the EIR. B. The City completed the Draft EIR, together with those certain technical studies (the "Appendices"), on March 1, 2019. The City circulated the Draft EIR and the Appendices to the public and other interested parties from March 1, 2019 through April 15, 2019. Advertisement of the public commenting period was provided by a Notice published in the EI Segundo Herald, a Notice mailed to all property owners within a 300 -foot radius, and a Notice was posted on the City's website. C. During the Draft EIR public comment period the City received numerous letters and comments. Responses to each of the individual comments were prepared and made available on June 25, 2019. The comments and responses are part of section II of the Final EIR, and are incorporated herein by reference. The written responses to comments were made available for public review in the Planning and Building Safety Department, at the EI Segundo Public Library and on the City's website. After reviewing the responses to comments, the revisions to the Draft EIR, and the Final EIR, the City Council finds that the information and issues raised by the comments and the responses thereto do not constitute significant new information requiring recirculation of the EIR. D. The Final EIR is comprised of the Draft EIR, comments and recommendations received on the Draft EIR, a list of persons, organizations and public agencies commenting on the Draft EIR, the City's Responses to Comments, Findings of Fact and a Statement of Overriding Considerations, and the Mitigation Monitoring and Reporting Program. RESOLUTION NO. 5159 PAGE 3 of 6 E. The Final EIR, which is attached as Exhibit "A-1," and incorporated by reference, was reviewed by the City Council and the information contained in the Final EIR was considered by the City Council before approving or denying the project in accordance with CEQA Guidelines §15090; F, Pursuant to CEQA Guidelines §15090 the Final EIR reflects the City's independent judgment and analysis. The City Council has independently reviewed and analyzed the FEIR. The FEIR is an accurate and complete statement of the potential environmental impacts of the project. The Final EIR was prepared under the City's direction and reflects its independent judgment and analysis of the environmental impacts and comments received on the Draft EIR; G. The FEIR generally identifies, for each potentially significant impact of the project, one or more corresponding mitigation measures to reduce impacts to a level of insignificance, with the exception of population, housing, and employment, and transportation, traffic and parking. The City Council finds that nearly all of the potentially significant impacts identified in the Draft EIR are mitigated by corresponding mitigation measures to the extent set forth in the Draft EIR; H. In accordance with CEQA Guidelines §15091, the City Council has considered written findings regarding each of the significant environmental effects identified in the DER before certifying the Final EIR. Each finding includes a rationale of how mitigation measures have lessened identified significant environmental effects to a less than significant level for those effects that have been identified as mitigatable. For the environmental effects that have been identified in the DER as not mitigatable to a less than significant level, the findings provide a rationale on how proposed mitigation measures have substantially lessened these four environmental effects; The DER states that the City Council must adopt a Statement of Overriding Consideration if it wishes to approve the project. In accordance with CEQA Guidelines §15093 a Statement of Overriding Consideration was included in the project's record for City Council consideration. This statement identifies specific reasons why to support approval of the project based on information in the EIR and in the project's record; and J. The specific issues included in the Statement of Overriding Considerations considered by the City Council are: a) the Project would return a previous industrial site to productive use by constructing state-of-the-art facilities for entertainment production, studio facilities, office and corporate headquarters that will contribute to job creation and balance growth with local resources and infrastructure capacity; b) the Project would create a development that would be compatible with and complementary to adjacent land uses; c) the Project would generate complementary economic activity by providing new businesses and services and by providing an employee base that could RESOLUTION NO. 5159 PAGE 4 of 6 patronize adjacent retail uses and restaurants; d) the Project will help foster economic development in the City by contributing to a strong business climate, with positive outcomes such as business retention and attraction, as well as effective levels of City services to all members of the community; e) the Project will improve the City's tax base by generating business, property, and sales tax revenues; f) the Project will provide traffic mitigation measures that will generally improve traffic circulation in this area of the City; g) the Project will reduce vehicle miles travelled, air pollutant and greenhouse gas emissions, and maximize the public investment in transit by developing an under-utilized site adjacent to several bus lines; h) the Project will be developed within one-half mile of the existing Metro Green Line rail station, which would be consistent with regional planning programs and plans, and EI Segundo General Plan land use policies that help improve mobility, livability, prosperity and sustainability; and i) the Project will provide environmentally sensitive development, by incorporating sustainable and green building design and construction that reduces waste, manages water use efficiently and conserves energy, and by providing employment opportunities within easy access of established public transit. SECTION 5: Actions. A. The City Council certifies the Final Environmental Impact Report of Environmental Impacts for Environmental Assessment No. EA -1201 as set forth in Exhibit "A-1 "; B. The City Council hereby adopts the Findings of Fact and Statement of Overriding Considerations as set forth in Exhibit "A-2" which is incorporated herein by reference; C. The City Council hereby adopts the Mitigation Monitoring and Reporting Program attached hereto as Exhibit "A -Y to ensure implementation of all feasible mitigation measures identified in the FEIR. The City Council finds that these mitigation measures are fully enforceable and binding conditions of approval of the project. SECTION 6: Reliance On Record. Each and every one of the findings and determinations in this Resolution is based on the competent and substantial evidence, both oral and written, contained in the entire record relating to the project. The findings and determinations constitute the independent findings and determinations of the Council in all respects and are fully and completely supported by substantial evidence in the record as a whole. SECTION 7: Limitations. The Council's analysis and evaluation of the project is based on the best information currently available. In all instances, best efforts have been made to form accurate assumptions. SECTION 8: Summaries of Information. All summaries of information in the findings, which precede this section, are based on the substantial evidence in the record. The absence of any particular fact from any such summary is not an indication that a particular finding is not based in part on that fact. RESOLUTION NO. 5159 PAGE 5 of 6 SECTION 9: This Resolution will remain effective until superseded by a subsequent resolution. SECTION 10: The City Clerk is directed to mail a copy of this Resolution to any person requesting a copy. SECTION 11: This Resolution is the City Council's final decision and will become effective immediately upon adoption. PASSED, APPROVED AND ADOPTED this 6" day of August, 2019. Drew Boyles, W01r ATTEST: Tracy Sh r `Il eaver, City Clerk APPROVED TO FORM: f Mark D. ensley, City Att rney RESOLUTION NO. 5159 PAGE 6 of 6 STATE OF CALIFORNIA COUNTY OF LOS ANGELES CITY OF EL SEGUNDO CERTIFICATION SS I, Tracy Weaver, City Clerk of the City of EI Segundo, California, do hereby certify that the whole number of members of the City Council of said City is five; that the foregoing Resolution No. 5159 was duly passed, approved, and adopted by said City Council at a regular meeting held on the 6th day of August, 2019, approved and signed by the Mayor, and attested to by the City Clerk, by the following vote: AYES: Mayor Boyles, Mayor Pro Council Member Nicol NOES: None ABSENT: Council Member Pimentel ABSTAIN: None Tem Pirsztuk, Council Member Brann, and WITNESS MY HAND THE OFFICIAL SEAL OF SAID CITY this day of August, 2019. ' Tr y Weaver, City Clerk of the City of EI Segundo, California EXHIBIT A-1 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 ipEcoTierra co n s u It in g TABLE OF CONTENTS I. INTRODUCTION 1. The CEC1,A Process and Public Review of the Draft EIR................... 2. Project Description ................................... ...... --- ...... ............. I-3 3. Summary of Environmental Impacts ............ 11, 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 Pagel LIST' OI* TABLES Table 1-1, Project Development Summary ....... ................................................................ .......... 1-4 Beach Cities Media Campus Project Table of Contents Page 1i 1. 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 Ili. 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 1. 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 CEQA. 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: httos://www,elseeundo.ore de is lannin safer Tannin 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: o 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: htt s.: www.elseeundo.ore/desats/ol'annin ss� afety/a endas.asq,,,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: htt s: /www.elseeundo.or/p,�epts/olanninesafetvJclannine/. 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 (17S 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 0Fitness centers (indoors only) 0 General offices 0 Indoor sale of automobiles, motorcycles, and motor scooters along with the sale of accessories and parts as an accessory use O Medical and dental offices 0 Multi -media offices June 2019 • Personal services a 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: a Data centers + Daycare centers • Financial institutions a 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 Summary 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 Total Proposed Project �i" ' ,SOtebtag la'hd 313,000 gsf gsf = gross square feet 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 June 2019 • 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 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 0 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: w Paleontological Resources, w Archaeological Resources, • Greenhouse Gas Emissions, r Hazards and Hazardous Materials, a 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 CEC1A. 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 "[t]he 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 City ofBSegundo Comment Letter No.1 State mfCalifornia Governor's Office of Planning and Research State Clearinghouse and Planning Unit Scott Morgan, Director, State Clearinghouse l4ODloth Street P.O.Box 3O44 Sacramento, CA 95812-3044 April 16, 2019 June 2019 This comment is a standard response from the State Clearinghouse of Planning and Research acknowledging the Draft E|R 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 CEKLA 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 toinResponses 2-1through 3-1O. Beach Cities Media Campus Project Page 11-4 U'Response tmComments STATE OF CALIFORNIA--CALIFORNIAM—&Tf-TRANSPORTATION AGLE&CY DEPARTMENT OF TRANSPORTATION DISTRICT 7 100 S. MAIN STREET, MS 16 LOS ANGELES, CA 90012 PHONE (213) 897-6536 FAX (213) 897-1337 TTY 711 www.dot.ca,9ov Usmagw1ow" Mr. Ethan Edwards, AICP City of El Segundo 350 Main Street El Segundo, CA 90245 Dear Mr. Edwards: commenLetter No. 2 avin %22mQgr" 0 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 1 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 2 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. 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 mufti -modal and complete streets 3 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" 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, MI y 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 El 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 June 2019 The comment accurately describes the Project as an introduction to the comments on the Draft EIR that follow. 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. 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. 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. WMEMOMMEEM 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 11. Response to Comments Page 11-8 City ofElSegundo June 2019 characteristics would reduce VMTs. In addition, the reduction ofVMTs and the increase in energy efficiency, would reduce greenhouse gas emissions, consistent with the goals outlined inthe 2O17Climate 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 |s noted for the administrative record and will be forwarded to the decision -makers for review and consideration. This comment states that the Project would generate net 2,83 daily trips and peak hour trips per Table K(K-3Project Trip Generation. The commenter accurately describes the Project. Response toComment 2-7 The commenter concurs with the concept of mitigation measure K4K0 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. Besoonseto 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 ioasensitive 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. Resoonse 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 mrmaterials. Beach Cities Media Campus Project x.Response toComments Page 11-9 Comment Letter No. 3 South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 9 1 765-4 1 78 (909) 396-2000 - www.aqmd.gov SENT VIA E-MAIL AND USPS: April 10, 2019 EEdwardsAhelseffundo.ore Ethan Edwards, AJCP_ Contract Planner City of El Segundo, Planning and Bitilding Safety Development Planning Division 350 Main Street El Segundo, CA 90245 Draft Environniental Irni)act Renort (Draft EIR) for the Proimsed, Ucieli Cities Media Carrinus, Pi-piiSt ( CH No.: 20171210351 South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to coinment on the above-mentioned document- The folloAing cornincrits are meant as guidance for the Lead Agency and should be incorporated into the Final EIR. SCAOMD Staffs Sunimary of Proicci DescriMLon The Lead Agency proposes to construct four buildings with, office and retail uses totaling 313,000 square feet on 6.39 acres (Proposed PrRiect). The Proposed Pmjecl is located awl 2021 Rosecrans Avenue on, the northeast comer or Rosecrans Avenue and Village Drive in, lite City of El Segundo, Based on 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). Impacted soil was removed from the site to the levels required for commercial development_ and a letter of No Further Action was issued in August 20173. Groundwater remedial action appears to be ongoingl- Comoliance with SCAQMD Rules & Ponnits Since the Proposed Project includes ,aiding and site preparation activities that might cause residual TPHs. lead, PCBs. and VOCs to become airborne during cowstruction. and in addition to a discuss -ion on SCAQMD Rule 1166 — Volatile Organic Compounds frorn Decontamination of S011. the Lead Agency should include a discussion to demonstrate compliance with SCAQMD Rule 1466 — Control of Particidate Emissions from Soils with Toxic Air Contaminants' in the Air Quality Section of the Final EIR. aniong the list of other applicable SCAQMD Rules, If on-site groundwater remediation or any on- site activity 'would involve equipment or oNtations. wfich either emits or controh; air pollution, SCAQMD Enginccring and Pcnuitling staff should be consulted in advance to detenninc whether or not 2 any pennits or plans are required to be filed and approved by SCAQMD prior to the start or any remedial activities or operations. In the event that implementation of the Proposed Project requiresa pe'rinit Frorn SCAQMD.. the Lead Agency should identify SCAQMD as a Responsible Agency for the Proposed Project in the Final EIR. 1?uussions 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 assuniptions in the Air Quality Aruilysis in the Final EIR will be used as the basis for Drafl FIR, HvArdsaiid I lazardous Materials. Page IVA-'.) - IVA-..3. Nd. Draft EIR Appcmdices, Appendix& I � Phase I Environmental Sile Assessniani, pages 738-7K6, Soutli Coast .lir QkiiilitvMoiiag---iiicnI District. Rule 1466 Control Emissions tiorn Soil-, with Toxic Air Contaminants, Accessed at: JJJtns' *v*,w%.aomd.vm, d0cs edt' Ethan Edwards April 10, 2019 permit conditions and limits. For more information on permits, please visit SCAQMD's webpage at: 2 cont. hqn://%v,.vw.aclmd,izov/hontc/pemiits. Questions on permits can be directed to SCAQMD's Engin=, ing and Permitting staff at (909) 396-3385. Conclusion Pursuant to California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(b), SCAQN4D staff requests that the: Lead Agency provide SCAQN4D 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. 'I'liere should, be, good faith, reasoned analysis in responsQ. Conclusory statements unsupported by factual information will not suffice (CEQA Guidelines Section 15088(c)). Concluson, statements do not facilitate the purposc and goal of CEQA on public disclosure and are not meaningfbi.. informative, or useful to decision makers and to the public who are interested in the Proposed Project. SCAO,MD staff is available to work with the Lead Agency to address any air quality questions that may arise fi-om this comment letter. Please contact Alina Mullins, Assistant Air Quality Specialist at amullins(O-6ciind,00v or (909) 396-2402, should you have any questions. LSAM LAC190305-07 Control Number Sincerely, zq;:�s .5" Lijin Sun, J.D. Program Supervisor, (-'FQA ICYR, Planning, Rule Development .- ea Sources 2 City ofEl Segundo Comment Letter No. South Coast Air Quality Management District Planning, Rule Development & Area Sources LijinSun, ].D.Program Supervisor, CEQA|GR 21065 Copley Drive Diamond Bar, CA 91765-4178 April 10,2O19 Response to Comment 3-1 June 2019 The comment accurately describes the Project asanintroduction to the comments on the Draft E|Rthat 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 isreferred toSection Ill. Revisions, [|ahficat\onsand Corrections onthe Draft E|R.|V.A.Air Quality, pages |V\A-12through }V.A-13have been revised. Inclusion ofthese revisions dm not affect the analysis or conclusions of the Draft EiN and therefore, recirculation of the Draft E|R is not required. The commenter states that the project would be required to comply with SCAQMD Rule 1166and Rule 1466. Thiscomment is noted. The project applicant would be required to complywith SCAQMD Rule 1166 and Rule 1466 because these are existing regulatory requirements. The commerterstates ifon-site groundwater remediation nranyon-siteactivitywmu|dinvolve equipment oroperations which emits orcontrols air pollution, SCAOYWDEngineering and Permitting staff should be consulted prior to the start ofremediation to determine vvhethe, or not permits are required by the SC4CiK8D. The project applicant would comply with SCAC1KU0 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 tothe certification ofthe Final E|R. The Lead Agency will provide the S[AQK00with acopy the responses to their comments prior to certification of the Final E|R. 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 U.Response toComments nT LOS '1101 1 CALABASAS EL MONTEINOUSTRY LAWNDALE AV SIGNAL HILL ,RTESIA GARDENA INGLEWOOD IiiII S. .. t° A% ZUSA CERRITOS DARYL L OSBY FIRE CHIEF FORESTER 8 FIRE WARDEN March 28, 2019 tom,ment Letter No. 4 COUNTY OF LOS ANGELES !j(:1411: ;&1Z 11614i�ll 1320 NORTH EASTERN AVENUE LOS ANGELES, CALIFORNIA 90063-3294 (323) 881-2401 www.fire.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 El Segundo, CA 90245 Dear Mr. Edwards: BOARD OF SUPERVISORS HILDA L. SOUS 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: u� ••^ s,s rIMRS• •» • For any questions regarding this response, please contact Loretta Bagwell, Planning Analyst, at (323) 851-2404 or Loretta. Bagwell( fire. lacountv,gov,. SERVING THE UNINCORPORATED AREAS OF LOS ANGELES COUNTY AND THE CITIES OF: 000RA HILLS CALABASAS EL MONTEINOUSTRY LAWNDALE PARAMOUNT SIGNAL HILL ,RTESIA CARSON GARDENA INGLEWOOD LOMITA PICO RIVIERA SOUTH EL MONTE ZUSA CERRITOS GLENDORA IRWINDALE LYNWOOD POMONA SOUTH GATE ALDW IN PARK CLAREMONT HAWAIIAN GARDENS LA CANADA-FLIN7RIDGE MALIBU RANCHO PALOS VERDES TEMPLE CITY -ELL COMMERCE HAWTHORNE LAHABRA MAYWOOD ROLLING HILLS WALNUT .ELL GARDENS COVINA HERMOSA BEACH LAMIRADA NORWALK ROLLING HILLS ESTATES WEST HOLLYWOOD -ELLFLOWER CUDAHY MODEN HILLS LA PUENTE PALMDALE ROSEMEAD WESTLAKE VILLAGE AADBURY 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 El Segundo, Therefore, the City of El 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. 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. The Health Hazardous Materials Division of the Los Angeles County Fire Department has no jurisdiction in the City of El Segundo. Please contact HHMD senior typist -clerk, Perla Garcia at (323) 890-4035 or 4 Perla.qarcia@fire.lacauntv,qov 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 Comment Letter No. 4 County ofLos Angeles Fire Department Prevention Services Bureau Michael Y.Takeshita, Acting Chief, Forestry Division 132DNorth Eastern Avenue Los Angeles, CA9DO63-3294 March 2QL2Olg June 2019 The comment states the Project islocated within the City ofE|Segundo and isnot part ofthe 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. The comment states the Project islocated within the City nfE|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. Besnonse tmComment 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 inthese areas should beaddressed. The commenter is referred to the Draft E|RSections^ |V'8 Cultural Resources, \V.F Hydrology and Water Quality, and Section Vil. Effects Not Found to be Significant for a discussion of the above issue areas. The comment states the Health and Hazardous Materials Division ofLos Angeles County Fire Department has no jurisdiction in the City of El 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 U.Response toComments Comment Letter No. 5 COUNTY SANITATION DISTRICTS OF LOS ANGELES COUNTY 1955 Workman Mih Road, Wbillier, CA 90601-1400 Mailing Address: P-0. Box 4998, Whittier, CA 90607-4998 Telephone. (562) 699-7411, FAX (5621 699,5422 www'locsd orn Mr. Ethan Edwards, AICP Conti -act Planner Planning Division City of El Segundo 350 Main Street El Segundo, CA 90245 Dear Mr. Edwards: GRACE ROBINSON HYDE April 15, 2019 Ref. Doc. No,: 4949636 DUR Rest)onse 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 klarch 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 enclosed) still apllkv to the subject proliect Mth the following updated information., I I Wastewater Treatment Facilities, page IV_41-21, top of page — The Joint Water Pollution Control Plant currently processes an average flow of 261,1 million gallons per day (ingd). 2, Operation, page IV M-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 in the 3 document is current, I 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 Mr. Ethan FAwards, AICD Contract Planner Planning Division City of El Segundo 350 Main Street El Segundo, CA 90245 Dear Mr, Edwards: COUNTY SANITATION OISTRICTS OF LOS ANGELES COUNTY December 26, 2017 Ref. Doe. No.: 4380003 NOP Resnonse for the Beach Cities .Media Campus Proiect. 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 floNv originating from the proposed prtaject will discharge to a local sewwer line, which is not maintained by the Districts, for conveyance to the Districts' Aviation Boulevard Relief Trunk Sewer, located in Aviation Boulevard at Rosccrans Avenue, The Districts' 27 -inch diameter trunk sewer has a capacity of 8.7 million gallons per day (mgd) and conveyed a peak now of 1.6 mgd when last measured in 2011. 2. 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 products an average recycled water flow of 253.4 mgd. 3. The expected increase in average wastewater flow from die 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 demolished, For a copy of the Districts' average wastewater generation factors, go to %Nw%%.1acsd.ore, 'Wastewater & Sewer Systems, click on Will Serve Program, and click on the Table 1. l.oadines for Each Class of kind I se 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 frown 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 wNv%v.Lacsd.org, 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 faciiities on the parcel. For more specific information regarding the connection fee application procedure and fees, please contact the Connection Fee Counter at (562) 9084288, 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 (SCAG), 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 the 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 tip 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, Adriana Raza Customer Service Specialist Facilities Planning Department AR:ar cc: A. Schmidt M. Tatalovich F49501219=32ffm City of El Segundo Comment Letter No.G County Sanitation Districts ofLos Angeles County Facilities Planning Department AdhanoRaza, Customer Service Specialist 1955Workman Mill Road VVhitter,CABDGO1-14O0 April 15,2019 June 2019 The comment provides suggested corrections to Section h(NL Utilities and Service Systems, of the Draft BR, page &\M-21. The correction isincluded inthis Final 8RinSection III Revisions, Clarification, and Corrections onthe Draft E|R. The correction relates tothe Joint Water Pollution Control Plant's average flow of 261.1 million gallons per day. Inclusion of this correction vxmuyd not change the Draft E|R's determination that impacts related to wastewater would be less than significant, The comment provides suggested corrections to Section IV.M, Utilities and Service Systems, of the Draft 8R, page K(K8-25,Tabke K1N0.3.1. The correction is included in this Final BR in Section U| Revisions, Clarification, and Corrections on the Draft E!R. The correction relates to the average wastewater flow from the project of7O,Q75 gallons per day. Inclusion ofthis correction would not change the Draft E|R~s determination that impacts related towastewater would beless than significant. The comment states all other information concerning the Districts facilities and sewerage service contained inthe document imcurrent. This comment isnoted for the administrative record and will be forwarded to the decision -makers for review and consideration. Beach Cities Media Campus Project U.Response toComments Comment Letter No. 6 From: Gana L Guiasr cganaG@cmgengr.corrm Sant: Toasday, April If, '20195'atr MA To. .lara y Mailhd; CraRq Fa o: SubjoiM FW: EIR for 22r' I r moven Ave FYI Uans f~nAtilvist. Alter Connaof Planner CayaulErSa�ctrodo—faV�n +i nr rr a I I IOf 524. 38'0 'l:=241 6 From: Edwards. Ethan .sedwards&elsegrtndo.arga Sent f,fra,da ,'fid IS. 20199 5$ P14 UGama L t Aso cganOG Ej,cag.nga com> Subject: Ford, EIR fax 2201 Flowan's Ave Ethan Edwards, AICD, Planner Cay of F3 5eag=nde " Pa u r f fl 10 ltaJS d"9,xna l,on4r ii^v'�S"L".x'tx� FK'rd �' ice" begin forwarded message: From: EricWasiond ct!IWAW ". f s AW A '15. 20 Wal 622@.3.5 PR GSf To: �+,;i"r1u,➢�a. k� w� nrlur'"„garTarM:r rwa+�weax�WS'yr a.i, n, 4xrr�,oran't+ ropkY' Cc: EAK ZOMN14 <4:;A05jU-2: .ulf1x' 9ubjoexd. Ftff for 220'1 Mw4xnno Aea Ni Ethan, I have a ocuple typo comments "follows • The top paragraph an Page 11.8 uses the phrase `maximum of 25 bicyda sparge . where it appears it should say °rrdnlnvum of 25 bicyds spaces" • For reIN" progara s, the statistics for H300 N Sepulveda were confused with 707 N Sepulveda, and should be par the table below (also an updated number of restaurant seats for 707 N,$epulvada,l Eric Haaland Associate Planner .. . . .+." n:o Ah.,v,. is^r +•a .: r x'.:v,l.xwr:ip.�Jh r�ar:i•. .y, -r * "+ Here for you 24/7, use our click and fix It app Download the mobile app now 'A a' �• .n• IgE A+a d.y Un+t, bu^Jn 'bMN Suw vvJuE wirvemwy i 3 n = c Fy,umn 9I'amnl In.p ,7 I• .,. ri m Ixer+�nn,+kw;n lh �, .. .. mw Yrt Wpr+n7MS M7b FbY uS7M %W—Wr 1g 50 _. "'i 157 IgE .:•... ."•"., d., 7GIN septi'-WBI R4]u tri MMr[iMfS Mv�R 3nfrM N.,v, eunG :g It, ?: 11 3l m �oMPI—kA"x tlrJ F9UalIIxn16u Wnn .r� t : "1 Inr ,r, Iat9H�geulem '19 Y+ lay 70 ;1 ji uP'W Eric Haaland Associate Planner .. . . .+." n:o Ah.,v,. is^r +•a .: r x'.:v,l.xwr:ip.�Jh r�ar:i•. .y, -r * "+ Here for you 24/7, use our click and fix It app Download the mobile app now City ofElSegundo Comment Letter No. 6 City of Manhattan Beach Eric Haalamd,Associate Planner 14OOHighland Avenue Manhattan Beach, C49O26G April lS,2O19 June 2019 The comment provides suggested corrections to Section iLProject Description, of the Draft E|R, page 11-8. The correction is included in this Final EIR in Section 111. Revisions, Clarification, and Corrections on the DraftE|R. The correction relates tothe number ofbicycle spaces. Inclusion ufthis correction would not change the Draft E|R'sdetermination. The comment provides suggested corrections to Section UL Environmental Setting, Table 111-1, Related Projects, pages 111'11 through 111'12, and Appendix H.1,Traffic Study, Table 4 Related Projects Trip Generation Estimates, page 31ofthe Draft E|R. The correction |sincluded inthis Final E|RinSection \\|. 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 mfrestaurant 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 10the City ofManhattan Beach comment. Steven Keith *S.%aith@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. 8e|owareourreyponsos: Caltrans—Thedeve|operwiUconply with the Caltrans requests regarding the proposed mitigation atIntersection 24:|-405NB on/off-ramps8kRosecrans Avenue. APermit 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. ManhattanBeach—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 ofthe analysis. Ihave tracked the changes inthe 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 usknow ifyou have any questions. Steven Beach Cities Media Campus Project U.Response toComments City of El Segundo June 2019 2. ORGANIZATION AND INDIVIDUALS Comment letters from community organizations and individuals Include: 0 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 11. Response to Comments Page 11-23 DRVRYL'.r 7 510.836.4200 F 510.836.4205 Via Email and U, S. Uail 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 Comment Letter No. 7 1939 Harf Isom SLrect. Ste 150 www Iozeaddr ury-corn Qakland CA 94612 i*"r-hErotFi,lozc-aijdrt;rycot7i Gregg McClain, Planning Manager Planning and Building Safety Dept. Planning Division City of El Segundo 350 Main Street El Segundo, CA 90245 eiiieclailir(l,)elsep-uaido.orp, 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 Adanagement Dist., 60 Cal. App. 4th 1109, 1121 (1997). Sincerely, Richard Drury 1 7 City of El Segundo Comment Letter No. 7 LozeouDrury LLP Richard Drury on behalf of Supporters Alliance For Environmental ("SAFER")(sic) 1939 Harrison Street, Ste. 150 Oakland, Q\94612 April 12, 2019 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 ionoted for the administrative record and will beforwarded hmthe decision makers for review and consideration. The comment suggests the Draft BRfaUs as an informational document and fails to impose feasible mitigation measure to reduce the s impacts, but provides no specifics. The comment suggests that the Planning Division should address the shortcomings in o revised Draft E(R and nndrou|mte the revised Draft EIRpMortnapproval. The comment states itreserves the riQhttmsupp|ennentthecomments during the review of the Final E|R for the Project and at the public hearings. The comment does not idenbfv any specific shortcomings of the Draft EI0 analysis or mitigation measures, and no specific response /atherefore possible orrequired. Furthermore, and contrary tothe allegation inthis comment, the Draft E|R complied fully with all mfCE0A's requirements. The comment presents no substantial evidence to the contrary about any specific impact area. As provided in Section 15064(M/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 ULResponse toComments City of El 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 11. Response to Comments Page 11-26 Comment Letter No. 8 April 29, 2019 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: 07 Kate Gordon Director 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://ceqanet.opr.ca.gov/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, 109 e organ Director, State Clearinghouse cc: Resources Agency 1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812-3044 TEL 1-916-445-0613 state.clearingbouse@opr.ca.gov www,opr.ca,gov I STATE OF CALIFORNIA Governor's Office of Planning and Research x. State Clearinghouse and Planning Unit Gavin Newsom Governor April 29, 2019 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: 07 Kate Gordon Director 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://ceqanet.opr.ca.gov/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, 109 e organ Director, State Clearinghouse cc: Resources Agency 1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812-3044 TEL 1-916-445-0613 state.clearingbouse@opr.ca.gov www,opr.ca,gov I Jared Blumenfeld Secretary for Environmental Protection April 5, 2019 0 Department of Toxic Substances Control Meredith Williams, Ph.D. Acting Director 9211 Oakdale Avenue Chatsworth, California 91311 ce Ck Gavin Newsom Govemor GM0A0U6fPWdng1RAW=h Ethan Edwards, AICP APR 2 9 2019 Contract Planner City of El Segundo, Planning Division STATECLEARINGHOUSE 350 Main Street El 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. Ov PnOed on Recycled Paper Mr. Ethan Edwards April 5, 2019 Page 2 DISC 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. 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 Kereazi�s 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 Response 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 IL Response to Comments Page 11-30 Ak Z() I JA' 1, to Comment Letter No. 9 Department of Toxic Substances Control C4__CV" Meredith Williams, Ph.D. G q% Jared BlumenfeldGavin Newsom Secretary for Acting Director AN Governor Environmental Protection 9211 Oakdale Avenue Chatsworth, California 91311 April 5, 2019 GMMVWU6fFkWn9&fiQW,,=h Ethan Edwards, AICP APR 29 2019 Contract Planner City of El Segundo, Planning Division STATE CLEARINGHOOSE 350 Main Street El 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. �D Printed on Recycled Paper Mr. Ethan Edwards April 5, 2019 Page 2 ---I 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.g�ov. 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. Sincerely,,---) 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 El 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 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, 197'0, 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 LIST. In May 2002, the, 1,000 -gallon skim oil LIST, 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 El 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/Kerdloon 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. 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. Basedi 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 I 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 11. Response to Comments Page 11-33 City ofBSegundo June 2019 The comment states the document should identify the mechanism b,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 toAir Products and Chemicals, all US?sinstalled bv Air Products and Chemicals have been removed from the Project Site. Based onthe data collected and work performed by Air Products and Chemicals, the RWQCB issued a NFA determination for the soil on August 21,2O17,which isincluded aoAppendix E.2inthis Draft BR. Asstated inResponse toComment 9-2, the Regional Water Quality Control Board has jurisdiction over the Project Site. Aaindicated imthe 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 mfthe project, soil contamination is 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 isreferred toResponse toComment 9-8. The comment states DTSC provides guidance for Preliminary Endangerment Assessment /PBA 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 U.Response toComments Comment Letter o.10 Ethan, On behalf of the applicant, Rosecrans -Sepulveda 4, LLC, we offer the following minor comments on the] DEIR. 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 El R 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 D Page IV.M-2 — reference Figure IV.M.1-1 0 Page IV.M-4 — reference Figure Table IV,M,1-2 0 Page IV.M-5 (first occurrence) — reference Table lv.M.1-4 0 Page IV.M-5 (second occurrence) — reference Table IV.M.1-5 0 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 l 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: lisa(a)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 I City of El Segundo Comment Letter No. 10 Lisa Kranitz Wallin, Kress, Reisman &%rambzLLP 1135SOlympic Boulevard, Suite 3OO Los Angeles, California 90064 March 25,2019 June 2019 This comment states on behalf ofthe applicant, Rosecrans -Sepulveda 4, LLC, Wallin, Kress, Reisman 8k Kranitz LLP has minor comments on the Draft EIR. This comment is noted for the administrative record. This comment states that the analysis of Noise refemces Mitigation Measures H-1 through H-7, but these measures do not exist. The commenter states as the E|R concluded that the impact was less than significant without mitigation, thus the commenter assumes that this language may have been left over from o previous document. The commenter states the Final B0shou|d delete these references. The correction is included in this Final E|R in Section U|. Revisions, Clarification, and Corrections onthe Draft E|R. The correction deletes the referenced mitigation measures. inclusion ofthis correction would not change the Draft E|R'sdetermination. 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 Ill. Revisions, Clarification, and Corrections on the Draft E|R. The correction corrects the number ofhouseholds inthe South Bay region. Inclusion of this correction would not change the Draft EIR's determination. The comment states in the analysis on Water there are onumber of places where the document states "ErrorRefemce 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 isincluded inthis Final 8R inSection |||. Revisions, Clarification, and Corrections onthe Draft E|R. The correction corrects both the figure and the table sources. inclusion mfthis correction would not change the Draft E|R's determination. Resoo se toComment 10-5 The comment states none of these changes lead to any new significant impacts and donot create aneed for recirculation, This comment ionoted for the administrative record. Beach Cities Media Campus Project U.Response toComments Comment Letter No. 11 DRURY—! T SIO 8�6,A2,00 F S10836.420S BY E-MAIL AND OVERNIGHT MAIL May 21, 2019 1939 Harrison Street. Ste 150 Oal(iand. CA 94612 Chairperson Ryan Baldino and Honorable Members of the City of El Segundo Planning Commission Planning and Building Safety Department, Planning Division 350 Main Str-- -• •• eegundoCalifornia 90245 rbaldino0elseoundoccb.orq; bnewman@glsegundoccb,orq; cwngate@elsegundoccb.org Ethan Edwards, AICP, Contract Planner City of El Segundo Planning and Building Safety Department, Planning Division 350 Main Street El Segundo, California 90245 eedwardsO , elsegundo.org 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 1 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 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 Projects impacts. Beach Cities Media Campus May 21, 2019 Page 2 of 8 Commenters request that the City of El Segundo ("City") address these shortcomings in a revised draft environmental impact report ("RDEIR") and recirculate the document prior to considering approvals for the Project. I 1. LEGAL STANDARDS TUIlest pos5loje proleclifun LQ Ult� 0[111WHIMN11 T7TVTMnFF-r language," Comm, for a Better Envt 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)(I)"Its purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are rnade. 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 COM177'rS, (2001) 91 CalApp. 4th 1344, 1354 ("Berkeley Jets"); County of Inyo V. Yorty (1973) 32 Ca I.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 Cal3d 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." CEA Guidelines § 1002(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: 1 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 Commrs (2001) 91 Cal.App.4th 1344,1367; People v Kern (1976) 72 Cal.app3d 761) A reasoned analysis of the issue and references to supporting evidence are required for substantive comments raised. (Calif Oak Found. v Santa Cladta (2005) 133 Cal.AppAth 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, 2019,1but 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, i 3 South Coast Air Quality Management District ("SCAQMD"), Department of Toxic 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 Ill. 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 RV' QCB 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 TPHI, lead, and PCBs; and VOCs were detected in soil vapor. Based on the data collected and work performed by Air Products and Chemicals, the RW0C8 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 OUR, 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 RUIeS, 1166 and 1466. (FEIR, 11-12). 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 Cai.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, 11-35). CEQA requires implementation of all feasible mitigation measures. These measures are clearly feasible, and the FOR 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. O�EHIHA 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. (ld.) Projects lasting more then 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. (1d.) The Project would last at least 30 years and certainly much longer than s,ix months, Therefore an HRA is required. Health risks can often be gated 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 feasibl�., gation 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 IVD-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 GH!Gs. 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 I 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 re!uirements, 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 111-2). 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 151 26.4(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 decisionm a, king. 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," (Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 307.) "[Rleliance on tentative plans for future mitigation after completion of the CEQA process significantly undermines CEQA's goals of full disclosure and informed decisionmaking; and[J 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. 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 typicaHY used in residential and office building crn 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, SLIch 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 w,••_ 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) ofthe California Air Resources Board (CARB), 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 SCAOMD'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 GARB rules went into effect. Even though new buildings conforming to CARB's ATOM had a 30% lower median indoor formaldehyde concentration and, cancer risk than buildings built prior to the enactment of the A,TCM, 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. Beach Cites Media Campus May 21, 2019 Page 8 of 8 IV. CONCLUSION Forthe foregoing reasons, the FIR fails to meet the requirements of CEQA, We urge the City to require preparation of a Revised Draft FIR 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 r Addressing Climate Change at the Project Level California Attorney General's Office Ab A 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 hftp,//aq.ca.qqv/olobialwarminiolceaa/cieneralr)lans,oho.) 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 r changes or mitigation — is for the local agency, exercising its informed judgment in compliance with the law and balancing a variety of public objectives. ML it.igation, Measures by Cates Energy Efficiency Incorporate green The California Department of Housing and Community Developmenfs Green building practices and Building & Sustainabifity Resources handbook provides extensive links to design elements. green building resources. The handbook is available at http:/Nvww.hcdca.q2M/�lhpd/oreen build.Ddf. 1AGC?, 6Z11,.,,.- AJLLl I I U1 .11 -11 -1--111--. .-I . I - 1 1- � -- 11 - ... - .1.11--- .1-l!"11-1-- I I .�-- .... I -� --.1-1---1--.- ... I 1 -1 -- � - -1 . 1.x,,.,.„„„1.,,, 111'-, 0 Project Level Mitigation Measures Page 1 [Rev. 1/6/20101 Available at,httpJ/a ca,aovJoIobaIwarmina1bdf1GVV mitioation mleasures,oldf Meet recognized green For example, an ENERGY STAR-qua4fied building uses less energy, building and energy is less expensive to operate, and causes fewer greenhouse gas efficiency benchmarks. emissions than comparable, conventional buildings hftD//WWW.enercUgaL,_oov/index.cfM?o_=_business.bus index, . California has over 1600 ENERGY STAR -qualified school, commercial i and industrial buildings. View U.S. EPA's list of Energy Star non- residential buildings at http://wWw,enerqy§Lar ,govfindex.cfm?fuseaction=labeled buildinc&J.9c Los Angeles and San Francisco top the list of U.S. cities with the most ENERGY STAR non-residential buildings, htti)"//www,enerovstar,,00vlial'business/downloadsJ2008 Too 25 cities chart.odf. 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, bfto://www,e:nerevster,00vlialnew homes/mill homes/too 20 markets. =1. Builders of ENERGY STAR homes can be more competitive in a tight market by providing a higher quality, more desirable product See hfto://www.enerovstar.00v/riai'Dartnerslmanuf res/Hodon pdf. W elm Builder program. AGO, Project Level Mitigation Measures Page 2 (Rev- 1/6/2010) Available at tat g:_//ag,0, ov/alobaIwarmja9Lpdf/GW mitmation measures,od 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,/Mww,enerovstar,aov/index,ofm?fuseaction=find a Droduct. 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-J/www.ar)oiiances.enieray.ca.govl, The Electronic Product Environmental Assessment Toot (EPEAT) ranks computer products based on a set of environmental criteria, including energy efficiency, See Mo,,/AArww,eoeat,net/AboutEPEAT,asZ, The nonprofit American Council for an Energy Efficient Economy maintains an Online, Guide to Energy Efficient Commercial Equipment, available at httD;//www aceee.oro/ooeece/Chl 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 hftDJ/www,fvDower.oro/. AGO, Project Level Mitigation Measures Page 2 (Rev- 1/6/2010) Available at tat g:_//ag,0, ov/alobaIwarmja9Lpdf/GW mitmation measures,od Use passive solar See U.S, Department of Energy, Passive Solar Design (website) design, e.g., orient hftD,/Avww,enerovsavers,ggyLyour home,rde ionina remodefino/index.cfmAmLt buildings and 061c=10250. incorporate landscaping to maximize passive See also California Energy Commission, Consumer Energy Center, Passive solar heating during Solar Design (website) cool seasons, minimize Lto://www.consumiereneravoeiiter.oro/home/construction/solardes'antindex,ht solar heat gain during MI. 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,q- Install light colored A white or bight 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 roof's 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 htto:Hwww. consumerenergvicenter, ora/coolroof/. See also Lawrence Berkeley National Laboratories, Heat Island Group (webpage) attt / eetd.lbt,agv/Heatlsland/. Install efficient lighting, LED lighting is substantially more energy efficient than conventional lighting (including LEDs) for traffic, street and other and can save money See htto:/ enerov.ca,aov/efficienov/cartnershio%ase studies/TechAsstCitv_.p 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 httD,//www,enerov.ca.00v/200l5oublica:tOns/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 htto://www. a nerov, ca, oov/efficienov/ria rtnershio/, Reduce unnecessary See California Energy Commission, Reduction of Outdoor Lighting (webpage) outdoor lighting. athttp://www.eneraV,ca.00viefficiencyiohtinct/outdoor reduction.html. AG....—J2111111. 1.11 .. _ .._...................... O Project Level Mitigation ...,, a.. Measures [Rev. 1/612010] Available at l t ):LLaq,ov/'alobal'warmin /WVGW mitioation Page 3 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, htto:llwww,consumerenercWMterlorothome/outside/pool§ s2gs,html. See also Sacramento Municipal Utilities District, Pool and Spa Efficiency Program (webpage) at httD/twww.smud,oro/e,n/residential/savinq- grgrgyPaoes/cook O,aspx, 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 httDI/WWW,stocktonaov.com/ener%a4vina/index,ofm. See also "Green County andfor tenants. San Bernardino," httD://Www-areencountvaLco a 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 ILtto:/Iwww,theVillashoa.orolareenteneroy/, 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 (CIEC) 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 httD,//www-enerqLca.00v/2009oublications/CEC-100-2009-003/CEC- 700.2009-003-CMIZ,13OF: CPUC, Long Term Energy Efficiency Strategic Plan (Sept, 2008), available at Ltto://www.or)ulc,ca,aov`/PUC/enerav/Enerav+Efficienov/eeso/ 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 hfto:ltwww,aosolarcalifornia,ora/, As mitigation, a developer could, for example, agree to participate in the NeWSofar Homes program See htto://www,00solarcalifornia,orcUbuildersfindex,html. 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 hftD-.//www,c;Luc,ga,,qov DucJenercIy/soIar/swh,htm. To search for available residential and commercial renewable energy incentives, visit Flex Your Power's website at htto:/Avww fvoower,o(qL, !'L ............ -,L1--1---1_ l4�. . . ............. ......... AGO, Project Level Mitigation Measures Page 4 (Rev. 1/6/2010) Available athttD-/Iaa.ca.aov/alobalwarmina/odf/GW miliciation measures.od 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:l/www,sce.com/solarleadershio/solar-rooftoor)rooramtqenera:V,- facOtm. TUTI 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 bttp,.//walmartstores,com/FactsNews/NewsRoonV909I.aspx. 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 aov.oro/osa/Alameda*/020Countv�/`�20- %20SoIar%2OCase%2OStudv odf. In 2007, California State University, Fresno installed at 11 -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. hfto1A.vww.fresnostatenews.com/2007/11/Solarwragg22..�t—m. Where solar systems U.S. Department of Energy, A Home,builder's Guide to Going Solar, (brochure) cannot feasibly be (2008), available at lZm/Awm,eere, enerov oov/solartodfs/43076,off 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 hftr),//Www.nrel.qov/docs/fv05osti/3760,2 odf. 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 htto:/]Www.datfvherd.corTVdirectories.asr)?oa)D=.724&ed id=8409, (additional California examples are included in article.) AGO, Project Level Mitigation Measures Page 5 (Rev V612010] Available at httor/lao.ca.00v/olobalwarmino/Ddf/GW mitioation measures,odf Include energy storage See National Renewable Energy Laboratory, Energy Storage Basics where appropriate to (webpage) at httoltwww, nrel,q2y1q§jrV_a/eds enerov storace, htmi, optimize renewable biogas per day and enough fuel to run two heavy duty trucks. This has reduced energy generation California Energy Storage Alliance (webpage) at systems and avoid tdof/store ega Iliance. oro/a bout. html. peak energy use. Ltto.//www,arb.ca,00vinewsrellnrO21 1,09b, htm: see also Public Interest Energy 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 hfto;//www,enera,v,oa,aov/2006Dublications/CEC-4,00-2006-006/CEC-400- 7006-006-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 Ltto.//www,arb.ca,00vinewsrellnrO21 1,09b, 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:lhvww,enerqy.ga,qov/2006;)ubPications/CEC 500 2006 083/CEC 500 2006 om,PIJF, _T" California, See Tom Frankiewicz, Program Manager, U.S. EPA Landfill Methane Outreach Program, Landfill Gas Energy Potential in California, available at Lfto,//www,enerav,ca,00v/2009 eneraygo Jicy/documents/2009-04- 21 «« «, Enaineers Presentption._odf. 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 ......... . . . . . ..... _'�. 1 111 J Project Level Mitigation Measures Page 6 (Rev 1/6/20101 Available at httollao,ca aov1olobaIwarmincVodf/GW miti:oation measures.Ul 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://www,eoa.cov/cho/`documents/C,ataloa of %20chD tech entire.odf and California Energy Commission, Distributed Energy Resource Guide, Combined Heat and Power (webpage) at htta:l/www,eneraX,cgLaov/distaenleouiomenYchplgb2,btrol, 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. I t7tto://www,epa,qov/0hp/basic/efficiencv.html, Currently, CHIP in California has a capacity of over 9 million kilowatts, See list of California CHID facilities at htto./Iwww,eea-inc,corrVchodata/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 CHIP 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 btto-./twww.enerov,ca.aov/wasteheat/. 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 86 billion gallons of diesel fueleve ryyear, See llo://www�enera:vca,gov/2007oublicati,ongQEQ_999 2007 008tCEC 999 2007 008 � PDF '. Reducing water use a4improving 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,//www.water, ca, oovtwateruseefficiencvAandsoaDeordinanoe/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 hfto:l/www,cwmb.ca,aov/oroanies/XeriscaetDc �RG�O -14,11 ... ... .... . U111.1,�_'.,.._ � I'll Project Level Mitigation Measures v. 1/6/20101 Available at hftr)°//aa,ca,aov/olobalwarminQ/r)df/GW Page 7 Install water -efficient U.S. Department of Energy, Best Management Practice". Water -Efficient irrigation systems and Irrigation (webpage) at devices, such as soil btlo:/Iwwwl,eere,enercLg_o_vLfe—rngWL9.WnVw@terefficiencv bMq5,htpl. moisture -based irrigation controls and California Department of Water Resources, Landscape Water Use Efficiency use water -efficient (webpage) atbW://www,water.9p..gov/wateruseefficiencv4andscar)e/`, irrigation methods. Pacific Institute, More with Less: Agricultural Water Conservation and Efficiency in California (2008), available at bgo://www.pacinst,orq/�Mports/more with less deltafindex.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:l/www.documents.css.ca,caovlbsc120001iartll 2008 caloreen code. Qdf waste water from bathtubs, showers, California Department of Water Resources, Dual Plumbing Code (webpage) at bathroom wash basins, http://www,w,ater.ca,,qov/recvciino/DualPlumbinqgodel. and water from clothes washing machines. See also Ahwahnee Water Principles, Principle 6, at Graywater to be used htto://www,lqc.oro/hwahnee/'h2o gIJncioleshtmI. 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, Mahn 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 US. EPA, Low Impact that maintain the Development (webpage) at httD:1/www,e0.gov/nos/Iid/- 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. httr)llwww.coastal,ca.q2ylnps/lid-factsheet,Q1, 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 h:t:to,//www, areen ca . aov/E PP/bui tdina(SaveH20, him, and appliances. Many ENERGY STAR products have achieved their certification because of water efficiency. See California Energy Commission's database, available at httr)J/www.appl,ianicer>,eneLgy.ca,gpv, .1_.4!3!,..._ I'll I., 111111�11.1 "I'll .."'! , _ .1 � ., "'.11111---11111, 1 - 44 . .......... AGO, Project Level Mitigation Measures Page 8 [Rev, 1/612010] Available at httD'//aa,ca,cov/alobal,waro2inar)df/GW miticiation measures,Ddf 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 uwmD 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 h_fto,l/www,ci.santa-cruz.ca,ustindex.asp2�2oaiae95; Santa Clara Valley conservation and Water District, Water Conservation at available programs and Wt' D,//W\WW.valle\oyalgr_,qro/conservationftndex.shtm, and Metropolitan Water incentives. District and the Family of Southern California Water Agencies, Be Water Wise athttol/www,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 Ltto1/www, ciwmb.ca. oov/condemo/. lumber, metal, and contains examples of "best practices!" for reducing greenhouse gas emissions, cardboard). organized around waste reduction and recycling goals and additional examples 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 MtD,//2erowaste.ca.,00v/ projects. The Institute for Local Governiment'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 hfto:/Iwww.ca-ile,o,ra/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, _t1tto,//,zerowaste.ca.qov/. 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 reevclebutte net. recycling services. Project Level Mitiga-ii-on" .... . ......Measures'' - ,," .. .. . ......... . .. . ..... . .. ...... . ........ .. .................... ... . . . ........ . ........... . .. .... . ..... Page 9 [Rev. 1/6/2010] Available at htto//aa,caaov/aobalwarminatgojL(W mi�tioation rneasures,Q�J Land Use Measures Ensure consistency U.S. EPA maintains an extensive Smart Growth webpage with links to with "smart growth" examples, literature and technical assistance, and financial resources. See principles — bgo://www.era.aov/smartarowtIVindex,htm. mixed-use, infill, and higher density projects The National Oceanic and Atmospheric Administration's webpage provides that provide smart growth recommendations for communities located near water. See alternatives to individual Coastal & Waterfront Smart Growth (webpage) at vehicle travel and t%o:llcoastatsmartarowth.noaa,qM/, The webpage includes case studies from promote the efficient California, delivery of services and goods. 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 htto,,/,/www,,eneray.caaovAanduse/` The Metropolitan Transportation Commission's webpage, Smart Growth I Transportation for Livable Communities, includes resources that may be useful to communities in the San Francisco Bay Area and beyond. See bgo,/Iwww.mte.ca.cov/olannina/smart arowth/. 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,sacoo.oraireaionaVfundingloetterwa.vs,qdf 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 LEEN-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 12ttD://WWW.usabc,ora/Dis[)IavPaae,asox?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.egaaov/aoinqlbho�a U S. EPA, Environmental Benefits of Smart Growth (webpage) at htto:://www,ea._oov/deed/topies/eb,htm (noting local air and water quality improvements). Centers for Disease Control and Prevention (CDC), Designing and Building Healthy Places (webpage), at Wt P,,//www.odc.ciov/healthyplacest. 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 hUoI/www, hod ca aov1hcd/mvthsnfacts.@fff, � II I. .-..-I'�1-11,1111,,..",��.,. 1111---,....".".,'.."..,l".'ll"".� �...,.-,.�.-- -.11I . .. . ..... . III �Lll X66, Project Level Mitigation Measures Page 10 [Rev. 116/2010] Available athtto,//aa,ca,aovtafobalwarminatr)df/GW miticiation measures,rgli Incorporate public Federal Transit Administration, Transit -Oriented Development (TOD) transit into the project's (webpage) atjet C)',//Www.fta.dot.aov/2Lqi "�olannina environment,6932.html� 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 b=,,/Jtransitarierlteddevelor)ment. dot ca.00v/miscellaneous/StatewideTOD, him Caltrans, California Transit -Oriented Development Searchable Database (includes detailed information on numerous TODs), available at http://transitorienteddevelooment,dot.ca.00vlmiscellaneous/NewHome,ice. California Department of Housing and Community Development, Transit Oriented Development (TOD) Resources (Aug. 2009), available at Lttr)://www,hcd.ca.cov/h;)d/tod.pdf. Preserve and create U.S. EPA, Smart Growth and Open Space Conservation (webpage) at open space and parks. htto://www.er)a.aov/dred/ovensoace.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 htto,-//www.eca, oov1dced/brownfieId& him, 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 htto Wwww. loc. orqlfte_e_oub/docs/communitv gesign/fact sheets/er case studi g1,p_df, For financial resources that can assist in brownfield development, see Center for Creative Land Recycling, Financial Resources for California Brownfieids (July 2008), available at httD:/AArww,ccir,ora/media/oublications/8 Financial, Resources 2008-qLf. 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://www.fhwa dot ov/environment/bike d/, 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://www, dot, ca aovtho&rAffops/survev/oedestrian/TR MAY0405.odf. This reference includes standard and innovative practices for pedestrian facilities and traffic calming. easures.cd Page 11 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 being 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 htto://www,enerov.ca,aov/2007oublications/CEC-600-2007- 008IGEC-600-2007-008-SF.PDF- 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." id, 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 I Community Places, Finding the Balance Through Smart Growth Solutions (Jan. 2006), available at httD°/lwww.eQg.cov/deed/Ddf/EPAParkinaSr)acesO6, pdf. Reforming Parking Policies to Support Smart Growth, Metropolitan Transportation Commission (June 2007) at htto://www,mte,ca.covfolannina/smart crowtNoarkina seminarfToolbox Handbookodf. See also the City of Ventura's Downtown Parking and Mobility Plan, available at htto://www,citvofventura,net/communitv develoomenVresources/mobility garki ng 121an-2df, and Ventura's Downtown Parking Management Program, available at htto,/Iwww,ci,ve,ntura.ca.us/der)ts/commdev/downtownr�anlchaolers.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, § 210643.) Transit Oriented Development (TOD) is a moderate to higher density development located within an easy walk of a major transit stop. tLttot/transitorienteddevelot)ment dot.ca oov/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 1/6/20101 Available at htto:i/aa.ca,aovlaiobalwarmina/DdflGW mitmation measures.D& 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 Ut o//www,its.dot,aov/JPODOCS/REPTS PR/13669.h=, employees, or free ride areas to residents and The Ernery 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 htto1Mww,emeVoround court. Seattle, Washington maintains a public transportation "ride free" zone in its downtown from 6:00 a.m. to 7,00 p.m daily. See httD;//transit.metrokc.aov/toos/accessible/oaccessible mao.htmittfare. I Promote "least Promoting "least pollutin4* methods of moving people and goods is part of a polluting" ways to larger, integrated "sustainable streets" strategy now being explored at U.Ca connect people and Davis's Sustainable Transportation Center. Resources and links are available goods to their at the Center's website,,ttLtp://sto,ucdavis.edu/outreach/sSD,Dho, I destinations. Incorporate bicycle Bicycling can have a profound impact on transportation choices and air I 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./lwww,arb.ca,cLov/olannino/tsaa/bicvcle/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 btlo;//www,fhwa,d0tr(3ovlenvironment/bikeDed/Dublications,htm., See also Caltrans Division of Research and Innovation, Designing Highway Facilities To Encourage Walking, Biking and Transit (Preliminary Investigation) (March 2009), available at Wo;//www.dot ca.cov/researchlresearchreoorts/rarely minary investioations/doc s/cii-desion for walking %20bikina and transit%26final,pof, 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. httD://www.arb.ca,00violaninina/tsao�/bbLevcle/factsht,htm. . . . ......... AGO, Project Level Mitigation Measures Page 13 [Rev. 1/6/2010] Available atbD2,/Lao,ca.aov/atobalwarmina/'odflGW mitiq@Lio mleaisures,cd Ensure that the project See, e.g.:, U,S. EPA's list of transit -related "smart growth" publications at enhances, and does not b=://www.eDa.00v/deed/oublications,htm#airincluding Pedestrian and disrupt or create Transit -Friendly Design: A Primer for Smart Growth (1999), available at barriers to, non- wwLg2aaov/dced/Ddf1otfd Drimer.od. motorized transportation. See also Toolkit for Improving Walkability in Alameda County, available at bicycling. t9r)"//www,acta2002, coratpLq too ' cad toolkit orin JkV Create bicycle lanes Pursuant to the California Complete Streets Act of 2008 (AB 1358, Gov. Code, and walking paths §§ 65040.2 and 65302), commencing January 1, 2011, upon any substantive directed to the location revision of the circulation element of the general plan, a city or county will be of schools, parks and required to modify the circulation element to plan for a balanced, multimodal other destination points. 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 =,//www.waIkscore.com/. paths and trails to encourage walking and In imany markets, homes in walkable neighborhoods are worth more than bicycling. similar properties where walking is more difficult, See Hoak, Walk appeei Create bicycle lanes Homes in walkable neighborhoods sell for more: study, Wall Street Journal and walking paths (Aug. 18, 2009), available at hfto:/Mrww,marketwatch.cortVstory/homes-in- directed to the location walkable-neiohborhoods-sell:For-more-2009-08-18, of schools, parks and 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 Mo://tranisformca, ora1windfa lI-for-alWdownload-reDort. 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 tLto://www.rdoh,ca,cov/Healthlnfo/iniviosaf/��Paoes/SafeRoLdestoSchool.asox, vehicles_ Seealso U.S, EPA, Smart Growth and Schools (webpage), available at ItLto:/Avww,er,)a.aov/dce,d/schools, htm. California Center for Physical Activity, California Walk to School (website) at httD://www.cawalktoschool.com 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 htlr)!I/www.arb.,ca,aov/Msr)roo/Schoolbus/schoolbus, htm AGO, Project Level Mitigation Measures Page 14 [Rev. 1/6/2010] Available at=�/Lagca.Mv/alobalwarmina/Ddf/GW mitfoation meas urqs,= 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 hfto//www,eQ"ov/otao/stateresources/rellinks/mms corloqrams h programs to reduce and Telework the federal government's telework website, at unnecessary employee httD:/Iwww,telework,qov/. transportation keeping tires inflated); Through a continuing FlexWork Implementation Program, the Traffic Solutions and low or zero- division of the, Santa Barbara County Association of Governments sponsors emission vehicles. flexwork consulting, training and implementation services to a limited number of Santa Barbara County organizations that want to create or expand flexwork Purchase, or create programs for the benefit of their organizations, employees and the community. incentives for See htto-://www.flexworksb,corrVread more about the fSBg_.html. Other local purchasing, low or zero - government entities provide similar services. Provide information on Many types of projects may provide opportunities for delivering more tailored alternative transportation information, For example, a homeowner's association could transportation options provide information on, its website, or an employer might create a for consumers, Transportation Coordinator position as part of a larger Employee Commute residents, tenants and Reduction Program See, e.g., South Coast Air Quality Management District, employees to reduce ;Transportation Coordinator training, at httr)://www,aqmd.00v/transAraino.htmi, transportation -related emissions. Educate consumers, See, for example U.S. EPA, SmartWay Transport Partnership° Innovative residents, tenants and artw po wh,a - Carrier Strategies (webpage) at htto:1Avww.eplm avArans rt/ I the public about options smartwav/carrier-strataqg§.htm, This webpage includes recommendations for for reducing motor actions that truck and rail fleets can take to make ground freight more efficient vehicle -related and cleaner. greenhouse gas emissions. Include The Air Resources Board's Drive Clean website is a resource for car buyers to information on trip find clean and efficient vehicles. The web site is designed to educate reduction; trip linking; Californians that pollution levels range greatly between vehicles. See vehicle performance btto1/www,drivecIean.ca.00v/. and efficiency (e.g., keeping tires inflated); The Oregon Department of Transportation and other public and private and low or zero- partners launched the Drive Less/Save More campaign. The comprehensive emission vehicles. website contains fact sheets and educational materials to help people drive more efficiently. See httoJ/www.drivetesssavemore.com/` Purchase, or create See Air Resources Board, Low -Emission Vehicle Program (webpage) at incentives for proo/ evoroo.hl htio://Www.arb,ca,aovinisqLgq/levI purchasing, low or zero - emission vehicles. Air Resource Board, Zero Emission Vehicle Program (webpage) at httt)://www.arb.ca,00v/msoroo/zevoroq/gev2rog,htm, 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 I (dirtiest) to 10 (cleanest) To search and compare vehicle EP Labels, visit www, DriveClean, ca, q2v. x6a, Ji _ 11..L ...... Project Level Mitigation Measures Page 15 (Rev. 1/6/2,0101 Available at_Utc):/Iaa-ca:,aov/alobalwarmino/r)dt/GVV' mitioation measures,o_& 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 I transportation. For example, the 511 Regional Rideshare Program is operated by the the Federal Highway Administration,Department of Transportation, the Metropolitan Transportation Commission, the Bay Area Air Quality Management District and county congestion management agencies. For more information, see _�Uolflrideshare.51 1,orq�, with large and small employers, as well as providings7uppo7rt to commuters 5 who wish to share rides or use afternative forms of transportation, See hfto�l/www,sanbao.caaov/Commuter/ricL*share.htM),r Valleyrides cam is a ridesharing resource available to anyone commuting to and from Fresno and Tulare Counties and surrounding communities. See hft0/Www,vaIlevddes,corTV, 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 htti:x//Www,citvcarshare.oro/, and Zipcar, see ILttoWwww.ziocar, cornk 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 hfto://www,sacramento- Create local "light See California Energy Commission, Consumer Energy Center, Urban Options vehicle" networks, such - Neighborhood Electric Vehicles (NEVs) (webpage) at as neighborhood Ltto://www.consumereneravcenter.oraltransoortatiorL/urban ootions/nev,htmi, electric vehicle systems. The City of Lincoln has an innovative NEV program See httoWwww. lincolnev, comlindex, h�M.. 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 1,$300 per violation. See httD/lwww,arb.ca.cov/enf/comolairits/idlino cv,htM. construction vehicles. Provide the necessary For a list of existing alternative fuel stations in California, visit facilities and 1 htto://www.cleancarmaos.conV. infrastructure to encourage the use of See, e.g., Baker, Charging -station mirk built along 101p S.F. Chron. low or zero -emission (9/23/09), available atbAo:/Iarticies.sfqgLe,-com/2009-09- vehicles, 23/news/17207424 1 rechgLqin_a-soler-firrav-tes.la-motors. II--....- . . ... ..... ..... . . . ...... ..... . ...... . .. .... ........ . ..... ...,,.,.-..,,,,,,,,,,,,.......,....W..,.,,..._,° AGO, Project Level Mitigation Measures Page 15 [Rev. 1/6/20101 Available at hittD,//aa,ca,aov/olobaiw,a,rmino/odf/GW mitioation measures,Wf Agriculture and Forestry (additional strategies noted above) Require best Air Resources Board (ARB), Economic Sectors Portal, Agriculture (webpage) management practices at=,r//WWW.arb,ea.aov/cc/cdLasectors/0hosectorsk�" ARB'swebpage in agriculture and includes information on emissions from manure management, nitrogen animal operations to fertilizer, agricultural offroad equipment, and agricultural engines, reduce emissions, 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,/MwwJV Dower. oro/agri/. biogas, wind and solar, Flex Your Power, Best Practice Guide / Food and Beverage Growers and Processors, available at htto://www.fvDower,otqLWindex,html?b=food and bey Antle et al., Pew Center on Global Climate Change, Agriculture's Role in Greenhouse Gas Mitigation (2006), available at htto;lfiwww.oewolimate,orcVdocUoloadslAoriculture's%2ORote%,20in!/020GHG�/`� 20Mitioation.pdf. 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. httg:i/www,eo.gov/seouestration/ a htm[ i Air Resources Board, Economic Sectors Portal, Forestry (webpage) at htto:t/www.arb.ca.aov/Cc/ahasectors/ohctsectors.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 l ILtto://www,fire.ca.ciov/resource mgt/resource mat urbanforestrv,oha and replacement ordinance. Off -Site Mi�tioation 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 [Rev, 1/6/2010] Available atDj�g, aov/alobaIwarmino/odf/GVV Page 17 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 hftD:I/www. climate rectistrv,o ra/.) • 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. a Programs to expand the use of renewable energy and energy storage. Preservation, and/or enhancement of existing natural areas (e.g., forested areas, agricultural [ends, 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, Project Level Mitigation Measures Page 18 [Rev. 1/6/20101 Available at htto.L@g,ca, ov1olobalwarmina1Ddf/GVV mitioation mearsurqs,of a � Indoor Air Quality in New California Homes with Mechanical Ventilation Wanyu Chan',% Yang-Scon Kim', Brett Singer', Iain Walker' I Lawrence Berkeley National Laboratory, Berkeley, USA 'Corresponding ei7?ail:wrchaii@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 (NOi), and PI\4z5 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 formaldehyde, NO2, and PNh.5 with a prior California New Home Study (CNHS) (Offermann, 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 surnmer 2018. 2 METHODS Integrated one-week concentrations of formaldehyde and NOx were measured using SKC U1vfEx-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-642/BT-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 I 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 L F 14 E P, OJ 0 20 40 o HFNGH CANH 60 so 100 120 V Lt E t3 U. E 0 20 30 Formaldehyde (ppb) NO2 (ppb) PM2 5 (ugfm3) 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 37 4.4 29 3.2 5.4 40 3 :�.O 3.1 11 3,1 35 PM2.5 (ug/rnl) 41 4.7 5.8 28 104 133 42 5,9 7.7 11 8,7 7.9 4DISCUSSION 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 BFNGH are similar to levels found in CNHS, the two studies differed in that HENGH homes all use gas for cooking, whereas almost all homes (98%) from the prior study used electric ranges. N4orc analysis is needed to determine the eftectivcness of source control, such as range hood use clujin,g cooking, on indoor concentrations of cooking emissions such as NO2 and PM2.5. Lower PMi--, indoors measured by IffiNCM compared to CNHS may be explained from a combination of lower outdoor PM2 5 levels, reduced particle penetration due to tighter budding envelopes (Stephens and Siegel, 2012) combined with exhaust ventilation, and use of medium efficiency air filter (MERV 11 or better) in some FIENGH 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 N07. and PX1z5 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, 6REFERENCES 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. 20121ndoor.=1 it 22(6):501-513. City of El 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 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. ftsoonse 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 El 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. 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 1.166 —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 11. Response to Comments Page 11-68 City of El 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 property 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 (Rev's) located on the Project Site. The commenterstates neitherthe Draft nor Final EIR contain any health risk assessment (HRA). The Draft EIR states that no HRA is required for toxic 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 lon&_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 HRA's- 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 11. Response to Comments Page 11-69 City of El Segundo June 2019 an HRA. As defined under the Hot Spots Act, anHRA includes acomprehensive analysis of the dispersion ofhazardous substances |nthe 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 inthe law, The process bvwhich Districts identify priority facilities for risk assessment involves consideration of potency, toxcity, 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. Aspart mfthis process Districts categorize facilities ashigh, intermediate, or low priority. (emphasis added)" High priorityfaci|hhesarerequiredtoprepenaanHRAandsubmittatheSCA[lMDforreviem/andapprovai 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 (~39Ometers) southwest and the multi -family attached and single- family detached residential dwelling units located approximately D.% rni|os (~322 meters) south of the Project Site. Afterconstruction iscomplete, the Project |1se|fwou|dnotbenotasourceoftoxicomisaions 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 mrmitigation measures are required. The commenter states that the E|R admits that the Project will have significant8reenhouse gas ("GHG") impacts. (FE|M 1'17, 18), "Proposed Puojecl!s unmitigated emissions are 6,007.71 metric tons of CO2 equivalents per year resulting in5.82K8TC0%e/SP/vear^(DE|R|V.D'31). The commenter states this isfar above the SCAQMDsignificance threshold for GHGsof3,DOOMT/vear. While the Draft E|Racknowledges that the Proposed Project's unmitigated emissions would exceed both the S[ACiMD Tier and Tier thresholds, the mitigation measures identified in the Draft E|R, MM D-1 through K8K8 O-4together 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 SCAQMDTier4 threshold of 4.8 MTCO2e/SP/yearfor projects (Draft E|R' page |V.0-41). The ewceedance of the 3,000 &0TC03e 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 Ca|EEK8od analysis provided in the Draft E|R and no substantial evidence is presented that would call this conclusion into question. Resomnse to Comment 11-7 The commenter states Ca[7ranssubmitted acomment concerning the 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 E|R,s TDM plan is deferred mitigation prohibited byCEQA. The commenter is referred to Section |V.K. Transportation, Traffic and Parking, page |V. K-46 which provides Mitigation Kneammne MM -K-1, which iythe Transportation Demand Management Program. These measures would need toreflect the characteristics wfthe Project asOna|\y constructed and occupied that cannot be presently known. Therefore, the Final BR includes the requirement that the City must approve the TDM plan prior to project opening. Beach Cities Media Campus Project fl. Response toComments 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, NO2 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. I 0 r 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 If. 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 ora feasible way to mitigate or avoid 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 ACIVIs 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 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-1 City of El Segundo June 2019 to !ead Nea!04 and Safety —1-d 1-41,- Thus imoacts from the release of hazardous materials into the environment would be less than 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 toand remove one ormore pipelines aswell asoverhead wires, conductors, cables and conduits, and appurtenances thereof, into the easement. The easement covers astrip ofland 43Y2 feet wide, and runs the entire length ofthe Project Site. The easement includes anexisting 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-41 impacts would bereduced toalevel ofless than significant. Section 1. Introduction and Summary, page 1-21, MM E-1 and MM E-2, revise as follows: anaiyaed for TPH, 1 OAA Drag n--_ as THP; KA&8E-21: Prior tothe issuance ofgrading penmits,theAppdinantshaUsu6m1tfina|dssignp|ansandadeai8n-|eve| geotechnical engineering report to the City of El 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. ATDN} oroeram will be irmm|emnented as Dart of'themitigation oachaRefor the Project. Several TDM PrmRmanme\ernemt's are PrmiectdesiRmfeatures that are currentk/ormDosedfor jnmo|ermentation. Other TDM orograrn elements would be de�Ve|moad as Dart pfpIeoemytimmmf adetai|ed TIDM o\en.tobeaoormvedbwCkwof E[Seewndo prior to amorova|ofafinal cerdfica:teofnccuriamcvfor the prmLqct. 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 111. Revisions, Clarifications and Corrections on the DraftBR City ofElSegundo June 2019 transit, walking, and biking. Strategies that are suggested asappropriate 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 imthe following. • Carpool encouragement, • Ride -matching assistance, w Preferential carpool parking, • Flexible work schedules for carpools, • Half time transportation coordinator; and = Vmnpwo|aosistance. = Due to the importance ofinformation sharing and marketing, marketing strategies toreduce commute trips would bmincluded as � New employee orientation oftrip reduction and alternative mode a Event promotions; and = Publications. Car Share Program—This Project could implement a car -sharing program tmallow people tohave on -demand access toashared fleet mfvehicles on an as -needed basis. User costs are typically determined through mileage orhourly rates, with deposits and/or annual membership fees. The car -sharing program could becreated through alocal 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 aguaranteed ride home option. Site Design—Project site will bedesigned 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. 111. PROJECT DESCRIPTION Section |tProject Description, page /1-8,revise os follows: Beach Cities Media Campus Project Ill. Revisions, Clarifications and Correctionsonthe DraftBR City of El 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 Wmi*61+kKR 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. Ill. ENVIRONMENTAL SETTING Section 111. Environmental Setting, Table 111-1, Related Projects, pages 111-11 through 111-12, revise as follows: Size 58 du 1,2,00 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 .&a 28 seats 7,000 sf 3,000 sf 4,700 sf 1,800 sf 1 d 5 du 5,000 sf 1.3, 000 sf 1,751,920 sf 73,580 sf 168,000 sf 148,1960 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 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-4 Table 111-1 Related Projects Address Land Use 1. 540 East Imperial Avenueb Residential 2. 201 North Douglas Street' High School 3. 400 Duley Road' Medical Office 4. 123 Nevada Street' Office 5. 2125 Campus Drive' Office 6. 2130 East Maple Drive and 725 Hotel Campus Square Westb Office 7. 140 Sheldon Streeti' Office/Warehouse 8. 740 North Sepulveda Boulevard" Drive through Restaurant 9. 1492 Hermosa Avenues iHotel 10. 2101 Pacific Coast HighwW Office 11. 8241St Streeta Office 12. 707 North Sepulveda Boulevarda Supermarket Restaurant Bank 13. 1800 Manhattan Beach Boulevarda General Office 14. 2205 North Sepulveda Boulevard' General Office 15. 1762 Manhattan Beach Boulevard' Medical Office Apartment 16. 757 Manhattan Beach Boulevard" Condominium 17. 1101 Manhattan Beach Boulevard' Medical Office 18. 1100 Manhattan Beach Boulevard" Retail 19. 2100 East El Segundo Boulevarda Office Warehouse Industrial Retail 20 500 South Douglas and 2330 Utah General Office Avenue b 21. 2171-2191 Rosecrans Avenue" Restaurant 22. 2516-2520 Nelson Avenue" Condominium 23. 2430 Marine Avenue' Hotel 1 24. 305 South Sepulveda Boulevard, Design Center 330 South Sepulveda Boulevard, and Executive Offices Hermosa Beach Sites' Coffee Shop General Office Size 58 du 1,2,00 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 .&a 28 seats 7,000 sf 3,000 sf 4,700 sf 1,800 sf 1 d 5 du 5,000 sf 1.3, 000 sf 1,751,920 sf 73,580 sf 168,000 sf 148,1960 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 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-4 City of El Segundo No. Address 25. 1700 East Imperial alAvenueb i� 26. 750 South Douglas Streeta 27, 1133 Artesia Boulevarda 28. 865 Manhattan Beach Boulevard' 29. 1000 North Sepulveda Boulevarda 30. 31 32. Table 111-1 Related Projects Land Use Office Industrial Grocery Store General Office Deli StipefFAad—i-I Medical Office Coffee Shoo 445 North Douglas Street' Office 455 Continental Boulevard and 1995 Office East Grand Avenue' 2420 Pacific Coast Highway' 33. 3200-3600 North Sepulveda Boulevarda 535 Indiana Street' 700-860 South Sepulveda Boulevard, 2001-2015 East Park Place, and 700-740 Allied Way Boulevard' 36, 14500 Aviation Boulevard` 37, 1301 El Segundo Boulevard' New Church Supermarket Shopping Center Residential Shopping Center Credit Union Office I I Warehouse du = dwelling units sf = square feet rm = rooms stu =students Related Project information provided by Erik Zondviiet, City of Manhattan Beach, November 6, 2017 Related Project information provided by Ethan Edwards, City of El Segundo, January 23, 2018. Related Project information provided by City of Hawthorne, January 18, 2018. Source: Fehr and Peers, LLC, November 2018. W.A. AIR QUALITY Section IV.A. Air Quality, pages IV.A-12 through IV.A-13, revise as follows: June 2019 SIze 86,520 sf 1,,990 sf ,000 sf 15,000 sf 700 sf _,,_@02&050sf Q,099 §6_5 sf 5..sf.. 155,660 sf 300,000 sf 32,190 sf 30,080 sf 110,000 sf 4 d 18,850 sf 300 sf 6,270 sf 5,880 sf 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 Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-5 City of El Segundo June 2019 Handbook (SCAQMD CEQA Handbook) prepared by the SCAQMD (1993) with the most current updates found at hjtR,//www.aqmd2 0_vLc_ec1a/hdbk.htrnl, 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. 141 SCAQMD Rule 1166 This rule sets reauirements to control the emission of Volatile Organic Comoounds (VOC) from excavating, grading, handline and treating VOC-contaminated soil as a result of leakage from storage or transfer goerations, accidental soillage, or other deoosition. Lh_e_p_uroose of this rule is to minimize the amount of off-site fugitive dust emissions containing toxic air contaminants by reducing oarticulate emissions in the ambient air as a result of earth-movine activities, including, excavatine. grading, handling, treating, stockpiling. transferring, and removine soil that contains aoulicable toxic air contaminants from sites that rneet the applicability reauirements of subdivision (b), U4 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: 1 http://Www.oqmd.govlhomelregulationslceqolair-quality-onalysis-handbook. Beach Cities Media Campus Project Ili. Revisions, Clarifications and Corrections on the Draft EIR Page 111-6 City of El 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 F 2 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 I less than significant. 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 TRH, 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 siRnificant. 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 Y2 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 Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-7 City of El Segundo June 2019 significant impacts. However, with the implementation of Mitigation Measure MM i 2MM E-1, impacts would be reduced to a level of less than significant. Section IV.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 asd MM E-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 MM E-22: 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 El 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 MIM E-1 and MM F 2 listed above, Project -level and cumulative hazards impacts would be reduced to a less -than -significant level. IV.H.NOISE Section W.H. Noise, page IV.H-15, revise as follows: Beach Cities Media Campus Project 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-8 tMIEU&N gg MM E-22: 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 El 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 MIM E-1 and MM F 2 listed above, Project -level and cumulative hazards impacts would be reduced to a less -than -significant level. IV.H.NOISE Section W.H. Noise, page IV.H-15, revise as follows: Beach Cities Media Campus Project 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-8 City of El 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 (d).- Construction noise will have a temporary or Periodic increase in the ambient noise levels. However, no residential uses ore located in close vroximitv to the Protect Site, the site is surrounded by commercial uses. Construction -related noise imoacts are considered to be less than Ekn !cant. tbe eemsPwst4an, �_91__ed mitigation e,estop;sLs A N 1 fhoeugh4WA444. 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 imoacts are considered to be less than slam Licant. f-of ne— IF) Me AF*fs vkinity 10199" Ievek -.,F the "est weuW be less then 5igm�pfanf .... AAAA AJ I IV -1. POPULATION, HOUSING AND EMPLOYMENT Section IV. I. Population, Housing and Employment, Section 4.Cumulative Impacts, pages IV.1-10 through IV.1-13, revise as follows: The geographic scope of the cumulative employment analysis is the City of El Segundo. Table IV.1-3 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.1-3, the Project in conjunction with the related projects would result in an increase in employment of approximately 16,709 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 El 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 Ili. Environmental Setting would further increase employment opportunities in the City of El Segundo and surrounding areas. As indicated in Table IV.1-3, the Project in conjunction with the related projects would cumulatively generate approximately 4:5,799 15,680 new jobs71Awi*_1, IAfll +he,;I)Fopese4 n-;-+ _f rl —b-1cru. lob growth is considered a beneficial effect, and while the project's incremental contribution to regional job growth would be Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-9 City of El Segundo June 2019 considered cumulatively considerable, such job growth would not be considered an adverse cumulative impact, aodiscussed below. Based upon the foregoing, SCAG employment forecasts clearly underestimate the potential employment growth in the City of El Segundo, and to a lesser extent, in the South Bay Cities Subregion as well. VVh||e the provision of employment is generally considered a beneficial effect of project, this discrepancy in employment forecasts may adversely affect S[AG'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".2 TablelV-1-3 Cumulative Population, Housing and Employment . - KD Type of Use Size Employment Total Total Population Total Generation Employment Housing Generation Population z SCAG Regional Fnnpurst Overview, website: ftt!p2lwwwscoo.ozommIDahno.��muces� accessed March Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections onthe Draft BR Factor* Factoil (per 1,000 sf) (per unit) I. Residential 58 du - ' 58 du 2L58 147 High School | / | lZO0mo - - | l -�� 3. � Medical Office 63,540sf 0.00427 271 | - | 4. Office I5,000sf 0.0047 72 ' 5. Office 153,530 sf 0.00479 735 - 6, Hotel 180nnu 0.00113 81 ~ Office 22,60sf 0.00479 109 - 7. Office/ 7,120 sf 0,00135 10 ' Warehouse U 8. Drive through 5'000sf 0.00153 8 - Restaurant | _-_ B :1 . Hotel 30nnu 0.00123 -- ( 14 - 10. Office 1I120af 0.00479 48 l - __-�/ ll Office ]'DOOsf 0.00478 14 - 12. / Supermarket 27,500sf 0.00153/ � 42 RestaurantU &2J8sea�, | 0.00153 40 z SCAG Regional Fnnpurst Overview, website: ftt!p2lwwwscoo.ozommIDahno.��muces� accessed March Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections onthe Draft BR Page 111-11 City of El Segundo June 2019 Bank 7,000 sf 0.00283 20 -3 General Office 3,000 sf 0,00479 14 14. General Office 4,700 sf 0.00479 23 15. Medical Office 1,800 sf p 0.00427 8 Apartment I du - I 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. I Restaurant 13,570 sf 0.00153 21 22. Condominium 9 d mm 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. SupeFFABFI(e 27,389 23,050 94)9"4-0.0047 4 110 Medical office sf ReStftFaR 152,999S 0.00153 Pharmacv 0.665 Seats Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-11 City of EI Segundo June 2019 2.53 10 .I 196 196 Notes: sf = square feet 0. 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: N,ar.' ihLvPoPW.wrawrcra:v�ie T75,.... 21b u[s.fnr't/txlrRst.I�,rariatmC r,,r�lrrr7yr�r„PS...... accessed March 13, 2018. Based on an estimate of 8 sf/seat. Based on an estimate of 400 sf/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 8aRk —Coffee 7,969-5 9QA;183 00153 .293 Shop 1,715s 30. Office 155,660 sf 0.00479 746 31. Office 300,000 sf 0.00479 1,437 32. New Church 32,190 sf 0.00153 49 Supermarket 30,080 sf 0.00153 46 33. Shopping 110,000 sf 0.00153 168 Center 34. Residential 4 du - 4 du 35. Shopping 18,850 sf 0.00153 29 Center 36. Credit Union 3,600 sf 0.00153 6 37, Office 6,270 sf 0.00479 30 Warehouse 5,880 sf 0.00135 8 Y V Cumulative Total 964,676 77 14,647 Project Total 1,033 Cumulative and Project Total 16,;99 77 15,680 June 2019 2.53 10 .I 196 196 Notes: sf = square feet 0. 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: N,ar.' ihLvPoPW.wrawrcra:v�ie T75,.... 21b u[s.fnr't/txlrRst.I�,rariatmC r,,r�lrrr7yr�r„PS...... accessed March 13, 2018. Based on an estimate of 8 sf/seat. Based on an estimate of 400 sf/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 El 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 El 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 El Segundo have been accounted for in the City's long range planning. Furthermore, because SCAG's regional planning incorporates the City of El 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 El 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 El 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.1-1, 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.1-3, confirms the projections for slow housing growth in the region; only 77 new housing units are currently proposed. in addition, approximately 15,709 11§80lobs 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 fegi4s will increase by 1, 00 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 imolemented as part of the mitigation package for the Proiect. Several TDM oroeram elements are oroiect design features that are currentiv Qr000sed for implementation. Other TDM program elements would be developed as part of preparation of a detailed TDM olan. to be aooroved by City of El Se undo prior to aporoval of a final certificate of occuoancv for the ProLlect, Cit Aqproval will be contineent upon submission of an accompanvino analvsis based on CAPCOA and latest available relevant research confirminp, that the Southern California Association of Governments, 2016-2040 Regional Transportation PlanISustainable Communities Strategies, Final Growth Forecast by Jurisdiction website: http.-Ilwww.scog.co.govIDocumentsl2016 2040RTPSCS FinalGrowthFori!costbyJurisdiction.pdf, accessed: December 6, 2018. Beach Cities Media Campus Project Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-13 City of El Segundo June 2019 elements in the TDM plan will vield the intended 6,5% reduction in weekday, peak hour trios 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. 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, 0 Event promotions; and a 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 baisis,. User costs are typically determined through mileage or hourly rates, with deposits and/or annual membership fees. The car-shairing 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 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-14 City of El 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 FrrAr-1 RefeFe SeeFee lure 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 supplyto the City of El 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 -1 6F -Refffenee seoKe-f4et4ebw4-,Table IV.M.1-2. Current Supotv-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. 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 W.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 gFF8Fl RefeFeRee SeWee Ret femW4, Table 1V.M,1-5.Supply and Demand - Multiple Dry Year. Section IV.M.1, Utilities and Service Systems, Water, page IV.M-6, revise as follows: 0-r—_ - 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 W.M.2, Utilities and Service Systems, Wastewater, page IV.M-21, revise as follows: fi) 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: http.11www.lacsd.orglwastewaterlwwfacilities/default asp#map. Beach Cities Media Campus Project 111. Revisions, Clarifications and Corrections on the Draft EIR Page 111-15 City of El Segundo June 2019 of the LACSDswastewater 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 X4:4-261.1 mRd of wastewater and is operating at approximately 64 65 percent of capacity.' 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 145.9 13_8,.9 million gpd of available capacity, The Project's net increase in wastewater of 70,075 gpd would represent approximately Q-(* Q..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 9:05-0.03 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: 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-eeneratine activities within the City. including he Proiect, would continue to be subiect to the requirements set forth in CALGreen BuildinR Code which requires a 65 oercent construction waste diversion from landfills, Therefore, the Project would not create Sanitation Districts of Los Angeles County; Joint Water Pollution Control Plant (JWPCP), available at: http,:Ilwww.locsd.orglwostewaterlwwfacilitiesljwpcpldefault asp. City of El Segundo, Continental Grand Campus Specific Plan Draft EIR, September 2017, page 4.K.2-2. 7 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 Ill. Revisions, Clarifications and Corrections on the Draft EIR Page 111-16 City of El Segundo June 2019 aneed for additional solid waste disposal facilities toadequately handle project construction -gene rated inert waste and impacts would be less than significant. V1. ALTERNATIVES Section ViAlternatives, Alternative 2, pages V|'14through V1'1S revise asfollows: Similar tothe Project, during excavation, on -mite grading, building construction and operation of the Alternative, hazardous materials, such msfuel, and oils, associated with construction equipment, a$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 vvwu|d not expose people to a substantial risk resulting from the release or explosion of 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 similar tothe Project. Under this Alternative, H,|zaxk, impacts associated with the accidental release of hazardous material would be less than significant, similar to the Project. Section lU.Alternatives, Alternative 3, pages VI -32 through VI-33,revise msfollows: Similar to the Project, during excavation, on-site grading, building conmtnuctioo 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 oracidic 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 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 significantsimilar tothe Project. Under this Alternative, impacts associated with the accidental release of hazardous material would be less than significant fellewing similar tothe Project. Section ViAlternatives, Alternative 4,pages V|-70through @-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, vvou|6 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 hazardous material, or from exposure to a health hazard, in excess mfregulatory standards. Therefore, impacts associated with hazardous waste management during construction and operation would be less thans1gnificant similar tothe Project. Beach Cities Media Campus Project |||. Revisions, Clarifications and Corrections onthe Draft E|R Page 111-17 City ofEl Segundo June 2019 Under this Alternative, t4e5e-fegolaif 49, impacts associated with the accidental release of a hazardous material would be less than Significant fellewiFig m4;4ga#e+i, similar to the Project. Section V1 - Alternatives, Alternative 5, pagesN'108 through VI -109, revise asfollows: Similar to the Project, during excavation, on-site grading, building construction and operation of the Alternative S,hazardous materials, such asfuel, and oils associated with construction equipment, aowell as coatings, paints, adhesives, and caustic oracidic 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 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 similar tothe Project. Under this Alternative, apf4k-a4k �:egu-atory impacts associated with the accidental release of hazardous material would be less than significant fellewing fRW4a#sp,similar tVthe Project. APPENDICES Appendix H.lTraffic Study, page 31, Table 4, Related Projects Trip Generation Estimates, Row 12 and Row 29, revise as follows: Beach Cities Media Campus Project 0.Revisions, Clarifications and Corrections cmthe Draft BR 7O7No�hGmpu�eda8ou�varP Supermarket - Z�5D�J- L12, � Restaurant 44J8ueat F� 7 Oksf � Bank 29. 1000 North SepulvedaBoulevard W-, ksf SW � �L�� I1. RestauFant Pharmacv_ 0�65�f7115 ksf Beach Cities Media Campus Project 0.Revisions, Clarifications and Corrections cmthe Draft BR 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 or to 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 El 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 responsibiefar the implementation of corrective actions relative to violations of SCAQIVID rules associated with mitigation. Departments listed below are all departments of the City of El 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 ij Project Design Features No specific Project Design Features are proposed with regard to cultural resources. i!) 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 ofE1Segundo June 2019 resume once the paleontologist's recommendations have been implemented tothe satisfaction ofthepa|eontm|ogist. 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 SO 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 U| data recovery and associated documentation, orother appropriate measures, The City shall determine the appropriate and feasible nmeosume(s)that will be necessary to mitigate impacts, /n consideration of the measure(s) recommended bxthe Monitor. The Applicant shall implement all mnmauune/a\ that the City determines necessary, appropriate and feasible. Within 60days 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 byaphoto key, tothe City, Monitoring Phase: Implementation Party: Enforcement Agency: Monitoring Agency: � Project Design Features Construction Applicant Planning and Building Safety Department Planning and Building Safety Department PDF C-1: AProject geotechnical and engineering report isrequired to be prepared by a Ca|#onnia-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 toProject cmnstruction|nronmpUancexviththemnmstourrentCitymf E| Segundo Department pfPublic 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 unotable/cmnso|iclatiom'pnone soils; bedrock characteristics; subsidence; earthquake ground shaking; slope instability; subsurface gas; Beach Cities Media Campus Project IV, Mitigation Monitoring and Reporting Program 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 IV -4 City of El 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 H. Hazards and Hazardous Materials Project Design Features No specific Project Design Features are proposed with regard to hazards and hazardous materials. H) 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 El Segundo Building and Safety Division for review and.. r 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: 1. Hydrology/Water Quality ij 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 El Segundo PDF F-4: June 2019 The Project shall comply with all NPDES Permit and waste discharge requirements. 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-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 SSMC. 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 Party: 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 J. 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: 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 El 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 PDFJ-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: 11 MiLfleation Measures No mitigation measures are required. H) 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. 111) 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 IV. Mitigation Monitoring and Reporting Program Page IV -11 City of EI Segundo v) Other Public Facilities June 2019 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: w 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; 0 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; Is 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; 4 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 El 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 if) 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 El 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: Beach Cities Media Campus Project 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, • Halftime transportation coordinator; and • Vanpool assistance. Page IV -13 IV. Mitigation Monitoring and Reporting Program City of El 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 0 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 El 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 Page IV -14 IV. Mitigation Monitoring and Reporting Program City of El Segundo Enforcement Agency: Public Works Department, City of Manhattan Beach Public Works Department 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 El 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 El Segundo Enforcement Agency: Monitoring Agency: Q. Tribal Cultural Resources 1) Project Design Features Public Works Department, Caltrans Public Works Department, Caltrans No specific Project Design Features are proposed with regard to tribal cultural resources. fl) 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 -Kith 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 ofr the measure(s) recommended by the Monitor. The Applicant shall implement all measures) 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 El Segundo June 2019 R. Utilities/Service Systems Water 11 Project 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: 2) Mitigation Measures No mitigation measures are required. ii) wastewater g Proiect Design Features Pre -Construction, Construction Applicant Public Works Department Planning and Building Safety Department PDF M.2-1: The Project Applicant shall submit a Utility Plan to the City of El 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 Page IV -17 IV. Mitigation Monitoring and Reporting Program City of El Segundo shall obtain necessary permits and licenses, and provide traffic control plans and shoring plans. Monitoring Phase: implementation Party: Enforcement Agency: Monitoring Agency: 2) Miti .yation Measures, No mitigation measures are required. iii) Solid Waste 11 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: Pre -Construction, Construction Implementation Party: Applicant Enforcement Agency: Planning and Building Safety Department Monitoring Agency: Planning and Building Safety Department PDF M.3-2: All structures constructed or uses established within any part of the Project shalt 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 El 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 ?1 Mitigation 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 PLANNING COMMISSION RESOLUTION NO. 2861 EXHIBIT E CITY COUNCIL RESOLUTION NO. 5159 EXH I BIT A-2 FINDINGS OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS REGARDING BEACH CITIES MEDIA CAMPUS PROJECT STATE CLEARINGHOUSE NO: 2017121035 After receiving, reviewing, and considering all the information in the entire administrative record for Beach Cities Media Campus (the "Project") including, without limitation, the factual information and conclusions set forth in this Resolution, the City Council finds, determines, and declares as follows: I. FINDINGS REQUIRED BY CEQA. California Environmental Quality Act (CEQA) Guidelines § 15090 require the City to certify and the City so certifies that: 1. The Final Environmental Impact Report (FEIR) which includes the Draft EIR dated March 1, 2019, the Final EIR dated June 20, 2019, and the entire administrative record for this matter. has been completed in compliance with CEQA; 2. The FEIR was presented to the decision-making body of the lead agency and that that decision-making body reviewed and considered the information contained in the FEIR before approving the Project; and 3. The FOR reflects the lead agency's independent judgment and analysis. II. FINDINGS REGARDING THE POTENTIAL ENVIRONMENTAL EFFECTS OF THE PROJECT. A. Imp acts Found To Be Insignificant' in the Initial Studv. The Initial Study for the Beach Cities Media Campus Project, dated December 8, 2017, identified the following environmental effects as not potentially significant. Accordingly, the City Council finds that the Initial Study, the FEIR, and the record of proceedings for the Project do not identify or contain substantial evidence identifying significant environmental effects of the Project with respect to the areas listed below. 1. Agriculture and Forest Resources (all subtopics); 2. Biological Resources (all subtopics); 3. Cultural Resources (historical resources); 4. Geology and Soils (seismic -related ground failure, including liquefaction, landslides, and septic tanks); 5. Hazards and Hazardous Materials (proximity to schools, public and private airports, and wildland fires); Page 1 6. Hydrology and Water Quality (100'year flooding, significant risk due to flooding, and seiche/tsunami/mudfloxv); T Land Use and Planning (community division and habitat conservation plans); 8. Mineral Resources (all subtopics); 9. Noise (public and private airports/airstrips); 10. Population, Housing and Em(displacement of existing housing or people); and 11. Transportation, Traffic and Parking (air traffic patterns and hazardous design features). B'Impacts Identified asLess Than Significant imthe Initial Study. The Initial Study identified the following environmental effects as less than significant. Accordingly, the City Council finds that the Initial Study, the FOR, and the record of proceedings for the Beach Cities Media Campus Project du not identify or contain substantial evidence identifying significant environmental effects ofthe Project with respect tothe areas listed below. 1. Aesthetics (all subtopics); 2. Air Quality (objectionable odors); l Geology and Soils (liquefaction); 4. Public Services parks, and public fod|ities 5. Recreation (all subtop|cs);and 6 Utilities and ServiceSystems (compliance with statutes and regulations). C.Impacts identified gsPotentially Significant inthe Initial Study, But Which Did Not Exceed Significance Thresholds 7nthe DE|R' The following environmental effects were identified as Potentially Significant in the Initial Study. The City Council finds that the FOR and the record of proceedings in this matter do not identify orcontain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect tothe areas listed below: Air Quality e) Facts/Effects: (1) /uQygP.The SCAQyND CEQA Handbook identifies two key indicators of consistency: Criteria 1 — Increase in the Frequency or Severity of Violations, and Criteria 2 — Exceed Assumptions in the AQMP. Based on the air quality modeling analysis, short-term construction impacts will not result in significant impacts based on the SCAQMD regional and local thresholds of significance. This analysis also found that long-term operations impacts will not result in significant impacts based on the SCAQMD local and regional thresholds of significance. Therefore, the Proposed Project is not projected to contribute to the exceeclance of any air pollutant concentration standards and is found to be consistent with the AQx8P for the first criterion. The Project Site is currently designated as Commercial Center in the City of EI Segundo General Plan and per the EI Segundo Municipal Code the site is zoned Commercial Center (C-4). The Project includes a general plan amendment and a zone change from Commercial Center (C-4) to Urban Mixed Use South (MU -S). 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 Floor Area Ratio (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 allowable 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. 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. Therefore, as both land uses allow for commercial development of similar intensity, with the general plan amendment and zone change, the Proposed Project is not anticipated to exceed the Air Quality Management Plan (AQMP) assumptions for the Project Site and is found to be consistent with the AQMP for the second criterion. Based on the above, the Proposed Project will not result in an inconsistency with the South Coast Air Quality Management District (SCAQMD) AQMP. Therefore, a less than significant impact will occur. (2) Air Quality Violation. The mass daily emissions generated by Project construction -related activities would not exceed the thresholds of significance recommended by SCAQMD. Furthermore, the mass daily operational emissions generated by the Project would not exceed thresholds of significance recommended by SCAQMD for Volatile Organic Compounds (VOC) and Nitrogen Oxide (NOx ). Therefore, construction and operation of the Project would not contribute to an existing or projected air quality violation. The impact would be less than significant. (3) Criteria Pollutants. The mass daily emissions generated by Project construction -related activities would not exceed the thresholds of significance recommended by SCAQMD. Furthermore, the mass daily operational emissions generated by the Project would not exceed thresholds of significance recommended by SCAQMD for VOC and NOx. Therefore, operation of the Project would not generate a cumulatively considerable increase of criteria pollutants. The impact would be less than significant. (4) Sensitive Receptors. The nearest sensitive receptors to the Project Site are the Manhattan Senior Villas apartments located approximately 0.18 miles southwest and the multi -family attached and single-family detached residential dwelling units located approximately 0.2 miles south of the Project Site. Single-family detached residential dwelling units are also located approximately 0.32 miles southwest and approximately 0.64 miles east of the Project Site. Vistamar School is located approximately 0.48 miles northeast of the Project Site. Emissions generated by the Project would not expose receptors in the vicinity of the Project Site to substantial pollutant concentrations. The impact would be less than significant. (5) Cumulative hmpacts, The Project area is out of attainment for ozone and in 2014 was out of attainment for particulate matter (PM1o). Construction and operation of cumulative projects will further degrade the local air quality, as well as the air quality of the Salton Sea portion of the South Coast Air Basin. The greatest cumulative impact on the quality Page 3 of regional air will be the incremental addition of pollutants mainly from increased traffic volumes from residential, commercial, and industrial development and the use of heavy equipment and trucks associated with the construction of these projects. Air quality will be temporarily degraded during construction activities that occur separately or simultaneously. However, in accordance with the SCAQMD methodology, projects that do not exceed the SCAQMD criteria or can be mitigated to less than criteria levels are not significant and do not add to the overall cumulative impact. With respect to long-term emissions, this Project would create a less than significant cumulative impact. Since the Los Angeles County portion of the Basin is currently in non -attainment for ozone, PMlo, and PM2.s, cumulative development could violate an air quality standard or contribute to an existing or projected air quality violation. This would be considered a significant cumulative impact. According to SCAQMD's CEQA Air Quality Handbook, individual construction projects that exceed the SCAQMD recommended daily thresholds for Project -specific impacts would cause a cumulatively considerable increase in emissions for those pollutants for which the Basin is in non -attainment. Construction emissions associated with the Project would not exceed the SCAQMD's thresholds of significance. Therefore, the cumulative impact of the Project's construction emissions would be considered less than significant. With respect to Toxic Air Contaminants (TACs), the greatest potential for TAC emissions at related projects would involve diesel particulate emissions associated with trucks and heavy equipment. The construction activities associated with the Project and related projects would be similar to other development projects in the City, and would be subject to the regulations and laws relating to toxic air pollutants at the regional, State, and federal level that would protect sensitive receptors from substantial concentrations of these emissions. In addition, and similar to the Project, related projects construction activity would not result in long-term substantial sources of TAC emissions and would not combine with the Project to generate ongoing TAC emissions. Therefore, cumulative TAC emissions from the Project and related projects would be less than significant. With respect to operational emissions, SCAQMD CEQA Air Quality Handbook has indicated that, if an individual project results in air emissions of criteria pollutants (CO, VOC, NOx, sulfur oxides (SOx,) PM1o, and PM2.5) that exceed the SCAQMD recommended daily thresholds for Project -specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants for which the Project region is in non -attainment under an applicable federal or State ambient air quality standard. The maximum mass daily construction -related emissions and localized construction - related and operational emissions associated with the Project would not exceed the thresholds of significance recommended by SCAQMD. Furthermore, the mass daily operational emissions generated by the Project would not exceed thresholds of significance recommended by SCAQMD for VOC and NOx. Therefore, the cumulative operational air quality impact would be less than significant. b) Mitigation, No mitigation measures are required to reduce the aforementioned impacts below a level of significance. Page 4 c) Finding: The City Council finds that the FOR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to AQMP, construction and operational air quality emissions, and cumulative air quality emissions. a) Facts/Effects: (1) Earthquake Fault Ruoturei Seismic Ground Shaking. The closest fault to the Project Site is the Charnock Fault, which is located approximately 1.47 miles north east of the Project Site. The closest major active fault near the Project Site with surface expression includes the Newport -Inglewood Fault Zone, located approximately 6.73 miles to the east of the Project Site. Based on the available geologic data, active or potentially active faults with the potential for surface fault rupture are not known to be located beneath or projecting toward the Project Site. The potential for fault rupture at the site is low due to its location outside of a designated earthquake fault zone, and impacts would be less than significant. With compliance with the regulatory requirements of the California Building Code and City of EI Segundo Building Code, and the site-specific recommendations in the Geotechnical Study and final design -level geotechnical report approved by the Director of Planning and Building Safety, impacts associated with geologic hazards (including earthquake fault rupture, and seismic ground shaking) would be less than significant. (2) Soil Erosion. The Project Site is located in an urbanized area of EI Segundo. Construction activities would involve excavation from the Project Site of approximately 35,000 to 49,400 cubic yards of soil to the maximum potential depth of approximately 15 feet below ground surface to construct the proposed subterranean parking and associated shoring. Although Project development has the potential to result in the erosion of soil during site preparation and construction activities, erosion would be reduced by implementation of all appropriate erosion controls during grading. With compliance with the regulatory requirements of the California Building Code and City of EI Segundo Building Code, and the site-specific recommendations in the Geotechnical Study and final design -level geotechnical report approved by the Director of Planning and Building Safety, impacts associated with sedimentation or soil erosion would be less than significant. (3) Lxxoansive Soils,. Expansive soils generally result from specific clay minerals that have the capacity to shrink or swell in response to changes in moisture content. The ability of clayey soil to change volume can result in uplift or cracking to foundation elements or other rigid structures, such as sidewalks or slabs, founded on these soils. The expansion potential for soils on the Project Site is anticipated to be low. With compliance with the regulatory requirements of the California Building Code and City of EI Segundo Building, as well as the recommendations included in the Geotechnical Study and a final design -level geotechnical report to be approved by the Director of Planning and Building Safety, impacts associated with expansive soils would be less than significant. Page 5 (4) Cumulative Impacts. Geologic, soils and seismicity impacts are typically confined to contiguous properties or a localized area (generally within a 500 -foot radius) in which concurrent construction projects in close proximity could be subject to the same fault rupture system or other geologic hazards or exacerbate erosion impacts. The Project Site is not located within an Alquist-Priolo Earthquake Fault Zone. In addition, City regulations and building codes require the consideration of seismic loads in structural design, which must be approved bythe Director of Planning and Building Safety before a building permit may be issued for a project, including those related projects defined in Section III (Environmental Setting) of the Draft Environmental Impact Report (EIR). For these reasons, Project implementation is not expected to result in a considerable contribution to cumulatively significant impacts related to substantial damage from fault rupture or seismic ground shaking to structures, infrastructure, or human safety. The nearest related projects that could potentially be under construction concurrently with the Project are Related Projects No. 21 (located on Rosecrans Avenue) and 33 (located on North Sepulveda Boulevard). However, these related projects are far enough away from the Project Site that they would not contribute to cumulative soil erosion impacts. Moreover, both of these related projects are under construction and grading and excavation activities that would temporarily expose soils are already completed. Thus, concurrent development of this project would not contribute to cumulative geologic hazards related to soil erosion, shoring and other soil and foundation issues. Additionally, similar to the Project, EI Segundo Municipal Code (ESMC) standards for shoring, SCAQMD's requirements for dust control, and Regional Water Quality Control Board regulations pertaining to surface water runoff and water quality (which would require Best Management Practices (BMPs) for construction projects greater and smaller than one acre of disturbance), would prevent significant cumulative impacts related to erosion and other geological impacts. Therefore, cumulative impacts would be less than significant. b) ,Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding; The City Council finds that the FOR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to earthquake fault rupture, seismic ground shaking, soil erosion, or expansive soils. Hazards and Hazardous Materials a) Facts/Effects: (1) Hazards From Routine Transport. During excavation, on-site grading and building construction, 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, and therefore, would require proper handling and management and, in some cases, disposal. All hazardous materials on the Project Site would continue to be acquired, handled, used, stored, and disposed of in accordance with all applicable federal, State and local requirements. Therefore, with implementation of appropriate hazardous materials Page 6 management protocols at the Project Site and continued compliance with all applicable local, State, and federal laws and regulations relating to environmental protection and the management of hazardous materials, as well as adherence to manufacturer's instructions for the safe handling and disposal of hazardous materials, potential impacts upon people, the environment, associated with the use, storage, and management of hazardous materials during operation of the Project would be less than significant. Operation of the Project would use potentially hazardous materials typical of those used in office, retail, and studio and production facilities, including cleaning agents, paints, pesticides, and other materials used for landscaping. Activities involving the handling and disposal of hazardous wastes would occur in compliance with all applicable federal, State, and local requirements concerning the handling and disposal of hazardous waste. Therefore, with compliance with relevant regulations and requirements, operational activities would not expose people, the environment, 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. Thus, impacts associated with hazardous waste generation, handling, and disposal during operation of the Project would be less than significant. (2) Hazardous Materials Database. None of the database listings that include the Project Site are considered to be an environmental concern as no violations/releases were identified and the databases on which the Project Site appears are for permitting/documentation purposes rather than for a noted hazardous release. Therefore, the Project Site does not consist of a hazardous material site pursuant to Government Code Section 65962.5, and the Project would not create a significant hazard to the public or the environment. Furthermore, the Project would not exacerbate the current environmental conditions so as to create a significant hazard to the public or the environment. As such, any impacts during construction or operation would be less than significant. (3) Emerge ncwr Evacuation Plan. The construction of the Project would occur within the property boundaries of the Project Site. However, it is expected that construction fences will encroach into the public right-of-way (e.g., sidewalk and roadways) adjacent to the Project Site on Rosecrans Avenue in order to accommodate deliveries, haul trucks, concrete trucks and other equipment. The Construction Management Plan would include measures to ensure pedestrian safety along the affected sidewalks and temporary sidewalks (e.g., use of directional signage, maintaining continuous and unobstructed pedestrian paths, and/or providing overhead covering). As such, the construction of the Project would not substantially nor permanently impede public access, travel upon a public right-of-way, or interfere with an adopted emergency response or evacuation plan. Therefore, Project impacts would be less than significant. Emergency access to the Project Site would be maintained at all times. While the Project is anticipated to affect the level of service of roadways in the Project vicinity, the increases in traffic would not greatly affect emergency vehicles because the drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Further, the Project Applicant is required to submit the Project plot plan to the ESFD for review to ensure compliance with applicable EI Segundo Fire Code, California Fire Code, City of EI Segundo Building Code, and National Fire Protection Association standards, thereby ensuring that the Project would not create any undue fire hazard or obstacle to emergency access or response. Compliance with this ESMC requirement and implementation of the Page 7 Construction Management Plan would ensure that Project impacts associated with emergency access and response would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to hazards and hazardous materials. Hydrology and Water Quality a) Facts Effects: (1) Hvdrolomv. The Project would not include new injection or supply wells. The Project construction activities would not result in significant impacts related to the availability of groundwater and would not result in the alteration of groundwater flows. Therefore, Project construction activities would result in less -than -significant impacts related to groundwater and would not substantially deplete groundwater supplies in a manner that would result in a net deficit in aquifer volume or lowering of the local groundwater table. The subterranean level of the Project would be designed such that it is able to withstand hydrostatic forces and incorporate comprehensive waterproofing systems in accordance with current industry standards and construction methods. As such, permanent dewatering operations are not expected. Therefore, the Project's potential impact during operation on groundwater level would be less than significant, and no mitigation measures would be required. IL Drainage Patterns. Construction activities for the Project would include site preparation, grading, excavation, and building construction. These activities have the potential to temporarily alter existing drainage patterns and flows on the Project Site by exposing the underlying soils and modifying flow direction. The Project would be required to comply with all applicable regulations that require necessary measures, plans, and inspections to reduce sedimentation and erosion. Thus, through compliance with all NPDES General Construction Permit requirements and implementation of BMPs, the Project would not substantially alter the Project Site drainage patterns in a manner that would result in substantial erosion, siltation, or flooding on- or off-site. Therefore, construction -related impacts to surface water hydrology drainage patterns with respect to potential for erosion or siltation would be less than significant. The Project Site is relatively flat with a gentle slope towards the southeast. The elevation at the Project site is approximately 100 feet above mean sea level. The Project Site's grade descends to the southeast. Drainage across the site is by sheetflow (i.e., along the surface) to Rosecrans Avenue to the south. Although the Project would alter the existing drainage pattern of the site, the proposed buildings or other hardscape would cover almost the entire Project Site, and there would be no bare soils on-site with the potential to erode or contribute silt to surface runoff. Therefore, operational impacts to surface Page 8 water hydrology drainage patterns with respect to potential for erosion or siltation would be less than significant. (33). Alter Drainage Pattern. The Project Site is relatively flat, and there are no streams or rivers present. The Project would require construction and excavation activities. However, these activities would not cause any flooding during construction because the Project would implement a SWPPP as well as construction -specific BMPs to reduce the amount of runoff to minimize flooding. Adherence to standard compliance measures during construction activities would ensure that the Project would not cause flooding that would have the potential to harm people or damage property; substantially reduce or increase the amount of surface water flow from the Project Site into a water body; or result in a permanent, adverse change to the movement of surface water to produce a substantial change in the current or direction of water flow during construction. Therefore, impacts would be less than significant and no mitigation measures are required. The Project would not modify the surrounding streets with respect to the manner in which they convey storm runoff to the City storm drain system, and would have no effect on regional facilities. The Project would increase the amount of impermeable surfaces at the Project Site compared to existing conditions. However, the flow direction of storm water would remain similar to existing conditions because runoff from the Project would continue via sheetflow towards Rosecrans Avenue. Therefore, the operational impact on drainage patterns with respect to the potential for flooding would be less than significant. ll Runoff. Currently, runoff from the Project Site drains via sheetflow (i.e., flows overland along the ground) and discharges the stormwater into the local storm drain system. Stormwater runoff from the Project Site discharges into the curb and gutter which conveys stormwater into nearby street catch basins. The stormwater infrastructure within the public right-of-way has sufficient capacity to accept the stormwater runoff from on-site existing conditions. Thus, the Project would not exceed the capacity of existing or planned stormwater drainage systems and impacts would be less than significant. The construction and operation of the Project would not introduce substantial sources of polluted runoff and impacts would be less than significant. u Degrade Water QgiLity. The Project would be subject to the requirements of the Los Angeles County MS4 Permit, which controls the quality of runoff entering municipal storm drains in the County. Accordingly, a SWPPP would be developed in compliance with SWRCB requirements and implemented during construction, which would outline BMPs and other measures to minimize the discharge of pollutants in stormwater runoff. BMPs would include appropriate disposal of waste; immediate clean up of leaks, drips, and spills; street sweeping; limiting the amount of soil exposed at one time; covering haul trucks; proper maintenance of construction equipment; and installation of sediment filters during construction activities. During operation, the Project would be required to prepare and implement a project - specific SUSMP meeting the requirements of the County -wide SUSMP adopted by the LARWQCB, and implement BMPs designed to address runoff and pollutants. Furthermore, as the Project would manage, capture, and treat runoff as required through regulatory compliance and PDFs, implementation of the Project would represent an improvement in water quality from the existing condition as runoff currently sheet flows untreated to the drainage system. Therefore, through compliance with regulatory Page 9 requirements and the PDFs, construction- and operation -related impacts to water quality would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Findin The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to hazards and hazardous materials. Land Use and Planning a) Facts/Effects: (1) ,Applicable Land Use Plans and policies. The development of the Project would be subject to numerous City land use plans, policies, and regulations, including the development regulations in the ESMC. The Project would be consistent with the goals in the Regional Comprehensive Plan (RCP), the principles of the Compass Growth Vision, the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), the EI Segundo General Plan Land Use Element, and Title 15 of the ESMC. Based on the analysis, the Project would be generally consistent with applicable goals, policies, and objectives in local and regional plans that govern development on the Project Site. Therefore, the Project would not be in substantial conflict with the General Plan, zoning, or the whole of relevant environmental policies in other applicable plans, including regional plans. As such, impacts related to land use consistency would be less than significant. (2) Cumulative Impacts. The study area for the land use cumulative impacts analysis includes the Project Site and the Southeast Quadrant of the City. The Project would be generally consistent with all applicable land use regulations and policies. The closest related projects to the Project Site include related project numbers 14,17,19, 20, 21, 26, 33, 35, and 36. These related projects, located in the vicinity of the Project Site, when developed in combination with the Project would intensify the land usage in the immediate project area. The Project would be generally consistent with all applicable land use regulations. Similar to the Project, the related projects would be required to comply with relevant land use policies and regulations, and would be subject to specific findings and conditions, which are based on maintaining general conformance with the land use plans applicable to the area. In addition, such related projects are not expected to fundamentally alter the existing land use relationships in the Southeast Quadrant of the City. As such, development of the Project and related projects is not anticipated to substantially conflict with the intent of the City's General Plan regarding the future development of the Southeast Quadrant, or with other land use regulations required to be consistent with the General Plan, such Title 15 of the ESMC. Development of the Project, in combination with the related projects, would not be expected to result in cumulatively considerable effects with respect to land use regulations. Page 10 Noise b) Miti, aVon: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to applicable land use plans and policies. a) Lans/Effects: (1) Noise. Although construction noise will have a temporary or periodic increase in the ambient noise levels above the existing within the Project vicinity, it is anticipated to occur during the permissible hours according to the City's Municipal Code. The City's Municipal Code also specifies a maximum construction noise levels of 65 decibel (dBA) plus the limits specified in subsection 7-2-4C of the municipal code for residential structures. However, no residential uses are located in close proximityto the Project Site, the site is surrounded by commercial uses. Therefore, construction -related noise impacts are considered to be less than significant. The Proposed Project would result in a substantial increase in ambient noise levels if the existing ambient noise level increases by 5 dBA at a residential use or 8 dBA at a commercial or industrial use. Existing traffic noise levels range between 66.8-79.5 dBA Community Noise Equivalent Level (CNEL) and the modeled Existing Plus Project traffic noise levels range between 66.8-79.5 dBA CNEL at the property line of the nearest receptor to each modeled road segment. Future (2020) traffic noise levels range between 67.1-80 dBA CNEL and the modeled Future (2020) Plus Project traffic noise levels range between 67.2-80 dBA CNEL at the property line of the nearest receptor to each modeled road segment. All modeled roadway segments are anticipated to change the noise a nominal amount (between approximately 0.00 to 0.12 dBA CNEL). Therefore, a change in noise level would not be audible and would be considered less than significant. Future vehicle traffic noise from Rosecrans Avenue is expected to result in noise levels ranging between 48 and 75 dBA on the Project Site. The proposed buildings shield the proposed outdoor uses areas from vehicle traffic noise. The proposed office buildings would fall into a "conditionally acceptable" category and construction would be acceptable as long as they are provided with air conditioning and/or fresh air supply systems to allow a "windows closed" condition. Impacts related to future traffic noise impacts to the Proposed Project would be less than significant. (2) Vibration. Construction activities associated with the proposed parking structure may occur within 25 feet of the existing parking structure to the east. Buildings with steel or reinforced concrete, such as factories, retaining walls, bridges, steel towers etc. withstand much higher vibration levels than a typical home. The adjacent parking structure is expected to withstand a PPV of at least 2.0 (California Department of Transportation Page 11 2013). Temporary vibration levels associated with Project construction would be less than significant and no mitigation would be required. Project -related ground -borne vibration would be from trucks making deliveries to the Project Site and garbage trucks picking -up Project -related refuse material. The vibration levels associated with these trucks would be less than the levels associated with large construction equipment. Therefore, the operational impacts associated with ground - borne vibration would be less than significant at nearby sensitive uses. (3) Ambient Noise. Although construction noise will have a temporary or periodic increase in the ambient noise levels above the existing within the Project vicinity, it is anticipated to occur during the permissible hours according to the City's Municipal Code. The City's Municipal Code also specifies a maximum construction noise levels of 65 dBA plus the limits specified in subsection 7-2-4C of the municipal code for residential structures. However, no residential uses are located in close proximity to the Project Site, the site is surrounded by commercial uses. Therefore, construction -related noise impacts are considered to be less than significant. Future vehicle traffic noise from Rosecrans Avenue is expected to result in noise levels ranging between 48 and 75 dBA on the Project Site. The proposed buildings shield the proposed outdoor use areas from vehicle traffic noise. The proposed office buildings would fall into a "conditionally acceptable" category and construction would be acceptable as long as they are provided with air conditioning and/or fresh air supply systems to allow a "windows closed" condition. Impacts related to future traffic noise impacts to the Proposed Project would be less than significant. (4) Temporary or Periodic Ambient Noise. Although construction noise will have a temporary or periodic increase in the ambient noise levels above the existing level within the Project vicinity, it is anticipated to occur during the permissible hours according to the City's Municipal Code. The City's Municipal Code also specifies a maximum construction noise levels of 65 dBA plus the limits specified in subsection 7-2-4C of the municipal code for residential structures. However, no residential uses are located in close proximity to the Project Site, the site is surrounded by commercial uses. Therefore, construction -related noise impacts are considered to be less than significant. (5) Cumulative Impacts. The nearest related projects to the Project Site include related project numbers 21 and 35. Related project number 21 is located at 2171-2191 Rosecrans Avenue, to the east of the Project Site. Related project number 35 is located at the following addresses: 700-860 South Sepulveda Boulevard, 2001-2015 East Park Place, and 700-740 Allied Way Boulevard; which isto the north east of the Project Site. Existing adjacent retail uses to the west and east of the Project Site as well as the retail uses located south of the Project Site (across Rosecrans Avenue) may be temporarily affected by short-term noise impacts associated the Project construction. Ambient noise levels in the Project vicinity range between 52.4 and 64.3 dBA Leq. Project construction noise may reach up to 87.4 dBA Leq at the Project line during grading activities. At 50 - feet from the property line, construction noise levels would drop to 77.5 dBA Leq, at 100 feet from the property line, construction noise levels would drop to 73.0 dBA Leq, and at 500 feet from the property line, construction noise levels would drop to 60.6 dBA Leq. There are no currently proposed construction projects within 500 feet of the Project Site. Therefore, the incremental contribution of project construction noise would not be cumulatively considerable. ................... ..................... Page 12 Project on-site operational noise is expected to range between 52.0 and 64.0 dBA Leq at nearby commercial land uses, including the new proposed on-site commercial buildings. Project operational noise at off-site adjacent properties would range between 52.0 to 54.0 dBA LeQ, and would not be audible over the existing noise environment. The incremental contribution of Project on-site operational noise would not be cumulatively considerable. The Noise Technical Report quantified the increase in ambient noise levels that can be expected with Project buildout along roadways affected by Project generated vehicle traffic. New vehicle trips associated with the Proposed Project are expected to result in a nominal increase in ambient noise levels along affected road segments (up to 0.12 dBA CNEL). These increases would nominally add to ambient noise levels as the area and would be consistent with what has been planned for and analyzed in the City's General Plan and General Plan Environmental Impact Report. Thus, Project operational noise would not contribute to a cumulative noise impacts at adjacent land uses. b) Mitieation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding; The City Council finds that the FOR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to noise, vibration, ambient noise, and/or temporary or periodic ambient noise. a) Facts/Effects: (1) Population, Fiousinp and Emolovment. While the Project would increase employment in the City of EI Segundo, the Project is consistent with employment, population, and housing forecasts. Impacts with respect to substantial population growth would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to population, housing, and employment. Public Services: Fire a) Facts/Effects: (1) Need for a New or PhvsicaIIv Altered Fire Station. Construction activities on the Project Site have the potential to result in accidental on-site fires by exposing combustible materials (e.g., wood, plastics, sawdust, coverings and coatings) to fire risks from Page 13 machinery and equipment sparks, and from exposed electrical lines, chemical reactions in combustible materials and coatings, and lighted cigarettes. The implementation of "good housekeeping" procedures by the construction contractors and the work crews would minimize these hazards. The transport, use, and disposal of construction -related hazardous materials would occur in conformance with all applicable local, State, and federal regulations governing such activities. The Project would be required to implement standard BMPs set forth by the City and the Regional Water Quality Control Board (RWQCB) which would ensure that wastes generated during the construction process are disposed of properly. Construction activities also have the potential to affect fire protection services, such as emergency vehicle response times, by adding construction traffic to the street network and potentially requiring partial lane closures during street improvements and utility installations. These impacts are considered to be less than significant for the following reasons: emergency access would be maintained to the Project Site during construction through marked emergency access points approved by the EI Segundo Fire Department (ESFD) (see PDF J-1); partial lane closures, if determined to be necessary, would not greatly affect emergency vehicles; and the Project would be required to prepare a Construction Management Plan. Moreover, construction impacts are temporary in nature and do not cause lasting effects to impact ESFD fire protection services. Accordingly, Project construction would not affect firefighting and emergency services to the extent that new, expanded, consolidated, or relocated fire facilities would be needed in order to maintain acceptable service ratios, response times, or other performance objectives of the ESFD. Therefore, construction -related impacts on fire protection services would be less than significant. The Project would be expected to generate 1,033 net new full- and part-time jobs. The increase in 1,033 net new employees and visitors to the Project Site during operation would create demand for additional fire protection services at the Project Site. Compliance with applicable regulatory requirements, including ESFD's fire/life safety plan review and fire/life safety inspection, would ensure that adequate fire prevention features would be provided in order to reduce the demand on ESFD facilities and equipment. In addition, in accordance with the fire protection -related programs set forth in the General Plan Public Safety Element, and PDF's, as well as ESFD's continued evaluation of existing fire facilities, Project impacts with regard to ESFD facilities and equipment would be less than significant. The final fire flow required for the Project would be established by the ESFD during its review of the Project plot plan, prior to the issuance of a building permit by the City. The plot plan would be required to identify the minimum fire flow requirements and the location of fire hydrants. Approval of this plot plan, and implementation of the applicable regulatory requirements would ensure the requisite fire flow for the Project Site. Therefore, impacts related to fire flow would be less than significant. Emergency response times would potentially be affected. However, upon completion of the Project, the ESFD would be provided with a diagram of each portion of the property, and this diagram would include access routes and any additional information that may facilitate ESFD response to the Project Site. Therefore, with the implementation of additional information that may facilitate ESFD response to the Project Site, Project impacts related to response times would be less than significant. Page 14 Based on the Project's proposed circulation plan, it is anticipated that the ESFD would be able to respond to emergency calls within the established response time. Therefore, impacts related to emergency access would be less than significant. (2) Cumulative Impacts. The geographic scope of the cumulative fire protection analysis encompasses the service area for the ESFD in general, and Fire Stations 1 and 2, in particular. The Project, in combination with the construction and operation of the related projects located within the service areas of these stations, would result in additional residential, industrial, educational, and commercial land uses within these service areas. It is anticipated that the additional population and commercial activity would increase the demand for fire protection in the service areas for ESFD Fire Stations 1 and 2. Specifically, there would be increased demand for additional ESFD staffing, equipment, and facilities overtime. However, each of the related projects regardless of location or size would be subject to ESFD review of site plans, hydrant locations, and fire flow requirements, to ensure compliance with fire and life safety standards. In addition to the capabilities of the local fire stations serving the Project Site and surrounding areas, including the related projects, growth in residential and student population and industrial and commercial development throughout the City could increase demand for ESFD staffing, equipment, and facilities. These demands are met by ESFD within the constraints of available resources, as well as through the allocation of resources between ESFD and other City departments, which is accomplished through the City's annual programming and budgeting processes. Through implementation of the existing management and regulatory requirements, the cumulative demand for fire protection is identified and addressed to the satisfaction of the City's elected leadership. Therefore, the Project, in combination with demand for fire protection services Citywide, would not result in a significant cumulative effect. Further, the Project impact analysis determined the impact on fire protection would be less than significant; thus, Project impacts would not be cumulatively considerable. Based on the above analysis, cumulative impacts related to fire protection would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Findin The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to fire services, and /or the need for a new or physically altered fire station. Public Services: Police a) LactslEffects. (1) Need for a New or Phvsicallv Altered Police Station. Construction sites can be sources of nuisances and hazards and invite theft and vandalism. When not properly secured, construction sites can contribute to a temporary increased demand for police protection services. With compliance with state law and local regulations, construction -related impacts would be minimized and would not generate a demand for additional police protection services that would substantially exceed the capability of the EI Segundo Police Page 15 Department (ESPD) to serve the Project Site. Project construction would not necessitate the provision of new or physically altered facilities in order to maintain the ESPD's capability to serve the Project Site; accordingly, the Project would not result in adverse physical impacts associated with the construction of new or altered facilities. Therefore, impacts on police protection services during Project construction would be less than significant. Although there is no direct proportional relationship between increases in land use activity and increases in demand for police protection services, the number of calls for police response to commercial and vehicle burglaries, damage to vehicles, traffic-related incidents, and crimes against persons could increase with the increase in on-site activity and increased traffic on adjacent streets and arterials. Such calls are typical of problems experienced in nearby neighborhoods and do not represent unique law enforcement issues specific to the Project. Design features that deter crime, including adequate and strategically positioned functional lighting to enhance public safety, minimizing visually obstructed and infrequently accessed "dead zones," and limiting public access to properly patrolled public areas, reduce the demand for police services. The design of the Project would also include crime prevention features, such as nighttime security lighting and secured parking facilities. With implementation of these features, in coordination with the ESPD, the Project would result in a less-than-significant operational impact on police protection services. Overall, no new or expanded police station is anticipated to be needed as a result of the Project. Therefore, Project impacts on police service ratios would be less than significant. Response times would not be substantially affected, given that there would be significant traffic impacts at limited locations and given the availability of alternative routes within the street pattern in the area surrounding the Project Site. In addition, the police have a variety of options to avoid traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic. Furthermore, upon completion of the Project, the ESPD would be provided with a diagram of each portion of the property, and this diagram would include access routes and any additional information that may facilitate police response to the Project Site. Therefore, Project impacts related to response times would be less than significant. Emergency vehicle access to the Project Site would continue to be provided from major roadways adjacent to the Project Site including Rosecrans Avenue and South Nash Street. The Project would be designed and constructed in accordance with ESMC requirements to ensure proper emergency access. Therefore, as traffic impacts would not result in the need for expanded, consolidated, or relocated police facilities during operation of the Project, and impacts to emergency service would be less than significant. (2) Cumulative Impacts. The geographic scope of the cumulative police protection analysis encompasses the service area for the ESPD. The Project, in combination with the construction and operation of the related projects located within the service area of the East Command area, would add residential, schools, industrial, and commercial land uses to the service area. It is anticipated that the additional population would increase the demand for police protection services in the East Command area. Specifically, there would be increased demand for additional ESPD staffing, equipment, and facilities over time. Page 16 The ESPD determines the adequacy of police protection using the existing number of police officers in the Project's police service area, the number of persons currently served in the area, the adequacy of the existing officer -to -population ratio in the area, and the number of persons that the Project would introduce to the area and the geographic distribution of crimes within the area. ESPD works with developers of projects to minimize demand for police services through review and coordination of project design, provision of adequate light, and on-site security measures, as warranted. The related projects are expected to have access to the expertise of the ESPD to benefit their design and operational planning, and each of the related projects would be subject to ESPD review of site plans, and security measures. Through this process, cumulative demand for police services within the East Command area would be managed, and the Project, in combination with related projects, would not result in a cumulatively considerable impact. In addition to the capabilities of the East Command area to serve the Project Site and surrounding areas, including the related projects, growth in daytime population and development throughout the City could increase demand for ESPD staffing, equipment, and facilities Citywide. These demands are met by ESPD through the allocation of available resources by ESPD management to meet varying needs throughout the City, as well as through the allocation of City resources between ESPD and other City departments, which is accomplished through the City's annual programming and budgeting processes. Through implementation of these existing management and regulatory processes, the cumulative demand for police protection is identified and addressed to the satisfaction of the City's elected leadership. Therefore, cumulative impacts related to police protection would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. C) Findin : The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to police services, and/orthe need fora new or physically altered police station. Transportation. Traffic and Parking a) Facts Effects: (1) Conflict UI,+'ith an Applicable Plan Construction. Construction activities would involve temporary heavy truck traffic for the transport of building debris and cement trucks. Additionally, construction worker vehicles, materials deliveries, and other construction - related trips are expected to add heavy truck trips per day. Construction activities may affect adjacent streets, including Rosecrans Avenue, and Nash Street. Construction trucks could disrupt traffic flows, limit turn lane capacities, and generally slow traffic movement. Other potential construction -related impacts include equipment staging, equipment idling, parked or queued heavy trucks that could potentially obstruct visibility, traffic flows and interfere with pedestrian and bicycle flows; parking usage by construction workers; temporary or extended closure of traffic lanes and sidewalks. During .................... ..... Page 17 construction staging, the storage of construction equipment may require the use of street parking and temporary closure ofportions ufadjacent streets. The Construction Management Plan would address individual phases of construction including site preparation, and on-going construction activities for each individual project, Implementation of PDF K'1 would reduce construction traffic impacts to less than significant. (Z) Comxestiom Manamement Plan (CMP) and Transit Service. Study intersection #1, Sepulveda Boulevard & El Segundo Boulevard, is also a CMP monitoring location. Based on the Project trip distribution and trip generation, the Project isexpected to odd approximately 33 trips in the AM peak hour and 30trips in the PM peak hourthrough the CMP arterial monitoring station. It is not expected to add enough new traffic to exceed the arterial analysis criteria of 50 vehicle trips at the above-mentioned location. Therefore, nofurther CMP arterial analysis is required. The next nearest [MP monitoring location to the south of the Project is located at Sepulveda Boulevard & Artesia Boulevard, over two miles away. Itbexpected that the monitoring station will not have more than SOtrips during either peak hour. The next nearest [K4P monitoring location to the north of the Project is located at Sepulveda Boulevard & Lincoln Boulevard, also over two miles away. It is expected that the monitoring station will not have more than 50 trips added during either peak hour. Since fewer than 150 trips would teadded during the ANorPNpeak hours in either direction at the freeway segments inthe vicinity ofthe study area, nofurther analysis of the freeway segments isrequired for CMP purposes. The Project and other related projects will cumulatively add new ridership tothe transit system. However, as noted, the Project Site and the greater El Segundo area in general are served by a considerable amount of transit service, including the Metro Green Line, numerous Metro bus routes, and local Beach Cities service. Transit service providers routinely acUumL service up to two times o year to reflect future cumulative demand. Additional transit riders would also increase tarebox recovery on transit lines, and therefore the Project generated transit riders would help to fund the service. Atthis level of increase, Project -related impacts on the regional transit system would not be significant. (3) 6dooted Policies oxPlans, The Project would not conflict with adopted polices, plans or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance orsafety ofsuch facilities. Impacts would beless than significant. (4) img1gency Vehicle Access, Emergency vehicle access tothe Project Site would continue to be provided from major roadways adjacent to the Project Site, including Rosecrans Avenue and Nash Street. All circulation improvements that are proposed for the Project Site would comply with the Fire Code, including any additional access requirements of the ESFD. Emergency access tmthe Project Site would bemaintained atall times. While the Project is anticipated toaffect the LOS ofroadways |nthe Project vicinity, the increases in traffic would not greatly affect emergency vehicles because the drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using their sirens to clear a path of travel or driving in the lanes of opposing traffic. Based on the Project's proposed circulation plan and the above considerations, it is anticipated that the ESFD would be able to respond to emergency calls within the established response time. Therefore, impacts related to emergency access would be less than significant. b) Mitieation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FOR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to transportation, traffic and parking. Utilities and Service Svstems: Water a) Facts/Effects: (1) Need for a New or Exoanded Water Treatment Facilities. Prior to ground disturbance, Project contractors would coordinate with West Basin Municipal Water District (WBMWD) to identify the locations and depth of all lines. Further, WBMWD would be notified in advance of proposed ground disturbance activities to avoid water lines and disruption of water service. Therefore, Project impacts on water infrastructure associated with construction activities would be less than significant. A Utility Plan showing existing and proposed utility improvements would be submitted to the City of EI Segundo Public Works Department for review and approval. These plan checks and consultations would ensure that available water supply and pressure would be sufficient to serve the Project requirements. Accordingly, implementation of the Project would not result in the need for new or additional water treatment facilities. Therefore, impacts would be less than significant. (2) Sufficient Water SuppLies, While Project construction activities would create a demand for some non -potable (recycled) water, construction activities would be temporary such that any associated water use would be temporary, and the construction activities requiring water use would not create substantial water demand. Therefore, Project construction activities would generate minimal potable water demand, and would not require water supplies that could not be met by existing City water entitlements and resources. Accordingly, impacts related to water demand during construction would be less than significant. According to the City Urban Water Management Plan (UWMP), water demands are projected to be 17,299, 17,457, 17,618, 17,782 and 17,942 AFY for the years 2020, 2025, 2030, 2035, and 2040, respectively. The Project's estimated consumption of 59 acre feet per year (AFY) would represent 0.34, 0.34, 0.33, 0.33, and 0.33 percent of the projected demands for these years, respectively, and would therefore, not be a significant increase in water demand. In addition, the potable water demand estimates for the Project are conservative because they do not take into future water conservation requirements, and the Project would comply with the water efficiency standards of Title 24 of the California Code of Regulations (CCR) and the City's UWMP, General Plan, and Municipal Code. The City would be able to meet Project operational water demand while meeting its existing and planned projected future water demands through at least 2040, and would Page 19 not require new City water entitlements or resources. Therefore, Project operational water supply impacts would be less than significant. (3) Cumulative nmoacts. The geographic context for the cumulative impact analysis on water supply is the WBMWD service area, which includes the entirety of the City. As identified in Section III, Environmental Setting, of the EIR, there are 37 related projects located in the project vicinity. With respect to cumulative water supply impacts, the Project -specific analysis presented above also represents the cumulative analysis because it considers water demand and supply within the whole of the City through the 2035 planning horizon of the City's 2015 UWMP. Sixteen of the 37 related projects are located within the City and are anticipated to have been included in the overall growth projections utilized in the City's UWMP. Furthermore, those related projects that meet the SB 610 criteria for requiring the preparation of a water supply assessment (WSA) would have WSAs prepared to demonstrate that adequate water supply is available to serve them, and only those related projects where their WSA's conclude that adequate water is available would be approved. The types of projects that are subject to the requirements of Senate Bill 610 tend to be larger projects that may or may not have been included within the growth projections of the 2015 UWMP. Lastly, even if the cumulative water supply impacts would be significant (for example, if multiple related projects are not assumed in the water demand estimates in the City's UWMP through year 2035), the Project contribution to any such impact would not be cumulatively considerable. The Project's water demand would represent 0.44 percent of the City's projected water demand for the year 2035. Additionally, the 21 projects located outside of the City (and thus have not been included in the City's projected demand), all are located within the service area of the WBMWD. WBMWD, as a public water service provider, is required to prepare and periodically update an Urban Water Management Plan to plan and provide for water supplies to serve existing and projected demands. The 2015 UWMP prepared by WBMWD accounts for existing development, as well as projected growth in its service area through the year 2035. The Project would represent 0.29 percent of the surplus supply (i.e. water supply available above projected demand) reported in the WBMWD UWMP. Further, the estimates of water demand for the Project are conservative because they do not account for increases in Project water conservation required by Senate Bill (SB) x7-7 and other existing and future legislation through year 2035. Compliance of the Project and future development projects with regulatory requirements that promote water conservation such as the ESMC, Ordinance No. 1433, and the Water Shortage Contingency Plan (WSCP), would also assist in assuring that adequate water supply is available on a cumulative basis. Based on the related project list and projections provided in adopted plans (e.g., the City UWMP and the WBMWD UWMP), it is anticipated that WBMWD would be able to meet the water demands of the Project and future growth through 2035 and beyond. The WBMWD UWMP forecasts adequate water supplies to meet all projected water demands in the City through the year 2035. Accordingly, the Project's incremental increase in water demand would not contribute to a cumulatively significant impact. The geographic context for the cumulative impact analysis on water infrastructure is the vicinity of the Project Site (i.e., the water infrastructure that would serve both the Project and specific related projects). Development of the Proposed Project in conjunction with Page 20 the 37 related projects in the City would incrementally increase the demand for capacity in the City's existing potable water infrastructure system. However, like the Proposed Project, most of the related projects would be subject to CEQA review, and they would all be subject to City review, to assure that the existing public utility facilities would be adequate to meet the domestic and fire water demands of each project. Developers are required to improve facilities where appropriate, and development cannot proceed without appropriate verification and approval. Furthermore, City's Public Works Department conducts ongoing evaluations to ensure that water infrastructure in the City is adequate, and undertakes infrastructure system improvements when required. Therefore, cumulative impacts on the water infrastructure system would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Fines_ The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to water, the need for a new or expanded water treatment facilities, and/or sufficient water supplies. Utilities and Service Svstems: Wastewater a) Facts/Effects: (1) exceed Wastewater Treatment,. Construction and operation of the Project would rely on existing stormwater drainage facilities. The Project would be required to prepare a SWPPP to prevent runoff and water quality impacts during construction, and appropriate BMPs to manage stormwater runoff and pollutants from the Project Site. Accordingly, construction of the Project would not introduce substantial sources of polluted runoff and impacts would be less than significant. With respect to Project compliance with the wastewater treatment requirements of the Los Angeles Regional Water Quality Control Board (LARWQCB), the Project would include office uses that would generate standard domestic/commercial wastewater. Project wastewater that discharges to the local wastewater collection system would comply with applicable County -wide waste discharge requirements (e.g., National Pollution Discharge Elimination System (NPDES) Permit requirements). Therefore, Project operation would not interfere with the ability of the Joint Water Pollution Control Plant (JWPCP) to meet the effluent limitations and waste discharge requirements set forth in its discharge permit (e.g., NPDES Permit No. CA0053813, Order No. R4-2011-0151). (2) Construction of New Wastewater Treatment Facilities. The Project would require improvements to the existing on-site wastewater collection system and connections to the existing off-site wastewater collection system. These improvements would be designed and constructed in accordance with applicable City regulations. Overall, when considering impacts resulting from the installation of any required wastewater infrastructure, all impacts are of a relatively short-term duration (i.e., months) and would cease to occur once the installation is complete. Thus, Project construction impacts to wastewater treatment and collection facilities would be less than significant. Page 21 Project Average Daily Wastewater Generation, the Project is estimated to generate an increase of approximately 70,075 gallons per day (gpd) of wastewater. The JWPCP currently treats approximately 261.1 million gpd of wastewater, and has a total permitted capacity of 400 million gpd. Thus, the plant is currently operating at approximately 65 percent of capacity and has approximately 138.9 million gpd of available capacity. The Project's net increase in wastewater of 70,075 gpd would represent approximately 0.03 percent of this available capacity. Accordingly, adequate available sewage treatment capacity exists at the JWPCP to serve the Project. (3) Construction of a New Stormwater Drainage Facility,. Construction and operation of the Project would rely on existing stormwater drainage facilities. The Project Site is currently a vacant dirt lot. Currently, runoff from the Project Site drains via sheetflow (i.e., flows overland along the ground) and discharges the stormwater into the local storm drain system. The Project would not substantially increase the amount of surface runoff or waste discharge from the Project Site. Therefore, stormwater runoff from the Project Site would not exceed the capacity of the existing stormwater drainage systems and impacts would be less than significant. (4) Determination by a Waste Treatment Provider. 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 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. (5) Cumulative Imoacts. The available treatment capacity of the JWPCP is based on projected growth associated with the adopted South California Association of Governments (SCAG) growth forecasts, which, in turn, are based on the growth projections of those portions of the County and those cities within the JWPCP service area. The 37 cumulative projects involve new developments that, along with the proposed Project, would increase the demand for treatment at the JWPCP. While it is likely that the majority of the related projects would be consistent with the adopted SCAG and growth forecasts of their respective cities, and thus consistent with the facility planning for the JWPCP, there is the potential that some of these projects could include populations greater than that projected/planned, thus resulting in greater demand for treatment capacity than accounted for in the JWPCP's facility planning. Therefore, there is the potential that the related projects could result in a significant impact on wastewater treatment facility capacity. However, as is the case for the Project, wastewater estimates are generally conservative. Related projects would also be required to implement water conservation features pursuant to City ordinances, and thus could have lower wastewater generation than projected. In addition, the related projects would also be subject to the provisions of the applicable jurisdiction's Municipal Code requiring provision of on-site infrastructure, improvements to address local capacity issues and payment of fees for future sewerage replacement and/or relief improvements. Thus, the Project would not contribute to a cumulative significant impact with regard to wastewater facilities. The proposed Project, together with the related projects, would increase the demand for the conveyance of sewage by the local wastewater collection system. However, only those related projects that would utilize the twelve -inch vitrified concrete pipe (VCP) along Rosecrans Avenue would combine with the wastewater collection facility impacts of the proposed Project. As shown in Figure III -7, Location of Related Projects, in Section Page 22 III, Environmental Setting, of the EIR, only related project No. 21 (2171-2191 Rosecrans Avenue) could potentially share this pipe. The preparation of the Sewer Study would ensure that adequate capacity exists in these sewer lines to serve the Project. In accordance with existing City/LACSDs requirements, each of the related projects that would utilize these same sewer lines would be required to demonstrate that adequate capacity exists in these lines to serve them and would be required to provide additional capacity should their flow analyses indicate that adequate capacity does not exist. Therefore, cumulative impacts on the wastewater collection system would be less than significant. Future development of the related projects could affect the amount, the rate, the velocity, and the quality of runoff within their respective local drainage areas. Whether the effects would be beneficial or adverse depends on a number of factors including the amount of pervious/impervious surfaces that would change, the duration of the construction period, the drainage improvements and BMPs that would be incorporated into the design, etc. for each of those projects. However, similar to the Project, the related projects would be subject to NPDES permit requirements for both construction and operation, including development of Storm Water Pollution Prevention Plans(SWPPPs), compliance with Standard Urban Storm Water Mitigation Plan (SUSMP) requirements during operation, and compliance with other local requirements pertaining to runoff volume and surface water quality. Each of the related projects would be required to undergo a preliminary review by the City to determine what, if any, drainage improvements and BMPs would be required to ensure that no significant runoff volume or water quality issues would result. Thus, cumulative construction impacts that may result from concurrent construction of the Project and the related projects, particularly those nearest to the Project Site, would be less than significant through the regulatory requirements of the City's planning permit review processes, which would address potential runoff volume and water quality issues priorto issuance of permits on a project - by -project basis. In addition, as discussed in Section IV.F, Hydrology and Water Quality, the Project would not result in any significant water quality impacts. Therefore, the Project would not have a cumulatively considerable contribution to water quality impacts, and cumulative impacts would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to wastewater, exceed wastewater treatment, construction of new wastewater treatment facilities, construction of a new stormwater drainage facility, and or determination by a waste treatment provider. Utilities and Service Svstems: Solid Waste a) Facts/Effects: (1) Landfill Ca aP.. city. The minor amount of Project -generated demolition debris and construction waste would represent a very small percentage of the inert waste disposal Page 23 capacity in the region. Therefore, the Project would not create a need for additional solid waste disposal facilities to adequately handle project construction -generated inert waste and impacts would be less than significant. Based on the number of employees the Project would employ (see Section IV.I, Population and Housing), the Project would generate approximately 1,725 net tons per year (tpy) (4.7 tons per day (tpd)) of solid waste. Project -generated waste would not exacerbate the estimated landfill capacity requirements addressed for the 15 -year planning period ending in 2031, or alter the ability of the County to address landfill needs via existing capacity and other options for increasing capacity. Therefore, impacts on solid waste disposal from Project operations would be less than significant. (2) Cumulative Impacts. The solid waste cumulative impacts study area is the County of Los Angeles because the landfills open to the City of EI Segundo serve the entire County. County planning for future landfill capacity addresses cumulative demand over 15 -year planning increments. The Los Angeles County Integrated Waste Management Plan, 2016 Annual Report anticipates a 9.66 percent increase in population growth within the County of Los Angeles between 2016 and 2031 and an increase of 16.37 percent in employment. The Project, in combination with the related projects and other reasonably foreseeable growth within the City, would increase solid waste generation during construction and operation. Similar to the Project, the 37 related projects and other reasonably foreseeable growth within the City would generate inert construction and demolition waste. Also similar to the Project, the related projects and reasonably foreseeable growth's construction and demolition waste would be recycled to the extent feasible. The remaining disposal capacity for the County's Class III landfills is estimated at approximately 103.18 million tons as of December 31, 2016. In addition to in -County landfills, out -of -County disposal facilities are also available to the City. Aggressive waste reduction and diversion programs on a Countywide level have helped reduce disposal levels at the County's landfills, and based on the Los Angeles County Integrated Waste Management Plan (ColWMP), the County anticipates that future Class III disposal needs can be adequately met through 2031. Given this future capacity, it is expected that all construction and debris waste can be accommodated during that time, and cumulative impacts regarding the disposal of construction and debris waste would not occur. Project analysis determined its impact on construction solid waste would be less than significant; thus, Project impact would not be cumulatively considerable. Therefore, cumulative impacts due to demolition and construction waste would be less than significant. As with the Project, the 37 related projects would participate in regional source reduction and recycling programs, significantly reducing the number of tons deposited in area landfills. Whereas in the past, solid waste disposal occurred solely within landfills located in the County, the trend in recent years is increased solid waste disposal at landfills located outside of the County. The use of out -of -County landfills will increase in the future given the difficulties associated with permitting new or expanded landfill facilities within the County. As such, the appropriate context within which to view the Project's potential solid waste impacts is total disposal capacity available at landfills located within, as well as outside of, the County. In addition, in order to satisfy the disposal capacity requirements of Assembly Bill (AB) 939, the County is developing facilities utilizing conversion technologies (defined as a wide array of biological, chemical, thermal _....... ....... Page 24 [excluding incineration] and mechanical technologies capable of converting post -recycled residual solid waste into useful products and chemicals, green fuels, such as hydrogen, natural gas, ethanol and biodiesel, and clean, renewable energy such as electricity). Pursuant to CCR Section 18755.5, the County prepared a Countywide Siting Element in June 1997. The Countywide Siting Element has identified goals, policies, and strategies to maintain adequate permitted disposal capacity on an ongoing basis through a 15 -year planning period, and for the long term. To provide this needed disposal capacity, the Countywide Siting Element identified sites that may be suitable for development of new or expansion of existing Class III landfills. The Countywide Siting Element also identified out -of -County landfills that may be available to receive waste generated in the County. Additionally, the Countywide Siting Element includes goals and policies to facilitate the use of out -of -County and remote landfills and foster the development of alternatives to landfill disposal. The County will continually address landfill capacity through the preparation of Annual Reports. The preparation of each Annual Report provides sufficient lead-time (15 years) to address potential future shortfalls in landfill capacity. Therefore, combined cumulative operational waste disposal impacts would be less than significant. It is also anticipated that related projects and other reasonably foreseeable growth would be subject to environmental review on a case-by-case basis to ensure that they would not conflict with AB 939 waste diversion goals or the solid waste policies and objectives in the County's Summary Plan, Siting Element, as well as the City's Source Reduction and Recycling Element (SRRE) and its updates, the Solid Waste Management Policy Plan (CiSWMPP), and the General Plan Framework. Therefore, cumulative impacts associated with solid waste regulations, plans, and programs would be less than significant. b) Mitigation: No mitigation measures are required to reduce the aforementioned impacts below a level of significance. c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Beach Cities Media Campus Project with respect to solid waste, and landfill capacity. Utilities and Service Svstems: Energy a) Facts/Effects: (1) Wasteful, Inefficient or Unnecessary Consumotion of Energy. The Project would not cause wasteful, inefficient, or unnecessary consumption of energy during construction or operation. The Project's energy requirements would not significantly affect local and regional supplies or capacity. Electricity generation capacity and supplies of natural gas and transportation fuels would also be sufficient to meet the needs of Project -related construction and operations. During operations, the Project would comply with existing energy efficiency requirements such as California Green Building Standards Code (CalGreen) as well as include energy conservation measures consistent with Federal, State, and local conservation and reduction goals. In summary, the Project's energy Page 25 demands would not significantly affect available energy supplies and would comply with existing energy efficiency standards. Therefore, Project impacts related to energy use would be less than significant during construction and operation. (2) Substantial Increase in Demand or Transmission Service Resulting in New or Expanded Sources of Energv. Construction and operation of the Project would not result in an increase in demand for electricity or natural gas that exceeds available supply or distribution infrastructure capabilities that could result in the construction of new energy facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Therefore, Project impacts related to energy infrastructure capacity would be less than significant during construction and operation. (3) Cumulative Impacts. Cumulative impacts occur when impacts that are significant or less than significant from a proposed project combine with similar impacts from other past, present, or reasonably foreseeable projects in a similar geographic area. As presented in Section III, Environmental Setting, of the EIR, there are 37 related projects located within the vicinity of the Project Site. The geographic context for the cumulative analysis of electricity is Edison's service area and the geographic context for the cumulative analysis of natural gas is SoCalGas' service area. The 37 related projects are all located within the service areas for Edison and SoCalGas. While the geographic context for transportation - related energy use is more difficult to define, it is meaningful to consider the Project in the context of County -wide consumption. Growth within these geographies is anticipated to increase the demand for electricity, natural gas, and transportation energy, as well as the need for energy infrastructure, such as new or expanded energy facilities. Buildout of the Project, 37 related projects, and additional forecasted growth in Edison's service area would cumulatively increase the demand for electricity supplies and infrastructure capacity. Edison's forecasted total energy consumption in 2019 (the Project buildout year) will be 111,220 gigawatt per hour (GWh) of electricity. As such, the Project -related net increase in annual electricity consumption of 6,378,694 kilowatt per hour (kWh) per year would represent approximately 0.006 percent of Edison's projected consumption in 2019. Although future development would result in the irreversible use of renewable and non-renewable electricity resources during Project construction and operation which could limit future availability, the use of such resources would be on a relatively small scale and would be consistent with growth expectations for Edison's service area. Furthermore, like the Project, during construction and operation, other future development projects would be expected to incorporate energy conservation features, comply with applicable regulations including CALGreen and State energy standards under Title 24, and incorporate mitigation measures, as necessary. As such, the Project's incremental increase in electricity consumption would not contribute to a cumulatively considerable impact. Cumulative impacts related to wasteful, inefficient, and unnecessary use of electricity would be less than significant. Buildout of the Project, 37 related projects, and additional forecasted growth in SoCalGas' service area would cumulatively increase the demand for natural gas supplies and infrastructure capacity. Based on the 2016 California Gas Report, the California Energy and Electric Utilities estimates natural gas consumption within Southern California Gas Company (SoCalGas') planning area will be approximately 2,581 million cf per day in 2019 (the Project's buildout year). As such, the Project would account for approximately 0.0003 percent of the forecasted consumption of natural gas in SoCalGas' planning area for 2019. SoCalGas forecasts account for projected population growth and development w ............. ................. .......... Page 26 based on local and regional plans. Although future development would result in the use of natural gas resources, which could limit future availability, the use of such resources would be on a relatively small scale, would be reduced by measures rendering the Project more energy-efficient, and would be consistent with regional and local growth expectations for SoCalGas' service area. Furthermore, future development projects would be expected to incorporate energy conservation features, comply with applicable regulations including CALGreen and state energy standards under Title 24, and incorporate mitigation measures, as necessary. As such, the Project's incremental increase in natural gas consumption would not contribute to a cumulatively considerable impact. Cumulative impacts related to wasteful, inefficient, and unnecessary use of natural gas would be less than significant. Buildout of the Project, 37 related projects, and additional forecasted growth would cumulatively increase the demand for transportation -related fuel in the state and region. At buildout, the Project would consume a total of 366,643 gallons of gasoline and 64,066 gallons of diesel per year, or a total of 430,709 gallons of petroleum-based fuels per year. For comparison purposes, the estimated transportation energy consumed during construction of the Project would represent approximately 0.009 percent and 0.009 percent of the 2016 annual on -road gasoline- and diesel -related energy consumption, respectively, in Los Angeles County. Additionally, petroleum currently accounts for 90 percent of California's transportation energy sources; however, over the last decade the State has implemented several policies, rules, and regulations to improve vehicle efficiency, increase the development and use of alternative fuels, reduce air pollutants and GHGs from the transportation sector, and reduce vehicle miles traveled which would reduce reliance on petroleum fuels. According to the California Energy Commission (CEC), gasoline consumption has declined by 6 percent since 2008, and the CEC predicts that the demand for gasoline will continue to decline over the next 10 years and that there will be an increase in the use of alternative fuels, such as natural gas, biofuels, and electricity. As with the Project, other future development projects would be expected to reduce vehicle- miles traveled (VMT) by encouraging the use of alternative modes of transportation and other design features that promote VMT reductions. Furthermore, the Project would be consistent with the energy efficiency policies emphasized by the 2016 RTP/SCS. Specifically, the Project would be well -served by existing public transportation, including Metro and Torrance Transit bus lines and the Metro Green rail line. The Project also would introduce new job opportunities within a HQTA, which is consistent with numerous policies in the 2016 RTP/SCS related to locating new jobs near transit. These features would serve to reduce VMT and associated transportation fuel consumption. By its very nature, the 2016 RTP/SCS is a regional planning tool that addresses cumulative growth and resulting environmental effects. Since the Project is consistent with the 2016 RTP/SCS, its contribution to cumulative impacts related to wasteful, inefficient and unnecessary use of transportation fuel would not be cumulatively considerable and, thus, would be less than significant. Based on the analysis provided above, energy consumption (i.e., electricity, natural gas, and fuel) related to development of the Project and 37 related projects and would not result in a cumulatively considerable effect related to the wasteful, inefficient, and unnecessary consumption of energy during construction or operation. As such, the Page 27 1 114 Project's incremental impacts would not contribute to a cumulatively considerable impact; therefore, cumulative energy impacts are concluded to be less than significant. Electricity infrastructure istypically expanded in response to increasing demand and system expansion and improvements by Edison are ongoing. Edison bexpanding and upgrading transmission and distribution networks to meet demand increases within its service area and improve grid performance, while meeting California's ambitious renewable -power goals. Edison's planned improvements account for future energy demand, advances in renewable energy resources and technology, energy efficiency, conservation' and forecast changes in regulatory requirements. Development projects within the Edison service area would also be anticipated to incorporate site-specific infrastructure improvements, as necessary. Each of the 37 related projects xvou/6 be reviewed by Edison to identify necessary power facilities and service connections to meet the needs oftheir respective projects. Project applicants would berequired toprovide for the needs of their individual projects, thereby contributing to the electrical infrastructure in the Project area. As such, the Project's contribution to cumulative impacts with respect to electricity infrastructure would not be cumulatively considerable and, thus, would beless than significant. Natural gas infrastructure is typically expanded in response to increasing demand and system expansion and improvements bySoCa|Gaooccur asneeded. it|sexpected that So[a|Gas would continue to expand delivery capacity ifnecessary tn meet demand increases within its service area. Development projects within its service area, including the Project and related projects also served by the existing SoCalGas infrastructure, would also be anticipated to incorporate site-specific infrastructure improvements, as appropriate. Assuch, the Project's contribution to cumulative impacts with respect to natural gas infrastructure would not be cumulatively considerable and, thus, would be less than significant. Based onthe analysis provided above, the Project's contribution tocumulative impacts related to energy consumption (i.e, electricity, natural gas) would not result in a cumulatively considerable effect related to available supply or distribution infrastructure capabilities that could result in the construction of new energy facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. As such, the Project's impacts would not be cumulatively considerable; therefore, cumulative energy infrastructure impacts are concluded to be less than significant. No mitigation measures are required to reduce the aforementioned impacts below a level of c) Finding: The City Council finds that the FEIR and the record of proceedings do not identify or contain substantial evidence identifying significant environmental effects ofthe Beach Cities Media Campus Project with respect toenergy, wasteful, inefficient orunnecessary consumption of energy, ora substantial increase in demand or transmission service resulting in new o, expanded sources ofenergy. D. Impacts Identified as Potentially Significant in the Initial Study, But Which Can Be Reduced to Less - Than -Significant Levels with Mitigation Measures. The City Council finds that the following environmental effects were identified as Less Than Significant with Mitigation Incorporated in the FOR, and implementation of the identified mitigation measures would avoid or lessen the potential environmental effects listed below to a level of significance. Cultural Resources Paleontolo.ical Resources a) Facts/Effects: (1) Paleontological Resources. Surface deposits on the Project Site consist of older Quaternary dune sands. These types of deposits typically do not contain significant vertebrate fossils in the uppermost layers, but in older sedimentary deposits at depth there may be significant fossil vertebrate remains. Findings of the paleontological resource records search (from the Natural History Museum of Los Angeles County) revealed that there are no known fossil records associated with the Project Site; however, six vertebrate fossil localities, LACM 2035, 3264, 7332, 3789. 1180, and 4942 were collected from depths between 13 feet and 40 feet below the surface from nearby locations. These locations were northwest, north, and northeast of the Project Site. The closest vertebrate fossil locality from older Quaternary deposits is LACM 2035, just northeast of the Project Site near the intersection of Prairie Avenue and 139 -Street, that produced fossil mammoth bones at an unrecorded depth. The paleontologist resource records search concluded that surface grading or very shallow excavations in the Quaternary dune sands would be unlikely to encounter significant vertebrate fossils. However, deeper excavations that extend into older deposits may encounter paleontological resources, including significant vertebrate fossils. To ensure impacts to potential paleontological resources would be less than significant, mitigation measure MM B-1 is recommended, in which a qualified paleontologist shall be retained to perform periodic inspections of excavation and grading activities of the Project Site. In the event paleontological materials are encountered, the paleontologist shall be allowed to temporarily divert or redirect grading and excavation activities in the area of the exposed material to facilitate evaluation and, if necessary, salvage. Therefore, implementation of mitigation measure MM B-1 would ensure that any potential impacts related to paleontological resources would be less than significant. (2) Cumulative Impacts. The study area for cumulative impacts to paleontological resources is the extent of the related project sites (as listed in Section III, Environmental Setting of the EIR). The paleontological resource records search, for the Project Site and area, concluded that very shallow excavations in the Quaternary dune sands would be unlikely to uncover significant vertebrate fossils. However, deeper excavations into older deposits may encounter paleontological resources, potentially including significant vertebrate fossils. Therefore, development of the related projects could have impacts if paleontological resources were found during construction activities. However, it is unknown whether or not significant resources will be found. The potential for an individual project to affect significant paleontological resources is unknown, but given the number of related projects, it is probable that development of the related projects could have impacts on significant paleontological resources (i.e., Public Resource Code (PRC) Section 21083.2). However, similar to the Project, it is anticipated that these related projects would comply with the existing regulatory requirements related to the discovery of previously unknown paleontological resources. In addition, as part of the Page 29 environmental review process for related projects, like the Project, it is expected that mitigation measures would be established to address the potential for uncovering paleontological resources. In addition, compliance with the existing regulatory requirement and implementation of mitigation measure MM B-1 would avoid Project -related impacts related to paleontological resources. This includes monitoring, recovery, treatment, and deposit of fossil remains in a recognized repository should a previously unknown paleontological resource be discovered at the Project Site during construction activities. Therefore, Project impacts to paleontological resources would not be cumulatively considerable, and cumulative impacts would be less than significant. b) Mitigation: Mitigation Measure MM B-1, as set forth in the EIR and MMRP. c) Einem The City Council finds that Mitigation Measure MM B-1 will be imposed as a condition of approval which will avoid or substantially lessen the paleontological resource impact to a less than significant level. Cultural Resources Archaeoloeical Resources. a) Facts/Effects: (1) Archaeological Resources. The results of the South Central Coastal Information Center (SCCIC) archaeological records search for the Project Site indicate that there are no known archaeological resources on the Project Site. As such, the Project Site has not yielded, nor is it likely to yield, information important in prehistory. Therefore, the Project Site would not be considered a historical resource in accordance with CEQA Guidelines Section 15064.5(a)(3)(D). Nevertheless, construction activities would involve excavation below existing grade up to depths of approximately 15 feet to construct the subterranean level at the Project Site and, thereby, create a potential to disturb any previously undiscovered archaeological resources. The archaeological records search recommends that, in order to identify any previously unidentified cultural resources, an archaeological monitor should be in place for ground -disturbing activities. Mitigation Measure MM B-2 provides that a qualified professional archaeologist shall monitor all ground disturbing activities of the Project. If a unique archaeological resource were to be discovered during construction of the Project, adherence to regulatory requirements, and the ceasing of all ground disturbing activities within 50 feet of the find until a qualified archaeologist has evaluated the find in accordance with federal, State, and local guidelines would ensure that potentially significant impacts would not result. Therefore, impacts on archaeological resources would be less than significant. (2) Human Remains. No known human burials have been identified on the Project Site or in recorded resources located within one-half mile of the Project Site. The Project would require excavation to potential depth of 15 feet below the existing grade to construct the subterranean parking level and foundation elements of the Project. As such, it is possible that human remains could be discovered during construction activities. Since human remains could be located subsurface, impacts to these resources would be unknown until encountered during excavation. Mitigation Measure MM B-2 provides that a qualified professional archaeologist shall monitor all ground disturbing activities of the Project. If ......................... .._... ...... _ _ .......... Page 30 human remains are encountered unexpectedly during construction demolition and/or grading activities, compliance with regulatory requirements would ensure that significant impacts do not result. Therefore, impacts on human remains would be less than significant. (3) Cumulative Impacts. The study area for cumulative impacts to archaeological resource and human remains are the extent of the related project sites (as listed in Section III, Environmental Setting of the EIR). In this area, Project construction activities could disturb or destroy previously unknown archaeological resources and, thereby, contribute to the progressive loss of these resources, or may discover previously unknown human remains. Development of the related projects could have impacts if archaeological resources and/or human remains were found during construction activities. However, it is unknown whether or not significant archaeological resources and/or human remains will be found. The potential for an individual project to affect significant archaeological resources and/or human remains is unknown, but given the number of related projects, it is possible that development of the related projects could have impacts on significant archaeological resources as well as human remains. However, similar to Project, it is reasonably anticipated that the related projects would comply with the existing regulatory requirement related to the inadvertent discovery of archaeological resources at a project site, and the existing State law related to discovery of human remains. Certain related projects may also be required to incorporate mitigation measures if there is a high potential for such resources to occur at that site in order to minimize impacts to the greatest extent possible. Compliance with existing regulatory requirements and Mitigation Measure MM B-2 related to archaeological resources or human remains would avoid Project -related impacts. The existing regulatory requirement related to archaeological resources includes monitoring, treatment of any discovered cultural resources, preparation of a final report, and curation of discovered materials in an approved facility. The existing regulatory requirement related to discovery of human remains includes halting work at the site and immediately contacting the coroner. With compliance with the existing regulations and Mitigation Measure MM B-2, Project impacts to archaeological resources would not be cumulatively considerable, and cumulative impacts would be less than significant. b) Mitigation: ,.ion: Mitigation Measure MM B-2, as set forth in the EIR and MMRP. c) Finding: The City Council finds that Mitigation Measure MM B-2 will be imposed as a condition of approval which will avoid or substantially lessen the archaeological resources and human remains impacts to a less than significant level. Greenhouse Gas Emissions a) Facts/Effects: (1) Greenhouse Gas Emissions and Conflict with Applicable Plan. The Project's mitigated Project -Related Greenhouse Gas Emissions, at a level of 3.55 Million tonnes of carbon dioxide equivalents (MTCOze/SP/year), do not exceed the tier 4 SCAQMD 2020 Target m Page 31 __�m Service Population Threshold of 4.8 MTCO2e/SP/year and is in compliance with the reduction goals of the City of EI Segundo CAP, AB -32 and SB -32. Furthermore, the Project will comply with applicable Green Building Standards and City of EI Segundo's policies regarding sustainability (as dictated by the City's General Plan and Climate Action Plan). Therefore, with incorporation of MM D-1 through MM D-4, the Proposed Project would not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases and impacts are considered to be less than significant. (2) Cumulative Impacts. Emitting greenhouse gas (GHGs) into the atmosphere is not itself and adverse environmental effect. Rather, it is the increased accumulation of GHGs in the atmosphere that may result in global climate change; the consequences of which may result in adverse environmental effects. The State has mandated a goal of reducing Statewide emissions to 1990 levels by 2020, even though Statewide population and commerce is expected to grow substantially. Currently, there are no applicable CARB, SCAQMD, or City of EI Segundo quantitative significance thresholds at the project or cumulative levels. Therefore, consistent with CEQA Guidelines Section 15064h(3), the City, as lead agency, has determined that the Project's contribution to cumulative GHG emissions and global climate change would be less than significant if the Project is consistent with the applicable regulatory plans and policies to reduce GHG emissions: Climate Change Scoping Plan, 2016 RTP/SCS, and the Green Building Standards. All projects in the state and City, which include the related projects, are subject to policies and regulations which work to achieve the state's GHG reduction goals, and include state and local green building standards, along with other statewide programs designed to reduce GHG emissions, such as mobile source emissions reductions, fuel standards, and conversion of electricity generation from carbon fuel sources to renewable sources. For these reasons, and since the Project is consistent with GHG reduction goals and policies, the contribution of the Project to the cumulative effect of global climate change is not considered to be cumulatively considerable. b) MltiRation: Mitigation Measures MM D-1, MM D-2, MM D-3, and MM D-4, as set forth in the EIR and MMRP. The City Council finds that Mitigation Measures MM D-1, MM D-2, MM D-3, and MM D-4 will be imposed as a condition of approval which will avoid or substantially lessen the air quality impacts to a less than significant level. Hazards and Hazardous Materials a) Facts/Effects: u Hazardous Release. The Phase I Environmental Site Assessment (ESA) noted that all structures have been removed from the existing Project Site, and no asbestos or asbestos - containing materials (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 Total Petroleum Hydrocarbons (TPH), lead, and polychlorinated biphenyls (PCBs). An Page 32 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 impacts from the release of hazardous materials into the environment would be less than significant. There is a Standard Oil Company and Standard Gasoline Company pipe line easement located along the Project Site frontage. 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-1, impacts would be reduced to a level of less than significant. Routine cleaning supplies used on the Project Site during operations could contain hazardous materials. However, usage of these supplies is subject to county, State, and federal requirements to minimize exposure to people and to ensure safe use, storage, and disposal of any chemicals, including common cleaning and maintenance materials. Compliance with existing regulations would ensure that routine cleaning solvents would not pose a risk from hazardous materials. Therefore, this impact would be less than significant. ll 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 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. Page 33 b) Mitigation, Mitigation Measures MM E-1, as set forth in the EIR and MMRP, c) Finding: The City Council finds that Mitigation Measure MM E-1, will be imposed as a condition of approval which will avoid or substantially lessen the hazard and hazardous materials impacts to a less than significant level. N iydrologv and Water Quality a) Facts/Effects;. (1) Violate Water Quality Standards or Waste Discharge Requirements. The Project would be subject to the NPDES Construction General Permit. Through compliance with NPDES requirements, the Project would be required to comply with the Los Angeles County MS4 Permit, which controls the quality of runoff entering municipal storm drains in the County. In accordance with these requirements, a SWPPP would be developed and implemented during Project construction, and an Erosion Control Plan (under the SWPPP) that specifies BMPs and erosion control measures to be used during construction to manage runoff flows and prevent pollution. Furthermore, construction of the Project would not result in discharges that would cause regulatory standards to be violated. With the compliance of the regulatory requirements and implementation of BMPs, and Mitigation Measures MM F-1 through MM F-6, construction -related impacts to surface water quality would be reduced to a level of less than significant. However, groundwater depths in the vicinity of the Project Site range from 62 to 78 feet bgs, and the historically highest groundwater level on the Project Site is on the order of 40 feet below ground surface (bgs). Excavation for the Project would reach a depth of 15 feet bgs and it is, therefore, not expected that groundwater would be encountered during construction that would require either temporary or permanent dewatering operations. The Project would not result in any substantial increase in groundwater contamination through hazardous materials releases. Accordingly, impacts on groundwater quality would be less than significant, and no mitigation measures are required. As the Project would manage, capture, and treat runoff as required through regulatory compliance and project design features (PDFs), implementation of the Project would represent an improvement in water quality from the existing condition as runoff currently sheet flows untreated to the drainage system. With compliance with regulatory requirements and PDFs incorporating BMPs, and a project -specific SUSMP, and Mitigation Measures MM F-1 through MM F-6, operation -related surface water quality impacts would be reduced to a level of less than significant. Operation of the Project would not require extraction from the groundwater supply based on the depth of excavation for the proposed uses and the depth of groundwater below the Project Site. Therefore, impacts on groundwater quality would be less than significant. (2) Cumulative Im ap cts. The geographic scope of the cumulative impact analysis on surface water hydrology and water quality impacts is the Dominquez Channel and Los Angeles Harbor Watersheds which are located in the southern portion of the Los Angeles Basin. The Project, in conjunction with the future development of the 37 related projects, could Page 34 affect the amount, the rate, the velocity, and the quality of runoff within their respective local drainage areas. Whether the effects would be beneficial or adverse depends on a number of factors including the amount of pervious/impervious surfaces that would change, the duration of the construction period, the drainage improvements and BMPs that would be incorporated into the design, etc., for each of those projects. The nearest related projects include related project numbers 14, 17, 19, 20, 21, 26, 33, 35, and 36. However, similar to the Project, the related projects would be subject to NPDES permit requirements for both construction and operation, including development ofSWPPPs, compliance with SUSMP requirements during operation, and compliance with other local requirements pertaining to hydrology and surface water quality. Each of the related projects would be required to undergo a preliminary review by the City to determine what, if any, drainage improvements and BMPs would be required to ensure that the storm drain capacity of the system serving each of the related projects is adequate, that no downstream flooding would occur as a result of exceedance of storm drain capacity, and that no significant water quality issues would result. Thus, cumulative construction impacts that may result from concurrent construction of the Project and the related projects, particularly those nearest to the Project Site, would be less than significant through the regulatory requirements of the City's planning permit review processes, which would address potential hydrologic and water quality issues prior to issuance of permits on a project -by -project basis. In addition, with implementation of the regulatory requirements, PDFs, and mitigation measures, the Project would not result in any significant hydrology or water quality impacts. Therefore, the Project would not have a cumulatively considerable contribution to hydrology and water quality impacts, and cumulative impacts would be less than significant. The geographic scope of the cumulative impact analysis on groundwater level and quality is the Gage Aquifer. The Project in conjunction with forecasted growth above the Gage Aquifer could cumulatively increase groundwater demand. Grading is expected to consist of excavations as deep as 15 feet bgs for the construction of the proposed subterranean parking level, foundation elements, and removal and recompaction of existing unsuitable soils for the at -grade portion of the Project. Groundwater depths in the vicinity of the Project Site range from 62 to 78 feet bgs, and the historically highest groundwater level on the Project site is on the order of 40 feet bgs. Excavation for the Project would reach a depth of 15 feet bgs and it is, therefore, not expected that groundwater would be encountered during construction Development of the related projects could result in changes in impervious surface area within their respective project sites. However, the related projects would be subject to review and approval pursuant to all applicable regulatory requirements, including any required mitigation of potential groundwater hydrology impacts. In addition, as the related projects are located in an urban area, any potential reduction in groundwater recharge due to the overall net change in impervious area within the area encompassed by the related project sites would be minimal in the context of the regional groundwater basin and, thus, would not result in a significant cumulative effect to groundwater hydrology and cumulative impacts would be less than significant. Future growth in the vicinity of the Project Site would be subject to LARWQCB requirements relating to groundwater quality. In addition, since the Project Site is located in an urban area, future land use changes or development are not likely to cause substantial changes in regional groundwater quality. The Project would not have a Page 35 significant impact on groundwater quality. Also, it is anticipated that like the Project other future development projects would also besubject toLARVVO[Brequirements and implementation of measures to comply with total maximum daily loads in addition to requirements of California Code of Regulations, Title 22, Division 4, Chapter 15 and the Safe Drinking Water Act. Therefore, based onthe fact that the Project does not have an adverse impact on groundwater quality and through compliance with all applicable laws, rules, and regulations, cumulative impacts to groundwater quality would be less than significant. Mitigation Measures MM F-1, MM F-2, MM F-3, MM F-4, MM F-5,and MM F-6, as set forth in the E|Rand K4MRP. The City Council finds that Mitigation Measures MM F-1, MM F-2, MM F-3, MM F-4, MM F-5, and MM F-6 will be imposed as a condition of approval which will avoid or substantially lessen the hydrology and water quality impacts toaless than significant level. Tribal Cultural Resources (l) Tribal Cultural Resmurcea, The City commenced tribal notification for this Project in accordance with AB 52 on November 7, 2017, via a mailing to tribal representatives of the 6abhe|eUo Band of Mission Indians — Kizh Nation, the only tribe which had requested notification of projects within the area including the Project Site. Consultation under AB 52 with the Gabrieleho Band of Mission Indians--Kizh Nation formally concluded onJanuary 3D,ZO18. Based on the records search conducted for the Project and documentation/information provided by Mr. Andrew Salas, on behalf of the Gabrieleho Band of Mission Indians—Kizh Nation, the Project Site is considered sensitive for potential tribal cultural resources. Project grading activities may encounter these resources and impacts may bepotentially significant. With the implementation cf MK8L, 1' which would provide for Native American Monitor during Project grading and excavation activities, impacts on tribal resources would he reduced to less than significant. (2) Cumulative Impacts. The study area for cumulative impacts to tribal cultural resources is the extent of the geographic area with which the identified tribes are traditionally and culturally affiliated. Although the Project Site is located near tribal lands, villages, L.A. Salt Works and Salt Pond, and the Old Salt Road trade route, the Project Site does not contain any known tribal cultural resources, nor did search results byS[C|C, provide substantial evidence as to the presence of tribal cultural resources on the Project Site. However, the Project Site is considered sensitive for potential tribal cultural resources. Projects within this area requiring the preparation of an |S/ND' IS/MND, or E|R are subject to the requirements of AB 52, which includes notifying tribes to solicit consultation and to analyze potential impact oftribal cultural resources. Compliance with existing regulatory measures safeguarding tribal cultural resources would ensure potential impacts from inadvertent discovery would be reduced to a less -than -significant level. Any project sites that contain tribal cultural resources would be required to comply with regulations and/or safeguard mitigation measures to reduce potential impacts to the greatest extent feasible. Nonetheless, as impacts related to tribal cultural resources within the Project Site would be less than significant, the Project would not result in a cumulatively considerable contribution to a significant cumulative impact. b) Mitigation: Mitigation Measure MM L-1, as set forth in the EIR and MMRP, c) Finding: The City Council finds that Mitigation Measure MM L-1 will be imposed as a condition of approval which will avoid or substantially lessen the tribal cultural resource impact to a less than significant level. E. Significant Unavoidable Effects that Cannot be Mitigated to a Level of Insignificance. The City Council finds that the following environmental effects were identified as Significant and Unavoidable in the FEIR. Implementation of the identified mitigation measures would lessen the potential environmental effects to the extent feasible but not below a level of significance. a) FactsCEffe t ; ll Cumulative Im ap cts. The geographic scope of the cumulative employment analysis is the City of EI Segundo. Table IV.I-3 of the EIR presents the estimated increase in employment, housing, and population associated with the 37 related projects identified in Section III, Environmental Setting, of the EIR. As shown in Table IV.I-3 of the EIR, the Project in conjunction with the related projects would result in an increase in employment of approximately 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 of the EIR, would further increase employment opportunities in the City of EI Segundo and surrounding areas. As indicated in Table IV.I-3 of the EIR, the Project in conjunction with the related projects would cumulatively generate approximately 15,680 new jobs. Job growth is considered a beneficial effect, and while the project's incremental contribution to regional job growth would be 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 Page 37 balance between employment, population, and households due to their interrelationship, assuming that employment growth is a driving force of regional population and household growth". To the extent that employment forecasts are used by SCAG to implement the region's 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 the "employment -population -household (EPH) 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 of the EIR, 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 in the EIR, 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 of the EIR, confirms the projections for slow housing growth in the region; only 77 new housing units are currently proposed. In addition, approximately 15,680 jobs would be created by the same list of cumulative projects. However, between 2015 and 2040, the number of households in the South Bay Cities Subregion will increase by 23,532 households. 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. b) Mitigation. No Project -level impacts related to population, housing, and employment have been identified, therefore no mitigation measures are required. There are no available mitigation Page 38 measures to address the incremental contribution of the Project to the significant cumulative impact related to population growth and housing demand. c) Fines The cumulative city and regional population and housing demand impacts of the Project cannot be mitigated below the threshold of significance. Transportation. Traffic and Parking a) Facts Effects: (1) Conflict With an Apohcable Plan Operation. As shown in Table IV.K-6 and Table IV.K-7 of the EIR, after applying the aforementioned significant impact criteria for the different jurisdictions, it is determined that the Project would result in significant impacts under Existing plus Project conditions at seven of the study intersections during the AM and/or the PM peak periods. The Project results in significant impacts at the following seven intersections: 12. Douglas Street & Park Place (PM) 14. Sepulveda Boulevard & Rosecrans Avenue (AM) 20. Aviation Boulevard & Rosecrans Avenue (AM and PM) 21. Isis Avenue & Rosecrans Avenue (AM) 22. Hindry Avenue & Rosecrans Avenue (PM) 24. Northbound 1-405 On -/Off -Ramp & Rosecrans Avenue (AM) 30. Aviation Boulevard & Marine Avenue (AM) None of the other study intersections would be significantly impacted under Existing plus Project conditions. As shown in Table IV.K-10 and Table IV.K-11 of the EIR, after applying the aforementioned significant impact criteria forthe different jurisdictions, it is determined that the Proposed Project would result in significant impacts under Future (year 2020) plus Project conditions at six of the 34 study intersections during the AM or the PM peak periods. The significant impacts are found at the following intersections: 12. Douglas Street & Park Place (AM and PM) 20. Aviation Boulevard & Rosecrans Avenue (AM and PM) 21. Isis Avenue & Rosecrans Avenue (AM) 22. Hindry Avenue & Rosecrans Avenue (AM and PM) 24.1-405 Northbound On -/Off -Ramp & Rosecrans Avenue (AM) 30. Aviation Boulevard & Marine Avenue (AM) None of the other intersections would be significantly impacted under Future plus Project conditions for the proposed Project. Page 39 Intersection 12. Douglas Street & Park Place, The Mitigation Measure MM K-3 would mitigate the significant impact under Existing and Future plus Project conditions. Installation of the signal would require approval from the City of El Segundo. Intersection 21- Isis Avenue & Rosecrans Avenue. The Mitigation Measure K8K8 K'4 would require the approval of the City of Hawthorne. With approval from the City of Hawthorne, the measure would mitigate the significant impact under Existing and Future plus Project conditions. Intersection 24.1-405 Northbound O & Rosecrans Avenue. The Mitigation Measure MM K-5 would require approval by Caltrans. With the approval of Caltrans, the measure would mitigate the significant impact under Existing and Future plus Project conditions. Due to physical constraints or potential secondary impacts, mitigation measures to the following intersections have been determined by to be infeasible. Thus, impacts on these intersections remain significant and unavoidable. Intersection 14. Sepulveda Boulevard && Rosecrans Avenue. This mitigation would involve restriping the northbound lane from two left, four through, and one right to two left, four through, and one through right. This would require the northern portion of the intersection to be reytriped to create an additional receiving through }ane. However, nestr|pinQ the northern portion will create an offset of approximately 10 feet for the northbound and southbound travel lanes making this mitigation infeasible. Since this measure is infeasible, the impact under Existing plus Project conditions would be considered significant and unavoidable. Since this measure is infeasible, the impact under Existing plus Project conditions would be considered significant and unavoidable. Intersection 20. Aviation Boulevard & Rosecrans Avenue. This mitigation would involve adding capacity to the westbound lanes from two left, four through, and one right to two left, five through, and one right. The western portion of the intersection would have to be widened to accommodate the additional through lanes. Theme is no right of way available to widen the road, therefore this mitigation has been deemed infeasible. Since this measure is infeasible, the impact under Existing and Future plus Project conditions would beconsidered significant and unavoidable. Intersection 22' HindrVAvanue & Rosecrans Avenue. This mitigation vxuu|d involve adding capacity tothe westbound lanes from two left, three through, and one shared through rightto two left, fourthrough, and one shared through right. The western portion of the intersection would have to be widened to add an additional receiving lane for the westbound through movements. Theme is no right of way available to widen the rood, therefore this mitigation has been deemed infeasible. Since this measure is infeasible, the impact under Future plus Project conditions would be considered significant and unavoidable. Intersection 30'Aviation Boulevard 8KMarine Avenue. This mitigation would involve adding capacity tothe northbound lanes from two left, two through, and one shared through/riBhtto two left, three through, and one shared through/right. The northern portion of the intersection would have to be widened for an additional receiving lane. There is no right of way available to widen the road, therefore this mitigation has been deemed infeasible. Since this measure is infeasible, the impact under Existing plus Project conditions would be considered significant and unavoidable. (2) Vehicular Access. Vehicular access to the Project Site is proposed to be provided by three driveways along two streets, Rosecrans Avenue and Nash Street. These driveways may be gated to create a secure campus for the Beach Cities Media Campus Project. Driveway 1, along Rosecrans Avenue, is proposed as a full -access entrance and exit allowing vehicular movements in and out of the Project Site from all directions. Driveway 2 will be right-in/right-out for vehicles traveling westbound on Rosecrans Avenue. Driveway 3 is an entrance and exit off the Nash Street & Park Place stop -controlled intersection. All three driveways are proposed as unsignalized. As a result, a majority of the traffic traveling eastbound from the Project Site will use Driveway 3 due to its proximity to the signalized Rosecrans Avenue & Nash Street intersection, which allows for protected and controlled turning movements. There are not really LOS standards for driveways, however, the EIR did identify the driveway as significant and unavoidable impact. Two of the three driveways are projected to operate at acceptable LOS (LOS D or better) under Existing plus Project (2017) and Future plus Project (2020) conditions. Driveway 1 is projected to operate at LOS F in the PM peak period under both Existing and Future plus Project scenarios and LOS E in the AM peak period under the Future plus Project scenario. With the implementation of MM K-2, which proposes for Driveway 1 to become a signalized access point for the Project, the intersection would remain full access, but the installation of a signal would allow for more controlled and efficient movements. It is proposed that the installation of the signal would not only provide better access to the Beach Cities Media Campus, but also to the Kinecta Federal Credit Union business center to the south of the Project Site. The driveway into and out of the Kinecta Federal Credit Union parking lot would be repositioned to align with Driveway 1 and become the southern leg of the intersection. The signal being proposed for Driveway 1 would include a protected left turn phase into the Project Site from the eastbound direction. Southbound access out of the site would include a left -only turning lane, and a shared through/right lane. This similar configuration would be used for the northbound movements, which would share the same signal phase and have permissive left turns. The LOS was rerun with the implementation of a signal at Driveway 1 and the resulting shift in project trips leaving and entering the site. Thus, with the implementation of the mitigation measure, impacts would be reduced to a level of less than significant. To the extent that these mitigation measures are not approved or adopted by relevant jurisdictions, impacts would remain significant and unavoidable. MM K-2 requires approval from the City of Manhattan Beach as well. (3) Cumulative Impacts. A total of 37 related development projects have been identified in the Project area. Although these projects are in varying stages of development (proposed, planned, approved, or under construction), and many may not ultimately be constructed there likely would be some overlap of construction activities between the projects. The 37 related projects are dispersed throughout the Project area. Although the Project would result in less -than -significant construction -related traffic impacts, cumulative construction impacts would be significant and unavoidable due to the potential for concurrent and/or overlapping construction activities of the related projects and the Project. The Project's contribution to this significant cumulative impact would be cumulatively considerable. Page 41 The growth in traffic due to the combined effects of continuing development, intensification of development, and related projects in conjunction with the Project is incorporated into the traffic impacts analysis above. In combination with the traffic of related projects, the increased traffic generated by the Project would result in significant cumulative impacts, as shown in Table IV.K-10 and IV.K-11 of the EIR. The Project's contribution to this significant cumulative impact would be cumulatively considerable. Mitigation Measure MM K-1, MM K-2, MM K-3, MM K-4, and MM K-5, as set forth in the EIR and MMRP. c) Finding: The City Council finds that 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. F. Growth Inducing Impacts. The City Council finds on the basis of the FEIR and the record of proceedings in this matter that there are no significant growth inducing impacts. G. Alternatives To The Project G.1 Alternatives Considered but Rejected as Infeasible a) Description: In accordance with CECIA Guidelines § 15126.6(c), an EIR should identify any alternatives that were considered for analysis but rejected as infeasible and briefly explain the reasons for their rejection. According to the CEQA Guidelines, among the factors that may be used to eliminate alternatives from detailed consideration are the alternative's failures to meet most of the basic project objectives, the alternative's infeasibility, or the alternative's inability to avoid significant environmental impacts. One Alternative was considered and rejected, an Alternative Sites Alternative. G.2 Alternative Sites a) Description: Alternative sites within the City of EI Segundo were considered for development of the Project. Such sites would need to be large enough to accommodate the proposed studio facilities and commercial uses (6.39 acres or greater), and be undeveloped or underdeveloped (e.g. surface parking lot). Very few sites within the City of EI Segundo are large enough to accommodate the Project and even fewer lie within the Transit Adjacent Zone. Alternative locations in the City may also be constrained (e.g., presence of historic resources, hazardous material site, etc.) in ways that would not permit the development of the Project with fewer potential impacts. Furthermore, because of their locations within the City, the overall traffic impacts of developing the Project on these sites would be comparable to the Project. Because these locations are constrained in ways that would not permit the development of the Project with fewer potential impacts, and the alternative sites are not under the control of the project applicant and are not currently available for development, alternative Page 42 locations in City were determined not to be viable. Therefore, these sites were discarded from further consideration. G.3 Project Alternatives 1. Alternative 1: No Proiect Alternative a) tescription: CEQA requires the alternatives analysis to include a No Project Alternative. The purpose of analyzing a No Project Alternative is to allow decision makers to compare the impacts of approving the Project with the impacts of not approving the Project (State CEQA Guidelines Section 15126.6(e)(1)). Pursuant to State CEQA Guidelines Section 15126.6(e)(2): The "no project" analysis shall discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, as well as what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans, and consistent with available infrastructure and community services. In the event the Project is not approved, it is expected that the Project Site would remain in its current condition and no new development would occur for the foreseeable future. The existing vacant lot, totaling approximately 6.39 -acres, would remain. The No Project Alternative assumes the development of the related projects listed in Section III. (Environmental Setting) of the EIR. The potential environmental impacts associated with the No Project Alternative are compared to the environmental impacts that would result from the implementation of the Project, as described in Section IV of the EIR. The No Project Alternative would avoid the Project's significant and unavoidable impacts regarding Population, Housing and Employment cumulative impacts, Transportation, Traffic and Parking intersections, and Transportation, Traffic and Parking cumulative construction because no construction would occur on the Project Site. b) Finding: The City Council finds that the No Project Alternative would not attain the Project's basic objectives. It would not contribute to the Project's objective to create job opportunities or increase the City's economic base. However, the No Project Alternative would avoid the significant and unavoidable Project -related impacts because no new development would occur on the Project Site. 2. Alternative 2: Reduced Proiect Under Alternative 2, Reduced Project, the Project would be reduced by approximately 33 percent. This would result in the construction of a mixed use project with approximately 160,800 sf office uses, 44,220 sf of studio and production facilities, and 4,690 sf of retail uses, as shown in Table VI -1, Alternative 2 Reduced Project of the EIR. The office, studio and retail uses would be provided in three separate buildings. Development of this Alternative also includes the construction of an approximately five -story parking structure with 656 parking spaces. Page 43 The design and configuration of this alternative would be similar to the Project The main difference would be the total square footage and building height, resulting in a mixed-use development with approximately 67percent ofthe mass ofthe Project. Alternative 2 assumes the development of the related projects listed in Section Ill. Environmental Setting of the E|0. The potential environmental impacts associated with the Alternative J one compared to the environmental impacts that would result from the implementation of the Project, as described in Section IV (Environmental Impact Analysis) of the EIR. b) The City Council finds that the Reduced Project Alternative would mostly satisfy the Project Objectives, as listed in Section 11 (Project Description) of the EIR, although to a lesser degree than the Project. The Reduced Project Alternative would reduce, but not avoid the significant and unavoidable Project -related impacts. However, the significant and unavoidable impacts of the Alternative would be lower than the significant and unavoidable impacts of the Project. Furthermore, the reduction in size makes the Project infeasible because it eliminates economies of scale, resulting in unachievable pricing, reduces the attractiveness of the project to large users, and results in a building scale which isnot compatible with the adjacent buildings |n Continental Park. The reduction in size would also reduce the ability to provide for on-site amenities that would allow trip reductions. 3. Alternative 3: Mixed Use Alternative with Studio and Production Facilities a) Alternative 3: Mixed Use Alternative with Studio and Production Facilities, is the same as Alternative 1,described inthe Traffic Report, asshown below. ° Alternative 1 - 25,000 square feet of retail space, 100,000 square feet of general office space, and 188,OOOsquare feet mfstudio and production facilities. Alternative 3, Mixed Use Alternative with Studio and Production Facilities, would develop the Project Site with the following uses: up to 25'000 square feet ofretail space' up to 100,000 square feet of general office space with an option to incorporate a roof deck, up to 188,000 square feet ofstudio and production facilities, and oparking structure, asshown inTable V| - G Alternative 3 Mixed Use Alternative with Studio and Production Facilities of the BR. No buildings onthe Project Site would exceed 14Ofeet inheight. Parking would beinanamount which meets the El Segundo Municipal Code and would be located in a combination of surface parking, underground parking, and aparking structure. Asshown inFigure V|'I,Alternative 3 of the EIR, access to the Project Site would be similar to the Project and would be provided by three driveways. Txxoentry/exi1 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 Lothe east that provides access toSouth Nash Street. Alternative 3 assumes the development of the related projects listed in Section }||. Environmental Setting. The potential environmental impacts associated with the Alternative 3 are compared to the environmental impacts that would result from the implementation of the Project, as described in Section IV (Environmental Impact Analysis) ofthe [|R. Except where otherwise indicated, mitigation measures identified for the Project are also applicable tothe Alternative. b) Finding; The City Council finds that the Mixed Use Alternative with Studio and Production Facilities would have similar impacts to the Project and would mostly satisfy the following Project Objectives, as listed in Section II (Project Description) of the EIR: • To obtain a change in the General Plan and zoning designation to allow development of an economically viable project for the Project Applicant by increasing the diversity of business that can locate on the Project Site. • To create a development that would be compatible with and complementary to adjacent land uses in the Continental Park Development, Plaza EI Segundo, and The Point. • To create the opportunity to develop new uses such as state-of-the-art facilities for entertainment production, studio facilities, office and corporate headquarter space for major technology and entertainment companies. • To reduce VMT and pollution emission, and maximize the public investment in transit by developing an under-utilized site adjacent to several bus lines. • To create economic vitality in the City of EI Segundo by creating construction jobs and permanent full-time on-site jobs. • To generate significant local and regional revenues through business, property, and sales tax revenues. • To obtain vested rights to develop the Project Site under the Mixed Use South zoning in exchange for a limit on the number of peak vehicle trips that may occur. The Mixed Use Alternative with Studio and Production Facilities would satisfy the following project objectives to a lesser degree than the Project: • To stabilize and improve the City's tax base by providing new businesses and services and by providing an employee base that could help support adjacent retail uses and restaurants which further stabilizes the City's tax base. Comparatively, the Mixed Use Alternative with Studio and Production Facilities would reduce, but not avoid the significant and unavoidable Project -related traffic impacts and would have the same impacts with relation to housing growth. Specifically, Alternative 3 would result in three fewer significantly impacted intersections before mitigation for the Existing plus Project scenario, and two fewer significant impacted intersections before mitigation under Future plus Project conditions. After mitigation, the Alternative would have one less significant and unavoidable impact compared to the Proposed Project mitigation for both the Existing plus Project and Future plus Project conditions. Although the Alternative may reduce the LOS impacts at two of the studied intersections, the difference is insignificant and, therefore, the Alternative does not substantially lessen any significant impact. Thus, impacts would be less than the Projects' significant and unavoidable impacts on traffic. 4. Alternative 4: Mixed Use Alternative with Research Development a) Description: Alternative 4: Mixed Use Alternative with Research and Development, is the same as Alternative 2 in the Traffic Report, as shown below. Page 45 Alternative 2 - 100,000 square feet of research and development, 10,000 square feet of retail, and 100,040 square feet of creative office space. Alternative 4, Mixed Use Alternative with Research and Development, would develop the Project Site with the following uses: up to 100,000 square feet of research and development space, up to 10,000 square feet of retail space, up to 100,040 square feet of creative office space with an option to incorporate a roof deck, and a parking structure as shown in Table VI - 28, Alternative 4 Mixed Use Alternative with Research and Development of the EIR. No buildings on the Project Site would exceed 140 feet in height. Parking would be in an amount which meets the EI Segundo Municipal Code and would be located in a combination of surface parking, underground parking, and a parking structure. As shown in Figure VI -2, Alternative 4 of the EIR, access to the Project Site would be similar to the Project and would be provided by three driveways. 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. Alternative 4 assumes the development of the related projects listed in Section III. Environmental Setting of the EIR. The potential environmental impacts associated with the Alternative 4 are compared to the environmental impacts that would result from the implementation of the Project, as described in Section IV (Environmental Impact Analysis) of the EIR. Except where otherwise indicated, mitigation measures identified for the Project are also applicable to the Alternative. b) Md'in The City Council finds that the Mixed Use Alternative with Research and Development would have lower impacts than the Project. The Mixed Use Alternative with Research and Development would achieve the following Project Objectives, as listed in Section II (Project Description) of the EIR, to a similar degree as the Project. • To obtain a change in the General Plan and zoning designation to allow development of an economically viable project for the Project Applicant by increasing the diversity of business that can locate on the Project Site. • To create a development that would be compatible with and complementary to adjacent land uses in the Continental Park Development, Plaza EI Segundo, and The Point. • To create the opportunity to develop new uses such as state-of-the-art facilities for entertainment production, studio facilities, office and corporate headquarter space for major technology and entertainment companies. • To reduce VMT and pollution emission, and maximize the public investment in transit by developing an under-utilized site adjacent to several bus lines. • To create economic vitality in the City of El Segundo by creating construction jobs and permanent full-time on-site jobs. • To generate significant local and regional revenues through business, property, and sales tax revenues. • To obtain vested rights to develop the Project Site under the Mixed Use South zoning in exchange for a limit on the number of peak vehicle trips that may occur. Page 46 The Mixed Use Alternative with Research and Development would achieve the following Project Objectives, as listed in Section II (Project Description) of the EIR, to a lesser degree than the Project: • To stabilize and improve the City's tax base by providing new businesses and services and by providing an employee base that could help support adjacent retail uses and restaurants which further stabilizes the City's tax base. Comparatively, the Mixed Use Alternative with Research and Development would reduce, but not avoid the significant and unavoidable Project -related traffic impacts and would have the same impacts with relation to housing growth. Alternative 4 would result in three fewer significantly impacted intersections before mitigation for the Existing plus Project scenario, and two fewer significantly impacted intersections before mitigation for Future plus Project conditions. After mitigation, the Alternative would have one less significant and unavoidable impact compared to the Proposed Project mitigation for both the Existing plus Project and Future plus Project conditions. Although the Alternative may reduce the LOS impacts at two of the studied intersections, the difference is insignificant and, therefore, the Alternative does not substantially lessen any significant impact. Thus, the significant and unavoidable impacts of the Alternative would be lessthan the significant and unavoidable impacts of the Project. 5. Alternative 5: All Creative Office Soace Alternative a) Description: Alternative 5: All Creative Office Space Alternative is the same as Alternative 3 in the Traffic Report, as shown below. • Alternative 3 - 261,990 square feet of creative office space. Alternative 5, the Creative Office Space Alternative, would develop the Project Site with the following uses: up to 261,990 square feet of creative office space with an option to incorporate a roof deck and a parking structure as shown in Table VI -50, Alternative 5 Creative Office Space Alternative of the EIR. No buildings on the Project Site would exceed 140 feet in height. Parking would be in an amount which meets the EI Segundo Municipal Code and would be located in a combination of surface parking, underground parking, and a parking structure. As shown in Figure VI -3, Alternative 5 of the EIR, access to the Project Site would be similar to the Project and would be provided by three driveways. 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. Alternative 5 assumes the development of the related projects listed in Section Ill. Environmental Setting of the EIR. The potential environmental impacts associated with the Alternative 5 are compared to the environmental impacts that would result from the implementation of the Project, as described in Section IV (Environmental Impact Analysis) of the EIR. Except where otherwise indicated, mitigation measures identified for the Project are also applicable to the Alternative. Page 47 b) Fines, The Creative Office Space Alternative would have lower impacts than the Project. The Creative Office Space Alternative would achieve the following Project Objectives, as listed in Section II (Project Description) of the EIR, to a similar degree as the Project. • To obtain a change in the General Plan and zoning designation to allow development of an economically viable project for the Project Applicant by increasing the diversity of business that can locate on the Project Site. • To create a development that would be compatible with and complementaryto adjacent land uses in the Continental Park Development, Plaza El Segundo, and The Point. • To stabilize and improve the City's tax base by providing new businesses and services and by providing an employee base that could help support adjacent retail uses and restaurants which further stabilizes the City's tax base. • To reduce VMT and pollution emission, and maximize the public investment in transit by developing an under-utilized site adjacent to several bus lines. • To create economic vitality in the City of EI Segundo by creating construction jobs and permanent full-time on-site jobs. • To generate significant local and regional revenues through business, property, and sales tax revenues. • To obtain vested rights to develop the Project Site under the Mixed Use South zoning in exchange for a limit on the number of peak vehicle trips that may occur. The Creative Office Space Alternative would achieve the following Project Objectives, as listed in Section II (Project Description) of the EIR, to a lesser degree than the Project. • To create the opportunity to develop new uses such as state-of-the-art facilities for entertainment production, studio facilities, office and corporate headquarter space for major technology and entertainment companies. Comparatively, the Creative Office Space Alternative would be the same as the significant and unavoidable Project -related impacts. III. STATEMENT OF OVERRIDING CONSIDERATIONS. The City Council finds on the basis of the FEIR which includes the Draft EIR dated March 1, 2019, the Final EIR dated June 20, 2019, and the entire administrative record for this matter, that the unavoidable significant impacts of the Beach Cities Media Campus Project as discussed in Section 11.1.E. above are acceptable when balanced against the benefits of the Project. The City Council finds that the following environmental effects were identified as Significant and Unavoidable in the FEIR. Implementation of the identified mitigation measures would lessen the potential environmental effects to the extent feasible but not below a level of significance. • 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 Page 48 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 City Council finds that 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. Additionally the City Council finds that the improvements to the Intersections of Isis Avenue/Rosecrans Avenue and 1-405 Northbound On -/Off Ramps and Rosecrans Avenue, as well as the installation of the traffic signal at Driveway 1 all require approval of other jurisdictions and the impacts at those locations may remain significant if not approved. The significant impacts are outweighed by the following substantial public and social factors as identified in the FEIR and the record of proceedings in the matter. Each Project objective/benefit set forth below constitutes an overriding consideration warranting approval of the Project. 1. The Project would return a previous industrial site to productive use by constructing state-of-the-art facilities for entertainment production, studio facilities, office and corporate headquarters space for major technology and entertainment companies that will contribute to job creation and balance growth with local resources and infrastructure capacity. Full build out of the Project is estimated to accommodate 1,033 new permanent jobs and numerous temporary construction jobs. 2. The Project would create a development that would be compatible with and complementary to adjacent land uses in the Continental Park Development, Plaza EI Segundo, and The Point. 3. The Project would generate complementary economic activity by providing new businesses and services and by providing an employee base that could patronize adjacent retail uses and restaurants in the Continental Park Development, Plaza EI Segundo, and The Point. 4. The Project will help foster economic development in the City by contributing to a strong business climate, with positive outcomes such as business retention and attraction, as well as effective levels of City services to all members of the community. S. The Project will improve the City's tax base by generating business, property, and sales tax revenues, thereby providing the Citywith resources to provide high-quality servicesto residents and the daytime population. 6. The Project will provide traffic mitigation measures and signalization that will generally improve traffic circulation in this area of the City and will observe automobile trip caps to ensure that the Project does not result in traffic impacts beyond those identified in the environmental analysis. 7. The Project will reduce vehicle miles travelled, air pollutant and greenhouse gas emissions, and maximize the public investment in transit, compared to a less beneficially sited project, by developing an under-utilized site adjacent to several bus lines. 8. The Project will be developed within one-half mile of the existing Metro Green Line rail station, which would be consistent with regional planning programs and plans, and EI Segundo General Plan land use policies which identify where investing planning efforts and resources will yield the greatest progress toward improving mobility, livability, prosperity and sustainability. 9. The Project will provide environmentally sensitive development, by incorporating sustainable and green building design and construction that reduces waste, manages water use efficiently and conserves energy, and by providing employment opportunities within easy access of established public transit. Page 49 IV. RECIRCULATION A. Facts: 1. The City received comments on the DEIR from public agencies in written form. The FOR contains written responses to all comments ("Responses to Comments") received on the DEIR as of May 22, 2019. Some comments were incorporated into the FOR as factual corrections and minor changes. The FEIR includes all factual corrections and minor changes to the DEIR. On July 12, 2019, the Council received late supplemental comments to a letter received on May 22, 2019. All comments and testimony received prior to and at the City Council's public hearing have been considered and errata to the FEIR was prepared. B. Finding: Pursuant to CEQA Guidelines § 15088.5 and Public Resources Code § 21092.1, and based on the FEIR and the record of proceedings for the Beach Cities Media Campus Project, the City Council finds that: 1. Factual corrections and minor changes are set forth as additions and corrections to the DEIR; and 2. The factual corrections and minor changes to the DEIR are not substantial changes in the DEIR that would deprive the public of a meaningful opportunity to comment on a substantial adverse environmental effect of the Beach Cities Media Campus Project, a feasible way to mitigate or avoid such an effect, or a feasible Project alternative; and 3. The factual corrections and minor changes to the DEIR will not result in new significant environmental effects or substantially increase the severity of the significant effects previously disclosed in the DEIR; and 4. The factual corrections and minor changes to the DEIR will not involve mitigation measures or alternatives which are considerably different from those analyzed in the DEIR that would substantially reduce one or more significant effects on the environment; and 5. The factual corrections and minor changes to the DEIR do not render the DEIR so fundamentally inadequate and conclusory in nature that meaningful public review and comment would be precluded. Thus, the City Council finds that none of the conditions set forth in CEQA Guideline § 15088.5 or Public Resources Code § 21092.1 requiring recirculation of a draft environmental impact report were met. The City Council further finds that incorporation of the factual corrections and minor changes to the DEIR into the FOR does not require that the FEIR to be recirculated for public comment. V. SUBSTANTIAL EVIDENCE The City Council finds and declares that substantial evidence for each and every finding made herein is contained in the FEIR, which is incorporated herein by this reference, and in the record of proceedings in the matter. Page 50 EXHIBIT A-3 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 IVA 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 13-2: 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 IV -4 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: Construction Implementation Party: Applicant Enforcement Agency: Planning and Building Safety Department Monitoring Agency: Planning and Building Safety Department 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 H. 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: Pre- Construction, Construction Implementation Party: Applicant Enforcement Agency: Planning and Building Safety Department Monitoring Agency: Planning and Building Safety Department L. Hydrology/Water Quality i) Project Design Features 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 Page IV -5 IV. Mitigation Monitoring and Reporting Program City of EI Segundo 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 PDF F-2: 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 June 2019 PDF F-4: The Project shall comply with all NPDES Permit and waste discharge requirements. Monitoring Phase: Construction, Post Construction Implementation Party: Applicant Enforcement Agency: Planning and Building Safety 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 forthe 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 Party: 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 El Segundo Monitoring Agency: June 2019 Planning and Building Safety Department, Los Angeles County Department ofPublic Works MM F-4: The applicant must design aconveyance and detainment system tomeet the Los Angeles County Department ofPublic Works limits onthe 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 ofPublic Works Planning and Building Safety Department, Los Angeles County Department ofPublic Works MM F-5: The Project must comply with City of ElSegundo Ordinance No. 1347 and No. 1248,which establishes storm water and urban pollution controls. Monitoring Phase: Implementation Party: Enforcement Agency: Monitoring Agency: 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 BMI)s for the life of the project. 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 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program City of EI Segundo J. Land Use/Planning June 2019 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. L. Noise 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) Project 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 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -10 City ofBSegundo Implementation Party: Enforcement Agency: Monitoring Agency: June 2019 Applicant Public Works Department Planning and Building Safety Department PDF J-2; Provide an automatic fire sprinkler system throughout each office/studio building, installed inaccordance with California Fire Code Chapter 9and the currently adopted edition ofthe NFPA --' Monitoring Phase: Pne'[onstructimn,Construction Implementation Party: Applicant Enforcement Agency: Fire Department Monitoring Agency: Planning and Building Safety Department PDF J-3: Provide manual fire alarm system throughout each building, installed inaccordance with California Fire Code Chapter 9and the currently adopted edition of NFPA 72. Monitoring Phmmm; 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 inaccordance with California Fire Code Chapter 9and the currently adopted edition ofNFPA 14. Beach Cities Media Campus Project Monitoring Phase: Construction Implementation Party: Applicant Enforcement Agency: Fire Department Monitoring Agency: Planning and Building Safety Department Page IV -11 - — _ IV. Mitigation Monitoring and Reporting Program City of EI Segundo June 2019 1 M ligation Measures No mitigation measures are required. ii) Police Protection 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. 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; Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -12 City of EI Segundo June 2019 • 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 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 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -13 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. a Carpool encouragement, • Ride -matching assistance, ■ Preferential carpool parking, • Flexible work schedules for carpools, ■ Half time transportation coordinator; and • 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, a 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: Implementation Party: Enforcement Agency: Monitoring Agency: Pre -Construction, Construction Applicant Public Works Department Planning and Building Safety Department Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -14 City of EI Segundo June 2019 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 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. Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -15 City of EI Segundo C1 June 2019 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: Implementation Party: Enforcement Agency: Monitoring Agency: Tribal Cultural Resources 0 Project Design Features Pre -Construction, Construction Applicant 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 logthat 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 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -16 City of EI Segundo R. June 2019 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 Utilities/Service Systems 0 Water 1) 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: Pre -Construction, Construction Implementation Party: Applicant Enforcement Agency: Public Works Department Monitoring Agency: Planning and Building Safety Department Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -17 City of EI Segundo ii) June 2019 1 Mita ation Measures No mitigation measures are required. Wastewater 1 Proiect Design Features PDF M.2-1: 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 shall obtain necessary permits and licenses, and provide traffic control plans and shoring plans. Monitoring Phase: Implementation Party: Enforcement Agency: Monitoring Agency: 1 MLtigation Measures No mitigation measures are required.. 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: Pre -Construction, Construction Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -18 City of EI Segundo June 2019 Implementation Party: Applicant Enforcement Agency: Planning and Building Safety Department Monitoring Agency: 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 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 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -19 City of EI Segundo June 2019 2) Mitigation 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 -20 City of EI Segundo June 2019 Beach Cities Media Campus Project IV. Mitigation Monitoring and Reporting Program Page IV -21