RPVCCA_CC_SR_2013_08_06_05_Border_IssuesCITY OF
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
REVIEWED:
HONORABLE MAYOR & CITY COUNCIL MEMBERS
CAROLYNN PETRU, AICP, DEPUTY CITY MANAGER~
AUGUST 6, 2013
BORDER ISSUES STATUS REPOR~ ... n.
CAROLYN LEHR, CITY MANAGER ~
Project Manager: Kit Fox, AICP, Senior Administrative Analyst@)
RECOMMENDATION
1) Receive and file the current report on the status of Border Issues; and 2) adopt
Resolution No. 2013-_, expressing an official City Council position opposing the
current Ponte Vista proposal.
EXECUTIVE SUMMARY
This month's report includes:
• A report on the release of the Final Environmental Impact Report (FEIR) for the
Ponte Vista project at the former Navy housing site on Western Avenue in Los
Angeles (San Pedro);
• An update on the Los Angeles County General Plan Update affecting the
unincorporated areas of the Peninsula;
• An update on recent issues and events related to the Rancho LPG butane
storage facility in Los Angeles (San Pedro); and,
• A report on the release of the Final Program Environmental Impact Report
(FPEIR) for the Port Master Plan Update in the Port of Los Angeles (San Pedro).
BACKGROUND
The following is the regular bi-monthly report to the City Council on various "Border
Issues" potentially affecting the residents of Rancho Palos Verdes. The complete text
of the current status report is available for review on the City's website at:
http://palosverdes.com/rovlp/anning/border issues/2013120130806 Border/ssues StatusRpt.cfm
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MEMORANDUM: Border Issues Status Report
August6,2013
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DISCUSSION
Current Border Issues
Ponte Vista Project at Former Navy Housing Site, Los Angeles (San Pedro)
On June 27, 2013, the City of Los Angeles released the Final Environmental Impact
Report (FEIR) for the Ponte Vista project on Western Avenue in San Pedro. The FEIR
and appendices are available for review on-line at the following link:
http://planning.la city. org/eir/Ponte VistaProj2/FEI R/FEI R%20Ponte%20Vista%20Project. htm I
Staff posted a link to PDFs of the FEIR and appendices under the "Spotlight" feature on
the City's home page, and the FEIR was also made available for review in digital form at
the Miraleste Branch Library on Palos Verdes Drive East.
Although the 1, 135-unit plan is still officially the "proposed" project, the FEI R makes it
clear that it is the developer's intention to pursue the reduced-density, 830-unit proposal
(Alternative 'C'). The FEIR includes detailed analysis of two (2) additional alternatives:
a 169-unit detached, single-family alternative that complies with the current site zoning
(R1-1XL and OS-1XL); and a 477-unit mixed-use alternative that includes commercial
and office space, a branch library and a 6-acre public park. However, both of these new
alternatives are rejected as financially infeasible. The FEIR also includes a detailed
summary and analysis of the project's relationship to the Rancho LPG facility.
A public hearing on the development entitlements and FEIR before the Deputy Advisory
Agency and the City Planning Commission Hearing Officer was initially scheduled for
Wednesday, July 24, 2013, at 10:00 AM at Los Angeles City Hall on Downtown Los
Angeles. Mayor Brooks contacted Los Angeles City Councilman Joe Buscaino to ask
for a change of venue for the public hearing, as had been done for the previous 2,300-
unit Ponte Vista proposal in 2008-2009. On July 3, 2013, Staff learned that the Ponte
Vista hearing had been moved to the Port of Los Angeles Administration Building in
Downtown San Pedro at 10:00 AM on Tuesday, July 30, 2013 (see attached revised
notice). Staff immediately notified subscribers to our Border Issues listserve group of
these changes. However, it should also be noted that the purpose of the public hearing
is only to receive public testimony on the development entitlements and FEIR. Based
upon public comment submitted at the hearing, a Staff report and recommendation will
be prepared for the consideration of the Los Angeles City Planning Commission at a
future date. The project will also need to be approved by the Los Angeles City Council.
On July 1, 2013, the Planning and Land Use Committee of the Northwest San Pedro
Neighborhood Council (NWSPNC) met to discuss the Ponte Vista FEIR. At that
meeting, the developer's community outreach representative reported that the 830-unit
proposal had been further modified to:
• Provide a 3.5-acre open space/park area along the access roadway to Mary
Star-of-the-Sea High School;
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MEMORANDUM: Border Issues Status Report
August6,2013
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• Incorporate a business center into the proposed resident community center;
• Allow for an on-site daycare center within the project site; and,
• Provide an emergency egress driveway from the adjacent Seaport Townhomes
condominiums.
Even with these further modifications, the NWSPNC remained concerned about the
FEIR and the proposed project and specific plan. However, NWSPNC refrained at that
time from expressing formal opposition to the project in the interest of maintaining open
lines of communication with the developer.
Shortly after the July 1st NWSPNC meeting, the developer's community outreach team
contacted Staff about meeting to discuss our City's concerns about the project.
Although we were unable to arrange a meeting before the July 30th public hearing, we
did ask if the developer would be able to make a brief presentation of the project to the
City Council at tonight's meeting. As of the date that this report was completed, the
developer had yet to confirm whether or not they would be able to attend tonight's
meeting. However, it should be noted that Staff has tentatively scheduled a meeting
with the developer's community outreach team on August 15, 2013.
Staff has reviewed the FEIR and the City of Los Angeles' responses to our previous
comments on the Draft EIR. On July 29, 2013, Staff transmitted the attached comments
on the project and FEIR to the City of Los Angeles. We acknowledged that the
applicant had responded extensively to all of the comments that we had made about the
Draft EIR. However, we also noted that we had lingering concerns with respect to:
• Emergency access along Western Avenue;
• Traffic impacts related to student drop-off/pick-up at Dodson Middle School;
• Increased public demand and wear-and-tear at Eastview Park;
• Traffic mitigation measures along Western Avenue; and,
• The rejection of several project alternatives as financially infeasible.
The public hearing on July 30, 2013, was well attended by members of the surrounding
community and included both proponents of and opponents to the project (see attached
agenda). This included Mayor Pro Tern Duhovic and Councilmen Campbell and
Misetich. The developer presented an extensive overview of the history of the site and
the proposed project, and the NWSPNC was allotted equal time to express its
opposition to the proposed project. Following these presentations, public comments
from the audience were accepted, including those of Councilmen Campbell and
Misetich and a representative of Los Angeles Councilman Buscaino's office.
Given that the Ponte Vista project is now entering the phase during which final
development entitlements may be granted (or not) by the City of Los Angeles in the
near future, Staff believes that the City Council may wish to consider taking a formal
position in support of or opposition to the project as currently proposed. In their
comments at the July 3ot11 public hearing, Councilmen Campbell and Misetich
suggested adopting a resolution expressing the City Council's formal position on the
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MEMORANDUM: Border Issues Status Report
August 6, 2013
Page4
current Ponte Vista proposal. Therefore, Staff has prepared the attached draft
resolution for the City Council's consideration.
At the July 30th public hearing, the hearing officer noted that the Los Angeles City
Planning Commission (CPC) was tentatively scheduled to consider the Ponte Vista
project on Thursday, September 12, 2013, at Los Angeles City Hall in Downtown Los
Angeles. However, he also noted that it appeared unlikely that the CPC Staff report
could be completed in time to make it on that agenda. Based upon our experience with
the previous 2,300-unit Ponte Vista proposal in 2008-2009, Staff anticipates that it may
be October or November before the CPC reviews this project. Staff will continue to
monitor this project in future Border Issues reports.
Los Angeles County General Plan Update, Unincorporated Areas of the Peninsula
On June 27, 2013, the City received notice of the revised Notice of Preparation of an
Environmental Impact Report (EIR) for the Los Angeles County General Plan Update
(see attachment). Similar to the issues of concern that we had raised with respect to
the unincorporated areas of the Peninsula in 2004 and 2007, Staff submitted the
attached comments to the County on July 26, 2013. These comments included
landslides and slope stability; private sewage disposal systems, biological resource
impacts; impacts upon local school facilities and changes in land use. Staff now awaits
the release of the draft EIR associated with the General Plan update, and will continue
to monitor this project in future Border Issues reports.
Rancho LPG Butane Storage Facility, Los Angeles (San Pedro)
At the .June 4, 2013, City Council meeting, the City Council directed Staff to prepare
letters to Los Angeles Councilman Joe Buscaino, U.S. Congresswoman Janice Hahn
and U.S. Congressman Henry Waxman regarding the Rancho LPG facility. The letters
were completed and signed by the Mayor on June 18, 2013 (see attachments). Copies
of these letters were also provided to State Senator Ted Lieu and State
Assemblymember Al Muratsuchi.
On July 8, 2013, Staff received a phone call from the EPA, advising us that Rancho
LPG had submitted written responses to their March 14, 2013, notice, and that the EPA
was reviewing these responses. Subsequently, in response to the Mayor's letter of
June 18, 2013, Congresswoman Hahn also sent the attached letter to the EPA on July
10, 2013, asking the EPA to expedite its review of Rancho LPG's response to the
violations alleged in the EPA's notice of March 14, 2013. In addition, on July 31, 2013,
Congressman Waxman sent the attached letter to the Department of Homeland
Security (OHS), asking for an explanation of apparent discrepancies between the
assessment of the risks posed by the Rancho LPG facility to OHS and EPA.
In the past two (2) months, several interested parties have forwarded items via e-mail,
drawing comparisons between the Rancho LPG facility and other recent hazard issues
and events. These have included:
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MEMORANDUM: Border Issues Status Report
August 6, 2013
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• The Chevron refinery fire in Richmond, CA in August 2012;
• The fertilizer plant explosion in West, TX in April 2013;
• The train derailment and resulting fire in Quebec, Canada in July 2013, and,
• A gas plant explosion in Florida in July 2013.
Copies of these e-mails are attached to tonight's report. Staff will continue to monitor
this project in future Border Issues reports.
Port Master Plan Update, Port of Los Angeles
On July 26, 2013, the City received the attached notice of the Final Program
Environmental Impact Report (FPEIR) for the Port Master Plan Update (PMPU). This
notice included responses to our previous comments on the Draft PEIR and the PMPU
itself (see attachments). Staff has reviewed these responses and is generally satisfied
with that the issues that we raised have been addressed.
The Board of Harbor Commissioners (BHC) is scheduled to conduct a public hearing to
consider certification of the FPEIR on Thursday, August 8, 2103 at 8:00 AM at the Port
of Los Angeles Administration Building, 425 S. Palos Verdes St., San Pedro, CA 90731.
Staff will continue to monitor this project in future Border Issues reports.
New Border Issues
There are no new Border Issues on which to report at this time.
Attachments:
• Draft Resolution No. 2013-_
• Revised notice for Ponte Vista hearing (received 7/8/13)
• Excerpts from FEIR for Ponte Vista project:
o Introduction (Section I)
o Response to Comments -Topical Responses (Section Ill.A)
o Response to Comments -Rancho Palos Verdes (Section 111.B)
o Corrections and Additions to Draft EIR (Section IV)
o Mitigation Monitoring and Reporting Program (Section V)
• NWSPNC Planning & Land Use Committee agenda (dated 7/1/13)
• Comments on Ponte Vista project and FEIR:
o Rancho Palos Verdes
o NWSPNC
o R Neighborhoods R1
o E-mail from Barbara Velez
• Daily Breeze article regarding Ponte Vista project (published 7/29/13)
• Public hearing agenda for Ponte Vista project (dated 7/30/13)
• Revised NOP for Los Angeles County General Plan Update (received 6/27/13)
• City comments on NOP for Los Angeles County General Plan Update (dated
7/26/13)
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MEMORANDUM: Border Issues Status Report
August6,2013
Page 6
Attachments (cont'd):
• Letters to Councilman Buscaino, Congresswoman Hahn and Congressman
Waxman regarding Rancho LPG facility (dated 6/18/13)
• Letter from Congresswoman Hahn to EPA regarding Rancho LPG facility (dated
7/10/13)
• Letter from Congressman Waxman to OHS regarding Rancho LPG facility (dated
7/31/13)
• E-mails regarding Rancho LPG facility (miscellaneous dates)
• Notice of FPEIR for Port Master Plan Update (received 7/26/13)
• Excerpts from FPEIR and Port Master Plan Update:
o Introduction
o Response to City comments on FPEIR
· o Response to City comments on Port Master Plan Update
M:\Border lssues\Staff Reports\20130806 _Borderlssues _ StaffRpt.docx
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Draft Resolution No. 2013-
5-7
RESOLUTION NO. 2013-_
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF RANCHO
PALOS VERDES, OPPOSING THE CURRENT, 830-UNIT PROPOSAL
FOR THE PONTE VISTA PROJECT AT THE FORMER SAN PEDRO
NAVY HOUSING SITE AT 26900 WESTERN AVENUE IN THE CITY OF
LOS ANGELES, AND RECOMMENDING THAT THE PROJECT BE
REDESIGNED TO FURTHER REDUCE ITS OVERALL RESIDENTIAL
DENSITY AND TO INCORPORATE A GREATE.R PERCENTAGE OF
TRADITIONAL, DETACHED SINGLE-FAMILY (I.E., "R-1 ") HOMES
WHEREAS, since its closure in the late 1990s, the City of Rancho Palos Verdes
has monitored, commented upon and participated as a stakeholder in the development
of plans for the reuse of the former San Pedro Navy housing site at 26900 Western
Avenue i.n the City of Los Angeles; and,
WHEREAS, the Rancho Palos Verdes City Council was appreciative of the
inclusion of several Rancho Palos Verdes residents on the Ponte Vista Community
Advisory Committee in 2007 when the original 2,300-unit proposal for the site was
under consideration; and,
WHEREAS, the Rancho Palos Verdes City Council went on record as supporting
the recommendations of the Ponte Vista Community Advisory Committee, which
rejected a revised 1,950-unit proposal and affirmed the current R-1 zoning and density
for the property, believing that these recommendations were reflective of the desires of
the majority of residents who live near the Ponte Vista site; and,
WHEREAS, the Rancho Palos Verdes City Council was subsequently pleased to
learn that the Los Angeles Planning Staff and City Planning Commission ultimately
recommended denial of the project in 2009, including recommendations for an un-gated
community with a mix of housing types at an overall density that was more comparable
with those of surrounding neighborhoods; and,
WHEREAS, the Rancho Palos Verdes City Council believes that the eventual
redevelopment of the former San Pedro Navy housing site for residential purposes is in
the best interest of the cities of Los Angeles and Rancho Palos Verdes and their
respective residents in that it would remove a blighted, obsolete land use from the site;
provide new home ownership opportunities in the Los Angeles Harbor area; provide
construction jobs and support for local businesses in both Los Angeles and Rancho
Palos Verdes; and contribute to the revitalization of the Western Avenue corridor; and,
WHEREAS, the Rancho Palos Verdes City Council has considered the project
proponent's current, 830-unit Ponte Vista proposal, including the review of the project's
Environmental Impact Report, draft specific plan and related development entitlements
(City of Los Angeles Case Nos. CPC-2012-2558-GPA-ZC-SP, VTT-71886-MU and
ENV-2005-4516-EIR).
5-8
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES DOES HEREBY FIND, DETERMINE, AND RESOLVE AS FOLLOWS:
Section 1: The City Council remains concerned about the impact of the
proposed project upon emergency access along Western Avenue, which is the only
point of ingress/egress for this project and for thousands of existing residents in
surrounding neighborhoods in Rancho Palos Verdes and San Pedro.
Section 2: Based upon our decades-long experience with school circulation
patterns in the project area, the assumption that middle-school students residing at
·Ponte Vista will desire (or even be permitted) to walk to Dodson Middle School is
unrealistic. As such, the City Council believes that traffic impacts upon the Rolling Hills
Riviera neighborhood surrounding the school have not been adequately or accurately
addressed.
Section 3: Even with the developer's last-minute offer of some limited public
open space within the Ponte Vista project, the City Council believes that the City's
Eastview Park will experience increased demand and wear-and-tear as a result of the
project, which will not be mitigated or offset by the payment of Quimby fees to the City
of Los Angeles.
Section 4: Although the project's traffic study concludes that adverse project
impacts can be fully mitigated, the City Council is concerned that some of these
proposed mitigation measures along Western Avenue will be unacceptable to our City
and/or CalTrans, thereby resulting in significant adverse traffic impacts that will not be
mitigated to an insignificant level. As an example, we are informed that CalTrans will
not permit the proposed signalization of the intersection of Western Avenue and Fitness
Drive.
Section 5: The Final EIR rejects as infeasible several project alternatives that
have lower residential density; include a greater mix of residential and non-residential
uses; and/or conform to the existing zoning of the site, on the basis (at least in part) that
such alternatives are financially infeasible. However, this is a condition that the City
Council believes that the surrounding community is not obligated to accept as a
rationale for maximizing the currently developer's profit due to the unrealistically high
price paid for the property by previous developers.
Section 6: For all of the reasons articulated above, the City Council opposes
the current, 830-unit Ponte Vista project.
Section 7: The City Council recommends redesigning the Ponte Vista project
to further reduce its overall residential density and to incorporate a greater percentage
of traditional, detached single-family (i.e., "R-1") homes than are provided under the
current, 830-unit proposal.
Resolution No. 2013-_
Page 2 of 3
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Section 8: The City Clerk shall certify to the adoption of this Resolution, and
shall cause this Resolution to be transmitted to the City of Los Angeles for inclusion as
a part of the administrative record of the Ponte Vista project (City of Los Angeles Case
Nos. CPC-2012-2558-GPA-ZC-SP, VTT-71886-MU and ENV-2005-4516-EIR).
PASSED, APPROVED, AND ADOPTED this_. th day of August 2013.
Mayor
Attest:
City Clerk
State of California )
County of Los Angeles ) ss
City of Rancho Palos Verdes )
I, Carla Morreale, City Clerk of the City of Rancho Palos Verdes, hereby certify that the
above Resolution No. 2013-_ was duly and regularly passed and adopted by the said
City Council at a regular meeting thereof held on August_, 2013.
M:\Border lssues\Ponte Vista Project\20130806_DraftResolution.docx
City Clerk
Resolution No. 2013-_
Page 3of3
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CITY OF Los ANGELES
CALIFORNIA
DEPARTMENT OF CITY PLANNING
To Owners: O Within a 100-Foot Radius
(!!Within a 500-Foot Radius
·And-Occupants: DWitl:lin a 10.QrF.oot Radius
!!]Within a 500-Foot Radius
And: !!]Others D·Abutting a Proposed Development Site
CONCURRENT PUBLIC HEARING ·LOCATION AND DATE OF HEARING CHANGED
You are being sent this notice because you own and/or reside at property near a site for which an application,
as described below, has been filed with the Department of C.ity Planning, you have indicated an interest in the
project and/or have requested such notice be provided to you, or you may have expertise/experience regarding
the project. All interested persons are invited to attend the public hearing at which you may listen, ask
questions, or present testimony regarding the project.
Hearing By: Advisory Agency/Hearing Officer Case No.: CPC-2012-2558-GPA-ZC-SP
VTT-71886-MU
ENV-2005-4516-EIR Date:
Time
Place:
Staff Contact:
Phone No:
EIR Case Staff
Contact:
Phone No:
PROJECT
LOCATION:
PROPOSED
PROJECT IN
EIR:
\l\'eanesElay, July 24, 2013
New Date
Tuesday, July 30, 2013
10:00 a.m.
200 N. Spring Street, Room 1020
New Location at
425 South Palos Verdes Street,
Boardroom, San Pedro, CA 90731
Henry Chu
(213) 978-1324
Erin Strelich
(213) 978-1351
26900 South Western Avenue
CEQANo.:
Previous
Cases:
Incidental
Cases:
Project Name:
Council No.:
Plan Area:
Specific Plan:
Certified NC:
GPLU:
Zone:
Applicant:
Representative:
SCH No. 2010101082
CPC-2006-8043-GPA-ZC-SP-DA,
VTT-63399
None
Ponte Vista
15
Wilmington/Harbor City
None
Northwest San Pedro
Low Residential and Open Space
R1-1XL and OS-1XL
SFI Bridgeview, LLC
David P. Waite,
Cox, Castle & Nicholson, LLP
The Project consists of the development of a residential community comprised of 1, 135
dwelling units featuring a combination of single-family homes, duplexes, townhomes, and
flats. The Project would be comprised of a combination of dwelling units within the following
categories:
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VVadnesday, July 24, 2013 Tuesday, July 30, 2013
CPC-2012-2558-GPA-ZC-SP, VTI-71886-MU
ENV-2005-451~ELR ·.
Page2
ALTERNATIVE.
ACCEPTED BY
APPLICANT
AS FILED:
· ··• ·•· '·'fwo-and three-story detached single-family homes with alley-loaded private garages
• Three-story buildings containing townhomes and flats with elevators and motor-court
private garages
• Two-and three-story townhome duplexes with alley-loaded private garages
• Three-story buildings containing townhomes and flats with alley-loaded private
garages
• Three-story townhomes in row house buildings with alley-loaded private garages
• Four-story buildings containing flats with elevators and secured common garages
• Four-story buildings with elevators over a secured common basement garage
containing apartments
As part of the Project, all existing improvements would be removed from the site, including
245 residential dwelling units, a community center, and a retail convenience facility that were
constructed in approximately 1962 by the U.S. Navy· for the .. purpose of housing personnel
stationed at the Long Beach Naval Shipyard. All of these buildings and uses are vacant.
The Environmental Impact Report CEIR) for the Project evaluated the following alternatives to
the proposed Project, which could be considered:
Alternative A: No Project Alternative/No Development: Alternative B: No Project
Alternative/Single-Family Homes: Alternative C: Staff R~commendation/Reduced Density
(Environmentally Superior Alternative); and Alternative D: Revised Site Plan.
Alternative C -Staff Recommendation/Reduced Density, as described in the EIR, would
develop the site at a Low Medium I Residential density and would add 830 residential
dwelling units, comprised of 208 single-family dwellings, 404 residential townhomes and row
houses and 218 apartment units, to the site. No public park would be developed. The
amount of publicly-accessible open space associated with Alternative C would be less than
that associated with the Proposed Project due to the elimination of the public park
component, but would include access to the trail and landscaped open space area
surrounding the perimeter of the Project Site and will also include pedestrian access to the
open space areas through the Project Site. Alternative C would, however, provide a greater
amount of open space for the use of Project residents. An access road from Western Avenue
to Mary Star of the Sea High School would be provided in this alternative.
Alternative C ~ould involve development of a project similar to the Proposed Project on the
site, however the total number of residential units would be reduced from 1, 135 to 830. A
total of six different housing product types would be included under Alternative C as shown in
the table below:
Alternative C Dwelllnn Unit Summa v
Housing Description Proposed# Dwelling Avg.#of Avg.Size/ Average#of Other
Product Type ofDwelllng Unlta/ Acre Units/ Bldg. Unit (sq. ft.) Bedrooms/ Description
Units IGrosel Unit of Units
Single· Family 2/3 Story; Street I Housing 69 s.s 1.0 2,400 3.0
(detached) Loaded
Single· Family 2/3 Story; Alley 2 Housing 60 9.0 1.0 2.000 3.0
(detached\ Loaded
Single-Family 213 Story; Alley 3 Housing 79 I I.I 1.0 1,540 3.0
<detached\ Loaded
Townhomes/Fla Elevator/Non·
4A/4B ts Combination 224 16.0 9.7 1;300 2.2 Elevator; Alley
Loaded
SA/SB Row Houses 180 17.8 S.9 1440 2.3 Allev Loaded
6 Apartments 218 SS.9 43.S 820 1.4 Walk-Up; Alley
Loaded
Totals 830 13.5 (average)
Source: SFJ Bridvei•lew, LLC.
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'A'-Odnesday, July 24, 2013 Tuesday, July 30, 2013
CPC-2012-2558-GPA-ZC-SP, VTT-71886-MU
ENV-2005-4516-EIR
Page 3
Alternative A would demolish and remove all existing improvements from the Project Site, but
would leave the Property undeveloped. It would avoid most of the Project's impacts and
would normally be identified as the Environmentally Superior Alternative. However, CEQA
mandates that when a "No Project" alternative is identified as environmentally superior, an
additional development alternative should also be identified as "environmentally superior".
Alternative C is also deemed the Environmentally Superior alternative in the EIR. The
Applicant has accepted Alternative C. It is expected that the City Planning Commission will
consider approval of Alternative C instead of the Proposed Project in the El R.
REQUESTED . The Deputy Advisory Agency will consider:
ACTION:
1. Pursuant to Section 21082.1(c) of the California Public Resources Code, the adoption of
the Certification of Environmental Impact Report, findings, Statement of Overriding
Considerations and accompanying mitigation measures and Mitigation Monitoring and
Reporting Program for ENV-2005-4516-EIR, SCH No. 2010101082;
· · 2. Pursuant to Los Angeles Municipal Code (LAMC) Section 17.15, Vesting Tentative Tract
Map 71886 for a 244-lot subdivision for 208 single family homes, 404 townhomes and
row houses, and 218 apartment units with 1,642 parking spaces and 349 guest parking
spaces on a 60.6 net acre site in the R1-1XL and OS-1XL zones.
The City Planning Commission Hearing Officer will consider:
1. Pursuant to Section 11.5.6 of the Municipal Code, a General Plan Amendment to the
Wilmington-Harbor City Community Plan to change the land use designation from "Low
Residential" and "Open Space" to "Low Medium I", "Low Medium II" and "Medium
Residential";
2. Pursuant to Section 12.32 of the Municipal Code, a Zone Change from R1-1XL and OS-
1XL to a Specific Plan zone to be created;
3. Pursuant to Section 11.5. 7 of the Municipal Code, the establishment of the Ponte Vista
at San Pedro Specific Plan to provide regulatory controls and the systematic execution
of the General Plan within the Project area;
The purpose of the hearing is to obtain testimony from affected and/or interested persons regarding this
project. The environmental document will be among the matters considered at the hearing. The decision
maker will consider all the testimony presented at the hearing, written communication received prior to or at the
hearing, and the merits of the project as it relates to existing environmental and land use regulations. After the
hearing. the Hearing Officer will prepare a report, including a recommendation, which will be considered by the
City Planning Commission at a later date.
EIR CERTIFICATION: An Environmental Impact Report (EIR) has been prepared for this project, as described
above, to assess potential environmental impacts. An EIR is comprised of two parts, the Draft EIR and the
Final EIR. A Draft EIR was made available and circulated for public review and comment, pursuant to the
provisions of the California Environmental Quality Act (CEQA), for an extended 60-day public review period
from November 8, 2012 to January 7, 2013. The Final EIR responds to the comments and includes text
revisions to the Draft EIR in response to input received on the Draft EIR. Unlike the Draft EIR, comments on
the Final EIR are not required to be responded to by the City. If written comments are received, they will be
provided to the Planning Commission as part of the staff report for the project. The EIR will be submitted to the
Planning Commission and City Council for requested certification and action on the Project.
EXHAUSTION OF ADMINISTRATIVE REMEDIES: If you challenge a City action in court, you may be limited
to raising only those issues you or someone else raised at the public hearing described in this notice, or in
written correspondence on these matters delivered to the Department before the action on this matter will
become a part of the administrative record. Note: This may not be the last hearing on this matter . ...
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\IVednesday, July 24, 2013 Tuesday, July 30, 2013
CPC-2012-2558-GPA-ZC-SP I VTI-71886-MU
ENV-2005-4516-EI R
Page4
ADVICE TO PUBLIC: The exact time this report will be considered during the meeting is uncertain since there
may be several other items on the agenda. Written communications may be mailed to (Henry Chu at The Los
Angeles Department of City Planning, Major Projects, City Hall, Room 750, 200 N. Spring Street, Los Angeles,
CA 90012).
WRITTEN COMMUNICATION: Written communications should cite the Case Number indicated at the top of
this notice and may be mailed to the attention of Henry Chu at The Los Angeles Department of City Planning,
Major Projects, City Hall, Room 750, 200 N. Spring Street, Los Angeles, CA 90012.
REVIEW OF FILE: CPC-2012-2558-GPA-ZC-SP and VTI-71886-MU, including the application and the
environmental assessment, are available for public inspection at this location between the hours of 8:00 a.m. to
4:00 p.m., Monday through Friday. Please call Henry Chu at (213) 978-1324 several days in advance to
assure that the files will be available. Case files will not be available for inspection on the day of the
hearing.
If you wish to revi~w a copy of the Final Environmental Impact Report (FEIR) or the documents referenced in
the FEIR, you may do so by appointment during our office hours of 8:00 a.m. to 4:00 p.m., at City Hall, 200 N.
Spring Street, Room 750, Los Angeles CA 90012. Please call Erin Strelich at (213) 978-1351. Copies of the
FEIR are also at the following Library Branches:
1. San Pedro Regional Branch Library, 931 S. Gaffey Street, San Pedro, CA 90731
2. Harbor City-Harbor Gateway Branch Library, 24000 S. Western Avenue, Harbor City, CA 90710
3. Wilmington Branch Library, 1300 N. Avalon Boulevard, Wilmington, CA 90744
4. Los Angeles Central Library, 630 W. 5th Street, Los Angeles, CA 90071
The Project Site is located near the jurisdictions of Los Angeles County, Lomita, arid Rancho Palos Verdes.
The DEIR will also be available in digital format for review at these libraries that are outside the City of Los
Angeles Public Library system, due to their proximity to the Project Site:
5. Lomita Public Library (County of Los Angeles, Public Library), 24200 Narbonne Avenue, Lomita, CA
90717
6. Miraleste Library (City of Ranchos Palos Verdes), 29089 Palos Verdes Drive East, Rancho Palos
Verdes, CA 90275
The FEIR is also available online at the Department of City Planning's website [http://cityplanning.lacity.org
(click on "Environmental" and then "Final Environmental Impact Reports")]. The FEIRs can be purchased on
CD-ROM for $7.50 per copy. Contact Erin Strelich of the City of Los Angeles at (213) 978-1351 to purchase
one.
ACCOMMODATIONS: As a covered entity under Tltle II of the Americans with Disabilities Act, the City of Los
Angeles does not discriminate on the basis of disability. The hearing facility and its parking are wheelchair
accessible. Sign language interpreters, assistive listening devices, or other auxiliary aids and/or services may
be provided upon request. Como entidad cubierta bajo el Titulo II de/ Acta de los Americanos con
Desabilidades, la Ciudad de Los Angeles no discrimina. La facilidad donde la junta se llevara a cabo y su
estacionamiento son accesibles para sil/as de ruedas. Traductores de Lengua de Muestra, dispositivos de
oido, u otras ayudas auxiliaries se pueden hacer disponibles si usted las pide en avance.
Other services, such as translation between English and other languages, may also be provided upon request.
Otros servicios, como traducci6n de Ingles a otros. idiomas, tambien pueden hacerse disponibles si usted Jos
pide en avance.
To ensure availability or services, please make your request no later than three working days (72 hours) prior
to the hearing by calling the staff person referenced in this notice. Para asegurar la disponibilidad de estos
servicios, por favor haga su petici6n al mi nimo de tres di as (72 horas) antes de la reuni6n, l/amando a la
persona def personal mencionada en este aviso.
5-14
;;;-
~=
--
GENERAL PLAN AMENDMENT-ZONE CHANGE·
SPECIFIC PLAN -VESTING TENTATIVE TRACT MAP -HAUL ROUTE
14549Arohwood Sl Suite 301
Van NU)'ll. California 91405
Phone (818) 997.7949 • Fax (818) 997-ll351
qmapp1ng@qesqma.com
ORAWNBV:
A,P,N. THOMAS BROTHERS
Page:793,B23 Grid: J.7,J-1 7 442-001-(009-012)
CD: 15
LEGAL
CT: 2951.01
LOT! PORLOT1
PA: 433-WILMINGTON
TRACT: 3192 M.B. 44-91·94
"SEEAPPLICATIONS" USES: FIELD
· CONTACT: FUSCOE ENGINEERING
DATE:~
SITE ADDRESS Update: 99 96 12
26900 WESTERN AVENUE 06-1§.13
CASE NO:
SCALE: 1 "=200'
D.M.: QZ1'.!!.1i3,024B 193
PHONE: 213·988·8802 NET AC! 61.53 '•. QMS: 12-0840 5-15
Excerpts from FEIR for Ponte Vista project:
Introduction (Section I)
5-16
City of Los Angeles
Department of City Planning• Environmental Analysis Section
City Hall• 200 N. Spring Street, Room 750 •Los Angeles, CA 90012
FINAL ENVIRONMENTAL IMPACT REPORT
WILMINGTON-HARBOR CITY COMMUNITY PLAN AREA
This document, together with the Draft EIR and its appendices, comprise the Final EIR as required under
the California Environmental Quality Act
Ponte Vista Projeet
Case Number: ENV-2005-4516-EIR
State Clearinghouse Number: 2010101082
Project Location: 26900 South Western A venue, Los Angeles, California, 90732
Council District: 15
Project Description:
The Project proposes a Specific Plan (proposed density is approximately 13.5 units per acre), General Plan
Amendment, Zone Change, and Vesting Tentative Tract Map for the subdivision, construction, and operation of an
830-unit residential development. The Project's residential units would he comprised of single-family, townhome,
flat, and apartment units ranging in size from 600 to approximately 2,800 square feet, within buildings constructed
over and/or adjacent to residential parking garages. Up to 218 of the 830 units may he rental units. The Project
would also provide an access road from Western A venue to the off-site, private Mary Star of the Sea High School.
The Project Site is approximately 61.5 acres. The Project would incorporate internal open space and recreational
areas, including a community clubhouse and pool/recreation area and approximately 7.1 acres of park area.
Additional recreational amenities would he distributed throughout the site. The Project would involve the
demolition and removal of all existing improvements on the Site, which include 245 vacant residential units, a 2,161-
square foot community center, and a 3,454·-square foot retail convenience facility which were constructed in
approximately 1962 by the U.S. Navy for the purpose of housing and accommodating personnel stationed at the
Long Beach Naval Shipyard. The Site (formerly known as "San Pedro Housing") was closed in the late 1990s.
APPLICANT: PREPARED BY:
SFI Bridgeview, LLC CAJ A Environmental Services
June 2013
ON BEHALF OF:
The City of Los Angeles
Department of City Planning
Environmental Analysis Section
5-17
TABLE OF CONTENTS
Section Page
I. Introduction ................................................................................................................................... .1-1
IL List of Commenters ...................................................................................................................... II-1
III. Responses to Comments ............................................................................................................. III-1
A. Topical Responses .............................................................................................................. 111.A-1
B. Individual Responses .......................................................................................................... III.B-1
IV. Corrections and Additions to the Draft EIR ................................................................................ IV-1
V. Mitigation Monitoring and Reporting Program ........................................................................... V-1
Appendices
Appendix A Comment Letters on the Draft EIR
Appendix B Alternatives Economic Feasibility Study
Appendix C LACSD "Will Serve" Letter
Appendix D Draft Ponte Vista Specific Plan
Ponte Vista Project
Final Environmental Impact Report
Table of Contents
Pagei
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City of Los Angeles
Ponte Vista Project
Final Environmental Impact Report
This page left blank intentionally
June 2013
Table of Contents
Page ii
5-19
I. INTRODUCTION
A. PURPOSE
Before approving a project, the California Environmental Quality Act (CEQA) requires the lead agency to
prepare and certify a Final Environmental Impact Report (Final EIR). The contents of a Final EIR are
specified in Section 15132 of the CEQA Statute and Guidelines, as follows:
The Final EIR shall consist of
(a) The Draft EIR or a revision of the Draft.
(b) Comments and recommendations received on the Revised Draft EIR either verbatim or in
summary.
(c) A list of persons, organizations, and public agencies commenting on the Revised Draft
EIR.
( d) The responses of the Lead Agency to significant environmental points raised in the
review and consultation process.
(e) Any other information added by the Lead Agency.
The evaluation and response to public comments is an important part of the CEQA process as it allows
the following: ( 1) the opportunity to review and comment on the methods of analysis contained within the
Draft EIR; (2) the ability to detect any omissions which may have occurred during preparation of the
Draft EIR; (3) the ability to check for accuracy of the analysis contained within the Draft EIR; (4) the
ability to share expertise; and (5) the ability to discover public concerns.
B. PROCESS
As defined by Section 15050 of the CEQA Guidelines, the City of Los Angeles Planning Department is
the Lead Agency for the Project. A Notice of Preparation (NOP) was prepared and circulated on October
26, 2010 through November 29, 2010 for the required 30-day review period.
The public review period for the Draft EIR for the Ponte Vista Project was November 8, 2012 to January
7, 2013, for a 61-day review period.
Comments on the Draft EIR were received during the comment period, and those comments are set forth
and are responded to in this Final EIR.
The Draft EIR and this Final EIR will be submitted to the Planning Commission and City Council for
requested certification and action on the Project.
Ponte Vista Project
Final Environmental Impact Report
I. Introduction
Page I-1
5-20
City of Los Angeles June2013
C. ORGANIZATION OF THE FINAL EIR
Together with the Draft EIR and its appendices, this document constitutes the Final EIR for the Project
and includes the following sections:
Section I. Introduction: This section provides an introduction to the Final EIR.
Section II. List of Commenters: This section includes a list of the persons and agencies that submitted
comments on the Draft EIR.
Section ill. Responses to Comments: This section includes responses to each of the comments
submitted by persons and agencies listed in Section II.
Section IV. Corrections and Additions to the Draft EIR: This section provides corrections and
additions to the Draft EIR, based on comments received during and after the public review period and
based on staff-initiated text changes.
Section V. Mitigation Monitoring and Reporting Program: This section includes all of the mitigation
measures identified to reduce or avoid environmental impacts of the project and notes the monitoring
phase, the enforcement phase, and the applicable department or agency responsible for ensuring that each
mitigation measure is implemented.
Appendices: The appendices to this document include copies of all the comments received on the Draft
EIR and additional information cited to support the responses to comments.
D. CHANGE IN PROPOSED PROJECT
Subsequent to the conclusion of the public review period for the Draft EIR, the Project Applicant (SFI
Bridgeview, LLC) formally requested the City to replace the original Proposed Project description (1,135
units) with a reduced density (830 units) site plan that was evaluated as "Alternative C" in the Draft EIR.
Because this reduced density proposal was evaluated in the Draft EIR, the responses to comments
contained in this document primarily address the 830-unit project proposal, rather than the 1,135-unit plan
that was presented as the Proposed Project in the Draft EIR.
In addition, the Project Applicant is no longer requesting approval of a Development Agreement from the
City for the Project. A secondary pedestrian/emergency vehicular access lane has also been added to the
Project along the site's southern boundary adjacent to the Seaport Village development.
Further discussion of these changes is presented in Section IV, Corrections and Additions to the Draft
EIR.
Ponte Vista Project
Final Environmental Impact Report
I Introduction
Page I-2
5-21
City of Los Angeles June2013
E. REVIEW AND CERTIFICATION OF THE FINAL EIR
Consistent with State law (Public Resources Code 21092.5), responses to agency comments will be
forwarded to each commenting agency at least 10 days prior to the public hearing. At the same time,
responses will be distributed to all commenters who provided an address.
The Final EIR is available for public review at the following locations:
Erin Strelich
City of Los Angeles
Department of City Planning
200 Spring Street, Room 750
Los Angeles, CA 90012
Telephone: (213) 978-1351
E-Mail: erin.strelich@lacitv.org
Central Library
630 W. 5th Street
Los Angeles, CA 90071
San Pedro Regional Branch Library
931 S. Gaffey Street
San Pedro, CA 90731
Harbor City-Harbor Gateway Branch Library
24000 S. Western Avenue
Harbor City, CA 90710
Wilmington Branch Library
1300 N. Avalon Boulevard
Wilmington, CA 90744
Lomita Public Library (County of Los Angeles)
24200 Narbonne Avenue
Lomita, CA 90717
Miraleste Library (City of Rancho Palos Verdes)
29089 Palos Verdes Drive East
Rancho Palos Verdes, CA 90275
The Final EIR is also available online at the Department of City Planning's website
[http://planning.lacity.org/ (click on "Environmental" and then "Final EIR")]. The Final EIR can be
Ponte Vista Project
Final Environmental Impact Report
l Introduction
Page I-3
5-22
City of Los Angeles June 2013
purchased on CD-ROM for $7.50 per copy. Contact Erin Strelich of the City of Los Angeles at
erin.strelich@lacity.org or by phone at (213) 978-1351 to purchase one.
Ponte Vista Project
Final Environmental Impact Report
/. Introduction
PageI-4
5-23
II. LIST OF COMMENTERS
The City of Los Angeles Department of City Planning received a total of 187 comment letters on the
Draft EIR. Each comment letter has been assigned a corresponding number, and distinct comments
within each comment letter are also numbered. For example, comment letter "Al" is from the State
Clearinghouse and Office of Planning and Research. Tue· comments in this letter are numbered "Al-1",
etc.
The agencies, organizations and persons listed below provided written comments on the Draft EIR to the
. City of Los Angeles during and after the formal public review period, which was from November 8, 2012
to January 7, 2013. Copies of the comments are included in Appendix A to this document.
Public Agencies and Neighborhood Councils
Al. State Clearinghouse and Office of Planning and Research (Scott Morgan) on January 8, 2013
A2. City of Los Angeles, Bureau of Sanitation (Ali Poosti) on December 10, 2012
A3. California Department of Fish and Game (Daniel Blankenship #1) on December 11, 2012
A4. California Department of Fish and Game (Daniel Blankenship #2) on November 27, 2012
AS. City of Lomita (Margaret Estrada, Mayor) on December 19, 2012
A6. South Bay Parkland Conservancy on December 31, 2012
A7. Metropolitan Transportation Authority (Scott Hartwell) on December 28, 2012
A8. City of Rancho Palos Verdes (Kit Fox) on January 7, 2013
A9. California Department of Transportation (Dianna Watson, Caltrans District 7) on January 7, 2013
AlO. County Sanitation Districts of Los Angeles County (Adriana Raza) on January 7, 2013
Al 1. U.S. Department of the Navy (Captain M.H. Hardy) on January 4, 2013
Al2. South Coast Air Quality Management District (Cheryl Marshall) on January 4, 2013
Al3. U.S. Department of Defense, Defense Logistics Agency (David Rodriguez) on January 4, 2013
Al4. Native American Heritage Commission (Dave Singleton) on November 21, 2012
Al5. City of Los Angeles, Northwest San Pedro Neighborhood Council (Diana Nave) on January 7,
2013
Al6. City of Rolling Hills Estates (David Wahba) on January 3, 2013
Ponte Vista Project
Final Environmental Impact Report
II. List of Commenters
Page II-I
5-24
City of Los Angeles
Private Individuals, Homeowners Associations, and Private Organizations
Bl. Yeager, Elizabeth on December 4, 2012
B2. Yeager, Walter on December 4, 2012
B3. Frka, Mike and Lisa (#1) on December 4, 2012
B4. Marks, William (#1) on December 4, 2012
BS. Lund, Harold on November 12, 2012
B6. Urwin, Jim on November 14, 2012
B7. Nave, Pat on January 7, 2013
B8. De Luca, Mike on December 17, 2012
B9. Sandell, April on December 19, 2012
BlO. Thorsen, Rob on December 20, 2012
Bl 1. Smith, James on December 18, 2012
Bl2. Kurata, Irene on December 29, 2012
B13. Gossett, Linda on January 1, 2013
B14. Robertson, Larry on January 1, 2013
B15. Vaughn, Erin on January 2, 2013
B16. Bero, Bryan on January 2, 2013
B 17. Penicks (no full name given) on January 2, 2013
B18. Franklin, Jan on January 2, 2013
B19. Huber, Sharon on January 2, 2013
B20. McKim, Gale and Judy on January 2, 2013
B21. Nelson, Dean on January 2, 2013
B22. Van Lue, Nick and Jan on January 2, 2013
Ponte Vista Project
Final Environmental Impact Report
June 2013
II List of Commenters
Page 11-2
5-25
City of Los Angeles
B23. Murphy, Raye on January 2, 2013
B24. Mattingly, Michael (#1) on January 2, 2013
B25. Howard, Lucy on January 2, 2013
B26. Macauley, Craig, on January 2, 2013
· B27. Muraro, Rose on January 2, 2013
B28. Divona, Frank on January 2, 2013
B29. Lanning, Joe on January 2, 2013
B30. Dileva, Ralph (#1) on January 2, 2013
B31. Sover, John and Suzanne on January 3, 2013
B32. Munoz, Martha on January 2, 2013
B33. Huskins, Robert and Marjorie on January 2, 2013
B34. Nunez, Jay on January 2, 2013
B35. Frka, Mike and Lisa (#2) on January 2, 2013
B36. Marcia, Suzanne on January 2, 2013
B37. Hester, Mary on January 2, 2013
B38. Gonzalez, Steven on January 2, 2013
B39. Stagnaro, Chris on January 2, 2013
B40. Stallman, William on January 2, 2013
B41. Ferree, Adrianne on January 2, 2013
B42. Muaina, Evon on January 2, 2013
B43. Wilson, Greg on January 3, 2013
B44. Mosich, Joyette on January 3, 2013
B45. Koehler, Jeff on January 3, 2013
Ponte Vista Project
Final Environmental Impact Report
June2013
II. List of Comm enters
Page Il-3
5-26
City of Los Angeles
B46. DiBemardo, Mike on January 3, 2013
B47. Marks, William and JoJean (#2) on January 3, 2013
B48. Camegis, Elaine and George on January 3, 2013
B49. Grant, Mike and Julie on January 3, 2013
· B50. Rutter, Connie on January 3, 2013
B51. Bonaventura, John on January 3, 2013
B52. Winkler, John on January 3, 2013
B53. Stinson, John on January 3, 2013
B54. Horton, Bruce on January 3, 2013
B55. Stinson, Debbie Sue on January 3, 2013
B56. Magee, Steve on January 3, 2013
B57. Carter, Sasha on January 3, 2013
B58. Lindsey, Janis on January 3, 2013
B59. Eckmier, Stuart on January 3, 2013
B60. Carter, Curtis and Frances on January 3, 2013
B61. Henderson, John on January 3, 2013
B62. Lancaster, Brad on January 3, 2013
B63. Mizuhashi, Masaki on January 3, 2013
B64. Spinelli, Bill on January 3, 2013
B65. Dileva, Ralph (#2) on January 3, 2013
B66. Brandelli, Donna on January 3, 2013
B67. Pearson, Holly on January 3, 2013
B68. Campbell, Eliana on January 3, 2013
Ponte Vista Project
Final Environmental Impact Report
June 2013
II. List of Comm enters
PageII-4
5-27
City of Los Angeles June 2013
B69. Brigden, N.K. on January 3, 2013
B70. Gregory, Connie on January 4, 2013
B71. Fly, Jonathan on January 4, 2013
B72. Kohler, Kim on January 4, 2013
· B73. Arzoumanian, Douglas and Laura on January 4, 2013
B74. Wagoner, Richard on January 4, 2013
B75. Mendoza, Eddie and Christine on January 4, 2013
B76. Bogdanovich, Yvonne on January 4, 2013
B77. Gaines, Jerry on January 4, 2013
B78. Harbor City/Harbor Gateway Chamber of Commerce (Joeann Valle) on January 4, 2013
B79. Wells, Mark on January 4, 2013
B80. Mattingly, Michael (#2) on January 4, 2013
B81. Kinsey, Robert on January 5, 2013
B82. Kaufman, Sheri on January 5, 2013
B83. Bauer, Norma on January 5, 2013
B84. San Pedro Peninsula Homeowners' Coalition (John Miller) on January 5, 2013
B85. Chartrand, Patrick and Barbro on January 5, 2013
B86. Dickson, Donald on January 5, 2013
B87. Hart, Chuck on January 7, 2013
B88. Sumich, Donna on January 5, 2013
B89. Grayson, Ashley on January 5, 2013
B90. Yablonovitz, Jeff on January 5, 2013
B91. Hur, John and Tina on January 5, 2013
Ponte Vista Project
Final Environmental Impact Report
II. List of Commenters
Page II-5
5-28
City of Los Angeles
B92. Litzel, Jim on January 5, 2013
B93. Contreras, Julie on January 5, 2013
B94. Cornell, Glenn on January 2, 2013
B95. Begovich, Mark on January 6, 2013
B96. Harriman, David on January 6, 2013
B97. Noon, Gail on January 6, 2013
B98. Scanlon, Matthew on January 6, 2013
B99. Burger, Jeff on January 6, 2013
BlOO. Siegman, Craig on January 6, 2013
BIOL Carrolle, Victoria and John on January 6, 2013
B102. Siegman, Anne Marie on January 6, 2013
B103. Hulett, Lupe on January 6, 2013
B104. Early, Jane on January 6, 2013
B105. Zuliani, Barbara on January 6, 2013
B106. Fuller Family on January 6, 2013
B107. Brunner, Richard on January 6, 2013
B108. Stockett, Marge on January 6, 2013
B109. Grajeda, Lupe on January 6, 2013
BllO. Dooley, Diane on January 6, 2013
Blll. Lauro, Janet on January 6, 2013
Bl 12. Jones, Helen on January 6, 2013
B 113. Grgas, Marijan on January 6, 2013
Bl 14. Ritzke, Jeanne and Raymond on January 6, 2013
Ponte Vista Project
Final Environmental Impact Report
June 2013
II. List of Commenters
Page//-6
5-29
City of Los Angeles June 2013
B 115. Moore, Cecelia on January 6, 2013
Bl 16. Spinelli, Margaret on January 6, 2013
B 117. Coloma, Deborah on January 6, 2013
Bl 18. Thorsen, Lucie on January 6, 2013
·Bl 19. Pizzini, Helene and Quentin on January 6, 2013
B120. McOsker, Connie on January 6, 2013
B 121. Akins, Patricia on January 7, 2013
B122. Kivett, George on January 7, 2013
B123. Misetich, Anthony (Rancho Palos Verdes City Councilman) on January 6, 2013
B124. Paul, Marcia on January 7, 2013
Bl25. R Neighborhoods RI (Nancy Castiglione) on January 7, 2013
B 126. Nave, Diana on November 10, 2012
B127. Welstead, Jim on January 7, 2013
B128. Marshall, John on January 7, 2013
B129. Herbert, Ruth on January 7, 2013
B130. Mendoza, Irene on January 7, 2013
B131. Mendoza, Ephraim on January 4, 2013
B132. Epperhart, Douglas on January 7, 2013
B133. Cantu, Cathy on January 7, 2013
B134. O'Donnell, Beverly and Jim on January 7, 2013
B135. Yoshimoto, Joy on January 7, 2013
B136. Greene, David on January 7, 2013
B137. Dray, Winnifred on January 7, 2013
Ponte Vista Project
Final Environmental Impact Report
II. List of Commenters
Page IJ-7
5-30
City of Los Angeles June 2013
B 138. Sierra Club, Palos Verdes-South Bay Regional Group (Alfred Sattler) on January 7, 2013
B139. Allman, Scott on January 7, 2013
B140. Verner, Winnie on January 7, 2013
Bl41. Norton, John OIJ. January 7, 2013
· B 142. Sattler, Barbara and Alfred on January 7, 2013
B143. Bradley, Sandra on January 7, 2013 ·
B144. Viramontes, Rachel on January 7, 2013
B145. Rivera, David on January 7, 2013
B146. Houske, M. on January 7, 2013
B147. Dillard, Joyce on January 7, 2013
B148. Shea, Terri on January 7, 2013
B 149. Dominguez, Louis and Suzanne on January 7, 2013
B150. Moen, Kathi on January 7, 2013
B151. Morgan, Brent on January 7, 2013
B152. Holmes, Vivian on January 7, 2013
B153. San Pedro Peninsula Homeowners United, Inc. (Chuck Hart) (#1) on January 5, 2013
B154. Campbell, Brian (Rancho Palos Verdes City Councilman) on January 7, 2013
B155. Terzoli, Paola on January 7, 2013
B156. Schoen, Tim and Sara on January 7, 2013
B157. Abrahams, Dale on January 7, 2013
B158. Pawlak, Bill and Marge on January 8, 2013
B159. San Pedro Peninsula Homeowners United, Inc. (Chuck Hart) (#2) on January 3, 2013
Bl60. Kurata, Yoshiko on December 30, 2012
Ponte Vista Project
Final Environmental Impact Report
II. List of Commenters
Page //-8
5-31
City of Los Angeles June 2013
Bl61. Welsh, Richard on January 6, 2013
Bl62. Khaleeli, Bizhan on January 7, 2013
Bl63. Burchett, Bob on January 6, 2013
Bl64. Harmatz, Mitch on January 7, 2013
B 165. Kumamoto, Kris on January 7, 2013
Bl66. Schaaf-Gunter, Janet on January 5, 2013
Bl67. Rolling Hills Riviera Homeowners' Association (Jeanne Lacombe) on December 30, 2012
B 168. Mah, Evelyn on January 4, 2013
Bl69. Lacombe, Jeanne on December 30, 2012
Bl 70. Cornell, Taylor on January 3, 2013
Bl 71. Maya, John on January 17, 2013
Ponte Vista Project
Final Environmental Impact Report
II. List of Commenters
Page Il-9
5-32
Excerpts from FEIR for Ponte Vista project:
Response to Comments -Topical Responses (Section Ill.A)
5-33
III. RESPONSES TO COMMENTS
A. TOPICAL RESPONSES
During the comment period, the Lead Agency received a number of comments that make common claims
and raise similar environmental issues. The Final EIR responds to all comments that were received
during the comment period. The topical responses below (Topical Responses) provide a response to
common themes presented in the comment letters, and thereby reduce the redundancy of responding to
each common comment individually with the same response. Accordingly, the individual responses to
each comment submitted will occasionally reference back to these Topical Responses.
This Final EIR presents the following Topical Responses:
1. Draft Em Review Period Extension Request
Several comments on the Draft EIR requested an extension of the comment period. In accordance with
the CEQA provisions, cited and discussed below, a 61-day public review period for the Draft EIR began
on November 8, 2012, and ended on January 7, 2013. With respect to the public review period for a Draft
EIR under CEQA, the California Public Resources Code, Section 21091(a) states:
The public review period for a draft environmental impact report may not be less than 30 days. If
the draft environmental impact report is submitted to the State Clearinghouse for review, the
review period shall be at least 45 days, and the lead agency shall provide a sufficient number of
copies of the document to the State Clearinghouse for review and comment by state agencies.
In addition, Section 15105(a) of the State CEQA Guidelines states:
The public review period for a draft EIR shall not be less than 30 days nor should it be longer
than 60 days except under unusual circumstances. When a draft EIR is submitted to the State
Clearinghouse for review by state agencies, the public review period shall not be less than 45
days, unless a shorter period, not less than 30 days, is approved by the State Clearinghouse.
Finally, Section 15203 of the State CEQA Guidelines, addresses "Adequate Time for Review and
Comment" and states:
The Lead Agency shall provide adequate time for other public agencies and members of the
public to review and comment on a draft EIR or Negative Declaration that it has prepared.
It also provides that:
Public agencies may establish time periods for review in their implementing procedures and shall
notifY the public and reviewing agencies of the time for receipt of comments on E!Rs. These time
periods shall be consistent with applicable statutes, the State CEQA Guidelines, and applicable
Clearinghouse review periods.
Ponte Vista Project
Final Environmental Impact Report
III.A. Responses to Comments -Topical Responses
Page III.A-I
5-34
City of Los Angeles June 2013
Just prior to the public review period for the Draft EIR, a Notice of Availability of the Draft EIR was sent
to owners and occupants within a 500-foot radius of the Project Site, as well as interested parties, persons
that attended the scoping meeting for the Project, persons that commented on the Notice of Preparation of
the Draft EIR, and those who requested notification. The Notice of Availability was also published in the
Los Angeles Times and the South Bay Daily Breeze on November 8, 2012. At the beginning of the public
review period, CD copies of the Draft EIR were provided to local neighborhood organizations and
numerous public agencies. As of November 8, 2012, the Draft EIR was also made available for public
review at five local libraries, at the City of Los Angeles Department of City Planning, Council Offices
(both City Hall and the field offices), and the City Clerk's Office. The Draft EIR was also available for
review on the City's website. Copies of the Draft EIR were also submitted to the State Clearinghouse.
Although CEQA allows for extensions to the standard 45-day comment period, CEQA does not require
them, and.they occur at the discretion of the Lead Agency. Because the minimum mandatory 45-day
public comment period would have ended just before the Christmas and New Year's holiday period, the
City extended the comment period by 16 additional days to January 7, 2013 to allow additional time for
public review. As described above, the Draft EIR has been made available for widespread review and has
been easily accessible by the public, including via the Internet. Moreover, the City received 187
comment letters, which indicates that a substantial number of public agencies and members of the public
were able to review and comment on the Draft EIR within the statutory timeframe. The City has also
recently limited review times of other Draft EIRs for significant projects, so the City is acting consistently
with its current policy and practice. Thus, the City, as Lead Agency, has determined that the 61-day
public comment period was consistent with both the letter and intent of CEQA.
In addition, Section I, Introduction/Summary, of the Draft EIR provides a comprehensive summary of the
Draft EIR that includes a description of the Project, a summary of the environmental impacts and
mitigation measures for each environmental issue evaluated within the Draft EIR, and an overview of the
alternatives to the Project that were evaluated. Although the statutory review time for the Draft EIR has
closed, the public will have several opportunities to provide comments regarding the Project during the
upcoming public hearing process. Based on the above, the City of Los Angeles fully complied with the
CEQA statutory time requirements for public review and notification of the Draft EIR for the Project.
Nevertheless, the comments requesting an extension of the comment period are noted and have been
incorporated into the Final EIR for review and consideration by the decision-makers prior to any action
on the Project.
2. Traffic Analysis
Several comments raise concerns regarding the traffic that would be generated by the Project and the
assumptions that were employed in the traffic analysis in Section IV.N (Transportation and Traffic) of the
Draft EIR. This Topical Response responds to many of these comments, while additional responses to
certain comments are contained in the letter-by-letter responses that follow.
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Traffic Study Methodology
The traffic analysis in Section IV.N (Transportation and Traffic) of the Draft EIR is based on the Traffic
Study included as Appendix IV.N-1 to the Draft BIR, which was prepared under the supervision of the
City of Los Angeles Department of Transportation (LADOT), in accordance with LADOT' s adopted
policies, procedures, and standards as outlined in the LADOT Traffic Study Policies and Procedures
Manual. In connection with the preparation of environmental impact reports by the City of Los Angeles,
LADOT is responsible for the identification of potential traffic impacts of the project and recommended
·traffic mitigation measures. The analysis and findings of the Traffic Study contained in the Draft BIR,
including the identification of potentially significant traffic impacts associated with the Project and the
corresponding measures to mitigate the impacts to less than significant levels, were also affirmed in the
LADOT letter dated April 10, 2012 and included as Appendix IV.N-1 to the Draft BIR.
The Traffic Study provides a comprehensive analysis of the potential traffic impacts associated with the
Project. As noted in Section 15151, Standards for Adequacy of an BIR in the CEQA Guidelines:
"An EIR should be prepared with a sufficient degree of analysis to provide decision-
makers with information which enables them to make a decision which intelligently takes
account of environmental consequences. An evaluation of the environmental effects of a
proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed
in the light of what is reasonably feasible. Disagreement among experts does not make
an EIR inadequate, but the EIR should summarize the main points of disagreement
among the experts. The courts have looked not for perfection but for adequacy,
completeness, and a good faith effort at full disclosure. "
Study Intersections
The Traffic Study uses several methods of evaluating potential traffic and transportation impacts in
accordance with LADOT's Policies and Procedures Manual. The principal method is to evaluate traffic
impacts based on a review of intersection performance. LADOT' s methodology focuses on intersections
because they are the points in the City's street network where congestion is most likely to occur and,
therefore, are where the additional traffic generated by the project would have its greatest potential to
cause adverse effects.
Following consultation with LADOT, and based on input received during the public scoping process, 56
area intersections were designated for study (Draft BIR, pp. IV.N-2 to IV.N-4). The study intersections
cover a wide geographic region and include intersections located in the City of Los Angeles, the City of
Rancho Palos Verdes, the City of Lomita and other nearby communities. A map of the study
intersections is included as Figure IV.N-1 on page IV.N-5 of the Draft BIR.
Each of the 56 study intersections was examined using the traffic analysis procedures and significant
impact thresholds adopted by the City of Los Angeles. In addition, although not required by LADOT
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policy or CEQA, for those intersections located outside the City of Los Angeles, the Traffic Study
supplements the City's analysis with analysis based on the procedures and methods used by the city in
which the intersection is located. For example, intersections in the City of Rancho Palos Verdes were
examined using the traffic impact analysis methods of both the City of Los Angeles and Rancho Palos
Verdes.
Traffic Counts
Jn the traffic engineering practice, intersections are evaluated over a peak one-hour period of traffic
volume. Typically, these peak periods of traffic occur during the weekday morning and/or afternoon
commuter periods, and also correspond with times of the year when schools are in session. Observational
data collected by the Institute of Transportation Engineers (ITE) for residential uses indicate that the
Project wil.l likely generate its highest amount of traffic onto the local street system during these weekday
morning and afternoon peak hours. Also, data collected to establish baseline conditions shows that
existing traffic experiences weekday morning and afternoon peak periods. Thus, the highest periods of
traffic generation by the Project, in combination with peak levels of background traffic on the local street
system, results in the weekday morning and afternoon peak hours as the time periods with the greatest
potential for significant Project-level and cumulative traffic impacts of the Project to occur. Therefore,
these weekday peak periods are appropriately analyzed in the Traffic Study.
To identify the morning and evening "peak" hour for each intersection, traffic counts were taken at the 56
study intersections during the weekday morning and afternoon commuter peak hours (7:00 to 10:00 AM
and 3:00 to 6:00 PM). Also, based on feedback from local community groups, additional traffic counts
were conducted during the 2:00-3:00 PM hour at the 12 study intersections located near schools to
determine if the peak hour may occur earlier in the day as a result of student departure activities. Finally,
additional counts were taken at intersections along Western A venue during a Saturday midday peak
period (11:00 AM to 2:00 PM). The peak one-hour period (e.g., 7:30-8:30 AM) was determined for each
study intersection for weekday AM and PM periods, as well as Saturday midday. Traffic counts were
generally conducted in September and October 2010 while local schools were in session.
Section 15125 of the CEQA Guidelines states, in relevant part:
"An EIR must include a description of the physical environmental conditions in the
vicinity of the project, as they exist at the time the notice of preparation is published, or if
no notice of preparation is published, at the time environmental analysis is commenced,
from both a local and regfonal perspective. This environmental setting will normally
constitute the baseline physical conditions by which a lead agency determines whether an
impact is significant. "
CEQA Guidelines Section 15126.2 also provides that:
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"An EIR shall identifo and focus on the significant environmental effects of the proposed
project. In assessing the impact of a proposed project on the environment, the lead
agency should normally limit its examination to changes in the existing physical
conditions in the affected area as they exist at the time the notice of preparation is
published, or where no notice of preparation is published, at the time environmental
analysis is commenced. "
The notice of preparation for the Project was published in October 2010 and the traffic counts for the
. Traffic Study occurred primarily in September and October 2010 (depending upon the individual
intersection). Thus, the traffic count data was collected for the appropriate baseline period in accordance
with CEQA's Guidelines.
Modifications of Existing Conditions
Some comments have asserted that the traffic counts used in the Traffic Study were conducted during a
period of relatively reduced levels of economic activity (locally and regionally), speculatively concluding
that this resulted in lower traffic volumes that are not representative of "normal" conditions. The
comments suggest that the traffic counts should be adjusted or redone. Such changes to the traffic count
data, or new traffic counts, are not required or advisable based on the following:
• Modifying the existing traffic counts would conflict with Section 15125(a) of the CEQA
Guidelines, which require that the effects of the Project be measured against conditions as they
exist at the time the Notice of Preparation is published. Modifying the traffic counts or
conducting new counts would represent a potential misrepresentation of the existing environment
at the time the Notice of Preparation was published in October 2010.
• Hypothetically, if an adjustment were to be made to the 2010 traffic counts, it would be highly
speculative to define a "normal" condition. It is possible, for example, that the traffic data
collected in 2010 reflect a new "normal" condition, and that traffic conditions in the immediate
years prior were atypical.
• The traffic study utilizes a highly conservative method to forecast future pre-Project traffic
volumes at the study intersections. The method uses both an annual ambient traffic growth
factor, plus estimates of traffic potentially attributable to cumulative development projects, and
likely results in a substantial overstatement of future traffic volumes at the study intersections.
As the traffic study analyzes Project-related impacts against both the 2010 baseline and the
derived future background condition, any perceived "abnormalities" in the 2010 traffic baseline
are addressed through the use of the highly conservative future pre-Project forecast.
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Trip Generation Rate
The Traffic Study's forecast of Project traffic is based on rates recommended in the Trip Generation
manual published by the Institute of Transportation Engineers (ITE). The ITE developed these trip rates
based on traffic counts conducted at existing development sites throughout the country (e.g., existing
condominium complexes, existing apartment complexes, etc.). ITE reviews the information submitted
and determines the appropriate land use category to assign the data.
As noted in Table IV.J-10 in the Draft BIR, the following ITE trip generation rates were employed in the
Traffic Study: ITE Land Use Code 210 (Single-Family Detached Housing) for the detached housing units,
ITE Land Use Code 230 (Residential Condominium/Townhouse) for the for sale attached housing units,
ITE Land Use Code 220 (Apartments) for the rental units, and ITE Land Use Code 412 (County Park) for
the public .park component. As explained below, the trip generation rates provide an appropriate and
conservative forecast of the trips to be generated by the Project.
The ITE trip rates are derived from actual studies of existing developments within the land use category.
Additionally, ITE requires data submissions of sites to be freestanding in nature. That is, as stated on
page 17 in the ITE's Trip Generation Handbook, the sites evaluated for potential inclusion in the Trip
Generation manual should have limited access to public transit services, as well as walk-in trips from
adjacent parcels. The data received by ITE are plotted and summarized in the Trip Generation manual by
both a weighted average and a fitted curve regression equation. The purpose of the fitted curve regression
equation is to capture the trip generation characteristic of most land uses such that as the size of the
development increases, the effective trip rate declines (e.g., a 500,000 square foot office building
generates fewer trips per square foot as compared to a 50,000 square foot office building). For the Traffic
Study, the weighted average trip rates were conservatively utilized for forecasting trips to be generated by
the Project's residential components even though use of the regression equation would have resulted in an
estimate of fewer trips generated by the Project.
Chapter 3 of the Trip Generation Handbook, Second Edition provides guidance in regards to the selection
of the appropriate methodology for estimating trip generation for a particular land use. The order of
preferred methodology is provided on page 9 of the Trip Generation Handbook and is listed below:
• Use the provided regression equation when provided for the land use if the independent variable
(in the case of the Project, the number ofresidential units) is within the range of data, and the data
plot has at least 20 points (or R-squared value is greater than or equal to 0.75).
• Use the weighted average rate if no regression equation is provided and there are at least three
data points and the independent variable is within the range of data.
• Collect local data if the conditions above are not satisfied.
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Review of the ITE Trip Generation manual for the three land use categories consulted in preparing the
Project trip generation forecast-Single-Family Detached Housing (ITE Land Use Code 210), Apartment
(ITE Land Use Code 220) and Residential Condominium/Townhouse (ITE Land Use Code 230) --
indicates that all criteria for using the regression equation apply. That is, regression equations are
provided, the independent variable is within the range of the data set, and there are at least 20 data points.
However, the Traffic Study conservatively utilizes the weighted average rate instead of the regression
equation provided in the Trip Generation manual. Had the regression equations provided in the Trip
Generation manual been utilized, the resulting calculation of trip generation associated with the Project
would have been lower than the forecast provided in the Traffic Study. For example, using the regression
equations, the forecast number of daily trips generated by the residential component of the Project would
be 7,015, as compared to the forecast of 7,462 daily trips provided in the Traffic Study. Thus, the
methodology used in the Traffic Study is highly conservative. Contrary to some comments on the Draft
EIR, ITE does not recommend the use of the "higher end" of the midpoint (or weighted average).
Some comments argue that an individual residential unit must generate higher daily trips. However, the
ITE data represents an aggregation of the overall vehicular trip generation characteristics occurring at a
residential development. The ITE rates are not intended to estimate trip generation on a unit-by-unit
basis. Thus, on any given day the trip generation characteristics vary considerably among different
households. For example, one household may be a working couple with school-aged children. Another
household may be an individual that works from home. One household may conduct its errands on the
way to and from work. Another household may make separate trips. The ITE rates aggregate all of these,
and other, behaviors. Similarly, on a peak hour basis, the trip generation characteristics will vary widely
between units. For example, one neighbor may arrive home from work at 4:00 PM, a second neighbor
may arrive home from work at 5:30 PM, while a third neighbor may arrive home from work at 7:00 PM.
While each of these neighbors believes that they are driving home in "rush hour" traffic, in fact only one
of the three neighbors is part of the actual peak hour of traffic evaluated in the Traffic Study. Thus, by
evaluating traffic impacts for the one-hour period of highest traffic at the study intersections (e.g., for the
5:30 PM commuter), the corresponding traffic impacts and mitigation (if required) are sufficiently
evaluated in the Traffic Study for the periods of slightly less traffic (e.g., for the 4:00 PM and 7:00 PM
commuters). Each of these variations in daily and peak hour trip generation behavior is accounted for in
the ITE trip rates for the overall residential development. More importantly, the ITE trip rates are based
on empirical data obtained through actual traffic counts, and not theory or speculation.
Although the Project Site is directly served by a number of bus lines (see Table IV.N-8, Existing Transit
Routes in Project Vicinity, and Figure IV.N-6, Existing Transit Routes in the Draft EIR) and commercial,
educational, and recreational uses are located within walking distances of the Project, in order to provide
a conservative assessment of the potential traffic impacts associated with the Project, no reductions or
discounts were made to the Traffic Study's Project trip generation forecast (which is based on the ITE trip
rates assuming nearly all trips by private vehicle) to provide credit for these public transit or walking trips
that are likely to replace some trips that would otherwise be made by a private vehicle.
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It has been suggested that "local data" should be collected related to the trip generation characteristics of
other residential developments. However, collection of additional data is not necessary due to the
extremely high statistical correlation of the data in ITE Land Use Codes 210, 220 and 230. This high
statistical correlation suggests that any additional data points would fall within close proximity to the
best-fit line.
In summary, sufficient data points are readily available in the Trip Generation manual to conclude that
the weighted average trip rates provide an adequately conservative forecast of trips associated with the
Project. Further, based on the high correlation of data collected, it is reasonable to conclude that
additional data points would not yield any meaningfully new information regarding the trip generation
characteristics of residential projects.
Project Trip Assignment
The peak hour trips forecast to be generated by the Project were assigned to the 56 study intersections in
conjunction with the assessment of potential impacts at each location. The relative percentage of Project-
related trips by turning movement at each study intersection is provided in the Draft EIR on Figure IV.N-
8. As described in the Traffic Study, the assignment is estimated based on the anticipated origins and
destinations of Project-related trips, and therefore the corresponding routes (streets and intersections) used
in traveling to and from the site. The distribution pattern reflected on Figure IV.N-8 was developed, in
part, based on a review of existing travel patterns at the study intersections.
In review of Figure IV.N-8, it is noted that a relatively higher percentage of Project-related trips are
forecast to travel to and from the site via Western A venue north of the site as compared to the segment of
Western Avenue south of the site. Specifically, as measured at the Western Avenue/Green Hills Drive
and Western Avenue/Avenida Aprenda intersections (i.e., the two vehicular access points proposed to
serve the Project Site), approximately 67% of Project-related trips are forecast to arrive at the site via
southbound Western Avenue and 72% of Project-related trips are forecast to depart the site via
northbound Western A venue.
The relatively higher percentage of forecast Project-related turning movement percentages arriving and
departing via Western A venue north of the site was forecast based on the generally greater number of
employment centers located north of the Project Site. In addition, the relative assignment of Project-
related trips at the site access points was made, in part, based on a review of existing turning movement
volumes at the Western A venue/Peninsula Verde Drive and Western A venue/Fitness Drive intersections,
which are immediately north and south of the Project Site, respectively. These intersections are similar to
the Project and its proposed access points because the existing residential units served by these streets
only have vehicular access to Western Avenue. Thus, the relative geographic distribution (i.e., trips using
Western A venue north and south of these intersections) should be reasonably similar to the travel patterns
seen at the Project Site following construction and occupancy of the proposed residential units. The
existing turning movement volumes at the Western A venue/Peninsula Verde Drive and Western
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A venue/Fitness Drive intersections are shown on Figure IV.N-3 for the AM peak hour, and Figure IV.N-4
for the PM peak hour.
Note that Figure IV.N-3 in the Draft EIR is incorrect and is being replaced in the Final EIR by the correct
graphic, which was included in Appendix IV.N-1 to the Draft EIR as Figure 5-1 (see Section IV,
Corrections and Additions to the Draft EIR). However, this revision does not change the conclusions of
the Draft EIR.
Table III-1 below provides a summary of the turning movement volumes using Western A venue north of
the Peninsula Verde Drive and Fitness Drive intersections. As noted in the Project trip generation
forecast provided in Table IV.N-10 of the Draft EIR, the majority of Project-related trips will be outbound
during the AM peak hour (e.g., motorists leaving their homes and driving to work) and inbound during
the PM peak hour. (e.g., motorists returning home after work). Thus, the data in the table below focus to
outbound trlps leaving Peninsula Verde Drive and Fitness Drive via northbound Western Avenue during
the AM peak hour, as well as inbound trips entering Peninsula Verde Drive and Fitness Drive via
southbound Western Avenue during the PM peak hour.
Tableill-1
Existing Turning Movement Volumes
Western A venue at Peninsula Verde Drive and Fitness Drive
As shown in Table III-1, approximately 75% of outbound trips leaving Peninsula Verde Drive and Fitness
Drive travel northbound on Western Avenue during the AM peak hour (i.e., as compared to 72% used in
the Traffic Study) and 63% of inbound trips arriving at Peninsula Verde Drive and Fitness Drive travel
southbound on Western Avenue during the PM peak hour (i.e., as compared to 67% used in the Traffic
Study). While traffic volumes (and turning movements) vary on a day-to-day basis, the data presented
above indicates that the trip distribution percentages assigned in the Traffic Study represent a reasonable
expectation of the relative proportion of Project-related trips using Western Avenue north of the Project
site.
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Future Pre-Project Conditions
At the time the Project is completed and occupied, additional traffic may be added to the street network
from sources such as other projects and job growth. To account for this possibility, in addition to an
analysis of traffic impacts on the baseline established by the NOP, the Traffic Study also estimates future
pre-project traffic conditions in accordance with LADOT policies and procedures to provide a future
baseline against which the Project's traffic impacts can be assessed. The Traffic Study uses 2017, the
year the Project is expected to be built out, as the future baseline date.
To forecast year 2017 pre-Project conditions, the Traffic Study utilizes two separate, though overlapping,
techniques in accordance with LADOT practices and policy. First, the Traffic Study assumes that traffic
will grow by a factor of 1 % each year until 2017 when the Project is completed. The use of the 1 %
annual gr~wth factor is highly conservative when compared to the computer traffic modeling efforts
prepared by Metro for sub-regions of Los Angeles County, including the South Bay/Harbor area, which
forecasts an equivalent annual traffic growth rate of only 0.335%. As discussed in the Draft EIR at page
IV.N-87, while the 1 % factor is intended to account for all reasonably foreseeable traffic growth, in
addition to the 1 % annual growth factor, the Traffic Study also assumes the build-out of all identified
cumulative development projects proposed in the City of Los Angeles and in other nearby communities in
the vicinity of the Ponte Vista site. As a result of the scoping process conducted at the time the NOP was
circulated for the Project in the fall of 2010, 154 cumulative projects were considered in the Traffic Study
(see Table III-2 in the Draft EIR for a list of these cumulative projects).
Various comments identify individual projects that the comments assert were not, or in fact were not,
included as cumulative projects in the Draft EIR. As discussed in Section III.C of the Draft EIR (at page
III-22), the CEQA Guidelines indicate that lead agencies may use two alternative means of identifying the
universe of past, present, and probable future projects in assessing the significance of cumulative impacts:
• A list of past, present, and probable future projects producing related or cumulative impacts,
including, if necessary, those projects outside the control of the agency; or
• A summary of projections contained in an adopted general plan or related planning
document, or in a prior environmental document which has been adopted or certified, which
described or evaluated regional or area wide conditions contributing to the cumulative
impact.
Because projects are constantly being proposed, abandoned, and modified, CEQA also encm.ll'ages the use
of a cut-off date for identifying cumulative projects for analysis in a Draft EIR. CEQA Guidelines
§15126.2 states that "[i]n assessing the impact of a proposed project on the environment, the Lead
Agency should normally limit its examination to changes in the existing physical conditions in the
affected area as they exist at the time the notice of preparation [NOP] is published[.]" (see also San
Franciscans for Reasonable Growth v. City and County of San Francisco, 151 Cal. App. 3d 61, 75 n.14
(Cal. Ct. App. 1984) ["Projects are constantly being fed into the environmental review process. The
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problem of where to draw the line on 'projects under review' that must be included in the cumulative
impact analysis of a particular project could be solved by the use of a reasonable cutoff date which could
be set for every project according to a standard procedure."]).
In accordance with the CEQA Guidelines, the Draft EIR identified cumulative projects that were probable
and foreseeable, using the Project's NOP as a cut-off. The NOP for the Project was circulated between
October 26, 2010 and November 29, 2010 .
. To obtain a list of cumulative projects, the preparers of the Draft EIR compiled information publicly
available from the City of Los Angeles Departments of Planning and Transportation, City of Rancho
Palos Verdes, City of Rolling Hills Estates, City of Carson, City of Long Beach, City of Torrance, City of
Lomita, and the County of Los Angeles. Cumulative projects were also identified through public
comments. received during the NOP and scoping process for the Draft EIR. All projects identified
through this manner were included in Table III-2 of the Draft EIR, except where specifically noted and
discussed in the Draft EIR. Thus, the Draft EIR presented a comprehensive list of cumulative
development projects at the time of the NOP based on the best information from responsible jurisdictions.
With respect to potential traffic, as well as air quality and noise effects, the analysis of the Draft EIR went
beyond the minimum requirements of Section 15130 of the CEQA Guidelines to prepare a highly
conservative cumulative impact scenario, as discussed in the Draft EIR at page IV.N-87. Specifically, to
forecast future pre-Project conditions, the Draft EIR assumed that traffic will grow by a factor of 1 % each
year until 2017 when the Project is completed. In addition, although the 1 % annual growth factor is
intended to account for all traffic growth from development and other sources, the Draft EIR also
assumed the build-out of all identified cumulative development projects proposed in Los Angeles and
other nearby communities. Thus, the Draft EIR's cumulative traffic, air quality, and noise analyses
conservatively characterize future pre-Project conditions, against which the Project's potential impacts are
assessed.
Individual responses addressing each project newly identified during the Draft EIR comment period are
provided in individual responses to comments. Some projects that commenters asserted were overlooked
were verified to have been included in the Draft EIR. Others were proposed or modified after the NOP
period cut-off date. A small number of projects had been proposed at the time of the NOP period cut-off
date, but the agencies having jurisdiction failed to identify them to the EIR preparers or in comments
during the NOP scoping period. These particular projects are not large and would not affect the results of
the analysis. One of the reasons for using the conservative growth factor discussed above is to capture the
growth in traffic from projects such as these in the overall analysis.
Finally, in accordance with LADOT practice and policy, the Traffic Study assumes that the cumulative
projects will not be accompanied by any traffic mitigation measures. In actuality, however, most major
projects are accompanied by traffic mitigation because of the requirements of CEQA and City CEQA
traffic impact significance thresholds. The intention of this methodology is to provide a conservative
scenario against which to assess potential traffic impacts and identify mitigation measures. As discussed
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in the Traffic Study and Draft BIR, this methodology is likely to significantly overstate future traffic
conditions in the vicinity of the Project, and provides a highly conservative basis for analyzing Project
traffic impacts.
After carefully reviewing the comments received, the City concludes that the cumulative projects list and
cumulative impact approach utilized in the Draft BIR is adequate for CBQA purposes. As discussed
earlier, the traffic, air quality, and noise cumulative analyses of the Draft BIR were prepared so as to
provide a highly conservative analysis of the potential cumulative effects of the Project and cumulative
projects. CBQA does not require that every potential cumulative project be considered in an BIR if
consideration is also given to planned or expected growth in an area. As noted in Section 15151,
Standards for Adequacy of an BIR, in the CBQA Guidelines:
"A_n EJR should be prepared with a sufficient degree of analysis to provide decision-
makers with information which enables them to make a decision which intelligently takes
account of environmental consequences. An evaluation of the environmental effects of a
proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed
in the light of what is reasonably feasible. Disagreement among experts does not make
an EIR inadequate, but the EIR should summarize the main points of disagreement
among the experts. The courts have looked not for perfection but for adequacy,
completeness, and a good faith effort at full disclosure. "
Traffic Mitigation
The Traffic Study outlines recommended measures to mitigate the potentially significant traffic impacts
associated with the Project at 20 affected intersections to less than significant levels. The LADOT letter
of April 10, 2012, included in Appendix IV.N-1 to the Draft BIR, affirms the findings of the Traffic Study
relative to the potentially significant traffic impacts and corresponding mitigation measures. At several
intersections, the Project's traffic mitigation measures will result in an improvement over existing
conditions with respect to intersection performance.
As discussed in the Draft BIR at page IV.N-160, the Project will be constructed in stages to account for
market absorption. Therefore, as the build-out of the Project is anticipated to occur over an approximate
five-year period, Project traffic mitigation will also be sequenced such that the improvements would be
constructed prior to the occurrence of a potential traffic impact due to a particular level of Project
occupancy. All measures involving improvement to the area roadway network must be funded and
completed prior to overall Project completion and occupancy.
LADOT Bike Lane Installation
Subsequent to the conclusion of the Draft BIR public review period, LADOT, acting to implement
portions of the Los Angeles Bicycle Plan, installed bike lanes on Westmont Drive and Capitol Drive in the
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San Pedro area. Concerns have been raised with the City with respect to the potential for these new bike
lanes to affect the data, analysis, and findings contained in Project Traffic Study.
In April 2013, bike lanes were installed by LADOT on the segments of Westmont Drive and Capitol
Drive between Western Avenue on the west and Gaffey Street to the east. Generally, the bike lanes were
created through the removal of one through travel lane in each direction of Westmont Drive and Capitol
Drive (i.e., reducing the number of through travel lanes in each direction from two to one). These
improvements were previously identified for Westmont Drive and Capitol Drive in the City's 2010
Bicycle Plan.1 LADOT reviewed the project to install bike lant;s on Westmont Drive and Capitol Drive
and determined that implementation of the bike lanes would not adversely affect vehicular, bicycle or
pedestrian traffic flow.
The following intersections along Westmont Drive and Capitol Drive were evaluated in the Project
Traffic Study:
• No. 20: Western Avenue/Westmont Drive
• No. 23: Western Avenue/Capitol Drive
• No. 37: Gaffey Street/Westmont Drive
• No. 38: Gaffey Street/Capitol Drive
The existing lane configurations at these study intersections are provided in the Traffic Study on Figure 4-
1 and in the Draft BIR on Figure IV.N-2. A recent field review of these intersections confirmed that the
current lane configurations have not been altered as a result of the bike lane implementation project.
Thus, the intersection Level of Service (LOS) calculations provided in the Draft EIR for the study
intersections along Westmont Drive and Capitol Drive do not require revision as a result of the bike lane
project.
The Project Traffic Study recommended mitigation measures that will result in minor changes to travel
lane configurations at three of the four intersections listed above. The future lane configurations are
generally shown on Figure 13-1 of the Traffic Study and Figure IV .N-31 of the Draft BIR. It has been
determined that the recommended mitigation measures at the study intersections along Westmont Drive
and Capitol Drive can be implemented even with consideration of the recent bike lane installations. Thus,
no changes to the mitigation measures recommended in the Traffic Study and Draft BIR are required as a
result of the bike lane project.
2010 Bicycle Plan, City of Los Angeles, Adopted March 1, 2011.
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City of Los Angeles June 2013
It has been reported anecdotally (e.g., in local newspaper articles) that the installation of the bike lanes on
Westmont Drive and Capitol Drive has slowed the movement of vehicular traffic, primarily due to the
removal of one of the travel lanes in each direction. While this may be correct, this change does not
affect the data, analysis, and findings of the Project Traffic Study for the following reasons:
• While the movement of vehicular traffic may have slowed on Westmont Drive and Capitol Drive
due to the removal of through travel lanes, motorists still have the potential to experience, on a
relative basis, greater delay at the signalized intersections at Western A venue and Gaffey Street.
It is for this reason that the Traffic Study evaluates the potential traffic impacts of the Project at
signalized intersections, and not on the mid-block street segments connecting these intersections.
Therefore, it is appropriate that the Traffic Study evaluates the relative effects of traffic generated
by the Project on Westmont Drive and Capitol Drive based on its relative impacts at the
signalized intersections at Western A venue and Gaffey Street.
• There is no reason to suspect that traffic volumes using Westmont Drive and Capitol Drive have
changed substantially since the implementation of the bike lanes as there are no direct alternative
east-west travel routes in the vicinity connecting Western Avenue and Gaffey Street. Thus, the
intersection traffic volume data utilized in the Project Traffic Study remain valid.
• Within the Traffic Study, a relatively nominal amount of Project-related traffic is assigned to the
segment of Westmont Drive between Western Avenue and Gaffey Street (i.e., 11 percent of
Project-related traffic was assumed to use this segment of Westmont Drive). No Project-related
traffic was assumed to use the segment of Capitol Drive between Western Avenue and Gaffey
Street.
In summary, based on a review of the recent installation of bike lanes on Westmont Drive and Capitol
Drive, it is concluded that these bike lanes do not affect the data, analysis and findings presented in the
Project Traffic Study and Draft BIR.
3. Impacts of the Environment on the Proposed Project
CBQA does not require and is not intended to require an BIR to analyze or mitigate the impacts of the
existing environment on a project. In this case, for example, the level of risk presented by nearby
industrial facilities (e.g., the Navy Defense Fuel Support Point, ConocoPhillips refinery, and Rancho LPG
facility) as a result of toxic air contaminant emissions and potential fire/spill hazards, represents an
existing environmental condition that the Proposed Project would not alter or worsen. Although the
Project would bring additional people near this existing environmental condition, the existing level of risk
presented by industrial facilities in the Project vicinity is not an impact of the Project on the environment,
and the Project would not affect the emissions from these facilities in any way. Instead, it is considered
an impact of the environment, that is, the conditions that currently exist as a result of emissions from
existing facilities, on the Project. ~ere are many other state and federal laws that regulate toxic air
emissions as well as the operation of potentially hazardous industrial facilities, but the purpose of CEQA
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City of Los Angeles June 2013
is to evaluate and mitigate impacts of a project on the environment. As numerous courts have affirmed,
the purpose of CEQA is "not to protect proposed projects from the existing environment" (Baird v.
County of Contra Costa (1995) 32 Cal.App.4th 1464; Pub. Res. Code Sections 21061, 21083(b), and
21060.5.) "[C]ourts have recognized that CEQA is not a weapon to be deployed against all possible
development ills." (South Orange County Wastewater Authority v. City of Dana Point (2011) 196 Cal.
App. 4th 1604, 1614.) It has a limited role. "The Legislature did not enact CEQA to protect people from
the environment." (Id. at 1617-1618.) "We agree with [SOCWA v. County of Orange], that the
Guidelines [15126.2]. .. is not an example of an environmental effect caused by development, but instead
is an example of an effect on the project caused by the environment. Contrary to Guidelines section
15126.2, subdivision (a), we hold that an EIR need not identify or analyze such effects .... Although the
Guidelines ordinarily are entitled to great weight, a Guidelines provision that is unauthorized under
CEQA is invalid." (Ballona Wetlands Land Trust v. City of Los Angeles (2011) 201 Cal.App.4th 455,
474.)]
The Draft EIR, in order to fully disclose existing environmental conditions in the vicinity of the Project
Site, evaluated, in a reasonable amount of detail, the level of risk that could be posed to future Project
residents from the continued, unchanged operation of three nearby industrial facilities as well as the Ports
of Los Angeles and Long Beach. However, CEQA does not obligate EIRs to include such analyses, as
the characteristics they consider do not represent impacts of the Project on the environment. Many of the
comments received on the Draft EIR, as well, address the effect on the Project that would or could be
caused by the existing environment, including comment Letters A-11 from the U.S. Navy and A-13 from
the Defense Logistics Agency pertaining to the DFSP facility. Although complete responses to the
comments in these letters are provided in this Final EIR, many of these comments do not raise CEQA
issues. Avoidance of spills and fires at the nearby industrial facilities, as well as compliance with
applicable laws and regulations governing toxic air emissions, is a responsibility of the owners/operators
of each facility, not the Project Applicant.
4. Rancho LPG Holdings
Several comments have raised concerns regarding the Rancho LPG Holdings storage facility, located
approximately 0.7 mile to the east of the Project Site, adjacent to Gaffey Street. There has been a
substantial amount of debate within the San Pedro/Harbor City/Rancho Palos Verdes community over the
past several years concerning the Rancho LPG facility with respect to the risk it may represent as a result
of product releases and/or catastrophic explosions and fires. This debate has occurred independently of
any discussion concerning the Proposed Project at the Ponte Vista site. Generally, the comments
pertaining to Rancho LPG that were submitted on the Draft EIR for the Ponte Vista Project have
addressed two principal issues: (1) the potential risk presented to future Project residents by the Rancho
LPG facility and (2) general concerns about the Rancho LPG facility, including the inadequacy of Rancho
LPG's Risk Management Plan (RMP) and on-site safety apparatus (and, by extension, the inadequacy of
the Draft EIR's analysis of the risk posed by the Rancho LPG facility to future Project residents given its
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City of Los Angeles June 2013
reliance upon the RMP). This topical response will address each of these issues and will provide a recent
history of the community debate over the Rancho LPG facility as it relates to the Ponte Vista Project.
As discussed above in Topical Response 3, CEQA does not require that impacts of existing development
upon a proposed project be considered in an EIR. This point is germane to this discussion because the
Rancho LPG storage facility has been in existence since the early 1970s and is located across the street
from existing residences that are themselves closer to the Rancho LPG facility than the proposed Ponte
Vista Project would be. The Project would not have any direct impact upon the Rancho LPG facility and
. would not result in the alteration of its operation. Indirect impacts of the Proposed Project that may affect
the Rancho LPG facility are limited to traffic on the roadways adjacent to the Rancho LPG facility. The
Project's traffic impacts are described in Section IV.N (Transportation and Traffic) of the Draft EIR,
which presents mitigation measures that would reduce each of the Project's significant impacts with
respect to ~affic to a less than significant level.
The Project would, however, place new residents within 0.7 to one mile of the storage tanks and
containment basin at the Rancho LPG facility. Under the Applicant's preferred development plan for the
Ponte Vista site (evaluated as Alternative C in the Draft EIR), an estimated 2,222 persons would
eventually reside at the Project Site upon Project completion and full occupancy. It should be noted that
the Project Site has previously been utilized for residential purposes and that previous residents at the site
were also exposed to the same level of risk presented by the Rancho LPG facility as future Project
residents would be.
Although CEQA does not require that an EIR consider the impact of the existing environment on a
project, the Draft EIR did include an analysis of these types of issues in the interest of informing the
public as well as providing a context for the discussion of land use compatibility. Specific to the Rancho
LPG facility, Section IV.H (Hazards and Hazardous Materials) of the Draft EIR presents an analysis of
the potential for toxic air contaminants emitted from the facility to present a significant cancer risk at the
Project Site (see Draft EIR at page IV.H-25) as well as an analysis of the potential for the facility to
present a significant risk of injury and/or property damage to the Project as a result from accidental
releases of hazardous materials (including fires and explosions; see Draft EIR at page IV.H-36). This
topical response addresses the second of these two analyses -that of an accidental release from the
Rancho LPG facility -as it is the topic of the majority of comments received on the Draft EIR in relation
to Rancho LPG. Comments specific to the issue of the health risk presented by toxic air emissions from
Rancho LPG are addressed individually (see Section III.B of this Final EIR).
Risk of Upset Analysis
The Draft EIR's analysis of the risk of accidental hazardous material releases (generically referred to as
"risk of upset") from the Rancho LPG facility states the following (from page IV.H-36 of the Draft EIR):
According to the RMP filed with City of Los Angeles Fire Department, the Rancho LPG
(formerly Amerigas) facility may store up to 120 million pounds of butane and 640
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City of Los Angeles June 2013
thousand pounds of propane.2 Under the RMP's offsite consequence analysis, a worst-
case release of butane would spill into an on-site containment pit and could result in a
vapor cloud explosion with an impact zone of 0.5 miles. A more likely alternative
scenario for release of propane identified by the facility could result in a vapor cloud fire
with an impact zone of 0.1 miles. There would be some quantifiable risk of upset from
other activities such as product delivery by rail or truck. However, any such event would
likely result in much smaller release amounts with a lower likelihood of vapor cloud
explosion than quantified in the RMP, and thus, a much lower radius of impact than
described in the RMP. Based on the worst-case RMP scenario and with the more likely
releases having a much smaller radius impact than 0.5 miles, there would be no impact to
the Project Site.
Multiple c~mmenters on the Draft EIR have taken issue with this analysis due to its reliance upon the
contents, assumptions, and methodology of the RMP for the Rancho LPG facility. Although some of
these issues are addressed through the individual responses in Section III.B, a general explanation of the
adequacy of the approach used for the Draft EIR is appropriate here as well.
Industrial facilities such as Rancho LPG are required to prepare Risk Management Plans (RMPs) that
address potential hazards resulting from their operations and how they will be minimized or managed.
RMPs are required by the federal Accidental Release Prevention Program (Title 40, Code of Federal
Regulations, Part 68), which implements Section 112 (r)(7) of the Clean Air Act Amendments of 1990.
California has similar requirements that are codified in the California Health and Safety Code (H&SC),
Division 20, Chapter 6.95, Article 2 (commencing with Section 25531). The California program is
known as the California Accidental Release Prevention (CalARP). The goal of the RMP, as required by
the federal and CalARP programs, is to prevent accidental releases of substances that can cause serious
harm to the public and the environment from short-term exposures and to mitigate the severity of releases
that do occur.
Both the federal and CalARP programs require that facilities subject to the programs conduct an offsite
consequence analysis (OCA) to provide information to the government and the public about the potential
consequences of an accidental chemical release. Per 40 CFR, Part 68, §68.22-33 (federal program) and
29 CCR, Title 19, §2750 (California program), the OCA is required to consist of two elements:
2
1. Worst-Case Release Scenario -release of the largest quantity of a regulated substance from a
single vessel or process line failure that results in the greatest distance to an endpoint.
Rancho LPG Holdings Risk Management Program filed with City of Los Angeles Fire Department, February 6,
2009.
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City of Los Angeles June 2013
2. Alternative Release Scenario -release that is more likely to occur than the worst-case scenario
and that reaches an endpoint off-site. This is considered to be the more reasonably foreseeable
scenario.
The distance to the endpoint is the distance the flammable gas will travel before dissipating to the point
that risk of combustion will no longer occur.
The scenarios are developed using a Process Hazards Analysis. A Process Hazard Analysis (PHA) is
.done as part of the RMP process and is codified in 40 CFR, Part 68, Section 68.67 and in 29 CCR, Title
19, Section 2760.2. The PHA focuses on equipment, instrumentation, utilities, human actions (routine
and non routine), and external factors that might impact the process. These considerations assist in
determining the hazards and potential failure points or failure modes in a process. The chief objective of
the PHA P!ocess is to provide a safety review of engineering design efforts. PHA information is usually
proprietary and updates are required at least once every five years or whenever there is a major change in
the process.
The main components of a typical PHA process identify the following:
• Hazards associated with the process and regulated substances
• Opportunities for equipment malfunction or human error that could result in a release
• External events that could impact the process and result in a release
• Safeguards that will control the hazards or prevent the malfunction or error
• Steps to detect or monitor releases
• All process safety information and ensure that it is up-to-date
The Rancho LPG facility stores butane and propane gases and is required to prepare and maintain RMP
documents. The RMP documents developed by Rancho LPG evaluated flammables, which include both
butane and propane. The Rancho LPG RMP was most recently updated in February 2011, although the
version utilized in the Draft EIR analysis is dated February 2009 and was the most recent iteration
available at the time the analysis was conducted. The analyses of these potential release events in the
RMP are not material-or product-specific, and apply to all fuels that are transported to and from the
facility, including liquefied petroleum gas and butane.
The release scenario presented in the Rancho LPG RMP is a worst-case scenario, as defined by EPA's
Risk Management Program Guidance for Offsite Consequence Analysis (OCA, April 2009). A worst-
case scenario is defined as "the release of the largest quantity of a regulated substance from a vessel or
process line failure, and the release that results in the greatest distance to the endpoint for the regulated
toxic or flammable substance." For butane and propane, the endpoint is 1 psi overpressure for a vapor
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City of Los Angeles June 2013
cloud explosion. The worst-case release is defined without regard to cause and potential human or
mechanical intervention. However, passive mitigation such as containment berms can be considered.
In its review of the RMP for application to the evaluation of risk of upset impact at the Ponte Vista
Project Site for the Draft EIR, BlueScape Environmental concluded that Rancho LPG correctly followed
the EPA regulatory guidance for release of refrigerated butane into a containment area (OCA, Section 5).
The RMP analysis assumed that the entire contents of a full tank would empty into a containment basin
over 10 minutes, with 10% of that quantity available for a vapor explosion. The maximum amount of
refrigerated butane stored in either of two large tanks is 57 million pounds (lbs). Of that, 570,000 lbs. of
refrigerated liquid butane was assumed to be released per minute for 10 minutes, with 57,000 lbs/min
available to evaporate and for a vapor cloud explosion. From OCA Reference Table 13, even if all
570,000 lbs. were instantaneously available for a vapor cloud, the distance to 1 psi overpressure would be
just over O.<;> miles. Measured from the edge of the containment areas for the refrigerated butane storage
tanks, the Proposed Project would Lie more than 0.7 miles distant, beyond the 0.5-mile worst-case
scenario radius. Therefore, this worst-case scenario explosion, and explosions under other scenarios with
lesser release quantities, were determined would not impact the Project Site at the significance level of 1
psi overpressure. Thus, the Draft EIR concluded that this scenario would have no impact upon future
Project residents.
The Rancho LPG RMP also defines an alternative, or more likely, release scenario as a release that would
occur when a truck pulls away after loading with a hose attached, with 14 lbs./min butane vapor released
over a period of 10 minutes. The 140 lb. release leads to a 0.02-mile distance to overpressure of 1 psi,
again, much closer to the facility than the Ponte Vista Project Site. The alternative release scenario
considers such mitigation as manual or automated shutoff procedures. This alternative case and other
similar scenarios are much more realistic of the types of releases that might occur at the Rancho LPG
facility, including leaks from valves, valve failures, pipe breaks, and other scenarios. In addition, these
scenarios account for the agency-required safety procedures that Rancho LPG must have in place to
minimize the risk of these releases. The worst-case scenarios of total butane or propane storage tank
failure lead to the furthest impacts to endpoint, but are also extremely unlikely to occur. Releases such as
leaks and spills from product delivery by truck or rail are much more likely than the.worst-case scenario,
but exhibit significantly less chemical released over a longer period. Thus, the Draft EIR properly
included that the Rancho LPG facility would have no impact on the Project under either the Worst-Case
Release Scenario or the Alternative Release Scenario presented in the RMP.
Commenters have presented numerous objections to the methodology and conclusions presented in
Rancho LPG's RMP. However, the RMP is filed with the Los Angeles City Fire Department (LAFD),
the delegated agency for managing compliance with federal and state regulations governing butane and
propane storage. The LAFD is charged with reviewing and approving the RMP document, completing
inspections, and enforcing compliance. Given this, it was properly concluded that the RMP represents the
most informed and reliable assessment of the potential product release scenarios at Rancho LPG and,
thus, provide the best basis for an analysis of the facility's potential to affect the Project Site.
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City of Los Angeles June2013
General Concerns About Rancho LPG
Many commenters on the Draft BIR have raised general objections to and concerns regarding the Rancho
LPG facility, above and beyond the potential for accidental releases of hazardous materials to impact the
Project Site specifically. These comments are understood as being presented within the context of an
ongoing community debate over the Rancho LPG facility, a debate that pre-dates the advent of a
redevelopment proposal for the Ponte Vista Project Site. It is clearly not within either the ability or the
mandate of the BIR for the Proposed Project to address or resolve each of the concerns that has been
expressed regarding Rancho LPG, nor would it be appropriate to attempt to do so. However, because the
Draft BIR does contain a brief discussion of the recent community debate over Rancho LPG as context
for the more direct analysis of Rancho LPG's potential to impact the Project, some general background
and discussion of recent developments is warranted.
Its original owner, Petrolane, constructed the Rancho LPG facility beginning in 1973. An BIR for the
project was certified by the City of Los Angeles in 1973 and the facility was granted all applicable
permits from the relevant regulatory agencies prior to construction and initial operation. Although the
Rancho LPG facility is not located within a designated surface fault rupture zone, the storage tanks were
constructed with an adequate safety factor for the maximum credible seismic event associated at the time
with the Palos Verdes Fault and have been subjected to routine evaluation to ensure that they meet current
building standards, will not fail due to seismic hazard, and provide reasonable assurance that a loss of
containment will not result in an offsite consequence of danger to the public.3 With respect to the most
recent seismic evaluation of the Rancho LPG tanks, the CalARP seismic assessment (mandated every five
years) for the facility was audited in 2011 with no violations reported.4
Additionally, Rancho LPG has engaged in a program of continual inspection and maintenance to ensure
that all vessels, tanks, piping, and infrastructure are maintained in accordance with applicable regulations.
The two large refrigerated butane tanks at the facility were internally and externally inspected in 2009 and
2012, with no major defects found. No major incidents, accidents, or releases have occurred in the
Rancho LPG facility's 40 years of operation.5
In 2010, the Northwest San Pedro Neighborhood Council commissioned a Quantitative Risk Analysis of
the Rancho LPG facility, prepared by Cornerstone Technologies, Inc. As discussed in the Draft BIR (at
page IV.H-36), this analysis estimated larger zones of impact of up to 1.7 miles for a pool fire, 4.0 miles
for a vapor cloud explosion, and 6.8 miles for a BLBVE than the RMP.6 The Draft BIR goes on to state:
3
4
5
6
Ron Conrow, Western District Manager, Plains/Rancho LPG Holdings, LLC, Written Correspondence to
Michael Lo Grande, Director, Department of City Planning, City of Los Angeles, December 21, 2012, p. 8.
Ibid.
Ibid,p. 9.
Cornerstone Technologies, Quantitative Risk Analysis for Amerigas Butane Storage Facility, September 2010.
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CUy of Los Angeles June 2013
Importantly, however, the Cornerstone Technologies conclusions are based on conditions
that are extremely unlikely to occur. First, a large magnitude earthquake from the Palos
Verdes fault zone (up to 7.3 magnitude) is only expected to occur once every 400-900
years. Also, the probability that this earthquake would be centered at the Rancho LPG
facility is moderate, since the fault zone extends for a distance of approximately 100
kilometers. Further, the tanks are designed with seismic safety features that reduce the
risk of rupture in the event of an earthquake. In addition, it is highly unlikely that the
vapor cloud would distribute and ignite before reaching its maximum radius, particularly
with weather conditions in the harbor typically generating consistent yet variable wind
speeds that would disperse the butane vapor more rapidly to prohibit dense, overpressure
conditions upon ignition. Further, Cornerstone Technologies did not consider the
presence of on-site passive mitigation at the Rancho LPG facility and the analysis does
not incorporate the effects of those safety features. 7 Therefore, the scenarios modeled by
Cornerstone Technologies are considered unrepresentative, and therefore comprise
remote and speculative characterizations of the foreseeable risks associated with the
facility.
According to Rancho LPG, Cornerstone Technologies' study was prepared without any visit to the
facility and in the absence of important facility-specific data and information, including consideration of
designed facility safety measures and, thus, included unrealistic, physically impossible, and technically
invalid scenarios.8
To respond to the Cornerstone report, Rancho LPG hired Quest Consultants, Inc. to perform a thorough
technical review of the Cornerstone analysis and to prepare a comprehensive Quantitative Risk Analysis
of the Rancho LPG facility. The Quest report disputed the conclusions reached by Cornerstone
Technologies and concluded that simplistic, conservative assumptions and use of the RMP Comp Model
led Cornerstone to substantially overestimate the distance to 1 psi overpressure. Additionally, Quest
concluded that no "cataclysmic domino effect" could occur as a result of any incident at Rancho LPG.9
In 2011, the U.S. EPA hired an independent third-party consultant, Professor Daniel Crowl at Michigan
Technological University, to perform a risk assessment and evaluation with respect to potential damage
from a worst-case release of butane and/or propane from the Rancho LPG facility. In addition, Professor
Crowl evaluated both the Cornerstone and Quest reports and concluded that the Quest report presented an
accurate assessment of the true risks associated with the Rancho LPG facility.10 This third-party
assessment is discussed in the Draft EIR at page IV.H-39. Subsequently, as is also discussed in the Draft
8
9
JO
Correspondence from Rancho LPG Holdings to NW San Pedro Neighborhood Council on October 27, 2010.
Letter from Ron Conrow, p. 11.
Ibid.
Correspondence from Daniel A. Crowl, Professor, Michigan Technological University to Ms. Mary Wesling,
EPCRAIRMP Enforcement Coordinator, U.S. EPA Region IX on April 11, 2011.
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City of Los Angeles June 2013
EIR, the City Attorney responded to local concerns regarding potential risk of upset at Rancho LPG,
indicating that (1) operations at Rancho LPG are consistent with applicable regulations and requirements
and that no violations were found during two inspections of the facility in 2011; (2) there has been no
demonstration of facts leading to a claim of harm or damage caused as a result of Rancho LPG's
activities; (3) no legal basis exists via which the City can enjoin permitted business activities or
operations at Rancho LPG; and (4) that Rancho LPG's current operations were adequately addressed in
previous CEQA documentation and analysis. 11
On June 27, 2012, the Public Safety Committee of the Los Angeles City Council held a meeting to
discuss the safety of the Rancho LPG facility and others (Safety Regu1ations and Precautions at Liquefied
Petroleum Gas (LPG) Facilities, February 19, 2013). The Committee meeting was attended by several
agencies charged with overseeing compliance with safety regulations applicable to Rancho LPG. The
report from this meeting reiterated the advantage of Rancho LPG storing butane as a liquid under
pressure; that upon release into a containment area, only a small amount could become involved in a
vapor cloud explosion. The containment area reduces the surface area for liquid butane to become vapor.
As far as oversight, the Committee requested that the Chief Legislative Analyst prepare a report on safety
regulations and precautions at LPG facilities. This report was released in February 2013 and states that
LAFD conducts routine inspections of tanks, fire suppression systems, fire hydrants, gas/liquid
monitoring, inventory of process and stored substances, emergency planning, and security. In addition,
the Department of Building and Safety (LAD BS) performs annual inspections pursuant to the Municipal
Code and state law. Relative to potential safety improvements, the report identifies two initiatives in
consultation with LAFD and LADBS: one focusing on conducting an emergency exercise to further
enhance the preparedness efforts of City first responders and to better engage community stakeholders
and a second to explore the specific levels of coordination between City and non-City inspection agencies
to determine the feasibility and benefits of automatic cross-notification of inspections.12
On March 14, 2013, the U.S. EPA issued a Notice of Potential Enforcement Action to Rancho LPG for
violations of the Clean Air Act resulting from inspections it conducted of the facility in 2010 and 2011.
The allegations cited in the notice include: 13
JI
• Failure to include the rail storage area in Rancho LPG's Risk Management Plan;
• Failure to adequately evaluate potential seismic stress on the support structure for the emergency
flare;
Correspondence from Carmen A. Trutanich, Los Angeles City Attorney, to Anthony G. Patchett, Esq. on
September 22, 2011.
12 Report of the Chief Legislative Analyst, Safety Regulations and Precautions at LPG Facilities, February 19,
2013.
13 Correspondence from Daniel A. Meer, Assistant Director, Supeifund Division, U.S. Environmental Protection
Agency, Region IX to Tony Puckett, Rancho LPG Holdings, LLC; March 14, 2013.
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City of Los Angeles June 2013
• Failure to appropriately address the consequences of a loss of the city water system for fire
suppression in the event of an earthquake;
• Failure to internally inspect Tank 1 in accordance with required timetables;
• Failure to develop and adopt an adequate emergency response program; and
• Failure to ensure that the drainage pipe at the base of the containment basin and the valve located
near Gaffey Street are included in the mechanical integrity program.
Rancho LPG has prepared a formal response to this notice and has submitted it to the EPA, which is
currently reviewing the information and intends to meet with Rancho LPG in midsummer 2013 to discuss
its response.14 However, it should be noted that none of the potential violations cited in the EPA notice
directly pertain to the analysis in the Draft EIR of Rancho LPG's potential to impact the Proposed Project
under one of the two modeled release scenarios discussed previously.
5. Emergency Evacuation and Response
Several comments raise concerns regarding the potential effect of the Project on emergency response and
evacuation efforts in the event of a major emergency, either natural or manmade, in the San Pedro area; a
situation that requires response beyond routinely occurring periodic police, fire, and ambulance response
events. This Topical Response is intended to provide additional information in response to these
comments, while additional responses to certain comments are contained in the letter-by-letter responses
that follow.
As is discussed in the Draft EIR (see pages IV.H-39 through -43), the Safety Element of the General Plan
is the governing policy document of the City of Los Angeles pertaining to response to disaster events. As
part of the General Plan, the Safety Element anticipates housing growth in the City of Los Angeles. As
discussed in the Draft EIR, the current Proposed Project (Draft EIR Alternative C) would provide about
67 percent of the additional housing units forecast for the Wilmington-Harbor City Community Plan areas
from 2010-2017 and about 30 percent of forecast 2010-2027 housing growth. It is thus consistent with
the Safety Element's growth assumptions, and would not interfere with implementation of the Safety
Element.
Contrary to the assumptions of several comments, the City maintains and continuously updates and
upgrades its emergency response plans and resources. After every significant emergency, City personnel
evaluate the effectiveness ofresponse, ways to improve response, and how to reduce potential loss oflife,
injury, and property damage in future similar events. Natural disasters within the City, as well as
14 E-mail correspondence from Mary Westing, USEPA Region 9 with CAJA Environmental Services, LLC; June
17, 2013.
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City of Los Angeles June 2013
disasters in other parts of the world, have added to existing knowledge about disaster preparedness. See
the Draft BIR (at page IV.H-39) for a discussion of the responsibilities of the City's Emergency
Operations Organization's (BOO) Transportation Division.
Individual division emergency plans are maintained by the EOO's Airports Division, Animal Regulation
Division, Building and Safety Division, Fire Suppression and Rescue Division, General Services
Division, Harbor Division, Information Technology Agency, Personnel and Recruitment Division, Police
Division, Public Welfare and Shelter Division, Public Works Division, Recovery and Reconstruction,
·Transportation Division, and Utilities Division. The Emergency Response Master Plan also contains
individual protocols and procedures (entitled "Annexes") to deal with particular types of emergencies,
including civil disturbances, earthquakes, hazardous materials releases, major aircraft accidents, major
fires, non-declared emergencies, and storms.
Interagency agreements, both formal and informal, enable the closest available unit to respond to an
emergency incident. Inter-jurisdictional assistance to assure public safety, protection and other assistance
services today generally are in the form of "mutual aid" agreements (see Draft BIR at page IV.H-40).
Mutual aid and other agreements provide for voluntary cooperative efforts and for provision or receipt of
services and aid to or from other agencies or jurisdictions when local capabilities are exceeded by an
emergency event. Through mutual aid agreements, the BOO and individual City agencies coordinate
emergency response planning with adjacent cities, the County of Los Angeles, the State, federal agencies
and other public and private organizations, such as the Los Angeles Unified School District and the
American Red Cross. In addition, they share information so as to improve hazard mitigation efforts and
coordinate resources for disaster response and recovery.
As discussed in the Draft BIR (at page IV.H-40), the BOO Harbor Division's emergency preparedness
plan addresses various contingencies, including the potential that, in the event of a major disaster, the
possibility exists that the Harbor would be geographically severed from the City making it impossible for
other divisions to move equipment and personnel into the area. For this purpose, the Harbor Division
maintains interagency cooperation agreements with the Port of Long Beach, U.S. Navy and the U.S.
Coast Guard. The Harbor Department also maintains current lists of Harbor Department construction
equipment, vehicles, vessels and radio equipment, and also a list of equipment in the area operated by
private industry. In general, the San Pedro/Harbor area is considered to have the most advanced, well-
developed set of emergency response and emergency evacuation procedures in the City of Los Angeles,
as well as in the greater Los Angeles region.15
The City is constantly planning and working to respond to emergency contingencies in the best manner
possible. The response to any given emergency depends on the particular emergency event that has
occurred, the timing and location of the emergency event, and the scope of the emergency event. Given
15 Joan McNamara, Commanding Officer-Harbor Area, Los Angeles Police Department; personal
communication, April 18, 2007.
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the numerous permutations of possible events and circumstances, discussion of a hypothetical event is
beyond the scope of this EIR.
In accordance with the Safety Element and Emergency Response Manual, in a state of emergency, the
EOO assumes command and control and responds with maximum feasible speed. The EOO informs the
public as to the steps that should be taken to protect themselves, and directs responding resources. As
persons become aware of the state of emergency, ordinary public activities, such as persons engaged in
shopping or work, are temporarily suspended. Public cooperation is assumed and public agencies assume
·control of public streets and facilities that are necessary to allow efficient emergency response, and where
relevant, evacuation activities.
While emergency preparedness is intended to be flexible to respond to unknown contingencies, the Safety
Element d~signates disaster routes, which for planning purposes are intended to function as primary
thoroughfares for movement of emergency response traffic and access to critical facilities.16 Immediate
emergency debris clearance and road/bridge repairs for short-term emergency operations will be
emphasized along these routes. The selected disaster routes also provide a plan for inter-jurisdictional
road reconstruction and rebuilding following a major disaster.
As is discussed in the Draft EIR (at page IV.H-40), within the vicinity of the Project Site, the Safety
Element does not designate Western A venue as a disaster route. The north-south disaster routes include:
Western A venue south of West Summer land A venue, Gaffey Street, Pacific A venue, and Harbor
Boulevard. East-west disaster routes include 25th Street, 9th Street, West Summerland Avenue east of
Western Avenue, Palos Verdes Drive North, Anaheim Street, Pacific Coast Highway, and Lomita
Boulevard. Interstate 110 is the major north-south freeway route in the vicinity. The Harbor Area and
San Pedro are also adjacent to surrounding cities and their disaster routes. Western Avenue would not be
used as an evacuation route in the event of an incident occurring at the Port of Los Angeles because it is
located too far to the west.17
Various comments posit a situation in which mass evacuation of the entire San Pedro/Harbor area would
be necessary. As is discussed in the Draft EIR, this is a remote and speculative scenario. Foreseeable
emergency situations such as explosions or hazardous material releases that would require evacuation as
the best possible response are likely to be far more localized in terms of size and seriousness of the event,
the geographic diversity and size of the surrounding area, the length of event, and influence of climactic
conditions. As discussed on page IV.H-41 of the Draft EIR, a mass evacuation would be the response of
last resort because a mass evacuation removes evacuees from their most ready shelter and supplies (their
homes) and subjects them to the risks of travel in an emergency situation. Localized evacuations would
be preferred, and would be for as short as a duration as possible. Specific evacuation methods have been
]6 City of Los Angeles, General Plan Safety Element; Exhibit H (Critical Facilities and Lifeline Systems).
17 Dave Malin, Harbor Department Emergency Preparedness Coordinator II, personal communication, March
15, 2007.
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developed for evacuations and inter-agency communication and coordination protocols, as well as public
communication methods and protocols, have been identified so that evacuation procedures are
implemented effectively and consistently among local agencies.18
As is stated in the Draft EIR, in the event of a localized emergency, normal traffic patterns would cease as
. the public becomes aware of the situation and as emergency personnel take control of streets. Traffic
patterns along routes in the Project vicinity would be controlled. The availability of centrally controlled
automated traffic signals, towards which the Project will contribute, would significantly improve
emergency response preparedness in the area. For localized emergencies to which evacuation is the
required response, the public would be instructed in accordance with a localized evacuation plan. Traffic
would be carefully managed and emergency personnel would have the ability to direct traffic to flow in
only one direction. For example, using the base traffic lane capacity assumed in the traffic analysis of
1,500 vehicles per lane per hour, Western Avenue could accommodate approximately 3,000 vehicles per
hour in a two-way street scenario (i.e., two lanes northbound leaving San Pedro), and up to 6,000 vehicles
per hour in a one-way street scenario (i.e., four lanes northbound leaving San Pedro).
Comments were submitted regarding the ability of the Los Angeles Fire Department (LAFD) and the Los
Angeles Police Department (LAPD) to respond to emergency calls within the traffic study area of the
Project, considering that several of the study intersections currently operate at poor levels of service
(LOS). Although the Project would add traffic to the study area, the required mitigation measures set
forth in Section IV.N (Transportation and Traffic) of the Draft EIR would reduce all of the Project's
traffic impacts to less than significant levels. The Project's traffic would not cause traffic flow to
"freeze," not allowing any vehicles, emergency or otherwise, to move through the study area. Traffic
congestion is commonplace in the City of Los Angeles, and the LAFD and LAPD are familiar with the
tactics needed to maneuver through traffic congestion during an emergency response, with the use of
sirens, lights, traffic signals, and use of alternate routes during peak traffic hours. The LAFD and LAPD
would continue to implement these tactics during the operation of the Project.
As stated previously, and on page IV.H-41 of the Draft EIR, for most emergency situations, emergency
preparedness and shelter-in-place is the preferred approach to be implemented. In these situations, the
emergency response plans focus on public awareness, education and communication methods and
protocols designed to provide accurate, timely, and consistent information to the public. In addition, the
plans include inter-agency communication and coordination protocols for shelter-in-place emergency
situations.19 In hazardous materials releases and other emergencies, the danger is most often avoided or
minimized by staying in place and indoors. In the event of a major catastrophe, damage, confusion and
hazards may be widespread, making it difficult, and potentially more perilous, to travel. Sheltering-in-
18 Joan McNamara, Commanding Officer-Harbor Area, Los Angeles Police Department; personal
communication, April 18, 2007.
19 Ibid.
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place also enables emergency response personnel to gain control and stability more quickly and
thoroughly by reducing panicked activity and interference in emergency response activities.20
As a Project Design Feature, the Project would prepare and implement an emergency response plan for
approval by the Los Angeles Fire Department (see pages IV.H-21 and IV.M-9 of the Draft EIR). The
emergency response plan will include but not be limited to the following: mapping emergency exits,
evacuation routes for vehicles and pedestrians, location of nearest hospitals, and fire departments. In
developing the emergency response plan, the Project Applicant will consult with neighboring land uses,
including but not limited to the U.S. Navy Defense Fuel Support Point (DFSP), the ConocoPhillips
Refinery, Rancho LPG, the Port of Los Angeles, and Mary Star of the Sea High School. The Project will
also include an additional emergency access point along its southern boundary adjacent to the Seaport
Village development.
This emergency response plan will help implement the City's emergency response plan policies
(described earlier in this Topical Response). Project access and design is already planned to conform to
the requirements ofLADOT, which has reviewed and approved preliminarily proposed Project circulation
and access routes, as well as the requirements of the Fire Department. In addition, the Project would fund
physical traffic capacity improvements to address Project and cumulative growth and would provide an
access to Western Avenue for Mary Star of the Sea High School. Implementation of the Project's traffic
mitigation measures would result in improved performance conditions at several of the intersections in
comparison to existing conditions, even with the addition of Project traffic. Also, as stated on p. IV.N-9
of the Draft EIR, signalized intersections near the Project Site have traffic control improvements
(ATSAC/ATCS and other similar computer-operated systems) that will assist in the centralized control
and operation of traffic signals, resulting in more rapid and effective emergency response. Except in the
event of a localized emergency of continuing duration, the reasonably foreseeable scenario is that Project
residents and their immediate neighbors would be instructed to abide by the same measures as other area
residents, avoid unnecessary travel, and remain inside their homes.21
As noted in the Draft EIR, the Project's emergency response plan will address the occupancy, number,
location, and design of the structures approved for the Project at the conclusion of the entitlement process.
It will require mapping of emergency exits, evacuation routes for vehicles and pedestrians within and
from the Project Site, and location of nearest hospitals and fire departments. The Applicant must also
consult with neighboring land uses, including but not limited to the DFSP and the Conoco-Phillips
Refinery. The plan must be completed and approved based on final building plans before building
permits for the Project's structures are issued. Once completed and approved by the Fire Department, this
required plan would be integrated with the regional emergency response plans described above by the
LAPD and LAFD and the other agencies responsible for emergency response measures. These
20 Ibid.
21 Ibid.
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requirements provide a mechanism for developing an integrated emergency response plan for the Project
and the surrounding community.
Emergency response plans for the San Pedro/Harbor area are being continually reviewed and updated in
response to changing land uses and population characteristics within the target area. Because land use
and population patterns are dynamic, this updating of emergency response plans is an ongoing process led
by the LAPD with involvement from the other agencies involved in implementing the plans, from the
LAFD to the California Highway Patrol. Whenever new development occurs, emergency response plans
are evaluated and, if necessary, revised to reflect the new development.22 The Project Site is not currently
identified in any existing emergency response plan as a physical evacuee location or other location of
public congregation or equipment/personnel mobilization. In light of the foregoing discussion, the
Project would have no impact with respect to interference with the provisions of adopted emergency
response plans.
With respect to non-state-of-emergency situations, as discussed in the Draft EIR at page IV.M-12, the
Project impacts related to emergency access also would be less than significant. Emergency access to the
Project Site (police, fire, and ambulance) would be provided via the two ingress/egress points off Western
A venue that would also provide general site access as well as via the additional emergency access lane
connecting to the Seaport Village development at the Site's southern boundary. In addition, a reciprocal
emergency access arrangement exists between Mary Star of the Sea High School and the Project that
would allow for emergency access from Mary Star and Taper Avenue to Western Avenue. Project-
specific impacts with respect to emergency response distance (police, fire and ambulance) would be less
than significant (see Draft EIR, p. IV.M-11).
Several comments assert that the Project would have a significant impact by resulting in increased
response times to fire, police, and emergency medical service calls within the area. Although no evidence
has been presented to support such an assertion, the obligation to provide adequate fire and emergency
medical services is the responsibility of the City (Cal. Const., art. XIII, Section 35, subd. (a)(2) ["The
protection of the public safety is the first responsibility of local government and local officials have an
obligation to give priority to the provision of adequate public safety services.]). In addition, the potential
"need for additional fire protection services is not an environmental impact that CEQA requires a project
proponent to mitigate. Section 15382 of the CEQA guidelines defines 'significant effect on the
environment' as 'a substantial, or potentially substantial, adverse change in any of the physical conditions
of the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and
objects of aesthetic or historic significance. An economic or social change by itself shall not be
considered a significant effect on the environment. A social or economic change related to a physical
change may be considered in determining whether the physical change is significant."' [City of Hayward
v Board of Trustees of the California State University, First Dist. Court of Appeal, Case No. A131412
22 Ibid.
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(May 2012) (Review pending)]. As is also stated in City of Hayward, "the potential dangers associated
with delayed response times do not mandate a finding of significance under section 15065, subdivision
(a)(4) of the Guidelines ... " [City of Hayward v Board of Trustees of the California State University, First
Dist. Court of Appeal, Case No. A131412 (May 2012) (Review pending)]. Thus, even ifthe Project were
shown to have resulted in delayed response times for relevant public services, such effects are not
considered to be environmental impacts under CBQA.
6. Alternatives to the Proposed Project
Several commenters have raised concerns over the range of alternatives to the Proposed Project that was
evaluated in Section VI of the Draft BIR .. Primary issues raised by commenters are (1) Alternative B (No
Project Alternative/Existing Zoning -Single-Family Homes) does not account for the existing Open
Space zoni~g on a portion of the Project Site and (2) the Draft EIR did not include a mixed-use alternative
that would combine residential with neighborhood-serving commercial/retail and limited office space
uses. These two issues are addressed in this topical response. Other specific comments pertaining to the
alternatives evaluated in the Draft BIR as well as other suggested possible alternatives are addressed
under the individual responses to comments in Section III.B.
Reasonable Range of Feasible Alternatives
As is discussed beginning on page VI-1 of the Draft BIR, the CEQA Guidelines require that BIRs include
the identification and evaluation of a reasonable range of alternatives that are designed to reduce the
significant environmental impacts of a project, while still satisfying the project objectives. Specifically,
Section 15126.6(a) of the CBQA Guidelines states:
Alternatives to the Proposed Project. An EIR shall describe a range of reasonable
alternatives to the project, or to the location of the project, which would feasibly attain
most of the basic objectives of the project but would avoid or substantially lessen any of
the significant effects of the project, and evaluate the comparative merits of the
alternatives. An EIR need not consider every conceivable alternative to a project.
Rather it must consider a reasonable range of potentially feasible alternatives that will
foster informed decisionmaking and public participation. An EIR is not required to
consider alternatives which are infeasible. The Lead Agency is responsible for selecting
a range of project alternatives for examination and must publicly disclose its reasoning
for selecting those alternatives. There is no ironclad rule governing the nature or scope
of the alternatives to be discussed other than the rule of reason.
Additionally, Section 15126.6(c) of the CEQA Guidelines states:
Selection of a range of reasonable alternatives. The range of potential alternatives to the
Proposed Project shall include those that could feasibly accomplish most of the basic
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objectives of the project and could avoid or substantially lessen one or more of the
significant effects. The EIR should briefly describe the rationale for selecting the
alternatives to be discussed. The EIR should also identify any alternatives that were
considered by the Lead Agency but were rejected as infeasible during the scoping
process and briefly explain the reasons underlying the Lead Agency's determination.
Additional information explaining the choice of alternatives may be included in the
administrative record. Among the factors that may be used to eliminate alternatives from
detailed consideration in an EIR are: (i) failure to meet most of the basic project
objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts.
Two points are particularly relevant to the suggestions made by commenters on the Draft EIR:
alternatives to a project must be potentially feasible and must feasibly accomplish most of the basic
objectives of a project.
The objectives of the Proposed Project are presented on page VI-3 of the Draft EIR and are as follows:
1. To remove the abandoned improvements currently present on the site, in accordance with the
contractual conditions of sale required by the U.S. Navy.
2. To provide new housing on unutilized land that will meaningfully contribute to meeting the
projected 2017 and 2027 housing need in the Wilmington-Harbor City Community Plan area, as
projected by the City's General Plan Framework and Southern California Association of
Governments, without requiring the demolition of existing market-rate or rent-controlled housing
stock.
3. To provide new housing that meets the housing needs of a broad spectrum of persons who desire
to live in the San Pedro community.
4. To provide a residential project with substantial common amenities, landscaping, and open space
for the use of its residents.
5. To provide a project that will invigorate the local economy, employment, and business
opportunities through project construction, and through the expenditures of its future residents.
6. To mitigate potential significant environmental impacts, to the extent feasible.
7. To develop a project that fiscally benefits the City of Los Angeles.
8. To provide a project that ensures high-quality development and maintenance through the creation
and adoption of a specific plan that will set land use, architectural, landscaping, streetscaping, and
lighting standards.
As the Draft EIR states, based on market conditions and demands, the Project Applicant determined that
residential development would best meet the objectives for the Project. The Applicant also determined
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that all potential alternatives should involve private development projects that might be financially
feasible to develop and market. All existing improvements must be removed from the Project Site
pursuant to the contract under which the site was first transferred to private ownership. Further, the site,
which was not graded or filled in accordance with current standards, must be comprehensively
reengineered as part of any development.
The other CEQA-mandated consideration in establishing the range of alternatives to the Proposed Project
to be evaluated in the Draft EIR is the extent to which the potential alternatives can either avoid or
substantially lessen the significant environmental impacts of the Proposed Project. As discussed
throughout Section IV of the Draft EIR, all of the Project's significant impacts can be mitigated to a less
than significant level through the implementation of the proposed mitigation measures with the exception
of impacts with respect to operational air emissions, construction-related noise and vibration, and
operational ·exterior noise within the Project itself (not at any off-site locations). Although alternatives
that were not evaluated in the Draft EIR may exist that would reduce some of the Project's other
significant impacts (e.g., operational traffic), the fact that the identified Project mitigation measures
would reduce these impacts to a less than significant level made it less critical to consider such
alternatives, particularly if they were determined to either be infeasible to develop or incapable of
attaining most of the defined project objectives listed above.
Thus, the ultimate selection of the range of alternatives to ·be evaluated in the Draft EIR was made based
on their feasibility to develop, their ability to achieve most of the project objectives, and their ability to
either avoid or substantially lessen the significant impacts of the Project that could not be mitigated to a
less than significant level. Nonetheless, the Draft EIR does present a discussion of additional alternatives
that were considered, but rejected from full evaluation (at page VI-5). These possible alternatives
included a development plan similar to that contained in the 1999 Base Reuse Plan for the site, a mixed-
use residential/commercial alternative, a fully commercial alternative, and an alternative site plan
containing a dedicated senior-housing component. The rationale for not evaluating any of these other
alternatives is discussed in Section VI of the Draft EIR.
Corrections to Draft EIR Alternative B
As was noted previously, multiple comments on the Draft EIR have stated that an alternative that would
develop the Project Site under its existing zoning and General Plan designations was not evaluated and
that the alternative in the Draft EIR (Alternative B) that purports to do exactly this, in fact, does not.
With respect to this issue, the commenters are correct. Alternative B, discussed at pages I-10 and VI-10
of the Draft EIR, would redevelop the Project Site with 385 single-family homes but would not retain the
site's existing zoning and General Plan land use designations, as the Draft EIR states. With respect to this
latter point, the Draft EIR is in error and has been revised as described below.
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As is described in Section IV.J (Land Use) of the Draft EIR, the Project Site is currently zoned for R-1
(single-family residential) development with the exception of 9.3 acres along the property's northern
boundary, which is zoned Open Space. The General Plan land use designations of the site track with the
zoning. Thus, it would not be possible to develop 385 single-family homes on the site unless the zoning
and land use designations of the property· were changed to eliminate the 9.3 acres of Open Space. As a
result, implementation of Alternative B would require that a Zone Change and General Plan Amendment
be approved for the Project.
In order to correct this error in the Draft EIR, the following revisions have been made to Section I
(Introduction/Summary) at page I-10 under the "Alternatives" section heading (see also Section IV,
Corrections and Additions to the Draft EIR):
In 'order to provide informed decision-making in accordance with Section 15126.6 of the CEQA
Guidelines, this Draft EIR considers a range of alternatives to the Project. The Draft EIR
analyzes the following alternatives: (A) No Project Alternative/No Development; (B) No Projeot
Alternative/Single-Family Homes; (C) Staff Recommendation/Reduced Density; and (D) Revised
Site Plan. Each alternative is described in full in Section VI, Alternatives to the Project, of this
DraftEIR.
Alternative B: No Projeet Altemative/Single-Family Homes
Alternative B presumes that the Project Site would be redeveloped aooording to existing zsooing
and General Plan designation allowed uses and densities in order to maximize the number of
single-family residences at the site. Taking site planning considerations into account, including
the required seismic setback, approximately 385 single-family homes could be developed on the
Project Site under the site's existing Rl zoning and Low Residential General Plan designation.
Such a site plan would require that the existing 9.3 acres of Open Space zoning and land use
designation on the Project Site be eliminated. Alternative B would not include a 2.8-acre public
park or an access road to Mary Star of the Sea High School from Western Avenue.
The following revisions have also been made to Section VI (Alternatives to the Proposed Project), first at
the bottom of page VI-4 (see also Section IV, Corrections and Additions to the Draft EIR):
Alternative B: No Projeot Altemafr;e/fadsting Zoning (Single-Family Home~
Also at page VI-10 (see also Section IV, Corrections and Additions to the Draft EIR):
Alternative B: No Projeet Alternative/Existing Zo:aiBg (Single-Family Homes~
Under Alternative B, the Project would not be developed on the Project Site. However, the
Project Site would not remain in its current condition. Under the conditions of the ownership
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transfer from the U.S. Department of Defense to the previous owner, all existing improvements
on the Project Site must be removed. Accordingly, the existing vacant former Navy housing
complex and associated roadways and other infrastructure would be demolished and all debris
removed from the Project Site under this alternative. Under the current land use designation in
the Wilmington-Harbor City Community Plan, a majority of the Project Site is designated for
Low Density Residential (4 to 9 dwelling units per acre) land uses. The Planning and Zoning
Code (Los Angeles Municipal Code [LAMC], Chapter 1), zones all but 9.3 acres of the Project
Site Rl-lXL (One-Family Zone, Extra Limited Height District No. 1). Single-family dwellings,
among other specified land uses, are permitted within the Rl zone. The Extra Limited Height
District No. 1 limits the height of buildings to two stories or 30 feet. The remaining 9.3 acres of
the site is zoned and designated Open Space.
If a Zone Change and General Plan Amendment were approved to remove the 9.3 acres of Open
Space zoning from the Project Site. the land use and zoning designations of the Project Site
would permit up to 429 single-family homes. In addition, if a single-family project were to
include below-market (moderate, low, and very-low income units), a potential density bonus of
35 percent under the City's existing rules and regulations, or 579 single-family units, might be
developed on the Project Site. Because of the significant site acquisition and site preparation
costs related to the Project, the Applicant indicates that it is unlikely that a single-family project
with below-market units would be developed.
Under City of Los Angeles zoning criteria, Rl zoning requires that each lot have a minimum area
of 5,000 square feet, a minimum width of 50 feet, front yards of not less than 20 percent of the
depth of the lot, and rear yards of not less than 15 feet, with resulting dwelling unit densities of
approximately six units per acre (taking streets into account). Due to high land prices in infill
locations within the City of Los Angeles, fewer and fewer new subdivisions are being developed
in accordance with Rl zoning. Instead, homebuilders seeking to develop single-family homes in
infill locations routinely propose homes on smaller lots at significantly higher densities.
In addition, the requirement to incorporate a seismic setback zone across the site, described in
Section IV.F, Geology and Soils, would eliminate approximately 44 potential lots from a single-
family residential site plan, reducing the total number of potential home lots from 429 to 385.
While infill housing in areas like the Project Site is not typically being developed in accordance
with traditional Rl zoning criteria, for the purpose of eomplying \s,rith SeetioR 15126.6(e)(2) of
the CEQA Guidelines, this alternatives analysis assumes that, under Alternative B, the Project
Site would be developed as a single-family home project in accordance with Rl zoning with
approximately 3 85 single-family homes and that a Zone Change and General Plan Amendment
would be approved to remove the current Open Space zoning/land use designation from the
northerly 9.3 acres of the site. A conceptual site plan for Alternative Bis shown in Figure VI-1.
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The number of homes in Alternative B is below the maximum density that could be developed
vlithout a General Plan amendment or rezoning under the Rl zoning in order to provide a street
and lot plan consistent with a move-up/high-end home plan as well as to, as described above,
incorporate the required seismic setback zone. The development would be designed to be
consistent with all e~dsting planning and zoning requirements.
All of the homes under Alternative B would be developed for sale at market rates. Due to the
same significant site acquisition and site preparation costs discussed previously, the Project
Applicant indicates that it would be necessary to develop the Project Site with the maximum
reasonable number of move-up/high-end single-family homes at the highest supportable prices in
the market area (Los Angeles/Wilmington-Harbor City/San Pedro) that could be achieved. The
Project Applicant estimates that such homes would range between 2,000 and 3,000 square feet
and would need to sell for an average price of $1 million. Given the current housing market and
state of the local and regional economy, there is uncertainty that such prices could be realized.
However. retaining the existing 9.3 acres of zoned Open Space on the site under Alternative B
would eliminate approximately 81 additional single-family home lots from the site plan, which
would likely make the alternative development economically infeasible to develop. For this
reason, Alternative B proposes to eliminate the 9.3 acres of Open Space zoning from the Project
Site.
The title of Figure VI-1 has been revised to read as follows (see also Section IV, Corrections and
Additions to the Draft EIR):
Conceptual Site Plan-Alternative B (No Projeet ,AJternativ:e/Single-Family Homes)
The following revisions have been made to the text on page VI-13 of the Draft EIR under the "Public
Park/Open Space" subheading (see also Section IV, Corrections and Additions to the Draft EIR):
No public park would be developed. The existing 9.3 acres of zoned Open Space on-site would
be eliminated through a Zone Change and General Plan Amendment process in order to allow for
development of a sufficient number of single-family homes to render the site plan economically
feasible. Although community open space and private park area would be located along the
seismic setback zone crossing the center of the Site, the total amount of open space associated
with Alternative B would be less than that associated with the Proposed Project due to the
elimination of the public park component and existing zoned Open Space.
The following revisions have been made to the text on pages VI-70 and VI-71 of the Draft EIR under the
"Impacts of Alternative B" subheading (see also Section IV, Corrections and Additions to the Draft EIR):
Contrary to the Proposed Project, Alternative B would be dev:eloped eonsistent with existing
planning and zoning designations for the Project Site require a Zone Change and a General Plan
Amendment to re-designate the existing 9.3 acres of Open Space on-site to Rl-lXL and Low
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Density Residential to match the remainder of the site's existing zoning and land use designation.
Lots for the 385 single-family homes would be created through the processing and recordation of
a tentative tract map. Alternative B would contribute fewer additional housing units to meet area
housing needs than the Project. In addition, it is expected that the sales price of homes developed
pursuant to Alternative B would average approximately $1,000,000. Thus, Alternative B would
provide housing for only the most affluent segment of the housing market, rather than for a broad
range of potential buyers and renters. Although it would contribute additional single-family
housing, Alternative B would not implement recommended air quality and regional planning
strategies to increase the density of infill housing so as to reduce urban sprawl impacts on natural
resources, reduce air quality emissions due to VMT for commuting purposes, and to reduce
regional congestion through VMT reduction. Alternative B would fail to promote further
attainment of many City and regional planning objectives and would be either inconsistent or less
consistent than the Proposed Project with several of the policies contained in the General Plan,
particularly those relating to the provision of a range of housing opportunities and the promotion
of higher densities in locations proximate to centers of employment and transit. Alternative B
would not set aside and dedicate a 2.8-acre public park as proposed by the Project. In addition,
the access road across the southern portion of the Project Site connecting Western A venue to the
Mary Star of the Sea High School campus would not be provided under this alternative, creating a
potential land use incompatibility with the school that did not previously exist by forcing school
traffic to pass through an existing single-family residential neighborhood (Taper Avenue). In
summary, impacts would be less than significant but, on balance, slightly greater than those
associated with the Proposed Project.
The following revisions have been made to the text on pages VI-103 of the Draft EIR under the "Impacts
of Alternative B" subheading (see also Section IV, Corrections and Additions to the Draft EIR):
Alternative B represents development under the e~tisting R 1 entitlemeat fer the Prajeet Site Rl-
lXL zoning and a Low Medium Residential land use designation. Under this entitlement With
approval of these entitlements, a total of 385 single-family homes could be constructed on the
Project Site. The vehicular access associated with Alternative B is assumed to be consistent with
the access scheme currently planned for the Proposed Project.
The heading of Table VI-19 beginning on page VI-133 of the Draft EIR has been revised as follows (see
also Section IV, Corrections and Additions to the Draft EIR):
Alternative B: Na PFajeet ,AJ.teFBative/ExistiBg Zoning (Single-Family Homes)
The following revisions have been made to the text on pages VI-146 and VI-147 of the Draft EIR under
the "Alternative B" subheading (see also Section IV, Corrections and Additions to the Draft EIR):
Alternative B would redevelop the Project Site with approximately 385 single-family homes,
consistent with existing zoning regulations governing the site Rl-lXL zoning and the Low
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Medium Residential land use designation. As discussed at the start of this section, beeause
Alternative B would ft0t require a General Plan Amendment eF and Zone Change to eliminate the
existing Open Space zoning and land use designation from the northerly 9 .3 acres of the site in
order to be implemented, it is also eonsidered to represent a "No Projeet" alternative, even though
it would result in redevelopment of the site.
Existing Zoning Alternative Site Plan
. In addition to pointing out the errors in the Draft EIR with respect to Alternative B (discussed above),
several commenters have also requested that an evaluation of an alternative site plan that is fully
consistent with the Project Site's existing zoning and General Plan land use designations be added to the
Draft EIR. Commenters have also requested that such an alternative site plan include the same public
access roa.dway to Mary Star of the Sea High School that is proposed under the Project and under
Alternatives C and D in the Draft EIR. Commenters have also requested that this alternative site plan
contain full-sized single-family home lots consistent with Rl zoning (5,000 square feet or 50 feet by 100
feet). Under these design constraints, a conceptual site plan was developed that would result in
development of 169 single-family homes at the Project Site. This plan would also incorporate the
required seismic setback zone across the center of the site and would include two recreation centers as
well as landscaped common area. The northernmost 9.3 acres of the Project Site would remain as open
space, consistent with the current zoning and land use designation of this portion of the property. This
area could be developed to some extent with park and recreation facilities for the use of the general
public, although its configuration and topography would likely limit its suitability for dedication to the
City as a neighborhood park. A conceptual site plan for this "Existing Zoning" alternative was developed
and is shown in Figure III.A-1.
As discussed at the start of this topical response, under CEQA, alternatives to a project that are evaluated
in a Draft EIR must be feasible to develop and must achieve a majority of the project's objectives. They
should also be capable of either avoiding or substantially reducing the project's unmitigated significant
impacts.
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~ < ~
~
~ ~
f:J ~
Source: Robert Hidey Architects, 02/27/2013.
CAJA Environmental Services, LLC
PRODUCT TYPE # OF UNITS (DU)
co
0 320 ----160
~
Scale (Feet)
Figure 111.A-1
Existing Zoning Alternative
Conceptual Site Plan 5-70
City of Los Angeles June 2013
Comparison to Project Objectives
With respect to being able to achieve most of the Project's objectives, the 169 single-family home
"Existing Zoning" alternative site plan would achieve seven of the Project objectives, although some
would be achieved to a substantially lesser extent than with the Proposed Project. The "Existing Zoning"
alternative site plan would remove the existing buildings on the Project Site; provide new housing on
unutilized land that would contribute to meeting the projected 2017 housing need in the area; provide a
project that would invigorate the local economy; mitigate its environmental impacts to the extent feasible;
provide substantial common open space along the site's northern boundary as well as two recreation
centers for the use of residents, and provide a high-quality development. The "Existing Zoning" site plan
would not provide new housing to meet the housing needs of a broad spectrum of persons desiring to live
in the San Pedro community due to the economic imperative to develop high-end, large-lot single-family
homes having a price well above the median for the region. While development of this "Existing Zoning"
site plan would fiscally benefit the City, it would likely do so to a significantly lesser degree than the
Proposed Project due to the reduced number of homes, even though the tax assessments would most
likely be greater on a per unit average basis. Similarly, the "Existing Zoning" alternative site plan would
not contribute to meeting the anticipated need for housing in the San Pedro area to the same degree as the
Proposed Project due to the reduced number of homes that would be developed and the prices they would
likely command.
Comparison to Project Impacts
The "Existing Zoning" alternative site plan would generally result in fewer impacts than the original
Proposed Project or Alternatives B, C, and D in the Draft EIR (note that Alternative C, the reduced
density alternative, is now the Applicant's preferred project), primarily due to the fewer number of homes
that would be developed at the site. Impacts that would result from development of the "Existing Zoning"
alternative site plan are summarized as follows:
• Aesthetics: The "Existing Zoning" site plan would have similar impacts with respect to visual
character and views as the Proposed Project, although the development on the site itself would be
of a lower scale and height. The existing visual character of the site would largely be retained,
albeit with greater density and replacing abandoned structures with a well-maintained residential
development. The northern slope of the property would not be developed but would instead be
preserved as open space, thus lessening the overall developed footprint on-site in comparison to
the Proposed Project or Alternatives B, C, and D. Building heights on the Project Site would be
lower, which would reduce the prominence of the homes on the site as compared to the taller
multi-family residential buildings of the Project when viewed from off-site locations. Overall
impacts on views and visual character under this alternative would be less than significant and
less than with the Proposed Project. Light and glare impacts would be reduced in comparison to
the Proposed Project due to the elimination of the public park and open space lighting as well as
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the lower building heights of the single-family homes. Similar to the Project, no shade/shadow
impacts would occur.
• Air Quality: Compared to the Project, the "Existing Zoning" site plan would involve the
construction of a smaller development and thus the duration and total construction-related air
quality emissions would be reduced. However, it is assumed that the maximum daily emissions
for the demolition, site preparation, grading and building construction phases would be similar to
the Project. Furthermore, it is expected that the same mitigation measures included for the
Project would also be required and implemented. As such, and similar to the Project, regional
and localized construction emissions would be reduced to less than significant levels with the
implementation of Mitigation Measures AQ-1 through AQ-3. The "Existing Zoning" site plan is
expected to generate 1,638 trips during a typical weekday, representing an approximate 72
pe:r;cent reduction compared to the Project. Motor vehicle trips are the primary source of daily
operational emissions. Because the "Existing Zoning" alternative would generate fewer vehicle
trips than the Project, it would also generate fewer average daily emissions. Modeled operational
emissions associated with the "Existing Zoning" site plan (2017 Buildout) would not exceed the
established SCAQMD threshold levels for any criteria pollutant. Thus, the "Existing Zoning" site
plan would eliminate the Project's (2017 Buildout) ROG and NOx significant and unavoidable
impacts. Additionally, localized CO impacts would also be reduced compared to the Project.
Because the Project's localized CO impacts at studied intersections under all scenarios resulted in
less than significant impacts, it can be deduced that the "Existing Zoning" alternative would also
result in less than significant CO impacts because it would involve substantially fewer vehicle
trips. As such, localized CO impacts would be considered less than significant and reduced when
compared to the Project.
• Biological Resources: The "Existing Zoning" alternative would avoid the Project's less than
significant impacts to the degraded CSS habitat on the previously graded northern slope of the
property by removing this part of the site from the development footprint. However, this slope
would not be revegetated and replaced with more extensive and higher functioning CSS habitat as
would be the case with the Project. Thus, although impacts to CSS habitat and the CAGN and
PVB would be less than significant, the Project's beneficial impact would not be realized.
Potential impacts on nesting birds would be similar to the Project. Similarly, potential impacts to
roosting bats would be similar to those associated with the Project. Similar to the Project, the
existing drainage channel crossing the southern portion of the site would be replaced and covered.
Due to the need to fully develop the property to maximize the number of single-family homes, no
opportunity to re-create riparian habitat along the channel would exist. Impacts would be
significant before mitigation and similar to those of the Proposed Project. As with the Project, no
substantial impediment to wildlife movement or gene flow could occur and the impact would be
less than significant and equivalent to the Project. Most of the 330 trees on the Project Site would
be removed, with the exception of those within the northerly 9.3 acres of the site. However, due
to site plan constraints, a substantially fewer number of new trees would be planted
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(approximately 428 net new trees) as compared to the Proposed Project. Nonetheless, impacts to
trees, including protected trees, would be less than significant, and slightly less than with the
Proposed Project. As with the Project, the "Existing Zoning" alternative would not conflict with
any local policies or ordinances protecting biological resources, such as tree preservation policies
or ordinances. Thus, no impact would occur.
• Cultural Resources: Potential archeological and paleontological resources impacts .associated
with the "Existing Zoning" alternative site plan would be largely the same as the Proposed
Project and would be potentially significant. Therefore, the Compliance Measure and mitigation
similar to Mitigation Measures CULT-I through CULT-9 would be required in order to reduce
potential impacts to a less than significant level. Any potential impacts along the northerly 9.3
acres would be avoided.
• Geology and Soils: The "Existing Zoning" site plan incorporates the required seismic setback
zone through the central portion of the Project Site and would thus be in compliance with
applicable City engineering requirements and would be similar to Alternative C, the current
Proposed Project. Otherwise, potential geology and soils impacts would be virtually the same as
the Proposed Project, although impacts along the northern slope of the site would largely be
avoided. Measures similar to the Compliance Measures for the Project would reduce these
impacts, although they would be less than significant.
• Greenhouse Gas Emissions: Compared to the Project, the "Existing Zoning" alternative site plan
would involve the construction of a smaller development and thus the duration and total
construction-related GHG emissions would be reduced. Furthermore, it is expected that the same
mitigation measures included for the Project would also be required and implemented to reduce
construction-related GHG emissions to the maximum extent feasible. The "Existing Zoning"
alternative is expected to generate 1,638 trips during a typical weekday, representing an
approximate 72 percent reduction compared to the Project. Motor vehicle trips are the primary
source of daily operational GHG emissions. Because fewer vehicle trips would be generated than
the Project, fewer average daily GHG emissions would be generated. Furthermore, as a
substantially smaller development would be constructed, fewer operational GHG emissions
would be generated from on-site sources and energy consumption. Specifically, it is estimated
that the operation of the "Existing Zoning" alternative would generate approximately 3,496 C02e
MTY assuming the same general sustainability measures outlined in MM AQ-4 for the Project
would be implemented under this alternative. This represents an approximate 70 percent
reduction compared to the Project. Similar to the Project, the "Existing Zoning" alternative
would be consistent with all feasible and applicable strategies to reduce greenhouse gas emissions
in California and the City of Los Angeles. As such, it would not conflict with an applicable plan,
policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.
Thus, GHG impacts would be considered less than significant and reduced compared to the
Project.
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• Hazards and Hazardous Materials: As with the Project, the "Existing Zoning" alternative site
plan would entail demolition of all existing structures and improvements, excavation and grading,
and construction of new buildings, improvements, utilities, and landscaping. Implementation of
Mitigation Measure HAZ-1 would therefore be required to ensure that petroleum-impacted soils
are characterized during Project excavation and grading activities and are either remediated on-
site or, if necessary, transported to an appropriate facility for disposal, thus reducing the impact to
a less than significant level, equivalent to the Project. Similarly, implementation of Mitigation
Measures HAZ-2 and HAZ-3 would be required to insure that ACMs and LBP in the existing on-
site structures are properly abated and that potential risks from ACMs and LBP are reduced to a
less than significant level, equivalent to the Project. DPM emissions generated during
construction would be reduced in duration compared to the Project due to the anticipated shorter
construction period; however, estimated daily emissions would be comparable to those of the
Prnject and would be less than significant. The types of hazardous materials associated with
routine, day-to-day operation would be expected to be comparable to those associated with the
Project. Nonetheless, the transport, use, and disposal of these materials would not be expected to
pose a significant hazard to the public or the environment and impacts would be less than
significant. The risk of upset potential associated with separation distances between the site and
the ConocoPhillips Refinery, DFSP, and Rancho LPG facilities would be virtually the same as
with the Project, and therefore less than significant. The human health risk associated with
emissions from these off-site facilities would also be identical to the Project, and therefore less
than significant. Because fewer residents would be present at the site (approximately 458
persons, or a 79 percent reduction compared to the Project), any emergency response plan for the
site would need to consider and manage a fewer number of residents. In summary, overall
impacts related to hazards and hazardous materials would be less than significant with mitigation
and less than the Project.
• Hydrology and Water Quality: Unlike the Project, the "Existing Zoning" alternative would not
redevelop the entire site, but would leave the northernmost 9.3 acres as under existing,
undeveloped conditions. Under future conditions, general drainage patterns on the site would
remain substantially the same as under existing conditions, although the existing open drainage
channel crossing the southern portion of the site would be undergrounded and covered in
approximately its existing location, as with the current Proposed Project (Draft EIR Alternative
C). As with the Project, a new internal storm drainage system would be installed within the
residential on-site street system and would connect to the County/City storm drainage facility at
the southern edge of the property. The amount of stormwater runoff generated at the site would
be slightly less than that associated with the Project due to the avoidance of any impervious
surface area in the northerly 9.3 acres. Thus, this alternative would not have an adverse impact
with respect to storm drain capacity and no mitigation measures would be required. Similarly,
the development would have a less than significant impact on storm drainage infrastructure and
flooding resulting from the alteration of existing drainage patterns and the increase in overall site
imperviousness. Impacts would be less than significant and slightly less than the Proposed
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Project. Impacts associated with the amount of runoff contributed to the Harbor and the
movement of surface water would be less than significant and slightly less than the Proposed
Project. Impacts associated with flooding, including the very slight risk of flooding resulting
from the complete, instantaneous failure of the Palos Verdes Reservoir, would be less than
significant and less than with the Project due to the fewer number of future residents to be located
on the site. Water quality impacts would be less than significant and similar to those of the
Project.
• Land Use and Planning: Contrary to the Proposed Project, the "Existing Zoning" alternative
would be developed consistent with existing planning and zoning designations for the Project
Site. Lots for the 169 single-family homes would be created through the processing and
recordation of a tentative tract map. This alternative would contribute fewer additional housing
units to meet area housing needs than the Project. In addition, in order for this alternative to
avoid a financial loss for the Applicant, a top line sales price of $1.57 million for homes
developed under the existing zoning would need to be achieved.23 Thus, the "Existing Zoning"
alternative would provide housing for only the most affluent segment of the housing market,
rather than for a broad range of potential buyers and renters. Although it would contribute
additional single-family housing, this alternative would not implement recommended air quality
and regional planning strategies to increase the density of infill housing so as to reduce urban
sprawl impacts on natural resources, reduce air quality emissions due to VMT for commuting
purposes, and to reduce regional congestion through VMT reduction. The "Existing Zoning"
alternative would fail to promote further attainment of many City and regional planning
objectives and would be either inconsistent or less consistent than the Proposed Project with
several of the policies contained in the General Plan, particularly those relating to the provision of
a range of housing opportunities. In summary, impacts would be less than significant but, on
balance, slightly greater than those associated with the Proposed Project.
• Noise: Given the size and location of the site, the requirement to demolish existing
improvements, and the need to re-engineer and grade existing soils, redevelopment of the site
under virtually any development scenario would result in significant temporary construction noise
and vibration (human annoyance) impacts to the identified sensitive receptors. Similar to the
Project, it is expected that the "Existing Zoning" alternative would include mitigation comparable
to the Project's Mitigation Measure's N0-1 through N0-11 aimed at reducing construction
related noise and vibration to the maximum extent feasible. Nevertheless, construction-related
noise and vibration impacts would be significant although reduced compared to the Project due to
the shorter anticipated construction period. Stationary noise impacts associated with HV AC
systems would be less than significant and reduced compared to the Project. Because the
23 The Concord Group, "Economic Feasibility Analysis Relative to the Development of the Ponte Vista
Property, San Pedro, CA", Final Report, June 18, 2013, p. 2.
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"Existing Zoning" alternative would result in fewer daily vehicle trips than the Project, off-site
roadway noise impacts would also be less than significant and reduced compared to the Project.
As with the Proposed Project, this alternative would result in generally unacceptable exterior
noise levels for the proposed residential and open space uses fronting Western A venue on the
Project Site. Compared to the Project, fewer residences would be placed in the generally
unacceptable ambient noise level areas. This significant and unavoidable impact would be
essentially equivalent to the Project, although fewer residences would be impacted.
• Population and Housing: As with the Proposed Project, no construction-related housing impacts
would be anticipated under the "Existing Zoning" alternative. The direct impact would be 169
single-family detached housing units. Including indirect/induced households, the total
households/housing unit impact at the Subregion level would be 252 households/housing units.
Within the Wilmington-Harbor City Community Plan area, the "Existing Zoning" alternative
would represent about 14 percent of 2010-2017 household growth; and about six percent of 2010-
2027 household growth. Therefore, like the Project, this alternative would not induce substantial
housing growth, because it would meet a portion of forecasted housing need rather than exceed
the housing growth forecast for the City of Los Angeles Subregion. The housing impact would
be less than significant and less than the Proposed Project. The "Existing Zoning" alternative
would achieve some of the Project's housing objectives, although to a substantially lesser extent
than with the Proposed Project, as discussed previously. The "Existing Zoning" alternative
would accommodate a population of 458 and would generate Subregion-level indirect/induced
population impact of 159 persons for a total Project population impact of 617 persons. This
alternative's direct plus indirect/induced population would represent about 21 percent of 2010-
2017 population growth; and about nine percent of 2010-2027 population growth within the
Wilmington-Harbor City Community Plan Area. Therefore, like the Project, this alternative
would not induce substantial population growth, because it would accommodate a portion of
forecasted population rather than exceed the population growth forecast for the City of Los
Angeles Subregion and Wilmington-Harbor City Community Plan area. Therefore, the
population impact would be less than significant and less than the Proposed Project.
• Public Services -Fire Protection: Fire protection service demands would generally be less than
for the Project due to the fewer number of residences to be constructed at the site. The proposed
plot plan for would be subject to LAFD review for compliance with applicable Los Angeles Fire
Code, California Fire Code, City of Los Angeles Building Code, and National Fire Protection
Association standards, thereby ensuring that this alternative would not create a fire hazard. For
the above reasons, impacts related to fire services and emergency access would be less than
significant and less than the Project.
• Public Services -Police Protection: Police protection service demands would be generally less
than for the Project due to the fewer number of residences to be constructed at the site.
Therefore, impacts to LAPD services and response times would be somewhat less than under the
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Proposed Project, given the reduced amount of overall development and, as with the Project's
impacts, would be less than significant.
• Public Services -Schools: The "Existing Zoning" alternative site plan would generate
approximately 29 elementary school students, 13 middle school students, and 17 high school
students at any one time. As compared to the Project, this alternative would generate 77 fewer
elementary school students, 39 fewer middle school students, and 47 fewer high school students,
which would generally create less of a demand for school services than the Project. Single-family
homes typically generate a greater number of students on a per/home basis than do multi-family
and rental dwelling units. With the addition of these students to existing school enrollments
utilized in the Draft EIR, Taper Elementary School would operate under capacity by 195 stu'dents,
Dodson Middle School would operate under capacity by 377 students, and Narbonne High School
would operate under capacity by 210 students. Similar to the Proposed Project, new development
under this alternative would be required to pay School Fees as a Compliance Measure. These
fees would be used to construct facilities, which according to LAUSD, are necessary to serve
overall student enrollment growth district-wide associated with new development, and are
deemed to mitigate CEQA school impacts by State law. Therefore, impacts to LAUSD services
would be less than significant and less than under the Proposed Project, given the reduced amount
of overall development.
• Public Services -Parks and Recreation: The "Existing Zoning" alternative would include 9.3
acres of undeveloped, common open space area along the site's northern boundary. This area
could be developed with publicly accessible recreational facilities to some extent, although the
configuration of this area and its comparatively steeply sloping topography would likely render it
unsuitable for use as a dedicated neighborhood park. Nonetheless, this area would provide
additional public open space on the Project Site and would represent a significant increase
compared to what would be available under the Proposed Project. In addition, this alternative
would include two recreation centers for the use of residents, as well as additional landscaped
open space and common areas scattered throughout the Site. The "Existing Zoning" alternative
would represent a substantial increase in the amount of public open space available when
compared to the Proposed Project. This open space area, coupled with the proposed recreation
centers on-site, would provide more than enough acreage to satisfy the parkland goals for the
population generated by development of this alternative. Thus, impacts on parks and recreation
would be less than significant and less than those of the Proposed Project.
• Public Services -Libraries: The "Existing Zoning" alternative would result in a smaller impact
to library services than the Proposed Project, as it would accommodate fewer residents. Thus,
impacts on library services would be less than significant and less than those of the Proposed
Project.
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• Transportation and Traffic: Development of the "Existing Zoning" alternative site plan would
generate substantially less traffic at the Project Site following completion and full occupancy.
Specifically, this alternative would be expected to generate 32 inbound and 95 outbound trips
during the weekday AM peak hour, and 108 inbound and 64 outbound trips during the weekday
PM peak hour. Over a 24-hour period, this alternative is forecast to generate a total of 1,638 trips
during a typical weekday. Compared to the Project's forecast 5,788 weekday trips (Draft EIR
Alternative C), the "Existing Zoning" alternative would generate 72 percent fewer daily total
trips. The alternative would create significant traffic impacts at five of the study intersections, as
compared to 16 under the Proposed Project (Draft EIR Alternative C). As with the Project, all of
the significant impacts that would be produced could be mitigated to a less than significant level
via the implementation of the traffic mitigations identified in the Draft EIR. Thus, traffic impacts
would be less than significant with mitigation and substantially less than those of the Proposed
Project.
• Utilities and Service Systems -Water: The "Existing Zoning" alternative site plan would result
in an increase in water consumption within the LAD WP' s service jurisdiction due to the
construction of 169 single-family homes and would generate a demand for approximately 43.57
AFY of water (approximately 38,870 gpd). This amounts to approximately 126 AFY less water
than the Project. Because LADWP has determined that adequate water supplies would be
available to serve the Project, it is reasonably inferred that the same would be true with respect to
the reduced demand for water under this alternative. Thus, as with the Proposed Project, the
alternative would result in a less than significant impact to water supplies, and less than the
Project.
• Utilities and Service Systems -Wastewater: Wastewater would be generated at the Project Site
by long-term operation of the single-family residential units. The "Existing Zoning" alternative
would generate approximately 38,870 gpd of wastewater. This amounts to approximately
124,650 fewer gpd than the Project. Because sufficient wastewater treatment capacity at the
TIWRP exists for the larger Project wastewater generation, it can therefore be reasonably
concluded that sufficient treatment capacity for the reduced demand under this alternative would
also be available. Therefore, impacts would be less than those under the Project and, as with the
Project, would be less than significant. Similarly, given that the total amount of wastewater
generated by this alternative would be less than the Project, impacts with regard to wastewater
conveyance would be less than significant and less than the impacts under the Project.
• Utilities and Service Systems -Solid Waste: The amount of solid waste generated during
demolition and site preparation would be approximately the same as that generated by the
Proposed Project during the same stages of construction. Solid waste generated during home
construction under the "Existing Zoning" alternative would be less than that associated with the
construction of the Proposed Project due to the reduced total square footage to be developed. As
such, and similar to the Project, the landfills would have adequate capacity to accommodate the
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average daily construction waste generated over the multi-year construction period, and
construction-related solid waste impacts would be less than significant. This alternative would
generate approximately 1.03 tons (2,067 pounds) of solid waste per day during its operation,
assuming a minimum 30 percent solid waste diversion rate (or 1.47 tons per day less than the
Project). The remaining combined daily intake of the Sunshine Canyon Landfill and the Chiquita
Canyon Landfill is 7 ,329 tons per day. As such, they would have adequate capacity to
accommodate the daily operational waste generated by this alternative. Operational solid waste
impacts would be less than significant and less than with the Proposed Project.
• Utilities and Service Systems -Energy: Similar to the Proposed Project, the "Existing Zoning"
alternative would require a line extension from the existing off-site lines to the premises, on-site
transformation facilities, and conduit and cable throughout the property to provide electricity to
the Project Site. The alternative itself would not require new (off-site) energy supply facilities
and distribution infrastructure. The conservatively estimated Alternative-related annual
electricity consumption of 950,879 kWh/year would represent a reduction of approximately
3,519,116 kWh/year when compared to the Proposed Project. Therefore, it is anticipated that
LADWP's existing and planned electricity capacity and electricity supplies would be sufficient to
support the alternative's electricity consumption. Less demand for natural gas would be created
by this alternative as compared to the Proposed Project. The alternative is forecast to increase
natural gas consumption by approximately 1.13 million cubic feet per month, which would be
approximately 2.26 million cubic feet per month less than the Proposed Project. Similar to the
Proposed Project, impacts related to natural gas would be less than significant and less than those
associated with the Proposed Project.
To summarize the impacts of the "Existing Zoning" alternative site plan in comparison to those of the
Proposed Project (Alternative C in the Draft EIR), this alternative has the potential to reduce or avoid the
following significant impacts:
• Regional operational air emissions
• Project-related traffic impacts at intersections within the Project area
The "Existing Zoning" alternative would not have the potential to reduce or avoid the Proposed Project's
potential impacts involving regional and local construction-associated air emissions, potential impacts on
nesting birds and/or roosting bats during construction, impacts to jurisdictional resources on-site,
potential impacts to archaeological and/or paleontological resources, potential impacts relating to
hydrocarbon-impacted soils, disturbance of asbestos-containing materials (ACMs) and lead-based paint
(LBP) that are present in the existing abandoned structures on-site, construction-related noise and
groundborne vibration, exterior noise at homes fronting Western A venue, and potential traffic impacts
associated with the installation of water service infrastructure. Other impacts associated with the Project,
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although less than significant, would be substantially reduced under this alternative due to the fewer
number of residences that would be developed on-site.
Feasibility
As discussed at the start of this topical response, under CEQA, alternatives to a project that are evaluated
in a Draft EIR must be feasible to develop. With respect to the "Existing Zoning" alternative site plan
that has been requested by numerous commenters on the Draft EIR, nothing would physically prevent the
aJternative from being developed at the Project Site. Therefore, the determination of its feasibility is
limited to its ability to produce a positive return on investment to the Applicant. In order to evaluate the
economic feasibility of the "Existing Zoning" alternative, a study was prepared by The Concord Group
(attached as Appendix B) in June 2013. The study concludes that the "Existing Zoning" alternative
(Alternative 1 in the Concord Group report) would be economically infeasible to develop due to the
substantial ievel of fixed costs associated with infrastructure and land that remain largely the same
irrespective of the total number of lots developed at the site.24 The "Existing Zoning" alternative could
only become economically feasible (e.g., avoid an economic loss for the Applicant) if it could achieve a
top line home sale price of $1.57 million ($525 per square foot of home), a level that is currently
unsupported in the market. The nearest new home project, Harbor Highlands, generates an average home
price of $554,000 ($300 per square foot) for a small-lot detached home. Nearby resales in Rancho Palos
Verdes, across Western Avenue from the Project Site, generate an average sale price of $721,000. In
light of the comparables proximate to Ponte Vista, any development at the Project Site would not support
home values in excess of $1 million.25 Given the realities of the current residential real estate market,
development of the "Existing Zoning" alternative at the Project Site would result in a loss of
approximately $87 million.
Conclusions
CEQA requires that a Draft EIR identify an "environmentally superior alternative". Section VI.D of the
Draft EIR contains this discussion and concludes that Alternative C (the reduced density alternative that
now represents the Applicant's preferred project) is the environmentally superior alternative among the
development alternatives that were evaluated. Although the "Existing Zoning" alternative discussed in
this topical response was not included in the Draft EIR, it would, as discussed above, substantially reduce
many of the Project's less than significant impacts and would avoid the Project's significant, unmitigated
operational air quality impact and reduce the Project's significant but mitigated traffic impacts. Thus, an
argument could be advanced that the "Existing Zoning" alternative could be the environmentally superior
alternative. However, as noted previously, CEQA requires that the range of alternatives evaluated in a
Draft EIR be feasible to develop. As has been shown above, the "Existing Zoning" alternative would not
be economically feasible to develop at the Project Site.
24 Ibid.
25 Ibid.
Ponte Vista Project
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Because the "Existing Zoning" alternative is economically infeasible, therefore, it is not the
environmentally superior alternative and will not be added to the EIR. Instead, the text on page VI-5 of
the Draft EIR, under the heading "Alternatives Considered But Rejected From Further Consideration" has
been revised as follows:
Alternatives that clearly would not be financially feasible to develop and market (considering
such factors as the cost of site acquisition and the costs to plan, permit, and develop the project),
such as public parks, were not considered. Included among such alternatives is development of
the Project Site under the existing zoning and General Plan land use designations, which would
retain 9.3 acres of the site as undeveloped open space and develop the remainder with 169 5,000
square foot single-family home lots consistent with the Rl-lXL zoning. Such an alternative has
been determined to be economically infeasible to develop at the Project Site. However, an
altrniative that would develop the site exclusively with single-family homes is discussed and
evaluated below as Alternative B.
Mixed Use Alternative Site Plan
Several commenters have also requested that an evaluation of a mixed-use residential/commercial
alternative site plan be added to the Draft EIR. Commenters have also requested that such an alternative
site plan include the same public access roadway to Mary Star of the Sea High School that is proposed
under the Project and under Alternatives C and D in the Draft EIR. Commenters have also requested that
this alternative site plan contain neighborhood-serving retail space, limited office space intended to serve
future Project residents, a six-acre public neighborhood park, and space for development of a
neighborhood branch library. Under these design constraints, a conceptual site plan was developed that
consists of 477 residential units in a mix of housing product types ranging from single-family homes to
townhomes and flats. A total of 181 single-family homes and 296 condominium units could be developed
under this alternative. In addition, 5,000 square feet of office space, 20,000 square feet of
retail/commercial space, and a site for a 20,000 square foot public library, as well as a 6-acre central
neighborhood park, are included in this alternative. This alternative would provide public access across
the site to Mary Star of the Sea High School from Western A venue. This plan would also incorporate the
required seismic setback zone across the center of the site and would include a central recreation center as
well as landscaped common area. A conceptual site plan for this "Mixed Use" alternative was developed
and is shown in Figure III.A-2.
As discussed at the start of this topical response, under CEQA, alternatives to a project that are evaluated
in a Draft EIR must be feasible to develop and must achieve a majority of the project's objectives. They
should also be capable of either avoiding or substantially reducing the project's unmitigated significant
impacts.
Ponte Vista Project
Final Environmental Impact Report
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Page IIJ.A-48
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/./J ~ ~
"l:'
&1 4J I
f.,.:.
f:J ~
Source: Robert Hidey Architects, 02/27/2013.
CAJA Environmental Services, LLC
PRODUCT TYPE # OF UNITS (DU)
PRODUCT 1 62
PRODUCT 2 60 .
PRODUCT 3 59
PRODUCT 4 296
NON-RESIDENTIAL PRODUCT
PRODUCT 7/8 I MAIN RECREATION AREA (6,732 SF)
PRODUCT 9
PRODUCT 10
PRODUCT 11
SECONDARY RECREATION ARE (1,415 SF)
OFFICE BUILDING (5,000 SF)
RETAIL I COMMERCIAL (20,000 SF)
LIBRARY BUILDING (20,000 SF)
0
liiiiiiiiiii
co
160
Scale (Feet)
320
Figure 111.A-2
Mixed Use Alternative
Conceptual Site Plan 5-82
City of Los Angeles June 2013
Comparison to Project Objectives
With respect to being able to achieve most of the Project's objectives, the "Mixed Use" alternative site
plan would achieve each of the Project objectives, although some would be achieved to a substantially
lesser extent than with the Proposed Project. The "Mixed Use" alternative site plan would remove the
existing buildings on the Project Site; provide new housing on unutilized land that would contribute to
meeting the projected 2017 housing need in the area; provide a project that would invigorate the local
economy; mitigate its environmental impacts to the extent feasible; provide substantial common open
space and park area as well as a recreation center for the use of residents; and provide a high-quality
development. The "Mixed Use" site plan would provide new housing to meet the housing needs of a
broad spectrum of persons desiring to live in the San Pedro community but to a lesser degree than the
Project due to the fewer number of units and housing product types to be developed. While development
of this "Mixed Use" site plan would fiscally benefit the City, it would likely do so to a significantly lesser
degree than the Proposed Project due to the reduced number of homes. Similarly, the "Mixed Use"
alternative site plan would not contribute to meeting the anticipated need for housing in the San Pedro
area to the same degree as the Proposed Project due to the reduced number of homes that would be
developed.
Comparison to Project Impacts
The "Mixed Use" alternative site plan would generally result in similar impacts as the Proposed Project,
with the differences primarily due to the fewer number of homes that would be developed at the site
and/or the addition of commercial/retail and public library and park uses. Impacts that would result from
development of the "Mixed Use" alternative site plan are summarized as follows:
• Aesthetics: The "Mixed Use" site plan would have similar impacts with respect to visual
character and views as the Proposed Project, although the development on the site itself would be
of a lower scale and height. The existing visual character of the site would largely be retained,
albeit with greater density and replacing abandoned structures with a well-maintained residential
development. Building heights on the Project Site would be lower due to the replacement of the
apartments along the site's southern border with two-story townhomes, which would reduce the
prominence of the homes on the site as compared to the taller multi-family residential buildings
of the Project when viewed from off-site locations. Overall impacts on views and visual
character under this alternative would be less than significant and marginally less than with the
Proposed Project. However, light and glare impacts would be somewhat increased in comparison
to the Proposed Project due to outdoor lighting for the six-acre public park and exterior lighting at
the library and commercial/retail and office buildings. The location of the park, however, would
be separated from the existing off-site residences to the south, thus ameliorating the potential
impact. In addition, mitigation would be applied to restrict lighting hours to protect adjacent on-
Ponte Vista Project
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site residences, ensuring that the impact would be less than significant. Similar to the Project, no
shade/shadow impacts would occur.
• Air Quality: Compared to the Project, the "Mixed Use" site plan would involve the construction
of a smaller development and thus the duration and total construction-related air quality
emissions would be reduced. However, it is assumed that the maximum daily emissions for the
demolition, site preparation, grading and building construction phases would be similar to the
Project. Furthermore, it is expected that the same mitigation measures included for the Project
would also be required and implemented. As such, and similar to the Project, regional and
localized construction emissions would be reduced to less than significant levels with the
implementation of Mitigation Measures AQ-1 through AQ-3. The "Mixed Use" site plan is
expected to generate 4,720 trips during a typical weekday, representing an approximate 18
percent reduction compared to the Project. Motor vehicle trips are the primary source of daily
operational emissions. Because the "Mixed Use" alternative would generate fewer vehicle trips
than the Project, it would also generate fewer average daily emissions. Modeled operational
emissions associated with the "Mixed Use" site plan (2017 Buildout) would exceed the
established SCAQMD threshold levels for NOx during the summertime (smog season) and
wintertime (non-smog season). Thus, the "Mixed Use" alternative would eliminate the Project's
(2017 Buildout) ROG significant and unavoidable impact. Additionally, localized CO impacts
would also be reduced compared to the Project. Because the Project's localized CO impacts at
studied intersections under all scenarios resulted in less than significant impacts, it can be
deduced that the "Mixed Use" alternative would also result in less than significant CO impacts
because it would involve substantially fewer vehicle trips. As such, localized CO impacts would
be considered less than significant and reduced when compared to the Project.
• Biological Resources: The "Mixed Use" alternative would result in virtually the same level of
impact to biological resources as the Proposed Project. Impacts to the degraded CSS habitat and
on the site's northerly slope would be less than significant and identical to those of the Project.
As with the Project, this north slope area would be regraded, re-engineered, and revegetated with
native species, including CSS species. Potential impacts on nesting birds would be similar to the
Project. Similarly, potential impacts to roosting bats would be similar to those associated with
the Project. Similar to the Project, the existing drainage channel crossing the southern portion of
the site would be replaced and covered. Due to the need to fully develop the property, no
opportunity to re-create riparian habitat along the channel would exist. Impacts would be
significant before mitigation and similar to those of the Proposed Project. As with the Project, no
substantial impediment to wildlife movement or gene flow could occur and the impact would be
less than significant and equivalent to the Project. As with the Project, all of the 330 trees on the
Project Site would be removed. However, due to site plan constraints, a substantially fewer
number of new trees would be planted (approximately 1,207 net new trees) as compared to the
Proposed Project. Nonetheless, impacts to trees, including protected trees, would be less than
significant, and identical to those of the Proposed Project. As with the Project, the "Mixed Use"
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alternative would not conflict with any local policies or ordinances protecting biological
resources, such as tree preservation policies or ordinances. Thus, no impact would occur.
• Cultural Resources: Potential archeological and paleontological resources impacts associated
with the "Mixed Use" alternative site plan would be identical to those of the Proposed Project and
would be potentially significant. Therefore, the Compliance Measure and mitigation similar to
Mitigation Measures CUL T-1 through CUL T-9 would be required in order to reduce potential
impacts to a less than significant level.
• Geology and Soils: The "Mixed Use" site plan incorporates the required seismic setback zone
through the central portion of the Project Site and would thus be in compliance with applicable
City engineering requirements and would be similar to Alternative C, the current Proposed
Pn;>ject. Otherwise, potential geology and soils impacts would be virtually the same as the
Proposed Project. Measures similar to the Compliance Measures for the Project would reduce
these impacts, although they would be less than significant.
• Greenhouse Gas Emissions: Compared to the Project, the "Mixed Use" alternative site plan
would involve the construction of a smaller development and thus the duration and total
construction-related GHG emissions would be reduced. Furthermore, it is expected that the same
mitigation measures included for the Project would also be required and implemented to reduce
construction-related GHG emissions to the maximum extent feasible. The "Mixed Use"
alternative is expected to generate 4,720 vehicle trips during a typical weekday, representing an
approximate 18 percent reduction compared to the Project. Motor vehicle trips are the primary
source of daily operational GHG emissions. Because fewer vehicle trips would be generated than
the Project, fewer average daily GHG emissions would be generated. Furthermore, as a smaller
development would be constructed, fewer operational GHG emissions would be generated from
on-site sources and energy consumption. Specifically, it is estimated that the operation of the
"Mixed Use" alternative would generate approximately 9,109 C02e MTY assuming the same
general sustainability measures outlined in MM AQ-4 for the Project would be implemented
under this alternative. This represents an approximate 21 percent reduction compared to the
Project. Similar to the Project, the "Mixed Use" alternative would be consistent with all feasible
and applicable strategies to reduce greenhouse gas emissions in California and the City of Los
Angeles. As such, it would not conflict with an applicable plan, policy or regulation adopted for
the purpose of reducing the emissions of greenhouse gases. Thus, GHG impacts would be
considered less than significant and reduced compared to the Project.
• Hazards and Hazardous Materials: As with the Project, the "Mixed Use" alternative site plan
would entail demolition of all existing structures and improvements, excavation and grading, and
construction of new buildings, improvements, utilities, and landscaping. Implementation of
Mitigation Measure HAZ-1 would therefore be required to ensure that petroleum-impacted soils
are characterized during Project excavation and grading activities and are either remediated on-
Ponte Vista Project
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site or, if necessary, transported to an appropriate facility for disposal, thus reducing the impact to
a less than significant level, equivalent to the Project. Similarly, implementation of Mitigation
Measures HAZ-2 and HAZ-3 would be required to insure that ACMs and LBP in the existing on-
site structures are properly abated and that potential risks from ACMs and LBP are reduced to a
less than significant level, equivalent to the Project. DPM emissions generated during
construction would be reduced in duration compared to the Project due to the anticipated shorter
construction period; however, estimated daily emissions would be comparable to those of the
Project and would be less than significant. The types of hazardous materials associated with
routine, day-to-day operation would be expected to be somewhat different than those associated
with the Project due to the commercial/retail and office components of the site plan. Nonetheless,
the transport, use, and disposal of these materials would not be expected to pose a significant
hazard to the public or the environment and impacts would be less than significant. The risk of
upset potential associated with separation distances between the site and the ConocoPhillips
Refinery, DFSP, and Rancho LPG facilities would be virtually the same as with the Project, and
therefore less than significant. The human health risk associated with emissions from these off-
site facilities would also be identical to the Project, and therefore less than significant. Because
fewer residents would be present at the site (approximately 1,766 persons, or a 21 percent
reduction compared to the Project), any emergency response plan for the site would need to
consider and manage a fewer number of residents. In summary, overall impacts related to
hazards and hazardous materials would be less than significant with mitigation and less than the
Project.
• Hydrology and Water Quality: As with the Project, the "Mixed Use" alternative would redevelop
the entire site. Under future conditions, general drainage patterns on the site would remain
substantially the same as under existing conditions, although the existing open drainage channel
crossing the southern portion of the site would be undergrounded and covered in approximately
its existing location, as with the current Proposed Project (Draft EIR Alternative C). As with the
Project, a new internal storm drainage system would be installed within the residential on-site
street system and would connect to the County/City storm drainage facility at the southern edge
of the property. The amount of stormwater runoff generated at the site would be slightly less than
that associated with the Project due to the greater amount of pervious surface area, primarily in
the vicinity of the proposed six-acre public park. Thus, this alternative would not have an adverse
impact with respect to storm drain capacity and no mitigation measures would be required.
Similarly, the development would have a less than significant impact on storm drainage
infrastructure and flooding resulting from the alteration of existing drainage patterns and the
increase in overall site imperviousness. Impacts would be less than significant and slightly less
than the Proposed Project. Impacts associated with the amount of runoff contributed to the
Harbor and the movement of surface water would be less than significant and slightly less than
the Proposed Project. Impacts associated with flooding, including the very slight risk of flooding
resulting from the complete, instantaneous failure of the Palos Verdes Reservoir, would be less
than significant and less than with the Project due to the fewer number of future residents to be
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located on the site. Water quality impacts would be less than significant and similar to those of
the Project.
• Land Use and Planning: As with the Proposed Project, the "Mixed Use" alternative would
require a Zone Change and General Plan Amendment to create a new Specific Plan zone and land
use designation for the Project Site. This alternative would contribute fewer additional housing
units to meet area housing needs than the Project. Although it would contribute additional single-
and multi-family housing, this alternative would not implement recommended air quality and
regional planning strategies to increase the density of infill housing so as to reduce urban sprawl
impacts on natural resources and to reduce regional congestion through VMT reduction to the
same degree as the Proposed Project. On the other hand, the provision of Project-and
neighborhood-serving retail/commercial space on-site as well as the availability of office space
that could be utilized by future residents of the Project and surrounding neighborhood would help
implement planning policies encouraging mixed use development in order to produce a
consequent reduction in local VMT and vehicle trips. The "Mixed Use" alternative would be less
consistent than the Proposed Project with several of the policies contained in the General Plan,
particularly those relating to the provision of a range of housing opportunities. In summary,
impacts would be less than significant and, on balance, approximately the same as those
associated with the Proposed Project.
• Noise: Given the size and location of the site, the requirement to demolish existing
improvements, and the need to re-engineer and grade existing soils, redevelopment of the site
under virtually any development scenario would result in significant temporary construction noise
and vibration (human annoyance) impacts to the identified sensitive receptors. Similar to the
Project, it is expected that the "Mixed Use" alternative would include mitigation comparable to
the Project's Mitigation Measure's N0-1 through N0-11 aimed at reducing construction related
noise and vibration to the maximum extent feasible. Nevertheless, construction-related noise and
vibration impacts would be significant although reduced compared to the Project due to the
shorter anticipated construction period. Stationary noise impacts associated with HV AC systems
would be less than significant and essentially equivalent to the Project. Because the "Mixed Use"
alternative would result in fewer daily vehicle trips than the Project, off-site roadway noise
impacts would also be less than significant and reduced compared to the Project. As with the
Proposed Project, this alternative would result in generally unacceptable exterior noise levels for
the proposed residential and open space uses fronting Western Avenue on the Project Site.
Compared to the Project, fewer residences would be placed in the generally unacceptable ambient
noise level areas. Thus, while the exterior noise level along Western A venue remains essentially
equivalent to the Project, the significant and unavoidable impact would be reduced because
fewer residences would be impacted.
• Population and Housing: As with the Proposed Project, no construction-related housing impacts
would be anticipated under the "Mixed Use" alternative. Within the Wilmington-Harbor City
Ponte Vista Project
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Community Plan area, the "Mixed Use" alternative would represent about 40 percent of 2010-
2017 household growth; and about 17 percent of 2010-2027 household growth. Therefore, like
the Project, this alternative would not induce substantial housing growth, because it would meet a
portion of forecasted housing need rather than exceed the housing growth forecast for the City of
Los Angeles Subregion. The housing impact would be less than significant and less than the
Proposed Project. The "Mixed Use" alternative would achieve some of the Project's housing
objectives, although to a lesser extent than with the Proposed Project, as discussed previously.
The "Mixed Use" alternative would generate a population growth of 1,766 persons and would
generate Subregion-level indirect/induced population impact of 449 persons for a total Project
population impact of 2,215 persons. This alternative's direct plus indirect/induced population
would represent about 59 percent of 2010-2017 population growth; and about 25 percent of 2010-
2027 population growth within the Wilmington-Harbor City Community Plan Area. Therefore,
like the Project, this alternative would not induce substantial population growth, because it would
accommodate a portion of forecasted population rather than exceed the population growth
forecast for the City of Los Angeles Subregion and Wilmington-Harbor City Community Plan
area. Therefore, the population impact would be less than significant and less than the Proposed
Project.
• Public Services -Fire Protection: Fire protection service demands would be approximately the
same as for the Project. Although fewer residences would be constructed, the provision of the
library, office and commercial/retail space would also be expected to generate fire protection
service demand. The proposed plot plan for would be subject to LAFD review for compliance
with applicable Los Angeles Fire Code, California Fire Code, City of Los Angeles Building
Code, and National Fire Protection Association standards, thereby ensuring that this alternative
would not create a fire hazard. For the above reasons, impacts related to fire services and
emergency access would be less than significant and essentially equivalent to the Project.
• Public Services -Police Protection: Police protection service demands would be approximately
the same as for the Project. Although fewer residences would be constructed, the provision of the
library, office and commercial/retail space would also be expected to generate police protection
service demand. Therefore, impacts to LAPD services and response times would be essentially
equivalent to those of the Proposed Project and, as with the Project's impacts, would be less than
significant.
• Public Services -Schools: The "Mixed Use" alternative site plan would generate approximately
75 elementary school students, 40 middle school students, and 49 high school students at any one
time. As compared to the Project, this alternative would generate 31 fewer elementary school
students, 12 fewer middle school students, and 15 fewer high school students, which would
generally create less of a demand for school services than the Project. With the addition of these
students to existing school enrollments utilized in the Draft EIR, Taper Elementary School would
operate under capacity by 149 students, Dodson Middle School would operate under capacity by
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350 students, and Narbonne High School would operate under capacity by 178 students. Similar
to the Proposed Project, new development under this alternative would be required to pay School
Fees as a Compliance Measure. These fees would be used to construct facilities, which according
to LAUSD, are necessary to serve overall student enrollment growth district-wide associated with
new development, and are deemed to mitigate CEQA school impacts by State law. Therefore,
impacts to LAUSD services would be less than significant and less than under the Proposed
Project, given the reduced amount of overall development.
• Public Services -Parks and Recreation: The "Mixed Use" alternative would include a six-acre
public neighborhood park in the west central portion of the site, adjacent to Western Avenue. In
addition, the alternative would include main and secondary recreation centers for the use of
Project residents. Landscaped common areas and other general open space areas would be
integrated throughout the site plan. Thus, the total amount of park/open space area under the
"Mixed Use" alternative would represent a significant increase compared to what would be
available under the Proposed Project. The "Mixed Use" alternative would also represent a
substantial increase in the amount of publicly accessible open space available on-site when
compared to the Proposed Project. This open space area, coupled with the proposed recreation
centers on-site, would provide more than enough acreage to satisfy the parkland goals for the
population generated by development of this alternative. Thus, impacts on parks and recreation
would be less than significant and less than those of the Proposed Project.
• Public Services -Libraries: The "Mixed Use" alternative would include the dedication of land
area for construction of a 20,000 square foot neighborhood branch public library. The Los
Angeles Public Library would need to construct the library, as the Applicant would merely donate
the land for it. Nonetheless, such a library would not only be more than sufficient to meet the
need for library services generated by the Project, but also would serve the broader San Pedro
community. Irrespective of the potential on-site library, the "Mixed Use" alternative would result
in a smaller impact to library services than the Proposed Project, as it would accommodate fewer
residents. Thus, impacts on library services would be beneficial.
• Transportation and Traffic: Development of the "Mixed Use" alternative site plan would
generate less traffic at the Project Site following completion and full occupancy. Specifically,
this alternative would be expected to generate 79 inbound and 216 outbound trips during the
weekday AM peak hour, and 286 inbound and 199 outbound trips during the weekday PM peak
hour. Over a 24-hour period, this alternative is forecast to generate a total of 4, 720 trips during a
typical weekday. Compared to the Project's forecast 5,788 weekday trips (Draft EIR Alternative
C), the "Mixed Use" alternative would generate 18 percent fewer daily total trips. The alternative
would still create significant traffic impacts at 16 of the study intersections, the same number of
intersections as under the Proposed Project (Draft EIR Alternative C). As with the Project, all of
the significant impacts that would be produced could be mitigated to a less than significant level
via the implementation of the traffic mitigations identified in the Draft EIR. Thus, traffic impacts
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would be less than significant with mitigation and less than those of the Proposed Project due to
the approximately 18% reduction in daily vehicle trips.
• Utilities and Service Systems-Water: The "Mixed Use" alternative site plan would result in an
increase in water consumption within the LADWP's service jurisdiction due to the construction
of 477 residential units and the associated mixed-use development and would generate a demand
that would be slightly less than that of the Proposed Project due to the fewer number of
residential units. This reduction would be partially offset by water demand associated with the
office, retail/commercial, library, and public park uses under this alternative. Because LADWP
has determined that adequate water supplies would be available to serve the Project, it is
reasonably inferred that the same would be true with respect to the reduced demand for water
under this alternative. Thus, as with the Proposed Project, the alternative would result in a less
tha'n significant impact to water supplies, and less than the Project.
• Utilities and Service Systems -Wastewater: The "Mixed Use" alternative would generate
slightly less wastewater than the Proposed Project due to the fewer number of residential units.
This reduction would be partially offset by wastewater generated from the office,
retail/commercial, library, and public park uses under this alternative. Because sufficient
wastewater treatment capacity at the TIWRP exists for the larger Project wastewater generation, it
can therefore be reasonably concluded that sufficient treatment capacity for the reduced demand
under this alternative would also be available. Therefore, impacts would be less than those under
the Project and, as with the Project, would be less than significant. Similarly, given that the total
amount of wastewater generated by this alternative would be less than the Project, impacts with
regard to wastewater conveyance would be less than significant and less than the impacts under
the Project.
• Utilities and Service Systems -Solid Waste: The amount of solid waste generated during
demolition and site preparation would be approximately the same as that generated by the
Proposed Project during the same stages of construction. Solid waste generated during home
construction under the "Mixed Use" alternative would be somewhat less than that associated with
the construction of the Proposed Project due to the reduced total square footage to be developed.
As such, and similar to the Project, the landfills would have adequate capacity to accommodate
the average daily construction waste generated over the multi-year construction period, and
construction-related solid waste impacts would be less than significant. This alternative would
generate slightly less solid waste during Project operation than the Proposed Project due to the
fewer number of residential units. This reduction would be partially offset by solid waste
generated from the office, retail/commercial, library, and public park uses under this alternative.
As such, and as with the Project, area landfills would have adequate capacity to accommodate the
daily operational waste generated by this alternative. Operational solid waste impacts would be
less than significant and slightly less than with the Proposed Project.
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• Utilities and Service Systems -Energy: Similar to the Proposed Project, the "Mixed Use"
alternative would require a line extension from the existing off-site lines to the premises, on-site
transformation facilities, and conduit and cable throughout the property. The alternative itself
would not require new (off-site) energy supply facilities and distribution infrastructure.
Electricity and natural gas consumption at the Project Site is anticipated to be essentially
equivalent to that of the Proposed Project. Therefore, as with the Project, it is anticipated that
LADWP's existing and planned electricity capacity and electricity supplies would be sufficient to
support the alternative's electricity consumption. Similar to the Proposed Project, impacts related
to natural gas would be less than significant.
To summarize the impacts of the "Mixed Use" alternative site plan in comparison to those of the
Proposed Project (Alternative C in the Draft EIR), this alternative has the potential to reduce or avoid the
following significant impacts:
• Regional operational air emissions
• Exterior noise at some Project residences
• Traffic (daily vehicle trips only)
The "Mixed Use" alternative would not have the potential to reduce or avoid the Proposed Project's
potential impacts involving regional and local construction-associated air emissions, potential impacts on
nesting birds and/or roosting bats during construction, impacts to jurisdictional resources on-site,
potential impacts to archaeological and/or paleontological resources, potential impacts relating to
hydrocarbon-impacted soils, disturbance of asbestos-containing materials (ACMs) and lead-based paint
(LBP) that are present in the existing abandoned structures on-site, construction-related noise and
groundborne vibration, significant traffic impacts at study intersections, and potential traffic impacts
associated with the installation of water service infrastructure. Other impacts associated with the Project,
although less than significant, would be either equivalent or reduced to some degree under this alternative
due to the fewer number of residences that would be developed on-site.
Feasibility
As discussed at the start of this topical response, under CEQA, alternatives to a project that are evaluated
in a Draft EIR must be feasible to develop. With respect to the "Mixed Use" alternative site plan that has
been requested by numerous commenters on the Draft EIR, nothing would physically prevent the
alternative from being developed at the Project Site. Therefore, the determination of its feasibility is
limited to its ability to produce a positive return on investment to the Applicant. In order to evaluate the
economic feasibility of the "Mixed Use" alternative, a study was prepared by The Concord Group
(attached as Appendix B) in June 2013. The study concludes that the "Mixed Use" alternative
(Alternative 2 in the Concord Group report) would be economically infeasible to develop due to the
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substantial level of fixed costs associated with infrastructure and land that remain largely the same
irrespective of the total number of lots developed at the site.26 In addition, the "Mixed Use" alternative
would donate acreage on-site to the Los Angeles Public Library for construction of a neighborhood
branch library and, thus, would return no economic value to the Applicant. Recently reviewed vacancy
reports for the area surrounding the Project Site indicate that 1,073,992 square feet of available (vacant)
office space exists within a five-mile radius of the Site and that 166,675 square feet of available (vacant)
retail space exists within a two-mile radius of the Site. These figures represent a relatively large amount
of vacant office and retail space and would likely present challenges to developing economically viable
commercial and retail uses at the Project Site. Given the realities of the current residential, office, and
retail real estate market, it is estimated that development of the "Mixed Use" alternative at the Project Site
would result in a loss of approximately $37 million.2 7
Conclusions
CEQA requires that a Draft EIR identify an "environmentally superior alternative". Section VI.D of the
Draft EIR contains this discussion and concludes that Alternative C (the reduced density alternative that
now represents the Applicant's preferred project) is the environmentally superior alternative among the
development alternatives that were evaluated. Although the "Mixed Use" alternative discussed in this
topical response was not included in the Draft EIR, it would, as discussed above, marginally reduce some
of the Project's less than significant impacts and would reduce the Project's significant, unmitigated
operational air quality impact. Thus, an argument could be advanced that the "Mixed Use" alternative
could be the environmentally superior alternative. However, as noted previously, CEQA requires that the
range of alternatives evaluated in a Draft EIR be feasible to develop. As has been shown above, the
"Mixed Use" alternative would not be economically feasible to develop at the Project Site.
Because the "Mixed Use" alternative is economically infeasible, therefore, it is not the environmentally
superior alternative and will not be added to the EIR.
26 Ibid.
27 Ibid.
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Excerpts from FEIR for Ponte Vista project:
Response to Comments -Rancho Palos Verdes (Section 111.B)
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Comment No. A7-3
MTA's Response to the Notice of Preparation
There is no indication in the Draft BIR or its appendices that the lead agency received MT A's response to
the Notice of Preparation for the proposed project. The letter is dated November 10th, 2010 and is
attached for you reference.
If you have any questions regarding these comments, please contact me at 213-922-2836 or by email at
· hartwells@metro.net. Please send the Final EIR to the following address:
MT A CEQA Review Coordination
One Gateway Plaza MS 99-23-2
Los Angel~s, CA 90012-2952
Attn: Scott Hartwell
Response to Comment No. A7-3
The comment notes that Metro provided a comment letter in response to the Notice of Preparation
circulated for the Proposed Project in November 2010 but correctly states that this letter was not included
or referenced in the Draft EIR. This was an inadvertent omission and has been corrected in this Final
EIR. The comments raised in the November 2010 NOP Response from Metro were considered in the
preparation of the Draft EIR.
Appendix I-2 of the Draft EIR has been revised to include the November 10, 2010 NOP response letter
from Metro (see also Section IV, Corrections and Additions to this Draft EIR).
LETTER NO. AS -CITY OF RANCHO PALOS VERDES
City of Rancho Palos Verdes
Kit Fox
Senior Administrative Analyst
30940 Hawthorne Blvd.
Rancho Palos Verdes, CA 90275-5391
Comment No. AS-1
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the Notice of
Availability/Completion (NONC) for the above-mentioned project. The City respectfully offers the
following comments on the content and analysis of the Draft EIR (DEIR) for the proposed project:
1) From the outset, the City of Rancho Palos Verdes would like to take this opportunity to remind the
City of Los Angeles that the purpose of an EIR is to disclose and describe the environmental impacts of a
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proposed project in a logical and concise manner so that decision makers are able to make fully informed
decisions before taking action on the proposed project in question. In the case of this BIR, however, it is
clear that the project proponent has no intention of building or seeking entitlements to build the so-called
"proposed" project, but instead intends to pursue Alternative C, as described in Section VI of the DEIR.
Nevertheless, thousands of pages of descriptions, diagrams, analyses and technical appendices are
expended on the "proposed" project in the DEIR, while fewer than one hundred fifty (150) pages at the
back of the DEIR are devoted to the analysis of all four (4) project alternatives combined. We appreciate
that the project proponent's decision to abandon the "proposed" project in favor of 830-unit Alternative C
or 1,135-unit Alternative D may have been in response to significant geotechnical issues that were
identified on the site after the initial circulation of the Notice of Preparation (NOP) in October 2010.
However, at that point, the project description should have been revised to address these changed
circumstances and the NOP recirculated. Instead, we are now presented with a DEIR that includes a
minutely-qetailed analysis of a "proposed" project that the project proponent has no interest in pursuing,
and superficial analyses of the "real" project proposal (i.e., Alternative C or D). Therefore, before we
comment in more detail on the DEIR as presented, the City of Rancho Palos Verdes wishes to go on
record as requesting that the DEIR be completely re-written with either Alternative C or Alternative D as
the "proposed" project accompanied by appropriately re-written descriptions, diagrams, analyses and
technical appendices and re-circulated for a new public review and comment period.
Response to Comment No. AS-1
The comment asserts that the Project Applicant has no intention of building the original 1,135-unit
version of the Proposed Project that was evaluated in the Draft BIR. As is discussed in Section I,
Introduction, of this Final BIR, the Project Applicant decided to replace the original version of the
Proposed Project with the reduced density 830-unit version that was evaluated in the Draft BIR as
Alternative C following the close of the public comment period on the Draft BIR and in response to the
public comments received. Prior to that, the Project Applicant had indicated that the preferred Project
was one that included 1,135 units, as discussed on page 11-1 of the Draft BIR. As presented on Table Vi-
l in the Draft BIR, the residential product types in both the original 1,135-unit plan and the reduced 830-
unit plan are very similar, with the only significant difference being in the number of units proposed. The
two site plans are largely the same, with the primary differences being the presence of the seismic setback
across the central portion of the site and the elimination of the proposed public park. These differences
between the two plans were evaluated in detail in Section VI (Alternatives to the Proposed Project) of the
Draft BIR. In all other areas, the impacts of the smaller 830-unit Alternative C were reviewed and found
to be either the same or less than those that would result from the larger 1,135-unit Proposed Project.
Thus, there is no requirement or justification for completely revising and recirculating a new Draft BIR,
as the comment suggests. All of the impacts associated with the current version of the Proposed Project
(Alternative C in the Draft BIR) were fully evaluated and disclosed in the Draft BIR, with appropriate
mitigation measures identified.
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With respect to the "significant geotechnical issues" cited by the comment, as noted on page IV.F-5 of the
Draft BIR, a splay of the Palos Verdes Fault was determined to cross the central portion of the Project Site
during the geotechnical investigation work for the BIR. Due to the uncertainty over the nature of this
fault splay and, in particular, its degree of activity, the Lead Agency conservatively treated the fault splay
as potentially active, classified the resulting impact as significant, and imposed Mitigation Measure GB0-
1 requiring the inclusion of a 50-foot wide structural seismic setback zone along the fault splay. In order
to evaluate any additional level of environmental impact that might be associated with the implementation
of this mitigation measure, Alternative D was added to the Draft BIR to study how the modified site plan
. could be developed while still retaining the original number of proposed residential units. According to
the Project Applicant, the decision to reduce the overall Project from 1,135 to 830 units was made
subsequent to and completely apart from the discovery of the fault splay. Regardless, the potential
environmental impacts of the original 1,135-unit project, the 1,135-unit plan incorporating Mitigation
Measure QB0-1, and the reduced density 830-unit current Proposed Project were each fully evaluated in
the Draft BIR.
CBQA Section 21092.1 and CBQA Guidelines Section 15088.5 provide the triggers for recirculation,
which fall into three general categories: (1) new or substantially more severe significant, unavoidable
impacts; (2) new, feasible mitigation, considerably different from the Draft BIR, that a project proponent
refuses to adopt; and (3) a Draft BIR so conclusory or otherwise inadequate that it precludes meaningful
public comment. The designation of either Alternative C or D as the "proposed Project" is not sufficient
to trigger a need to recirculate the Draft BIR since both alternatives were fully evaluated in the document
and the public was afforded an opportunity to review and comment on these evaluations. Recirculation is
the exception, rather than the rule. The purpose of public review and comment on Draft BIRs is "not to
promote endless rounds of revision and recirculation." Save Our Peninsula Assn. v. County of Monterey,
87 Cal. App. 4th 99 (2001).
Comment No. A8-2
2) The City respectfully takes exception with some of the "important planning issues" purportedly
addressed by the "proposed" project (pp. 1-8 to 1-9):
a) The introduction states that the "site's size and relative physical isolation make it possible to
avoid or reduce many of the typical 'adjacency' impacts that result from infill development."
While the proposed project may be remote from the developed areas to the north and east by
virtue of the adjacent Defense Fuel Support Point San Pedro, no comparable buffer is provided
from the adjacent neighborhoods in San Pedro to the south or Rancho Palos Verdes to the west.
Response to Comment No. A8-2
The Draft BIR citation notes that the Project Site offers "relative physical isolation" with respect to
surrounding residential land uses. The Project Site is buffered from development to the west by Western
Avenue, a 94-foot-wide State Highway (including sidewalks) carrying 35,000 vehicles per day.
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Additionally, Project buildings would be set back between 18-80 feet from Western Avenue along the
site's western frontage, further separating the Project from single-family uses located in the City of
Rancho Palos Verdes across Western A venue. Although there is no existing buffer between the Project
Site and existing residential buildings to the south, the Project would include a landscaped perimeter trail
and open space system surrounding the entire site. The Project's residential buildings would also be set
back up to 80 feet from the Project Site's southern property line with the aforementioned perimeter open
space serving as a buffer between the developments. Additionally, densities would be modulated across
the Project Site, with the highest densities occurring adjacent to, and consistent with, multi-family
development immediately south of the Project Site. As acknowledged by the comment, the Defense Fuel
Support Point provides significant buffering to the north and east. The Project Site is unique because
typical infill development projects do not offer this amount of buffering. Because the site is relatively
isolated, the impacts on surrounding residential uses will be diminished or avoided as compared to more
typical infiJl projects.
Comment No. AS-3
b) Furthermore, the introduction asserts that the increased residential density proposed is
necessary to meet regional housing needs, and notes that the project site is located near "the Ports
of Los Angeles and Long Beach, which are among the region's largest employers." However, as
far as we can tell, the "proposed" project includes absolutely no provisions to ensure that any of
the proposed housing units would be made affordable or accessible to Port or Port-related
employees, other than by virtue of mere physical proximity.
Response to Comment No. AS-3
The environmental impact analysis of the Draft BIR does not make assumptions about particular locations
where Project residents would in fact be employed. Rather, the Draft EIR states that the Project is
consistent with City and regional planning policy objectives to add housing to locations with employment
opportunities, and that the general vicinity of the Project, including the Ports of Los Angeles and Long
Beach, is one of the region's major job centers. Current regional planning policies, including but not
limited to air quality and transportation planning, are based on the assumption that if housing
opportunities are located closer to employment centers, commuting distances (and vehicle miles traveled)
will tend to be reduced and urban sprawl will tend to be discouraged. As discussed in the Draft BIR,
while the South Bay area has been one of the region's most significant and growing employment centers,
comparatively little new housing has been added to the Wilmington-Harbor City Community Plan area in
the past several years. As discussed in the Draft BIR, by providing 1,135 new dwelling units (830 units in
the currently Proposed Project) across a spectrum of prices and unit configurations on an infill site that is
close to some of the region's major job centers, the Project provides opportunities for residents and local
employees to avoid long-distance commutes to other locations and is consistent with widely accepted
local and regional planning policies designed to encourage more efficient growth patterns.
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Comment No. AS-4
3) The City appreciates that a much more comprehensive assessment of the aesthetic impacts of the
"proposed" project was conducted in the current DEIR than was the case for the previous 2,300-unit
proposal in 2007. This included the acknowledgement that adverse impacts upon views characterized by
manmade features such as those that occur in and around Los Angeles Harbor are potentially significant.
Views of the Harbor area -especially at night -are a prominent visual feature of Rancho Palos Verdes
neighborhoods along Western A venue, and the City of Rancho Palos Verdes frequently considers (and
protects) city-light views of the harbor when considering development proposals. ·unfortunately, the
DEIR dismisses adverse impacts to views from private property in the City of Rancho Palos Verdes as
less than significant. This includes views from Green Hills Memorial Park and from homes in the Rolling
Hills Riviera neighborhood on the west side of Western Avenue. The City of Rancho Palos Verdes takes
this opportunity to formally object to this assessment.
Response to Comment No. AS-4
The Draft EIR evaluates views from private property surrounding the Project Site beginning on page
IV.B-7. Views from private vantage points, including those within the City of Rancho Palos Verdes on
the west side of Western Avenue, are described for both the existing condition and the future with-Project
condition. The likely impacts to these views are disclosed in the Draft EIR beginning on page IV.B-45.
As is stated in the Draft EIR, neither the CEQA Guidelines nor the City's CEQA Thresholds Guide
consider changes to private views to be significant impacts. Project impacts to views from both Green
Hills Memorial Park and individual homes within the Rolling Hills Riviera neighborhood are described,
and in the case of the former location, simulated in the Draft EIR (see Figure IV.B-17). It is not possible
to individually assess the Project's impact to views from each private parcel surrounding the site, nor do
City planning policies and ordinances explicitly protect views from privately owned properties. CEQA
does not require analysis of impacts to specific people, only on the environment, and the Draft EIR
properly focuses on public views, including those from potentially affected neighborhoods. Thus, the
evaluation of the Project's impacts on views as presented in the Draft EIR was presented in accordance
with the requirements of CEQA and City policy. The Draft EIR does not merely "dismiss" the impacts
referenced in the comment. To the contrary, they are discussed in the document. Many of the available
views are fleeting and would not be substantially obscured by the Project. Nonetheless, the comment's
objection to this methodology is acknowledged for the record and will be forwarded to the decision-
making bodies for their review and consideration.
Comment No. AS-5
We also offer the following specific comments on Section IV.B (Aesthetics):
a) There are repeated references in Section IV.B to homes on "Palondra Drive" in Rancho Palos
Verdes. There is no such street in the City, and we are unsure what homes the DEIR is referring
to.
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Response to Comment No. AS-5
The references in the Draft EIR to Palondra Drive were made in error; the street being referred to is
correctly known as Palmeras Place, which is a signed street located immediately adjacent and parallel to
Western Avenue on its west side, connecting Redondela Drive to Avenida Aprenda. It is a short street
that is separated from Western A venue by a small landscaped median containing a bus stop. The street
extends south of A venida Aprenda for a short distance before it ends in a cul-de-sac. A total of four
single-family homes within the City of Rancho Palos Verdes with direct driveway access from Palmeras
Place currently have direct views of the southwestern corner of the Project Site.
The following revisions have been made to the Draft EIR to correct this error (see also Section IV,
Corrections and Additions to the Draft EIR):
On page IV.B-19 in Section IV.B (Aesthetics), replace all references to "Palondra Drive" in the
fourth paragraph with "Palm eras Place".
On page IV.B-20 in Section IV.B (Aesthetics), replace the reference to "Palondra Drive" in the
last paragraph with "Palm eras Place".
On page IV.B-48 in Section IV.B (Aesthetics), replace the reference to "Palondra Drive" in the
first partial paragraph with "Palmeras Place".
Comment No. AS-6
b) The description of private viewing areas in Rancho Palos Verdes (pp. IV.B-19 to IV.B-20)
identifies two (2) neighborhoods on the west side of Western Avenue to the south of Green Hills
Memorial Park that overlook the project site. In fact, there is only one (1) residential
neighborhood in this area, which is known as Rolling Hills Riviera
Response to Comment No. AS-6
The description in the Draft EIR that is referred to by the comment is intended to communicate the fact
that elevations within the neighborhood the comment refers to as the Rolling Hills Riviera relative to the
Project Site are substantially different north of A venida Aprenda. This is an important fact to consider in
the assessment of both the existing viewshed and potential Project effects on views from these areas. The
two areas may be part of the same neighborhood for the purposes of the City of Rancho Palos Verdes, but
they will experience different effects on views of and over the Project Site as a result of the Proposed
Project.
Nonetheless, the following clarifying revisions have been made to the fourth and fifth paragraphs on page
IV.B-19 of the Draft EIR (see also Section IV, Corrections and Additions to the Draft EIR):
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+we-A_single-family residential areas neighborhood within the City of Rancho Palos Verdes
known as Rolling Hills Riviera is aFe located on the west side of Western Avenue, across from
the Project Site, and to the south of Green Hills Memorial Park. For purposes of this analysis, the
Rolling Hills Riviera neighborhood can be divided into two parts based on their respective
elevations relative to the Project Site. The first of these neighborhoods areas is located along
Redondela Drive, Palondra Drive, Palmeras Place, Tarrasa Drive, and Avenida Feliciano and is
situated at a lower elevation than either Green Hills to the north or the adjacent neighborhood
portion of the Rolling Hills Riviera neighborhood to the south. Views of and across the Project
Site from this neighborhood area are limited due to the north-south orientation of most of the
homes and the low elevation of the area. A few homes along the east side of Tarrasa Drive and
Palondra Drive Palmeras Place border Western A venue and thus would have partial direct views
of the Site's western frontage. These views are blocked to some degree by the embankment
alo~g which Western Avenue ascends the slope to the north. Where the Project Site is visible,
views largely consist of the chain-link fence along its Western A venue frontage, scattered trees,
and portions of the abandoned duplexes. A few homes along Palondra Drive Palmeras Place have
limited views of the riparian vegetation on-site. No views across the Project Site to areas beyond
are available from this neighborhood lower elevation portion of the Rolling Hills Riviera
neighborhood.
The second neighborhood part of the Rolling Hills Riviera neighborhood to be considered is
located west of Western Avenue and south of the Redondela/Feliciano neighborhood area
discussed above. This neighborhood is Homes in this area are located on a sloping hillside along
A venida Aprenda and Pontevedra Drive and is are situated at a substantially higher elevation
(between 200 and 375 feet above sea level) than the Project Site (approximately 180 feet above
sea level). Although most of the homes in this neighborhood area are oriented north-south and
therefore do not directly overlook the Project Site, the backyards of some homes along
Pontevedra Drive and the lower portion of A venida Aprenda have direct northeasterly views of
and across the Project Site. These views include the riparian vegetation on-site as well as
portions of the abandoned housing complex. To the north, the hillside along the Site's northern
boundary with the DFSP is visible as a low ridgeline. Due to topography, no views north onto
the DFSP itself are available from this area. Views to the east across the Project Site to the
harbor area are not generally available from homes in this neighborhood area due to their
principal north-south orientation as well as to the visual blockage provided by the Seaport Homes
and Casa Verde Apartment complexes adjacent to the Site's southern boundary. A representative
view from this portion of the Rolling Hills Riviera neighborhood is shown in Figure IV.B-12.
Comment No. AS-7
c) The "before-and-after" photographic simulations included in Section IV.B -which we find to
be crude, at best -should be placed closer to one another in the DEIR so as to make it easier for
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readers to compare the photos and draw their own conclusions. In the current DEIR, these
"before-and-after" images are separated by two (2) dozen or more pages of text.
Response to Comment No. A8-7
The comment does not state a specific question regarding the adequacy of the Draft EIR in identifying
and analyzing the environmental impacts of the Project. However, the comment does suggest that the
Draft EIR could be made more user-friendly by reordering the placement of the figures in Section IV.B,
Aesthetics. As such, the comment is acknowledged for the record and will be forwarded to the decision-
. making bodies for their review and consideration.
Comment No. A8-8
4) W~ were surprised to learn (as, we suspect, was the project proponent) of the existence of a
subsurface fault crossing the subject property, as described in Section IV.F (Geology & Soils). As
mentioned above, we appreciate that this discovery drove changes in the site plans of the project
alternatives so as to protect future residents, resulting in the designation of a 100-foot-wide seismic
setback zone (Mitigation Measure GE0-1 ). However, we believe that the discovery of this issue should
have resulted in complete reconsideration of the description of the "proposed" project and recirculation of
the DEIR, as described above in Comment 1.
Response to Comment No. A8-8
See Response to Comment A8-1. It should also be noted that, because the fault splay was discovered
during preparation of the Draft EIR, no new information in addition to that which was provided in the
Draft EIR has been presented.
Comment No. A8-9
5) We have several comments with respect to the assessment of Hazards and Hazardous Materials in
the DEIR (Section IV.H):
a) Section IV.H describes the health risk assessment (HRA) conducted in relation to toxic air
contaminant (TAC) emissions from several industrial sources near the project site (i.e., DFSP,
ConocoPhillips and the Port of Los Angeles). However, we were surprised to read that among
the sites that were not included in the HRA was the Rancho LPG facility at North Gaffey Street
and Westmont Drive (p. IV.H-25). This omission is of particular concern due to recent
incidences of TAC emissions (i.e., leaks) at both ConocoPhillips (September 2012) and Rancho
LPG (October 2012), both of which we understand are under investigation by the AQMD.
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Response to Comment No. AS-9
The comment's reference to the Rancho LPG facility appears to be with respect to a health risk
assessment (HRA) for routine, operational toxic air contaminant (TACs) emissions (see Draft EIR, page
IV.H-5). As noted in the Draft EIR, the Rancho LPG facility was not included in the HRA conducted for
the Ponte Vista Project Site due to the comparatively small quantity of its emissions relative to the nearby
ConocoPhillips refinery (see Draft EIR, page IV.H-31). It was determined that including documented
TAC emissions from the Rancho LPG facility in the HRA for the Project Site would not increase either
. the chronic or acute hazard indices for the site appreciably closer to the significance thresholds for cancer
risk. For this reason, the Rancho LPG facility was excluded from the HRA.
The comment also references recent leaks at the ConocoPhillips and Rancho LPG facilities; leaks, it
should be noted, that apparently occurred at approximately the same time the Draft EIR was being
published for public review. These leaks, however, are not the same as the types of operational TAC
emissions that are evaluated in HRAs and which were considered in the HRA conducted for the Project
Site. Hazardous material spills and chemical releases from process upsets such as leaks or accidental
spills are a different category of risk and are addressed in Section IV.H (Hazards and Hazardous
Materials) of the Draft EIR at pages IV.H-15-16, 21, 25, 33, 36-39, 42, and IV.J-17. See also Topical
Response 4 with respect to the Rancho LPG facility. Although the effects of these facilities were
described in the Draft EIR for informational purposes, they represent impacts of the environment on the
Project and are not, therefore, required for analysis and mitigation (see Topical Response 3).
Comment No. AS-10
b) The analysis of off-site releases of hazardous materials notes that an independent risk-of-upset
hazard analysis was performed in relation to the DFSP and ConocoPhillips, but not Rancho LPG.
Given the high level of public concern about the Rancho LPG facility in recent years, we believe
that it would have been most prudent to include all three (3) of these facilities in the independent
risk-of-upset hazard analysis.
Response to Comment No. AS-10
The comment is incorrect in his statement that no risk of upset hazard analysis was presented in the Draft
EIR with respect to the Rancho LPG facility. The analysis of potential releases of hazardous materials
from the Rancho LPG facility is presented at pages IV.H-35 to -38 of the Draft EIR. See also Response
to Comment A8-9 and Topical Responses 3 and 4 for a discussion of this category of impacts as well as
of the Rancho LPG facility.
Comment No. AS-11
c) The DEIR concludes that the "proposed" project has no impact with respect to conflicts with
adopted emergency response plans, based (at least in part) upon an assertion that the City of
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Rancho Palos Verdes has not designated Western A venue as an emergency evacuation route
along the frontage of the project site (p. IV.H-41). The DEIR cites an exhibit in the Safety
Element of the Rancho Palos Verdes General Plan (Figure 39, Disaster Routes) that was not
updated after the Eastview area was annexed by Rancho Palos Verdes in 1983. However, the text
accompanying this exhibit notes that routes depicted on Figure 39 are conceptual and that the
designation of evacuation routes is found in the E~ergency Operations Plan (EOP) and Standard
Operating Procedures (SOP), not in the General Plan. Furthermore, the City of Rancho Palos
Verdes is currently updating its General Plan, and expects that Western A venue -the major north-
south arterial serving the Eastview area of the City -will be incorporated into the updated version
of Figure 39. As such, the City of Rancho Palos Verdes believes that the "proposed" project is
very likely to have an effect upon emergency response in the Eastview area of the City, and that
this effect should be analyzed in the DEIR.
Response to Comment No. AS-11
The evaluation of existing designated emergency evacuation routes in the Draft EIR was based on the
most current available information in existence at the time the NOP for the Project was circulated in the
fall of 2010. The screening threshold for potential impacts is whether a project would conflict with an
adopted emergency response plan. The comment acknowledges that Western Avenue is not identified as
an official emergency evacuation route on the relevant exhibit in the Safety Element of the City of
Rancho Palos Verdes' General Plan. Regardless of whether or not Western A venue is ultimately added to
this exhibit as an official emergency evacuation route, the Draft EIR evaluated the potential for the
Project to adversely impact the use of Western Avenue for emergency evacuation purposes (see page
IV.H-38 through IV.H-42, Draft EIR). The comment offers no evidence to support the assertion that the
Proposed Project is likely to have an effect upon emergency response in the City of Rancho Palos Verdes,
contrary to the conclusions of the Draft EIR. See also Topical Response 5 for a more detailed discussion
of emergency response.
Comment No. AS-12
d) Finally, notwithstanding the discussion on p. IV.H-18 of the DEIR, the City of Rancho Palos
Verdes believes that the project site is within a 2-mile radius of Torrance Municipal Airport
(TOA), so that the potential aircraft safety hazards posed for future residents should be assessed
in the DEIR.
Response to Comment No. AS-12
According to Google Maps, the Project Site is approximately 11,000 feet (direct line measurement) from
the Torrance Airport at their closest points of proximity, which is just over two miles. For this reason, the
Draft EIR did not include an analysis of the potential impact of the Project upon operations at Torrance
Airport. Nonetheless, the Project consists of residential buildings no taller than approximately 65 feet.
Such structures are of a comparable height to existing buildings in the immediate vicinity and would not
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represent a potential aircraft safety hazard due to both their low height and their distance from Torrance
Airport.
Comment No. AS-13
6) The discussion of Land Use/Planning impacts suggests that the "proposed" project is necessary to
meet a variety of perceived housing needs, even though the existing residential density of the project site
would be increased by more than four (4) times. We do not believe that the DEIR adequately
demonstrates the need for higher-density residential development on this site or in the surrounding
·community. In fact, we would point out that existing, unsold higher density developments located to the
south of the project site and in downtown San Pedro actually demonstrate that there is a glut of this type
of housing in the local market. The City remains concerned that a proposal for residential densities in
excess of eighteen (18) units per acre for this site will be out of character with the surrounding patterns of
development, both in Rancho Palos Verdes and Los Angeles.
Response to Comment No. AS-13
The comment raises concerns aboutthe Proposed Project's density and relationship to unidentified unsold
higher density developments located to the south of the project site (but which may refer to the
development known as Seaport Homes Community, located at 28000 South Western A venue) and in
downtown San Pedro. It is not the intent or responsibility of the Draft EIR to demonstrate the "need" for
higher-density residential development on the Project Site or in the surrounding community. Rather, the
purpose of the Draft EIR is to inform City decision makers and the public about the Proposed Project's
impact on the physical environment. As analyzed in the Draft EIR, the Project includes a range of
housing types, including 2-and 3-story single family homes, town homes, row houses and apartments,
which range in density from 11 units per acre to 34 units per acre. This housing mix is very different
from the one housing type (i.e., condos) situated in four "stacked flats" residential levels over podium
parking in the Seaport Homes development, which was developed at a density of about 75 units to the
acre. 5
Although it does not concern an impact on the physical environment, the fact that some existing
developments, including Seaport Homes, may have unsold units is not necessarily an indicator of a "glut"
of housing in the Wilmington-San Pedro area. Existing vacancies in particular buildings occur for many
reasons, including lack of demand for particular types or configurations of units, the asking purchase
price or rent of the units, available unit or building amenities, development location relative to off-site
amenities, among others. Due to data limitations at the time it was prepared, the Draft EIR reported total
residential vacancy rates (i.e., for the combination of for-sale and for-rent) only for the City of Los
Angeles (4.0%) and for the combination of the Wilmington-Harbor City and San Pedro Community Plan
5 Source: ZIMAS information available from the Dept. of City Planning Web site (bttp:/lzimas.lacitv.org), which
lists the Seaport Homes development as 136 units on a 1.81-acre site.
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areas (6.3%).6 These data reflect depressed housing market conditions resulting from the 2007-2009
Great Recession, and housing market conditions have generally improved since then. 7
Although it is not exactly the same vacancy measure as used by the U.S. Census Bureau, the percentage
of idle utility meters is often used as an indicator of monthly and annual residential vacancies. According
to the most recent data available, 3.7 percent of multi-family utility meters were idle in the generalized
"San Pedro" area of the City of Los Angeles as of December 2012. This percentage was lower than in
Central Los Angeles (4.2%), West Los Angeles (3.8%), and the City of Los Angeles as a whole (3.8%),
although higher than in the San Fernando Valley (3 .1%).8 These readings do not suggest an unusually
high vacancy rate in the Project vicinity that would reflect a "glut" of vacant units, as mentioned in the
comment.
The comment expresses an op1mon concerning the Project's design and its compatibility with the
characterof surrounding land uses in both the City of Rancho Palos Verdes and City of Los Angeles. The
compatibility of the Project with surrounding land uses is addressed in Section IV.J of the Draft EIR.
However, the comment is acknowledged for the record and will be forwarded to the decision-making
bodies for their review and consideration.
Comment No. AS-14
7) The analysis of Noise impacts in the DEIR (Section IV.K) concludes that there will be significant
and unavoidable exterior noise impacts of the "proposed" project upon certain project residences located
along the Western Avenue frontage of the site. We question ifthere may be similar, adverse exterior noise
impacts to existing residences on the west side of Western A venue in Rancho Palos Verdes that have not
been adequately addressed in the DEIR
Response to Comment No. AS-14
This comment misinterprets the operational noise impact statements for the Project in the Draft EIR. The
Project would not result in significant long-term operational noise generation impacts. Rather, as
proposed under the Project, the placement of sensitive land uses (Project residences) in a generally loud
urban location, such as the Project Site, was determined to be a significant and unavoidable impact.
Specifically, page IV.K-24 of the Draft EIR states:
With respect to placing future Project residences fronting Western Avenue, Table IV.K-
13 indicates that cumulative roadway noise levels at distances of 50 feet from the
6 See Draft EIR Appendix JV.L-1, Population and Housing Study, Table Ill-I, page 33.
7 See for example. Jim Puzzanghera, "Home prices up 9. 7% year-over-year in January, CoreLogic reports, "Los
Angeles Times, March 5, 2013 (available at: http://www.latimes.com/businesslmoney/la-fi-mo-home-prices-
corelogic-housing-20 I 30305, 0, 22 45458.story?track=rss).
8 Ibid.
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subregion (p. IV.L-22). However, the "proposed" project includes no assurances that any of the project's
2,923 new residents would be employed locally, nor that any of the project's 1, 13 5 new units would be
affordable to current employees of the Port or other nearby institutional or private employers.
Response to Comment No. AS-15
The comment presents an opinion about whether the project's unit counts and population would be
beneficial. The Draft EIR does not make assumptions about particular locations where Project residents
would in fact be employed. With respect to jobs-housing balance, the information presented in the Draft
· EIR (see p. IV.L-22), as noted in the comment, is measured at the scale of the City of Los Angeles
subregion, because that is the only geography for which there are existing adopted planning policies.
Given the scale of this subregion (i.e., the entire City of Los Angeles, the City of San Fernando, plus
various unincorporated areas and federal government property), it is reasonable to assume that most
employed Project residents would work within that geographic area. The wide range of housing types in
the Proposed Project, ranging from detached single-family to apartments and including both for-sale and
rental units, also indicates a range of housing prices that would be consistent with demand in the housing
market surrounding the Project Site. Unlike SCAG and its system of subregions, the City of Los Angeles
does not have any official policy with respect to jobs-housing balance within the City or any of its
Community Plan areas, including the Wilmington-Harbor City Community Plan. Accordingly, there is
no basis for making a significance determination with respect to the Project's impact on a "local" jobs-
housing balance. See also Response to Comment A8-3 for additional discussion of this topic.
Comment No. AS-16
9) The discussion of Public Services-Schools impacts concludes that, based upon LAUSD estimates,
sixty-eight (68) children residing in the "proposed" project are expected to attend Dodson Middle School
in the City of Rancho Palos Verdes at any given time (Table IV.M-8). Although LAUSD may represent
the Dodson campus as being well under capacity, it is the City's and the surrounding residents' actual
experience that the current level of enrollment at Dodson results in significant noise, traffic and other
nuisance impacts (i.e., trash, graffiti, etc.) in the surrounding Rolling Hills Riviera neighborhood. We
suspect that the addition of even sixty-eight (68) more students to the campus population will have
significant adverse impacts upon the Rolling Hills Riviera neighborhood.
Response to Comment No. AS-16
The comment presents concerns regarding existing neighborhood impacts associated with the operation of
the Los Angeles Unified School District's (LAUSD) Dodson Middle School and the potential of the
Project to exacerbate these impacts. According to the Draft EIR's analysis, sufficient capacity currently
exists at Dodson Middle School to accommodate the number of students estimated to be generated by the
Project. Thus, it is the responsibility of the LAUSD to operate Dodson Middle School in such a manner
as to ameliorate the types of impacts described by the comment, including noise, trash, graffiti, and
traffic. Any traffic or traffic-related noise impacts associated with Project-related student attendance at
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Dodson Middle School are included in the analysis of those environmental topics in the Draft BIR, as the
environmental baseline for these impacts includes current enrollment and use patterns at Dodson. The
"nuisance impact" allegations related to the behavior of 68 students (e.g., noise, trash, graffiti) are
speculative and therefore are not addressed in the Draft BIR. Further, given the relatively close proximity
of the Dodson Middle School to the Project Site, it is possible that some students would walk to school
rather than be transported in a private vehicle. Thus, the traffic generated by the middle school students
related to the Project is considered to be relatively minor. In conclusion, given the uncertainty of the
actual attendance location for Project-related middle school students, as well as the relatively small
number of vehicle trips generated by these middle school students, the Traffic Study in the Draft BIR
appropriately assigned the middle school related trips to the regional street system consistent with the
overall assignment of Project-related traffic. Nonetheless, the comment is acknowledged for the record
and will be forwarded to the decision-making bodies for their review and consideration.
Comment'No. AS-17
10) The discussion of Public Services-Recreation impacts concludes that the impact of the "proposed"
project will be less than significant as the result of the payment of Quimby fees to the City of Los
Angeles, and the provision of 4.1 acres of publicly-accessible parks and open space, and 16.5 acres of
private parks, landscaping and recreational amenities. The City of Rancho Palos Verdes respectfully
notes, however, that the nearest public park to the project site is Rancho Palos Verdes' Eastview Park,
located at 1700 Westmont Drive (Figure IV.M-4). The payment of Quimby fees to Los Angeles will do
nothing to offset impacts to nearby Rancho Palos Verdes park facilities from future project residents.
Furthermore, since Alternatives C and D no longer contain a public park, we believe that the project's off-
site recreational impacts will be significant and should be more fully assessed in the DEIR.
Response to Comment No. AS-17
The comment is correct to note that Eastview Park in the City of Rancho Palos Verdes is the closest
neighborhood park to the Project Site. The currently Proposed Project (830 units) would result in an
estimated population of 2,222 persons at the Project Site, as described on page VI~83 of the Draft BIR.
As presented in Table IV-10 of the Draft BIR, the current Proposed Project (830 units; Draft BIR
Alternative C) would contain 20.5 total acres of open space and recreational amenities, including 8.1
acres of dedicated park area and outdoor recreational spaces. The majority of this space would be
reserved for the use of Project residents and their guests, although pedestrian access would be provided to
the general public. Based upon the City's Public Recreation Plan neighborhood park area goals, the
Project would exceed its generated private (non-rental) neighborhood park need by 4.1 acres, but would
create a net unmet 0.3-acre demand for publicly accessible neighborhood park area.
Although the Project would provide other passive open space and landscaped common area amenities that
would bring the overall on-site open space acreage to 20.5 acres and would provide additional indoor
recreational amenities (fitness rooms, etc.) to residents of both the public and private portions of the
Project, it is likely that the majority of the Project-generated need for recreational facilities will be met
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on-site. Nonetheless, the Draft EIR acknowledges (at page VI-93) that the net unmet demand for publicly
accessible neighborhood park area would result in an increased demand at other neighborhood and
community parks within the surrounding area. It is not possible with any degree of certainty to ascertain
which specific parks this additional demand would affect, although it is likely that at least some of this
usage would occur at Eastview Park in the City of Rancho Palos Verdes.
The comment is correct that the payment of Quimby Fees and DUCT fees by the Project Applicant would
go to the City of Los Angeles for improvement of park areas throughout the City and would not
contribute to the improvement and/or expansion of park facilities in the City of Rancho Palos Verdes,
including Eastview Park. However, it is speculative to assume that future Project residents would use
Eastview Park for their recreation to such an extent that the park would suffer from overcrowding. If the
City of Rancho Palos Verdes believes that residents of the City of Los Angeles, both now and in the
future, are using its park and recreational facilities to such an extent that they are being degraded, the City
has the ability to limit such usage by restricting use of its facilities to residents of Rancho Palos Verdes.
Nonetheless, the comment is acknowledged for the record and will be forwarded to the decision-making
bodies for their review and consideration.
Comment No. A8-18
I I) The discussion of Transportation and Traffic impacts (Section IV.N) raises several issues of
concern to the City:
a) Vehicular access to and from Mary Star of Sea High School will be maintained through the
project site, but will be shifted from its current access point at the Green Hills Drive intersection
to the A venida Aprenda intersection. A queue analysis needs to be conducted to justify the
appropriate increase to the existing left-tum pockets on Western Avenue at the Green Hills Drive
and A venida Aprenda intersections.
Response to Comment No. A8-18
Project Design Features are described beginning on Page IV.N-46 of the Draft EIR. As noted on Page
IV.N-47 of the Draft EIR, the length of the southbound left tum pockets on Western Avenue at
intersections serving the Project Site would be modified as needed based on the forecast left-tum
movement. Note that the final design of the left-tum pockets will be determined as part of the permit
process related to construction of the improvements.
Comment No. A8-19
b) The project is proposing left-tum signal phasing at the intersections of Western Avenue at
Green Hills Drive and A venida Aprenda as a project feature. Prior to approval, the applicant
must provide justification for appropriate left-tum phase sequencing to maximize operational
benefits while minimizing safety impacts.
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Response to Comment No. AS-19
See Response to Comment A8-18 regarding Project Design Features. Left turn phasing is not required at
the Western A venue intersections serving the Project Site, but is proposed as a project feature. Design
issues such as timing and sequencing are determined as part of the permit process related to the
construction of the improvements.
Comment No. AS-20
c) On page 55 of the traffic study, the reports states that certain improvements have been
implemented along Western A venue as a result of the Western Corridor Improvement Project
Plan. To date, none of the improvements, as recommended by this study, have been
implemented.
Response to Comment No. AS-20
Pages IV.N-14 and IV.N-15 of the Draft EIR describe the Western Avenue Task Force. As noted in the
Draft EIR, the recommendation in the Western Avenue Task Force report to coordinate and synchronize
traffic signals along Western Avenue has already been completed.9
Comment No. AS-21
d) Removal of the raised concrete median at various intersections along Western A venue poses a
huge safety concern. There is existing evidence of operational issues at many of these
intersections, especially the left-tum movements. Removing the raised concrete median nose
opens the opportunity for other safety-related concerns. Please provide an alternative to striping
for safety purposes.
Response to Comment No. AS-21
The comment refers to mitigation measures TRANS-5, TRANS-8 and TRANS-9 described on pages
IV.N-161 and IV.N-162 of the Draft EIR. The comment does not provide or reference the "evidence" of
existing operational issues at these intersections associated with left-tum movements, nor how removal or
modification of the medians would adversely affect these conditions. Note that the final design of the
left-tum lanes, including modifications of the raised medians, is to be determined as part of the permit
process related to construction of the improvements.
For TRANS-8 (Western Avenue/Westmont Drive) and TRANS-9 (Western Avenue/Capitol Drive), the
concept plans of the recommended traffic mitigation measures contained in the Traffic Study appendices
indicate a removal of the existing raised median on Western Avenue, but provide a four-foot wide "nose"
on both the north and south legs of Western Avenue adjacent to the left-tum lane, which may be utilized
9 Caltrans, District 7, "Inside Seven", April 2013 issue.
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as a striped median, or a raised concrete median. The final design of the median noses (i.e., striped or
raised concrete) at the affected intersections will be determined by Caltrans.
For TRANS-5 (Western Avenue/Palos Verdes Drive North), the concept plan in the Traffic Study shows
removal of the raised median on the south leg of the intersection. If required by Caltrans, a raised median
could be provided through modification of travel lane widths.
Comment No. AS-22
e) The City is concerned about the retention of the wide northbound No. 2 lanes that invite
motorists to create a third travel lane. With the project distributing and attracting approximately
60% of the project trips from the north and approximately 30% of project trips from the south
along Western A venue, there is a potential for many vehicles to attempt to avoid the traffic in the
striped travel lanes and utilize the wide shoulder area to create a third lane. This pattern exists
today.
Response to Comment No. AS-22
The comment appears to assert that the existing physical condition of Western A venue south of the
Project Site facilitates the potentially unsafe and illegal use of the shoulder area as a de facto traffic lane.
Further, the comment appears to assert that the Project may lead to an increase in this undesirable
motorist behavior. See Topical Response 2 for a discussion of the analysis of traffic impacts due to the
Project as evaluated in the Draft EIR. For intersections along Western Avenue, the Draft EIR determines
either: 1) the Project-related impact is less than significant; or 2) the impact of the Project is significant,
but can be mitigated to less than significant levels based on implementation of the recommended
mitigation measures. In both cases, the effect of the Project on Western A venue intersections is such that
the levels of congestion that might induce motorists use the shoulder areas as traffic lanes would be no
different than pre-Project conditions, and therefore, it is reasonable to conclude that the Project would not
cause a noticeable increase in such undesirable behaviors. Although the Project improvements would add
a third travel lane to Western Avenue adjacent to the Project Site, the potential for motorists to utilize the
shoulder both north and south of the Site on Western Avenue would remain unchanged.
Comment No. AS-23
12) It is the City's understanding that the conveyance of wastewater from the "proposed" project will
be via a connection to the City of Los Angeles' sewer system within the right-of-way of Taper A venue (p.
IV.0-25), not via the former connection to the Los Angeles County Sanitation Districts' Western Avenue
Pumping Plant (WAPP) in the City of Rancho Palos Verdes. We presume that this will also be the case in
any of the alternatives to the "proposed" project. The City of Rancho Palos Verdes is concerned that any
proposal or alternative that might continue to utilize the former WAPP connection for this site could place
a burden upon the County sewer system that serves the City's residents.
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Response to Comment No. AS-23
See Response to Comment A2-l. As evidenced by the LACSD "will serve" letter (see Appendix C), the
existing LACSD facilities, including the adjacent WAPP facility, have adequate sewer conveyance and
treatment capacities to serve the Project (and each of the Project alternatives) should the Project Applicant
ultimately decide to utilize LACSD for wastewater service for the Project. At this time, however, the
Applicant intends for the Project to be served by City of Los Angeles Bureau of Sanitation sewer
conveyance and treatment facilities.
Comment No. AS-24
13) The DEIR identifies significant unavoidable impacts in the areas of operational air emissions and
construction-related air quality, noise and vibration impacts (p. V-1). Residents in Rancho Palos Verdes'
Rolling Hills Riviera neighborhood are likely to feel the brunt of these impacts, being the nearest single-
farnily residential neighborhood to the project site. It hardly seems equitable that the City of Los Angeles
will reap the benefits (if any) of the "proposed" project while the residents of the City of Rancho Palos
Verdes will be forced to live with its day-to-day impacts upon their lives.
Response to Comment No. AS-24
This comment incorrectly characterizes the Project's significant and unavoidable impacts. As
summarized on page V-1 of the Draft EIR, construction-related air emissions would be less than
significant. With respect to Project noise and vibration construction impacts on the Rancho Palos Verdes'
Rolling Hills Riviera neighborhood, it should be noted that construction-related noise and vibration
impacts would be a relatively short-term nuisance and would not have a long-term impact on the
neighborhood. Additionally, and contrary to the comment, residents of Los Angeles would also
experience such impacts on a short-term basis, as described in the Draft EIR. Mitigation Measures N0-1
to N0-8 would ensure that these impacts would be reduced to the maximum extent feasible.
The only off-site significant and unavoidable operational impact of the Project described in the Draft EIR
is regional air quality emissions. These emissions are primarily associated with the operation of mobile
vehicles, are typical for a residential project of this size, and there is no feasible mitigation to reduce these
emissions to a less than significant level. It should be noted that the significant and unavoidable
operational air quality emissions for the Project would exceed the SCAQMDs regional thresholds of
significance. Thus, these air quality emissions would be released over a large geographic area and
associated network of roadways. Localized automobile emissions generated by the Project were
evaluated at potential CO hotspot locations, including intersections near the Rancho Palos Verdes'
Rolling Hills Riviera neighborhood along Western Avenue. The Draft EIR concluded that localized CO
hotspot impacts would be less than significant for all sensitive receptors near the following studied
intersections: Western Avenue and Palos Verdes Drive North (Intersection No. 15), Western Avenue and
Peninsula Verde Drive (Intersection No. 16), and Western Avenue and Westmont Drive (Intersection No.
20). Thus, all studied intersections in the Draft EIR were determined to have less than significant impacts
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with respect to CO hotspots, and localized operational air quality impacts would be less than significant
for the Rancho Palos Verdes' Rolling Hills Riviera neighborhood.
Also, as described in Section I of this Final EIR, the Applicant is now proposing the development of
reduced density Alternative C, rather than the original Proposed Project, in response to public comments.
If Alternative C is ultimately developed rather than the Project, operational air quality impacts would be
reduced. Specifically, Alternative C would involve development of a project similar to the Proposed
Project on the site, however the total number of residential units would be reduced from 1,135 to 830.
Alternative C is expected to generate 5,788 trips during a typical weekday and 5,781 trips during a typical
Saturday, representing approximately 22 and 30 percent reductions (respectively) compared to the
original Project. Because Alternative C would generate fewer vehicle trips than the Project, it would also
generate fewer average daily emissions. As illustrated in Tables VI-5 and VI-6 of the Draft EIR, although
Alternative C would reduce air quality emissions and nearly eliminate the Project's ROG impact, regional
operational emissions would remain significant for Alternative C, although reduced compared to the
original Project.
Comment No. AS-25
The discussion of Alternatives to the Proposed Project (Section VI) raises several issues of concern to the
City:
a) As mentioned in Comment 1 above, the City of Rancho Palos Verdes is concerned that the
DEIR primarily analyzes the impacts of a "proposed" project that the project proponent is not
interested in pursuing, and provides only a cursory assessment of the developer's preferred
proposal(s) in the discussion of alternatives. We believe that this approach is needlessly
confusing and does not serve to improve the transparency of the development review process for
the Ponte Vista project.
Response to Comment No. AS-25
See Response to Comment A8-1 for a discussion of the format and analysis of the Project and alternatives
in the Draft EIR.
Comment No. AS-26
b) With respect to Alternatives A and B, the City of Rancho Palos Verdes is dismayed to learn
that it would be the project proponent's intent to revoke the access currently provided to Mary
Star of the Sea High School under these development scenarios. We believe that this simply a
mean-spirited attempt by the project proponent to diminish the feasibility and community
acceptance of these alternatives to the "proposed" project.
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Response to Comment No. AS-26
As noted in the Draft EIR (pages VI-8 and VI-13), the responsibility for securing vehicular access to
Mary Star of the Sea High School rests with the Archdiocese. The Project Applicant is under no
obligation to construct an improved, permanent access from Western Avenue across the Project Site for
the school. Alternative A in the Draft EIR is a no project, no development alternative, and the Applicant
is contractually obligated to remove all existing Navy-constructed improvements from the site, including
the street network. It is certainly possible under this alternative that Mary Star of the Sea High School
could enter some arrangement with the Applicant to secure the property needed for the access road;
however, this is not an obligation that has been placed on the property owner of the Ponte Vista site and
thus cannot be assumed as part of the no project, no development alternative.
With respect to Alternative B in the Draft EIR, the rationale for eliminating the access road is presented
on page VI-13. Inclusion of the access road would result in the elimination of approximately 30 single
family home sites from the site plan, which would further reduce the feasibility of an already potentially
economically infeasible (due to the estimated sale price of the homes) plan. For this reason, the access
road was eliminated from the alternative. As noted above, the Project Applicant is under no obligation to
provide the access.
Comment No. AS-27
c) With respect to Alternatives B, C and D, the City is similarly dismayed to learn that it would
be the project proponent's intent to eliminate the public park and other public-accessible site
amenities under these development scenarios. As mentioned above, we believe that the
elimination of the public park from the "proposed" project will have adverse impacts upon
Rancho Palos Verdes' Eastview Park.
Again, thank you for the opportunity to provide comments on this important project. If you have any
questions or need additional information, please feel free to contact me at (310)-544-5226 or via email at
kitf@rpv.com.
Response to Comment No. AS-27
The discovery of the potential geologic constraint to development across the central portion of the Project
Site made inclusion of the larger public park infeasible for Alternatives B, C, and D. Instead, Alternatives
C and D incorporate an approximately equivalent amount of park and open space area throughout the site.
Although most of this area would only be fully accessible to Project residents, each alternative does retain
the landscaped perimeter open space area that would include a walking/jogging path surrounding the
property. This area would be accessible to the general public. In addition, the interior park and open
space areas within the Project would be accessible to pedestrians. Due to the need to evaluate the effects
of Mitigation Measure GE0-5 on a development plan with 1,135 units, Alternative B could not feasibly
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provide an equivalent amount of public park and open space area. See also Response to Comment A8-l 7
for a discussion of the Project's parkland impacts.
LETTER NO. 09-CALIFORNIA DEPARTMENT OF TRANSPORTATION (CAL TRANS)
Department of Transportation
District 7, Office of Transportation Planning
IGR/CEQA Branch
Dianna Watson
IGR/CEQA Program Manager
100 Main Street, MS # 16
Los Angeles, CA 90012-3606
Comment.No. A9-1
The California Department of Transportation (Caltrans) has reviewed the Transportation and Traffic
section of the Draft Environmental Impact Report (DEIR) prepared for the proposed Ponte Vista
development. The proposed project consists of the development of a residential community comprised of
1,135 dwelling units featuring a combination of for-sale and rental single-family homes, duplexes,
townhomes, and flats. The proposed project site location is the former U.S. Navy San Pedro Housing
complex and is bordered by Western Avenue (State Route 213) to the west.
Response to Comment No. A9-1
This comment is an introduction and does not state a specific concern or question regarding the adequacy
of the Draft EIR in identifying and analyzing the environmental impacts of the Project. The comment is
acknowledged for the record and will be forwarded to the decision-making bodies for their review and
consideration.
Comment No. A9-2
Based on the traffic information included in the DEIR, we have the following comments: The proposed
project is estimated to generate approximately 7468 average daily weekday trips with 570 occurring
during the AM peak hour and 700 during the PM peak hour. As these trips are distributed and assigned to
the surrounding roadway network, they are projected to significantly impact various intersections along
Western Avenue (State Route 213) and Pacific Coast Highway (State Route 1). The traffic study report
recommends mitigation improvements on Western Avenue at the following intersections: Lomita Avenue
(TRANS-3), Pacific Coast Highway (TRANS-4 and TRANS 15), Palos Verdes Drive North (TRANS-5),
Peninsula Verdes Drive (TRANS-6), Fitness Drive (TRANS-7), Westmont Drive (TRANS-8), Capitol
Drive (TRANS-9), Summerland Avenue (TRANS-10).
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Excerpts from FEIR for Ponte Vista project:
Corrections and Additions to Draft EIR (Section IV)
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IV. CORRECTIONS AND ADDITIONS TO THE DRAFT EIR
INTRODUCTION
This section presents corrections and additions that have been made to the text of the Draft EIR. These
changes include revisions resulting from responses to comments and others that are necessary to provide
clarifications to the project description and analysis and to correct non-substantive errors. The revisions
are organized by section and page number as they appear in the Draft EIR. Text deleted from the Draft
EIR is shown in strikethrough, and new text is underlined. For corrections resulting from a response to a
. comment on the documents, references refer to the comment letter number and name of commenter.
Table of Contents
1. Page viii under List of Figures, revise the title of Figure VI-1 to read:
Figure VI-1, Conceptual Site Plan -Alternative B (No Projeet Alternativ:e/Single-
Family Homes) ......................................................................................................................... VI-11
Section I Introduction/Summary
2. Page I-7, the bottom paragraph is revised to read:
The discretionary land use approvals necessary for the Project include the following: (1) a
General Plan amendment; (2) a Zone Change and Specific Plan are proposed to provide zoning,
architectural, landscape and streetscape standards to guide the project's development (at
residential densities ranging from 11 dwelling units per acre to approximately 34 dwelling units
per acre, the project will fall within the City of Los Angeles' Low-Medium I, Low-Medium II and
Medium General Plan Land Use Designations)1; and (3) a Vesting Tentative Tract Map, and (4) a
Development Agreement. The project is anticipated to be completed within five years of the time
construction has commenced.
3. Page I-10 the paragraph under the heading "E. ALTERNATIVES" is revised to read:
In order to provide informed decision-making in accordance with Section 15126.6 of the CEQA
Guidelines, this Draft EIR considers a range of alternatives to the Project. The Draft EIR
analyzes the following alternatives: (A) No Project Alternative/No Development; (B) No Projeet
Alternative/Single-Family Homes; (C) Staff Recommendation/Reduced Density; and (D) Revised
By way of comparison, the City of Los Angeles' medium-density multiple family residential
zoning category, "R3", permits approximately 54 units per acre, while the City's lower density multi-family
residential category, "RU 1.5", permits approximately 28 units per acre.
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City of Los Angeles June 2013
Site Plan. Each alternative is described in full in Section VI, Alternatives to the Project, of this
DraftEIR.
4. Page 1-10 the heading and paragraph describing Alternative Bare revised to read:
Alternative B: Na Prajeet AlterB:ative/Single-Family Homes
Alternative B presumes that the Project Site would be redeveloped according to existing zooing
and General Plan designatioo allowed l:lses and densities in order to maximize the number of
single-family residences at the site. Taking site planning considerations into account, including
the required seismic setback, approximately 3 85 single-family homes could be developed on the
Project Site under the site's existing Rl zoning and Low Residential General Plan designation.
Such a site plan would require that the existing 9 .3 acres of Open Space zoning and land use
designation on the Project Site be eliminated. Alternative B would not include a 2.8-acre public
park or an access road to Mary Star of the Sea High School from Western A venue.
5. Table 1-1, Executive Summary of Project Impacts, Mitigation Measures, and Impacts After Mitigation
-The table's "Required Mitigation Measures" column will be modified to include the changes,
revisions, and additions of the mitigation measures identified below for Air Quality, Biological
Resources, Noise, and Transportation/Traffic.
Section II Project Description
6. Page 11-2, Table 11-1 is revised as follows:
5,6 Row Houses 516 0 262 262 ~23/27 5.9 1,320 2.5 Allev Loaded
7 Apartments 7 392 0 392 ~34 43.5 975 1.5 Walk-Up; Alley
Loaded
7. Page 11-17, the following is added to the end of the second full paragraph:
The Project would also provide an emergency access only lane connecting the new roadway
across the Site's southern portion with the southern property boundary adjacent to the off-site
Seaport Village development. All non-emergency vehicular access would be prohibited.
8. Figure 11-10, Proposed Land Use Plan, is revised to remove the text paragraph discussing the
Development Agreement under the heading "Requested Entitlements".
9. Page 11-34, the last full paragraph is revised as follows:
While the Project Applicant intends to complete Project construction by the end of 2017, it is at least
possible that the Project might not be completed until as late as 2027 due to the potential utilization of
extensions that are available to the Applicant through the Vesting Tentative Tract Map process. As
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City of Los Angeles June 2013
noted below, the Project Applicant requests approval of a Development Agreement (DA) which
would confer on the Project Applicant a vested right to develop the Project throughout the term of the
agreement. It is 6*pected that the DA would be approved in 2013 and that the term of the agreement
v10uld be for a period of 15 years, thus e1tpiring in 2027. Due to the possibility of an extended Project
buildout during the DA period, an "Extended Buildout Analysis" is addressed briefly under each of
the environmental issue discussions in Sections IV and VI of this Draft EIR for both the proposed
Project and the alternatives to the proposed Project.
. 10. Page II-37, the fifth bullet under the "F. Discretionary Actions" section heading is revised as follows:
• De·,zelopment Agreement bet\veen the project de'+reloper and the City of Los Angeles in order
to provide reasonable assurances and certainty to the developer concerning applicable
regulations while providing the City of Los Angeles with public benefits;
Section III Environmental Setting
11. Page III-2, the second footnote is revised as follows:
An "Extended Buildout Analysis" is also addressed throughout this Draft EIR in order to account
for the possibility that completion of the Project does not occur until as late as 2027, or the ending
year of the De>relopment Agreement being requested by the Project Applicant.
Section IV.B Aesthetics
12. In response to Comment Letter No. A8 (City of Rancho Palos Verdes), page IV.B-19, fourth and fifth
paragraphs are revised to read:
'.:fwe--A._single-family residential areas neighborhood within the City of Rancho Palos Verdes
known as Rolling Hills Riviera is are located on the west side of Western A venue, across from
the Project Site, and to the south of Green Hills Memorial Park. For purposes of this analysis, the
Rolling Hills Riviera neighborhood can be divided into two parts based on their respective
elevations relative to the Project Site. The first of these neighborhoods areas is located along
Redondela Drive, Palondra Dri·,zePalmeras Place, Tarrasa Drive, and Avenida Feliciano and is
situated at a lower elevation than either Green Hills to the north or the adjacent neighborhood
portion of the Rolling Hills Riviera neighborhood to the south. Views of and across the Project
Site from this neighborhood area are limited due to the north-south orientation of most of the
homes and the low elevation of the area. A few homes along the east side of Tarrasa Drive and
Palondra DrivePalmeras Place border Western A venue and thus would have partial direct views
of the Site's western frontage. These views are blocked to some degree by the embankment
along which Western Avenue ascends the slope to the north. Where the Project Site is visible,
views largely consist of the chain-link fence along its Western Avenue frontage, scattered trees,
and portions of the abandoned duplexes. A few homes along Palondra Dri·,zePalmeras Place have
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City of Los Angeles June2013
limited views of the riparian vegetation on-site. No views across the Project Site to areas beyond
are available from this neighborhood lower elevation portion of the Rolling Hills Riviera
neighborhood.
The second neighborhood part of the Rolling Hills Riviera neighborhood to be considered is
located west of Western Avenue and south of the Redondela/Feliciano neighborhood area
discussed above. This neighborhood is Homes in this area are located on a sloping hillside along
A venida Aprenda and Pontevedra Drive and is are situated at a substantially higher elevation
(between 200 and 375 feet above sea level) than the Project Site (approximately 180 feet above
sea level). Although most of the homes in this neighborhood area are oriented north-south and
therefore do not directly overlook the Project Site, the backyards of some homes along
Pontevedra Drive and the lower portion of A venida Aprenda have direct northeasterly views of
an~ across the Project Site. These views include the riparian vegetation on-site as well as
portions of the abandoned housing complex. To the north, the hillside along the Site's northern
boundary with the DFSP is visible as a low ridgeline. Due to topography, no views north onto
the DFSP itself are available from this area. Views to the east across the Project Site to the
harbor area are not generally available from homes in this neighborhood area due to their
principal north-south orientation as well as to the visual blockage provided by the Seaport Homes
and Casa Verde Apartment complexes adjacent to the Site's southern boundary. A representative
view from this portion of the Rolling Hills Riviera neighborhood is shown in Figure IV.B-12.
13. In response to Comment Letter No. A8 (City of Rancho Palos Verdes), page IV.B-20, the first
sentence of the last paragraph is revised to read:
Direct views of the Site's frontage along Western Avenue are also available from portions of
A venida Aprenda, Tarrasa Drive, Redondela Drive, and Palondra DriYePalmeras Place to the
west.
14. In response to Comment Letter No. A8 (City of Rancho Palos Verdes), page IV.B-47, the third
sentence of the last paragraph is revised to read:
Private view locations consist of single-family residences located along portions of Tarrasa Drive,
Redondela Drive, and Palondra Dfr1ePalmeras Place to the west of Western A venue.
15. Page IV.B-69, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide vrith the anticipated eKpiration of the term of the
DeYelopment Agreement (Df..) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
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Section IV.C Air Quality
16. Page IV.C-50, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antieipated eJrpiration of the tenn of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
17. In response to Comment Letter No. A12 (South Coast Air Quality Management District), the
following additional mitigation measures have been added to Section IV.C, Air Quality, of the Draft
EIR:
AQ-3: The Project shall provide electric outlets on residential balconies and common areas for
electric barbeques to the extent that such uses are permitted on balconies and common areas per
the Covenants, Conditions and Restrictions recorded for the property.
AQ-4: The Project shall use electric lawn mowers and leaf blowers, and electric or alternatively
fueled sweepers with HEP A filters, for maintenance of the Project.
Section IV.D Biological Resources
18. Page IV.D-51 under the heading "Project Design Features" is revised to read:
To this end, the following Project Design Feature§. has have been identified for the Proposed
Project:
19. In response to Comment Letter No. BIOi (Carrolle, Victoria and John), the following additional
Project Design Feature has been added to Section IV.D, Biological Resources, of the Draft EIR (at
page IV.D-51):
Prior to the start of demolition activities at the Project Site, the Project Applicant shall contract
with a pest control/pest extermination company to perform a survey of potential rodent issues on
the Project Site. This survey will consist of setting traps for a period of time to establish whether
or not a rodent problem exists. If a rodent problem is found, remediation shall begin
approximately one month prior to the start of any demolition.
20. Page IV.D-55, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antieipated eKpiration of the tertn of the
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Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
21. In Mitigation Measures BI0-1 through BI0-4, all references to the California Department of Fish and
Game or "CDFG" are revised as follows:
California Department of Fish and Game-Wildlife
CDFGW
Section IV.E Cultural Resources
22. Page IV.E-15, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analy!?is" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide •.vith the antieipated eKpiration of the tenn of the
DeYelopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
23. Page IV.E-22, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antieipated eKpiration of the tenn of the
Development Agreement (D:A) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
24. Page IV.E-35, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide vrith the antieipated eKpi-ration of the tenn of the
Dev•elopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.F Geology and Soils
25. In response to Comment Letters No. All (U.S. Department of the Navy) and A13 (U.S. Defense
Logistics Agency), the following Project Design Feature has been added to Section IV.F, Geology
and Soils, of the Draft EIR (at page IV.F-22):
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No Project Design Featl:li'es relating to potential impacts with respect to geology and soils have
been identified for the Proposed Project The following Project Design Feature pertaining to
geology and soils has been identified for the Proposed Project:
• The Project Applicant shall confer with the Navy and/or Defense Logistics Agency, as
operators of the Defense Fuel Support Point (DFSP) facility, with respect to potential
slope-stability-related impacts to the integrity of DFSP tanks, piping, and other
infrastructure, during Project construction.
26. Page IV.F-30, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to coincide with the anticipated Mpi-ration of the term of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.G Greenhouse Gas Emissions
27. Page IV.G-26, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to coincide ·.vith the anticipated expiration of the term of the
Development A.greement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.H Hazards and Hazardous Materials
28. In response to Comment Letter No. A15 (Northwest San Pedro Neighborhood Council), the Project
Design Feature under Section IV.H, Hazards and Hazardous Materials, of the Draft EIR (at page
IV.H-21) is revised to read:
Prior to the initial occupancy of any residential unit in the Project, the Project Applicant would
submit an emergency response plan for approval by the Los Angeles Fire Department (LAFD).
The emergency response plan will include but not be limited to the following: mapping of
emergency exits, evacuation routes for vehicles and pedestrians, location of nearest hospitals, and
fire departments. In developing the emergency response plan, the Project Applicant shall consult
with neighboring land uses, including but not limited to the U.S. Navy Defense Fuel Support
Point (DFSP), the ConocoPhillips Refinery, Rancho LPG, the Port of Los Angeles, the City of
Rancho Palos Verdes, and Mary Star of the Sea High School.
29. Page IV.H-42, the second sentence of the last paragraph is revised as follows:
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Emergency access to the Project Site (police, fire, and ambulance) would be provided by the two
ingress/egress points on Western Avenue that would also provide general site access, as well as
via an emergency-only lane connecting the southern Project roadway to the southern site
boundary adjacent to the off-site Seaport Village development.
30. Page IV.H-43, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide '.Vith the antieipated eJl:f)ira-tion of the term of the
Dev=elopment A.greement (DA:) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.I Hydrology and Water Quality
31. Page IV.I-56, the first sentence of the paragraph under the sub-heading "Extended Buildout Analysis"
is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by I 0 years to eoineide with the antieipa:ted expiration of the term of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.J Land Use and Planning
32. Page IV.J-8, second full paragraph is revised to read:
The Project Site is presently designated a combination of "Low Residential" and "Open Space" in
the Community Plan. The majority of the property is designated "Low Residential." An
estimated 9.+J acres of the northwestern earner of the site, generally parallel to its northern
boundary with (along Western AYen-ae and adjaeent to the U.S. Navy's DFSP property:) is
designated "Open Space."
33. Page IV.J-13, first paragraph under the "OS-IXL" heading is revised to read:
2
An estimated-9:-1-9.3 acres of the northwestern comer of the Project Site (along Western Avenue
and adjacent to the U.S. Navy's DFSP property) is zoned OS-IXL.2 Generally, the City's Open
Space zone is used to identify public, recreational, park, or natural resource land. At the time the
Estimated using City of Los Angeles Zoning Information and Map Access System (ZIMAS), website:
http://zimas.lacity.org/, August 29, 2011.
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Project Site was annexed to the City of Los Angeles in 1980, it was fully developed with a Navy
Housing complex (under public ownership). No portion of the Project Site was identified as a
recreational, park, or natural resource area.
34. Page IV.J-17, the first paragraph is revised to read:
The Project is also located adjacent to the Navy DFSP, which is a fuel and oil storage facility.
Fuel storage facilities at the DFSP primarily consist of underground tanks, with fuel transfer
accomplished largely through delivery via pipeline. Beea-use the bulk of the faeilities are loeated
l:lflderground, the property, although off limits to the publie, funetions in some aspeets as open
spaee, ineluding providing proteeted habitat to the threatened Palos Verdes Blue Butterfly and
visually natural, open spaee views for the eommunity.'"° Other loading facilities at the DFSP are
located away from the Project Site along Gaffey Street to the east. Fuel and oil storage is a
passive aetivity. The risks and potential health hazards associated with the adjacent DFSP are
addressed in Sections IV.C (Air Quality) and IV.H (Hazards and Hazardous Materials) of this
Draft BIR.
35. Page IV.J-18, first sentence of bottom paragraph is revised to read:
An estimated 94 9.3 acres of the northwestern corner of the Project Site (along Western Avenue
and adjacent to the U.S. Navy's DFSP property) is zoned OS.
36. In response to Comment Letter No. A15 (Northwest San Pedro Neighborhood Council), the following
discussion is added to page IV.J-55, above the "Impact Summary" subheading:
Urban Design Principles
The Proposed Project would incoi:porate each of the City's ten Urban Design Principles to
varying degrees as follows:
• Usable and Accessible Transit Areas: The Proposed Project would help to implement this
principle through the creation of a network of pedestrian and bicycle paths both within
the Project and connecting the Project with Western Avenue. In addition, the Project
would provide a bus turnout lane on Western A venue and bus stop facilities at bus stops
adjacent to the Project Site (see Mitigation Measure TRANS-27). Bicycle storage areas
would also be provided at the Project Site, and the Project would also coordinate with
local and regional transit operators to develop and implement strategies to increase transit
use by Project residents (see Mitigation Measure TRANS-26), as well as coordinate with
'"° Pales Verdes LaHd CeBservaRey, The Defefl:se Ftlel Sappert Paint aftd Nursery webpage:
httmf!WWW:flYp~aaelsklf:spn7af!l?, aeeessed 10112112.
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LADOT to potentially extend the existing San Pedro DASH route northerly on Western
A venue to serve the Project Site (see Mitigation Measure TRANS-28).
• Reinforce Walkability and Wellbeing: The Proposed Project would help to implement
this principle through the creation of a network of pedestrian pathways throughout the
site. including a walking/jogging path around the perimeter of the Project. These paths
would connect to the existing sidewalk along Western Avenue adjacent to the site.
Pedestrian access would also be provided along the new road across the site between
Western A venue and Mary Star of the Sea High School. In addition, recreational
facilities for the use of Project residents would be provided within each of the housing
products in the Project. All of the pedestrian areas within the Project would be
landscaped.
• Bridging the Past and the Future: This principle is not directly applicable to the Project
Site in that the local vicinity does not contain notable examples of historical architecture
and/or historical areas.
• Accentuate Visual Interest: The Project would establish detailed design guidelines within
its Specific Plan with the purpose of creating a unified, appealing, and distinct visual
presentation for the Project Site. These guidelines will address building facades,
awnings, sign.age, architectural treatments, utilities, building setbacks, and other
components of the Project, including pedestrian access.
• Nurture Neighborhood Character: The Project Site is a relatively challenging location
given its current isolation from surrounding land uses as well as the variety of contiguous
land uses surrounding it. The Project would help to implement this design guideline by
modulating development in different areas of the site, precisely to vary the density
according to the context of the surrounding uses. Overall, density within the Project
generally increases as one moves across the Project Site from north/northeast to
south/southwest, with the lowest densities nearest the DFSP, Green Hills Memorial Park,
and single-family residential communities west of Western Avenue and north of Avenida
Aprenda. The Project would improve the connection of Mary Star of the Sea High
School to the community, but would not provide direct connections to the multi-family
developments to the south or the single-family neighborhood to the east.
• Develop Street Furnishings: The Project would help to implement this guideline by
establishing consistent guidelines through its Specific Plan for landscaping, streetscaping,
paving materials, lighting, and benches along the public perimeter pathway and other
walking paths.
• Emphasize Early Implementation and Long Term Maintenance: This principle is not
directly applicable to the Project, being directed primarily at City Planners. Nonetheless,
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the Project's Specific Plan would ensure that all development at the site attains an
approved standard. In addition, the Project would include a Homeowners' Association
and CC&Rs to ensure maintenance of the site and Project roadways.
• Stimulate Sustainability and Innovation: The Project would help to implement this
guideline through both compliance with the City's Green Building Code and the
implementation of Project Design Features, including biofiltration of storm.water runoff,
drought tolerant landscaping. and accessibility to reclaimed water delivery infrastructure.
• Improve Equity and Opportunity: The Project would help to partially implement this
guideline by developing a range of housing product types oriented toward different
segments of the market.
• Generate Public Open Space: The Project would partially implement this guideline by
providing a substantial amount of open space accessible to all residents of the Project as
well as to the general public via pedestrian accessways, including a central recreation
area and multiple park areas, as well as additional open space accessible to the general
public.
• Navigation, Connection, and Flow: The Project would help to implement this guideline
by providing a network of walking, bicycle, and automobile circulation routes to be
developed according to the design specifications in the Specific Plan. These routes
would be signed, lighted, and treated with aesthetically consistent paving surfaces.
It should be noted that few projects will be consistent with each of these principles. The Urban
Design Principles recognize that areas and communities within the City have a variety of unique
elements that do not necessarily apply throughout the City and therefore should not be uniformly
applied throughout the City. As noted above, the Project is either partially or fully consistent
with each of the applicable Urban Design Principles. However, the Project's partial
inconsistency with some of these planning objectives does not mean that the Project is necessarily
inappropriate for the Project Site, nor does it constitute an adverse environmental impact. Indeed,
the Urban Design Principles are presented with the caveat that not every location within the City
is an appropriate site for the utilization of these planning objectives.
37. In response to Comment Letter No. A15 (Northwest San Pedro Neighborhood Council), the following
discussion is added to page IV.J-55, above the "Impact Summary" subheading:
Walkability Checklist
The Prooosed Proiect would incorporate each of the objectives presented m the City's
Walkability Checklist to varving degrees as follows:
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• Sidewalks: The Project would address this objective by providing pedestrian connections
from the sidewalk along Western A venue to the proposed perimeter walking/jogging path
surrounding the Project Site. Benches and other amenities would be provided within this
landscaped public perimeter open space. Additional pathways would connect to the
interior of the Project.
• Crosswalks/Street Crossings: The Project would address this objective through its
Specific Plan, which would contain guidelines for the design and placement of
crosswalks and pedestrian/bicycle street crossings within the Project.
• On-Street Parking: The Project would offer a limited amount of public, on-street parking
along the proposed access road to Marv Star of the Sea High School.
• Utilities: The Project would be consistent with this objective by placing all utilities
underground and buffering aboveground utility extensions with landscaping.
• Building Orientation: Although this objective is primarily oriented toward retail
developments, the Project would partially address the concept by making building
entrances visible from pedestrian pathways and providing direct pathways from the
Project's interior to the transit stops on Western Avenue. The Project would also provide
architectural continuity along the Western Avenue frontage.
• Off-Street Parking and Driveways: Parking for the Project would primarily consist of off-
street garages and understructure spaces. This parking would be virtually invisible from
Western Avenue due both to Project buildings and landscaping. The Project would be
generally consistent with this objective.
• On-Site Landscaping: The Project would be consistent with this objective by
incorporating extensive, visually interesting landscaping throughout the site, including
over 3,000 new trees. Pedestrian pathways would be landscaped both within the Project
itself and around the site's perimeter.
• Building Facade: The Project's building design would include features intended to
promote visual interest and diversity when viewed from public frontages. Views from
the Western Avenue frontage into the Project interior would be available from the
pedestrian pathway. Blank walls would be minimized and articulated massing would be
incorporated into Project building design. The Project would be largely consistent with
this objective.
• Building Signage and Lighting: The Project would provide a consistent signage theme as
specified in the Specific Plan. Lighting design and placement would also be similarly
coordinated for the Project via the Specific Plan. Both would be consistent with this
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objective by being oriented to assist both pedestrians and automobile passengers and
being "dark sky" compliant.
Notwithstanding the discussion provided above, the objectives and goals included in the
Walkability Checklist are not mandatory, and not every objective or goal would be appropriate
for every project. The primary objective is to achieve t~e implementation of some of these
objectives in every project, thereby improving pedestrian access, comfort and safety. As noted
above, the Project is either partially or fully consistent with applicable items of the Walkability
Checklist. However, the Project's partial inconsistency with some of these planning objectives
does not mean that the Project is necessarily inappropriate for the Project Site, nor does it
constitute an adverse environmental impact. Indeed, the Walkability Checklist is presented with
the caveat that not every location within the City is an appropriate site for the utilization of each
ophese planning objectives.
38. Page IV.J-55, the first sentence of the paragraph under the sub-heading "Extended Buildout Analysis"
is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to coincide with the anticipated expiration of the term of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.K Noise
39. Page IV.K-29, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to coincide with the anticipated eJEpiration of the term of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
40. In response to Comment Letter No. AS (City of Lomita), the following mitigation measures in
Section IV.K, Noise, of the Draft BIR (at page IV.K-33) have been revised as follows:
N0-6 All construction truck traffic shall be restricted to truck routes approved by the City of
Los Angeles Department of Building and Safety, which shall avoid residential areas and other
sensitive receptors to the extent feasible. Prior to the commencement of construction at the
Project Site, a meeting shall be held with appropriate representatives of the Cities of Rancho
Palos Verdes, Torrance, and Lomita. The purpose of the meeting will be to designate truck routes
for off-site load hauling vehicles and other construction-related vehicles.
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IV. Corrections and Additions to the Draft EIR
Page IV-13
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City of Los Angeles June 2013
N0-7 Two weeks prior to the commencement of construction at the Project Site, notification
shall be provided to the immediate surrounding cities and off-site residential, school, and
memorial park properties that discloses the construction schedule, including the various types of
activities and equipment that would be occurring throughout the duration of the construction
period.
Section IV.M.1 Public Services -Fire Protection
41. In response to Comment Letter No. B151 (Morgan, Brett), the text of the Draft BIR on page IV.M-2
(bottom paragraph) has been revised as follows:
In addition, backup support for fire protection services in the Project area is provided through an
informal mutual aid agreement between the LAFD and the Los Angeles County Fire Department
(LACFD). The decision as to which agency responds to a particular emergency in any service
area is made on a case-by-case basis, based on the nature and location of the emergency, and the
availability of fire protection equipment at the time.4 There are two LACFD fire stations within a
two mile radffis the vicinity (as shown in Figure IV.M-1) of the Project Site: Station 6 located at
25517 S. Narbonne Avenue in Lomita (approximately two miles from the Project Site), and
Station 83 located at 83 Miraleste Plaza in Rancho Palos Verdes (approximately M 2.6 miles
driving distance from the Project Site).
42. In response to Comment Letter No. A15 (Northwest San Pedro Neighborhood Council), the Project
Design Feature under Section IV.M.l, Fire Protection, of the Draft BIR (at page IV.M-9) is revised to
read:
Prior to the initial occupancy of any residential unit in the Project, the Project Applicant would
submit an emergency response plan for approval by the Los Angeles Fire Department (LAFD).
The emergency response plan will include but not be limited to the following: mapping of
emergency exits, evacuation routes for vehicles and pedestrians, location of nearest hospitals, and
fire departments. In developing the emergency response plan, the Project Applicant shall consult
with neighboring land uses, including but not limited to the U.S. Navy Defense Fuel Support
Point (DFSP), the ConocoPhillips Refinery, Rancho LPG, the Port of Los Angeles, the City of
Rancho Palos Verdes, and Mary Star of the Sea High School.
Section IV.L Population and Housing
43. Page IV.L-26, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
4 Mutual aid and interagency coordination is discussed on page I-2 of the Safety Element of the City of Los
Angeles City General Plan: http://citvplanning.lacity.orgicwd/gnlpln!SafivElt.pdf
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Page IV-14
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City of Los Angeles June 2013
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoinoide ',vith the antieipated expiration of the tenn of the
De¥elopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.M Public Services
44. Page IV.M-12, the first paragraph is revised as follows:
General and emergency access to the Project would be provided from Western Avenue at the two
existing signalized intersections with Green Hills Drive and A venida Aprenda on the north and
south, respectively. The northern access point would be gated with restricted public access;
however, the gates would be designed with key or code access for emergency vehicles. The
southern access point would be a public street across the Project Site. Gated access from this
street to the non-apartment residential areas of the Project would also be provided. As with the
northern access point, this gate would be designed with key or code access for emergency
vehicles. An additional emergency access point would be located along the Site's southern
boundary and would connect the southern Project roadway to the off-site Seaport Village
development. This emergency-only lane would be gated with key or code access for emergency
vehicles. The Project Site's internal roadway system would enable any of these emergency
access points to be reached from any location in the Project. In addition, as part of a reciprocal
emergency access arrangement, the Project Site would have emergency access from its southern
access point through the Mary Star of the Sea High School to Taper Avenue. Thus, the Project
Site would be able to take emergency access from an additional street other than Western
Avenue.5
45. Page IV.M-13, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antieipated expiration of the terrn of the
Development .Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
46. Page IV.M-22, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
5 Use of the Taper Avenue emergency access would be strictly limited to emergency conditions
necessitating access to the Project Site from locations other than Western A venue. In all other
circumstances, access to the Project Site would be taken from Western A venue.
Ponte Vista Project IV. Corrections and Additions to the Draft EIR
PageIV-15 Final Environmental Impact Report
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As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the aBtieipated expiration of the term of the
DevefopmeBt Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
47. Page IV.M-35, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the aBtieipated e11:piration of the term of the
Development A:greemem (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
48. Page IV.M-54, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide vtith the aBtieipated expiration of the term of the
Development Agreemem (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
49. Page IV.M-60, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the aBtieipated e11:piration of the term of the
DeYelopment Agreemem (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section IV.N Transportation and Traffic
50. In response to Comment Letter No. AS (City of Lomita), the following references in the Draft EIR to
the intersection of Arlington A venue/Lomita Boulevard are revised as follows:
• Intersection No. 8 in Tables IV.N-1, IV.N-4, IV.N-6, IV.N-7, IV.N-11, IV.N-12, IV.N-13, IV.N-
16, IV.N-17, IV.N-18, IV.N-19, IV.N-20, IV.N-21, IV.N-22, IV.N-23, IV.N-24, and IV.N-25 is
revised as follows:
Arlington Avenue Narbonne Avenue/Lomita Boulevard
• Intersection No. 8 on Figures IV.N-2, IV.N-3, IV.N-4, IV.N-8, IV.N-9, IV.N-10, IV.N-12, IV.N-
13, IV.N-16, IV.N-17, IV.N-19, IV.N-20, IV.N-22, IV.N-23, IV.N-25, IV.N-26, IV.N-28, IV.N-
29, and IV .N-31 is revised as follows:
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-I6
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City of Los Angeles June 2013.
Arlington Avenue Narbonne Avenue/Lomita Boulevard
51. Figure IV.N-3 in Section IV.N, Transportation and Traffic, is replaced with revised Figure 5-1 from
the Project Traffic Study (Appendix IV.N-1 to the Draft BIR), retaining the same figure title.
52. In response to Comment Letter No. A9 (Caltrans), the first full paragraph on page IV.N-86 is revised
to read:
Construction of the Project would not require any temporary street closures or closures of two or
more traffic lanes. It is possible that portions of traffic lanes adjacent to the Project Site could be
temporarily blocked off to allow for installation of utility connections. However, the Project
Applicant would be required to install signage in appropriate locations to notify travelers of the
temporary lane closures. The degree to which signage and/or a traffic management plan would be
required of the Project Applicant to minimize temporary traffic impacts during the construction
phase would be determined by LADOT, in consultation with Caltrans, at the time the Applicant
applies for permits that are required for the temporary lane closure.
53. Page IV.N-86, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide »vith the antieipated eJ1:piration of the term of the
Development Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
54. Page IV.N-87, the last sentence of the third full paragraph is revised as follows:
This corresponds to an annual growth rate of approximately 0.355 percent, or a total growth of
6.04 percent for the period 2010 through 2027 (end of the proposed De•1elopment Agreement).
55. In response to Comment Letter No. A7 (Metro), sub-part (b) of Mitigation Measure TRANS-12 on
page IV.N-162 of the Draft BIR is revised to read:
Relocate the existing southbound near-side Metro bus stop on Gaffey Street to the far_side of the
intersection (i.e., south of the intersection) where a full bus pad is to be installed in the street;
56. Mitigation Measure TRANS-27 is revised as follows:
In conjunction with the street widening of Western Avenue adjacent to the Project Site, the
Applicant shall provide a bus turnout lane and bus stop facilities (shelter, bench and schedule
information) at bus stops adjacent to the Site.
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Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-17
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Section IV.O Utilities and Service Systems
57. Page IV.0-14, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis'' is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide 1Nith the antieipated expiration of the term of the
De1;elopment A.greement (DA:) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
58. Page IV.0-22 under the heading "Current Project Site Wastewater Generation" is revised to read:
The Project Site is currently developed with 245 residential units, a 2,161-square foot community
center, and a 3,454-square foot retail convenience facility. All of the existing residences and
buildings have been vacated and currently generate no wastewater. ,AJthough the The Project Site
is new within the wastewater jurisdiction of the City of Los Angeles Bureau of Sanitation, whieh
is overseen by the Department of Publie Works, historieally it v;as served by the Los Angeles
County Sanitation Districts (LACSD) District No. 5.
The LACSD are a confederation of independent special districts that provide wastewater and
solid waste management for approximately 5.1 million people in Los Angeles County. The
LACSD's 1,400 miles of main trunk sewers and 11 wastewater treatment plants convey and treat
approximately 510 million gallons per day (mgd) of wastewater, 190 mgd of which are available
for reuse.6 The LACSD's service area covers approximately 800 square miles and encompasses
78 cities and unincorporated territory within the County. The area§ surrounding adjacent to the
Project Site on the west and south also falls within LACSD's District No. 5, which generally
includes the Cities of Rancho Palos Verdes, Rolling Hills, Rolling Hills Estates, Torrance,
Gardena, Lawndale, Hawthorne, and Inglewood.
Although the Projeet Site is loeated within the serviee area of the City of Los .Angeles Bureau of
Sanitation:, the The former Navy Housing uses at the site Project Site did not discharge
wastewater to the City Bureau of Sanitation system. Rather, as described below, wastewater was
sent to the County sewer infrastructure for conveyance to LACSD treatment facilities;
specifically, the Joint Water Pollution Control Plant (JWPCP) operated by the LACSD and
located in the City of Carson, approximately four miles from the Project Site.
59. Page IV.0-24, add the following discussion under the heading "Project Impacts":
6 Sanitation Districts of Los Angeles County, General Information, website:
http://www.lacsd.org/csdinfo.htm#Wastewater%20Management, June 2011.
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JV. Corrections and Additions to the Draft EIR
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As discussed above, the majority of the Project Site is located within the boundaries of LACSD
District No. 5. A portion of the site is located within the sewer service area boundaries of the
City's Bureau of Sanitation system. Thus, the Project would have two ultimate sewer service
connection options: (1) service by the City's Bureau of Sanitation: or (2) service by the LACSD.
Under the first option, the Project would connect to the existing City sewer facility located in
Taper Avenue, adjacent and to the east of the Project's eastern property boundary. Under the
second option, the Project would connect via a new sewer lateral to the existing LACSD facilities
located across and adjacent to the site's southwest comer, within the Western Avenue right-of-
way.
The Project Applicant's preferred option is to deliver all Project wastewater to the City Bureau of
Sanitation's sewer system for conveyance and treatment. However, in order to connect to the
City's sewer system, the Project Applicant must first pursue and perfect a de-annexation from the
LACSD service area for the majority of the Project Site and, subsequently, annexation to the City
Bureau of Sanitation service area. This process requires approval by the Local Agency
Formation Commission (LAFCO) as well as by the two wastewater service agencies. Although
the Project Applicant has initiated this process, it is not estimated to be completed until mid-2013.
Although, as is discussed below, both the LACSD and City Bureau of Sanitation have opined that
adequate conveyance and treatment capacity exists with which to serve the Proposed Project, in
the event that the transfer of the majority of the Project Site out of the LACSD service area and
into the City's service area is not approved, analyses of Project wastewater conveyance and
treatment by both the City Bureau of Sanitation and the LACSD are presented in this section.
60. Page IV.0-25, under the heading "Wastewater Conveyance" is revised to read:
Proposed Sewer System
Preferred City Option
The Project Applicant's preferred proposed sewer design for the Project includes a sewer
discharge connection to the existing City system at the LAD PW' s 8-inch gravity sewer main
within the Taper Avenue right-of-way (Record Plan D-19444). Sewage effluent from the Project
would be discharged into the existing 8-inch sewer main via a sewer line connection to the
existing upstream terminus manhole (station number 17+25.41 per record plan D-19444). The
preliminary design concept for the proposed on-site sewer system includes new sewer main
infrastructure consisting of a new lift station/force main package, manholes, and 6-inch, 8-inch
and 10-inch sewer piping elements. The final on-site sewer infrastructure layout and design will
be a function of the sewer confluence point locations coupled with the specified pipe sloping and
fall conditions.
The Project's on-site sewer system would discharge into a single connection point to the 8-inch
sewer main at the end of Taper A venue, approximately where the existing Mazy Star of the Sea
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High School campus abuts the eastern edge of the Project Site. This location represents the
current upstream end of this sewer main; no upstream sewage effluent would exist in the main at
the point where the Project would connect to it. Maintenance of the on-site portion of the
Project's wastewater collection and conveyance system would eventually be the responsibility of
the future homeowners' association (HOA).
Alternative County Option
In the event that transfer of the majority of the Project Site from the LACSD's sewer service
jurisdiction to the City Bureau of Sanitation's service area is not approved, an alternate sewer
system would be developed to serve the Project. Preliminary designs for the internal Project
sewer system would include new on-site sewer main infrastructure consisting of a new on-site lift
station/force main package, manholes, and 6-inch, 8-inch, and 10-inch sewer piping elements.
Based upon the LACDPW methodology for calculating the wastewater conveyance requirements
of existing and proposed land uses, the Project would produce a daily average sewer flow of
203.100 gpd and a peak daily flow of 507.750 gpd. When combined with the existing off-site
wastewater flows from the apartment and condominium units located on the adjacent tracts
( 45060 and 34044-C) to the south of the site, the total wastewater conveyance delivered through
the existing 8-inch sewer lateral crossing Western Avenue southwest of the site would be 215,841
gpd (average daily) and 539,603 gpd (peak daily).
Off-Site Conveyance Capacity
Preferred City Option
The LADPW analyzes the impacts of a proposed development on the surrounding existing sewer
infrastructure through an applicant-driven process called a Sewer Capacity Availability Request
(SCAR). Through this process, the Project Applicant requested that the City analyze its existing
infrastructure and issue either an agreement or a denial to service the Proposed Project's sewage
effluent. A SCAR was filed with the Bureau of Sanitation requesting the City's agreement to
service the Project's sewage effluent as tabulated in Table IV.0-3 above. The City then analyzed
the existing sewer system and determined that sufficient residual conveyance and treatment
capacity exists in the sewer lines to which the Project is proposing to discharge. Specifically, the
Project's estimated wastewater flow would constitute approximately 35 percent of the available
capacity in the 8-inch Taper A venue sewer main.
Consequently, the City issued a SCAR response in essence committing to serve the Project (see
Appendix IV.0-2).7 The City's sewer system has sufficient capacity to accommodate the total
Approved SCAR, Bureau of Engineering, Department of Public Works, City of Los Angeles, May 24, 2012.
Ponte Vista Project
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JV. Corrections and Additions to the Draft EIR
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. flow for the Project, therefore Project impacts with regard to wastewater conveyance would be
less than significant.
Alternative County Option
In the event that transfer of the majority of the Project Site from the LACSD' s sewer service
jurisdiction to the City Bureau of Sanitation's service area is not approved. the County system
would provide off-site conveyance of Project wastewater. The LACSD's WAPP facility would
serve all sewers flowing from the existing LACDPW 8-inch sewer line crossing Western Avenue,
including the Project's wastewater. In terms of off-site sewer conveyance, the existing LACDPW
8-inch sewer line in Western Avenue has a "50 percent full" design flow capacity of 0.63 cfs and
a "75 percent full" design flow capacity of 1.15 cfs. The existing sewer peak flow generated
from the existing off-site development to the south is 0.049 cfs. When the Project's wastewater is
added to this existing off-site wastewater (peak flow), the total amount requiring conveyance
would be 0.835 cfs. Given the 8-inch sewer pipe's existing size slope and material, the proposed
total sewer flow of 0.835 cfs would utilize 59 percent of the full pipe capacity, which is 32
percent more than would be permitted under the "50 percent full" design flow capacity. This
condition would yield a flow velocity of 3 .9 feet per second, which is above the 3 feet per second
standard utilized by LACDPW. Because the proposed flow depth/velocity would fall under
LACDPW special case consideration, specific approval from LACDPW is required. This
approval was sought and granted on July 20, 2011. Therefore, Project impacts with regard to
wastewater conveyance would be less than significant.
61. Page IV.0-26 under the heading "Wastewater Treatment" is revised to read:
Preferred City Option
Wastewater from the Project Site would be subsequently conveyed to the TIWRP, which has a
remaining treatment capacity of approximately 14 mgd. The 205,950 gpd net increase in
wastewater generation that would be created by the Project represents approximately 1.5 percent
of the remaining capacity at the TIWRP. Therefore, TIWRP has enough remaining capacity to
accommodate treatment of Project-generated wastewater. The Project's additional wastewater
flows would not substantially or incrementally exceed the future scheduled capacity of any
treatment plant by generating flows greater than those anticipated in the Integrated Resources
Plan, Sewer System Management Plan, or General Plan. Impacts upon wastewater treatment
capacity as a result of the Project would be less than significant.
Alternative County Option
In the event that transfer of the majority of the Project Site from the LACSD's sewer service
jurisdiction to the City Bureau of Sanitation's service area is not approved, the County system
would provide off-site treatment of Project wastewater. The Joint Water Pollution Control Plant
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City of Los Angeles June 2013
(JWPCP) is operated by the LACSD and is located in the City of Carson, approximately four
miles from the Project Site. The plant began operation in 1928 and has a permitted design
treatment capacity of 400 million gallons per day (mgd) of wastewater with an approximated
current average flow of 300 mgd.8 The operation at JWPCP consists of screening, grit removal,
primary sedimentation, pure oxygen activated sludge reactors, secondary clarification, and
chlorination. The 205,950 gpd net increase in wastewater generation that would be created by the
Project represents approximately 0.2 percent of the remaining capacity at the TIWRP. Therefore,
TIWRP has enough remaining capacity to accommodate treatment of Project-generated
wastewater. Impacts upon wastewater treatment capacity as a result of the Project would be less
than significant.
62. Page IV.0-26 under the heading "Construction Impacts" has been revised to read:
Preferred Citv Option
The required sewer connection and related infrastructure upgrades would not be expected to
create a significant impact to the physical environment because: (1) existing service would not be
disrupted; (2) replacement of the sewer lines would be within public and private rights-of-way;
and (3) the existing infrastructure would be replaced with improved infrastructure in areas that
have already been significantly disturbed. Furthermore, the Project Applicant would pay for
needed upgrades. All of the proposed sewer improvements would occur on-site and away from
existing traffic flows, with the lone exception of where the Project's new discharge connection
would connect to an existing manhole located in Taper A venue. Because the existing manhole is
located at the end of a private local street (on the Mary Star of the Sea High School campus), the
interim construction window of a few days to make the sewer connection would not create a
disruption to the surrounding community. The proposed sewer connection to the upstream
terminus end of the sewer line would not result in an interruption in service to any existing
downstream properties serviced by the line. Therefore, Project impacts with regard to wastewater
infrastructure installation/improvement would be less than significant.
Alternative County Option
The required sewer connection and related infrastructure upgrades would not be expected to
create a significant impact to the physical environment because: (1) existing service would not be
disrupted; (2) replacement of the sewer lines would be within public and private rights-of-way;
and (3) the existing infrastructure would be replaced with improved infrastructure in areas that
have already been significantly disturbed. Furthermore, the Project Applicant would pay for
8 LACSD Joint Water Pollution Control Plant facility
about/wastewater f(1cilities!jwpcp/defi;iult.asp. accessed September 16, 2011.
information; http://www. lacsd org/
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IV. Corrections and Additions to the Draft E!R
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needed upgrades. Where the Project's new force main would connect to the existing manhole
No. 174 located along Western Avenue, impacts to traffic flows on Western Avenue are not
expected to occur because the manhole is located in the unpaved parkway area along the east side
of the street rather than within the street itself. Therefore, Project impacts with regard to
wastewater infrastructure installation/improvement would be less than significant.
63. Page IV.0-27, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antieipated expiration of the term of the
De•,relopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
64. Page IV.0-27 under the heading "Cumulative Impacts" has been revised to add the following sub-
heading:
Preferred City Option
65. Page IV.0-28, discussion under the heading "Cumulative Impacts" and just above Table IV.0-4 is
revised to read:
Alternative County Option
In the event that transfer of the majority of the Project Site from the LACSD's sewer service
jurisdiction to the City Bureau of Sanitation's service area is not approved, the County system
would provide off-site collection, conveyance, and treatment of Project wastewater. Thus, in
order to present the most conservative cumulative impact assessment, it has been assumed that all
of the 154 cumulative projects, along with the Project, would discharge to the LACSD's
treatment facility at the JWPCP.
As shown in Table IV.0-4, development of the cumulative projects would increase the generation
of wastewater in the Project area to approximately 1.83 mgd (average daily). Including the
Project's wastewater generation to this total yields a cumulative wastewater generation of
approximately 2.03 mgd (average daily). The JWPCP currently has capacity for an additional
122.5 mgd. Therefore, the JWPCP would have adequate capacity to treat cumulative wastewater
flows from the Project and cumulative projects.
Furthermore, each of the individual cumulative projects would be subject to the LACDWP's
determination of whether there is allotted sewer conveyance capacity available prior to the formal
acceptance of plans and specifications by the construction permitting authorities within each
jurisdiction where the cumulative projects are to be developed. Therefore, the cumulative impact
of the cumulative and proposed projects on wastewater would be less than significant.
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Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-23
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66. Page IV.0-52, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antiei}Jated expiration of the term of the
De't'elopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
67. Page IV.0-69, the first sentence of the paragraph under the sub-heading "Extended Buildout
Analysis" is revised as follows:
As discussed in Section II (Project Description), the potential exists for the Project buildout year
to be extended by 10 years to eoineide with the antiei}Jated expiration of the term of the
D6¥elopment Agreement (DA) in 2027 accommodate potential extensions allowed under the
Vesting Tentative Tract Map process.
Section VI Alternatives to the Proposed Project
68. Page VI-4 at bottom, revise Alternative B title to read:
Alternative B: No Projeet Alternative/Existing Zoning (Single-Family Homes)
69. Page VI-5 under the heading "Alternatives Considered But Rejected From Further Consideration" is
revised to read:
Alternatives that clearly would not be financially feasible to develop and market (considering
such factors as the cost of site acquisition and the costs to plan, permit, and develop the project),
such as public parks, were not considered. Included among such alternatives is development of
the Project Site under the existing zoning and General Plan land use designations, which would
retain 9.3 acres of the site as undeveloped open space and develop the remainder with 169 5,000
square foot single-family home lots consistent with the Rl-lXL zoning. Such an alternative has
been determined to be economically infeasible to develop at the Project Site. However, an
alternative that would develop the site exclusively with single-family homes is discussed and
evaluated below as Alternative B.
70. Page VI-10, revise Alternative B title and discussion to read:
Alternative B: No Projeet Aiternative/Existing Zoning (Single-Family Homes)
Under Alternative B, the Project would not be developed on the Project Site. However, the
Project Site would not remain in its current condition. Under the conditions of the ownership
transfer from the U.S. Department of Defense to the previous owner, all existing improvements
on the Project Site must be removed. Accordingly, the existing vacant former Navy housing
Ponte Vista Project
Final Environmental Impact Report
JV. Corrections and Additions to the Draft EIR
Page!V-24
5-139
City of Los Angeles June 2013
complex and associated roadways and other infrastructure would be demolished and all debris
removed from the Project Site under this alternative. Under the current land use designation in
the Wilmington-Harbor City Community Plan, a majority of the Project Site is designated for
Low Density Residential ( 4 to 9 dwelling units per acre) land uses. The Planning and Zoning
Code (Los Angeles Municipal Code [LAMC], Chapter 1), zones all but 9.3 acres of the Project
Site Rl-lXL (One-Family Zone, Extra Limited Height District No. 1). Single-family dwellings,
among other specified land uses, are permitted within the Rl zone. The Extra Limited Height
District No. 1 limits the height of buildings to two stories or 30 feet. The remaining 9.3 acres of
the site is zoned and designated Open Space.
If a Zone Change and General Plan Amendment were approved to remove the 9 .3 acres of Open
Space zoning from the Project Site, the land use and zoning designations of the Project Site
wo~ld permit up to 429 single-family homes. In addition, if a single-family project were to
include below-market (moderate, low, and very-low income units), a potential density bonus of
35 percent under the City's existing rules and regulations, or 579 single-family units, might be
developed on the Project Site. Because of the significant site acquisition and site preparation
costs related to the Project, the Applicant indicates that it is unlikely that a single-family project
with below-market units would be developed.
Under City of Los Angeles zoning criteria, Rl zoning requires that each lot have a minimum area
of 5,000 square feet, a minimum width of 50 feet, front yards of not less than 20 percent of the
depth of the lot, and rear yards of not less than 15 feet, with resulting dwelling unit densities of
approximately six units per acre (taking streets into account). Due to high land prices in infill
locations within the City of Los Angeles, fewer and fewer new subdivisions are being developed
in accordance with Rl zoning. Instead, homebuilders seeking to develop single-family homes in
infill locations routinely propose homes on smaller lots at significantly higher densities.
In addition, the requirement to incorporate a seismic setback zone across the site, described in
Section IV.F, Geology and Soils, would eliminate approximately 44 potential lots from a single-
family residential site plan, reducing the total number of potential home lots from 429 to 3 85.
While infill housing in areas like the Project Site is not typically being developed in accordance
with traditional Rl zoning criteria, for the purpose of eomplying with Seetion 15126.6(e)(2) of
the CEQA Guidelines, this alternatives analysis assumes that, under Alternative B, the Project
Site would be developed as a single-family home project in accordance with Rl zoning with
approximately 385 single-family homes and that a Zone Change and General Plan Amendment
would be approved to remove the current Open Space zoning/land use designation from the
northerly 9.3 acres of the site. A conceptual site plan for Alternative Bis shown in Figure VI-1.
The number of homes in Alternative B is below the maximum density that could be developed
\.vithout a General Plan amendment or re!i"ioning under the Rl zoning in order to provide a street
and lot plan consistent with a move-up/high-end home plan as well as to, as described above,
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-25
5-140
City of Los Angeles June 2013
incorporate the required seismic setback zone. The de•;elopment would be designed to be
consistent with all e*isting planning and zoning requirements.
All of the homes under Alternative B would be developed for sale at market rates. Due to the
same significant site acquisition and site preparation costs discussed previously, the Project
Applicant indicates that it would be necessary to develop the Project Site with the maximum
reasonable number of move-up/high-end single-family homes at the highest supportable prices in
the market area (Los Angeles/Wilmington-Harbor City/San Pedro) that could be achieved. The
Project Applicant estimates that such homes would range between 2,000 and 3,000 square feet
and would need to sell for an average price efapproaching $1 million. Given the current housing
market and state of the local and regional economy, there is uncertainty that such prices could be
realized. However, retaining the existing 9.3 acres of zoned Open Space on the site under
Alternative B would eliminate approximately 81 additional single-family home lots from the site
plan. which would likely make the alternative development economically infeasible to develop.
For this reason, Alternative B proposes to eliminate the 9.3 acres of Open Space zoning from the
Project Site.
71. Figure VI-1, revise the figure title to read:
Conceptual Site Plan~ Alternative B (No Project ,AJternatiYe/Single-Family Homes)
72. Page VI-13 under the "Public Park/Open Space" subheading is revised to read:
No public park would be developed. The existing 9.3 acres of zoned Open Space on-site would
be eliminated through a Zone Change and General Plan Amendment process in order to allow for
development of a sufficient number of single-family homes to render the site plan potentially
feasible. Although community open space and private park area would be located along the
seismic setback zone crossing the center of the Site, the total amount of open space associated
with Alternative B would be less than that associated with the Proposed Project due to the
elimination of the public park component and existing zoned Open Space.
73. Page VI-16, the last paragraph is revised to read:
Vehicular access to the Alternative C project would be from Western Avenue at the two existing
signalized intersections with Green Hills Drive and Avenida Aprenda on the north and south,
respectively. The proposed southerly Project entrance at the Western Avenue/Avenida Aprenda
intersection would feed into a new east-west road crossing the southern portion of the Project Site
that would provide access to the Mary Star of the Sea High School campus adjacent to the Project
Site on the east. As with the Proposed Project, additional emergency-only vehicular access would
be provided along the Site's southern boundary adjacent to the off-site Seaport Village
development.
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-26
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City of Los Angeles June 2013
74. Page VI-17, the second paragraph is revised to read:
When completed, Alternative C would redevelop 100 percent of the Project Site. Alternative C
would incorporate a seismic setback area along the fault splay crossing the center of the site (see
Section IV.F, Geology and Soils, for more detail). Alternative C would not include the 2.8-acre
public community park that is included in the Proposed Project. However, Alternative C would
incorporate approximately 20 acres of total open space, consisting of approximately one acre of
outdoor recreational amenity space (including a recreation center with adjacent community
clubhouse and pool/event lawn area in the central portion of the site), approximately 7.1 acres of
dedicated park area (including the open space/trail network around the perimeter of the Project
Site), 10.2 acres of landscaped common area throughout the Project, and an additional 2.1 acres
of general open space, resulting in a total amount of open space similar to that provided by the
Proposed Project (20.5 acres versus 20.6 acres). All of this open space would be accessible to the
general public via pedestrian access points. Additional indoor recreational amenities (e.g., rec
rooms, fitness centers, etc.) would be distributed across the site and are not included in the
acreages above. These recreational facilities would be for the private use of residents and their
guests and would not be accessible to the general public. The v1alking/jogging path surrounding
the perimeter of the Projeet and extending through the landseaped open spaee surrounding the
Site would be open to the generaJ publie, although the other open spaee areas of the Projeet 1.vould
net.
75. Page VI-18, the paragraph under the "Public Park/Open Space" sub-heading is revised to read:
No public park would be developed. The amount of publicly-accessible open space associated
with Alternative C would be less than approximately the same as that associated with the
Proposed Project due to the elimination of the publie park eomponent and would be limited to the
trail and landseaped open spaee area surrounding the perimeter of the Project Site. Alternative C
would, h(}Vi'e>ler, provide a greater amount of private open space for the use of Project residents.
76. Page VI-23, the second full paragraph is revised to read:
Vehicular access to the Alternative D project would be from Western Avenue at the two existing
signalized intersections with Green Hills Drive and A venida Aprenda on the north and south,
respectively. The proposed southerly Project entrance at the Western Avenue/Avenida Aprenda
intersection would feed into a new east-west road crossing the southern portion of the Project Site
that would provide access to the Mary Star of the Sea High School campus adjacent to the Project
Site on the east. As with the Proposed Project, additional emergency-only vehicular access would
be provided along the Site's southern boundary adjacent to the off-site Seaport Village
development.
77. Pages VI-70 and VI-71 under the "Impacts of Alternative B" subheading are revised to read:
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
Page IV-27
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City of Los Angeles June 2013
Contrary to the Proposed Projeet, Alternative B would be developed eonsistent »Yith e~dsting
planning and zoning designations for the Projeet Site require a Zone Change and a General Plan
Amendment to re-designate the existing 9.3 acres of Open Space on-site to Rl-lXL and Low
Density Residential to match the remainder of the site's existing zoning and land use designation.
Lots for the 385 single-family homes would be created through the processing and recordation of
a tentative tract map. Alternative B would contribute fewer additional housing units to meet area
housing needs than the Project. In addition, it is expected that the sales price of homes developed
pursuant to Alternative B would average apprmdmatelyapproach $1,000,000. Thus, Alternative
B would provide housing for only the most affluent segment of the housing market, rather than
for a broad range of potential buyers and renters. Although it would contribute additional single-
family housing, Alternative B would not implement recommended air quality and regional
planning strategies to increase the density of infill housing so as to reduce urban sprawl impacts
on. natural resources, reduce air quality emissions due to VMT for commuting purposes, and to
reduce regional congestion through VMT reduction. Alternative B would fail to promote further
attainment of many City and regional planning objectives and would be either inconsistent or less
consistent than the Proposed Project with several of the policies contained in the General Plan,
particularly those relating to the provision of a range of housing opportunities and the promotion
of higher densities in locations proximate to centers of employment and transit. Alternative B
would not set aside and dedicate a 2.8-acre public park as proposed by the Project. In addition,
the access road across the southern portion of the Project Site connecting Western Avenue to the
Mary Star of the Sea High School campus would not be provided under this alternative, creating a
potential land use incompatibility with the school that did not previously exist by forcing school
traffic to pass through an existing single-family residential neighborhood (Taper Avenue). In
summary, impacts would be less than significant but, on balance, slightly greater than those
associated with the Proposed Project.
78. Page VI-93, the first paragraph under the sub-heading "Parks and Recreation" has been revised to
read:
Approximately 33 percent of Alternative C's post-development acreage (or 20.5 acres) would
consist of a combination of open space, landscaped common areas, recreational amenities, and
parks, as shown conceptually in Figure VI-5 and tabulated in Table VI-10. Of this total, 0.5 acre
would be aeeessi-ble to the genera-1 publie located outside the gated portion of the Project and 20
acres would be aeeessible only to the residents of the private (non rental) located inside the gated
portion of the Project. Alternative C would exceed its generated private (non-rental)
neighborhood park need by 4.1 acres, but would create a net unmet 0.3-acre demand for publicly
accessible neighborhood park area. Non-vehicular public access to the parks and open space
within the gated portion of the Project would be provided via pedestrian access points.
79. Page VI-103 under the "Impacts of Alternative B" subheading is revised to read:
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
PageIV-28
5-143
City of Los Angeles June 2013.
Alternative B represents development under the e:K:isting R 1 entitlement for the Projeet Site Rl-
lXL zoning and a Low Medium Residential land use designation. Under this entitlement With
approval of these entitlements, a total of 385 single-family homes could be constructed on the
Project Site. The vehicular access associated with Alternative B is assumed to be consistent with
the access scheme currently planned for the Proposed Project.
80. Table VI-19, the repeating header beginning on page VI-133, is revised for Alternative B to read:
Alternative B: Ne Prejeet t..Jtereative/Existieg Zeeieg (Single-Family Homes)
81. Pages VI-146 and VI-147 under the "Alternative B" subheading are revised to read:
Alternative B would redevelop the Project Site with approximately 385 single-family homes,
consistent with e~dsting !i3oning regi:ilations governing the site Rl-lXL zoning and the Low
Medium Residential land use designation. As discussed at the start of this section, beeause
Alternative B would H:0t require a General Plan Amendment er and Zone Change to eliminate the
existing Open Space zoning and land use designation from the northerly 9 .3 acres of the site in
order to be implemented, it is also eonsidered to represent a "No Projeet" alternative, e·1en though
it v1ould result in rede•1elopment of the site.
Appendix 1-2, Responses to the NOP
82. In response to Comment Letter No. A7 (Metro), Appendix I-2 of the Draft EIR has been revised to
include the November 10, 2010 NOP response letter from Metro.
Ponte Vista Project
Final Environmental Impact Report
IV. Corrections and Additions to the Draft EIR
PageIV-29
5-144
REQUESTED ENTITLEMENTS
General Plan Amendment to the Wilmington -Harbor City
Community Plan from "Low Residential" to "Low Medium
I Residential," "Low Medium II Residential" and "Medium
Residential."(Per LAMC § 11.5.6)
Zone Change from the existing R1-1XL and OS-1XL to a new
Specific Plan Zone. (Per LAMC § 12.32)
Specific Plan adopted for Ponte Vista, establishing project-
specific development standards and guidelines. (Per LAMC
§12.32)
Vesting Tract Map for the development of 1, 135 residential
condominium units on the 61.5 acre Ponte Vista site. (LAMC
§ 17.00 et. seq.)
Source: Ponte Vista, San Pedro, 2011.
AJA Environmental Services, LLC
Legend
General Plan Land
Use Designation
Other Land Uses
Public Park
Open Space
Total Site
DU AC
353 27.6
390 16.5
392 11.7
1,135 55.8
2.8
2.9
61.5
Figure 11-1 O
Proposed Land Use Plan
5-145
I ~
2STHST
Source: Linscott, Law & Greenspan, Engineers, 03/08/2012.
CAJA Environmental Services, LLC
No.1
Hawthorne/Sepulveda
No.2
HawthomeJPCH
No.10 No.11
PVO East/PVD North Western/Sepulveda
No.19
Western/Fitness
No.20
Western/Westmont
No. 28 No. 29
Western/Weymouth Westem/9th
No.37
Gaffey/Westmont
No.46
Vermont/PCH
No.55
WHmington/PCH
' ' I I ~---,
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No.47
1·110 SB/PCH
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No.56
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No.12
western/Lomita
No.13
Western!PCH
' '
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No.14
WestemtAnahelm
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WestemfPVD North
,'
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No.21 No.22 No.23
Westeml'Capitof -~ -~ -~ No.27
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No.30
Western/25th
No.39
Gaffey/Channel
,' .-\'-2-48
No. 31
Weymouth/9th
No.40
Gaffey/Mlraflores-1-110 SB
No. 32 No. 33
Normandle/Seputveda Normandle/Lomlta
' I
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No.41 No.42
Gaffey/Summertand Gaffey/1·110 NB-SB-SR-47
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Flgueroa/l-110 NB Figueroa Pl/1-110 SB Figueroa Pi/Anaheim Figueroai'Sepulveda
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No. 34
Nonnandle/PCH
No.43
Gaffey/9th
No.52
Flgueroa/PCH
--r-' '
' " ,' Yt. -~ \
I I \ I ( I
' !!: I ' = I
..... -_,. ...
No. 35 No. 36 Vermont/
Vermont/Normandle PVO North-Gaffey/Anahefm
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Vermont/Sepulveda ,1---, ," ... '-18 \
/ ';$~.,..,-119 \
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Flgueroa/1-110 NB
No.45
Vermont/Lomita
No.54
Figueroa/Anaheim
0
Notto Scale
Figure IV.N-3
Existing AM Traffic Volumes
5-146
Source: FUSCOE Engineering, June 18, 2012.
CAJA Environmental Services. LLC
co
0 100 200 -----i.....--.
Scale (Feet)
Figure Vl-1
Conceptual Site Plan -Alternative B
(Single-Family Homes) 5-147
Excerpts from FEIR for Ponte Vista project:
Mitigation Monitoring and Reporting Program (Section V)
5-148
V. MITIGATION MONITORING AND REPORTING PROGRAM
A. INTRODUCTION
Section 21081.6 of the Public Resources Code requires a Lead Agency to adopt a "reporting or
monitoring program for the changes made to the project or conditions of project approval, adopted in
order to mitigate or avoid significant effects on the environment" (Mitigation Monitoring and Reporting
Program).
Section 15097 of the CEQA Guidelines provides additional direction on mitigation monitoring or
reporting):
15097. MITIGATION MONITORING OR REPORTING.
(a) This section applies when a public agency has made the findings required under paragraph
(1) of subdivision (a) of Section 15 091 relative to an EIR or adopted a mitigated negative
declaration in conjunction with approving a project. In order to ensure that the mitigation
measures and project revisions identified in the EIR or negative declaration are implemented, the
public agency shall adopt a program for monitoring or reporting on the revisions which it has
required in the project and the measures it has imposed to mitigate or avoid significant
environmental effects. A public agency may delegate reporting or monitoring responsibilities to
another public agency or to a private entity which accepts the delegation; however, until
mitigation measures have been completed the lead agency remains responsible for ensuring that
implementation of the mitigation measures occurs in accordance with the program.
The City of Los Angeles is the Lead Agency for the Project. Any agency listed below is assumed to be
within the City of Los Angeles, unless its jurisdiction is listed separately.
An Environmental Impact Report (EIR) has been prepared to address the potential environmental impacts
of the Project. This Mitigation Monitoring and Reporting Program (MMRP) is designed to monitor
implementation of the mitigation measures identified for the Project. The MMRP is subject to review and
approval by the Lead Agency as part of the certification of the EIR and adoption of project conditions.
The required mitigation measures are listed and categorized by impact area, as identified in the Draft EIR
and Final EIR, with an accompanying identification of the following:
• Monitoring Phase, the phase of the Project during which the mitigation measure shall be
monitored;
o Pre-Construction, including the design phase
o Construction
o Pre-Occupancy (prior to issuance of a Certificate of Occupancy)
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-1
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City of Los Angeles June 2013
o Occupancy (post-construction)
• Enforcement Agency, the agency with the power to enforce the mitigation measure; and
• Monitoring Agency, the agency to which reports including feasibility, compliance,
implementation, and development are made.
• Monitoring Frequency, the frequency at which the mitigation measure shall be monitored.
• Action( s) Indicating Compliance, the action( s) of which the Enforcement or Monitoring Agency
indicates that compliance with the identified mitigation measure has been implemented.
The Project Applicant shall be responsible for implementing all mitigation measures unless otherwise
noted. The MMRP performance shall be monitored annually to determine the effectiveness of the
measures implemented in any given year and reevaluate the mitigation needs for the upcoming year.
Program Modification
After review and approval of the MMRP by the Lead Agency, minor changes and modifications to the
MMRP are permitted, but can only be made by the Applicant or its successor(s) subject to approval by the
City of Los Angeles. This flexibility is necessary due to the nature of the MMRP, and the need to protect
the environment with a workable program. The Lead Agency, in conjunction with any appropriate
agencies or departments, will determine the adequacy of any proposed change or modification. No
changes will be permitted unless the MMRP continues to satisfy the requirements of CEQA, as
determined by the Lead Agency.
B. MITIGATION MONITORING AND REPORTING PROGRAM
Section IV.A. Impacts Found to be Less Than Significant
No mitigation measures required.
Section IV.B. Aesthetics
No mitigation measures required.
Section IV.C. Air Quality
AQ-1 The following equipment specifications shall be implemented for construction activity, consistent
with recent SCAQMD recommendations.1 If these exact specifications cannot be feasibly
1 Based on a review ofSCAQMD Project-level comment letters published in 2011;
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-2
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City of Los Angeles June 2013
attained, the Project Applicant shall include a comparable measure demonstrating an equivalent
effectiveness at reducing construction related air quality emissions.
• Three excavators shall meet Tier 3 off-road emissions standards;
• One grader shall meet Tier 3 off-road emissions standards;
• Two scrapers shall meet Tier 3 off-road emissions standards; and
• Six rubber-tired dozers shall meet Tier 3 off-road emissions standards and Diesel
Particulate Filters (DPF) Level 2.2
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Quarterly, during the time the listed equipment will be used
Action Indicating Compliance: Compliance report submitted by contractor
AQ-2 The Project Applicant shall ensure that construction contractors use super-compliant architectural
coatings as defined by the SCAQMD (VOC standard ofless than ten grams per liter).3
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, for each phase of development
Action Indicating Compliance: Compliance report submitted by contractor prior to use
http://www.aqmd.gov/ceqa/letters.html, accessed April 13, 2011.
2 SCAQMD off-road mitigation measures; http://www.aqmd.gov!ceqalhandbook/mitigation/ojfroad/
TableII.xls; and http://www.aqmd.gov/ceqalhandbooklmitigation/ojfroad/Tablelll.doc; accessed April 13,
2011.
3 SCAQMD, Super-Compliant Architectural Coatings Manufacturers and Industrial Maintenance Coatings
List, http://www.aqmd.gov/prdas/Coatings/super-compliantlist.htm.
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-3
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City of Los Angeles June 2013
AQ-3 The Project shall provide electric outlets on residential balconies and common areas for electric
barbeques to the extent that such uses are permitted on balconies and common areas per the
Covenants, Conditions and Restrictions recorded for the property.
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, for each phase of development
Action In.,icating Compliance: Compliance report submitted by contractor prior to use
AQ-4 The Project shall use electric lawn mowers and leaf blowers, and electric or alternatively fueled
sweepers with HEP A filters, for maintenance of the Project.
Monitoring Phase: Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Annual
Action Indicating Compliance: Compliance report submitted by Project Homeowners
Association
Section IV.D. Biological Resources
BI0-1 Potential impacts to nesting birds, migratory birds, and raptors shall be avoided either by
scheduling grading, vegetation removal and demolition during the non-nesting period (August
30th through February 14th), or if this is not feasible, by conducting a pre-construction survey for
raptor nests and avoiding disturbance of active nests. Provisions of the pre-construction survey
and nest avoidance, if necessary, shall include the following:
• If grading or vegetation removal is scheduled during the active nesting period (February 15th
through August 31 5~, a qualified wildlife biologist shall conduct a pre-construction raptor and
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-4
5-152
City of Los Angeles June 2013
nesting bird survey no more than 30 days prior to initiation of grading to provide
confirmation on presence or absence of active nests in the vicinity.
• If active nests are encountered, species-specific measures shall be prepared by a qualified
biologist in consultation with the CDFW and implemented to prevent abandonment of the
active nest. At a minimum, grading in the vicinity of the nest shall be deferred until the
young birds have fledged. A nest-setback zone of at least 300 feet for all raptors and 100 feet
for loggerhead shrike and other non-raptors shall be established within which all
construction-related disturbances shall be prohibited. The perimeter of the nest-setback zone
shall be fenced or adequately demarcated with staked flagging at 20-foot intervals, and
construction personnel restricted from the area.
• If permanent avoidance of the nest is not feasible, impacts shall be minimized by prohibiting
disturbance within the nest-setback zone until a qualified biologist verifies that the birds have
either a) not begun egg-laying and incubation, or b) that the juveniles from the nest are
foraging independently and capable of independent survival at an earlier date.
• A survey report by the qualified biologist verifying that the young have fledged shall be
submitted to the City prior to initiation of grading in any nest-setback zone.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Construction
Department of Building and Safety
California Department of Fish and Wildlife
Once, prior to grading or vegetation removal, if grading or
vegetation removal is scheduled during the active nesting period
(February 15th through August 31st), and at any time, in the event
that avoidance of a nest becomes infeasible during grading or
vegetation removal.
Survey report by qualified biologist
BI0-2 Prior to issuance of a demolition or grading permit, the Project Applicant shall have a qualified
biologist conduct Phase 3 entry surveys within the interior of all buildings at the Project Site
identified as having a high to moderate potential to provide bat roost habitat. These surveys shall
involve accessing the attic and other areas (if warranted) to look for evidence of bats and utilizing
heterodyne-style bat detectors to aid in the acoustic detection and identification of potentially
roosting bats.
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-5
5-153
City of Los Angeles June 2013
If bats or bat sign are not encountered during the Phase 3 surveys, the buildings shall be
daylighted prior to demolition. Daylighting includes removal of substantial portions of the roof
to create a well-lit, well-ventilated attic preventing bats from establishing in these buildings.
Daylighting shall occur under the supervision of a qualified biologist at least 48 hours prior to
building demolition. If bats are encountered during daylighting, all disturbance activities within
the structure and within 200 feet shall be halted until: (a) the roost is vacated, or (b) a qualified
biologist has coordinated with CDFW to develop alternative impact avoidance measures, up to
and including bat removal.
If bats or bat sign are encountered during Phase 3 Surveys, the qualified biologists shall leave the
building immediately to avoid further disturbance to roosting bats and conduct an emergence
s~ey. Emergence surveys shall be conducted at dusk to determine where bats are exiting the
building. Emergence surveys shall be conducted to determine the ingress/egress location,
estimate the approximate number of bats using the roost, and identify the species occupying the
roost using an ultrasonic bat detector. Demolition of occupied roosts shall be postponed until
appropriate exclusion and mitigation measures have been determined in consultation with CDFW.
Examples of exclusion measures include one-way barriers installed at the ingress/egress site that
allow bats to exit the roost but not return.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Construction
Department of Building and Safety
California Department of Fish and Wildlife
Once, prior to demolition or grading of each vacated housing
structure
Once, during an emergence survey if bats are encountered
Survey report by qualified biologist; final report upon
completion of demolition
BI0-3 Palm trees at the Project Site shall have the dead frond skirts removed between October 1 and
March 31 before being felled to avoid impacts to roosting Southwestern Yell ow Bats. A qualified
arborist shall supervise removal of palm frond skirts in a systematic manner beginning with the
top fronds and working towards the base of the tree. If bats are encountered during this process,
trimming should halt and remain halted until (a) the roost is confirmed to have been vacated by a
qualified biologist, or (b) a qualified biologist has coordinated with CDFW to develop alternative
measures up to and including bat removal from the trees.
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-6
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City of Los Angeles
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
·Actions Indicating Compliance:
June 2013
Pre-Construction
Department of Building and Safety
California Department of Fish and Wildlife
Daily, during removal of palm trees
Compliance report submitted by contractor;
Survey report and final report by qualified biologist, if bats are
encountered
BI0-4 Prior to issuance of a grading permit, the Project Applicant . shall enter into a Streambed
Alteration Agreement or other documentation (satisfactory to CDFW) with CDFW to provide a
1: 1 replacement of 0.86 acre of suitable streambed and associated riparian habitat either on-site as
additional habitat creation, off-site either through habitat creation or purchase of credits in an
approved mitigation bank in the Los Angeles Basin, or via a combination of these approaches.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Construction
Department of Building and Safety
California Department of Fish and Wildlife
Once, prior to issuance of grading permit
Streambed Alteration Agreement or other documentation to the
satisfaction of the CDFW; submittal of same to Department of
Building and Safety
Section IV.E.1. Cultural Resources -Archaeological Resources
CULT-1: A qualified archaeologist shall be present to monitor all ground-disturbing activities
associated with the Project.
Monitoring Phase:
Enforcement Agency:
Ponte Vista Project
Final Environmental Impact Report
Pre-Construction; Construction
Department of Building and Safety
V. Mitigation Monitoring and Reporting Program
Page V-7
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City of Los Angeles June 2013
Monitoring Agency: Department of City Planning
Monitoring Frequency: Daily, during ground-disturbing activities
Action Indicating Compliance: Quarterly compliance report submitted by qualified archaeologist
CULT-2: Prior to initiation of ground-disturbing activities, the archaeological monitor shall
conduct a brief awareness training session for the benefit of all construction workers and
supervisory personnel. The training, which could be held in conjunction with the
Project's initial on-site safety meeting, shall explain the importance of and legal basis for
the protection of significant archaeological resources. Each worker shall also learn the
proper procedures to follow in the event that cultural resources or human remains/burials
are uncovered during ground-disturbing activities. These procedures include work
curtailment or redirection and the immediate contact of the site supervisor and the
archaeological monitor. It is recommended that this worker education session include
visual images of artifacts that might be found in the Project vicinity.
Monitoring Phase: Pre-Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of City Planning
Monitoring Frequency: Once, prior to ground-disturbing activities
Action Indicating Compliance: Compliance report submitted by qualified archaeologist
CULT-3: In the event that cultural resources are exposed during construction, work in the
immediate vicinity of the find shall stop until a qualified archaeologist can evaluate the
significance of the find. Construction activities may continue in other areas.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of City Planning
Daily, during ground-disturbing activities
V. Mitigation Monitoring and Reporting Program
Page V-8
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City of Los Angeles June 2013
Action Indicating Compliance: Quarterly compliance report submitted by contractor
Section IV.E.2. Cultural Resources -Paleontological Resources
CULT-4: Prior to ground disturbance, the vertebrate fossils observed at locality JLD 102210-02 (see
Appendix IV.E-2) shall be collected. A bulk sample of the matrix (approximately 2,000
pounds) containing the invertebrate specimens shall also be collected and screened.
Following matrix sampling, this area shall be closely monitored during construction
grading to ensure the recovery of any additional scientifically significant fossil
specimens.
Monitoring Phase: Pre-Construction; Construction
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Department of Building and Safety
Department of City Planning
Once, prior to ground-disturbing activities;
Daily, during ground-disturbing activities
Vertebrate fossil collected;
Compliance report for fossil collection submitted by qualified
paleontologist;
Quarterly compliance report for daily monitoring
CULT-5: Prior to ground disturbance, a qualified paleontologist shall be retained to produce a
Paleontological Monitoring and Mitigation Plan for the Project and to supervise
monitoring of construction excavations. Paleontological resource monitoring shall
include inspection of exposed rock units during active excavations within sensitive
geologic sediments. The monitor shall have authority to temporarily divert grading away
from exposed fossils to professionally and efficiently recover the fossil specimens and
collect associated data.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Ponte Vista Project
Final Environmental Impact Report
Pre-Construction
Department of Building and Safety
Department of City Planning
V. Mitigation Monitoring and Reporting Program
Page V-9
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City of Los Angeles
Monitoring Frequency:
Action Indicating Compliance:
June 2013
Once, prior to ground-disturbing activities
Produce a Paleontological Monitoring and Mitigation Plan;
Quarterly compliance report submitted by qualified
paleontologist per mitigation measure CULT-6, below
CULT-6: All Project-related ground disturbance that could potentially affect the San Pedro Sand
and Palos Verdes Sand shall be monitored by a qualified paleontological monitor on a
full-time basis. Part-time monitoring shall be conducted in all Project-related ground
disturbances affecting younger Quaternary alluvium.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Construction
Department of Building and Safety
Department of City Planning
Daily, during ground-disturbing activities
Quarterly compliance report submitted by qualified
paleontologist
CULT-7: At each fossil locality, field data forms shall be used to record pertinent geologic data,
stratigraphic sections shall be measured, and appropriate sediment samples shall be
collected and submitted for analysis.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of City Planning
Prior to ground-disturbing activities;
Daily, during ground-disturbing activities if a new fossil locality
is discovered
V. Mitigation Monitoring and Reporting Program
Page V-10
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City of Los Angeles
Action Indicating Compliance:
June 2013
Field data forms and sediment samples collected by qualified
paleontologist
CULT-8: Recovered fossils shall be prepared to the point of curation, identified by qualified
experts, listed in a database to facilitate analysis, and reposited in a designated
paleontological curation facility.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Construction
Department of Building and Safety
Department of City Planning
As fossils are recovered
Submittal of identified fossils and associated information by
qualified paleontologist
CULT-9: The qualified paleontologist shall prepare a final monitoring and mitigation report to be
filed with the City, the Project Applicant, and the repository.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of City Planning
Once, at end of the construction phase
Submittal of final monitoring and mitigation report by qualified
paleontologist
V. Mitigation Monitoring and Reporting Program
Page V-11
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City of Los Angeles June 2013
Section IV.E.3. Cultural Resources -Historic Resources
No mitigation measures required.
Section IV.F. Geology & Soils
GE0-1 A 50-foot wide structural setback zone shall be designated on each side of the interpreted
centerline of the surface projection of Fault A (100-foot total width), as shown in Figure
IV.F-4. No habitable structures shall be located within this setback zone.
Monitoring Phase: Pre-Construction
Enforcem~nt Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, during Plan Check
Action Indicating Compliance: Plan approval
Section IV.G. Greenhouse Gas Emissions
No mitigation measures required.
Section IV.H. Hazards and Hazardous Materials
HAZ-1 Hydrocarbon-impacted soils encountered during grading and excavation work at the Project Site
shall be characterized. Any soils containing hydrocarbons at levels of concern shall be either
remediated on-site prior to reuse or removed and disposed of in accordance with all applicable
laws and regulations, including those promulgated by the California Department of Toxic
Substances Control (DTSC). All necessary approvals shall be obtained from the lead
enforcement agency including, but not limited to, the Los Angeles County Fire Department
Health and Hazardous Materials Division.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Ponte Vista Project
Final Environmental Impact Report
Construction
Los Angeles County Fire Department Health and Hazardous
Materials Division
Department of Building and Safety
V. Mitigation Monitoring and Reporting Program
Page V-12
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City of Los Angeles
Monitoring Frequency:
Actions Indicating Compliance:
June2013
Once, prior to grading and excavation work
Once, after remediation is complete, if necessary
Characterization of hydrocarbon-impacted soils by contractor;
Approvals Los Angeles County Fire Department Health and
Hazardous Materials Division
HAZ-2 Prior to demolition activities, an investigation for asbestos containing materials (ACMs) shall be
q:mducted and identified asbestos shall be abated in accordance with the South Coast Air
Quality Management District (SCAQMD)'s Rule 1403, as well as all other applicable City,
state, and federal regulations.
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, prior to issuance of demolition permit
Actions Indicating Compliance: Issuance of demolition permit
HAZ-3 Prior to demolition activities, an investigation for lead-based paint (LBP) shall be conducted and
identified LBP shall be abated in accordance with applicable City, State, and federal regulations.
Construction workers shall be properly trained in lead-related construction in order to avoid
exposure of such workers to lead-containing material.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Actions Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of Building and Safety
Once, prior to issuance of demolition permit
Issuance of demolition permit
V. Mitigation Monitoring and Reporting Program
Page V-13
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City of Los Angeles June 2013
Section IV.I. Hydrology and Water Quality
No mitigation measures required
Section IV.J. Land Use and Planning
No mitigation measures required.
Section IV.K. Noise
N0-1 Noise and groundbome vibration construction activities whose specific location on the Project
Site may be flexible (e.g., operation of compressors and generators, cement mixing, general truck
idlip.g) shall be conducted as far as possible from the nearest noise-and vibration-sensitive land
uses.
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Periodic field inspections during construction
Actions Indicating Compliance: Field inspection sign-off;
Quarterly compliance report submitted by contractor
N0-2 When possible, construction activities shall be scheduled so as to avoid operating several pieces of
equipment simultaneously, which causes high noise levels.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Actions Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of Building and Safety
Periodic field inspections during construction
Field inspection sign-off;
Quarterly compliance report submitted by contractor
V. Mitigation Monitoring and Reporting Program
Page V-14
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City of Los Angeles June2013
N0-3 Flexible sound control curtains shall be placed around all drilling apparatuses, drill rigs, and
jackhammers when in use.
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Periodic field inspections during construction
Actions Indicating Compliance: Field inspection sign-off;
Quarterly compliance report submitted by contractor
N0-4 The Project contractor shall use power construction equipment fitted with the best available
technology in noise shielding and muffling devices.
Monitoring Phase: Construction
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: At initiation of construction activities, and quarterly thereafter
Action Indicating Compliance: Quarterly compliance report submitted by contractor
N0-5 Barriers such as plywood structures or flexible sound control curtains extending eight-feet high
shall be erected around the Project Site boundary to minimize the amount of noise on the
surrounding noise-sensitive receptors to the maximum extent feasible during construction.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Actions Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Construction
Department of Building and Safety
Department of Building and Safety
Prior to construction activities, then periodic field inspections
during construction
Field inspection sign-off;
V. Mitigation Monitoring and Reporting Program
Page V-15
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City of Los Angeles June 2013
Quarterly compliance report submitted by contractor
N0-6 All construction truck traffic shall be restricted to truck routes approved by the City of Los
Angeles Department of Building and Safety, which shall avoid residential areas and other
sensitive receptors to the extent feasible. Prior to the commencement of construction at the
Project Site, a meeting shall be held with appropriate representatives of the Cities of Rancho Palos
Verdes, Torrance, and Lomita. The purpose of the meeting will be to designate truck routes for
off-site load hauling vehicles and other construction-related vehicles.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Construction
Department of Building and Safety
Department of Building and Safety
Periodic field inspections during construction
Approval of Haul Route; quarterly compliance report submitted
by contractor
N0-7 Two weeks prior to the commencement of construction at the Project Site, notification shall be
provided to the immediate surrounding cities and off-site residential, school, and memorial park
properties that discloses the construction schedule, including the various types of activities and
equipment that would be occurring throughout the duration of the construction period.
Monitoring Phase: Pre-Construction
Enforcement Agency: Department of Building and Safety
. Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, 2 weeks prior to construction
Actions Indicating Compliance: Compliance report submitted by contractor
N0-8 Equipment warm-up areas, water tanks, and equipment storage areas shall be located a minimum
of 45 feet from abutting sensitive receptors.
Monitoring Phase:
Ponte Vista Project
Final Environmental Impact Report
Construction
V. Mitigation Monitoring and Reporting Program
Page V-16
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City of Los Angeles June 2013
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Building and Safety
Monitoring Frequency: Once, at initiation of construction;
Periodic field inspections during construction
·Actions Indicating Compliance: Field inspection sign-off;
Quarterly compliance report submitted by contractor
Section IV.L. Population and Housing
No mitigation measures required.
Section IV.M.1. Public Services -Fire Protection
No mitigation measures required.
Section IV.M.2. Public Services -Police Protection
No mitigation measures required.
Section IV.M.3. Public Services -Schools
No mitigation measures required.
Section IV.M.4. Public Services-Parks and Recreation
No mitigation measures required.
Section IV.M.5. Public Services -Libraries
No mitigation measures required.
Section IV.N. Transportation and Traffic
TRANS-1 Prior to the generation of 451 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Restripe the southbound approach and median islands on Crenshaw Boulevard at
Pacific Coast Highway to accommodate a second left-tum lane; and
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-17
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City of Los Angeles June 2013
b. Modify the traffic signal to accommodate the installation of the second southbound
left-tum lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action In4icating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 451 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-2 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
modify the existing traffic signal at the intersection of Crenshaw Boulevard and Palos
Verdes Drive North to provide a northbound right-tum signal phase on Crenshaw
Boulevard that would overlap with the westbound left-tum signal phase on Palos Verdes
Drive North. To accommodate this signal phasing, U-tum movements on the westbound
approach of Palos Verdes Drive North shall become prohibited.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-3 Prior to the generation of 151 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Restripe the southbound approach on Western A venue at Lomita Boulevard to
accommodate installation of a right-tum only lane; and
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-18
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City of Los Angeles June 2013
b. Modify the existing traffic signal at Western A venue and Lomita Boulevard to
provide a southbound right-tum signal phase on W estem A venue that would
overlap with the eastbound left-tum signal phase on Lomita Boulevard.
Monitoring Phase: Occupancy
Enforcement Agency: Department of Building and Safety
·Monitoring Agency: Department of Transportation
Monitoring Frequency: Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 151 PM peak hour trips
Action Indicating Compliance: Field inspection sign-off for the listed modifications
TRANS-4 Prior to the generation of 1 PM peak hour trip at the site, the Project Applicant shall do
the following:
a. Modify the southbound approach on Western A venue at Pacific Coast Highway
to install a second left-tum lane and a third through lane; and
b. Modify the existing traffic signal at the intersection of Western A venue and
Pacific Coast Highway to accommodate the modification to the southbound
approach.
Monitoring Phase: Pre-Occupancy
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Department of Building and Safety
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-5 Prior to the generation of 1 PM peak hour trip at the site, the Project Applicant shall do
the following:
a. Modify the westbound approach on Palos Verdes Drive North at Western
Avenue to install a second left-tum lane;
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-19
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City of Los Angeles June 2013
b. Modify the existing median on Palos Verdes Drive North and the existing traffic
signal at the intersection of Palos Verdes Drive North and Western Avenue to
accommodate the modification to the westbound approach;
c. Modify the existing median and restripe the northbound approach on Western
Avenue at Palos Verdes Drive North to install a right-tum only lane;
d. Restripe the southbound approach on Western Avenue at Palos Verdes Drive
North to install a right-tum lane.
Monitoring Phase: Pre-Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Transportation
Monitoring Frequency:
Action Indicating Compliance:
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-6 Prior to the generation of 1 PM peak hour trip at the site, the Project Applicant shall
install a traffic signal at the intersection of Western Avenue and Peninsula Verde Drive.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-7 Prior to the generation of 451 PM peak hour trips at the site, the Project Applicant shall
install a traffic signal at the intersection of Western Avenue and Fitness Drive.
Monitoring Phase:
Enforcement Agency:
Ponte Vista Project
Final Environmental Impact Report
Occupancy
Department of Building and Safety
V. Mitigation Monitoring and Reporting Program
Page V-20
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City of Los Angeles
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
June2013
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 451 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-8 Prior to the generation of 151 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Modify the northbound approach on Western Avenue at Westmont Drive to
install a right-tum only lane; and
b. Restripe the eastbound approach on Westmont Drive at Western A venue to
provide one left-tum lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 151 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-9 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
restripe the northbound approach on Western A venue at Capitol Drive and modify the
raised median to install a right-tum only lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Field inspection sign-off for the listed modifications
V. Mitigation Monitoring and Reporting Program
Page V-21
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City of Los Angeles June 2013
TRANS-10 Prior to the generation of 451 PM peak hour trips at the site, the Project Applicant shall
modify the existing traffic signal to provide a westbound right-tum signal phase on
Summerland A venue that would overlap with the southbound left-tum signal phase on
Western A venue at the Summerland A venue intersection .
. Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 451 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-11 Prior to the generation of 151 PM peak hour trips at the site, the Project Applicant shall
widen the south side of Anaheim Street west of Vermont Avenue by approximately 12
feet to accommodate a 180-foot long turn pocket and install a right-tum only lane at the
eastbound approach to the intersection.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 151 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-12 Prior to the generation of 151 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Widen Gaffey Street north of Westmont Drive to accommodate installation of a
right-tum only lane at the southbound approach to the intersection;
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-22
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City of Los Angeles June 2013
b. Relocate the existing southbound near-side Metro bus stop on Gaffey Street to
the far side of the intersection (i.e., south of the intersection) where a full bus pad
is to installed in the street;
c. Modify the existing traffic signal to provide a southbound right-tum signal phase
on Gaffey Street that would overlap with the eastbound left-tum signal phase on
Westmont Drive at the Gaffey Street intersection; and
d. Enhanced signage shall be provided as needed to guide the right-tum motorists
from the eastbound Anaheim Street approach to Gaffey Street and Palos Verdes
Drive North.
It is noted that the southbound approach on Gaffey Street can be modified to include
continuation of the existing bicycle lane and the southbound right-tum only lane.
Monitoring Phase: Occupancy
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 151 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-13 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Restripe the southbound approach on Gaffey Street at Summerland A venue to
accommodate the installation of a right-tum only lane, and
b. Modify the existing traffic signal to provide a southbound right-tum signal phase
on Gaffey Street that would overlap with the eastbound left-tum signal phase on
Summerland A venue at the Gaffey Street intersection.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Ponte Vista Project
Final Environmental Impact Report
Occupancy
Department of Building and Safety
Department of Transportation
V. Mitigation Monitoring and Reporting Program
Page V-23
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City of Los Angeles June 2013
Monitoring Frequency: Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Action Indicating Compliance: Field inspection sign-off for the listed modifications
TRANS-14 Prior to the generation of 451 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Modify the westbound approach on Sepulveda Boulevard to accommodate the
installation of a second left-tum lane at the Vermont Avenue intersection;
b. Remove the existing raised median island on Sepulveda Boulevard, east of
Vermont Avenue, to accommodate installation of the second westbound left-tum
lane; and
c. Modify the traffic signal to accommodate the installation of the second
westbound left-tum lane.
Monitoring Phase: Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Transportation
Monitoring Frequency: Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 451 PM peak hour trips
Action Indicating Compliance: Field inspection sign-off for the listed modifications
TRANS-15 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Widen the north and south sides of Pacific Coast Highway east and west of
Vermont Avenue to provide up to a 42-foot half roadway on the 50-foot half
right-of-way;
b. Install a second left-tum lane at the westbound approach; and
c. Modify the existing traffic signal and roadway striping at the intersection as
needed.
Ponte Vista Project V. Mitigation Monitoring and Reporting Program
Page V-24 Final Environmental Impact Report
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City of Los Angeles June 2013
Monitoring Phase: Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Transportation
Monitoring Frequency: Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Action Indicating Compliance: Field inspection sign-off for the listed modifications
TRANS-1.6 Prior to the generation of 1 PM peak hour trip at the site, the Project Applicant shall do
the following:
a. Modify the existing traffic signal at Figueroa Place/ Anaheim Street to provide a
southbound right-tum signal phase on Figueroa Place that would overlap with the
eastbound left-tum and through phase sufficiently long enough to accommodate
the southbound right-tum volumes; and
b. Install a new traffic signal at Figueroa Place/I-110 Southbound Off-ramp (north
of Anaheim Street).
Monitoring Phase: Pre-Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Transportation
Monitoring Frequency: Once, prior to issuance of the first certificate of occupancy for
the Project
Action Indicating Compliance: Field inspection sign-off
TRANS-17 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
do the following:
a. Modify the southbound approach on Figueroa Street at the Harbor Freeway
Northbound On-ramp (north of Pacific Coast Highway) to accommodate the
installation of a right-tum-only lane;
b. Adjust the median to accommodate the right-tum-only lane; and
Ponte Vista Project V. Mitigation Monitoring and Reporting Program
Page V-25 Final Environmental Impact Report
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City of Los Angeles June 2013
c. Modify the traffic control equipment as needed.
Monitoring Phase: Occupancy
Enforcement Agency: Department of Building and Safety
Monitoring Agency: Department of Transportation
·Monitoring Frequency:
Action Indicating Compliance:
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-18 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
modify the westbound approach on Pacific Coast Highway at Figueroa Street to
accommodate a fourth through lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-19 Prior to the generation of 1 PM peak hour trip at the site, the Project Applicant shall
install a traffic signal at the Figueroa Street/Harbor Freeway Northbound On-ramp
intersection (north of Anaheim Street). In addition, the existing roadway striping at the
northbound approach to the intersection would be adjusted based on direction from
LADOT.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Ponte Vista Project
Final Environmental Impact Report
Pre-Occupancy
Department of Building and Safety
Department of Transportation
V. Mitigation Monitoring and Reporting Program
Page V-26
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City of Los Angeles
Monitoring Frequency:
Action Indicating Compliance:
June 2013
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-20 Prior to the generation of 301 PM peak hour trips at the site, the Project Applicant shall
widen the westbound approach on Anaheim Street at Figueroa Street by approximately
10 feet to accommodate a 120-foot long turn pocket and install a right-tum-only lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of a certificate of occupancy for a mix of
uses that would generate 301 PM peak hour trips
Field inspection sign-off for the listed modifications
TRANS-21 Prior to completion of the Project, the Project Applicant shall make a fair-share payment
toward the installation of the County's traffic signal synchronization system for the
Normandie Avenue/Sepulveda Boulevard intersection.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy
Department of Building and Safety
Los Angeles County Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-22 Prior to completion of the Project, the Project Applicant shall make a fair-share payment
toward the following:
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-27
5-175
City of Los Angeles June 2013
a. Modify the northboWld approach on Normandie Avenue to accommodate the
installation of a second left-tum lane at the Lomita Boulevard intersection; and
b. Remove the raised median island on Normandie Avenue, south of Lomita
Boulevard, to accommodate the installation of the second northboWld left-tum
lane.
It is noted that the northboWld approach on Normandie A venue can be modified to
include continuation of the existing bicycle lane and the second northboWld left-tum lane.
Monitoring Phase: Pre-Occupancy
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Department of Building and Safety
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-23 Prior to completion of the Project, the Project Applicant shall make a fair-share payment
toward the following improvements:
a. Modify the northboWld and southboWld approaches on Vermont A venue at
Sepulveda Boulevard to accommodate the installation of a second right-tum only
lane; and
b. Remove the existing raised median island on Vermont A venue, south of
Sepulveda Boulevard, and modify the existing raised median island on Vermont
A venue, north of the intersection, to accommodate the installation of the second
right-tum lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Ponte Vista Project
Final Environmental Impact Report
Pre-Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
V. Mitigation Monitoring and Reporting Program
Page V-28
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City of Los Angeles June 2013
Action Indicating Compliance: Field inspection sign-off
TRANS-24 Prior to completion of the Project, the Project Applicant shall make a fair-share payment
toward the following improvements:
a. Modify the eastbound approach on Lomita Boulevard, west of Vermont A venue,
to accommodate the installation of a second left-tum lane;
b. Remove the existing raised median island on Lomita Boulevard, west of Vermont
A venue, and modify the striping on the east leg of the intersection as needed; and
c. Modify the traffic signal to accommodate the installation of the second
southbound left-tum lane.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy
Department of Building and Safety
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-25 Prior to the issuance of Building Permits for each residential building within the Project,
the Project Applicant shall perform, to the satisfaction of LADOT, a trip generation
analysis for the units to be constructed. The results of these studies shall indicate which
of the intersection improvements shown above in Mitigation Measures TRANS-1 through
TRANS-20 must be operational prior to the occupancy of the subject residential units.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Ponte Vista Project
Final Environmental Impact Report
Pre-Construction
Department of Building and Safety
Department of Transportation
As specified for TRANS-I to TRANS-24, above
Trip Generation analysis approval by LADOT
V. Mitigation Monitoring and Reporting Program
Page V-29
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City of Los Angeles June 2013
TRANS-26 The Project Applicant shall coordinate with local and regional transit operators, including
Metro and LADOT, to develop and implement strategies to increase transit utilization by
Project residents. These transportation demand management (TDM) strategies could
include, but would not be limited to, providing bus schedules and transit route
information to residents, providing bicycle racks and information regarding optimal bike
routes to local destinations to residents, and a carpooling information exchange.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy, Occupancy
Department of Transportation
Department of Transportation
Once, prior to issuance of a certificate of occupancy for each
residential structure;
Annually, during occupancy
Annual compliance report submitted by building management
TRANS-27 In conjunction with the street widening of Western Avenue adjacent to the Project Site,
the Applicant shall provide a bus turnout lane and bus stop facilities (shelter, bench and
schedule information) at bus stops adjacent to the Site.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Action Indicating Compliance:
Pre-Occupancy
Department of Transportation
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Field inspection sign-off
TRANS-28 The Project Applicant shall coordinate with LADOT to potentially extend the existing
San Pedro DASH route northerly on Western Avenue to serve the Project Site. If deemed
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-30
5-178
City of Los Angeles June2013
necessary, the Project Applicant shall provide appropriate turnaround facilities to allow
the DASH vehicles to utilize the Project Site as an end point on the route.
Monitoring Phase:
Enforcement Agency:
Monitoring Agency:
Monitoring Frequency:
Actions Indicating Compliance:
Pre-Occupancy
Department of Transportation
Department of Transportation
Once, prior to issuance of the first certificate of occupancy for
the Project
Determination by LADOT regarding the DASH Route;
Field inspection sign-off
Section IV.0.1. Utilities and Service Systems -Water
UTIL-1 In the event of full or partial public street closures, the Project Applicant shall employ
flagmen during the construction of new water lines, to facilitate the flow of traffic.
Monitoring Phase: Construction
Enforcement Agency: Department of Transportation
Monitoring Agency: Department of Transportation
Monitoring Frequency: Periodic field inspections during closures
Actions Indicating Compliance: Field inspection sign-off;
Compliance report submitted by contractor
Section IV.0.2. Utilities and Service Systems-Wastewater
No mitigation measures required.
Section IV.0.3. Utilities and Service Systems -Solid Waste
No mitigation measures required.
Section IV.0.4. Utilities and Service Systems -Energy
No mitigation measures required.
Ponte Vista Project
Final Environmental Impact Report
V. Mitigation Monitoring and Reporting Program
Page V-31
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NWSPNC Planning & Land Use Committee agenda
5-180
Northwest San Pedro Neighborhood Council
Planning and Land Use Committee Agenda
Monday, July 1, 2013, 6:00 p.m.
San Pedro City Hall
638 S. Beacon St.
Room 452
1. Welcome/Introductions
2. Ponte Vista
• Specific Plan
• EIR Release
• Motion
3. Rancho Holdings -Motion
4. Public Comment on Non-Agenda Items
5. Adjourn -To Be Announced
Note: Anything on this Agenda Could Result in a Motion
To Contact us: www.nwsanpedro.org, board@nwsanpedro.org, or 310-732-4522
As a covered entity under Title II of the Americans with Disabilities Act, the City of Los Angeles
does not discriminate on the basis of disability and upon request will provide reasonable
accommodation to ensure equal access to its programs, services, and activities. Sign language
interpreters, assisted listening devices, or other auxiliary aids and/or services may be provided
upon request. To ensure availability of services please make your request at least 3 business
days (72 hours) prior to the meeting by contacting the Department of Neighborhood
Empowerment at 213-485-1360.
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Comments on Ponte Vista project and FEIR:
Rancho Palos Verdes
5-182
CITY OF RANCHO PALOS VERDES
CITY MANAGER'S OFFICE
ADMINISTRATION
29 July 2013
VIA ELECTRONIC & U.S. MAIL
· Henry Chu, City Planner
Los Angeles Department of City Planning, Major Projects
200 N. Spring St., Rm. 750
Los Angeles, CA 90012
SUBJECT: Comments on the Ponte Vista Project (Case Nos. CPC-2012-2558-
GPA-ZC-SP, VTT-71886-MU & ENV-2005-4516-EIR)
Dear Mr. Chu:
Thank you for providing the City of Rancho Palos Verdes with the opportunity to
comment on the Ponte Vista project. I plan to attend tomorrow's public hearing in San
Pedro but also wanted to enter these written comments into the record.
The City of Rancho Palos Verdes has monitored the reuse of the former San Pedro
Navy Housing site for many years, and we were appreciative of the inclusion of several
Rancho Palos Verdes residents on the Ponte Vista Community Advisory Committee in
2007 when the original 2,300-unit proposal for the site was under consideration. At that
time, our City Council went on record as supporting the recommendations of the
Advisory Committee, which rejected a revised 1,950-unit proposal and affirmed the
current R-1 zoning and density for the property. Our City Council believed that these
recommendations were reflective of the desires of the majority of residents who live
near the Ponte Vista site, and we were pleased to see that the Los Angeles Planning
Staff and City Planning Commission ultimately agreed (at least in part) in 2009. ·
Beginning in 2011, we began meeting with the new Ponte Vista development team
under the auspices of the Northwest San Pedro Neighborhood Council's Planning and
Land Use Committee. These meetings initially focused on the new traffic study being
prepared for the revised 1, 135-unit proposal, but eventually included other aspects of
the proposed project, including the draft EIR and Specific Plan.
In January 2013, we submitted extensive comments on the Draft EIR for the revised
Ponte Vista project. We appreciate that the recently-released Final EIR includes
extensive and detailed responses to all of our comments. However, we would take this
opportunity to respectfully raise several issues of concern about the Ponte Vista project
and EIR that we believe have not been adequately addressed:
30940 HAWTHORNE BLVD. I RANCHO PALOS VU<OES, CA 90275-5391 I (310) 544-5205 I FAX (310) 544-52fl1
WWW.W\LQSVERDES.COM/Rf'V
PRINTED ON RECYCLED PA.f'CR 5-183
Henry Chu
29 July 2013
Page2
• We remain concerned about the impact of the proposed project upon emergency
access along Western Avenue, which is the only point of ingress/egress for this
project and for thousands of existing residents in surrounding neighborhoods in
Rancho Palos Verdes and San Pedro.
• Based upon our decades-long experience with school circulation patterns in the
project area, the assumption that middle-school students residing at Ponte Vista
will desire (or even be permitted) to walk to Dodson Middle School is unrealistic.
• Even with the developer's last-minute offer of some limited public open space
within the project, we believe that the City's Eastview Park will experience
increased demand and wear-and-tear as a result of the project, which will not be
offset by the payment of Quimby fees to the City of Los Angeles.
• Although the project's traffic study concludes that adverse project impacts can be
mitigated, we are concerned that some of these proposed mitigation measures
along Western Avenue will be unacceptable to our City and/or CalTrans, thereby
resulting in significant adverse traffic impacts that cannot be mitigated.
• The Final EIR rejects as infeasible several project alternatives that have lower
residential density; include a greater mix of residential and non-residential uses;
and/or conform to the existing zoning of the site, on the basis (at least in part)
that such alternatives are financially infeasible. However, this is a condition that
the City believes that the surrounding community is not obligated to accept as a
rationale for maximizing the currently developer's profit due to the unrealistically
high price paid for the property by previous developers.
Thank you for your consideration of the concerns of the City of Rancho Palos Verdes
regarding the Ponte Vista project. If you have any questions or need additional
information, please feel free to contact me at (310) 544-5226 or via e-mail at
kitf@rpv.com. s#:
Kitfox.Z
Senior Administrative Analyst
cc: Mayor Susan Brooks and Rancho Palos Verdes City Council
Carolyn.Lehr, City Manager
Carolynn Petru, Deputy City Manager
M:\Border lssues\Ponte Vista Project\20130729_Chu_PonteVistaComments.docx
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Comments on Ponte Vista project and FEIR:
NWSPNC
5-185
PONTE VISTA: FEIR COMMENTS AND CONSIDERATIONS
On Tuesday, July 30, 2013, the City of Los Angeles will conduct a public hearing discussing the final EIR
for the Ponte Vista Development located at 26900 S. Western Ave., San Pedro. Starting at 10:00 A.M.,
the hearing will be located at the Port of Los Angeles Administration Building, 425 S. Palos Verdes St.,
Harbor Commission Board Room, San Pedro, CA 90731.
Formally military housing, the Ponte Vista Project will prove to be one of San Pedro's most significant
developments with 61.5 acres of high density housing proposed. On this parcel of land, 830 units are
. projected. We invite you to participate in the hearing process and voice your thoughts, interest or
concerns.
As you may be aware, the Northwest San Pedro Neighborhood Council (NWSPNC) has examined the
draft EIR submitted by the applicant and have found many areas of concern. The Council filed an
extensive response to the draft EIR. Additionally, the NWSPNC, invited the applicant to sit with
representatives to discuss our concerns for quite a while. Recently, discussions occurred with the
applicant making minor modifications to their plans. Earlier this month, the applicant presented
portions of their revised drawings of the project to the NWSPNC highlighting a small change to the
proposed open space associated with the project. The applicant has yet to produce a complete set of
the revised application -it appears the applicant may not know or have all parts of their application
ready. It is the position of the Northwest San Pedro Neighborhood Council that a public hearing
should only be called after the applicant has submitted a complete and stable application packet
giving staff and the community adequate time to review the packet before the hearing.
Therefore, the Northwest San Pedro Neighborhood Council will request at the public hearing next
Tuesday, the hearing panel to continue the hearing to allow the applicant to finish the revised packet
and allow adequate review time for the community.
At its last board meeting on July 8, 2013, the NWSPNC adopted a resolution that expressed "serious
concerns about the project as proposed." In part, the concerns expressed include; a lack of traditional
single family housing; no senior housing; a lack of public open space and no jobs for local community
unemployed or underemployed. The resolution states; "At a minimum the plan should : 1) Include at
least as much real public space as the existing zoning (requires); 2) Have public roads, not gated; 3)
Include senior housing; 4) Include on-site amenities to reduce need to travel from site and 5) Be
consistent with the character of San Pedro." The resolution left the door open for further negotiations
with the applicant. Since then, we have had two meetings with the applicant and their technical staff.
The applicant has expressed willingness to edit some of the shortcomings of their specific plan to
address some of our concerns with the document. From their perspective, the number of units and
exclusive private auto access nature of the project remain unchanged.
1
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PONTE VISTA: FEIR COMMENTS AND CONSIDERATIONS
Besides the density and gated nature, our review and discussion has focused on the:
1) Incompleteness of Specific Plan;
2) Inconsistency with San Pedro Community Plan;
3) Lack of Meaningful Public Participation Opportunity;
. 4) Disregard of the Local Context;
S) Lack of making a publicly accessible and desirable place with public open spaces and recreational
amenities that are walkable and diverse like many of our traditional neighborhoods.
The Northwest San Pedro Neighborhood Council invites you to participate in this public hearing and
support your neighborhood council to express the above-listed issues and other points that may be of
interest you.
2
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Comments on Ponte Vista project and FEIR:
R Neighborhoods R 1
5-188
Planning Department
City of Los Angeles
200 N. Spring St.
Los Angeles, Ca. 90012
Attn: Henry Chu
Major Projects
Room 750C
Case No.: CPC-2012-2558-GPA-ZC-SP, VTT-71886-MU
CEQA No.: ENV-2005-4516-EIR
Hearing Date: July 30, 2013
Re: Single Family Alternative Feasibility Analysis
Dear Mr. Chu,
1. The FEIR analyzes no "build by right" alternative.
The FEIR contains no analysis of a "build by right", single-family home
alternative. It is difficult to see how it can be approved without a good faith
analysis of such an alternative.
The DEIR contained two "no project" alternatives; Alternative A, a "do nothing"
alternative, and Alternative B, a 385 single-family housing project. However,
Alternative B was not a true "no project" alternative because it had no Open
Space component even though part of the site is zoned as Open Space.
Applicant now claims that it can only build 169 homes and needs a zone change
to do even that. It has dropped its Alternative B. The claim that it can only build
169 shows that Alternative B for 385 homes was a sham.
The FEIR does not include an alternative that analyzes what the applicant could
build on the property under a claim of right, by ministerial actions of the City with
no zone change required. The failure to include a build-by-right alternative is a
serious and flagrant omission. Because of this, the FEIR is inadequate and
cannot be approved. The applicant and City should prepare a good faith R1
alternative and circulate it for comment.
2. The Applicant's 169 unit analysis is unsupported by substantial
evidence.
The applicant might claim that its 169 home project discussed in Topical
Comment 6 and in its Concord Group Economic Feasibility Analysis is the single-
family alternative, even though it requires discretionary approval by the City. In
it, they say they cannot build more than 169 single family homes because an
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earthquake fault takes away buildable space, and that they need more land for a
public road to Mary Star so that they can still have private roads in the project
site. As for feasibility, they say that building costs are very high because land
compaction is needed, and the project is not feasible because the land
acquisition cost was $120 million.
There have been a number of R1 numbers thrown about, i.e. 385, 166, 291. The
one thing they all have in common, as applicant acknowledges, is that each is far
superior environmentally while achieving most of the project objectives. They
say, however, that any single family proposal does not achieve the objective of
furnishing a range of housing options, and are not feasible to build.
We agree that the single-family options are superior environmental proposals; it
would be hard to argue to the contrary. We do not agree however, that their
analY.sis is complete or legally sufficient. For example:
[a] They have not discussed nor explained why they cannot use existing lots and
street layouts; we note that the Navy constructed 245 units on the existing pads
so it is hard to understand why the applicant can only build 169. They have also
not addressed the open area where they intend to build six story apartments.
That area is at least six acres. If anything, their claim that only 169 units can be
constructed, shows that an analysis of 385 units in Alternative 8 was superficial.
[b] They have not explained whether soil compaction applies only for the large
buildings they propose, or why it would be required for homes on the lots where
they now exist.
[c] They have not explained why two roads, one private and one public, are
necessary in order to achieve project objectives.
1
[d] They have not analyzed, not discussed in any way, whether they can furnish a
range of housing options using existing R1 zoning. Their analysis does not even
consider how variety might be achieved, and worse, places their "range of
options" objective on a pedestal without ever considering the damage to the
City's efforts to revitalize downtown San Pedro by building competing product
types.
[e] With respect to economic feasibility, they have not.
1/ explained who Bridgeview LLC is nor explained their relationship to
!Star Financial;
2/ explained why they use $120 million as a land cost value. If I Star is the
owner, did anyone pay down any part of the amount owed before !Star took back
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the property? If so, how much did they pay and how much is the real base for
IStar? Did anyone, perhaps Credit Suisse, pay down the amount Bisno et al.
owed, perhaps $40 to $50 million, to avoid a filed foreclosure action so that
!Star's base is actually much lower, perhaps between $62.5 and $72.5 million
rather than $120 million?
3/ explained the jus~ification for using a land value based on speculation
of a zone change rather than a value based on existing zoning.
We also do not agree with their cost feasibility analysis; they use the speculation
value of the property as their cost basis. They should be using the value of the
land for an R 1 development, the use for which it is zoned, and not the
speculation value Bisno paid for it based on a zone change for 2230 units. They
have also used the original bid price for the land value, not the amount that is
their ~ctual cost basis.
To allow an applicant to use a price-paid, speculative cost basis invites massive
manipulation. For example, what would prevent an owner from establishing a
subsidiary, selling the property to the subsidiary at a very high price and taking a
note for the payment, then having the subsidiary apply for a zone change and
increased density using the high note value as a cost basis because a less
dense development is no longer feasible?2 Or, what if an applicant says the land
value with high-rise office buildings on it is $600 Million? Would they be entitled
to claim a land value of $600 Million to show that an R1 project is infeasible?
3. An R1 project is both reasonable and feasible.
The applicant did not propose a zone compliant project, but the earlier
RNeighborhoodsR1 comment letter did. It used 291 units for analysis, based on
15 acres of Open Space zoning. Since then, we have taken into account the
applicants calculation that the correct figure is 9.8 acres and that our earlier
comment letter did not include certain land preparation expenses.
Based on that data, we have modified our numbers. While the pro rata reduction
from 385 would be 323, we have instead used seven houses per acre for R1, or
360 single family homes based on 51.7 acres zoned R1. Further, we have
addressed the variety of housing options objective by providing for a range of
house sizes, with 90 each in sizes from 1400 sf to 2600 sf at increments of 400
sf. While this alone achieves some range of housing options, further design can
achieve even more, with clustering, shared open areas, shared common yards,
for example.
2 We note that both the buyer and seller end up with inflated assets accounts on
their balance sheets through this device.
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As in our earlier comment letter, we use the State of California publication on
residential building costs but have updated the data to 2013 numbers, now
available at http://www.boe.ca.gov/proptaxes/pdf/ah53113.pdf. We once again
use six corner construction with post 1990 Modern quality level D-8 3 and used
the 1.4 cost adjustment specified for Los Angeles County for each of the house
sizes4 . We then added land development costs per lot of $95,000, a calculation
we did not include in our earlier comment letter.5 The big difference however, is
that we also use land values reflecting a wider range of land values, several of
which reflect the actual zoning rather than the inflated, speculation number used
by the applicant.6
SF PSF Cost7 Build Total Land Prep 8 Cost Plus Prep
1400 sf 178.40 249,760 92,000 341,760
1800 sf 168.52 303,336 92,000 395,336
2200.sf 162.22 356,884 92,000 448,884
2600 sf 157.47 409,422 92,000 501,422
For ease of illustration, we then use a uniform price per lot, based on land cost.
Land Cost Cost per Lot Sale Price[Cost per lot plus cost plus prep]
1400 1800 2200 2600
30 Million 83,333 425,093 478,669 532,217 584,755
60 Million 166,666 508,426 562,002 615,550 668,088
75 Million 208,333 550,093 603,669 657,217 709,755
All of these prices are lower than the average in the area and many of them are
lower than the psf costs in Harbor Highlands.
While we believe that using the $120 million speculation price paid by the original
buyer, Bisno, is inappropriate and not legally defensible, even that cost figure
results in sale prices that are lower than the high end of the range in the area:
3 See page 70 of the link for a description. We note that the description there
appears to be superior to the construction types in the surrounding areas.
4 See pages 32 and 76 of the link.
5 This approximates the cost used by applicant's consultant.
6 It appears that !Star's actual cost base is between $62.5 and $72.5 million. We
have included a cost figure of $75 million. We still assert that the proper figure is
what the land is worth as zoned, not what it might be worth if the City rezones it
for them.
7 Per State Guidelines, includes builder profit
8 Includes developer profit. If developer uses existing streets and lots, it is hard
to see why this cost would be this high.
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Land Cost Cost per Lot Sale Price[Cost per lot plus cost plus prep]
1400 1800 2200 2600
120 Million 333,332 675,092 728,668 782,216 834,75
Land valuation is almost the entire point of the applicant's feasibility argument.
Bisno, the original borrower through a LLC, paid a little over $120 million for the
property based on the hope that he could secure a zone change, and applied for
2,230 units very soon after winning the bid. That is not an indication of the land
value for R1 zoning nor has the applicant proved that it is its actual cost basis;
the LLC borrowed about $112.5 million from IStar and later, when Bisno could
not entitle the project, IStar reportedly received $40 to $50 million from one or
more of the persons involved in the project in order to avoid a formal foreclosure
action. Since the figure of $120 million is essential to the applicant's claim that
an R1 alternative is infeasible, the City ought to require proof of its claim.
Please note that the Concord Group Economic Feasibility Analysis changes
dramatically with a truer cost basis. For example, its analysis of a mixed use
project of 477 units pus commercial space shows a loss of $37 million using a
cost basis of $120 million. We have a lot of issues with the study, but even using
their figures, that project would show a profit with any cost basis below $83
million.
Applicant essentially admits that its cost figure is a speculation price when it says
it is infeasible to build a project that complies with present zoning. It is doubtful
that a feasibility analysis under CEQA permits the use of an inflated value, a
value based on some other use.
As between the applicant and the City, who should reward the applicant's
speculative behavior? Should it be the applicant who pays the price for its
speculative behavior or should it be the citizens who bail them out, who pay
through increased traffic, damage to downtown revitalization, etc.?
At any rate, their claim that a R1 alternative is infeasible is a claim that they could
not use the property as it was zoned and that the $120 million claimed cost basis
is a speculation number. Nor is their claim that it is infeasible accurate. They
should be required to do a legally sufficient analysis of an honest R1 alternative.
Please include these comments on behalf of RNeighborhoodsR1.
Sincerely,
Jonathon P. Nave
for RNeighborhoodsR1
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Comments on Ponte Vista project and FEIR:
E-mail from Barbara Velez
5-194
Kit Fox
From:
Sent:
To:
Carolynn Petru
Tuesday, July 30, 2013 10:58 AM
Kit Fox
Subject: FW: Ponte Vista property-IStar Properties
FYI
From: Sherry Hernandez [mailto:renoira@sbcglobal.net]
Sent: Tuesday, July 30, 2013 10:07 AM
To: CC
Cc: councildistrictlS@lacity.org
Subject: Fwd: Ponte Vista property-!Star Properties
Begin forwarded·message:
From: Sherry Hernandez <renoira@sbcglobal.net>
Date: July 30, 2013 10:02:28 AM PDT
To: councilmember.buscaino@lacity.org
Cc: cc@rpv.org, councildistrict@lacity.org
Subject: Re: Ponte Vista property-IStar Properties
On Jul 30, 2013, at 9:57 AM, Sherry Hernandez wrote:
I am writing regarding the Ponte Vista Property and the many problems that are alined with its
development. As a resident of this area, along with other residents we have very crucial concerns and cannot
understand why this has even become a consideration for our city. This property is zones as Rl and the
congestion and problems already plaguing o~r growing city along Western A venue would not environmentally
accommodate multiple dwellings.
Why would our local officials even give a moments thought to accommodating I-Star Financial
and their problems since it would cause our community numerous problems? Lots of citizens
have worked long hours fighting off the Bisno project, why would we now accept a project from
a company that is not an intricate part of our community, a company that would not have to cope
with the numerous problems it would leave in it's wake should this project continue?
In lieu of the Environmental Impact Report, the numerous citizens objections, studies and
reports, in lieu of the recent economic bubble that we are still recuperating from, why would our
city even consider such a project?
Please stand with the citizens of this city and reject the upcoming project. As public servants, it
should be your responsibility to stand with the citizens of the cities you represent.
1
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Thank you in advance for your consideration,
Barbara Velez
2
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Daily Breeze article regarding Ponte Vista project
5-197
San Pedro: Latest Ponte Vista housing plan moves to Planning
Commission
By Donna Littlejohn donna.littlejohn@dailybreeze.com @donna/ittlejohn on Twitter Daily Breeze
Posted: DailyBreeze.com
Long-stalled development plans for the former Navy housing property in San Pedro move to the Los
Angeles Planning Commission on Tuesday, when the latest vision for the Ponte Vista project will be
reviewed.
A hearing on the city's final environmental impact report, released June 27, will be held during the
commission's 10 a.m. meeting at the Port of Los Angeles Administration Building at 425 S. Palos Verdes
St. in San Pedro.
While the new Ponte Vista plan calls for developing 830 homes --much smaller than earlier proposals that
went as high as 2,300 homes --there remains strong opposition among those who want the 61.2-acre
property to remain .R-1, which would cut the numbers back even further.
If you go
What: Los Angeles Planning Commission hearing on the final EIR for the Ponte Vista housing
development in San Pedro
When: 10 a.m. Tuesday, July 30, 2013
Where: Port of Los Angeles Administration Building, 425 S. Palos Verdes St., San Pedro
Information: http://bit.ly/1 bshD3N/. For those who cannot attend, send comments via email to
henry.chu@lacity.org with a copy to joe.buscaino@lacity.org. Include reference number
ENV-2005-4516-EIR in the subject line.
Board members of the Northwest San Pedro Neighborhood Council continued to express "serious
concerns" about the proposal in its July 8 resolution. Those concerns include a lack of traditional
single-family housing in the plan, no dedicated senior housing and not enough public open space.
Supporters, including the San Pedro Chamber of Commerce, believe the project will work in concept.
Developing the entire parcel at 26900 S. Western Ave. with detached single-family homes would not be
financially feasible, according to iStar, which currently owns the property.
Supporters also say it's time to move forward on the project after nearly a decade of discussion.
As originally planned in 2005, Ponte Vista called for building 2,300 homes on a long-vacant and
dilapidated site still dotted with old Navy homes.
The proposal encountered widespread opposition from residents who said it was too dense and would
cause more traffic congestion in the area.
The project went through numerous revisions after that as the property also changed hands. It was
purchased by iStar Financial in 2010. 5-198
Public hearing agenda for Ponte Vista project
5-199
CITY OF LOS ANGELES
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER
HEARING AGENDA -SUBDIVISIONS -HEARING OFFICER
Tuesday, July 30, 2013
425 South Palos Verdes Street,
Harbor Commission Board Room,
San Pedro, CA 90731
APPROXIMATE CASE NO. CD OWNER/ PROPERTY ZONE
TIME ENGINEER ADDRESS/
COMMUNITY
PLAN
1.10:00A.M. VTT-71886-MU, 15 SFI Bridgeview, 26900 S. Western Existing:
CPC-2012-2558-GPA-ZC-SP; LLC/ Cox, Avenue R1-1XL & OS-
Henry Chu ENV-2005-4516-EIR Castle & (Ponte Vista) I 1XL
(213) 978-1324 (830 dwelling units featuring a Nicholson, LLP Wilmington -
combination of single-family and Fuscoe Harbor City Proposed:
homes, duplexes, townhomes, Engineering Community Plan Penta Vista
and flats); General Plan Speci~ic Plan
Amendment from Low Residential designation.
and Open Space to Low Medium I
and II and Medium Residential,
Zone Change, Establishment of a
Specific Plan)
Abbreviations: APC-Area Planning Case; APT-Apartments; C-Condominium; CC-Condominium Conversion; CDP-
Coastal Development Permit; CM-Commercial; CMC-Commercial Condominium; CMCC-Commercial Condo Conversion;
CPC-City Planning Case; ENV-Environmental Assessment Case; IND-Industrial; INDC-Industrial Condominiums; INDCC-
lndustrial Condo Conversion; MANF-Manufacturing; MF-Multiple-Family; MOD-Modification; PP-Project Permit; PS-Private
Street; RV-Reversion to Acreage; SC-Stock Cooperative; SF-Single-Family; SUB-Subdivision; ZC-Zone Change
EIR-Environmental Impact Report; MND-Mitigated Negative Declaration; ND-Negative Declaration; CE-Categorical Exemption
NOTE: Per State Government Code Section 65009(b)(2):
If you challenge any agenda items in court, you may be limited to raising only those issues raised in
person at the public hearing, or in correspondence received at or before the public hearing.
If you seek judicial review of any decision of the City pursuant to California Code of Civil Procedure Section 1094.5, the
petition for writ of mandate pursuant to that section must be filed no later than the 90th day following the date on which the
City's decision became final pursuant to California Code of Civil Procedure Section 1094.6. There may be other time limits
which also affect your ability to seek judicial review.
•:• FACILITY AND PARKING ARE WHEELCHAIR ACCESSIBLE
•:• SIGN LANGUAGE INTERPRETERS, ASSISTIVE LISTENING DEVICES, OR OTHER AUXILIARY AIDS
AND/OR SERVICES MAY BE PROVIDED IF REQUESTED AT LEAST 72-HOURS PRIOR TO THIS MEETING
BY CALLING (213) 847-6564.
5-200
Revised NOP for
Los Angeles County General Plan Update
5-201
REVISED NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT
REPORT AND NOTICE OF PUBLIC SCOPING MEETING
To:
Date:
Subject:
State Clearinghouse, Responsible and Trustee Agencies, and Interested Individuals
June 20, 2013
Notice of Preparation of a Draft Environmental Impact Report and Notice of Public
Scoping Meeting
Project: Los Angeles County General Plan Update
Lead Agency: . Los Angeles County
NOTICE IS HEREBY GIVEN that County of Los Angeles, through the Department of Regional Planning
(Department), will be the Lead Agency for the preparation of an Environmental Impact Report (EIR) in
accordance with the California Environmental Quality Act (CEQA) for the project described below. The
County released the Notice of Preparation (NOP) for a public review period of 30 days for this process
from August 15, 2011 to September 14, 2011. The project description in the August 15, 2011 NOP
included an update to the General Plan (excluding the Housing Element) and an update to the Antelope
Valley Area Plan. This notice advises interested parties and responsible agencies that the project
description has been revised to exclude the Antelope Valley Area Plan Update. The revisions to the
proposed project result in changes to the scope of the upcoming EIR from what was previously
identified in the August 15, 2011 NOP. An EIR for the Antelope Valley Area Plan Update will be
processed and noticed separately.
PROJECT INFORMATION: The project is a comprehensive update of the Los Angeles County General
Plan. The project includes goals, policies, implementation programs and ordinances. The project covers
the unincorporated areas of Los Angeles County and accommodates new housing and employment
opportunities in anticipation of population growth in the County and the region. The General Plan
Update focuses growth in the unincorporated areas with access to services and infrastructure and
reduces the potential for growth in the County's environmentally sensitive and hazardous areas. The
project will replace the adopted General Plan.
For a comprehensive project description and additional information on the General Plan Update, please
visit http://planning.lacounty.gov/generalplan, or contact the General Plan Development and Housing
Section at (213) 974-6417 or genplan@planning.lacounty.gov.
NOTICE OF PREPARATION: A Revised NOP for the EIR, which describes the project and outlines the
potential environmental impacts, has been prepared. The Revised NOP will be available for review from June
28, 2013 to July 29, 2013 on the Department's website at http://planning.lacounty.gov/generalplan/ceqa.
Hardcopies will be available at the Department's main office and field office locations listed at the following
link: http://planning.lacounty.gov/locations; all County libraries; Calabasas Library located at 200 Civic Center
Way, Calabasas, CA 91302; and Altadena Library (Main Library) located at 600 East Mariposa Street,
Altadena, CA 91001.
Page 1of2
5-202
The Department is seeking input from both agencies and members of the public on the scope and
content of the environmental information and analysis to be contained in the EIR. Any correspondence
related to the General Plan Update received as part of the first NOP does not have to be resubmitted; it
has already been incorporated as part of the environmental review process for the project. Due to the
time limits mandated by State law, written comments must be sent via mail, e-mail, or fax no later than
5:00 PM on Monday, July 29, 2013. Please send your comments at the earliest possible date to:
Connie Chung, AICP
Supervising Regional Planner
Los Angeles County
Department of Regional Planning
320 W. Temple Street, Room 1356
Los Angeles, CA 90012
Email: genplan@planning.lacounty.gov
Fax: (213) 626-0434
PUBLIC SCOPING MEETING: Pursuant to the California Public Resources Code Section 21803.9, Los
Angeles County will conduct a public scoping meeting. This meeting will provide a public forum for
information dissemination and dialogue regarding the components of the proposed project, the overall
process, and the draft EIR. While staff will summarize the issues raised at these meetings, anyone
wishing to make formal comments on the NOP must do so in writing. The public scoping meeting will be
held at the time and location listed below:
Date:
Time:
Location:
July 11, 2013
5:00 p.m. to 6:00 p.m.
Los Angeles County
Department of Regional Planning
320 W. Temple Street, Room 150
Los Angeles, CA 90012
The scoping meeting will also be streamed live at the following link:
http://streaming.planning.lacounty.gov/meeting. Afterward, the recorded presentation and meeting will
also be posted at the following link: http://planning.lacounty.gov/generalplan/ceqa.
Page 2 of2
5-203
REVISED NOTICE OF PREPARATION (NOP)
County of Los Angeles, Department of Regional Planning
Project Title: Los Angeles County General Plan Update
Introduction: The County of Los Angeles will be the Lead Agency and will prepare an environmental impact
report for the comprehensive update of the Los Angeles County General Plan. The project includes goals,
policies, implementation programs and ordinances. The project covers the unincorporated areas of Los Angeles
County and accommodates new housing and employment opportunities in anticipation of population growth in the
County and the region. The project will replace the adopted General Plan.
The County released the NOP for a public review period of 30days for this process from August 15, 2011 to
September 14, 2011. The project description in the August 15, 2011 NOP included an update to the General Plan
(excluding the Housing Element) and an update to the Antelope Valley Area Plan. This notice advises interested
parties and responsible agencies that the project description has been revised to exclude the Antelope Valley
Area Plan Update. The revisions to the proposed project result in changes to the scope of the upcoming EIR from
what was previously identified in the August 15, 2011 NOP. An EIR for the Antelope Valley Area Plan Update will
be processed and noticed separately.
1. ENVIRONMENTAL SETTING
1.1 Project Location
Los Angeles County is geographically one of the largest counties in the country with approximately 4,083 square
miles. The County stretches along 75 miles of the Pacific Coast of Southern California and is bordered to the east
by Orange County and San Bernardino County, to the north by Kern County, and to the west by Ventura County.
The County also includes two offshore islands, Santa Catalina Island and San Clemente Island, as shown in
Figure 1, Regional Location. The unincorporated areas account for approximately 65 percent of the total land area
of the County.
The unincorporated areas in the northern portion of the County are covered by large amounts of sparsely
populated land and include the Angeles National Forest, part of the Los Padres National Forest, and the Mojave
Desert. The unincorporated areas in the southern portion of the County consist of 58 noncontiguous land areas,
which are often referred to as the County's unincorporated urban islands. The County's governmental structure
comprises five Supervisorial Districts with the Los Angeles County Board of Supervisors as the governing body
responsible for making all legislative land use decisions for the unincorporated areas. Maps of the Supervisorial
Districts and unincorporated areas of the County are available online on the Department of Regional Planning's
website: http://planning.lacounty.gov/generalplan.
1.2 General Plan and Planning Areas Framework
The Los Angeles County General Plan is the guide for growth and development for the unincorporated areas of
Los Angeles County. The General Plan guides the long-term physical development and conservation of the
County's land and environment through a framework of goals, policies, and implementation programs. The
California Government Code requires that each city and county adopt a general plan "for the physical
development of the county or city, and any land outside its boundaries which bears relation to its planning." Long-
range planning provides the opportunity to responsibly manage and direct future development, conserve natural
areas, support economic development objectives, and improve mobility in the region.
Page 1of14 5-204
The Los Angeles County General Plan serves as the framework for existing community-based plans, including
Area Plans, Community Plans, Neighborhood Plans, and Local Coastal Land Use Plans. Area Plans provide
additional details to General Plan goals and policies, focusing on sub regional land use issues and other policy
needs that are specific to the Planning Area. Community Plans and Neighborhood Plans cover smaller
geographic areas within the Planning Area, and address neighborhood and/or community level land use policy
issues. Local Coastal Land Use Plans are components of the Local Coastal Program (LCP}, which consist of land
use plans, zoning ordinances and maps, and implementing actions to protect coastal resources within the state
designated coastal zone. All community-based plans are components of the General Plan and must be consistent
with General Plan goals and policies. The following is a list of adopted community-based plans:
Area Plans
• Antelope Valley Area Plan (adopted 1986)
. • Santa Clarita Valley Area Plan (adopted 1984; updated 2012)
• Santa Monica Mountains North Area Plan (adopted 2000)
Community Plans
• Altadena Community Plan (adopted 1986)
• East Los Angeles Community Plan (adopted 1988)
• Hacienda Heights Community Plan (adopted 1978; updated 2011)
• Rowland Heights Community Plan (adopted 1981)
• Twin Lakes Community Plan (adopted 1991)
• Walnut Park Neighborhood Plan (adopted 1987)
• West Athens-Westmont Community Plan (adopted 1990)
Local Coastal Land Use Plans
• Marina del Rey Local Coastal Land Use Plan (adopted; certified Local Coastal Program 1996; updated
2012)
• Malibu Local Coastal Land Use Plan (adopted 1986)
• Santa Catalina Island Local Coastal Land Use Plan (adopted; certified Local Coastal Program 1983)
1.3 Adopted General Plan
The County's efforts to prepare a General Plan for the unincorporated areas began in the 1970's with the creation
of the Environmental Development Guide. In 1973, the County adopted its first General Plan, followed by a
comprehensive update in 1980. The County's adopted General Plan and community-based plans can be found
online at http://planning.lacounty.gov/plans/adopted.
2. PROJECT DESCRIPTION
The proposed project is a comprehensive update of the Los Angeles County General Plan. The project includes
goals, policies, implementing programs, and ordinances. The project covers the unincorporated areas of Los
Angeles County and accommodates new housing and employment opportunities in anticipation of population
growth in the County and the region. The General Plan Update focuses growth in the unincorporated areas with
access to services and infrastructure and reduces the potential for growth in the County's environmentally
sensitive and hazardous areas.
2.1 Draft General Plan
The proposed project is the preparation of a comprehensive update of the County's 1980 General Plan that meets
California Code requirements for a general plan. The Draft General Plan accommodates new housing and jobs
within the unincorporated area in anticipation of population growth in the County and the region through the year
2035. The theme of the Draft General Plan is sustainability. Sustainability requires that planning practices meet
the County's needs without compromising the ability of future generations to realize their economic, social, and
environmental goals. The Draft General Plan has been designed to utilize, promote, and implement policies that
promote healthy, livable, and sustainable communities. Five guiding principles-Smart Growth; Sufficient
Page 2 of14 5-205
Community Services and Infrastructure; Strong and Diversified Economy; Environmental Resource Management;
and Healthy, Livable and Equitable Communities-are supported by community-identified goals and stakeholder
input, and further the overall goal of sustainability throughout the Draft General Plan.
The Draft General Plan consists of the following elements (the update to the Housing Element, which is a
component of the General Plan, is underway through a separate effort):
• Land Use Element
• Mobility Element
• Air Quality Element
• Conservation and Open Space Element
• Parks and Recreation Element
• Noise Element
• Safety Element
• Public Services and Facilities Element
• Economic Development Element
To clarify the framework of the General Plan and to facilitate the planning of the unincorporated areas, the Draft
General Plan establishes 11 Planning Areas, as shown online at http://planning.lacounty.gov/generalplan.
• Antelope Valley Planning Area
• Coastal Islands Planning Area
• East San Gabriel Valley Planning Area
• Gateway Planning Area
• Metro Planning Area
• San Fernando Planning Area
• Santa Clarita Valley Planning Area
• Santa Monica Mountains Planning Area
• South Bay Planning Area
• West San Gabriel Valley Planning Area
• Westside Planning Area
The Draft General Plan provides a framework of goals and policies to achieve countywide planning objectives
within the 11 Planning Areas, and serves as the foundation for all existing and future community-based plans.
Furthermore, the Draft General Plan involves a revision to the current General Plan land use policy map, and
revisions to elements required by the State of California and optional elements. Table 1, Proposed General Plan,
provides a description of the land uses designations proposed in the Land Use Plan. The following describe the
major land use policies in the Draft General Plan, which are supported by goals, policies, programs and strategic
changes to the land use policy maps:
Transit Oriented Districts: Transit Oriented Districts (TOD) are areas within a 1/2 mile radius from a major
transit stop. TOD areas are located in proximity to major transit stops, provide the best opportunities for infill
development, and are well-suited for higher density housing, mixed uses, and civic activities. The TODs guide
the increase of residential densities and the allowance of mixed uses along major corridors in the draft land
use policy maps. All TODs are envisioned in the future to have a TOD specific plan with standards,
regulations, and capital improvement plans that tailor to the unique characteristics and needs of each
community.
Special Management Areas: The County's Special Management Areas require additional development
regulations that are necessary to prevent the loss of life and property, and to protect the natural environment
and important resources. Special Management Areas include but are not limited to Agricultural Resource
Areas, Airport Influence Areas, Seismic Hazard Zones, Flood Hazard Zones, Significant Ecological Areas,
Hillside Management Areas, and Very High Fire Hazard Severity Zones. The Draft General Plan minimizes
Page 3 of14 5-206
risks to hazards and limits development in Special Management Areas through goals, policies and programs.
The Draft General Plan also includes the Hazard, Environmental, and Resource Constraints Model, which is
a visual representation of the Special Management Areas and serves 1 ) as a tool to inform land use policies
for future community-based planning initiatives; 2) to inform applicants and planners of potential site
constraints and regulations; and 3) to direct land use policies and the development of planning regulations
and procedures to address hazard, environmental, and resource constraints.
Preservation of Industrial Land: Planning for future growth and the appropriate land use mix has major
impacts on the local and regional economy. The Draft General Plan includes land uses and policies that
protect the remaining industrial land in the unincorporated areas. The Draft General Plan identifies
Employment Protection Districts, which are economically viable industrial land and employment-rich lands,
with policies to prevent the conversion of industrial land to non-industrial uses.
Table 1
Proposed General Plan
Bldg. Sq.
Acres3
Density/
ulation5
Footage (in
Land Use Designation lntensity4 Units Po thousands Jobs5
..... 1•··-'1:::11~1~1•::.i••"ll••• '""'..:' •
~BP.P9~ ·· ~1:,.'·~~i~ .. ·. 1d~:~2~:r. .. .·. 1~l~~~~t···· ~.~~~~~~8 ./ (:J::j'$1~~4~.~ ·~1~a;~~a·
Commercial 962 --0 0 20,982 41,872
CG -General Commercial 961.14 0.5 (F) 0 0 20,933 41,842
CM -Major Commercial 0.64 1.5 (F) 0 0 42 17
CR -Rural Commercial 0.62 0.25 (F} 0 0 7 13
Industrial 3,560 --0 0 77,531 59,365
IH -Heavy Industrial 1,706 0.5 (F) 0 0 37,167 28,458
IL -Light Industrial 1,853 0.5 (F) 0 0 40,365 30,907
10 -Industrial Office 0 1 (F) 0 0 0 0
Mixed Use & Specific Plan 459 --19,003 53,019 10,347 38,949
MU -Mixed Use 158 120 (D) I 19,003 53,019 10,347 20,249 1.5 (F)
SP -Universal Studios Specific 301 --0 0 0 18,700 Plan
Open Space 57,374 --0 0 0 1,933
OS-BLM -Bureau of Land 76 0 0 0 0 Management --
OS-C -Conservation 7,648 --0 0 0 0
OS-ML -Military Land 36,615 --0 0 0 0
OS-MR -Mineral Resources 1,088 --0 0 0 0
OS-NF -National Forest 2,777 --0 0 0 0
OS-PR -Parks and Recreation 7,105 --0 0 0 1,625
OS-W-Water 2,065 --0 0 0 307
Public I Semi-Public 6,917 --0 0 452,681 29,267
P -Public and Semi-Public 6,917 1.5 (F) 0 0 452,681 29,267
Rural 16,324 --2,080 8,008.70 0 101
RL40 -Rural Land 40 38 0.03 (D) 1 4 0 0
Page 4 of14 5-207
Table 1
Proposed General Plan
Bldg. Sq.
Density/
Population5
Footage (in
Jobs5 Land Use Designation Acres3 lntensity4 Units thousands)
RL20 -Rural Land 20 12,759 0.05 (D) 638 2,456 0 0
RL 10 -Rural Land 10 2,247 0.1 (D) 225 865 0 0
RL2 -Rural Land 2 126 0.5 (D) 63 243 0 0
RL 1 -Rural Land 1 1,153 1 (D) 1,153 4,440 0 101
Residential 21,025 --173,058 605,560 0 4,674
H2 • Residential 2 1,462 1.6 (D) 2,340 9,007 0 100
H5 -Residential 5 1,768 4 (D) 7,073 27,229 0 100
H9 -Residential 9 14,394 7.2 (D) 103,640 373,103 0 3,086
H18 -Residential 18 2,469.36 14.4 (D) 35,559 128,011 0 711
H30 -Residential 30 808.31 24 (D) 19,337 53,951 0 427
H50 -Residential 50 117.90 40 (D) 4,716 13, 157 0 250
H 100 -Residential 100 4.93 80 (D) 395 1, 101 0 0
•11(•11'111'1111••'"'"'~·
'A;~Jt~PgN~''<1 ' :··· ·~· .... ..... ,t,·~~iqi·~: .·. ...... , ~1,~596 ••.8i''it ::::;;; ~~~,~~ '·\f\:?1~il§~ .· •, .. . . :;;,:1:l;:'
Commercial 64 ·-0 0 2,784 9,376
GC -General Commercial 64 1 (F) 0 0 2,784 9,376
Industrial 38 ·-0 0 1,004 3,075
BP -Business Park 38 0.6 (F) 0 0 1,004 3,075
Infrastructure 815 .. 0 0 0 0
Public Streets 815 --0 0 0 0
Mixed Use & Specific Plan 255 .. 904 2,800 2,226 4,561
MU -Mixed Use "Center" 37 17.6(D)/ 642 1,792 2,226 4,411 1.4 (F)
SP -La Vina Specific Plan 219 --262 1,008 0 150
Public & Open Space 915 ·-0 0 3,981 1,066
I -Institutions 183 0.5 (F) 0 0 3,981 803
MOS -Miscellaneous Open 68 --0 0 0 100 Space
NF -National Forest and 416 0 0 0 0 National Forest Managed Lands --
PR -Public and Private 103 0 0 0 164 Recreation --
U -Utilities 145 --0 0 0 0
Residential 3,516 --15,335 58,558 0 386
E -Estate/Equestrian 93 0.4 (D) 37 144 0 5
N -Non-Urban 327 1 (D) 105 403 0 0
LD -Low Density Residential 3,068 4.8 (D) 14,726 56,694 0 377
LMD -Low/Medium Density 1 9.6 (D) 12 46 0 0 Residential
MD -Medium Density 26 17.6 (D) 456 1,271 0 4 Residential
Page 5 of14 5-208
Table 1
Proposed General Plan
Bldg. Sq.
Acres3
Density!
Population5
Footage (in
Jobs5 Land Use Designation lntensitv4 Units thousands)
ANTELOPE VALLEY.AREA 1,132~!4ft '27:8,158 1.1070,571 46,870 ~1.~19 .Pl.:.Af\11 . .. I!.<
'
. ;'.', ,... ,•. ,,
Commercial 902 .. 0 0 19,652 38,329
C -Commercial 902 0.5 (F) 0 0 19,652 38,329
Industrial 579 --0 0 12,606 9,652
M -.lndustrv 579 0.5 (F) 0 0 12,606 9,652
Open Space 583,967 .. 0 0 0 524
OS-BLM -Bureau of Land 2,436 0 0 0 0 Management --
0 -Open Space 70,471' --0 0 0 324
0-NF -National Forest 510,413 --0 0 0 200
0-W -Water Body 648 --0 0 0 0
Public I Semi-Public 17,029 .. 0 0 14,613 767
Airport 16,358 0 0 0 50
P -Public and Semi-Public 671 1.5 (F) 0 0 14,613 717 Facility
Rural 522,077 .. 261,773 1,007,826 0 1,361
N 1 -Non-Urban 1 502,174 0.5 (D) 242,712 934,440 0 926
N2 -Non-Urban 2 19,903 1.0 (D) 19,061 73,385 0 436
Residential 5,541 "" 16,385 62,746 0 485
U1 -Urban 1 4,450 2.6 (D) 11,411 43,931 0 335
U1 .5 -Urban 1.5 140 1.6 (D) 224 862 0 0
U2 -Urban 2 738 5.3 (D) 3,248 12,505 0 150
U2-D -Urban 2 (specific 50 3.2 (D) 160 614 0 0 development criteria)
U3 -Urban 3 9 12.0 (D) 105 377 0 0
U3-D -Urban 3 (specific 155 8.0 (D) 1,238 4,457 0 0 development criteria)
Infrastructure 2,649 "" 0 0 0 100
TC -Transportation Corridor 2,649 --0 0 0 100
EAST.~QSANGELE~! I 3;~'1 :;·v. •' ,,. > , . ;
I .. 41,60$ 1),.:: 128,487'·• · 44Hs9 42i459 COMIVIONlTv PLAN '·• [' ; ' ! .·.,. ··.
Commercial 338 "" 0 0 21,255 26,156
CC-Community Commercial 150 1.5 (F) 0 0 9,778 19,239
CM -Commercial 93 1.3 (F) 0 0 5,252 4,289 Manufacturing
MC -Major Commercial 95 1.5 (F) 0 0 6,225 2,627
Industrial 158 "" 0 0 6,873 5,234
I -Industrial 158 1 (F) 0 0 6,873 5,234
Mixed Use & Specific Plan 65 "" 1,563 4,361 3,404 6,848
Page 6 of14 5-209
Table 1
Proposed General Plan
Bldg. Sq.
Acres3
Density/
Population5
Footage (in
Jobs5 Land Use Designation lntensity4 Units thousands)
CR -Commercial Residential 65 24 (D) I 1,563 4,361 3,404 6,848 1.2 (F)
Other 21 --0 0 0 0
RP -Residential Parking 21 --0 0 0 0
Public & Open Space 582 .. 0 0 12,667 2,753
P -Public Use 582 0.5 (F) 0 0 12,667 2,753
Residential 2,218 .. 40,045 124,127 0 1,469
LD -Low Density Residential 132 6.4 (D) 843 3,246 0 0
LMD -Low/Medium Density 1,045 13.6 (D) 14,207 51, 146 0 565 Residential
MD -Medium Density 1,041 24 (D) 24,994 69,735 0 904 Residential
HACtENDAHEIGHtS .·:· .. J;~}$~o /•;••::• i:.:
65833
•· ... :
;jij 310 .CQIVIM(JN1ty P,LAN · .· · ...... n+ :.: 17,~~~ • 9,864 : < '·: .. '
::: ::· ·: ·•
Commercial 131 .. 0 0 5,708 11,194
CG -General Commercial 131 1 (F) 0 0 5,708 11, 194
Industrial 28 -· 0 0 609 466
IL -Light Industrial 28 0.5 (F) 0 0 609 466
Public & Open Space 1,709 .. 0 0 3,547 300
OS-C -Open Space 403 --0 0 0 0 Conservation
OS-PR -Open Space Parks 1, 131 --0 0 0 200 and Recreation
P-CS -Public and Semi-Public 42 0.5 (F) 0 0 651 100 Community Serving
P-TF -Public and Semi-Public 0 0 0 0 0 Transportation Facilities --
P-UF -Public and Semi-Public 133 0.5 (F) 0 0 2,896 0 Utilities and Facilities
Rural 862 .. 145 559 0 35
RL 10 -Rural Lands 1 O 714 0.1 (D) 71 275 0 0
RL2 -Rural Lands 2 148 0.5 (D) 74 284 0 35
Residential 3,630 .. 17,288 65,274 0 1,315
H2 -Residential 2 719 1.6 (D) 1,150 4,429 0 100
HS -Residential 5 2,110 4 (D) 8,441 32,499 0 1,000
H9 -Residential 9 582 7.2 (D) 4,277 16,466 0 200
H18 -Residential 18 201 14.4 (D) 2,889 10,402 0 15
H30 -Residential 30 10 24 (D) 248 693 0 0
H50 -Residential 50 7 40 (D) 281 785 0 0
Page 7 of14 5-210
Table 1
Proposed General Plan
Bldg. Sq.
Acres3
Density!
Population5
Footage (in
Jobs5 Land Use Designation lntensity4 Units thousands)
~~~g~~o;ctNCQASTAL .. 5.1,.141 .. . 4,347 16,729 15~239 22,13.8
: . ' ', ,,.:_:-.. :(' ·•
Commercial 729 --0 0 6,352 11,929
12 -Rural Business 18 0.2 (F) 0 0 158 309
13 -General Commercial 0.45 0.2 (F) 0 0 4 8
14 -Office/Commercial 0.18 0.2 (F) 0 0 2 5 Services
16 -Low-Intensity Visitor-710 0.2 (F) 0 0 6,187 11,603 Serving Commercial Recreation
17 -Recreation-Serving 0.20 0.2 (F) 0 0 2 3 Commercial
Mixed Use & Specific Plan 39 --0 0 336 672
MU -Mixed Use -Specific Plan 39 0.2 (F) 0 0 336 672 Required
Public & Open Space 16,423 --0 0 8,551 7,776
11 -Institution and Public 982 0.2 (F) 0 0 8,551 7,600 Facilities
18 -Parks 15,441 --0 0 0 175
Rural 32,945 --3,298 12,697 0 1,761
M2 -Mountain Land 23,051 0.05 (D) 1,153 4,437 0 1,603
5 -Rural Land Ill 2,615 0.5 (D) 1,196 4,604 0 120
4 -Rural Land II 3,375 0.2 (D) 603 2,320 0 15
3 -Rural Land I 3,905 0.1 (D) 347 1,336 0 23
Residential 1,005 --1,049 4,032 0 0
6 -Residential I 903 1 (D) 674 2,595 0 0
8A -Residential lll(A) 21 3.2 (D) 31 121 0 0
8B -Residential lll(B) 75 4.8 (D) 331 1,273 0 0
9B -Residential IV(B) 5 8 (D) 7 29 0 0
9C -Residential IV(C) 0.47 16 (D) 5 15 0 0
M~RINA··OelQ~ISY··~QC,AL '7'~684 21,439
: .. ···.' r···· 694 --• 1<861..1 4,493 COA$TAL .. t~ND usi; Pl-AN ... ·.· .. .··· ....... ~ ... ·.····· . .•
Commercial 86 --0 0 1,413 4,111
H -Hotel 26 1027
rooms 0 0 0 1,027
MC -Marine Commercial 24 0.5 (F) 0 0 521 1,020
0 -Office 5 1 (F) 0 0 235 780
VS/CC -Visitor-Serving I 30 0.5 (F) 0 0 656 1,284 Convenience Commercial
Industrial 5 --0 0 112 250
PF -Public Facilities 5 0.5 (F) 0 0 112 250
Other 401 --0 0 82 82
B -Boat Storage 19 0.1 (F) 0 0 82 82
Page 8 of14
5-211
Table 1
Proposed General Plan
Bldg. Sq.
Density/
Population5
Footage (in
Jobs5 Land Use Designation Acres3 lntensitv4 Units thousands)
P -Parking 17 --0 0 0 0
W-Water 366 --0 0 0 0
Public & Open Space 42 --0 0 0 0
OS -Open Space 42 --0 0 0 0
Residential 159 --7,684 21,439 254 50
R 111 -Residential 111 38 28 (D) 1,063 2,966 0 0
R IV -Residential IV 23 36 (D) 814 2,270 0 0
R V -Residential V 97 60 (D) 5,807 16,202 0 0
SA-Senior Accommodations 2 --0 0 254 50
~ i:f:422: }:, r;:
< 14,0f) ··~·· 50900 .1i,1.34 •r.20 1~~~·
'' ·• , : .: ', '·l ' '
' ' ', '
Commercial 192 --0 0 8,378 15,764
C -Commercial 192 1 (F) 0 0 8,378 15,764
Industrial 144 --0 0 3,756 3,027
I -Industrial 144 0.6 (F) 0 0 3,756 3,027
Other 793 --723 2,783 0 0
TOS -Transitional Open Space 272 0.2 (D) 54 210 0 0 (N1)
TOS -Transitional Open Space 268 1 (D) 181 695 0 0 (N2)
TOS -Transitional Open Space 252 2.56 (D) 488 1,878 0 0 (U1)
Public & Open Space 1,566 --0 0 0 194
0 -Open Space 1,566 --0 0 0 194
Residential 4,727 --13,392 48,117 0 1,676
N1 -Non-Urban 1 1,459 0.2 (D) 292 1,124 0 0
N2 -Non-Urban 2 510 1 (D) 449 1,730 0 200
U1 -Urban 1 1,276 2.56 (D) 2,857 10,998 0 401
U2 -Urban 2 1,278 4.8 (D) 5,903 22,728 0 1,075
U3 -Urban 3 68 9.6 (D) 643 2,477 0 0
U4 -Urban 4 51 17.6 (D) 902 2,517 0 0
US -Urban 5 84 28 (D) 2,345 6,543 0 0
SANTA.GAlAl..INAISJ..A.NP . ::.•: I'•· ' ,,
LQ~AL ctt~sfAt LAND'ldSE '$J,p)137 ,,', 21 0 0 570 PLAN ·'· .• ·· ''''' ' ' ' . (';~; ... ,' .....
Commercial 26 --0 0 0 7
Commercial -Two Harbors 3 --0 0 0 7
Lodges/Inns -Two Harbors 14 --0 0 0 0
Marine Commercial -Two 3 0 0 0 0 Harbors --
Utilities/Services -Two Harbors 7 --0 0 0 0
·Page 9of14 5-212
Table 1
Proposed General Plan
Bldg. Sq.
Density/
Population5
Footage (in
Jobs5 Land Use Designation Acres3 lntensity4 Units thousands)
Industrial 690 --0 0 0 6
Extractive Use -Catalina 514 --0 0 0 0
Industrial/Transportation -Two 5 --0 0 0 0 Harbors
Industrial/Transportation/Utilities 172 --0 0 0 6 -Catalina
Other 87 --0 0 0 0
undefined* -Two Harbors 3 --0 0 0 0
View Corridor -Two Harbors 84 --0 0 0 0
Public & Open Space 45,197 --0 0 0 557
Conservation/Primitive 20,212 0 0 0 32 Recreation -Catalina --
Conservation/Recreation -Two 820 0 0 0 17 Harbors --
Open Space/Recreation -Two 108 --0 0 0 2 Harbors
Open Space/Structured 24,057 --0 0 0 505 Recreation -Catalina
Residential 136 --21 0 0 0
Residential Land Uses -Two 136 0.25 (D) 21 0 0 0 Harbors
's.6.NtA.:·~l:;ARITAiVALLEY '1 )> • }······· :i·•· ........ •t1,1s~·· .· ... · ••• ·1as·aa1· 27:0889 2sf·sas· . ···. · .• ! .··.·.·.; !I . ·:.. .<ii\ 1'.REA PLAN ·•· I •·•'".. .... f. . ! .. ··.
•'·<·· ' . ,, •,;. i; ;. . . •
Residential -- --
77,155 237,638 ----
Non-Residential -- --------81,265-
107,123
iSANJ:A::l\lf()Nl.¢ft4WQUNTAIN$ ······~? ...... ·.
·. I;'/, (;~~3Q~·~~.5 ··;14;\l:i&; r .·• ...
>20·162 '1 <~ia.41 ~k~Q~ NORTHAREA PUA~· . . . ' •. u.
.' '.~:,'.~::'.\ >···· ~ .. >;
',' "''· ,•,•.·,• . .:•,•/1" , ·.·,·.'···
Commercial 166 --0 0 3,215 5,959
C -Commercial 120 0.5 (F) 0 0 2,604 4,764
CR -Commercial Recreation -47 0.3 (F} 0 0 611 1,195 Limited Intensity
Infrastructure 0 --0 0 0 0
TC -Transportation Corridor 0 --0 0 0 0
Public & Open Space 6,651 --0 0 11,214 73
OS -Open Space 775 --0 0 0 0
OS-DR -Open Space Deed 591 --0 0 0 0 Restricted
OS-P -Open Space Parks 4,731 --0 0 0 62
OS-W -Open Space Water 39 --0 0 0 11
P -Public and Semi-Public 515 0.5 (F) 0 0 11,214 0 Facilities
Rural 12,920 --1,601 6,164 0 537
Page 10 of14 5-213
Table 1
Proposed General Plan
Bldg. Sq.
Acres3
Density/
Population5
Footage (in
Jobs5 Land Use Designation lntensity4 Units thousands)
N20 -Mountain Lands 20 5,505 0.05 (D) 275 1,060 0 16
N 10 -Mountain Lands 10 4,265 0.1 (D) 369 1,419 0 200
N5 -Mountain Lands 5 2,028 0.2 (D) 361 1,388 0 200
N2 -Rural Residential 2 668 0.5 (D) 292 1,124 0 100
N1 -Rural Residential 1 454 1 (D) 305 1,173 0 21
Residential 425 --840 3,235 0 0
U2 -Residential 2 252 1.6 (D) 360 1,386 0 0
U4 -Residential 4 148 3.2 (D) 344 1,323 0 0
U8 -Residential 8 26 6.4 (D) 137 526 0 0
• T\(llJN·LAKE$'¢0MMUNITY ·· •: ,>
'LPLAN~ . . . . 45 '':-_>·:·,..:"." .. 4~ 174' CJ •. ·o
•: ·. : ··,:
Rural 45 --45 174 0 0
RC -Rural Communities 45 1 (D) 45 174 0 0
.~~~Nl4! • ~~ff',,):>·.·. ......... } ii~~~'., i~~~ •
. .. · ... ;;<~~I'~{ \. --. 4isas. '·· •rf3717·· s;o44 . Ni;l.(lffQP •. ............ : ··•··
.;.\:::;·\. ' .. ·': :· :
,::[-,'~~ :
Commercial 41 --0 0 2,135 4,358
GC -General Commercial 35 1.3 (F) 0 0 1,963 3,786
OC -Office Commercial 7 0.6 (F) 0 0 173 572
Industrial 8 --0 0 180 112
PU/I -Public Use I Institutional 8 0.5 (F) 0 0 180 112
Mixed Use & Specific Plan 11 --0 0 242 474
MC-Mixed Commercial 11 0.5 (F) 0 0 242 474
Other 4 --26 100 0 0
RIP -Residential I Parking 4 7.2 (D) 26 100 0 0
Residential 305 --4,312 13,617 0 100
NP I -Neighborhood 167 7.2 (D) 1,200 4,619 b 100 Preservation I
NP II -Neighborhood 21 14.4 (D) 298 1,146 0 0 Preservation II
NR -Neighborhood 117 24 (D) 2,814 7,852 0 0 Revitalization
WESTATHENS -We$TMON'r :. : . :·.-,· ··.: -,/ ·:·:~
NEIGHBORHOODRLAl'I 1,4891 l.f. --< : 11,}~~5 40,53$ 10;820 10,8$4
:: .. '.( .. ·,,.' . ' "
Commercial 155 --0 0 6,047 8,456
C.1 -Regional Commercial 45 1 (F) 0 0 1,940 1,060
C.2 -Community Commercial 81 1 (F) 0 0 3,513 6,994
C.3 -Neighborhood 2 0.5 (F) 0 0 41 79 Commercial
C.4 -Commercial 15 0.64 (F) 0 0 416 318 ManufacturinQ
CR -Commercial Recreation 13 0.25 (F) 0 0 137 5
Public & Open Space 278 --0 0 4,773 1,813
Page 11 of14 5-214
Table 1
Proposed General Plan
Bldg. Sq.
Density/
Pooulation5
Footage (in
Jobs5 Land Use Designation Acres3 lntensitv4 Units thousands)
OS.1 -Recreation I Open 122 0 0 0 70 --Space
PL.1 -Public/Quasi-Public Use 157 0.7 (F) 0 0 4,773 1,743
Residential 1,057 --11,185 40,539 0 625
RD 2.3 -Single Family 485 6.4 (D) 3,103 11,945 0 325 Residence
RD 3.1 -Two Family Residence 549 13.6 (D) 7,463 26,868 0 200
RD 3.2 -Medium Density Bonus 19 24 (D) 463 1,292 0 100
SCD -Senior Citizen Density 4 40 (D) 156 434 0 0 Bonus
Grand Total 1,653,056 --668,911 2,383,373 729,510 477,862
Notes:
1. Historically, jurisdiction-wide buildout levels do not achieve the maximum allowable density/intensity on every parcel and are, on
average, lower than allowed by the General Plan. Accordingly, the buildout projections in this General Plan do not assume buildout at
the maximum density or intensity and instead are adjusted downward to account for variations in buildout intensity.
2. The County has adopted a total of 13 community-based plans. The adoption date of these community-based plans vary and the
boundaries of the community plans may or may not be coterminous with a specific plan.
3. Acres are given as adjusted gross acreages, which do not include the right-of-way for roadways, flood control facilities, or railroads.
4. The density/intensity figure shown reflects the projected density/intensity for buildout purposes, which is generally 80% of the maximum
density/intensity permitted for that land use category. (D) denotes residential density and (F) denotes Floor Area Ratio.
5. Projections of population by residential designation are based on a persons-per-household factor that varies by housing type.
Additionally, the projections of jobs by designation are based on an employment generation factor that varies by employment category,
or actual number of jobs.
6. The figures for the unincorporated Santa Clarita Valley reference the figures in the Environmental Impact Report for the Santa Clarita
Valley Area Plan Update. The methodology used to derive the figures for the unincorporated Santa Clarita Valley differs from the
methodology used to generate the figures for other unincorporated areas and, therefore, they cannot be broken down by Land Use
Category.
7. The Antelope Valley Area Plan represents the adopted plan, with the exception of the portion that overlaps with the Proposed General
Plan community of 'Kagel I Lopez Canyons'. Therefore, the total acreage of the Antelope Valley represented here is less than the
actual area of the adopted plan boundarv.
The project will replace the adopted General Plan, including all of the elements (excluding the Housing Element),
land use distribution maps, and circulation maps. Other components of the comprehensive General Plan Update
include, but are not limited to:
•
•
•
•
•
•
•
Update the Special Management Areas including but not limited to Agricultural Resource Areas, Seismic
Hazard Zones, Flood Hazard Zones, Significant Ecological Areas, Hillside Management Areas, and Very
High Fire Hazard Severity Zones.
Update Significant Ecological Areas boundaries .
Update of the Highway Plan .
Amendments to the existing County ordinances and/or adoption of new County ordinances as necessary
to implement the updated General Plan, including but not limited to the SEA CUP Ordinance, Hillside
Management Ordinance, and the addition of new zones to implement portions of the land use legend.
Rezoning as necessary to implement and/or maintain consistency with the updated General Plan .
Rescinding or updating outdated policies, ordinances, manuals, codes and other guidance documents
and enacting new implementing policies, ordinances, manuals, and other guidance documents as needed
to reflect current law and the updated General Plan
Digitizing, parcelizing, and refining land use policy maps for existing community-based plans, as needed .
Page 12of14 5-215
3. PROBABLE ENVIRONMENTAL EFFECTS
Environmental Issues:
The County has determined that a Program EIR will be prepared for the proposed comprehensive General Plan
Update. Section 15168 of the CEQA Guidelines states that a Program EIR may be prepared on a series of
actions that can be characterized as one large project and are related either: 1) geographically; 2) as logical parts
in the chain of contemplated actions; 3) in connection with issuance of rules, regulations, plans, or other general
criteria to govern the conduct of a continuing program; or 4) as individual activities carried out under the same
authorizing statutory or regulatory authority and having generally similar environmental effects that can be
mitigated in similar ways. The Program EIR will be prepared in accordance with the requirements of CEQA
Statutes and Guidelines, as amended. Pursuant to Section 15146 of the CEQA Guidelines the degree of
specificity in the Program EIR will correspond to the degree of specificity involved in the comprehensive General
Plan Update. The EIR will focus on the primary effects that can be expected to follow from adoption of the
comprehensive General Plan Update and will not be as detailed as an EIR on the specific development or
construction projects that may follow. Based on the County's preliminary analysis of the project, the following
environmental issues will be examined in the Program EIR:
~ Aesthetics ~ Agricultural and Forest Resources ~ Air Quality
~ Biological Resources ~ Cultural Resources ~ Geology I Soils
~ Greenhouse Gas Emissions ~ Hazards & Hazardous Materials ~ Hydrology I Water Quality
~ Land Use I Planning ~ Mineral Resources ~ Noise
~ Population I Housing ~ Public Services ~ Recreation
~ Transportation I Traffic ~ Utilities I Service Systems ~ Mandatory Findings of Significance
The Draft EIR will address the short-and long-term effects of the Los Angeles County General Plan Update on
the environment. Mitigation measures will be proposed for those impacts that are determined to be significant. A
mitigation monitoring program will also be developed as required by Section 15150 of the CEQA Guidelines.
REVIEW PERIOD: This Revised NOP will be available for review from June 28, 2013 to July 29, 2013 on the
Department of Regional Planning (Department) website at http://planning.lacounty.gov/generalplan/ceqa.
Hardcopies will be available at the Department's main office and field office locations listed at the following link:
http://planning.lacounty.gov/locations; all County libraries; Calabasas Library located at 200 Civic Center Way,
Calabasas, CA 91302; and Altadena Library (Main Library) located at 600 East Mariposa Street, Altadena, CA
91001.
The Department is seeking input from both agencies and members of the public on the scope and content of the
environmental information and analysis to be contained in the EIR. Any correspondence related to the General
Plan Update received as part of the first NOP does not have to be resubmitted; it has already been incorporated
as part of the environmental review process for the project. Due to the time limits mandated by State law, written
comments must be sent via mail, e-mail, or fax no later than 5:00 PM on Monday, July 29, 2013. Please send
your comments at the earliest possible date to:
Connie Chung, AICP
Supervising Regional Planner
Los Angeles County
Department of Regional Planning
320 W. Temple Street, Room 1356
Los Angeles, CA 90012
Email: genplan@planning.lacounty.gov
Fax: (213) 626-043
Page 13 of14 5-216
PUBLIC SCOPING MEETING: Pursuant to the California Public Resources Code Section 21803.9, Los Angeles
County will conduct a public scoping meeting. This meeting will provide a public forum for information
dissemination and dialogue regarding the components of the proposed project, the overall process, and the draft
EIR. While staff will summarize the issues raised at these meetings, anyone wishing to make formal comments on
the NOP must do so in writing. The public scoping meeting will be held at the time and location listed below:
Date:
Time:
Location:
July 11, 2013
5:00 p.m. to 6:00 p.m.
Los Angeles County
Department of Regional Planning
320 W. Temple Street, Room 150
Los Angeles, CA 90012
The scoping meeting will also be streamed live at the following link:
http://streaming.planning.lacounty.gov/meeting. Afterward, the recorded presentation and meeting will also be
posted at the following link: http://planning.lacounty.gov/generalplan/ceqa.
Page 14of14 5-217
VENTURA COUNTY
~·::'':··
ANAGAPA ISLAND
........_SANNICOLAS
-.J ISLAND
LEGEND
KERN COUNTY
Un.Incorporated Los ~ngeles County
Source: Los Angeles County Department of Regional Planning
Los Angeles County General Plan Update
Regional Location
SAN
BERNARDINO
COUNTY
RIVERSIDE
COUNTY
SAN DIEGO
COUNTY
0--25 m
Scale (Miles) LJ
The Planning Center I DC&E • Figure 1
5-218
City comments on NOP for
Los Angeles County General Plan Update
5-219
CITY OF RANCHO PALOS VERDES
CITY MANAGER'S OFFICE
ADMINISTRATION
26 July 2013
County of Los Angeles
Department of Regional Planning
VIA ELECTRONIC AND U.S. MAIL
ATIN: Connie Chung, AICP, Supervising Regional Planner
320 W. Temple St., Rm. 1356
Los Ange.las, CA 90012
SUBJECT Comments in Response to the Revised Notice of Preparation of an
Environmental Impact Report and Notice of Public Scoping Meeting
for Los Angeles County General Plan 2035
Dear Ms. Chung:
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the
revised Notice of Preparation (NOP) for the above-mentioned project. The City
respectfully requests the inclusion of the following issues within the scope of the
potential environmental impacts analyzed in conjunction with the proposed general plan
update and amendment:
1) Many areas of the Palos Verdes Peninsula-which includes the Westfield Urban
County Island (UCl)-are characterized by areas containing major landslides
and/or exhibiting high slope instability. The discussion of geotechnical hazards in
the Draft Environmental Impact Report (DEIR) should carefully consider these
potential impacts as they apply in the Westfield UCI.
2) The Palos Verdes Peninsula is perhaps most accurately characterized as a semi-
rural area, where traffic is the most common source of "nuisance" noise. The
project description in the Initial Study indicates the Mobility Element will be
amended. On the Palos Verdes Peninsula, a 1.25-mile segment of Crenshaw
Boulevard traverses the Westfield UCI (between Palos Verdes Drive North and
Silver Spur Road), while the entire length of Hawthorne Boulevard from Pacific
Coast Highway to Palos Verdes Drive West is a designated County highway
(Route N7). If any changes are proposed to the classification, configuration or
alignment of either of these thoroughfares as a part of the proposed General
Plan update, the associated noise impacts upon adjacent land uses should also
be fully analyzed in the DEIR for this project.
30940 HAWTHORNE BLVD./ RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5205 /FAX (310) 544-5291
WWW.PA~OSVERDES.COM/RPV
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Connie Chung
26 July 2013
Page2
3)
4)
5)
6)
7)
A significant portion of the Westfield UCI currently utilizes private sewage
disposal systems. Such systems have potential negative impacts upon
groundwater quality, as well as upon landslides and slope instability (see
Comment 1 above). Therefore, we suggest that the discussion of water quality
resource impacts in the DEIR should address the expansion of private sewage
disposal systems.
Biological surveys conducted in association with the City's Natural Communities
Conservation Plan (NCCP) program identified coastal sage scrub habitat on the
side slopes within Agua Negra Canyon, which extends from Palos Verdes Drive
North to Silver Spur Road and is bisected by Crenshaw Boulevard (see
Comment 2 above). As such, the City believes that biological resource impacts
will almost certainly occur within the Westfield UCI, and should be carefully
considered in the DEIR for this project.
Please note that the intersection of Western Avenue and Toscanini Drive in the
City of Rancho Palos Verdes is one of the intersections that are monitored for
compliance with the County's Congestion Management Plan (CMP). As such,
the City requests that the traffic impact analysis in the DEIR for the proposed
project include the intersection of Western Avenue and Toscanini Drive.
Residents in the Westfield UCI are served by the Palos Verdes Peninsula Unified
School District (PVPUSD), which, in the past decade, has re-opened several
closed campuses in the face of increased demand from the community. Any
proposed amendments to the General Plan that directly or indirectly induce
additional population growth in the Westfield UCI have the potential to
exacerbate this condition. The City suggests that the County should consult with
all affected school districts serving the unincorporated areas of the County-not
just the Los Angeles Unified School District (LAUSD)-in its assessment of the
potential environmental effects of the proposed project.
We understand that changes in land use designation may be proposed to reflect
existing land use patterns that are not depicted on the current Land Use Policy
Map. This may have the effect of "legalizing" existing nonconforming land uses,
thereby providing greater opportunities for the expansion of these uses in the
future. Within the Westfield UCI, there is an existing office building at the
southeast corner of Crenshaw Boulevard and Palos Verdes Drive North that is
designated "Residential 1-Low Density" on the current Land Use Policy Map.
There may also be portions of residential neighborhoods in the Westfield UCI
(also designated "Residential 1-Low Density") that were built out at higher
densities prior to the adoption of the current County General Plan. The DEIR for
5-221
Connie Chung
26 July 2013
Page 3
this project should analyze the potential growth-inducing effects that land use
changes involving existing nonconforming uses could generate.
Again, thank you for the opportunity to provide comments on this important project. If
you have any questions or need additional information, please feel free to contact me at
· (310) 544-5226 or via e-mail at kitf@rpv.com.
Sincerely,
!2Z
Senior Administrative Analyst
cc: Mayor Susan Brooks and City Council
Carolyn Lehr, City Manager
Carolynn Petru, Deputy City Manager
M:\Border lssues\LA County General Plan Update\20130726_RevisedNOPComments.docx
5-222
Letters to Councilman Buscaino, Congresswoman Hahn and
Congressman Waxman regarding Rancho LPG facility
5-223
SUSAN BROOKS, MAYOR
JERRY V. OUHOVIC, MAYOR PRO TEM
BRIAN CAMPBELL, COUNCILMAN
JIM KNIGHT, COUNCILMAN
ANTHONY M. MISETICH, COUNCILMAN
CITY OF
The Honorable Joe Buscaino
· City of Los Angeles, 15th Council District
200 N. Spring St., Rm. 425
Los Angeles, CA 90012
RANCHO PALOS VERDES
June 18, 2013
SUBJEC.T: Resolution of Issues Related to the Rancho LPG Facility, 2110 North
· Gaffey Street, San Pedro, California
Dear Councilman Buscaino:
Since your election to the Los Angeles City Council in 2011, my City Council colleagues
and I have very much appreciated your leadership in addressing community concerns
about the Rancho LPG facility. As you know, the operation of this facility has potential
impacts upon residents in both of our cities .. Our City Council receives regular updates
related to the facility from our Staff. However, there are several issues for which we
have sought (unsuccessfully) answers to our questions about the facility, and for which
we now turn to you for assistance.
Rancho LPG Insurance Information
At a public meeting before the Rancho Palos Verdes City Council in October 2012, a
representative of Rancho LPG expressed willingness to provide our City with
information about the insurance and liability coverage for the Rancho LPG facility.
However, in January 2013, Rancho LPG subsequently refused to provide this
information on the grounds that it was "proprietary information" (see enclosures). We
seek any assistance that you and the Los Angeles City Attorney's Office can provide in
obtaining copies of Rancho LPG's insurance information.
Chief Legislative Analyst's Recommendations
In February 2013, the Chief Legislative Analysfs (CLA) Office of the City of Los Angeles
released its report on "Safety Regulations and Precautions at Liquefied Petroleum Gas
(LPG) Facilities." After summarizing the legislative and regulatory background affecting
the Rancho LPG facility in its report, the CLA made two (2) recommendations:
1. Instruct the Fire Department to develop potential options for a community
outreach effort and preparedness exercise with City departments and
30940 HAWTHORNE BOULEVARD/ RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5205 I FAX (310) 544-5291 I WWW.PALOSVERDES.COM/RPV
@PRINTED··ON RECYCLED PAPER 5-224
Councilman Joe Buscaino
June 18, 2013
Page2
stakeholders in the San Pedro area, including the facility operator, local
Neighborhood Councils, homeowner groups, and other community based
organizations.
2. Instruct the Fire Department and Department of Building and Safety, with the
assistance of the Chief Legislative Analyst, to report back with a list of
inspections conducted by non-City agencies at liquid bulk storage facilities that
would benefit City agencies by receiving automatic notification of inspection
deficiencies.
Recently,. we forwarded to your staff information about a possible grant funding
opportu'nity for emergency preparedness that might help to implement the CLA's
recommendations (see enclosure). We would appreciate an update on the status of the
implementation of the CLA's recommendations regarding the Rancho LPG facility.
Environmental Protection Agency Enforcement Action
In March 2013, the U.S. Environmental Protection Agency (EPA) issued a "Notification
of Potential Enforcement Action for Violation of Section 112(r)(7) of the Clean Air Act" to
the Rancho LPG facility (see enclosure). This notice apparently stemmed from site
inspections conducted by the EPA in 201 O and 2011. The allegations against Rancho
LPG include:
• Failing to include the rail storage area of the site in its Risk Management Plan;
• Failing to adequately evaluate seismic impacts upon the facility's emergency
flare;
• Failing to address the consequences of a loss of City water for fire suppression
during an earthquake;
• Failing to conduct a timely internal inspection of Tank 1 (i.e., one of the 12%-
million-gallon butane storage tanks);
• Failing to develop an Emergency Response Plan to protect public health and the
environment; and,
• Failing to include a drain pipe and valve in the containment basin in the
Mechanical Integrity Program.
Rancho LPG was given until April 15, 2013, to file responses to EPA's allegations. Our
Staff contacted the EPA on May 6, 2013, to inquire into the status of Rancho LPG's
response, but we have received no response to our inquiry from EPA. We seek your
assistance in getting an update from EPA in this matter.
5-225
Councilman Joe Buscaino
June 18, 2013
Page3
Again, I thank you for your continued leadership in addressing this issue affecting all of
our constituents. If you have questions or need additional information, please contact
Senior Administrative Analyst Kit Fox at (310) 544-5226 or kitf@rpv.com.
Sincerely yours,
~~
Susan M. Brooks
Mayor ..
enclosures
cc: Rancho Palos Verdes City Council
Carolyn Lehr, Rancho Palos Verdes City Manager
Mayor Margaret Estrada and the Lomita City Council
Michael Rock, Lomita City Manager
Mayor James F. Goodhart and the PaJos.Verdes Estates City Council
Anton Dahlerbruch, Palos Verdes Estates City Manager
Mayor Frank E. Hill and the Rolling Hills City Council
Steve Burrell, Rolling Hills Interim City Manager
Mayor Frank V. Zerunyan and the Rolling Hills Estates City Council
Doug Prichard, Rolling Hills Estates City Manager
Kit Fox, Senior Administrative ~nalyst
M:\Border lssues\Rancho LPG Butane Storage Facility\20130618_Buscaino_RanchoLPG.doc
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John H. Kyles
Senior Attorney
January 29, 2013
Carol W. Lynch, Esq.
RANCHO
LPG Holdings LLC
City Attorney, City of Rancho Palos Verdes
c/o: Richards, Watson & Gershon
355 South Grand Avenue 4oth Floor
Los Angeles, CA 90071
RE: Rancho LPG Holdings LLC
San Pedro Terminal, 211 O North Gaffey, San Pedro, CA
Phone: (713) 993·5136
Fax: (713) 646-4216
City of Rancho Palos Verdes, CA Information Request Response
(Plains File: L6686A}
Dear Ms. Lynch,
You and Mr. Kit Fox have inquired about the insurance coverage that Rancho LPG has in place in
case of a catastrophic event involving the storage tanks at Rancho's facility. After internal review,
Rancho LPG has concluded that the requested information is proprietary. Therefore, Rancho will not
make the insurance policies and their details available to the City.
However, Rancho LPG wants Rancho Palos Verdes City government to know that Rancho works
closely with its underwriters and has been advised that Rancho has an appropriate level of insurance
for a facility of this type.
Thank you for your consideration and cooperation in this matter.
Sincerely,
Kit Fox, AICP
Senior Admin Analyst
City Manager's Office
City of Rancho Palos Verdes
30940 Hawthorne Blvd.
Rancho, Palos Verdes, CA
90275
Ron Conrow
Western District Manager
Plains LPG Services, LP
Shafter, CA
PAA: LAW_.COM: 650204v1
Dan Johansen ·
San Pedro Terminal
211 O North Gaffey,
San Pedro, CA 90731
Scott Sill
Managing Director, LPG Operations
1400, 607·8 Avenue SW
Calgary AB T2POA7
Hon. Rudy Svorinich, Jr.
1891 N. Gaffey Street
Suite221
San Pedro, CA 90731
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Blais&Associates
professional grant management
FACT SHEET
l"alEMA Hazardous Materials Emergency Preparedness Grant
(HMEP)
Funding Information and Application Requirements
FAST FACTS
·--"'~~
1 . Application Deadline
2 Workshops (if any)
3 Eligible Applicants
4 Purpose of Program
5 Success Rate Last Year
6 Authorizing Resolution Required?
FUNDING INFORMATION
7 Total Funds Available
8 High, Low, Average Grant Last Year
9 Maximum Funding Request
'""""'~------·
10 Local Match Required
11 Funding Cycle
PROJECT INFORMATION
12 Examples of Funded Projects
Applications are due to California's local Emergency Planning
Committees (lEPCs) approximately July 15, 2013. Check with
your LEPC chair to confirm their internal deadline date. LEPCs
contact information is located at the end of this fact sheet.
LEPCs are to submit applications to Cal EMA by August 15, 2013.
----~·· ------~ ···---~ .. --.
There are no workshops scheduled at this time.
State or local agencies and federally recognized tribal
governments.
Local governments are defined as, "A county, municipality, city,
town, township, local public authority such as school district,
special district, intrastate district, council of governments ... any
other regional or interstate government entity, or any agency or
instrumentality of a local government."
For public sector planning and training in support of the
emergency planning and training efforts of States, Indian tribes,
and local communities to deal with hazardous materials
emergencies, particularly those involving transportation.
2012: 11 applications were received and nine were funded.
Success rate was 82 percent.
2011: 15 applications were received and all were funded. Success
rate was 100 percent.
Not stated as required.
Anticipated funding $738,380.
High: $64,000; Average: $27,753; Low: $10,422 -------
There is no stated maximum.
---··---·-··---·---
20 percent of the total cost of the approved project with non-
Federal funds.
Annual
• Corona Fire Department -Area Plan Update: a minimum of
75% of the HMEP Planning grant allocation is made available
to the LEPCs for allowable projects via a sub-grant process that
requires the LEPCs to approve and prioritize all applications for -----·---------------·---·· .. -----·
5-228
""m"WMMW., ...... .,~AA~~ .... """w
~-·-"·-
Blais&Associates
professional grant management
their region. $11,000.
• City of Lancaster -HazMat Needs/Hazards Assessment and
Response Exercise: To fund a Needs/Hazards Assessment of
the existing HazMat transportation conditions in the City,
create a database and GIS maps to document existing facilities
and thoroughfares that use or transport Hazardous Materials,
and share the data with the existing EOC software programs
and all first responders. This data would also be used to
design, conduct, and evaluate a full-scale exercise that
evaluates the current readiness levels of the EOC, field
response crews, and CERT volunteers to determine future
needs. The scenario will involve a tanker truck accident and
resulting spill. Results of the assessment and exercise lessons
learned will directly relate to an intended 2013-14 application
to fund the development of a HazMat Transportation
Emergency Area Plan. $10,422.
• Trinity County -Rural HazMat Decon Team Revitalization
Project: Project is to design and conduct a multi-jurisdictional,
multi-discipline full-scale HazMat exercise involving a
transportation element, including the decontamination of
ambulatory and non-ambulatory victims and responders. An
after-action report and corrective action plan will support
future updates to the HazMat Area Plan. Supplies and
equipment necessary to support this exercise -and future
training, exercises, and responses -include Level B Chemical
Protective Clothing, ICS ID vests, and a transport trailer. The
$10,880 being requested is 40% of the identified Total Project
Costs versus the allowable 80%. This project will deliver long-
term life safety benefits to responders by improving timeliness
and effectiveness of essential victim & responder
decontamination and by improving coordination between local
and regional HazMat response resources. $10,880.
·-=,,~-"'"""m"~--·-·---,,,_,_,__,_,,,~,-~~-----'"""'mm-""'""-""""'-"""''~ -----~-------· ----------·~~,_..,,,,_,, __ ~-~---·
13 Priorities
14 Eligible Project Types
A minimum of 75% of the HMEP Planning grant allocation is made
available to the LEPCs for allowable projects via a sub-grant
process that requires the LEPCs to approve and prioritize all
applications for their region.
-~--------~-...... -~~-~~
• Project MUST be HazMat and Transportation related.
• Development, improvement, and implementation of
emergency plans required under the EPCRA.
• Enhancement of emergency plans, including hazards analysis,
and response procedures for emergencies involving
transportation of hazardous materials, including radioactive
materials.
• An assessment to determine the flow patterns of hazardous
materials within the state, between states or Native American
lands, and development and maintenance of a system to keep
such information current.
• An assessment of the need for regional hazardous materials
5-229
15 Ineligible Activities
Blais&Associates
professional grant management
emergency response teams.
• An assessment of local response capabilities.
• HazMat emergency response drills and exercises to test
capabilities and identify gaps in training. (Allowable costs
include planning and design, participation, evaluation, and
after action review costs.)
• Provision of technical staff to support the planning effort.
• Additional activities appropriate to implement the scope of
work for the proposed project plan and approved in the grant.
(These activities must be approved by Cal EMA before
initiated.)
• Costs incurred outside the performance period.
• Equipment purchases -Some equipment necessary for the
completion of allowable project activities may be approved on
a case-by-case basis, but will likely be funded at less than 80
percent of the total cost.
• Overtime wages or Call Backs/Backfill
• Food items
• Software -with the exception of CAMEO
• Weapons of Mass Destruction (WMD) planning or exercise
activities
• All-hazards or fixed-facility only planning or exercise activities
• Community Emergency Response Team (CERT), Neighborhood
Watch, and other community planning organization activities
---------------~ --~-"-'" ----------------------·---~-----·-----------~---~-------------------,~--~--~---------·--·-··-~--·-·------~--·------
16 Project Readiness The grant performance period is October 1 through September 30.
HOW TO APPLY
17 Application Requirements • Application Form
• Project Narrative (limited to two pages)
• Designation Statement
• Budget Worksheet and Budget Narrative
• Work Schedule and Deliverables Form
• Grant Assurances
···-····~·--~····----··-.. --.. ~----
18 Submission Requirements Eligible public agencies must submit their planning grant
applications to the LEPCs for review, prioritization, and approval.
«••-·-·-------·--.. --------·---
HOW APPLICATIONS WILL BE SCORED
~~~~-------
19 Evaluation Criteria and Process • Each LEPC is responsible for evaluating, approving and
prioritizing the HMEP Planning sub-grant applications from
within their region.
• Once Cal EMA receives the applications, they are evaluated to
determine if they are allowable, reasonable, and allocable to
the HMEP grant program.
• Additionally, the project is evaluated against the goals,
objectives, and planning priorities for that grant cycle and
whether the criteria listed on the application forms'
instructions have been met.
• Awards are expected September 30, 2013.
5-230
Blais&Associates
professional grant management
WHO TO CONTACT
20 Agency Cal EMA ------·----
21 Contact Name/Phone Number Neverley Shoemake at: (916) 845-8765 or
neverley.shoemake@calema.ca.gov
·-····--···----·-··--·-···---~·--·--····-----··-·~-····--··-······-~-··---
22 Web Site h!!p_:LL~Y.!L.~.,_(;_!!l_~ ma . .f!!.,E.Q.'.l!'.L!::l a za rd g_~.s Mate ria lsLPage~L!::I ME P..::
5-231
LOCAL EMERGENCY PLANNING COMMITTEE (LEPC) CHAIRS
CALIFORNIA EMERGENCY MANAGEMENT AGENCY (CALEMA) STAFF
Planning: Neverley Shoemake (916) 845-8765; CSTI Training: Susan Kocher (805) 549-3534 or Annabelle Dixon (805) 549-3544
E-mail: neverlev.shoernake@calerna.ca.gov; susan.kocher@calema.ca.gov; Annabelle.dixon@calema.ca.gov
Chair CalEMA Staff
Region I Region I
RANDY ALVA JERI SIEGEL
Los Angeles County Fire Department CalEMA, Southern Region
18239 W. Soledad Canyon Road 4671 Liberty Avenue
Canyon Country, CA 91351 Los Alamitos, CA 90720-5158
Phone: (510) 238-7759. Phone: (805) 473-3035; Fax. (805) 679-1996
E-mail: aalva(@firc.Iacounty.gov E-mail: jeri.seigel@calema.ca.gov
Regionll Regionll
DAVE DEARBORN SANDRA MCKENZIE
California Highway Patrol CalEMA, Coastal Region
1551 Benicia Road 1300 Clay Street, Suite 400
Vallejo, CA 94591 Oakland, CA 94612
Phone: (707) 373-7719 Phone: (510) 286-6748; Fax. (510) 286-0853
E-mail: ddearborn(@chu.ca.gov E-mail: sandra.mckenzie(@calema.ca.gov
Region ID Region ID
WILLIAM FULLER DEBORAH VERCAMMEN
Yuba City Fire Department CalEMA, Inland Region (North)
824 Clark A venue 20645 Gas Point Rd.
Yuba City, CA 95991 Cottonwood, CA 96022
Phone: (530) 822-4809; Fax. (530) 822-7561 Phone: (530) 347-6494; Fax. (530) 347-6456
E-mail: wfuller(@yubacitv.net E-mail: deborah.vercammen@calema.ca.gov
Region IV Region IV
MICHAEL PARIS SI DANA OWENS
San Joaquin County Environmental Health Department CalEMA, Inland Region
1868 East Hazelton A venue 3650 Schriever Avenue
Stockton, CA 95205 Mather, CA 95655
Phone: (209) 953-6213; Fax: (209) 468-3433 Phone: (916) 845-8482; Fax. (916) 845-8474
E-mail: dave.iohnston@edcgov.us E-mail: dana.owens(@calema.ca.gov
Region V Region V
CRAIG PERKINS KEVIN NAGATA
Bakersfield Fire Department CalEMA, Inland Region (South)
2101 H Street 2550 Mariposa Mall, Room 181
Bakersfield, CA 93301 Fresno, CA 93721
Phone: (661) 326-3684; Fax: (661) 852-2171 Phone: (559) 445-6125; Fax. (559) 445-5987
E-mail: ctuerkins(@bakcrsfieldfire.us E-mail: kevin.nagata@calema.ca.gov
Region VI Region VI
NICK VENT JOANNE PHILLIPS
County of San Diego CalEMA, Southern Region
Hazardous Materials Division 4050 Taylor Street, M5243
P.O. Box 129261 San Diego, CA 92110
San Diego, CA 92112-9261 Phone: (619) 220-5369; Fax. (619) 278-3793
Phone: (858) 505-6693; Fax. (858) 694-3705 E-mail: ioanne.phillips@calema.ca.gov
E-mail: nick.vent(@sdcountt.ca.gov
Revision date: 5/13/2013
5-232
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
Mr. Tony Puckett
Rancho LPG Holdings, LLC
2110 North Gaffey Street
San Pedro, California 90731
75 Hawthome Street
San Francisco, CA 94105
MAR I 4 2013
CERTIFIED MAIL NO.:
RETURN RECEIPT REQUESTED
In Reply Refer to:
Rancho San Pedro Terminal, San Pedro, CA
RE: Notification of Potential Enforcement Action for Violation of Section 1l2(r)(7) of the
Clean Air Act
Dear Mr. Puckett:
On April 14, 2010, and January 11, 2011. the U.S. Environmental Protection Agency
("EPA") conducted inspections at the San Pedro Termin;tl ('the Facility') owned by Plains LPG
Services and operated by Rancho LPG Holdings, LLC (the "Companies") at 2110 North Gaffey
Street, in San Pedro, California. The purpose of the inspections and subsequent information
requests were to evaluate the Companies' compliance with the requirements under Section l 12(r)
of the Clean Air Act ("CAA").
Based upon the information obtained during our investigatio~ EPA is prepared to initiate
a civil administrative action against the Companies to ensure compliance with federal law and
assess a penalty pursuant to Section 113 of the CAA, 42 U.S.C. § 7413. The anticipated
allegation includes violation of Section 112(r)(7) of the CAA, 42 U.S.C. § 7412(r)(7), and its
implementing regulations.
Specifically, the anticipated allegations against the Companies include:
1. The Companies failed to identify and assess its rail storage area as a process
for inclusion in its Risk Management Plan (''RMP''). The rail storage area
should have been included as a covered process where a regulated substance
was present above a threshold quantity when it submitted an RMP. As a result,
the Companies failed to conduct a hazard assessment of that process, in
violation of Section 112(r)(7) of the CAA, 42 lJ.S.C. § 7412(r), and 40 C.F.R.
§ 68.12(a) and (b).
5-233
2. The Companies failed to adequately evaluate potential seismic stresses on the
support structure for the emergency flare in accordance with design codes. As
a consequence, the Companies violated Section 112(r)(7) of the CAA, 42
U.S.C. § 7412(r), and 40 C.F.R. § 68.65(a) and(d)(2-3), which requires that the
owner or operator ensure that complete process safety information is compiled
on the technology of the process and that the equipment complies with
recognized and generally accepted good engineering practices.
3. The Companies did not appropriately address the consequences of a loss of the
city water system for fire suppression in the event of an earthquake. This
omission is a violation of Section l 12(r)(7) of the CAA, 42 U.S.C. § 7412(r),
and 40 C.F.R. § 68.67(c)(4), which requires th.at the owner or operator address
the consequences of the failure of engineering and administrative controls in
the process hazard analysis.
4. The Companies failed to internally inspect Tanlc 1 according to a timetable set
forth in API Standard 653, in violation of Section l 12(rX7) of the CAA, 42
U.S.C. § 7412(r), and 40 C.F.R. § 68.73(d)(2), which require that the owner or
operator ensure that inspection and testing procedures follow recognized and
generally accepted good engineering practices.
. 5. The Facility's emergency response plan identified the facility as a responding
facility for which employees will take response action in the event of a release,
per 40 C.F.R. 68.90(a). However, the Facility's emergency response plan
developed under paragraph (a)(l) of that part was not coordinated with the
community emergency response plan developed under 42 U.S.C. 11003.
In addition, the Facility Manager and employees stated to EPA that they are
not emergency responders for the Facility, but are only authorized to talce life
safety and evacuation actions. The Companies failed to develop and
implement an emergency response program for the purpose of protecting
public health and the environment, including at a minimum, procedures for
infonning the public and emergency response agencies in the event of a
release. The Facility failed to clearly indicate to their own employees whether
they would be emergency responders or would evacuate. This is in violation of
Section l 12(r)(7) of the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R.
§ 68.95(a)(l)(i), which requires an owner or operator to develop and
implement an emergency response program including a plan that shall be
maintained at the stationary source and contain procedures for infonning the
public and local emergency response agencies about accidental releases.
6. The Companies failed to ensure that the drain pipe located in the base of the
containment basin and the valve located near Gaffey Street were included in
the mechanical integrity program. This is in violation of Section 112(r)(7) of
the CAA, 42 U.S.C. § 7412(r), and 40 C.F.R. § 68.73(d), which requires
inspection and testing procedures to follow recognized and generally accepted
good engineering practices.
2 5-234
Before filing a Determination of Violation, Compliance Order and Notice of Right to
Request a Hearing ("Complaint"), EPA is extending to the Companies an opportunity to advise
EPA of any other information that the Companies believes should be considered before the .filing
of such a Complaint. Relevant information may include any evidence of reliance on compliance
assistance, additional compliance tasks performed subsequent to the inspection, or fma.ncial
factors bearing on the ability to pay a civil penalty.
Your response to this letter must be made by a letter, signed by a person or persons duly
authorized to represent the Companies. Please send any such response by certified mail, return
receipt requested, addressed to:
Ms. Mary Wesling (SFD-9-3)
Environmental Scientist
U.S. EPA Region IX
75 Hawthorne St.
San Francisco, CA 94105
Please provide such information by no later than April 15, 2013. EPA anticipates filing a
Complaint in this matter on or about·May 15, 2013, unless the Companies first advise EPA, with
supporting information, of subst.antial reasons not to proceed as planned. Any penalty proposed
for violation of the CAA will be calculated pursuant to EPA' s "Final Combined Enforcement
Policy for the Clean Air Act Section 112(r)(l), the General Duty Clause, and Clean Air Act
Section l 12(r)(7) and 40 C.F.R. Part 68, Chemical Accident Prevention Provisions," dated June
20, 2012, a copy of which is enclosed (the "Penalty Policy"). Civil penalties may be mitigated,
under the EPA "Supplemental Environmental Projects Policy,"1 which describes the terms under
which a commitment to perform an environmental project may mitigate, in p~ a civil penalty.
Even if the Companies are unaware of any mitigating or exculpatory factors, EPA is extending to
the Companies the opportunity to commence settlement discussions concerning the above
described violations.
Additionally, to fully consider application of the Penalty Policy, EPA is additionally
requesting responses to specific questions set forth below. EPA makes this request for
information pursuant to 42 U.S.C. § 7414(a). Failure to comply with the information request in
this letter may result in enforcement action being ta.ken in accordance with Section 113 of the
Act, 42 U.S.C. § 7413. This may include civil and administrative penalties of up to $37,500 per
day of noncompliance~ pursuant to section l 13(b)(2) and 113(d) of the Act, 42 U.S.C.
§§ 7413(b)(2) and 7413(d). Instructions regarding the requests also are set forth below.
Ill
1 httn ;//www. epa. govJcompI ian cc/resources/policies/ c i vil/s"'s/fn lsup-hermn-mem, pdf. and
htt]2:// c fpub .epa. gov/compliance/ resources/policies/c iyiV~eps/.
3 5-235
If there are any questions, please contact Mary Westing of my staff at (415) 972~3080 or
Wesling.Mary@epa.gov. Please direct any questions or inquiries from legal counsel to Andrew
Helmlinger, EPA Counsel, at (415) 972-3904 or Helmlinger.Andrew@epa.gov.
Thank you for your prompt attention to this matter.
Enclosures:
Sincerely,
··1 "" .-,
.l'/f"7Ji'1/ /J :r--J ~Y-1<:-h& (
Daniel A. Meer, Assistant Director
Superfund Division
Final CAA § 112(r) Combined Enforcement Policy
cc Cw/enclosures):
T. Puckett, Plains LPG Services, LLC, Houston, TX
M. Wesling, U.S. EPA Region IX
A. Helmlinger, U.S. EPA Region IX
4
5-236
ENCLOSURE
INSTRUCTIONS
1. Please provide a separate response to each request, and identify each response by the number
. of the request to which it corresponds. For each document produced, identify the request to
which it is responsive.
2. Knowledge or information that has not been memorialized in any document, but is
nonetheless responsive to a request, must be provided in a narrative form.
3. The scope of this Information Request includes all information and documents obtained or
independently developed by the Companies, their attorneys, consultants or any of their
agents, consultants, or employees.
4. The Companies may not withhold any information from EPA on the grounds that it is
confidential business information. EPA has promulgated regulations, under 40 C.F.R. Part 2,
Subpart B, to protect confidential business information that it receives. The Companies may
assert a business confidentiality claim (in the manner specified in 40 C.F.R. § 2.203(b)) for
all or part of the information requested by EPA. However, business infonnation is entitled to
confidential treatment only if it satisfies the criteria set forth in 40 C.F.R. § 2.208. EPA will
disclose business information entitled to confidential treatment only as authorized by 40
C.F.R. Part 2, Subpart B. If no claim of confidentiality accompanies the information at the
time EPA receives it, EPA may make it available to the public without further notice.
5. Notice is hereby given, pursuant to 40 C.F.R. § 2.310(h), that EPA may disclose confidential
information provided by the Companies to EPA's authorized representatives, including its
contractor, Science Applications International Corporation ("SAIC"). Confidential
information may be disclosed to EPA's authorized representatives for the following reasons:
to assist with document handling, inventory and indexing; to assist with dooument review
and analysis for verification of completeness; and to provide expert technical review of the
contents of the response. Pursuant to 40 C.F.R. § 2.310(h), the Companies may submit, along
with its response to this Information Request, any comments regarding EPA's disclosure of
confidential information to its authorized representatives.
6. If information or documents not known or available to the Companies at the time of any
response to this Infonnation Request later become known or available to it, it must
supplement its response to EPA. Moreover, should the Companies find at any time after the
submission of any response that any portion of the submitted information is false or
misrepresents the truth, the Companies must notify EPA as soon as possible and provide
EPA with a corrected response.
7. If information responsive to a request is not in the Companies' possession, custody, or
control, identify the persons or entities from whom such infonnation may be obtained. For
each individual or entity that possesses responsive information, please provide the following:
name, last known or current address, telephone number, and affiliation with the Companies
or the Facility.
5 5-237
8. If you believe that th.ere are grounds for withholding information or documents that are
responsive to this request, e.g., attorney-client privilege, you must identify the information or
documents and state the basis for withholding.
INFORMATION REQUEST
1. Provide cost information for the development and implementation of the Facility's RMP.
Disaggregate the RMP development costs by capital and one-time non-depreciable expenses.
Regarding implementation costs, provide actual or estimated incremental (above the
Facility,s previously existing level-of-effort) annually recurring costs (e.g. Operation &
Maintenance).
2. Provide a statement and supporting documentation indicating the Companies, present net
worth,.
6 5-238
SUSAN BROOKS, MAYOR
JERRY V. OUHOVIC, MAYOR PRO TEM
BRIAN CAMPBELL, COUNCILMAN
JIM l<NIGHT, COUNCILMAN
ANTHONY M. MISETICH, COUNCILMAN
CITY OF
The Honorable Janice Hahn
44th Congressional District of California
United States House of Representatives
400 Cannon House Office Building
Washington, DC 20515
RANCHO PALOS VERDES
June 18, 2013
SUBJECT: Resolution of Issues Related to the Rancho LPG Facility, 2110 North
Gaffey Street, San Pedro, California
Dear Congresswoman Hahn:
During your tenure on the Los Angeles City Council and in your current capacity
representing the 44th Congressional District of California, my City Council colleagues
and I have very much appreciated your leadership in addressing community concerns
about the Rancho LPG facility. As you know. 'the operation of this facility has potential
impacts upon residents in both the cities of the 44th District and residents on the Palos
Verdes Peninsula in the adjoining 33rd District. Our City Council receives regular
updates related to the facility from our Staff. However, there are several issues for
which we have sought (unsuccessfully) answers to our questions about the facility, and
for which we now turn to you for assistance.
Rancho LPG Insurance Information
At a public meeting before the Rancho Palos Verdes City Council in October 2012, a
representative of Rancho LPG expressed willingness to provide our City with
information about the insurance and liability coverage for the Rancho LPG facility.
However, in January 2013, Rancho LPG subsequently refused to provide this
information on the grounds that it was "proprietary information" (see enclosures). We
seek any assistance that you can provide in obtaining copies of Rancho LPG's
insurance information.
Chief Legislative Analys~'s Recommendations
In February 2013, the Chief Legislative Analyst's (CLA) Office of the City of Los Angeles
released its report on "Safety Regulations and Precautions at Liquefied Petroleum Gas
(LPG) Facilities." The report was prepared in response to several motions by your
successor, 15th District Los Angeles City Councilman Joe Buscaino. After summarizing
30940 HAWTHORNE BOULEVARD I RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5205 I FAX (310) 544-5291 I WWW.PALOSVERDES.COM/RPV
@PRINTED 0N RECYCLED PAPER 5-239
Congresswoman Janice Hahn
June 18, 2013
Page2
the legislative and regulatory background affecting the Rancho LPG facility in its report,
the CLA made two (2) recommendations:
1. Instruct the Fire Department to develop potential options for a community
outreach effort and preparedness exercise with City departments and
stakeholders in the San Pedro area, including the facility operator, local
Neighborhood Councils, homeowner groups, and other community based
organizations.
2. Instruct the Fire Department and Department of Building and Safety, with the
assistance of the Chief Legislative Analyst, to report back with a list of
inspections conducted by non-City agencies at liquid bulk storage facilities that
would benefit City agencies by receiving automatic notification of inspection
deficiencies.
Recently, we forwarded to Councilman Buscaino's staff information about a possible
grant funding opportunity for emergency preparedness that might help to implement the
CLA's recommendations (see enclosure). We would appreciate any assistance that you
might offer to the City of Los Angeles in pursuing these grant funds to assist in the
implementation of the CLA's recommendations regarding the Rancho LPG facility.
Environmental Protection Agency Enforcement Action
In March 2013, the U.S. Environmental Protection Agency (EPA) issued a "Notification
of Potential Enforcement Action for Violation of Section 112(r)(7) of the Clean Air Act" to
the Rancho LPG facility (see enclosure). This notice apparently stemmed from site
inspections conducted by the EPA in 2010 and 2011. The allegations against Rancho
LPG include:
• Failing to include the rail storage area of the site in its Risk Management Plan;
• Failing to adequately evaluate seismic impacts upon the facility's emergency
flare;
• Failing to address the consequences of a loss ·of City water for fire suppression
during an earthquake;
• Failing to conduct a timely internal inspection of Tank 1 (i.e., one of the 12%-
million-gallon butane storage tanks);
• Failing to develop an Emergency Response Plan to protect public health and the
environment; and,
• Failing to include a drain pipe and valve in the containment basin in the
Mechanical Integrity Program.
5-240
Congresswoman Janice Hahn
June 18, 2013
Pagel
Rancho LPG was given until April 15, 2013, to file responses to EPA's allegations. Our
Staff contacted the EPA on May 6, 2013, to inquire into the status of Rancho LPG's
response, but we have received no response to our inquiry from EPA. We seek your
assistance in getting an update from EPA in this matter.
Again, I thank you for your continued leadership in addressing this issue affecting all of
our constituents. If you have questions or need additional information, please contact
Senior Administrative Analyst Kit Fox at (310) 544-5226 or kitf@rpv.com.
Sincerely .. yours,
er~~
Susan M. Brook
Mayor
enclosures
cc: Rancho Palos Verdes City Council
Carolyn Lehr, Rancho Palos Verdes City Manager
Mayor Margaret Estrada and the Lomita City Council
Michael Rock, Lomita City Manager
Mayor James F. Goodhart and the Palos Verdes Estates City Council
Anton Dahlerbruch, Palos Verdes Estates City Manager
Mayor Frank E. Hill and the Rolling Hills City Council
Steve Burrell, Rolling Hills Interim City Manager
Mayor Frank V. Zerunyan and the Rolling Hills Estates City Council
Doug Prichard, Rolling Hills Estates City Manager
Kit Fox, Senior Administrative Analyst
M:\Border lssues\Rancho LPG Butane Storage Facility\20130618_Hahn_RanchoLPG.doc
5-241
SUSAN BROOKS, MAYOR
JERRY V. OUHOVIC, MAYOR PRO TEM
BRIAN CAMPBELL, COUNCILMAN
JIM KNIGHT, COUNCILMAN
ANTHONY M. MISETICH, COUNCILMAN
CITY OF
The Honorable Henry A. Waxman
· 33rd Congressional District of California
United States House of Representatives
2204 Rayburn House Office Building
Washington, DC 20515
'
RANCHO PALOS VERDES
June 18, 2013
SUBJECT: Resolution of Issues Related to the Rancho LPG Facility, 2110 North
Gaffey Street, San Pedro, California
Dear Congressman Waxman:
My City Council colleagues and I are pleased to welcome you as the U.S.
Congressional Representative for the City of Rancho Palos Verdes and the other cities
and communities on the Palos Verdes Peninsula. As you may be aware, an issue of
concern to many residents in this portion of the 33rd District is the Rancho LPG facility in
San Pedro, which stores and handles more than 25 million gallons of butane and
propane in a densely-populated area near the Port of Los Angeles. The operation of
this facility has potential impacts upon residents in both the cities of the 33rd District and
those in the adjoining 44th District. Our City Council receives regular updates related to
the facility from our Staff. However, there are several issues for which we have sought
(unsuccessfully) answers to our questions about the facility, and for which we now turn
to you for assistance.
Rancho LPG Insurance Information
At a public meeting before the Rancho Palos Verdes City Council in October 2012, a
representative of Rancho LPG expressed willingness to provide our City with
information about the insurance and liability coverage for the Rancho LPG facility.
However, in January 2013, Rancho LPG subsequently refused to provide this
information on the grounds that it was "proprietary information" (see enclosures). We
seek any assistance that you can provide in obtaining copies of Rancho LPG's
insurance information.
Chief Legislative Analyst's Recommendations
In February 2013, the Chief Legislative Analyst's (CLA) Office of the City of Los Angeles
released its report on "Safety Regulations and Precautions at Liquefied Petroleum Gas
30940 HAWTHORNE BOULEVARD I RANCHO PALOS VERDES, CA 90275-5391 / (310) 544-5205 /FAX (310) 544-5291 I WWW.PALOSVERDES.COM/RPV
@PRINTED ON RECYCLED PAPER 5-242
Congressman Henry A. Waxman
June 18, 2013
Page2
(LPG) Facilities." The report was prepared in response to several motions by 15th
District Los Angeles City Councilman Joe Buscaino. After summarizing the legislative
and regulatory background affecting the Rancho LPG facility in its report, the CLA made
two (2) recommendations:
1. Instruct the Fire Department to develop potential options for a community
outreach effort and preparedness exercise with City departments and
stakeholders in the San Pedro area, including the facility operator, local
Neighborhood Councils, homeowner groups, and other community based
organizations.
2. Instruct the Fire Department and Department of Building and Safety, with the
assistance of the Chief Legislative Analyst, to report back with a list of
inspections conducted by non-City agencies at liquid bulk storage facilities that
would benefit City agencies by receiving automatic notification of inspection
deficiencies.
Recently, we forwarded to Councilman Buscaino's staff information about a possible
grant funding opportunity for emergency preparedness that might help to implement the
CLA's recommendations (see enclosure). We would appreciate any assistance that you
might offer to the City of Los Angeles in pursuing these grant funds to assist in the
implementation of the CLA's recommendations regarding the Rancho LPG facility.
Environmental Protection Agency Enforcement Action
In March 2013, the U.S. Environmental Protection Agency (EPA) issued a "Notification
of Potential Enforcement Action for Violation of Section 112(r)(7) of the Clean Air Acf' to
the Rancho LPG facility (see enclosure). This notice apparently stemmed from site
inspections conducted by the EPA in 2010 and 2011. The allegations against Rancho
LPG include:
• Failing to include the rail storage area of the site in its Risk Management Plan;
• Failing to adequately evaluate seismic impacts upon the facility's emergency
flare;
• Failing to address the consequences of a loss of City water for fire suppression
during an earthquake;
• Failing to conduct a timely internal inspection of Tank 1 (i.e., one of the 12%-
million-gallon butane storage tanks); ·
• Failing to develop an Emergency Response Plan to protect public health and the
environment; and,
• Failing to include a drain pipe and valve in the containment basin in the
Mechanical Integrity Program.
5-243
Congressman Henry A. Waxman
June 18, 2013
Page3
Rancho LPG was given until April 15, 2013, to file responses to EPA's allegations. Our
Staff contacted the EPA on May 6, 2013, to inquire into the status of Rancho LPG's
response, but we have received no response to our inquiry from EPA. We seek your
assistance in getting an update from EPA in this matter.
· Again, I thank you for your leadership in addressing this issue affecting all of our
constituents. If you have questions or need additional information, please contact
Senior Administrative Analyst Kit Fox at (310) 544-5226 or kitf@rpv.com.
Sincerely yours,
~'/n~
Susan M. Brooks
Mayor
enclosures
cc: Rancho Palos Verdes City Council
Carolyn Lehr, Rancho Palos Verdes City Manager
Mayor Margaret Estrada and the Lomita City Council
Michael Rock, Lomita City Manager
Mayor James F. Goodhart and the Palos Verdes Estates City Council
Anton Dahlerbruch, Palos Verdes Estates City Manager
Mayor Frank E. Hill and the Rolling Hills City Council
Steve Burrell, Rolling Hills Interim City Manager
Mayor Frank V. Zerunyan and the Rolling Hills Estates City Council
Doug Prichard, Rolling Hills Estates City Manager
Kit Fox, Senior Administrative Analyst
M:\Border lssues\Rancho LPG Butane Storage Facility\20130618_Waxman_RanchoLPG.doc
5-244
Letter from Congresswoman Hahn to EPA
regarding Rancho LPG facility
5-245
JANICE HAHN
44TH DISTRICT, CALIFORNIA
COMMITTEES:
TRANSPORTATION AND
INFRASTRUCTURE
SMALL BUSINESS
PORTS CAUCUS
FOUNDER AND CO-CHAIR
SOUTHERN CALIFORNIA REGIONAL WHIP
GUN VIOLENCE PREVENTION TASK FORCE
<teongrr:5'5' of tbe -mniteb ii5>tate5'
~ouS't of laepreS'entatOns-
•a!!fJingtou, jl(!t 20515-0544
The Honorable Jared Blumenfeld
Regional Administrator
U.S. Environmental Protection Agency
75 Hawthome St. (OPA-3)
San Francisco, CA 94105
Dear Administrator Blumenfeld,
July 10, 2013
W.AS.t!!.N.GI.QN..Q£f.K~:
404 CANNON HousE OrncE 8uu.1>1N<;
WASH!NGTON, DC 20516
(202) 225-8220
FAX: (202) 226-7290
QJ.SIBtc.I...QJ.flCf.~
140 W. 6n1 Smrnr
SAN PEDRO, CA 90731
(310) 831-1799
FAX: (310) 831·· 1885
HTTP:llMAHN.H(ltJSE.GOV
As you are aware, I am deeply concemed with the safety of members of my community who live,
work, and send their children to school in the shadow of the Rancho LPG Facility in San Pedro. I
greatly appreciated your taking the time to come to my district office last year to hear directly from
community leaders who expressed t\1eir continuing concern about the safety of the site.
In March 2013, the EPA issued a ''Notification of Potential Enforcement Action for Violation of
Section l 12(r) (7) of the Clean Air Act" to the Rancho Facility and Rancho was given until April 15,
2013 to respond. I was gratified to see the EPA pursuing the safety concerns of my constituents so
forthrightly, and I want to thank you again for your vigilance.
I understand that the EPA wants to schedule a meeting with Rancho LLP to address their response in
August. The community is eager to see this matter resolved as quickly as possible, and so I write to
request that the meeting be held this month.
I continue to believe that the relocation of these tanks is the only pennanent solution to the threat posed
by the Rancho facility. Until we achieve that, however, I know the community would appreciate a
report as soon as possible about the steps EPA is taking to aggressively confront and correct any and
all possible violations at the facility.
Thank you for attention to this matter. If you have any questions, please call my District Director,
Elise Swanson at (310) 831-1799.
Sincerely,
nice Hahn
ember of Congress
CC: Councilmember Joe Buscaino, Los Angeles City Council
Mayor Susan Brooks, City of Rancho Palos Verdes
5-246
Letter from Congressman Waxman to OHS
regarding Rancho LPG facility
5-247
FRED UPTON, MICHIGAN
CHAIRMAN
ONE HUNDRED THIRTEENTH CONGRESS
HENRY A. WAXMAN, CALIFORNIA
RANKING MEMBER
etongrt~~ of tbt ~lnittb tatt~
jj}ouse of 3lcpresentatibes
COMMITTEE ON ENERGY AND COMMERCE
2125 RAYBURN HousE OFFICE ButLDING
WASHINGTON, DC 20515-6115
The Honorable Janet Napolitano
Secretary of Homeland Security
Washington, DC 20528
Dear Madame Secretary:
Majority {202) 225-2927
Minority {202) 225-3641
July 31, 2013
This week, explosions at a propane gas plant in Flori.da underscored the potential dangers
to local communities from facilities that store liquefied gas. The Florida plant was relatively
small, but the incident there injured workers, some critically, and forced an evacuation of the
surrounding communi.ty.
b1 my district, there is a facility with much larger tanks that stores liquefied gas. My
investigation indicates that the Department does not appear be taking the steps necessary to
protect the public from the risks of explosions. In fact, the Department is reaching conclusions
that conflict with those of EPA inspectors, creating confusion and potentia1ly delaying safety
measures. I am writing to call this facility to your attention and to urge the Department to take
all necessary steps to safeguard the local community.
Earlier this year, community leaders brought to my attention the liquefied petroleum gas
storage facility owned by Rancho LPG Holdings LLC in San Pedro, California. Like the Blue
Rhino facility that exploded in Florida, Rancho holds significant quantities of flammable gases,
including propane. Unlike the Florida facility, the Rancho facility's holdings are stored in large
tanks, posing a threat of a larger scale explosion than what was seen in Florida.
The community leaders in Rancho Palos Verdes are concerned about the risks Rancho
poses to its neighboring residents. They told me that unexplained flaring has occurred at the site
without proper notification and that mitigation measures have not been performed at the site to
prevent an accident or terrorist attack. ·They are concerned that the tanks are simply too close to
homes and schools, given the possibility of a large-scale explosion.
On March 14, 2013, the U.S. Environmental Protection Agency (EPA) initiated an
enforcement action against Rancho for violations of legal requirements of EPA' s Risk
Management Program. Rancho was cited for failure to share the facility's emergency response
plan with first responders who would have a role in responding to a release at the facility, failure
5-248
The Honorable Janet Napolitano
July 31, 2013
Page 2
to assess risks in its rail storage area, and a failure to properly plan for seismic events.
Essentially, EPA said that Rancho is not prepared for an earthquake or accident.
When I learned of these facts, my staff contacted the Department of Homeland Security
(DHS) to learn what the Department was doing to protect the community. Under the current
system, federal oversight of a facility like Rancho is split between EPA, which is charged with
protecting against chemical accidents, and DHS, which is charged with protecting against
chemical releases that are caused by terrorist or criminal acts.
What we learned from DHS was surprising. While EPA has taken action to protect the
community from deficiencies in the Rancho facility's preparedness, DHS found no significant or
disqualifying problems at Rancho. An official of the Department told my staff that the facility
hadjust undergone a "successful CFATS inspection."1 No explanation was given as to how
Rancho could be a danger to the cmmnunity according to EPA but perfectly safe according to the
Department of Homeland Security.
Last week, my staff reviewed the records from that inspection, and they reveal serious
inadequacies in the DHS inspection at the facility. Most of the information DHS relied upon was
self-reported by the facility. And when the inspectors went to the facility to conduct the
inspections, their verification efforts were minimal.
For example, the DHS inspector "verified" that the facility's emergency response plan
had been communicated to local emergency responders based on an interview with a senior
representative of the company's management who did not work at the facility, whereas EPA
found by checking with employees and local emergency responders that the facility's emergency
response plan was not on file.
Similarly, the DHS inspector "verified" that employees had been trained on their roles
and responsibilities in emergency situations by reviewing training records and interviewing the
same senior manager, but EPA discovered by checking with the employees that they did not
know what their roles and responsibilities are for emergency response.
As I hope you can understand, the DHS actions have the potential to create considerable
confusion for the community. EPA says Rancho is not prepared for an accident; DHS says the
company is prepared for an intentional attack. The EPA inspection appears thorough; the DHS
inspection seems cursory. The EPA findings are alanning; the DHS conclusions are reassuring.
I believe the root cause of the problem may be deficiencies in the Chemical Facility Anti-
Terrorism Standards (CFATS) program administered by DHS. The CFATS program has a long
1 Oral communication between DHS staff and Energy and Commerce Committee staff
(Mar. 21, 2013).
5-249
The Honorable Janet Napolitano
July 31, 2013
Page 3
record of ineffectiveness. As Rep. Bennie Thompson, the Ranking Member of the Committee on
Homeland Security, and I wrote President Obama earlier this year, CF ATS appears to be a
"failing" program that has shown a "distressing lack of progress in securing these facilities since
the program was established nearly six years ago."2 Now, this example suggests that the
benchmarks for progress through the CF ATS program are not reliable indicators of a facility's
security. It is troubling to think that we might never have become aware of the deficiencies in
the CF A TS inspection if not for EPA• s work. Significant changes to the CF A TS program appear
warranted.
I urge you to review the Department's actions at Rancho and the larger CFATS progran1.
I hope you will then take whatever steps are necessary to ensure public safety.
Thank you for your attention to this matter.
Sincerely,
Henry A. Waxman
Ranking Member
2 Letter from Rep. Henry A. Waxman, Energy and Commerce Committee Ranking
Member, and Rep. Bennie Thompson, Homeland Security Committee Ranking Member, to
President Barack Obama (May 2, 2013) ( online at
http://democrats.energycommerce.house.gov/index.php?q=news/ranking-members-waxman-and-
thompson-urge-president-to-establish-blue-ribbon-commission-on-chemi).
5-250
E-mails regarding Rancho LPG facility
5-251
Kit Fox
From:
Sent:
To:
Cc:
Subject:
Janet Gµnter <arriane5@aol.com>
Wednesday, June 19, 2013 11 :29 PM
MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; det31 O@juno.com; connie@rutter.us;
jody.james@sbcglobal.net; Kit Fox; chateau4us@att.net; connie@rutter.us;
lisa.pinto@mail.house.gov; aaron.wilensky@mail.house.gov; dan.tillema@csb.gov;
don.holmstrom@csb.gov; Beth.Rosenberg@csb.gov; Mark. Griffon@csb.gov; Rafael. Moure-
Eraso@csb.gov; wesling.mary@epamail.epa.gov; meer.daniel@epa.gov;
helmlinger.andrew@epa.gov; blumenfeld.jared@epa.gov; marciesmiller@sbcglobal.net;
pmwarren@cox.net; igornla@cox.net; dwgkaw@hotmail.com; burling102@aol.com;
jacob.haik@lacity.org; richard.vladovic@lausd.net; bonbon90731@gmail.com;
nancy.lauer@lapd.lacity.org
lhermanpg@cox.net; pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu;
c.jjkondon@earthlink.net; rcraemer@aol.com; goarlene@cox.net; leneebilski@hotmail.com;
overbid2002@yahoo.com; diananave@gmail.com; mandm8602@att.net;
dlrivera@prodigy.net; peter.burmeister@sbcglobal.net; ronkil@aol.com; lpryor@usc.edu;
earl .southwell@gmail.com
Another article on Prof. Bea who has acknowledged the extremely high risk of Rancho LPG in
San Pedro
http://discovermagazine.com/2013/june/14-master-of-disaster#. UcKZU uNC-1
1
5-252
Master of Disaster I DiscoverMagazine.com Page 1of6
FROM THE JUNE 2013 ISSUE
Earthquakes and hurricanes will always wreak havoc, but risk management
expert Robert Bea says the greatest tragedies result from hubris and greed.
By Linda Marsa I Thursday, May 23, 2013
RELATED TAGS: NATURAL DISASTERS
Paul Chinn/San Francisco Chronicle/Corbis
Robert Bea has an unusual specialty: He studies disasters. As one of the world's leading experts in
catastrophic risk management, the former Shell Oil Co. executive sifts through the wreckage to
unravel the chain of events that triggers accidents. The blunt-spoken civil engineer has spent more
than a half-century investigating high-profile engineering failures, from the space shuttle Columbia's
horrific end to the explosion of the Deepwater Horizon oil-drilling rig in the Gulf.
A professor emeritus of civil engineering at the University of California, Berkeley, Bea's disaster
autopsy methods. -such as looking at the organizational breakdowns that lead to calamities -have
been widely adopted. Although policymakers and corporate honchos seek his counsel, sometimes
they don't like what he has to say -witness the flak he took from BP during the Deepwater Horizon
probe.
Now in his mid-70s, Bea's voice is raspier, but his critical faculties are undimmed. On a crisp fall day,
he talked with DISCOVER in his comfortable one-story house in Moraga, a leafy suburb east of
http://discovermagazine.com/2013/june/l 4-master-of-disaster 7/29/2013 5-253
Master of Disaster I DiscoverMagazine.com Page 2of6
Berkeley, about what causes catastrophes.
You have said that engineering failures aren't the chief culprits behind disasters, pointing
instead to human and organizational failures -inadequate safety protocols, corporate
hierarchies, conflicting egos or just plain laziness. Was there an "aha moment" when this
became apparent?
When I was involved in the investigation into the Piper Alpha disaster, when an explosion destroyed
an Occidental Petroleum oil-drilling platform in the North Sea, killing 167 men in 1988. The external
investigation team that had been hired by Occidental into what caused Piper Alpha found it was a
corporate culture that had gone bad, had lost its way.
I was part of that team all the way through the Lord Cullen Commission hearings in London, and I
had to listen to one of my friends explain to the Cullen Commission why he and his colleagues had
turned off the smoke alarms on the platform because the operating crew was doing a routine
maintenance procedure late in the evening. Unfortunately, for over a month, certain alarms had been
disabled to prevent unnecessary shutdowns on the rig -in some cases as a response to practical
jokes. But turning off the alarms was one of the reasons they got caught by surprise.
Ironically, two years before, I was brought in to advise Occidental on risk management for Piper
Alpha because they were having gas releases, pipes were leaking. Of course, you didn't have to be
very smart to say, "Yeah, we've got a problem -it's called rusty pipes. And we've got problems with
people not doing what they should be doing, and people who don't understand what's happening."
One evening, during the first year of the investigation, I saw spread out on the reception table of the
Occidental offices a copy of the London Times newspaper with a great, big, bold headline that said,
"Occidental puts profit before safety."
It had a picture of one of the bandaged, beat-up, horribly scarred survivors from the disaster who was
telling this to the newspaper. What this survivor was observing is true. If you don't have profitability,
you don't have the resources to invest in achieving adequate protection. What the tension is, is
having the discipline and the foresight to make those investments before you're in trouble.
When I came back to Berkeley after the investigation was completed, I realized that for the past 50-
some-odd years of my career, I'd been working on 10 percent of the problems. I'd been working on
normal engineering things, and 90 percent of the problems are humans and/or organizations.
We often have ample warnings before catastrophes hit, but we tend to ignore them until it's
too late. Why?
http://discovermagazine.com/2013/june/14-master-of-disaster 7/29/2013 5-254
Master of Disaster I DiscoverMagazine.corn Page 3 of6
The problem is attention span, particularly in this country because we are a pretty young country. Our
knowledge of history is very limited. We are extremely blessed. Lots of good things attract our
attention. It's a noisy environment, really noisy. It's unusual to find people who are comfortable sitting
in a room by themselves thinking.
You could say the eruption of Mount St. Helens was certainly painful, but it actually affected relatively
few people and then disappeared into that strong noise environment. At that point people say, "Well,
it's never happened to me.
I can't even remember my parents talking about it, and I've got these new things to play with, and
they require attention," like Facebook and Twitter. And suddenly, we have flitted from something that
is difficult and painful to think about back to something that is enjoyable.
You seem to be suggesting that people have
trouble dealing with issues over the long term.
Are there other examples?
Well, global climate change is a perfect one, or
rising sea levels. It's happening slowly. People
love living by the beach, so they build a beautiful
home on a concrete slab, on top of the sand a few
feet above sea level, and [ignore the fact] that the
sea level is [rising]. So thinking about these slowly
evolving long-term things, it is painful. It says,
"Well, I might have to move my home. I really
enjoy the beach," and we don't like to give those
things up.
Is this inability to think long term also true of
organizations -corporations or government
agencies?
Yes. The equation for disaster is A+ B = C. A is
natural hazards, things like hurricanes, gases and
liquids under pressure that are extremely volatile.
They're volcanoes. They're tsunamis. They're
natural, and there's nothing unusual about them.
Robert Bea helped investigate the 1988 Piper Alpha
disaster, where an exploding oil platform killed 167 in
the North Sea.
Press Association/AP
http:// discovermagazine.corn/2013/june/l 4-rnaster-of-disaster 7/29/2013 5-255
Master of Disaster I DiscoverMagazine.com Page 4 of6
B is organizational hazards: people and their hubris, their arrogance, their greed. The real killer is our
indolence.
So human error is the kindling that escalates a natural hazard - a hurricane, a tsunami,
chemicals under pressure -into C, a catastrophic disaster. Can you give me some
examples?
Hurricane Ike. Galveston, Texas, got completely wiped out in 1900. Thousands of people got killed.
So.the U.S. Army Corps of Engineers built a seawall on Galveston Island, and that sucker has gone
through every major hurricane since 1900.
But people think that if a storm hasn't happened since they lived there, somehow it can't happen to
them. This is.where B comes in -the hubris and shortsightedness. Because a hurricane hadn't
flattened the city in decades, civic leaders decided to let people build at sea level again. And when
Hurricane Ike came through in 2008, it was just like Berlin at the end of the second world war.
Everything was gone.
Before Superstorm Sandy, I wrote that the subways were going to flood, but no one did anything.
Mayor Bloomberg even hired some of my engineer friends from the Netherlands to come to New
York City and advise him about building gates to cut off incoming hurricane surges.
But here we're back to B -hubris and shortsightedness. People think because they've never seen a
storm like what happened in New Jersey or they've never seen the tunnels flooded in New York City
that it can't happen, or that they need to think about building a levee.
When I lived in New Orleans, we lost everything in Hurricane Betsy [in 1965]: our house, wedding
photographs, marriage license, birth certificates. Yet 40 years later, after Katrina, I go back to the
same place. There's a new home built on the foundation, and the owners are dragging wet, oily
mattresses out the front door.
Luckily I had no one with me that morning, but I broke down and cried. It wasn't tears of sadness. It
was tears of frustration at such a miserable, despicable mess. While we can't prevent disaster, we
can do things that are more sensible to mitigate risks, like maybe not building homes in floodplains.
But the cities are already there. Are you going to move entire cities?
In some cases, yes. We did it in the Mississippi River Valley after the 1993 floods. We actually
moved entire towns to higher ground, like Valmeyer, Ill., and Rhineland, Mo., because we suddenly
http://discovermagazine.com/2013/june/l 4-master-of-disaster 7/29/2013 5-256
Master of Disaster I DiscoverMagazine.com Page 5 of6
recognized they'd rebuilt them five times in the same damn place. Doing it six times doesn't quite
make sense. But there is not a "one size fits all" answer.
In other cases, there are intermediate solutions that can work, such as occupying only what you can
defend properly and in a sustainable manner. An example is the "new New Orleans," where parts of
the city outside of the defended perimeter of the levee system can be expected to flood severely and
frequently. Individuals there are building structures on higher ground and making them stronger, and
preparing to take care of themselves in future storms.
1 of3 e
Comment on this article
http://discovermagazine.com/2013/june/14-mastet-of-disaster 7/29/2013 5-257
Master of Disaster J DiscoverMagazine.com
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Linda Jablonowski a month ago
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7/29/2013 5-258
Kit Fox
From:
Sent:
To:
Janet Gunter <arriane5@aol.com>
Thursday, June 27, 2013 5:29 PM
MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; det31 O@juno.com;
jody.james@sbcglobal.net; connie@rutter.us; marciesmiller@sbcglobal.net;
dwgkaw@hotmail.com; igornla@cox.net; fbmjet@aol.com; owsqueen@yahoo.com;
lljonesin33@yahoo.com; dan.weikel@latimes.com; paul_h_rosenberg@hotmail.com;
stanley.mosler@cox.net; bonbon90731@gmail.com; dlrivera@prodigy.net; overbid2002
@yahoo.com; diananave@gmail.com; burling102@aol.com; pmwarren@cox.net;
carriescoville@yahoo.com; chateau4us@att.net; Kit Fox; lhermanpg@cox.net;
pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu; c.jjkondon@earthlink.net;
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mary _gligorov@yahoo.com; ksm ith@klct.com; robertrnch@aol .com;
richard.vladovic@lausd.net; nancy.lauer@lapd.lacity.org; lisa.pinto@mail.house.gov;
aaron.wilensky@mail.house.gov; lpryor@usc.edu; carl.southwell@gmail.com
Subject: Fwd: Testimony of CSB Chairperson Before the U.S. Senate Committee on Environment and
Public Works
Wake up everybody!!!
If Professor Bob Bea is concerned ... don't you think everybody should be?????!!! The "Premiere Authority" on Risk in the
United States has confirmed that there is a serious problem in San Pedro with extraordinary risk exposure. Why is
Rancho going to have to blow up before anyone responds to this flagrant hazard??!!
Janet G
-----Original Message-----
From: Robert G. BEA <rgb251@berkeley.edu>
To: Janet Gunter -San Pedro LPG Risk <arriane5@aol.com>
Sent: Thu, Jun 27, 2013 2:49 pm
Subject: Fwd: Fw: Testimony of CSB Chairperson Before the U.S. Senate Committee on Environment and Public Works
" ... tragedies of the kind that should be prevented ... "
~
To view this message in a browser, please click here
CLICK HERE to view the written statement
CLICK HERE to view the CSB's preliminary findings
BEGIN TESTIMONY
Chairman Boxer, Senator Vitter, and distinguished Committee members -thank you for inviting me today. I am CSB
Chairperson Rafael Moure-Eraso.
The two explosions we are discussing today -West Fertilizer and Williams Olefins -are tragedies of the kind that
should be prevented.
The destruction I personally saw in West -the obliteration of homes, schools, and businesses by an ammonium
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nitrate explosion -was almost beyond imagination. The loss of life was horrible.
The CSB has determined that ammonium nitrate fertilizer storage falls under a patchwork of U.S. safety standards
and guidance - a patchwork that has many large holes.
These holes include: the use of combustible wooden buildings and wooden storage bins, sprinklers generally not
required, and no federal, state, or local rules restricting the storage of large amounts of ammonium nitrate near
homes, schools and hospitals.
Voluntary fire codes have some useful provisions for ammonium nitrate. But Texas and most of its counties have no
fire code. So at West, these fire code provisions were strictly voluntary, and West Fertilizer had not
volunteered. Our investigators learned that combustible seeds were stored near the ammonium nitrate, not
· separated by any fire-resistant partition.
OSHA has some similar provisions for ammonium nitrate fertilizer in its Explosives standard, 1910.109. However,
OSHA has not focused extensively on ammonium nitrate storage and hadn't inspected West since 1985.
Other natiohs have gone much further than the U.S. on ammonium nitrate safety. The UK recommends dedicated,
noncombustible storage buildings and noncombustible bins. The U.S. manufacturer, CF Industries, recommends the
same and urges sprinklers as well.
But the fertilizer industry tells us that U.S. sites commonly store ammonium nitrate in wooden buildings and bins -
even near homes, schools, or other vulnerable facilities. This situation must be addressed.
Preventing the risk of fire essentially eliminates the potential for an explosion like we saw in West, by removing one
of the preconditions for detonation.
Facilities like West fall outside existing federal process safety standards, which were developed in the 1990's and
are list-based.
Ammonium nitrate would likely have been included, if the EPA had adopted our 2002 recommendation to cover
reactive chemicals under its Risk Management Program.
But the modestly sized RMP program is no panacea; it already covers large refineries and petrochemical sites -
including Williams Olefins -and yet we still see serious accidents.
The Williams plant has over a hundred workers, producing ethylene and propylene.
On June 13, there was a catastrophic failure involving a heat exchanger and associated piping which broke loose
from a distillation tower. The ensuing explosion led to the deaths of two employees. We join in mourning their loss.
It is too soon in our investigation to tell why the equipment failure occurred.
The bigger picture in process safety is that EPA and OSHA resources are under duress. Regulations need to be
modernized -but more inspection and prevention are needed as well.
Meantime, we are finding encouraging alternatives to the current situation:
Following the Chevron refinery fire last year, and acting upon CSB recommendations, California is poised to triple
the number of dedicated process safety inspectors ... funded by industry fees.
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Another promising approach is the 'safety case'-successfully used in other nations, which insurers say have much
lower petrochemical accident rates than we do.
Companies identify and commit to follow the best safety standards from around the world, subject to approval and
oversight by a competent, well-funded regulator. Many experts believe this is the best safety regime for complex,
technological industries, rather than the U.S. system which calls upon a prescriptive and often outdated rule book.
Thank you again for the opportunity to testify today.
END TESTIMONY
Robert Bea
Professor Emeritus
Center for Catastrophic Risk Management
University of California Berkeley
Email: bea@ce.berkeley.edu
Risk Assessment & Management Services
60 Shuey Drive
Moraga, CA 94556
925-631-1587 (office)
925-699-3503 (cell)
Email: BeaRAMS@gmail.com
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Kit Fox
From:
Sent:
To:
Cc:
Subject:
Janet Gunter <arriane5@aol.com>
Saturday, July 06, 2013 8:22 PM
MrEnvirlaw@sbcglobal.net; det31 O@juno.com; jody.james@sbcglobal.net; connie@rutter.us;
chateau4us@att.net; Kit Fox; burling102@aol.com; marciesmiller@sbcglobal.net;
dwgkaw@hotmail.com; igornla@cox.net; fbmjet@aol.com; robertrnch@aol.com;
bonbon90731@gmail.com; pmwarren@cox.net; ksmith@klct.com;
kyle_ chapman@boxer.senate.gov; maurice _lyles@boxer.senate.gov;
michael_ davies@feinstein.senate.gov; michael .picker@gov.ca.gov;
lisa.pinto@mail.house.gov; aaron.wilensky@mail.house.gov; lhermanpg@cox.net;
pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu; c.jjkondon@earthlink.net;
rcraemer@aol .com; goarlene@cox.net; leneebilski@hotmail.com
bea@ce.berkeley.edu; lpryor@usc.edu; carl.southwell@gmail.com
LPG Fires re: today's Canada rail explosion. Attention to 2nd link as it relates to the "domino
effect"
Remember that San Pedro's Rancho LPG LLC's 25 Million Gallons of Butane & 300,000 Gallons of Propane are
surrounded on three sides by more jet propellants (in huge underground storage tanks across the street) at the Naval Fuel
Depot (west) and a host of other types of oil and gasses (including additional butane) at the abutting Phillips 66 refinery
(north). Let's not forget the full array of marine oil terminals within 1/2 mile (east) or the multitude of chemical and fuel
pipelines running directly underneath the Rancho facility. The massive volume of butane and propane at this site is
extraordinary .... and the geologic vulnerabilities along with the antiquated infrastructure make the Rancho facility a concern
of great urgency. Not only would it annihilate people for miles, but decimate both ports of LA and Long Beach. See videos
at these links:
http://www.youtube.com/watch?v=nNY2YsVjcd4
http://www.youtube.com/watch?v=UFFDLk1 fXcU
http://www.youtube.com/watch?v=Xf3WKTwHplU
It's time to do something.
Jiminy Cricket
www.hazardsbegone.com
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Kit Fox
From:
Sent:
To:
Subject:
Attachments:
Paul:
Noel Weiss <noelweiss@ca.rr.com>
Saturday, July 06, 2013 9:12 PM
Paul Rosenberg; Janet Gunter; Anthony Patchett; Connie Rutter; Jody James; det310
@juno.com; June Smith; marciesmiller@sbcglobal.net; chateau4us@att.net; Peter M.
Warren; hanslaetz@gmail.com; Kit Fox
Re: LPG Railcar Explosion today in Canada
National Fire Protection Association -2009 -Safe Tank Separation Requirements.pdf; Rancho
-Revocable PERMIT _RP_ 10-05.o.pdf; Contra Costa County Risk Management
Ordinance.o.pdf; Janice Hahn Motion on Rancho -September 14, 2010.pdf; RIGZONE -
Alberta Government Charges Plains Midstream Over Oil Spill-April, 2013.pdf
Thanks for the invite .... and thanks for the terrific and informed coverage from Random Lengths over the years ....
I believe Paul that there are tank cars in varying numbers {I am not sure how many) that line up near the facility to receive
(and possibly deliver) butane for transport ...
This does raise an issue of infrastructure and the integrity of the rail spur owned by the Port and leased to Rancho (very,
very cheaply ... possibly so cheaply that it represents a de facto subsidy by the Port to Rancho which would be a violation
of the Tidelands Trust Doctrine which makes unlawful the use of tidelands trust monies and assets monies to benefit a
private entity not part of the tidelands grant -which is the reason neither the Port revenues or the Airport revenues can be
used for anything other than the operation and maintenance of the airport and the port (as the case may be)) ....
I
Who maintains the rail spur?
Note that the permit says the Port can control what happens on the rail spur. . This language arguably is broad enough to
include direction by the Board to Rancho on how Rancho operates the facility since what occurs in the facility impacts on
the integrity of the rail spur (if Rancho ever 'blew', is there any doubt the rail spur would be destroyed or seriously
damaged ... But the language is so incredibly poorly written, that needless confusion arises, which prejudices the people's
safety, to say nothing of the Port's contractual rights ... Our (former) incompetent City Attorney in action .. The hope is
now Paul that this Rail Spur Permit gets rewritten by someone who knows how to write a contract that protects the people,
and includes a requirement that Rancho provide insurance and an indemnity to protect the Port, the City, and the people
from all damages occasioned by the Rancho's operations ..... The kind of thing I am thinking of are things (beside
insurance) such as:
1. Limiting the use of the tanks to just one tank instead of two until some kind of wall is built in front of the facility which
makes it just a little more difficult for a terrorist to plug a bunch of high-powered bullets into the tanks from the street;
2. Requiring the tanks be separated by a safe distance, and controlling the amount of butane on-site to (say half) until the
tanks are safely separated;
3. Including a provision in the contract that says that Rancho is strictly liable for all damages to the people, the Port, and
the City occasioned by its operations .... period, end of story.
4. Rancho files with the Port and the City (with the right of public inspection) a clear, unambiguous Risk Management
Program of the type contemplated by the Risk Management Ordinance enacted by Contra Costa County;
5. That the rent be raised to pay for the costs of bi-annual inspections whose results are open to the public;
6. That the lease incorporate any changes to existing laws passed by the City of Los Angeles .. and in the meantime,
have Rancho fully comply with the provisions of the Contra Costa County Ordinance (which could be incorporated into the
rail spur permit, plus provide an adequate amount of insurance ($1.5 Billion Minimum) to protect the people, the Port, and
the City .... ; (Keep in mind Paul, that the permit is revocable without cause on 30 days notice .. so the Port and the City
of LA could make these changes post-haste to take effect within 60-90 days, or else the permit would be terminated);
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7. Clarify that the use of the rail spur tracks are to facilitate Rancho's business activities, clearly identified (storage, sale,
and transport of butane and propane) ... the rail spur permit is unclear and ambiguous in this regard;
8. Clarify that it is Rancho who is to maintain the rail spur. ..... Because the permit is a 'form' document applied to
buildings instead of rail spurs, the maintenance provisions are confusing and therefore ambiguous ...
9. Revise totally Paragraph 13 (which says that Rancho shall not permit hazardous materials to be used on the rail spur ..
in quantities that would require reporting to the Feds or the State .. ) .Seems, therefore, on the face of it, that using the rail
spur to transport butane would not be allowed under this language .. Of course, it is part of the incredibly poor lawyering
done by the City Attorney's office who, of course, is completely conflicted out because the City Attorney represents
conflicting sides .. The Port (against whom the City will have a claim if there ever is an explosion that necessitates police
and fire) and the City (the Port has not agreed to indemnity and insure the City ... something the City should insist upon ..
. . relying instead on Rancho's promise of indemnity .. backed by a small insurance policy. . . but in any event, the City
has claims against the Port for the Port's negligent management of this rail spur permit. .. Being on both sides of this
situation puts the City Attorney in an impossible ethical conflict which could be and should be obviated in the absence of a
clear and informed waiver by the City Council and the Port .... a waiver which should never occur ... Trutanich and
Delgadillo were either blind to this ethical slight or ignored it. . Meanwhile, the people are prejudiced and the City
Attorney's fiduciary duties to the people violated (The fiduciary duties are borne out of the fact that the City of Los Angeles
is a public trust, operated by the Trustee (the municipal corporation created by the Charter), for the benefit of the people,
who are the beneficiaries of that public trust. .. That makes each City Council person, the Mayor, the City Attorney, and
the Controller Trustees (or agents of the Trustee-Municipal Corporation) ... and as public Trustees of the public trust, they
owe special fiduciary duties to the trust beneficiaries (in this case, us (we the people) .... So Mike Feurer needs to resign
from representing the Port, who should retain its own council. .. The job of the City Attorney is not to run political
interference for the Council or the Port Commissioners (or the Mayor) .. But to be a check and a balance on political
excess, political favoritism, and crony-capitalist insider City Hall dealings .... If Feurer fails to do so, he is committing
legal and political malpractice ... But regardless, this piece of garbage that masquerades as a legal contract (a permit)
needs serious, serious revision to protect the people's interest. ...
My contention is that Rancho is in violation of Paragraph 17 .. the use of this rail spur is not consistent with the Tidelands
Trust Doctrine because the Port is making a gift of public assets to Rancho by leasing the rail spur for a pittance ($1187
per month -where they came up with that number. . who knows .. ) when the value is much, much more ... particularly
when taking into account that the rail spur is the only way the butane gets to 'market', whatever that is ... .
Which, by the way, leads to another avenue of inquiry Paul. .... With all of the new drilling and tracking going on, natural
gasses (including butane) are in plentiful supply ... Meanwhile, the demand is down .. which means the price for butane is
low .... It would appear, however, that Rancho may be gambling with the public safety by using this facility to speculate in
the butane market. . by purchasing butane and storing it during the summer months (when the price is especially low),
and then selling it at a profit during the winter months when demand picks up due to the requirement that butane be used
as an additive in gasoline .... If true, this is 'rank' speculation on the backs of the people .. Given that accidents will
happen (even when companies flush with bucks like Exxon Mobil, Chevron, and PG&E fail to spend what is necessary to
properly maintain their facilities and pipelines) and Plains All America (which really owns Rancho) just had an oil spill in
Alberta last month ... and a major pipeline leak two years ago, for which the government of Alberta is now going after it
(seemingly) big-time for its rank obduracy in failing to be responsible and responsive to the core needs of the situation ....
. it is reasonable to assume that some accident will occur at the facility .. and if it does, then the question to Rancho is:
Why should the public bear the risk of loss from Rancho's operations? Is that fair? Is that right? Is that good public
policy?
The Port should use what leverage this rail spur permit gives it to insist on a much greater degree of safety .. .for the
Port's own good and its own pocketbook, if for nothing else .....
That leads to a question of whether the Port is insured for the costs occasioned by an accident at the Rancho facility ..
and if so, the Port needs to let us know what kind of insurance it has which covers its exposure .. which, by the way,
includes exposure to the Citizens of Rancho Palos Verdes ....
If the Port does not have insurance to cover its liability exposure, it needs to go out and get it (again, $1.5 Billion
Minimum) and then charge Rancho for the cost. . and if Rancho can't pay, then Rancho needs to shut-down and the rail
spur permit revoked ..... The Rail spur permit is so poorly written, that this issue is simply not clear ...
So the core question for the Port is ... 'Why are you acting so incredibly recklessly in allowing Rancho to socialize the
losses this way ... ? It is not a lawful expenditure of port funds or assets to allow a private enterprise like Rancho to
exploit the people, the Port, and the City .. Frankly, apart from appearing reckless, the Port Commissioners and the
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Executive Director look like idiots ... Who, in their right mind, would expose the Port, the People, and the City to this kind
of risk .... "?Conoco may store 6 million gallons or butane on its property, but Conoco has its own fire department ... and
while I haven't seen a picture of Conoco's facility, my guess is that those 6 million gallons are not concentrated in one
tank .... but are probably split up among several tanks ...
It just seems so incredibly reckless to allow such a large concentration of such a flammable gas like butane ..... at an
exposed facility .. where there is no serious risk management program in place .. and where the public confronts the
specter of having to pay for Rancho's negligence or a terrorist act. .. when both should be Rancho's responsibility .....
As currently written, the rail spur permit allows Rancho to privatize its gains while the losses are socialized on the people .
. . . Not acceptable .... and it should not be allowed to continue ... Joe Busciano, where are you?\
The rail spur permit needs to clearly and unequivocally state that the losses are to be 'strictly' borne by Rancho ... not by
the people, Rancho .. Not by the Port. . Rancho ... Not by the City ... But by Rancho ... Not by the People of Rancho
Palos Verdes .. But by Rancho ....
Another question: When was the last time the rail spur was inspected?
Paragraph 16 of the Rail Spur Perm it does gives the Port the right to inspect the tanks .... Has the Port done so ...
Ever? This clause is the one that could imposes on the Port liability to the City should there be a problem .. .If the Port
fails to exercise the rights it has under the rail spur permit to inspect, then the Port would be negligent. ... If the City has to
respond and expend resources in the process, then the Port should be liable to the City ... There should be some
Memorandum of Understanding along those lines ... Is there? If not, why not? The Port should exercise the power it has
under the rail spur permit (poorly written as it is), particularly now that Rancho has been cited by the EPA ...... In fact,
the Port should send a letter to Rancho insisting on proof of adequate insurance, coupled with proof that Rancho has fully
complied with the EPA mandate ... as well as all other Federal mandates .... This is an appropriate line of inquiry Paul
directed to the Port .. Namely: "Have you?"
The LA City Controller could subpoena all of this documentation under Section 217 of the City Charter .... including
Rancho's insurance ... as part of an objective evaluation of the cost to the City of having to respond to an accident at
Rancho (including the costs of having to reimburse the County Fire and Sheriff's Department, if any) ... Ditto the Mayor. .
Ditto the Harbor Commission .. Ditto the City Council, the President of the City Council, and the Public Safety Committee .
. So it is reasonable to ask these people why they are sitting on their hands ... Because Rancho says no, it will not
provide the documents, or that they are proprietary? Are you kidding me? I don't recall any of these people running for
office saying that if elected, they will let Rancho decide what is in the public interest. .... So now they are in power, it is
not unreasonable to expect them to represent the broader public safety interest. . not Rancho's interest. . Rancho has its
own lobbyists and lawyers .. Who has the public got? The elected trustees of the public trust which is the City of Los
Angeles .... Time for them to do their job.
So technically, the City of Los Angeles and the Port have the ability to protect the people ... until those tanks are
eventually made to go ..... But have they done so? If not, it is time the people insist on openness, transparency, and
action ... Paul, I don't believe Rancho can survive such scrutiny .... It needs to go .. The tanks need to go ... Meanwhile,
the pressure needs to be maintained so the people are protected in the meantime ....
Ask Joe Busciano why he has not re-introduced Janice Hahn's motion of September 14, 2010? (Copy enclosed) ...
Ask Joe Busciano why he has refused to push his motions forward .. If they are bottled up in Committee, Rule 54 of the
Council Rules empowers the full council to vote to bring them out of committee. Joe can fight much harder for the people
here ....
Ask Joe Busciano what is stopping him from pushing the LA City Council to pass a risk-management ordinance modeled
off of the risk-management ordinance in force in Contra Costa County (and fully accepted by the refineries there ..
particularly after the explosion at the Richmond refinery that occurred first in 1999, then in August, 2012 .... ?
Ask Ron Galperin whether he will subpoena Rancho's insurance policy .. and the Port records of inspection of Rancho's
tanks and operation?
Ask Eric Garcetti whether he will use the subpoena power he has under Section 217 of the Charter to get Rancho's
documents and insurance policy, and convene a task force to study and evaluate the risk?
Ask the Port Commissioners why they don't commission an independent study of the risk and charge it to Rancho under
the rail spur permit lease?
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Ask Janice Hahn why she doesn't use her position as Co-Founder of the Port Caucus to hold a hearing of her Port
Caucus (or members) on Rancho and Port Security at the Port .. at which the City officials can attend, along with EPA and
DOT personnel (and Janice Hahn is also a member of the Transportation Committee of the House) ... On September
14,2010, Janice asked Jane Harman to step-up and provide assistance to the City in providing more vigorous
enforcement of Rancho's operations .... Today, Janice sits where Jane sat. .. So the question to Janice is when she is
going to pick up the (proverbial) 'phone call' she placed to Jane back in September, 2010, now that it is Janice on the
receiving end ...
Ask Henry Waxman whether he will join the Port Caucus and stand with the need to remove this blight on the public
safety; or short of that, insist that Rancho cease using this business model of socializing the losses onto the people while
it privatizes the gains ....
Ask the Port Director what kind of insurance Rancho has submitted to the Port as part of the insurance and indemnity
provisions of the rail spur permit (the figure of $1 Million is mentioned; but the permit gives the Director the discretion to
ask for more ... Has she? If not, why not? If so, then the Port should produce the insurance in response to a public
records request (which the City of Rancho Palos Verdes can make also .. and the rail spur permit can request that the
City of Rancho Palos Verdes and its citizens be named additional insureds, along with the people of the City of Los
Angeles .... and then raise the amount from $1 Million to $1.5 Billion ... ) .. Given the situation and the risks, the current
conditions require greater insurance be mandated .. and if the Port fails to require it, then the Port stands exposed to
liability .... That is an opinion I would hope to get (eventually) from the City Attorney of Rancho Palos Verdes (rendered
at the request of the Council) ... armed with that opinion, I can then go to the City Attorney of Los Angeles, the City
Council of Los Angeles, the Mayor, and the Controller in support of my advocacy for the passage of a Risk-Management
Ordinance modeled after the Risk-Management Ordinance passed by the County of Contra Costa.
Why did the Port not get Plains All-America to guarantee Rancho's performance under the rail spur permit? I'm not sure
the Rail Spur Permit is even properly signed (I don't have the version which is stamped approved by the Board .. I assume
one exists ... Perhaps you can check that out. .. ). But Rancho is stated to be a Delaware Limited Partnership located in
Calgary, Alberta .... Yet the document is signed by some 'Vice-President' (actually someone for the Vice-President. .
someone who we don't even know has the authority to sign .. or what is the entity on whose behalf he is signing .... The
question is: "Vice President" of what? If Rancho is a Delaware limited partnership, then who is the general partner .. If it is
a corporation, then who is the corporation? What are its assets?
Rancho is said to be a subsidiary of Plains Mainstream Canada (the same entity that had the oil spill in May, 2013, and
was responsible for the second largest oil pipeline spill in Alberta, Canada history in 2011 (see attached) and is now being
charged by the Canadian authorities with failing to competently remediate the problems stemming from its negligence .. I
don't know if these are civil or criminal charges .. But the point is that it is this same Canadian entity that owns Rancho
that screwed up twice in the last two years in connection with their Canadian operations .. and has been cited now by the
EPA. ...
Meanwhile, Plains Mainstream Canada is a subsidiary of Plains All America ..... So who knows if the signature on the
Rail Spur Permit is even correct. ... and really binds Rancho to anything (One wonders which entity actually pays the
rent) ... So Paragraph 27 of the Rail Spur Permit has to be read in this context. . It says the permit is void if 25% of the
shares of Rancho LPG Holdings, LLC are ever transferred .. Kind of touch to know when it is not clear the City ever took
steps to find out precisely what is going on with Rancho's ownership .. But at a minimum, it would not be took much to ask
that the rail spur permit be signed by the General Partner ... (It is also kind of funny that Rancho is identified as a
'Delaware Limited Partnership in the First Paragraph of the Rail Spur Permit), but is denominated with the letters 'LLC
which usually refers to a 'limited liability corporation" .. So who knows what it is we are dealing with here .... The LA
City Attorney approved the document as to form and content. .. but one has to ask .. What were they thinking? or Were
they thinking?
This whole thing almost has an Enron-like quality about it where some insiders at Plains All American set up this separate
limited partnership to buy the facility and make some easy insider money for themselves by setting up this special limited
purpose entity (be it an LLC (limited liability corporation) or Limited Partnership (LP) to own and operate the Rancho
facility ... where they could make some easy cash by purchasing butane (and possibly propane) at low prices during the
summer, and resell the product at higher prices during the winter months when demand tightens due to the need for
butane as a gasoline additive ... Again Paul, this is worthy of some investigation .... because it is not right for the Port of
Los Angeles to allow its property (the rail spur) to be used by a private company to speculate in the purchase, sale, or
storage of butane .... Regardless, Rancho's ownership structure needs to be fully disclosed ... particularly given the risks
inherent in the storage and transport of this concentrated quantity of butane ..
In short, Paul, there is a lot that can be done here by an inquiring media type such as yourself ... Talents that simply are
absent from the LA Times or the Daily News .....
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PAA {Plains All American) bonds are rated BBB+ ... Not great. ... So Plains is seriously leveraged .... How that impacts
on whether Plains is going to spend all the money needed to safely operate this facility is an open question ... We need to
find out. ... Rancho has a duty to this community ... and that duty entails more openness and transparency than has
been exhibited to date ....
If Rancho is storing butane for others at the site, I can assure you Paul that Rancho's storage contract with its customers
has Rancho indemnifying and insuring them against all liability occasioned by Rancho's operations ... So if Rancho has to
indemnity and insure its customers, Rancho can and should certainly indemnity and insure the people, the Port, and the
City ....
This issue of insurance may come to be relevant on the Keystone Pipeline issue .... There should be a requirement for
the Keystone Pipeline, if it is approved ... that the operator assume strict liability for all spills or damages flowing from its
operation, and that adequate insurance be in place to protect the people ... If there is not a market for insurance, then the
Federal Government should provide it, subject to strict requirements of safety .. which could include a requirement that the
company abide by risk management laws enacted in the local jurisdictions through which the pipeline will flow .. .If that
can't be done .. then no pipeline ...
If such a provision were enacted pertaining to Rancho, then the City of LA could pass a risk-management ordinance
modeled after the Contra-Costa County Ordinance ... an ordinance which Senator Boxer praised in the hearings she held
last month on the Texas fertilizer plant explosion and the Chemical Plan explosion in Louisiana ....
Meanwhile, speak to the members of the Rancho Palos Verdes City Council. . Mayor Susan Brooks sent letters to Janice
Hahn, Henry Waxman, and Joe Busciano asking them to advise what they are doing about Rancho .. and in the case of
Joe Busciano, why the City of LA is not applying for HAZ-Mat (Hazardous Materials) Funding Grants from the State which
will assist in the ability of the fire department to keep people safe .. If Joe can't see his way clear to even do that, what is
he doing on the City Council? .. A nice smile can only get one so far ... In this case, the people need some tangible action
and some tangible results .. so far, neither of which have been forthcoming ....
So I am counting on the City of Rancho Palos Verdes to provide a kick-start to this process .... the 'spark' (no pun
intended} to ignite action ... all eventually leading to at a minimum, a safer facility, the passage by the City of Los Angeles
of a competent risk-management ordinance, and our political leaders (Joe Busciano, Janice Hahn, and Henry Waxman)
truly stepping up and fulfilling their duties to the people ....
If Rancho can't hack it, then Rancho has to leave ...
Abiding such a reckless situation is poor public policy ....
Failing to even discuss it, and thereby allowing Rancho to hide behind lobbyists or politicians who spike public discussion
of the issue is morally corrupt. ...
Joe Busciano is paid a lot of money .. over $200K in cash and non-cash benefits ...
He is not paid to simply smile .. He is paid to act as a co-public trustee of the public trust which is the City of Los Angeles .
. . In that capacity he has a fiduciary duty to the people ...
It is time he take that responsibility seriously ...
Thanks again Paul for your continuing interest in Rancho ....
My confidence now rests with the RPV City Council to help us all 'jump-start' this process .... Hopefully by one or more
formal resolutions asking Joe Busciano, Janice Hahn, and Henry Waxman to report personally to the Council .. along with
eventually procuring an opinion from the Rancho Palos Verdes City Attorney on the legal liabilities attendant to this
situation which run in favor of RPV and its citizens and against the Port and the City of Los Angeles -an opinion I can
then take to the LA City Attorney and the City Council as part of the effort to 'shame' the City of Los Angeles into being
much more pro-active in protecting the broader public interest instead of Rancho's narrow private interest. Once that
happens, I expect Joe Busciano and Janice Hahn to move .... and I will insist that the new Controller, the new City
Attorney, and the new Mayor aggressively join the effort. I also hope and expect this process can and will be facilitated by
serious, well-directed, and thoughtful public participation from RPV residents and from City of Los Angeles residents ..
working together for the collective good ..... reflective of the kind of citizen action that makes our democracy 'hum' and
our Country special. .. true political empowerment of the people to make the system work as it should.
5
5-267
Noel
(310) 822-0239
From: Paul Rosenberg
Sent: Saturday, July 06, 2013 4:02 PM
To: Janet Gunter ; Anthony Patchett ; Connie Rutter ; Jody James ; det310@juno.com ; June Smith ;
marciesmiller@sbcglobal.net; chateau4us@att.net; Peter M. Warren; hanslaetz@gmail.com; kitf@rpv.com;
noelweiss@ca. rr .com
Subject: RE: LPG Railcar Explosion today in Canada
Comments, anyone?
Random Lengths will at least do a news brief on this. But I'd like to have folks thoughts, whether or not we can
go to press with them right now. Obviously our ongoing coverage of Rancho LPG will continue.
Paul Rosenberg
@PaulHRosenberg
Columnist
Al Jazeera English
http://www.aljazeera.com/indepth/opinion/profile/paul-rosenberg.html
Senior Editor
Random Lengths News
http:Uwww.randomlengthsnews.com
To: MrEnvirlaw@sbcglobal.net; connie@rutter.us; jody.james@sbcglobal.net; det310@juno.com;
burling102@aol.com; marciesmiller@sbcglobal.net; chateau4us@att.net; pmwarren@cox.net;
hanslaetz@gmail.com; kitf@rpv.com; noelweiss@ca.rr.com
Subject: LPG Railcar Explosion today in Canada
From: arrianeS@aol.com
Date: Sat, 6 Jul 2013 12:56:44 -0400
http://www.yalibnan.com/2013/07/06/several-missing-after-rail-tanker-cars-explode-in-canada/
6
5-268
Kit Fox
From:
Sent:
To:
Subject:
Janet Gunter <arriane5@aol.com>
Tuesday, July 16, 2013 12:20 PM
MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; connie@rutter.us;
jody.james@sbcglobal.net; chateau4us@att.net; Kit Fox; igornla@cox.net;
dwgkaw@hotmail.com; fbmjet@aol.com; mandm8602@att.net; dlrivera@prodigy.net;
peter.burmeister@sbcglobal.net; pmwarren@cox.net; burling102@aol.com;
marciesmiller@sbcglobal.net; guillermovillagran@sbcglobal.net; ruboysen@aol.com;
lhermanpg@cox.net; pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu;
c.jjkondon@earthlink.net; rcraemer@aol.com; goarlene@cox.net; leneebilski@hotmail.com;
lljonesin33@yahoo.com
IMPORTANT CONNECTION TO RANCHO LPG ... Action on Refinery Safety ...... see link
http ://W'Ww. dai lybreeze. com/news/ci 236641 07 /californ ia-panel-u rges-stri ngent-refi nerv-safety-oversig ht-after
1
5-269
California panel urges stringent refinery safety oversight after Richmond Chevron fire - T ... Page 1 of 2
California panel urges stringent refinery safety oversight
after Richmond Chevron fire
By Robert Rogers, Contra Costa Times Daily Breeze
Posted: DailyBreeze.com
RICHMOND -A state panel convened in the wake of last year's Chevron refinery fire has
recommended the creation of a refinery safety task force, with broad powers to impose
stiffer penalties and improve air-quality monitoring standards.
A report released last week by the lnteragency Working Group on Refinery Safety, a panel
formed by Gov. Jerry Brown in response to the Aug. 6 fire, recommended that existing
regulators work together under a single task force that would be created within the California
Environmental Protection Agency by Sept. 1.
Known a~ the lnteragency Refinery Task Force, it would bring together the work of all the
state agencies with a role in regulating refinery operations and ensure they all freely share
and have access to the same information. The task force would have greater control over
penalties related to refinery accidents and develop a real-time, air-quality monitoring system.
The report states personnel at Chevron's El Segundo refinery, a near duplicate of the
northern facility, found "significant thinning" in piping in a crude unit --which is where the
failure occurred in Richmond. Workers made upgrades with what were deemed to be safer
construction materials.
The U.S. Chemical Safety Board conducted a lengthy investigation into the Richmond fire
and released a preliminary report earlier this year blaming the blaze on a badly corroded
pipe that should have been replaced and warned of ongoing safety shortcomings at the
aging refinery.
Chairman Rafael Moure-Eraso hailed the working group's findings.
"This report represents an important step forward in improving oil refinery safety and
environmental performance both in California and nationally," Moure-Eraso said in a
statement. " ... Not only are more preventive inspections by highly competent inspectors
needed, but more rigorous major accident prevention requirements are necessary as well."
Chevron referred questions about the state report to the Western States Petroleum
Association, an industry group that represents refineries in six states, including 11 in
California.
Association President Catherine Reheis-Boyd said the group has worked alongside the
governor's office and other regulators and is "committed to the ongoing work of refinery
safety."
Reheis-Boyd said she welcomes the call for additional inspectors, paid for by fees levied on
refineries.
http://www.dailybreeze.com/news/ci_ 23664107 /califomia-panel-urges-stringent-refinery-s. .. 712912013 5-270
California panel urges stringent refinery safety oversight after Richmond Chevron fire -T... Page 2 of2
"It's clear that there needs to be better coordination among (regulatory) agencies," Reheis-
Boyd said. "That's an essential element" to reform.
Of the recommendation for stiffer fines and penalties on refineries, Reheis-Boyd said, "We
just want to make sure it's fair and representative of whatever has occurred."
Chevron has said repeatedly in recent months that it welcomes the scrutiny after the fire and
looks forward to working with regulators and government officials to enhance safety and
prevent future accidents.
Federal, state and local officials all have weighed in recently on the need for stronger
refinery regulations and oversight.
At Richmond City Hall on Thursday, the Planning Commission unanimously passed a
resolution calling for city inspectors to declare the Chevron refinery a "dangerous building"
and to use powers under the city charter to more aggressively regulate and inspect the
2,900-acre facility.
"There is additional corrosion all over the refinery," said Roger Lin, an attorney for
Communities for a Better Environment, a local activist group. "We are concerned the refinery
could explode any day."
Chevron spokeswoman Melissa Ritchie said the company is opposed to the resolution.
Andres Soto of Communities for a Better Environment said it is time for "local bureaucrats to
stop dragging their feet" and use their powers to impose greater scrutiny on the refinery.
The state report gives a grim view of refinery safety in California that "raises significant
issues relevant to the state's other 14 refineries."
Calls Monday to Chevron's El Segundo refinery were not immediately returned.Staff writer
Kristin S. Agostoni contributed to this report.
http://www.dailybreeze.com/news/ci_23664107 /califomia-panel-urges-stringent-refinery-s. .. 712912013 5-271
Kit Fox
From:
Sent:
To:
Subject:
Janet Gunter <arriane5@aol.com>
Friday, July 19, 2013 11 :21 AM
MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; jody.james@sbcglobal.net;
connie@rutter.us; det310@juno.com; chateau4us@att.net; Kit Fox;
kyle_ chapman@boxer.senate.org; maurice _lyles@boxer.senate.gov;
lisa.pinto@mail.house.gov; aaron.wilensky@mail.house.gov; elise.swanson@mail.house.gov;
michael.picker@gov.ca.gov; dan.tillema@csb.gov; don.holmstrom@csb.gov;
Beth.Rosenberg@csb.gov; Rafael.Moure-Eraso@csb.gov; Mark.Griffon@csb.gov;
lpryor@usc.edu; earl .southwell@gmail.com; burling 102@aol.com;
marciesmiller@sbcglobal.net; pmwarren@cox.net; mandm8602@att.net;
dlrivera@prodigy.net; peter.burmeister@sbcglobal.net; Zenponee@aol.com;
tdramsay@gmail.com; igornla@cox.net; dwgkaw@hotmail.com; jacob.haik@lacity.org;
john@nrcwater.com; lhermanpg@cox.net; pjwrome@yahoo.com; katyw@pacbell.net;
jwebb@usc.edu; c.jjkondon@earthlink.net; rcraemer@aol.com; goarlene@cox.net;
leneebilski@hotmail.com; claudia.r.mcculloch@gmail.com; bonbon90731@gmail.com;
fmillar@erols.com; Betwixt1@yahoo.com; bmsacks@gmail.com
RL report on Disaster in Quebec and relevance to San Pedro's Rancho LPG Storage facility. &
Sen. Boxer
Cut and paste into your browser for article
http://issuu.com/randomlengthsnews/docs/rln 07-11-13 edition/7?e=4576045/4004393
Turn top. 6.
1
5-272
ISSUU -Rln 07 11 13 edition by Random Lengths News Page 6 of63
The !nside Scoop On Going Nude This Summer 20'13
L SET RET=ON RA::irl now
@PJL SET ECONOMODE=OFF
@PJL SET TRA Yl TEMP= NORMAL
@PJL SET RESOLUTION=60
http://issuu.com/randomlengthsnews/docs/rln _ 07-1 l-13 _ edition/7?e=4576045/4004393 7/29/2013 5-273
Kit Fox
From:
Sent:
To:
Cc:
Subject:
Fred Millar <fmillarfoe@gmail.com>
Friday, July 19, 2013 12:17 PM
Janet Gunter
AGPatchett .; noelweiss@ca.rr.com; Jody James; connie@rutter.us; det310@juno.com;
chateau4us@att.net; Kit Fox; kyle_chapman@boxer.senate.org;
maurice_lyles@boxer.senate.gov; lisa.pinto@mail.house.gov;
aaron.wilensky@mail.house.gov; elise.swanson@mail.house.gov;
michael.picker@gov.ca.gov; dan.tillema@csb.gov; Don. Holmstrom;
Beth.Rosenberg@csb.gov; Rafael. Moure-Eraso; Mark. Griffon; lpryor@usc.edu;
earl .southwell@gmail.com; burling 102@aol.com; marciesm iller@sbcglobal.net;
pmwarren@cox.net; mandm8602@att.net; dlrivera@prodigy.net;
peter.burmeister@sbcglobal.net; Zenponee@aol .com; tdramsay@gmail.com;
igornla@cox.net; dwgkaw@hotmail.com; jacob.haik@lacity.org; john@nrcwater.com;
lhermanpg@cox.net; pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu;
c.jjkondon@earthlink.net; rcraemer@aol.com; goarlene@cox.net; leneebilski@hotmail.com;
claudia.r.mcculloch@gmail.com; bonbon90731@gmail.com; Fmillar@Erols. Com; Betwixt1
@yahoo.com; bmsacks@gmail.com
Re: RL report on Disaster in Quebec and relevance to San Pedro's Rancho LPG Storage
facility. & Sen. Boxer
You all might have noticed that the owner of the est, TX fertilizer plant whose Ammonium Nitrate blew up,
killing 15 including all 12 firefighters who responded, had only $1million in insurance for the disaster costing
an estimated $100 million in property damage alone.
No state or local agency has info on how much insurance your butane facility has?
Fred
On Fri, Jul 19, 2013 at 2:20 PM, Janet Gunter <arriane5@aol.com> wrote:
Cut and paste into your browser for article
http://issuu.com/randomlengthsnews/docs/rln 07-11-13 edition/7?e=4576045/4004393
Turn top. 6.
Fred Millar
915 S. Buchanan St No. 29
Arlington VA 22204
703-979-9191
1
5-274
Kit Fox
From:
Sent:
To:
Cc:
Subject:
Attachments:
San Pedro Peninsula Homeowners United <sphomeunited@gmail.com>
Sunday, July 28, 2013 12:47 PM
lisa.pinto@mail.house.gov; aaron.wilensky@mail.house.gov; elise.swanson@mail.house.gov;
hamilton cloud; jacob.haik@lacity.org; helmlinger.andrew@epa.gov; mary wesling;
kyle_chapman@boxer.senate.gov; maurice_lyles@boxer.senate.gov; michael davies; Kit Fox;
jeanne lacomb; norma fassler-katz; jim.clark@lacity.org; jcynthiaperry@aol.com; dan tillema
(chemical safety board); don.holmstrom@csb.gov; blumenfeld.jared@epa.gov;
The.Secretary@hq.doe.gov; sally magnani; jennifer.lucchesi@slc.ca.gov;
Beth.Rosenberg@csb.gov; Raphael.Moure-Eraso@csb.gov; Mark.Griffon@csb.gov
mrenvirlaw@sbc.global.net; noel weiss; Bonnie Christensen; richard.vladovic@lausd.net;
cynthia gonyea; Diana Nave; lljonesin33@yahoo.com; pmwarren@cox.net;
richard.havenick@cox.net; john miller; Kathleen Woodfield; Guillermo Villagran;
peter.burmeister@sbcglobal.net; david rivera; Carl Southwell; lawrence pryor; Jody James;
June Smith; marcie miller
Fwd: Letter to email to legislators ....
spphuranchobeareferraljuly2013sig.doc
We are currently in possession of de-classified documents from the Nixon administration that reveal the
emphasis placed on the introduction of the Petrolane/Amerigas/Rancho Liquid Petroleum Gas facility. These
documents help to explain why the facility was allowed to escape a proper review process and receive
exemptions making its installation possible in the early 70's. The existence of this facility and the elevated
threat that it represents is unacceptible to the public and to the safety of the Ports of LA & Long Beach. This
attached letter was written prior to receipt of these documents. Obviously, it is a very reasonable request. We
urge all government officials copied on this letter to use their influence to address this crucial issue.
Thank you.
1
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San Pedro Peninsula Homeowners United, Inc.
July 21, 2013
Ron Conrow
Western District Manager
Plains LPG Service, LP
19430 Beech Ave.
Shafter, CA 93263
Post Office Box 6455, San Pedro, CA 90734
Email: sphomeunited@gmail.com -Fax (310) 548-4255
RE: REQUEST THAT RANCHO LPG/PLAINS ALL AMERICAN PIPELINE EMPLOY THE
EXPERT ADVICE OF PROFESSOR BOB BEA IN DEVELOPING A PROBABALISTIC RISK
ASSESSMENT AND MANAGEMENT PROCESSES ON RANCHO LPG FACILITY, SAN PEDRO
Dear Mr. Armstrong:
Your company and its subsidiary, Rancho LPG LLC, have been adamant in your consistent position that
Rancho LPG poses no real threat to the safety of the adjacent residents and Ports of LA and Long Beach.
Professor Bob Bea, at UC Berkeley, is recognized as the pre-eminent authority on risk in the USA.
Therefore, it would seem a prudent, wise and cost effective decision by Plains All American Pipeline to
engage in a "comprehensive risk analysis" and "probabilistic risk assessment" utilizing a team of
qualified professionals while engaging Professor Bea in an advisory capacity. Given the authoritative
credentials of Professor Bea, his participation in establishing your facility's safety would go a long way
to assure the public and allow the business of Rancho to move forward unimpeded by nervous
homeowners and citizens of other local municipalities.
While Professor Bea has reviewed some details of your LPG operation, we would encourage your
company to solicit his recommendation of analysis so that all details of the operation can be more fully
examined and your claims of Rancho LPG's safety proven.
The federal Chemical Safety Commission and Senator Barbara Boxer have recognized the flagrant
deficiencies in refinery and chemical storage operations that have led up to the devastating events of San
Bruno, Richmond, West, Texas, and Louisiana. Your own Plains Mid-Stream Canada pipeline spill in
2011 in Alberta (one of the worst spills on record) has added significantly to the existing trepidation of
your operation.
5-276
Great effort is now being focused on what can and should be done to "prevent" these catastrophes that
have been and "are" entirely preventable. US Chemical Safety Commissioner Moure-Eraso said in a
recent statement, " Not only are more preventive inspections by highly competent inspectors needed, but
more rigorous major accident prevention requirements are necessary as well."
Engaging in this comprehensive risk analysis with Professor Bea's assistance would certainly help the
neighbors in and around Rancho LPG, who have long feared for their safety, develop the sense that your
company is not ambivalent to their very real concerns. This Study would be a gesture of great
importance that could underscore a commitment by your company to the safety of the general public.
We sincerely hope that you will follow through with this recommendation and contact Professor Bea
soon in the best interest of all involved parties.
Respectfully, .
Chuck Hart
President
5-277
Notice of FPEIR for Port Master Plan Update
5-278
IA
THE PORT
OF LOI ANGILll 425 S. Palos Verdes street Poat Office Box 151 San Pedro, CA 90733-0161 TEUTDD 310 SEA-PORT www.portolloaangeles.org
Antonio R. Vlllaralgosa ! Mayor. City of Los Angs/es
Board of Halbor 'I; Cindy Mllclkowlkl David Allan
Commlnloners President Vice President
Geraldine Knalz, Ph.D. Executive D/r80tor
Robin M. Kramer Douglas P. Krause SUng Won Sohn, Ph.D.
July 24, 2013
SUBJECT: TRANSMITTAL OF THE FINAL PROGRAM ENVIRONMENTAL IMPACT
REPORT FOR THE PORT OF LOS ANGELES MASTER PLAN UPDATE (SCH
NO. 2012071081)
The City of Los Angeles Harbor Department (LAHD) has released the Final Program
Environmental Impact Report (PEIR) for the following project in the Port of Los Angeles (Port):
Port of Los Angeles Master Plan Update
The Final PEIR includes responses to comments on the Draft PElR, as well as changes made
to the document. The Board of Harbor Commissioners (Board) is scheduled to consider
certification of the Final PEIR at 8:30 am on August 8, 2013 at the Port of Los Angeles,
Administration Building, Board Hearing Room located at 425 South Palos Verdes Street, in
San Pedro. In accordance with California Public Resources Code Section 21092.5, written
responses to comments received by public agencies have been provided to those agencies at
least 1 O days prior to the Board's consideration of whether to certify t!ie Final PEI R.
A copy of the Final PEIR is attached or available for review at: Los Angeles Public Library,
Central Branch, 630 W. 5th Street, Los Angeles, California 90071; Los Angeles Public Library,
San Pedro Branch, 931 South Gaffey Street, San Pedro, Califomia-90731; Los Angeles Public
Library, Wilmington Branch, 1300 North Avalon, Wilmington, California 90744; and the LAHD
Environmental Management Division, 222 W. 6th Street, San Pedro, California 90731. The
Final PEIR is also available on the Port website: http://www.portoflosangeles.org.
For additional information, please· contact James Bahng, CEQA Project Manager at (31 O) 732·
3675.
CHRISTOPHER CANNON
Director of Environmental Management
CC:JB:yo
ADP No.: 110518-060
5-279
Excerpts from FPEIR and Port Master Plan Update:
Introduction
5-280
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1.1
1.2
INTRODUCTION
Final Program EIR Organization
A Draft Program Environmental Impact Report (PEIR) was prepared and circulated
for public comment to evaluate environmental impacts related to the Port of Los
Angeles (Port) Master Plan Update (PMPU or proposed Program). The Draft PEIR
analyzed potential environmental impacts from a Port-wide perspective that is
programmatic in nature. Project-specific analysis would be undertaken in
environmental documents prepared when the proposed appealable/fill projects are
initiated and carried forward for environmental review.
The PMPU serves as a long-range plan to establish policies and guidelines for future
development at the Port, located in San Pedro Bay approximately 20 miles south of
downtown Los Angeles. The PMPU focuses on the portion of the Port that is within
the coastal zone (i.e., the Port's coastal zone boundary), as required under the
California Coastal Act (CCA). In general, the PMPU area is bounded by the
community of Wilmington to the north, lands surrounding the Consolidated Slip to
the northeast, the City of Los Angeles boundary and lands surrounding the Cerritos
Channel to the east, the Pacific Ocean to the south, and the community of San Pedro
to the west.
This chapter presents background and introductory information for the proposed
Program. The proposed Program is described in detail along with a brief summary of
general changes and modifications made to the Draft PEIR. Chapter 2.0, Response to
Comments, presents information regarding the distribution of and comments on the
Draft PEIR, and responses to those comments. Chapter 3.0, Modifications to the
Draft Program Environmental Impact Report (EIR), presents the modifications to the
Draft PEIR. This Final PEIR has been prepared in accordance with the requirements
of the California Environmental Quality Act (CEQA) (Public Resource Code [PRC]
Section 21000 et seq.) and State CEQA Guidelines (California Code of Regulations
[CCR] Title 14, Section 15000 et seq.). The Los Angeles Harbor Department
(LARD) is the lead agency.
CEQA Review Process
Preparation of the PEIR began in July 2012 with the publication of the Notice of
Preparation (NOP) and will conclude with the consideration of the City of Los
Angeles Board of Harbor Commissioners (Board) to certify the Final PEIR, which is
W™~Mi~ !t!@lilMl~ilMl!M1Ml!tml!llirtWllMilml!lli1l!!!lttRfll!illlfl!lll1i!llll!illl?'t~~-%3 ml!ll!l!illlJl!illlJk~~
Port of Los Angeles Master Plan Update 1-1
Final Program Environmental Impact Report
5-281
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1.2.1
1.2.2
1.2.3
1.0 Introduction
anticipated to occur in July 2013. The following describes the environmental review
process that LARD has undertaken for the proposed Program.
Notice of Preparation and Scoping Process
On July 26, 2012, the LARD issued a NOP and Initial Study (IS) to inform
responsible and trustee agencies, public agencies, and the public that the LARD was
preparing a PEIR. for the proposed Program, pursuant to CEQA. The NOP/IS (State
Clearinghouse Number 2012071081) was circulated for a 30-day comment period
from July 26, 2012 to August 24, 2012, to neighboring jurisdictions, responsible
agencies, other public agencies, and interested individuals in order to solicit input on
the scope of the environmental analysis to be included in the PEIR. The LARD held
a public scoping meeting on August 14, 2012. A total of two individuals commented
at the meeting, and twenty comment letters were received during the public comment
period. Table 1.6-1 in Draft PEIR. Section 1.6, Scope and Content of the Draft
Program EIR., presents a summary of the key comments received during the NOP/IS
public comment period. The NOP/IS and public comment letters received are
included in Appendix B of the Draft PEIR..
Draft Program EIR and Public Review
The Draft PEIR. was released for public review on February 21, 2013 for a 45-day
public review period, which ended on April 8, 2013. Copies of the Draft PEIR. were
distributed to various government agencies, organizations, individuals, and Port
tenants. The Draft PEIR. was also available for public review on the LARD website
and at the LARD Environmental Management Division, Los Angeles Public Library
Central Branch, Los Angeles Public Library San Pedro Branch, and Los Angeles
Public Library Wilmington Branch.
LARD conducted a public hearing regarding the Draft PEIR. on March 13, 2013 to
provide an overview of the proposed Program and alternatives and accept public
comments on the Draft PEIR. A total of 8 individuals commented at the meeting and
3 comment cards were received during the public hearing. LARD received a total of
28 comment letters during the public comment period.
Final Program EIR and Certification
This Final PEIR. has been provided to the public for review, comment, and
participation in the planning process. This Final PEIR. is being distributed to provide
the basis for decision making by the lead agency. Should the Board decide to approve
the proposed Program, it will adopt Findings of Fact to support a decision on the
PMPU (PRC Section 21081 and CEQA Guidelines Section 15091). Additionally,
because the PEIR. identified significant and unavoidable impacts, the Board will
consider a Statement of Overriding Considerations, which finds that specific
overriding economic, legal, social, technological, or other benefits of the proposed
Program outweigh the unavoidable adverse environmental effects (PRC
Section 21081[b]; 14 CCR15093). Since the PEIR. identified mitigation measures to
reduce certain environmental impacts, the Board must also adopt a mitigation
monitoring and reporting program (MMRP).
!illill!lll!illill!lll!illill!lll!illill!lll&llll~iMllllti!£illlllMlllld!illill!lll!illill!lll11ilil!iiii!illill!lll!illill!lll!illill!lll!illill!lll!illill!lllllllP@llll9WJq&.llllbkllll&a.!illill!lllWllllJ~Wllll&,lt@lllJ&ll!li~-~OOIHWtwt t ®~i!H!l
Port of Los Angeles Master Plan Update
ll!li!!!!!i!l~'i
1-2
Final Program Environmental Impact Report
5-282
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1.3
1.3.1
1.3.2
I. 0 Introduction
Existing Environmental Setting
Regional Setting
The Port is located at the southernmost end of the City of Los Angeles and comprises
43 miles of waterfront and 7,500 acres ofland and water, with approximately
300 commercial berths. The Port is approximately 23 miles south of downtown
Los Angeles and is surrounded by the community of San Pedro to the west, the
Wilmington community to the north, the Port of Long Beach to the east, and the
Pacific Ocean to the south (Figure 1.3-1).
The Port is an area of mixed uses that support various maritime-related activities.
Port operations are predominantly centered on cargo shipping activities, including
containerized, break bulk, dry bulk, liquid bulk, auto, and intermodal rail shipping; in
2011 the Port was the nation's largest seaport approximately 3,950 recreational
vessels, 150 commercial fishing boats, 35 miscellaneous small service craft, and
15 charter vessels that handle sport fishing and harbor cruises. The Port has retail
shops and restaurants, primarily along the west side of the Main Channel. It also has
recreation, community, and educational facilities, such as a public swimming beach,
Cabrillo Beach Youth Waterfront Sports Center, the Cabrillo Marine Aquarium, the
Los Angeles Maritime Museum, 22nd Street Park, and the Wilmington Waterfront
Park, by cargo volume. In addition to the large shipping industry at the Port, there is a
cruise ship industry and a commercial fishing fleet. The Port also accommodates boat
repair yards and provides slips for slips for approximately 3,950 recreational vessels,
150 commercial fishing boats, 35 miscellaneous small service craft, and 15 charter
vessels that handle sport fishing and harbor cruises. The Port has retail shops and
restaurants, primarily along the west side of the Main Channel. It also has recreation,
community, and educational facilities, such as a public swimming beach, Cabrillo
Beach Youth Waterfront Sports Center, the Cabrillo Marine Aquarium, the Los
Angeles Maritime Museum, 22nd Street Park, and the Wilmington Waterfront Park.
Program Setting
The PMPU area includes the entire Port boundary that lies within the coastal zone
(i.e., the Port's coastal zone boundary). In general, the PMPU area is bounded by the
community of Wilmington to the north, lands surrounding the Consolidated Slip to
the northeast, the City of Los Angeles boundary and lands surrounding the Cerritos
Channel to the east, Los Angeles Harbor to the south, and the community of San
Pedro to the west (Figure 1.3-1).
The existing Port Master Plan (PMP) divides the Port into nine planning areas
(Figure 1.3-2), as described in Sections 1.3.2.1-1.3.2.9, and allows a variety ofland
uses within each planning area (Tables 1.3-1 and 1.3-2).
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Figure l.3-1. Regional Location
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J<"igare l.3~2. Existing PMP Planning Areas
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Planning Areas
Coastal Zone t
Boundary 9{,
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Table 1.3-1. Existing PMP Planning Areas and Allowable Land Uses
Planning Area Land Uses Allowed
1 Recreation, Industrial (light), Liquid Bulk, General Cargo, Other
2 General Cargo, Liquid Bulk, Dry Bulk, Commercial Fishing, Commercial, Recreation,
Institutional, Industrial, Other
3 General Cargo, Liquid Bulk, Commercial, Institutional, Industrial, Other
4 General Cargo, Liquid Bulk, Industrial, Other
5 General Cargo, Liquid Bulk, Other Liquid Bulk, Dry Bulk, Commercial Fishing, Commercial*,
Recreational*, Institutional, Industrial, Other
6 Recreation, Liouid Bulk, Other
7 General Cargo, Liquid Bulk, Dry Bulk, Commercial Fishing, Institutional, Industrial, Other
8 General Cargo*, Drv Bulk*, Commercial Fishing, Recreation, Industrial, Liquid Bulk, Other
9 General Cargo, Liquid Bulk*, Dry Bulk, Commercial Fishing*, Institutional, Industrial, Other
Note: *Indicates allowed land uses based on PMP Amendments.
Table 1.3-2. Existing PMP Land Use Definitions
General Cargo
Liquid Bulk
Other Liquid
Bulk
Dry Bulk
Commercial
Fishing
Recreational
Industrial
Institutional
Commercial
Other
1.3.2.1
1.3.2.2
Generally including container, unit, break bulk, neo bulk, and passenger facilities.
Comnrising crude oil, petroleum products, petrochemical products, chemicals, and allied products.
Comprising molasses, animal oils, and fats and vegetable oils.
Comprising metallic ores, some nonmetallic minerals, coal, chemicals, and allied products,
primarily metal products, waste and scrap materials, and grains.
Generally relating to the commercial fishing industry, including commercial fishing docks, fish
canneries, fish waste treatment facilities, fish markets, and commercial fishing berthing areas.
Uses include water-oriented parks, marinas, and related facilities, small craft launching ramps,
museums, youth camping and water-oriented facilities, public beaches, public fishing piers, and
sports fishing.
Uses include shipbuilding/yard/repair facilities, light manufacturing/industrial activities, and
ocean resource-oriented industries.
Uses pertain to those lands that are either owned or leased by institutions of federal, state, or
city governments.
Uses include restaurants, tourist attractions, Ports O'Call office facilities, and retail activities.
Uses include some vacant land, proposed acquisitions; rights of way for rail, utilities, and
roads; and areas not designated for a specific short-term use.
Planning Area 1 (West Channel/Cabrillo Beach)
Planning Area 1 (West Channel/Cabrillo Beach) is located in the southwestern
portion of the Port and encompasses approximately 110 acres. This area is generally
designated for marine-oriented recreation activities. Existing land uses within
Planning Area 1 include recreation, open space, commercial, institutional, and vacant
lands (Figure 1.3-3).
Planning Area 2 (West Bank)
Planning Area 2 (West Bank) is located west of the Los Angeles Harbor Main
Channel and south of Fourth Street. This area encompasses approximately 218 acres
and contains a variety of land uses including liquid bulk, break bulk, commercial
fishing, commercial, recreational, institutional, and vacant lands (Figure 1.3-3).
Pfiilllllifiilll!lilili!liiiiiiiiiiiiiii!iilll!li&k&k' &k&k@k@k@k@k~-'!iilll!li&k&k&k&k~--lili!IM!iilll!li&k&ki Hlili!l-lili!l!iilll!li&k&klili!l@lili!l@Jlili!llili!l!iilll!li!iilll!li&k&klili!l~&k&klili!l~IWlili!l~lllllllliH~ll!lll!!M!llllmll.fil((f~Mllllilliffi Mllillillifilili!IMli!Wo mmm~
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li'igure 1.3-3. Existing Land Uses (2011)
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General Cargo (Container)
Liquid Bulk
Dry Bulk
Commercial Fishing
Recreational (Marina)
Industrial
Institutional
Commercial
General Cargo (Break Bulk)
1.0 Introduction
0
Recreation (Open Space)
Commercial (Passenger Supporting)
Other
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1.3.2.3
1.3.2.4
1.3.2.5
1.3.2.6
1.3.2.7
1.3.2.8
1.0 Introduction
Planning Area 3 (West Turning Basin)
Planning Area 3 (West Turning Basin) encompasses approximately 213 acres and
extends from Berth 87 on the south to Berth 115 on the north. Existing land uses
within this area include container cargo, liquid bulk, commercial, maritime support,
institutional, open space, passenger, and vacant lands (Figure 1.3-3).
Planning Area 4 (West Basin)
Planning Area 4 (West Basin) encompasses 224 acres and is located between the
Harbor Freeway and the West Basin area of the Inner Harbor. Existing land uses
include container cargo, liquid bulk, break bulk, dry bulk, institutional, maritime
support, and vacant lands (Figure 1.3-3).
Planning Area 5 (Wilmington District)
Planning Area 5 (Wilmington District) comprises approximately 622 acres
encompassing the northern terminus of the Main Channel and includes areas adjacent
to the community of Wilmington and the Consolidated Slip. Existing land uses
include break bulk, dry bulk, liquid bulk, institutional, recreationai, and vacant lands
(Figure 1.3-3).
Planning Area 6 (Cerritos Channel)
Planning Area 6 (Cerritos Channel) is located in the northeastern portion of the Port
between the East Basin and Cerritos Channel. This area encompasses approximately
59 acres and includes nine separate marinas and supporting facilities (e.g., boat repair
and maintenance, administrative offices, marine supplies, and recreational areas).
Existing land uses include recreational and open space (Figure 1.3-3).
Planning Area 7 (Terminal Island/Main Channel)
Planning Area 7 (Terminal Island/Main Channel) encompasses approximately
743 acres extending from Berth 206 to Reservation Point and is adjacent to the East
Basin Channel, Turning Basin, and Main Channel. Fish Harbor and southern
Terminal Island are situated on the southeastern boundary of this area. Existing land
uses include container cargo, liquid bulk, dry bulk, institutional, and vacant lands
(Figure 1.3-3).
Planning Area 8 (Fish Harbor)
Planning Area 8 (Fish Harbor) encompasses approximately 134 acres and is located
in the southern portion of Terminal Island. Existing land uses include commercial
fishing, container cargo, break bulk, commercial, liquid bulk, maritime support,
institutional, and vacant lands (Figure 1.3-3).
!li!l!ll$llliillill!QiiQiiilllll1M¥illlll!li!l@®i iiAiiiilllll!li!IQiiQiilllll!li!IAAIA!!A•illlll•Ai!iiQiMIQIQii@ilib.Qi@iiAiiiilllll!li!l*4iQ:D£@@iiQi@iiQildQiil~iAilW$!!Ail illlll!li!IAiiAilQiiQi%iiQM\ilMilllllQim@ii®QiiiAiil~!i!jQii~~-'t@i~i!Q!lll illlll!li!IQiiQitlW!lliilMQiimMilllll!li!l'illlllAiilllll!li!lma•••~Aii-
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1.3.2.9
1.4
1.4.1
1.4.2
1.5
i*i#fo#kiml WP%
Planning Area 9 (Terminal Island/Seaward
Extension)
1.0 Introduction
Planning Area 9 (Terminal Island/Seaward Extension) is generally located on the
southern portion of Terminal Island and adjacent to the Outer Harbor. This area
encompasses approximately 1, 170 acres and supports container cargo, liquid bulk,
institutional, open space, and vacant lands (Figure 1.3-3).
Program Purpose and Objectives
Program Purpose
The overall purpose of the PMPU is to create a consolidated planning document that
clarifies LAHD's short-and long-term land-use plans in an easily accessible manner.
The PMPU is needed to update historically outdated language in the 1980 PMP, as
amended, with policies and guidelines that reflect current community and
environmental conditions and account for trends in foreign and domestic waterborne
commerce, navigation, and fisheries.
Program Objectives
The overall objectives of the PMPU are to:
• Develop the Port in a manner that is consistent with federal, state, county, and
city laws, including the CCA and Charter of the City of Los Angeles;
• Integrate economic, engineering, environmental, and safety considerations into
the Port development process for measuring the long-term impact of varying
development options on the Port's natural and economic environment;
• Promote the orderly, long-term development and growth of the Port by
establishing functional areas for Port facilities and operations; and,
• Allow the Port to adapt to changing technology, cargo trends, regulations, and
competition from other United States (U.S.) and foreign ports.
Proposed Program
The PMPU addresses all elements required under CCA Chapter 8, Article 3
(Section 30711 [a] and [b ]), including permitted uses, design and location of land use
areas, estimates of development effects on environmental resources, and anticipated
projects listed as appealable.
The PEIR includes the following elements in the program description:
• Changes to the number and boundaries of existing planning areas;
• Changes to existing PMP land use categories;
• Revisions to allowable land uses within the planning areas;
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1.5.1
1.0 Introduction
• Descriptions of proposed appealable/fill projects; and,
• A list of the other projects that have been approved in a certified CEQA
document and/or are undefined (i.e., in the conceptual design stage) that are
identified for public disclosure purposes consistent with the PMPU.
Changes to Existing Planning Areas
The PMPU would result in three principal changes to the existing planning areas:
• Consolidate the number of land uses within the planning areas and specify a
single land use for most sites;
• Reduce the number of planning areas from nine to five; and,
• Modify the boundaries of the individual planning areas.
The reduction in the number of planning areas is intended to consolidate general
areas with predominant land use patterns within the Port. These changes are largely
administrative and would cause no impacts to the physical environment. The
locations, acreages, and allowable land uses for the proposed planning areas are
described in Table 1.5-1, and the boundaries and land use designations for each
planning area are shown in Figures 1.5-1 and 1.5-2.
Table 1.5-1. Proposed PMPU Planning Areas and Allowable Land Uses
Planning Area Location Acreage Allowable Land Uses*
1 (San Pedro) From the Breakwater up to the 413 Recreational Boating, Commercial, Break
Vincent Thomas Bridge Bulk, Open Space, Institutional, Cruise
Operations, and Maritime Support
2 (West Basin From the Vincent Thomas Bridge 1,098 Container, Open Space, Liquid Bulk, Break
and Wilmington) to north of the Cerritos Channel Bulk, Dry Bulk, Maritime Support,
Recreational Boating, and Commercial
3 (Terminal Terminal Island, excluding Fish 1,940 Container, Liquid Bulk, Dry Bulk, Maritime
Island) Harbor Support, Open Space
4 (Fish Harbor) Fish Harbor, including former 92 Commercial Fishing, Maritime Support, Break
Southwest Marine Shipyard site Bulk, and Institutional
5 (Water) All water excluding areas 3,209 Navigable Waterways, Maneuvering Areas,
adjacent to marinas Anchorage Areas, and Shallow Water Habitat
Note: *Proposed land uses would be confined to the specific sites identified on the PMPU Land Use Designations Map (Figure 1.5-2).
1.5.2 PMPU Land Use Categories
The PMPU land use plan would consolidate the number ofland uses within the
planning areas and would specify a single land use for most sites. For much of the
PMPU area, the revised land use categories would be compatible with or less
intensive than existing land uses, potentially resulting in fewer impacts to the
physical environment than under existing condition conditions. The proposed
changes to land use categories are listed in Table 1.5-2.
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Figure 1.5-l. Proposed PMPU Pfanning Areas
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1.0 Introduction
Planning Areas
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Boundary
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Figure 1.5-2. Proposed Pl\fi>U Land Use Designations
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Container
Liquid Bulk
Ory Bulk
Commercial Fishing
Recreational Boating
Maritime Support
Institutional
Visitor Sevlng Commercial
Break Bulk
Open Space
Cruise Operations
1. 0 Introduction
Liquid Bulk Option
Liquid Bulk Option
Mixed Use
Mixed Use
Mixed Use
Mixed Use
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Table 1.5-2. Changes in Land Use Categories
Existing PMP
Land Use Categories
General Cargo
Liquid Bulk
Other Liquid Bulk
Dry Bulk
Commercial Fishing
Recreational
Industrial
Institutional
Commercial
Other
Proposed PMPU Comments Land Use Categories
Container The General Cargo land use category is divided into three
Break Bulk categories to provide more specificity.
Cruise Operations
Liquid Bulk Liquid Bulk and Other Liquid Bulk (nonhazardous) are
consolidated into one category.
Dry Bulk No change.
Commercial Fishing No change.
Recreational Boating This category is divided to differentiate marinas from parks/beaches
Open Space due to their different land use and water requirements.
Maritime Support This category is renamed to provide more clarity to the land use
description.
Institutional No change.
Visitor Serving This category is renamed to provide more clarity to the land use
Commercial description.
Not Applicable (N/A) This land use category is no longer needed.
The proposed PMPU land and water use definitions are provided in Table 1.5-3; the
examples of these uses are not comprehensive, but are only meant to be illustrative of
the types of activities that may occur in the various land and water use categories.
Table 1.5-3. Proposed PMPU Land and Water Use Definitions
Land Use Description Examples
,' ::· '.:: .J .. ~ .. L.andT;/s?, ;". ', ,' : :
'• '' ::
Container Water-dependent uses focused on container • Container Terminal
cargo handling and movement. • Chassis Storage
• On-Dock Rail Yard
• Omni Terminal
Dry Bulk Water-dependent uses focused on non-• Cement
containerized, dry bulk cargoes shipped in • Potash and similar
large, unpackaged amounts. • Grain;
• Scrap Metal
Break Bulk Water-dependent uses focused on non-• Roll-On Roll-Off Cargoes
containerized, bulk cargoes packaged as a • Steel Slabs
unit. • Neo Bulk
• Fruit
• Automobiles
Cruise Operations Water-dependent operations focused on • Cruise Facilities
cruise operations and passenger handling. • Baggage Handling Facilities
Liquid Bulk Water-dependent uses focused on storage, • Crude Oil Terminal
receipt, and delivery of liquid bulk • Petroleum Products Terminal
commodities. • Non-petroleum Products and Other
Liquid Bulk Commodities
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Table 1.5-3. Proposed PMPU Land and Water Use Definitions
Land Use Description Examples
Maritime Support Water-dependent and non water-dependent • Barge/Tugboat
operations necessary to support cargo • Boatyard and Ship Repair
handling and other maritime activities. • Marine Fueling Station
• Marine Service Contractors,
(e.g., diving, and emergency response
services)
• Water Taxi
• Cargo Fumigation
Commercial Facilities related to commercial fishing and • Fish Processing
Fishing processing. • Cold Storage/Fish Unloading/Ice House
• Fishing Vessel Moorage
• Fish Laboratories and Testing
Recreational Recreational boating activities generally • Marinas
Boating associated with marinas. • Upland Boat Storage
• Yacht Clubs
• Marina-Related Retail
Visitor-Serving Visitor serving commercial uses for the • Restaurant
Commercial public, including museums. • Maritime Related Office
• Visitor Serving Retail
• Harbor Tour Vessels
• Sport Fishing
• Museums
• Community Centers/Conference
Centers
• Exhibit Space
Open Space Open spaces reserved for the general public • Public Beaches
such as parks and beaches or open areas • Parks
reserved for environmental protection. • Environmentally Protected Area
• Wetlands
Institutional Uses and facilities operated by government • Public Safety (Police and Fire)
agencies. • Other federal, state, and local agencies
• Educational
• Marine Research Facility
• Non-profit Organizations
•
',', .... '
:,: WatefUs~. ·,: :
:
Navigation Water areas devoted to anchorage of vessels, • Main Channel
movement and maneuvering of vessels. • East and West Turning Basin
Environmental Water areas dedicated to environmental • Shallow Water Habitat
Mitigation protection and not suitable for the
navigation of cargo moving vessels.
Recreational Water areas associated with the mooring of • Marina Slip Areas
Boating recreational vessels.
Berthing Water areas directly adjacent to cargo • Cargo Berths
berths. These areas are dedicated to the
berthing of cargo vessels.
Note: *In addition to the specific land use definitions and scope of activities, uses directly related to and supporting the land use are also
permitted activities. Examples include but are not limited to an administrative office and/or maintenance and repair facility that support a
container tenninal or administrative offices and/or quality control laboratory that support commercial fishing processing activities.
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Figure l.S-3. Proposed PMPU Land Use Changes
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I. 0 Introduction
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}'igure 1.5-4. Proposed PM.PU Appealable/Ji'ill Projects
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1.0 Introduction
Berths 187 -189 Liquid Bulk Relocation
Yang Ming Terminal Redevelopment
China Shipping Fill
Berth 300 Development
Tri Marine Expansion
338 Cannery Street Adaptive Reuse
Al Larson Marina
Planning Area Boundary A
"""""""' Coastal Zone Boundary ,~
!!Y..
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Table 1.5-4. Proposed PMPU Appealable/Fill Projects and Land Use Changes
Planninf! Area Avvealable!Fill Projecta,o Land Use Chanf!e 0
PlanninJZ;A,r,(!!a 1
Planning None 1: (Mixed Land Use Site): Existing institutional uses at Warehouse No. 1
Area 1: San would remain and/or be changed to visitor-serving commercial.
Pedro . .: .. ·:
·.· ·····
. ... Pti.tnnin"s! A:rea.2 .....• ....
Planning Berths 187-189 Liquid 2: The liquid bulk terminal at Berths 187-189 (Vopak) would be relocated
Area 2: West Bulk Relocation to Berths 191-194. Berths 187-189 would consist of open space and
Basin and institutional land uses.
Wilmington Yang Ming Terminal 3: An additional 6 acres of fill at Berths 120-121 and cut of3 acres ofland
Redevelopment, including at Berths 121-127 for the Yang Ming Terminal would be designated as
Cut and Fill (3-acre cut; container area.
6-acre fill) 4: The liquid bulk facility at Berths 118-120 (Kinder Morgan) would be
eliminated and replaced with container cargo uses.
China Shipping Fill 5: An additional 16 acres of fill would be added at Berth 102 for the China
' 16-acre fill) Shinning container terminal and designated for container cargo uses.
None 6: (Optional Land Use Site): Vacant land on Mormon Island between San
Clemente Avenue and Hermosa Street would be changed to liquid bulk or
break bulk.
.· •: •>) Plq'flfiifiJ!fArfi!a 3 • ••••••• :
Planning Berth 300 Development 7: An additional 18 acres of fill would be added at Pier 300 and designated
Area3: '18-acre fill) for container cargo uses.
Terminal Island None 8: (Mixed Land Use Sites): Vacant land at Berths 206-209 would be
changed to container, break bulk, and/or dry bulk and dry bulk land at
Berths 210-211 would be changed to dry bulk and/or container.
9: Vacant land between Seaside Avenue and Reeves Avenue and south of
Reeves Avenue would be changed to maritime sunnort.
10: Vacant land along Ferrv Street would be changed to maritime sunnort.
11: The land use consisting of the existing liquid bulk area (ExxonMobil)
north of the Terminal Island Water Reclamation Plant (TIWRP) would be
reolaced with container cargo uses.
12u: The institutional area south of Pier 400 would be changed to open
space (least tern habitat).
13: Existing container area on Pier 400 would be changed to maritime
sunnort.
14: Vacant land, commercial fishing, and industrial areas near Fish Harbor
Mrould be changed to container cargo uses.
15: (Optional Land Use Site): Existing maritime support uses at Berth 301
would be changed to container or liquid bulk .
... < ·• . . · .•. • .. · · Pl«ni#liil4f:ed.4 : >•/' ·.t ">••" ,(/ ': .. ,:
Planning Tri Marine Expansion None
Area 4: Fish 338 Cannery Street None
!Harbor Adantive Reuse
Al Larson Marina 16: Land use change from recreational boating to maritime support.
None 17: (Mixed Land Use Site): Vacant land at Southwest Marine Shipyard
would be changed to break bulk and/or maritime support. The surrounding
area would be changed to maritime sunnort.
18: Vacant land, commercial fiShing, liquid bulk, and institutional land uses
at Fish Harbor would be replaced with commercial fishing and maritime
sunnort.
PlanninflArea s·
Planning rone rone
Area 5: Water
Notes:
a. These projects are appealable to the CCC, as defined under CCA Section 30715. Refer to Section 1.5.3, Changes to Land Uses and Proposed
Appealable/Fill Projects within the PMPU Planning Areas, for additional details.
b. Proposed fill projects would be consistent with the PMPU, once certified, and would not require an amendment. Appealable/fill projects that
would have fill or cut and fill are bolded.
c. Refer to Figure 1.5-3 (Proposed PMPU Land Use Changes) for the specific locations of the proposed land use changes. The numbers included in
this column correspond to the number of the land use change depicted in Figure 1.5-3.
d. This land use change is administrative because it only changes the definition of the land use; no impacts to the physical environment would
occur. Therefore, this land use change is not carried forward for analysis in the PEIR.
!fill!IWll\Willll\Willll\Wil!Th~@mmmm~ro•"f"i%l~n:mm1m1~Hll\Willll\WillmlllN•n••~MM•~~--~¥~~~HU£@UDf1!1l~millll\W!llN•llBIB!fill!IW"A!m~hmWIB~'.!!NN!rn1R~~Nm•tw.m1*~~11\Wi11W.NN!W.NmkNN!~•~~NN~
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Table 1.5-5. Other PMPU Projects and Land Use Changes8
Planning Area Other Projects Appealabli Land Use Changes Comments
I<:: ..... ·. :· .'·;.'' ,· . f?tcifmtrig.:.At~rn· .. . .....
Planning Outer Harbor No Vacant land would be changed This project was previously
Area 1: San Cruise Terminal to cruise operations and open evaluated in the certified San
Pedro and Outer Harbor space. Pedro Waterfront Project
Park Environmental Impact Statement
(EIS)/EIR.
City Dock No. 1 No The break bulk area east of East This project was previously
Marine Research Channel (Berths 57-71) would evaluated in the certified City
Project be changed to institutional. Dock No. 1 Marine Research
Project EIR.
Ports O'Call No Industrial uses along Harbor This project was previously
Redevelopment Boulevard would be changed to evaluated in the certified San
commercial. Pedro Waterfront Project EIS/EIR.
Various No A variety of projects occurring These land use changes were
along the San Pedro Waterfront previously evaluated in the
have associated land use certified San Pedro Waterfront
changes which eliminate Project EIS/EIR and the certified
industrial land uses and result in Cabrillo Marina Phase II
increased public access to the Development Project EIR.
waterfront (open spaces),
additional visitor-serving
commercial development within
the Port, and expanded cruise
operations .
:·:••·• <·' ;' .··. . llt~~~tngA,,,ea.2 .>/ .: ... ,, :
.... / . :>
Planning Wilmington No Institutional and industrial areas This project was previously
Area2: West Waterfront near Wilmington (north of evaluated in the certified
Basin and Development Berths 184-185) would be Wilmington Waterfront
Wilmington Project changed to open space. Development Project EIS/EIR.
Anchorage Road No None This is not a proposed project.
Soil Storage Site Specific details are currently not
(ARSSS) Open available.
Space
Berths 176-181 No The Mormon Island container This is not a proposed project.
Break Bulk area (Berths 17 4-181) would be Specific details are currently not
Terminal changed to break bulk. available.
Redevelopment
East Basin Marina Yes Vacant land east of Yacht Haven This is not a proposed project.
Improvements Marina (Berths 201-203) would Specific details are currently not
be changed to recreational available.
boating.
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Table 1.5-5. Other PMPU Projects and Land Use Changes3
Planning Area Other Projects Appealabli Land Use Changes Comments
\. RltJjthing Area 3 .
Planning Pier 500 (200-acre No None This is not a proposed project.
Area3: fill) Specific details are currently not
Terminal available.
Island Trucking Support No None This is not a proposed project.
Center Specific details are currently not
available.
Terminal Island No None This is not a proposed project.
On-Dock Rail Specific details are currently not
Facility available.
Berths 212-224 No None This is not a proposed project.
Container Terminal Specific details are currently not
Expansion available.
Relocation of Yes None This is not a proposed project.
ExxonMobil Specific details are currently not
Storage Tanks available.
··.· ..... :( ... < . · ... .... · l/lltJ11nli-,gll,re,cr~ · . · .. ·• .. ~· ... .:.· . .
··········
.· .· ... ·
Planning Relocation of Yes None This project was previously
Area 4: Fish Jankovich Marine evaluated in the certified San Pedro
Harbor Fueling Station Waterfront Project EIS/BIR.
Notes:
a. The PEIR does not analyze the impacts of other projects included in the PMPU that have already been evaluated in a certified
CEQA document. Furthermore, as some projects included in the PMPU are in the conceptual design stage, sufficient project
details are not available to support a programmatic evaluation of potential impacts. These other projects are listed in the PEIR
for purposes of public disclosure and addressed in Draft PEIR Chapter 4.0, Cumulative Analysis.
b. These projects are appealable to the CCC, as defined under CCA Section 30715. Please refer to Section 1.5.3, Changes to Land
Uses and Proposed Appealable/Fill Projects within the PMPU Planning Areas, for additional .details.
1.5.3.1
1.5.3.1.1
1.5.3.1.2
Planning Area 1: San Pedro
General Overview
Planning Area 1 would encompass the San Pedro Waterfront, extending from the
breakwater to the Vincent Thomas Bridge along the western boundary of the Port
(Figure 1.5-5). This area includes Berths 19-95, the Port's cruise operations,
institutional uses, open space (Cabrillo Beach), and recreational boating activities.
Planning Area 1 includes land uses focused on public access to the waterfront, but also
has limited cargo operations and commercial fishing activities. Planning Area 1
emphasizes waterfront access through a waterfront promenade, parks, museums,
academic uses, and visitor-serving commercial uses and attractions. fu Planning
Area 1, existing institutional uses at Warehouse No. 1 would remain and/or be changed
to visitor-serving commercial. Adaptive reuse of Warehouse No. 1 would occur in
conformance with LAHD's Built Environment Historic, Architectural, and Cultural
Resource Policy.
Appealable/Fill Projects
No appealable/fill projects would occur within Planning Area 1.
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Open Space
Cruise Operations
Maritime Support Mixed Use
Institutional -= Planning Area A
Visitor Serving Commercial "'""""""' Coastal Zone Boundary T
B:eakBulk r
Mile 1.0
Figure l.5-5. Proposed PMPU Planning Area .1 Land Use Designations
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1.5.3.2
1.5.3.2.1
1.5.3.2.2
1.0 Introduction
Planning Area 2: West Basin and Wilmington
General Overview
Planning Area 2 would encompass the West Basin and Wilmington areas, and
includes Berth 96 through Berth 204 (Figure 1.5-6). The West Basin consists of
container terminals, while the remaining Wilmington areas consist of a variety of
uses ranging from liquid bulk at Berths 148-150, liquid bulk and dry bulk uses on
Mormon Island, to recreational boating and open space along Anchorage Road.
Public access to the waterfront is provided at Berths 183-186. The planning
framework for Planning Area 2 addressed in the PMPU is based on the Wilmington
Waterfront Plan, Berths 97-109 (China Shipping) Container Terminal Project,
Berths 136-147 (TraPac) Container Terminal Project, the Anchorage Road Soil
Storage Site Concept Plan, and Wilmington Marinas Plan. Vacant land on Mormon
Island between San Clemente Avenue and Hermosa Street would be an optional use
site and allow liquid or break bulk uses. Additional land use changes are associated
with the proposed appealable/fill projects in Planning Area 2.
Appealable/Fill Projects
Berths 187-189 Liquid Bulk Relocation
This project would relocate existing liquid bulk berthing operations at
Berths 187-189 to Berths 191-194. Tankage located along Berths 187-189 would also
be removed and replaced with new tankage at Berths 191-194. A new Marine Oil
Terminal Engineering and Maintenance Standards (MOTEMS)-compliant wharf and
equipment would be constructed at Berths 191-194. Land uses at Berths 187-189
would change from liquid bulk to open space and institutional.
Yang Ming Terminal Redevelopment
This project would include filling approximately 6 acres of the harbor at
Berths 120-121 and cutting (i.e., creating open water) approximately 3 acres ofland
at Berths 121-127 to facilitate redevelopment of the West Basin Container Terminal.
The proposed cut and fill, combined with wharf redevelopment, would create
approximately 3,400 feet of new wharf. The project would also include a land use
change near Berths 118-120 from liquid bulk to container terminal and would
accommodate an approximately 20-acre backland expansion.
China Shipping Fill
This project would fill approximately 16 acres of a slip at Berth 102 to add additional
backland to the existing China Shipping container terminal.
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Container
Liquid Bulk
Dry Bulk
Recreational Boating
Maritime Support
Institutional
0
.Figure l.5·6. Proposed PMPU Planning Area 2 l.,and Use Designations
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Final Program Environmental Impact Report
1.0 Introduction
Visitor Serving Commercial
Break Bulk !
Open Space T
Liquid Bulk Option 9?{.
~ Planning Area T
-Coastal Zone Boundary ~
Mile LO
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1.5.3.3
1.5.3.3.1
1.5.3.3.2
1.0 Introduction
Planning Area 3: Terminal Island
General Overview
Planning Area 3, located on Terminal Island, would be the largest planning area and
would focus on container operations. The proposed area comprises all of Terminal
Island, with the exception of Fish Harbor, which would be in Planning Area 4
(Figure 1.5-7). Of the six container terminals at the Port, four are located in Planning
Area 3. The Terminal Island Land Use Plan provides the framework for land uses
located in Planning Area 3. The plan optimizes cargo-handling operations on
Terminal Island, while restricting non-cargo and non water-dependent uses.
Open space is located along the southern tip of Pier 400 as an environmentally
protected area for least terns and the urban forest area north of the Los Angeles
Export Terminal (LAXT) rail loop. The proposed appealable/fill projects would
provide additional space for expanding container and liquid bulk cargoes by clearing
underutilized and vacant facilities, reconfiguring existing operations, and completing
approximately 18 acres of land expansion/filling. The following land use changes
would occur within Planning Area 3:
• The land use consisting of the existing ExxonMobil liquid bulk facility north of
the Terminal Island Water Reclamation Plant (TIWRP) would be replaced with
container uses;
• Planning Area 3 includes two mixed use sites that would allow break bulk, dry
bulk, and/or container uses at Berths 206-209 and dry bulk and/or container uses
at Berths 211-212;
• Berth 301 would be an optional use site that would allow conversion of existing
maritime support uses to either container or liquid bulk;
• Vacant land between Seaside Avenue and Reeves Avenue and south of Reeves
A venue would be changed to maritime support;
• Vacant land along Ferry Street would be changed to maritime support;
• Vacant land, commercial fishing, and industrial areas near Fish Harbor would be
changed to container cargo uses; and,
• Existing container area on Pier 400 would be converted to maritime support.
Appealable/Fill Projects
Berth 300 Development
This project would fill approximately 18 acres of water behind Berths 270-271 and
Berth 301 to create additional container backland. This project would include
berthing for maritime support.
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Container
Liquid Bulk
Maritime Support
Institutional
Open Space
Liquid Bulk Option
Mixed Use
Mixed Use
~ Planning Area
.......,... Coastal Zone Boundary
p::::::::::=r::-~····--··-··'F==3
0 Mile LO
Figure 1.5-7, Proposed PMPU Planning Area 3 Land Use Designations
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1.5.3.4
1.5.3.4.1
1.5.3.4.2
1.5.3.5
1.5.3.5.1
1.5.3.5.2
1.0 introduction
Planning Area 4: Fish Harbor
General Overview
Planning Area 4 would contain Fish Harbor and focus on expanding commercial
fishing while maintaining adequate acreages for maritime support uses. Commercial
fishing would remain in the northern and eastern portions of Fish Harbor, while
maritime support, break bulk cargo, and other institutional uses would be located
along the western portion of Fish Harbor (Figure 1.5-8). Vacant land at Southwest
Marine Shipyard (Berths 240-241) would be a mixed land use site and would allow
break bulk and/or maritime support uses. Additional land use changes are associated
with the proposed appealable/fill projects in Planning Area 4. The Terminal Island
Land Use Plan also provides the framework for Planning Area 4.
Appealable/Fill Projects
Tri Marine Expansion
This project would expand Tri Marine's current fish processing facility at Berth 264.
The expanded facility would include fish processing operations, cold storage, and
office space. A new fish pump to transfer fish from the fishing boats to the new
facility would be constructed to complement the existing fish pump at the facility.
338 Cannery Street Adaptive Reuse
This project would redevelop a nine-acre site located in Fish Harbor at Berth 265 by
adaptive reuse of the existing historic buildings for commercial fishing development.
Improvements would complement and maintain existing historic structures, while
helping to create a financially sustainable commercial fishing development.
Al Larson Marina
This project would remove approximately 125 recreational boating slips at
Berths 256-257 to allow for the expansion of the boatyard located directly north of
the marina.
Planning Area 5: Waterways
General Overview
Planning Area 5 would consist of water areas in the Port. Water uses allowed in
Planning Area 5 include general navigation, areas designated for environmental
mitigation, recreational boating, and berthing {Figure 1.5-9). No land use changes
would occur in Planning Area 5.
Appealable/Fill Projects
No appealable/fill projects would occur within Planning Area 5.
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Figure 1.5-8. Proposed PMPU Planning Area 4 Land Use Designations
Port of Los Angeles Master Plan Update
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1.0 Introduction
Commercial Fishing
Maritime Support
Institutional t
Break Bulk
Mixed Use ~ == Planning Area T ·
....._,,. Coastal Zone Boundary ft
Mile 0.25
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Figure l.5-9. Proposed PMPU Planning Area 5 Land Use Designations
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Planning Area f
Coastal Zone Boundary f
i=:;:::::::::::·-~·"-'E==3
0 Mile l.O
No1e: No appealablelfill projects or land use
ctianges are proposed for this planning area.
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1.5.4
1.0 Introduction
Changes in Land Use Acreage
The proposed changes in land use would result in changes to the total acreages
associated with individual land use categories. Table 1.5-6 provides a summary of the
land use changes (acres by land use type) that would occur with implementation of
the PMPU, shown as differences between existing baseline conditions, defined as
those occurring in 2011, and proposed conditions. Section 1.5.3, Changes to Land
Uses and Proposed Appealable/Fill Projects within the PMPU Planning Areas,
provides details regarding land use changes within specific planning areas.
Table 1.5-6. Summary of Proposed PMPU Land Use Changes
Existing Proposed Previously Overall PMPU
Land Use Type (2011) Changes Analyzed Difference Acreage Evaluated in the Changes (acresf PEIR (acres) (acresl (acres) (acres)
Container· 2,050 288 33 321 2,371
Liquid Bulle 119 -17 66 49 168
DrvBulk 45 -30 1 -29 15
Commercial Fishing 20 36 2 38 58
Recreational Marina 66 0 25 25 91
(Recreational Boating)
Industrial (Maritime 45 75 13 88 133
Support)
Institutional 115 -37 15 -22 92
Commercial (Visitor 88 6 15 21 109
Serving/Commercial)
Break Bulle 160 21 38 59 219
Open Space 92 28 110 138 231
Passengers/Supporting 54 0 15 15 69
Commercial (Cruise
Operations)
Vacant 658 -333 -325 -658 0
Open Waterc 3,224 -37 -7 -44 3,180
Totald 6,735 0 0 0 6,735
Notes:
a. All acreages are approximate. Acreages for mixed use and optional land use sites are associated with the "worst case" or
most intensive land use for an individual site, as evaluated in this PEIR.
b. The PEIR does not analyze the impacts of the land use changes included in the PMPU that have already been evaluated in
a certified CEQA document.
c. Acreages do not include the Reservation Point Area (i.e., 64 acres). This is not LAHD controlled property.
d. The total area includes open water acreage and all unassigned acreage in Planning Areas 1-4 and boundary differences.
1.5.5 Program Schedule
Buildout of the proposed appealable/fill projects would occur in multiple phases,
although the precise schedule, and in most cases the scope, of these projects is
unknown or has not been developed in sufficient detail at this time. The LAHD
anticipates, however, that the proposed appealable/fill projects described above
would be implemented within the next 5 years. However, the analysis of the PMPU
planning horizon extends out to year 2035.
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1.5.6
1.6
I.O Introduction
Summary
In summary, the PMPU would consolidate areas characterized by predominant land
use patterns within the Port and allocate a single land use to most sites. The PMPU
would also include appealable/fill projects and other projects that have been approved
in certified CEQA documents and/or are currently undefined (i.e., in the conceptual
design stage). The proposed appealable/fill projects included in the PMPU are in
various planning stages and are expected to be initiated or completed within the next
5 years.
This PEIR focuses on land use changes that would result in changes and/or
intensification of activities with the potential for directly or indirectly impacting the
physical environment (CEQA Guidelines Section 15378(a)). Several changes
proposed in the PMPU are administrative (e.g., changes to existing planning areas
and land use categories/definitions) and would cause no impacts to the physical
environment. For much of the PMPU area, proposed land use categories would be
compatible with or less intensive than existing land uses, potentially resulting in
fewer impacts to the physical environment compared to existing conditions.
This PEIR focuses on the proposed appealable/fill projects, as defined under CCA
Section 30715, and provides a programmatic evaluation of impacts associated with
buildout of these projects. In general, this PEIR is intended to simplify the task of
preparing subsequent environmental documents for the proposed appealable/fill
projects and will serve as the first-tier document for later CEQA review of the
proposed appealable/fill projects included in the PMPU. The LARD expects that
most of the proposed appealable/fill projects that are included in this PEIR would
require separate environmental documents. CDPs for the proposed appealable/fill
projects would not be issued until those project-specific CEQA reviews are
completed.
This PEIR does not analyze the impacts of other projects included in the PMPU that
have already been evaluated in certified CEQA documents. Furthermore, as some
projects included in the PMPU are in the conceptual design stage, sufficient project
details are not available to support a programmatic evaluation of potential impacts.
These other projects are listed in the PEIR for purposes of public disclosure and
addressed in Draft PEIR Chapter 4.0, Cumulative Analysis.
Changes to the Draft Port Master Plan
Update
A summary of the changes made to Draft PMPU is provided below. Revisions to the
Draft PMPU that directly correspond to changes to the Draft PEIR are presented in
Chapter 3.0, Modifications to the Draft Program EIR, of this Final PEIR. The Final
PMPU is included in Appendix A, Port Master Plan, of this Final PEIR.
The key changes to the Draft PMPU include:
• Clarification of the PMPU Goals;
• Inclusion of additional PMPU land use examples;
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1.7
I. 0 Introduction
• Clarification of public access infrastructure and programs at the Port;
• Modification of PMPU land use designations and boundaries;
• Clarification of land use acreages for the PMPU planning areas; and,
• Clarification of an existing and inclusion of an additional other project.
Changes to the Draft Program EIR
The Final PEIR discusses changes and modifications that have been made to the
Draft PEIR. Actual changes to the text, organized by chapters, sections, and
appendices, are presented in Chapter 3.0, Modifications to the Draft Program EIR, of
this Final PEIR.
Changes noted in Chapter 3.0, Modifications to the Draft Program EIR, are identified
by text strikeout and underline. These changes are referenced in Chapter 2.0,
Response to Comnients, of this Final PEIR, where applicable. The changes and
clarifications presented in Chapter 3.0, Modifications to the Draft Program EIR, were
reviewed to determine whether or not they warranted recirculation of the PEIR prior
to certification according to CEQA Guidelines. The changes would not result in any
new significant environmental impacts or a substantial increase in the severity of an
existing environmental effect.
A summary of the key changes to the Draft PEIR include:
• Correction of the PMPU land use designation for Cabrillo Beach from visitor-
serving commercial to open space;
• Inclusion of the boat launch area at Cabrillo Beach into the total acreage
associated with the recreational boating land use category;
• Designation of Warehouse No. 1 in Planning Area 1 as a mixed land use site that
would allow institutional and/or visitor-serving commercial uses;
• Modification of the break bulk land use boundary in Planning Area 4 to include
all of the buildings at the Southwest Marine terminal site (Berth 240). This area
was also designated as a mixed land use site that would allow break bulk and/or
maritime support;
• Enhancement of mitigation measure MM CR-3 to specify additional protective
measures (e.g., in-situ preservation, adaptive reuse, and relocation); and,
• Inclusion of additional freeway modeling and analyses completed for the
proposed Program.
¥WE& n l~illM44 Wlrf~E
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Excerpts from FPEIR and Port Master Plan Update:
Response to City comments on FPEIR
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2.1
RESPONSE TO COMMENTS
Distribution of the Draft Program EIR
The Draft PEIR was distributed to the public and regulatory agencies to review and
comment from February 21, 2013 to April 8, 2013. Copies of the Draft PEIR were
distributed to various government agencies, organizations, individuals, and Port
tenants. In addition, postcards were mailed to all addresses in the communities of
Wilmington and San Pedro. LARD conducted a public hearing regarding the Draft
PEIR on March 13, 2013 to provide an overview of the proposed Program and
alternatives and accept public comments on the Draft PEIR.
The Draft PEIR was available for review at the following locations:
• LARD, Environmental Management Division, 222 W. 6th Street, San Pedro,
CA 90731;
• Los Angeles Public Library-Central Branch, 630 West 5th Street, Los Angeles,
CA 90071;
• Los Angeles Public Library -San Pedro Branch, 931 S. Gaffey Street,
San Pedro, CA 90731; and,
• Los Angeles Public Library-Wilmington Branch, 1300 North Avalon
Boulevard, Wilmington, CA 90744.
In addition to printed copies of the Draft PEIR, electronic versions were made
available, as requested by interested parties. Due to the size of the document, the
electronic versions were prepared as series of PDF files to facilitate downloading and
printing. The Draft PEIR was available in its entirety on the LARD website at
http://www.portoflosangeles.org/EIR/PMPlJ/DEIR/deir pmpu.asp, and the public
notice was available online at
http://wW\v.portoflosangeles.org/EIR/PMPU/DEIR/ Public Notice.pdf.
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2.2
2.0 to Comments
Comments on the Draft Program EIR and
Draft PMPU
The public comment and response component of the CEQA process serves an
essential role. It allows the respective lead agencies to assess the impacts of a project,
and it provides the opportunity to amplify and better explain the analyses that the
lead agencies have undertaken to determine the potential environmental impacts of a
project. To that extent, responses to comments are intended to provide complete and
thorough explanations to commenting agencies and individuals, and to improve the
overall understanding of the proposed Program for the decision making bodies.
The Draft PEIR and Draft PMPU were released on February 21, 2013 for a 45-day
public review period ending on April 8, 2012. The LARD received 28 comment
letters, 3 public hearing comment cards, and 77 oral comments on these documents
during the public review period. Table 2.2-1 presents a list of those agencies,
organizations, and individuals who commented on the Draft PEIR and Draft PMPU.
Table 2.2-1. Public Comments Received on the Draft Program EIR and Draft PMPU
Letter Code Date OY?;anizationllndividual Pa~e
/
; ?\. ·.· •. StQte Oovf]rnmenf. • ·.·
NARC 2/5/2013 Native American Heritage Commission 2-5
CSLC 4/8/2013 California State Lands Commission 2-11
DOT 4/10/2013 California Department of Transportation (Caltrans) District 7 2-17 .. .· . · ;;; .• laaatf!fQvt!rfiifi~izt ; i.·; .
.; .. .... · .. ·;
RPVl 4/2/2013 City of Rancho Palos Verdes 2-31
RPV2 4/8/2013 City of Rancho Palos Verdes 2-35
BOS 4/11/2013 City of Los Angeles, Bureau of Sanitation 2-41
··• ·. (·········
; · .. ·;>· .• Qfi!anra:ations ·· .; .. ·. .·;;
PTLA 4/5/2013 PortTechLA 2-47
PSLl 417/2013 Proiect Street Legal 2-51
CCA 4/8/2013 Coalition for Clean Air 2-55
LAC 4/8/2013 Los Angeles Conservancy 2-67
NTHP 4/8/2013 National Trust for Historic Preservation 2-85
AS 4/8/2013 The Art Spot 2-99
CFASEl 4/8/2013 Coalition For A Safe Environment 2-105
.. · < .··?<··;· <:•· .. /;;;; ••: '· . · ····· .. •ti#ltJ?~41:(ii/s /, , /;'• .. ,;;.' ; " ·.· ;
PR 3/25/2013 Patricia Ross 2-115
SG 3/29/2013 Stanley Green 2-119
LF 4/3/2013 Lawrence Fafarman 2-123
PB 4/3/2013 Philip Belfer 2-127
JR 4/6/2013 Jay Ross 2-131
DE 41512013 Donna Ethington 2-135
LA 4/6/2013 Linda Alexander 2-143
SC 4/6/2013 Sue Castillo 2-147
CE 417/2013 Christine Esprabens 2-151
DSS No Date Denise and Stephen Smith 2-155
FA No Date Frank B. Anderson 2-159
Businesses ..
SAR 4/2/2013 SA Recycling 2-163
EXXONl 4/4/2013 ExxonMobil Pipeline Company 2-173
GSNT 4/4/2013 Gresham Savage Nolan & Tilden 2-177
BH 4/8/2013 Brandt-Hawley Law Group 2-485
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Port of Los Angeles Master Plan Update
Final Program Environmental Impact Report
2-2
5-314
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Los 2.0 to Comments
Table 2.2-1. Public Comments Received on the Draft Program EIR and Draft PMPU
CFASE2
EXXON2
PSL2
PTl
PT2
2.3
2.3.1
3/13/2013 Coalition for a Safe Environment 2-489
3/13/2013 ExxonMobil 2-495
3/13/2013 2-499
3/13/2013 2-503
2-559
Responses to Comments
In accordance with CEQA (Guidelines Section 15088), LARD has evaluated the
comments on environmental issues received from agencies and other interested
parties and has prepared written responses to each comment pertinent to the adequacy
of the environmental analyses contained in the Draft PEIR. In specific compliance
with CEQA Guidelines· Section 15088(b), the written responses address the
environmental issues raised. In addition, where appropriate, the basis for
incorporating or not incorporating specific suggestions into the proposed Program is
provided. In each case, LAHD has expended a good faith effort, supported by
reasoned analysis, to respond to comments.
This section includes responses to the written and oral comments received during the
Draft PEIR public review period. This section also includes all the comments
received on the Draft PMPU. Information provided in the response to comments on
the Draft PMPU is included in Appendix A, Final PMPU, of this Final PEIR. Some
comments have prompted revisions to the text of the Draft PEIR, which are
referenced and included in Chapter 3.0, Modifications to the Draft Program EIR. A
copy of each comment letter is provided, with responses to each comment
immediately following.
Public Comments and Responses to
Comments
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Port of Los Angeles Master Plan Update 2-3
Final Program Environmental Impact Report
5-315
CITYOF
2 April 2013
Port of Los Angeles
Planning & Economic Development Division
425 S. Palos Verdes St.
San Pedro, CA 90731
l<ANCHO PALOS VEl~DES
CITY MANAC?fR'S OFFICE
AOMINISTf~ATION
VIA ELECTRONIC & U.S. MAIL
SUBJECT: City of Rancho Palos Verdes' Comments on Draft Port Master Plan
To Whom It May Concern:
The City of Rancho Palos Verdes-located just west of the San Pedro community of the RPVI·I
City of Los Angeles-appreciates the opportunity to review the Port of Los Angeles'
Draft Port Master Plan. We have reviewed the Plan and offer the following comments:
1. Section 5.0 of the Plan describes the five (5) planning areas of the Plan,
including the designation and acreage of land uses therein. We understand that
the Plan proposes to eliminate liquid bulk storage within Planning Area 1 (located
nearest to densely-populated areas in San Pedro and Rancho Palos Verdes) and
to designate at least one hundred sixty-six acres (166 ac.) within Planning
Areas 2 and 3 for liquid bulk storage. The City of Rancho Palos Verdes is sup-
portive of any plan that would reduce the risk of exposing residents to the
hazards related to the storage and transport of liquid bulk cargoes. We further
suggest that the Port should make additional provisions in the Plan to facilitate
the relocation of liquid bulk storage facilities to the harbor area, including the
future 200-acre Pier 500 project within Planning Area 3 (i.e., Terminal Island).
2. Section 8.0 of the Plan describes the Risk Management Plan (RMP) for the Port. RPVl-2
We understand that the stated intent of the RMP "is to assess the potential risks
of the storage and transfer of hazardous commodities occurring at liquid bulk
terminals within the Port." To this end, we offerthe following observations:
a. Although apparently not mandated by the California Coastal Commission,
we believe that the RMP should also include a "good faith'' effort to assess
the risks associated with the storage and handling of hazardous liquid bulk
cargoes on vessels, tanker trucks, rail tank cars and in pipelines, at least
within the areas covered by the Plan. To do so would demonstrate the
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Port of Los Angeles Master Plan Update 2-31
Final Program Environmental Impact Report
5-316
RPVJ-3
2.0
Port of Los Angeles
2 April 2013
Page2
b.
Port's willingness to provide more than the minimum, statutorily-required
protection and notification to "vulnerable resources."
We note that the RMP identifies "[residents] living in the area around the
Port [as] the largest and most vulnerable number of people exposed to
risks." It also specifically identifies certain critical Port infrastructure (i.e.,
the Vincent Thomas and Badger Avenue bridges) as "vulnerable
resources." The RMP discusses "hazard footprints" in terms of potential
adverse impacts upon these "vulnerable resources," including radiant
heat, toxic and/or flammable vapor cloud, blast overpressure and flying
debris However, the RMP provides no specifics or details regarding the
location or extent of these "hazard footprints" for either existing or
proposed liquid bulk facilities in the Port.
RPVl4 3. Section 9.0 of the Plan summarizes the Program Environmental Impact Report
(PEIR) prepared for the Plan. The City of Rancho Palos Verdes will be
commenting separately on the Draft PEIR, on or before the end of the public
comment period on B April 2013.
Again, thank you very much for the opportunity to review and comment upon this
important project If you have any questions or need additional information, please feel
free to contact me at (310) 544~5226 or via ~mail at kfff@rpv.com
sh~
Kit Fox, AICP
Senior Administrative Analyst
cc: Mayor Susan Brooks and City Council
Carolyn Lehr, City Manager
Carolynn Petru, Deputy City Manager
Border Issues file
M:\Border lssues\LA Port Master Plan Update\20130402_POLA_DmflPMPComments.docx
to Comments
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Port of Los Angeles Master Plan Update 2-32
Final Program Environmental Impact Report
5-317
Comment Letter RPV1: City of Rancho Palos Verdes
2 Response to Comment RPVl-1:
3 This comment addresses the PMPU and does not raise issues that require a response
4 under CEQA. Please refer to Final PEIR Appendix A, Final PMPU, for information
5 provided in response to this comment.
6 Response to Comment RPVl-2:
7 This comment addresses the PMPU and does not raise issues that require a response
8 under CEQA. Please refer to Final PEIR Appendix A, Final PMPU, for information
9 provided in response to this comment.
10 Response to Comment RPVl-3:
11 This comment addresses the PMPU and does not raise issues that require a response
12 under CEQA. Please refer to Final PEIR Appendix A, Final PMPU, for information
13 provided in response to this comment.
14 Response to Comment RPVl-4:
15 Thank you for your comment. Responses to the city's comments on the Draft PEIR
16 are provided in responses to Comments RPV2-1 through RPV2-4. The comment is
17 noted and is hereby part of the Final PEIR, and is therefore before the decision-
18 makers for their consideration prior to taking any action on the PMPU.
Port of Los Angeles Master Plan Update
Final Program Environmental Impact Report
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Los
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Port of Los Angeles Master Plan Update
Final Program Environmental Impact Report
2-34
5-319
Los
CITY OF
8 April 2013
2.0
r~cHO PALOS VERDES
OFFICE OF THE CITY MANAGER
VIA ELECTRONIC & U.S. MAIL
Christopher Cannon, Director of Environmental Management
Los Angeles Harbor Department
425 S. Palos Verdes St.
San Pedro, CA 90731
SUBJECT: City of Rancho Palos Verdes' Comments on Draft Program Environ-
mental Impact Report for the Port Master Plan Update
Dear Mr. Cannon:
to Comments
The City of Rancho Palos Verdes appreciates the opportunity to review the draft RPV2·.l
Program Environmental Impact Report (PEIR) for the Port Master Plan Update (PMPU).
We have reviewed the PEIR and offer the following comments:
1. Section 3.7 of the PEIR discusses the hazards and hazardous materials impacts
of the PMPU. The two (2) relevant mitigation measures proposed in Section 3.7
are in response to "reasonably foreseeable upset and accident conditions
involving the release of hazardous materials into the environment" (i.e., Impact
HAZ-2). However, the City of Rancho Palos Verdes respectfully suggests that
Section 3.7 of the PEIR requires additional analysis in the following issue areas:
a. The analysis of Impact HAZ-1 (i.e., relating to "[hazards] to the public or
the environment through the routine transport, use, or disposal of
hazardous materials") concludes that impacts will be less-than-significant
and that no mitigation is warranted because these activities are already
"extensively regulated ... to prevent releases and accidents, and ensure the
capability to respond in the event of an accident." From our review of the
draft PMPU document, we understand that the California Coastal
Commission does not mandate the assessment of risks associated with
the storage and handling of hazardous liquid bulk cargoes on vessels,
tanker trucks, rail tank cars and in pipelines as a part of a port master
plan. However, we believe that the PEIR should include a "good faith"
effort to assess these risks as well. To do so would demonstrate the
Port's willingness to provide more than the minimum, statutorily-required
protection and notification to vulnerable resources and populations in the
vicinity of the Port.
309110 HAWTHORNE 8t\IO / IQ\NCHO rmos VERDES. CA 90275·5391 I (310) 544·5205 /FAX (310) 544·5291
C·MAI. CtF.HRliJRPVC0'1 / Wl'J\VJ'AlCSVf.llQf.SC0!-1/Rl'll
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Port of Los Angeles Master Plan Update 2-35
Final Program Environmental Impact Report
5-320
RPV2-2
2.0
Christopher Cannon
8 April 2013
Page2
b. The analysis of Impact HAZ-2 (i.e., relating to ''reasonably foreseeable
upset and accident conditions involving the release of hazardous materials
into the environment'') concludes that there are potentially-significant
impacts related to the risk of hazardous materials releases into the waters
of the Port, and suggests two (2) mitigation measures that would only
apply to "projects involving hazardous liquid bulk facilities with in-water
operations." The PEIR briefly discusses the Port's Risk Management Plan
(RMP) as the means by which conflicts between liquid bulk facilities and
vulnerable resources and populations are to be resolved. From our review
of the draft PMPU document, we understand that this is to be done
through the Port's assessment and identification of any overlapping
"hazard footprints" for liquid bulk facilities and nearby vulnerable resources
and/or populations. However, neither the PEIR nor the PMPU provides
any specifics or details regarding the location or extent of these "hazard
footprints" for either existing or proposed liquid bulk facilities in the Port.
As such, we respectfully suggest that the conclusion that such
environmental impacts are less-than-significant is not adequately
supported by evidence provided in the PEIR.
RPV2-3 2. Section 5.0 of the PEIR discusses the program alternatives to the proposed
PMPU. The PEIR notes that, although many key components of the program
alternatives suggested by the Port Community Advisory Committee (PCAC) have
been included in the PMPU, the PCAC recommendations related to liquid bulk
storage facilfties near the Wilmington community In the City of Los Angeles and
on Terminal Island were rejected, respectively, as:
• Not avoiding or reducing significant environmental impacts; and,
• Being physically and financially infeasible.
The City of Rancho Palos Verdes offers the following comments with respect to
the rejection of the PCAC alternative (Section 5.1.4.1) in the PEIR:
a. With respect to the PCAC recommendations regarding liquid bulk storage
near Wilmington, the PEIR (Page 5-4, Lines 32-39) again relies upon the
Port's RMP to ensure that there are no significant adverse impacts upon
"vulnerable resources." However, as we noted in our Comment 1.b
above, we are concerned that the lack of details and specifics about the
"hazard footprints" of existing or proposed liquid bulk facilities in the Port
does not offer sufficient evidence to support this conclusion in the PEIR.
b. With respect to the PCAC recommendations regarding the relocation of
liquid bulk storage to Terminal Island, the PEIR (Page 5-5, Lines 1-16)
asserts that there is a lack of available berthing capacity and that the cost
of such relocation would be economically infeasible. It is not clear if these
to Comments
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Port of Los Angeles Master Plan Update
Final Program Environmental Impact Report
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Christopher Cannon
8 April 2013
Page3
2.0 to Comments
conclusions took into account the possible future expansion and RPV2-4
development of the "Pier 500" project on Terminal Island, as described in
the draft PMPU document. Would the berthing capacity for the relocation
of liquid bulk facilities still be inadequate on Terminal Island with the
addition of Pier 500? Would the relocation of such facilities to Pier 500
still be infeasible?
Again, thank you very much for the opportunity to review and comment upon this
important project. If you have any questions or need additional information, please feel
free to contact me at (310) 544-5226 or via e-mail at kitf@rpv.com
:?2:
Senior Administrative Analyst
cc: Mayor Susan Brooks and City Council
Carolyn Lehr, City Manager
Carolynn Petru, Deputy City Manager
Border Issues file
M:\Sorder lssues\LA Port Master Plan Update\20130408_POLA_DraftPEIRCcimments.docx
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Port of Los Angeles Master Plan Update 2-3 7
Final Program Environmental Impact Report
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Los 2.0 to Comments
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Los 2.0 to Comments
Comment Letter RPV2: City of Rancho Palos Verdes
2 Response to Comment RPV2-1:
3 This comment addresses the PEIR. and requests that Draft PEIR. Section 3. 7, Hazards
4 and Hazardous Materials, assess the risks to the public and environment (under
5 Impact HAZ-1) associated with storage and handling of liquid bulk cargoes on
6 vessels, tanker trucks, rail tank cars, and pipelines.
7 Draft PEIR Section 3.7.4.3, Impacts and Mitigation Measures, addresses the risks
8 under Impact HAZ-1 of routine transport, use, or disposal of hazardous materials.
9 The Draft PEIR. does not address risks to the public and environment associated with
10 vessel or pipeline transport of liquid bulk from future liquid bulk facilities because
11 specific project details are not available. The Draft PEIR concludes that operation of
12 the proposed appealable/fill projects and land use changes would present a less than
13 significant risk to the public in part because transportation, storage, and use of
14 hazardous materials are extensively regulated. These safety regulations that govern
15 the shipping, transport, storage, and handling of hazardous materials (i.e., United
16 States Coast Guard [USCG], City of Los Angeles Fire Department [LAFD], and
17 United States Department of Transportation [USDOT] regulations and requirements)
18 will limit the severity and frequency of potential releases of hazardous materials. The
19 LAHD's Risk Management Plan (RMP) also contains rigorous policies to prevent or
20 minimize risks associated with operations of liquid bulk facilities in the Port.
21 Siting is another primary method of controlling risks, and the LAHD's RMP
22 precludes the siting of new hazardous liquid bulk facilities and modifications to
23 existing facilities near vulnerable resources that could be impacted. The RMP also
24 precludes vulnerable resources from being sited near existing hazardous liquid bulk
25 facilities. Additionally, siting of new vulnerable resources proximal to existing or
26 approved facilities that handle hazardous liquid bulk cargoes is not permitted.
27 Improvements or modifications to existing hazardous liquid bulk facilities or
28 operations that would expand a hazard footprint, and therefore result in an overlap
29 with vulnerable resources, are not permitted. For security reasons the LAHD does not
30 provide maps with hazard footprints in CEQA documents or the PMPU.
31 Nevertheless, the LAHD believes that risks of routine handling of hazardous
32 materials are adequately addressed in the Draft PEIR., and no further changes are
33 warranted.
34 Response to Comment RPV2-2:
35 This comment addresses the PEIR. and states that the less than significant conclusion
36 under Impact HAZ-2 (refer to Draft PEIR. Section 3.7, Hazards and Hazardous
37 Materials) is not adequately supported because the PEIR and PMPU do not show
38 hazard footprints and their relationships to sensitive resources.
39 Draft PEIR. Section 3.7.4.3, Impacts and Mitigation Measures, addresses the risks
40 under Impact HAZ-2 of a release of hazardous materials to the environment through
41 reasonably foreseeable upset or accident conditions. As discussed in Response to
42 Comment RPV2-l, LAHD's RMP prohibits the siting of hazardous liquid bulk
43 facilities near vulnerable resources that could be impacted. Compliance with existing
44 regulations and requirements would appropriately limit the risk to the public from an
Port of Los Angeles Master Plan Update
Final Program Environmental Impact Report
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2-39
5-324
5
-
3
2
5
Excerpts from FPEIR and Port Master Plan Update:
Response to City comments on on Port Master Plan Update
5-326
Designating land uses for properties outside the Coastal Zone in the PMP would be
inappropriate because they are not subject to the policies and procedures provided in
the Coastal Act.
The previous approvals for the China Shipping Terminal, TraPac Terminal Expansion,
and BNSF SCIG projects were consistent with the PMP. There are no properties to be
obtained as part of the PMP. Properties previously acquired by the Port met all legal
requirements .
. b. States that the berth numbers described in the text are not identified on the
maps.
Response: Maps with berth numbers can be found on the Port website
(http://www.portoflosangeles.org).
c. States that wetland or potential wetlands were not identified in the PMP.
Response: "Wetlands" was added to the definition of the Open Space land use
designation.
d. Asserts that the on-dock rail was not considered for the potential Pier 500
project.
Response: Pier 500 is not an approved project in the PMP. The current concept would
designate Container use for the landfill. The comment incorrectly states that on-dock rail
is not considered for Pier 500 since the definition of container use includes on-dock rail.
e. The comment requests a 90 day extension for public comment.
Response: The Draft PMP and Draft PEIR were released on February 21, 2013 and
public comment was accepted until April 8, 2013. The 45 comment day period was
consistent with both the Coastal Act and CEQA.
LOCAL GOVERNMENT
Kit Fox, City of Rancho Palos Verdes
a. Requests that the PMP facilitate the relocation of liquid bulk facilities to
Planning Area 3 (Terminal Island), including Pier 500.
Response: All current liquid bulk facilities are consistent with the Risk Management Plan
and therefore do not pose a risk.
5-327
b. Requests that the Port assess the risks associated with the movement of
liquid bulk commodities (vessels, trucks, rail cars, and pipelines).
Response: As discussed in the Risk Management Plan, risk assessments of
commodities either transiting on a vessel, tank truck, rail tank car or in a pipeline are not
addressed in the Risk Management Plan due to their transitory nature. For example,
tank cars transit into and out of a rail yard frequently carrying a variety of commodities.
Therefore, it is difficult to determine at any one time what commodities may be inside a
tank car and where that tank car might be located in the rail yard. The transitory nature
of these operations, including vessels moving within the Port, prevents accurate and
representative hazard footprints from being prepared.
c. Requests that the location or extent of hazard footprints generated by liquid
bulk facilities at the port under the Risk Management Plan be publically
disclosed.
Response: Hazardous footprint calculations from existing hazardous liquid bulk facilities,
as defined by the Port's Risk Management Plan, are not released to the general public
due to security/safety reasons expressed by the U.S. Coast Guard. Nevertheless,
coastal permits on liquid bulk facilities before the Board of Harbor Commissioners are
required to include information on whether the proposed project conforms to the Risk
Management Plan. Presently, all existing liquid bulk facilities are consistent with the
Risk Management Plan.
BUSINESSES
Barna Szabo, SA Recycling
• Advocates for the PMP to allow for continued dry bulk operations at Berths
210-211, as well as for the possible addition of another wharf available for
loading bulk cargo and the construction of an elevated connecting roadway
between the two adjacent terminals.
Response: The text relative to the potential relocation of SA Recycling was revised to
include several options with regard to SA Recycling's existing facility. Under the new
text, the existing dry bulk facility may be allowed to remain in its current location and
potentially expand its operations, depending upon the operational scheme and acreage
requirements for the container terminal expansion, including the elevated connected
roadway. The land use plan for SA Recycling and Berths 206-209 are consistent with
the options identified in the text, including the elevated roadway, since Berths 210-211
5-328