City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 1 of 6
RECOMMENDATION:
That the Culver City Redevelopment Agency (the “Agency”) direct staff as deemed
appropriate.
BACKGROUND:
In November 2005, Westfield obtained Planning Commission approval to construct a
project that consisted of modifying the existing 1.05 million square foot mall by
demolishing some 180,000 square feet of existing space and replacing it with some
446,000 square feet of new space in a multi-level configuration with rooftop parking.
The new mall would have approximately 1.3 million square feet of retail space upon
completion, would be supported by 4,233 parking spaces, and would implement an
array of on-site and off-site access and circulation improvements.
This expansion and remodeling project (the “Project”) was subject to environmental
review pursuant to the California Environmental Quality Act via the preparation of a
Mitigated Negative Declaration (“MND”) by the City in August 2005 and revised in
September and November 2005. This document was duly circulated for public
review and adopted by the City Planning Commission with the conclusion that the
Project would not result in significant adverse environmental impacts.
In the successive two years, the mall’s scale, massing and mix of uses has
remained in substantial conformance with that approved by the Planning
Meeting Date: 12/17/07 Item Number: A-3
AGENDA ITEM: Consideration of a Design for Development for the Westfield Mall
at Fox Hills.
Contact Person/Dept.: Sol Blumenfeld or
Todd Tipton
Phone Number: (310) 253-5760
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Consent Item: [] Action Item: [X] Attachments: [X]
Public Notification: Master Notification List; Fox Hills Homeowner Association on
December 14, 2007; Chamber of Commerce on December 14, 2007.
Department Approval:
Sol Blumenfeld 12/13/07
Executive Director Approval:
Jerry Fulwood 12/13/07
Chief Financial Officer:
Jeff Muir 12/13/07
City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 2 of 6
Commission in November 2005. At the time, several wall-mounted panel signs
located on the mall’s westerly, freeway-facing facades were proposed by Westfield.
The project’s conditions of approval required Westfield to submit a Master Sign
Program (“MSP”) that further described the proposed signs. Pursuant to the Culver
City Municipal Code, Master Sign Programs are subject to administrative review and
approval.
Westfield submitted a MSP in September 2007, which proposed the following signs
in addition to the wall-mounted panel signs:
• Three vertical freeway-oriented signs each rising approximately 80 feet over the
expanded mall’s rooftop located along the Sepulveda Boulevard frontage; and
• Four pole-mounted, billboard-type signs located in the parking lot west of the
mall building.
Because the freeway and billboard signs were not contemplated in the initial MND, a
subsequent environmental analysis (“the Analysis”) is necessary. The Analysis
considers aesthetics, traffic safety and impacts on global climate in connection with
the MSP. The global climate change portion of the Analysis will determine whether
or not the proposed signs substantively increase the mall’s power demand beyond
what is currently consumed.
On December 3, 2007, the Agency authorized execution of an agreement with PCR
Services Corporation to conduct the necessary environmental review. The
agreement took into consideration potential environmental impacts such as
aesthetics, light/glare, (height?), energy consumption, etc. The agreement was fully
funded by Westfield.
DISCUSSION:
In 1975 when the mall was developed, a primary objective of the City was that this
large new retail development serves as an attractive gateway as well as an
important sales tax generator. While the mall enjoyed success for many years, it
has more recently experienced a slowdown due to the loss of Robinson-May,
introduction of newer and upgraded competing properties, which resulted in limited
reinvestment by the owner.
City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 3 of 6
Since Westfield acquired the mall in 1998, it has sought to improve the mall’s
performance via a major renovation that was approved by the Planning Commission
in August 2005. The City, Agency and Westfield desire that the mall redevelopment
be of the highest quality design and materials, and be comprised of the best possible
tenants.
In order to achieve this goal, Westfield believes it imperative that the mall’s visibility
be improved. To accomplish this, Westfield proposed an aggressive Master Sign
Program in August 2007 consisting of:
• Vertical Signs - Three vertical signs (Signs AP-A) are proposed to be oriented
primarily to the I-405 Freeway and would be located atop the expanded mall
structure's western façade overlooking Sepulveda Boulevard. Each would
provide two separate display panels approximately 70 to 80 feet in length and
35 feet in width facing generally opposite directions. When mounted on the
mall roof the display panels of these signs would be approximately 120 feet in
height from adjacent grade ;
• Façade-Mounted Signs - Four façade-mounted sign panels (Signs AP-B)
would be located on the expanded mall’s western façade and on the western
ends of the mall’s northern and southern facades. These would be oriented to
both freeways as appropriate and would vary in size from 14 feet in length
and 48 feet in width to 29 feet in length and 64 feet in width; and
• Pole-Mounted Signs (billboards) - Four pole-mounted signs (Signs AP-C)
would be located in the parking lot north of the mall primarily addressing the
SR 90 Freeway, which is elevated over the project site approximately 27 feet.
Pole-mounted signs would each be as high as 60 feet above grade. Three of
these latter signs would provide sign panels 14 feet in length and 48 feet in
width, while a fourth is proposed in a more vertical configuration with three
panels 40 feet in length and 24 feet in width.
The content on all eleven freeway-oriented signs would consist of fixed copy and
images (that is, they would not be digitally sequencing) and each would be
illuminated. Each would be operable from 5:00 A.M. to daylight and from dusk to
midnight. All of these signage panels will be powered with solar collectors
(photovoltaic or other systems, as appropriate) made either a part of the respective
signage structures or located elsewhere on the property. As a result, operation of all
eleven freeway-oriented signs will be power grid and carbon neutral.
City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 4 of 6
A DFD is required in order to thoroughly analyze Westfield’s proposal due to the
unique nature of the mall property and the type of signs proposed. The DFD must
consider:
1. Regional, local and neighborhood visibility to the mall and potential negative
impacts to community character.
2. Regulate special signage that could be viewed by those traveling on the San
Diego (405) and Marina (90) Freeways, and provides a major focal point
along the Sepulveda Boulevard and Green valley Circle frontages.
3. Enhance a major employment center in the region, while retaining, expanding
and attracting businesses that enhance the City.
4. Support the business community by attracting employees and visitors to the
area that will frequent local stores, restaurants, and hotels;
5. Expand Culver City’s economic base by attracting visitors to the mall.
6. Contribute to the expansion of the City’s economic base through the
development of underutilized property, thereby providing additional tax
revenue to the City and Culver City Redevelopment Agency;
7. The proposed DFD establishes standards that assure the Master Sign
Program is appropriate to the mall, that the signs are attractive, aesthetically
pleasing and compatible with the mall’s environment and that they do not
create an adverse environmental impact (see attached environmental
analysis). In regard to the signs, the DFD specifically addresses:
Sign type, quality and size;
Content
Architectural design;
Height;
Illumination; and
Prohibitions
It is noted for the Agency member’s information that the DFD does not permit all
items requested by Westfield in their Master Sign Program. Staff believes it
important that the size and number of signs be limited in order to maintain the
aesthetic character of the area.
Maximum Sign Height
The success of the mall is dependent upon its ability to attract customers. Without
freeway oriented signs, the mall owners believe that they will have difficulty drawing City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 5 of 6
the larger customer base required for high quality retail tenants and will not be able
generate sufficient revenue to reduce the funding gap for the mall improvements.
The critical issue related to the proposed MSP is sign height. The signs must be tall
enough to serve their purpose of commanding customer attention from the Freeway
but not so tall that they intrude upon the views from surrounding residential
neighborhoods. The elevation of the mall on Sepulveda Boulevard must also be
considered relative to the Vertical sign height. The mall ranges from approximately
23 feet to 30 feet below the San Diego (405) Freeway from North to South. Thus, to
be clearly seen from the Freeway, the signs must be elevated to the height of the
Freeway.
If the goal of the Master Sign Program is to ensure sign visibility for the distance of
the mall frontage, (approximately 1000’) then the vertical sign height must be a
minimum of 100 feet. Approximately 30’ above grade is required to clear the
Freeway elevation and 50’ to 60’ of elevation is required to provide enough height to
see the signs over a 1000’ foot distance. (Please see Attached DFD, Exhibit C). The
actual length of the vertical signs would be 50’ to 60’ and mounted at the mall roof
level which is approximately 40 feet in height. Consistent with the definition of
freeway oriented signs and based upon the visibility criteria described in the DFD,
Vertical signs should not exceed 100 feet above grade. (Currently, Westfield has
proposed Vertical signs with advertising displays in excess of 120 feet above grade).
The DFD must strike a compromise between meeting the goal of visibility along the
Freeway and protecting views from the surrounding residential area.
According to the photo-simulations, at a reduced elevation, the Vertical signs provide
sufficient visibility from the Freeways, but are also are partly visible to surrounding
residential areas (Culver Crest, Westchester Bluff and surrounding neighborhoods).
Signs with a height less than 100 feet above adjacent grade, however, do not
provide sufficient visibility to view them along the length of the freeway mall frontage
and may not achieve the goal of drawing customers through increased Freeway
visibility. (Please see Photo-simulations – DFD, Exhibit C).
Limiting the height of the vertical signs to 100 feet above grade permits sufficient
sign visibility along the length of the mall frontage without severely affecting
surrounding areas (Culver Crest, Westchester Bluff and surrounding
neighborhoods). The photo-simulations indicate that Vertical signs with a height less
than 100 feet above grade do not provide sufficient visibility from the Freeway to fully
meet the intent of the freeway oriented signs.
City of Culver City, California
Redevelopment Agency Agenda Item Report
Page 6 of 6
Prohibited Pole Mounted Signs:
The four pole-mounted signs proposed to be located in the parking lot north of the
mall and oriented to the SR 90 Freeway, are prohibited.
CONCLUSIONS:
Westfield has proposed a mall improvement and expansion program to help
reposition it as a modern regional retail center. The DFD incorporates a Sign
Program proposed by Westfield to support the mall improvements. The DFD is
based upon the land use policies of the General Plan which recommend upgrading
and expanding the mall to maintain economic viability while mitigating the impacts to
nearby residential neighborhoods. To the extent that the Sign Program helps attract
new customers and expands the customer base, it supports the mall improvement
and may achieve this redevelopment objective. Many of the proposed signs are
freeway oriented, and as such, require enough height to be clearly visible along
Freeway mall frontage. However, the DFD must strike a compromise between
meeting the goal of Freeway visibility and protecting views from surrounding
residential areas.
ATTACHMENTS:
1. Proposed Westfield Culver City Design for Development with related exhibits.
MOTION:
That the Culver City Redevelopment Agency:
1. Direct staff as deemed appropriate.
Attachments
Meeting Date: 12/17/07
AGENDA ITEM: Consideration of a Design for Development for the
Westfield Mall at Fox Hills.
Attachments Page
1. Proposed Westfield Culver City Design for 1 -51
Development with related exhibits
CULVER CITY
REDEVELOPMENT AGENCY
DESIGN
FOR
DEVELOPMENT
WESTFIELD CULVER CITY
Table of Contents
I. Introduction 2
A. General Objectives 2
B. Special Controls 3
C. Definitions 3
II. Westfield Culver City 4
A. Background 4
B. Purpose and Intent of Signage 4
C. Proposed Master Sign Plan 5
III. General Provisions 6
A. General Plan 7
B. Redevelopment Plan 8
C. Zoning Code 8
IV. Signage Standards 9
A. Type, Quantity and Size 9
B. Advertising Display 11
C. Advertising Content 11
D. Architectural Design 11
E. Illumination 12
F. Prohibitions 12
V. Implementation Signage Review
Procedures 13
VI. Environmental Review 13
VII. Responsibility for Securing
Permits and Paying Applicable
Fees 13
VIII. Conclusions 14
Exhibits
Exhibit A: Map of DFD Area 15
Exhibit B: Location of Signs (Map) 16
Exhibit C: Photo Simulations of Proposed Signs in 17
Mitigated Negative Declaration
1
DESIGN FOR DEVELOPMENT
WESTFIELD CULVER CITY
I. Introduction
The Fox Hills Mall (Mall), recently renamed Westfield Culver City is located at
200 Fox Hills Mall in the City of Culver City on nearly 44 acres of land. This
property, identified in Exhibit A, is joined by five public roadways including
Sepulveda Boulevard, Slauson Avenue, Hannum Avenue, Green Valley
Circle and Fox Hills Drive. In addition, the Mall borders both the San Diego
(405) Freeway and the Marina (90) Freeway. The location, size, and unique
architectural design of the Mall give it the potential to serve as a physical
gateway to Culver City.
The property owner, Westfield Corporation (“Westfield”), has proposed a
Master Sign Program (MSP) that focuses upon the Mall’s significant freeway
orientation as part of redevelopment of the site. The size and unique location
of the signs adjacent to the 405 and 90 freeways requires special design and
regulatory considerations. The purpose of this Design for Development (DFD)
is to promote signage standards that are appropriate to the Mall, considering
site and planning constraints.
This DFD is intended to set signage controls necessary to reposition the Mall
as an important commercial enterprise both within the City and the
surrounding region. To further attract commerce, tourism and visitation to the
Mall and surrounding area, this DFD will ensure signage for the site is
attractive, aesthetically pleasing, effective and compatible with the Mall’s
environment and the community. The DFD will further implement the goals
of the Agency and the City by enabling the continued economic viability of the
Mall and the continued improvement of the economic welfare of the
community. The DFD is intended to only regulate the signs described herein
and all other signs shall be in compliance with zoning code Section 330 and
as approved as a part of the Master Sign Program.
This DFD supplements, augments, and focuses the goals, policies and
objectives of the various Planning and Redevelopment documents affecting
this area. However, these standards are not inclusive of all applicable City
procedures, provisions, regulations and requirements that may apply to the
development of the area.
A. General Objectives
The Agency wishes to encourage design concepts that will:
1. Expand Culver City’s economic base by attracting visitors to the
Mall;
22. Provide regional, local and neighborhood visibility to the Mall
without negatively impacting community character;
3. Regulate special signage that may be viewed along the
elevated 405 Freeway and provides a major focal point along
the Sepulveda Boulevard and Green Valley Circle frontages;
4. Redevelop an architecturally distinctive Mall that will utilize its
location at the intersection of the 405 Freeway and major
thoroughfares to create a gateway for the area;
5. Contribute to the expansion of the City’s economic base through
the development of underutilized property, thereby providing
additional tax revenue to the City and Culver City
Redevelopment Agency;
6. Support the business community by bringing employees and
visitors into the area that will frequent local stores, restaurants,
and hotels; and
7. Enhance a major employment center in the region, while
retaining, expanding and attracting businesses that enhance the
City.
B. Special Controls
Consistent with the purposes of this DFD and pursuant to the
authority of the Agency under Section 423 of the Redevelopment
Plan for the Culver City Redevelopment Project, Component Area
No. 1, the Agency hereby establishes the following controls and
restrictions for development of The Mall, which are in addition to
applicable General Plan requirements and guidelines, Zoning and
Building Codes, and other requirements of the Culver City
Municipal Code (CCMC).
C. Definitions
For the purposes of this DFD, the following definitions shall apply:
(For all other definitions in this DFD, refer to the definitions listed in
Section 17.700 of the CCMC.)
1. Development: The physical alteration of any parcel or area
of land, including buildings, structures, grading and other
related changes by any private person or entity and/or by
any public body or agency. (Applies to both public and
private construction and development.)
2. Freeway-Oriented Signs: As used herein, are on-site signs
that are directed essentially to be visible only from a
freeway.
3
3. Pole Mounted Signs: A sign that is displayed on or totally
supported by one or more support elements that are on the
ground with no part of the sign attached to a building or
structure.
4. Wall Mounted Signs – A sign that is displayed on or attached
to an exterior wall of a building or structure.
II. Westfield Culver City
A. Background
The existing Mall was opened in 1975 and is improved with some
1,054,150 square feet of commercial space including department
stores, numerous smaller retail shops, restaurants and related uses,
and a freestanding office building at the southwest corner of the site.
There are 4,359 parking spaces presently serving the Mall. Westfield
does not own the two large department stores; JC Penny’s and Macy’s
are independently owned.
Westfield acquired the Mall as the primary property owner in October
1998, and as the representative of all of the site’s property owners filed
a complete Site Plan Review application for the expansion and
remodeling of the existing Mall in August, 2005. The application
proposed demolition of some 180,000 square feet of existing space
including the existing freestanding office building, and new construction
of slightly over 446,000 square feet of new retail and related space in a
multi-level configuration with rooftop parking. The total resulting floor
area within the Mall after demolition and new construction was to be
1,320,465 square feet.
Onsite and offsite elements include architectural improvements such
as pedestrian plazas and wall mounted signage; retail and restaurant
uses; revisions to vehicle access ramps and expansion of the parking
structure; parking lot improvements including striping, curbing,
landscaping and handicapped parking upgrades; relocation of two
primary driveway locations and realignment of medians and left turn
pockets along Sepulveda Boulevard; and signalization of the Hannum
Avenue driveway.
B. Purpose and Intent of Signage
A major objective of the City for the Mall in 1975 was that this large
new retail development would serve as an attractive new gateway to
the City of Culver City as well as an important sales tax generator.
Anticipated patrons included City residents, residents from surrounding
communities and, importantly, from those utilizing the nearby freeway.
4
While the Mall enjoyed success for many years, it has more recently
fallen on slower times due to the introduction of newer and upgraded
competing properties, limited reinvestment by the owners and to the
fact that, despite appreciable effective freeway frontage, only limited
freeway visibility has ever been established at the Mall.
Currently, the Mall lacks a sense of connection to the rest of Culver
City. The discontinuity of established streets to the north limits easy
access to the rest of the City and exacerbates a sense of separation.
To the southwest, the site vicinity is distinguished by the Howard
Hughes Center’s signage and mid- and high-rise buildings. Signage
and design guidelines of the Mall are based on its uniqueness as
outlined in the following findings:
1) The project is 43.77 acres. This is the largest commercial site in
Culver City.
2) The Mall includes over one million Gross Square Feet of retail
space, making it the largest retail space within the City.
3) The site is surrounded by five public streets and adjacent to the
elevated 405 Freeway, the 90 Freeway and the obstructing
overpass interchange between the two.
4) The project site’s elevation is below the 405 Freeway and below
the neighboring properties.
5) The elevation of the Mall on Sepulveda Boulevard ranges form
approximately 23 feet to 30 feet below the 405 Freeway from
North to South.
6) The actual Freeway frontage with an obstructed view to the Mall
is approximately 1,375 feet in length.
7) The unobstructed 405 Freeway view is framed on the north end
by the three story office building located at 5995 Sepulveda
Avenue and the tree blind at the Sepulveda Avenue exit at the
south.
8) The elevated 405 and 90 Freeways, and overpass interchange,
visually obstruct and prevent the project site from realizing its
potential as a gateway to Culver City.
9) The freeway traffic does not have a clear view of the project site
until after a passerby has passed any viable freeway exit ramp.
C. Proposed Master Sign Program
Planning Commission Resolution No 2005-PO19 approving Westfield’s
expansion and remodel of the Mall requires that Westfield submit a
MSP for the exterior signs. Westfield submitted a MSP to the City in
September 2007, which includes the following signs:
• Vertical Signs - Three Vertical Signs (Signs AP-A, Exhibit C) are
proposed to be oriented primarily to the 405 Freeway and would
5be located atop the expanded Mall structure's western façade
overlooking Sepulveda Boulevard. Each vertical sign contains
two separate display panels approximately 70 to 80 feet in
length and 35 feet in width facing generally opposite directions.
In addition, the Vertical Sign structural framework extends
beyond the sign advertising panel display length by up to 15’-6’
to create an architectural feature and spire. The Vertical Signs
will be mounted on top of the Mall which varies in height from
46’- 10” to 57’-2”. With the Vertical Signs mounted at the Mall
roof line, the height of the advertising display will extend up to
137’–2” and the spire will extend up to 152’ – 8” on the south-
west elevation.
• Wall-Mounted Signs - Four Wall-Mounted Sign panels (Signs
AP-B, Exhibit C) would be located on the expanded Mall’s
western façade and on the western ends of the Mall’s northern
and southern facades. These would be oriented to both
freeways as appropriate and would vary in size from 14 feet in
length and 48 feet in width to 29 feet high and 64 feet in width;
and
• Pole-Mounted Signs (billboards) - Four Pole-Mounted Signs
(Signs AP-C, Exhibit C) would be located in the parking lot north
of the Mall primarily addressing the 90 Freeway, which is
elevated over the project site approximately 27 feet. Pole-
Mounted Signs would each be as high as 60 feet above grade.
Three of these signs provide sign panels 14 feet in length and
48 feet in width and one is proposed in a more vertical
configuration with three panels 40 in length and 24 feet wide.
The content on all eleven Freeway-Oriented Signs would consist of
fixed copy and images (that is, they would not be digitally sequencing)
and each would be illuminated. Each would be operable from 5:00
A.M. to daylight and from dusk to midnight. All of these signage panels
will be powered with solar collectors (photovoltaic or other systems, as
appropriate) made either a part of the respective signage structures or
located elsewhere on the property. As a result, operation of all eleven
freeway-oriented signs will not be derived from the power grid and will
be carbon neutral.
III. General Provisions
Uses permitted in the DFD area shall be compatible with the General Plan,
the Redevelopment Plan and the Zoning Code.
6
A. General Plan
The General Plan designates the Mall as Regional Center. This
designation allows large-scale commercial uses that may share
parking. It is intended to support existing and anticipated commercial
developments that serve a regional market area and would serve both
the residential and business communities. The designation is
characterized by varying height limits, expansive landscaped setbacks,
and a minimum parcel size.
The following policies of the General Plan guide the DFD for the Mall
Area and are especially pertinent. The DFD is based on the General
Plan as it currently exists or as amended in the future.
1. Land Use Element
i. Policy 5.D Provide development incentives for projects that
provide specific community or neighborhood needs.
ii. Policy 5.G Encourage the location of high quality retail
shops and fine restaurants in areas which could serve both
businesses and residential patrons.
iii. Policy 6.A Encourage revitalization of commercial corridors
in the City through new development and renovation of
existing structures with incentives which address
development standards and the project approval process.
iv. Policy 6.B Focus commercial development into cohesive
districts by identifying and encouraging intensities and
qualities of commercial uses that are sensitive to their
locations, and by emphasizing specific uses (i.e., general
commercial or regional commercial corridors).
v. Policy 7.B Allow existing regional and community centers to
upgrade and expand in response to changing market
demands, to maintain their economic viability, with adequate
mitigation of impacts to nearby residential neighborhoods.
vi. Policy 25.B Improve the Fox Hills Sub Area’s identity as part
of Culver City by assigning high priority to signage and
gateway improvements to this area.
vii. Policy 25.F Reinforce the physical and visual connection
between the Fox Hills mall and nearby hotels.
7
B. Redevelopment Plan for the Culver City Redevelopment Project
The DFD area falls within Redevelopment Project Component Area
No. 1. Section 423 of The Redevelopment Plan (“The Redevelopment
Plan”) applies:
Within the limits, restrictions, and controls established in the Plan, the
Agency is authorized to establish heights of buildings, land coverage,
setback requirements, design criteria, traffic circulation, traffic access,
and other development and design controls necessary for proper
development of both private and public areas within the Component
Area. Such controls may not relax the requirements of the Culver City
Planning and Zoning Ordinance, or any applicable specific plan.
No new improvement shall be constructed and no existing
improvement shall be substantially modified, altered, repaired, or
rehabilitated except in accordance with any such controls. In the case
of Real Property that is the subject of a disposition and development or
participation agreement with the Agency, it shall be constructed in
accordance with architectural, landscape, and site plans submitted to
and approved in writing by the Agency.
One objective of the Redevelopment Plan is to create an attractive and
pleasant environment in the Component Area. Therefore, such plans
must give consideration to good design, open space, and other
amenities to enhance the aesthetic quality of the Component Area.
The Agency will not approve any plans that do not comply with the
Redevelopment Plan.
C. Zoning Code
The sign regulations are enacted to “serve the interests of community
aesthetics, vehicular and pedestrian safety, to protect and preserve
property values, to improve the visual environment of the City so as to
promote commerce, investment, tourism, and visitation, and the overall
quality of life for persons living in, doing businesses in, or visiting the
City” (CCMC 17.330.005).
All signs must conform to City sign standards and regulations as they
now exist or are hereafter legislated. It is recognized that the
coordination of signs within this DFD area affect its appearance and
image. Therefore, it is the intent of this DFD that the Agency may
adopt additional signage standards and guidelines which may be more
restrictive than City standards in order to further the goals of the
Redevelopment Plan or the objectives of a special district.
8
IV. Signage Standards
The DFD establishes appropriate regulations for the sign program for the Mall
related to quantity, size, height, location, color construction materials, lighting,
and other design features. The DFD addresses signs and graphics on the
exterior of the Mall and throughout the site. Each sign in the proposed sign
program shall also comply with applicable city, state and federal regulation
with regard to size, materials and structure, illumination and content. Signs
within the interior of the Mall are exempt from the DFD.
One of the critical issues related to the proposed Vertical Signs is height. The
signs must be tall enough to serve their purpose of commanding customer
attention from the freeway, but not so tall that they intrude upon the views
from surrounding residential neighborhoods. The elevation of the Mall on
Sepulveda Boulevard ranges from approximately 23 feet to 30 feet below the
405 Freeway from North to South. Thus, to be seen from the freeway, the
signs must at minimum be located above the Freeway elevation. The size of
the signs also has bearing on the proposed repositioning of the Mall. The
DFD goal of attracting new customers with highly visible signage may not
parallel the goal of creating a more upscale mall environment.
Photo simulations modeling the project vertical signs at varying heights above
the freeway elevation have been prepared to evaluate the height effects of
the signage from vantage points in the areas surrounding the Mall. The
photo-simulations indicate that at the currently proposed heights, the signage
will be visible from residential neighborhoods to the east and west and
commercial areas to the north and south. Westfield’s proposed height for the
signs may be obtrusive to these neighborhoods, unless the sign height is
modified.
The following provides a discussion of standards that may be applied to
achieve the goals of the MSP and moderate the effects of sign height upon
neighborhoods in and around Redevelopment Component Plan Area No. 1:
A. Type, Quantity & Size
a. Vertical Signs. The success of the Mall is dependent upon its ability to
attract customers. Without Freeway Oriented Signs, the Mall owners
believe that they will have difficulty drawing a larger customer base that is
required for high quality retail tenants. Pursuant to the findings in Section
II B and consistent with the economic development and Redevelopment
Plan goals for Component Area 1 noted in Sections III A and B, Vertical
Signs should be permitted to be large enough to be legible from the 405
and 90 Freeways. If appropriately sized, these signs will reinforce the
Mall’s identity and guide customers from the freeway to the Mall, while
minimizing the effects upon surrounding neighborhoods. In this manner,
9the Mall signage will support the General Plan’s goal for the Mall to serve
as a gateway to Culver City.
1. Maximum Number and Height:
Up to three Vertical Signs (oriented to the405
Freeway and located on the expanded Mall roof structure's
western façade overlooking Sepulveda Boulevard) may be
permitted. Each Vertical Sign may provide two separate
display panels measuring approximately 50-60 feet in length
and 35 feet in width facing generally opposite directions.
Mounted at the roof level, the signage would extend up to a
maximum of 100’ from the finished grade immediately below it,
providing adequate visibility from the Freeway and moderating
visibility to residential areas to the east and west of the Mall as
shown in Exhibit C).
The photo-simulations (Exhibit C) reveal that at 100 feet in
height, the vertical signs will be visible from an approximate
distance of 1000 feet along the 405 Freeway, the approximate
length of the Mall freeway frontage. From this distance, the
signs may be visible though not readily legible. In addition,
existing freeway landscaping partially obstructs the view of
some of the Vertical Signs along the freeway. (Please see
Photo-simulations – Exhibit C).
Further, signs that are part of the structural support of the
building should not exceed 56 feet above grade. Any sign that
is part of the structural support of the building and that
exceeds 56 feet in height above grade should be prohibited.
If the goal is to maximize Vertical Sign visibility for the distance
of the mall frontage, (approximately 1000’) then the Vertical
Sign height must be a minimum of 100 feet. (Approximately
30’ above grade is required to clear the freeway elevation and
50’ to 60’ above the freeway is required to provide enough
elevation to see the signs over a 1000 foot distance. The
actual length of the Vertical Signs would be 50’ to 60’ mounted
at the Mall roof level. Consistent with the definition of Freeway
Oriented Signs and based upon the visibility criteria above,
Vertical Signs should not exceed 100 feet above grade.
(Currently, Westfield has proposed Vertical Signs with
advertising displays in excess of 120 feet above grade). The
DFD must strike a compromise between meeting the goal of
visibility along the Freeway and protecting views from the
surrounding residential area.
10According to the photo-simulations, at this elevation, the
Vertical Signs provide sufficient visibility from the freeways;
however they are partly visible to surrounding residential areas
(Culver Crest, Westchester Bluff and surrounding
neighborhoods). Signs with a height less than 100 feet above
adjacent grade do not provide sufficient visibility from the
freeway along Mall frontage and may not achieve the goal of
drawing customers through increased freeway visibility.
(Please see Photo-simulations – Exhibit C).
2. Maximum Number of Sign Faces:
No more than two sign faces per Vertical sign are permitted
and the portion of the sign not oriented toward the freeway
shall not contain advertising of any kind. The portion of the
sign not oriented toward the freeway must be a solid material
and painted to match the remainder of the sign structure.
b. Wall-Mounted Signs.
1. A maximum of four Wall-mounted Sign Panels may be
located on the expanded Mall’s western façade and on the
western ends of the Mall’s northern and southern facades.
These maybe oriented to both freeways where feasible.
2. Façade-mounted signs may vary in size from14 feet in length
and 48 feet in width to 29 feet in length and 64 feet in width.
c. Pole-Mounted Signs (Billboards).
1. Pole-mounted signs are prohibited.
B. Advertising Display
Signs will be used exclusively for advertisements consisting of fixed copy
and images and shall not be digitally sequencing.
C. Advertising Content
Signs will be used exclusively to advertise the businesses or services
upon the property upon which the signs are placed.
D. Architectural Design
This DFD is intended to promote project design that is attractive,
functional and consistent with the regional commercial designation of the
General Plan and the applicable zone. Toward that end, the MSP must
11harmonize with the architecture of the mall buildings and surrounding area
and comport with the City’s Zoning Code.
Vertical signs must be architecturally but not structurally integrated into the
building facade in order to avoid creating an over-height building condition.
They must clearly be signage affixed to the building and not a structural
building feature. The signs should be integrated with the building’s
architectural form and be compatible with the new Mall design. The signs
structural elements shall be consistent with the Mall’s exterior color.
E. Illumination
Sign illumination shall not adversely affect adjacent uses, especially
nearby residential development. All exterior sign illumination shall be
designed, installed and maintained so as to be non-intrusive to
surrounding areas.
Creative, energy efficient, low-maintenance illumination solutions
(Photovoltaic) are required. Sign panels shall be powered with solar
collectors (photovoltaic or other systems, as appropriate) made either a
part of the respective signage structures or located elsewhere on the
property with the intent to be power grid and carbon neutral.
Signs shall only be illuminated from 5:00 A.M. to daylight and from dusk to
midnight and only the sign copy shall be illuminated (no architectural
lighting).
F. Prohibitions
Signs shall not include any use or structure which by reason of design,
traffic, smoke, glare, noise, odor, or similar factors would be incompatible
with the surrounding areas or structures.
Signs shall not contain multiple advertisements (no stacked advertising
signs).
Signs shall be for advertising only and shall not contain telecommunication
facilities.
The following sign types are prohibited within the DFD area:
• Pole-Mounted Signs.
• Internally illuminated Digitally Sequence Signs.
• Off-site Advertising Signs.
• Changeable Copy Signs (Manually, Mechanically Electronically)
12
V. Implementation - Signage Review Procedures
CCMC Chapter 17.330 specifies a comprehensive sign regulating process
that considers types of signs, maximum sign areas, maximum sign heights,
maximum number of signs, and locations of signs. The CCMC provides for
MSPs as a mechanism “…to modify the CCMC and to ensure the signs for a
uniquely planned or designed development or area are most appropriate for
that particular development or area.”[17.330.050(D)(2)].
Signs for the Mall shall be subject to the applicable signage requirements of
the City Zoning Ordinance and this DFD, and shall be processed pursuant to
a Master Sign Program as outlined in Section 17.330.050.D.2. Formulation of
a MSP by the “developer” as an integral part of the overall development
concept shall be required. Notwithstanding specific CCMC provisions having
citywide application, the Agency intends to allow only signs essential and
appropriate to the scale and character of a quality regional center. Within this
general framework, the Agency is receptive to innovative and imaginative sign
techniques and proposals.
When appropriate, notice to surrounding properties, community outreach, and
opportunities for early public participation in the design and development
process may be required and are always encouraged.
VI. Environmental Review
Development of buildings, structures, and public and private facilities within
the DFD Area shall be subject to specific environmental review pursuant to
the applicable City and Agency review procedures. Such environmental
review may include, but is not limited to:
1. Completion of the City’s Preliminary Environmental Information Form;
and
2. Any additional review up to and or including a full environmental impact
report or negative declaration.
Cost for any such environmental review, consultants, and contract
administration (if required) shall be paid by the property owner or developer.
A technical study has been prepared to examine potential aesthetic
environmental effects related to views, light and glare, traffic and climate
change and found that the proposed MSP will not cause new significant
environmental impacts.
VII. Responsibility for Securing Permits and Paying Applicable Fees
Nothing contained in this DFD or in subsequent agreements shall be
construed in any way to exempt the developer, person or agency proposing
13the public or private development or facility (or his/her assignee, buyer,
transferee, conveyee or lessee) from securing all permits and paying all fees
required of developers of private property within the City of Culver City.
VIII. Conclusions
Westfield has proposed a Mall improvement and expansion program to help
reposition it as a modern regional retail center. The DFD incorporates a Sign
Program proposed by Westfield to support the Mall improvements. The DFD
is based upon the land use policies of the General Plan which recommend
upgrading and expanding the Mall to maintain economic viability while
mitigating the impacts to nearby residential neighborhoods. To the extent that
the Sign Program helps attract new customers and expands the customer
base, it supports the Mall improvement and may achieve this redevelopment
objective. Many of the proposed signs are freeway oriented, and as such,
require enough height to be clearly visible along Freeway mall frontage.
However, the DFD must strike a compromise between meeting the goal of
Freeway visibility and protecting views from surrounding residential areas.
Also the size of the signs has bearing on the proposed repositioning of the
mall. The goal of attracting new customers with highly visible signage may
not be consistent with the goal of creating a more upscale mall environment
that harmonizes with the surrounding community.
14
Exhibit A
SITE MAP
DESIGN FOR DEVELOPMENT
WESTFIELD CULVER CITY
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PCR Services Corporation December 2007
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II. PURPOSE OF THE ADDENDUM TO THE ADOPTED IS/MND
Section 15164(b) of the CEQA Guidelines provides that an addendum to an adopted
MND may be prepared if some changes or additions are necessary and none of the conditions
described in Section 15162 of the Guidelines calling for the preparation of a Subsequent MND
have occurred. Section 15162 of the CEQA Guidelines specifies that a Subsequent MND need
only be prepared if:
1. Substantial changes are proposed in the project which will require major revisions of
the previous MND due to the involvement of new significant environmental effects or
a substantial increase in the severity of previously identified significant effects;
2. Substantial changes occur with respect to the circumstances under which the project
is undertaken which will require major revisions of the previous MND due to the
involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects;
3. New information of substantial importance, which was not known and could not have
been known with the exercise of reasonable diligence at the time the previous
negative declaration was certified as complete shows any of the following:
a. The project will have one or more significant effects not discussed in the previous
MND,
b. Significant effects previously examined will be substantially more severe than
shown in the previous MND,
c. Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects of
the project, but the project proponents decline to adopt the mitigation measure or
alternative, or
d. Mitigation measures or alternatives which are considerably different from those
analyzed in the previous MND would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
City of Culver City Fox Hills Mall Improvement Project
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Page i
TABLE OF CONTENTS
I. INTRODUCTION .....................................................................................................................1
Background ...............................................................................................................................1
Approved Project ....................................................................................................................1
Master Sign Program ..............................................................................................................3
II. PURPOSE OF THE ADDENDUM TO THE ADOPTED IS/MND ..................................4
III. THE CURRENT PROJECT AND THE MASTER SIGN PROGRAM ...........................6
The Current Project ...................................................................................................................6
Master Sign Program ..............................................................................................................6
IV. ENVIRONMENTAL ASSESSMENT ..............................................................................14
Aesthetics ..............................................................................................................................15
Transportation Safety ............................................................................................................29
Global Climate Change ...........................................................................................................31
V. CONCLUSION.......................................................................................................................34
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LIST OF FIGURES
Figure Page
1 Location of the Project .............................................................................................................2
2 Level 1 Plan .............................................................................................................................7
3 Level 2 Plan .............................................................................................................................8
4 Level 3 Plan .............................................................................................................................9
5 Roof Level Plan .....................................................................................................................10
6 Freeway Oriented Signs .........................................................................................................12
7 Vertical Signs .........................................................................................................................13
8 View Locations ....................................................................................................................17
9 View 1 - State Route 90 Eastbound to Interstate 405 Southbound Transition ....................18
10 View 2 - Residential Neighborhood along Westchester Bluffs at Riggs Place near
Kentwood Avenue .................................................................................................................19
11 View 3 - Interstate 405 Northbound at Slauson Avenue Exit ..............................................20
12 View 4 - Residential Neighborhood at 11505 Segrell Way (between Berryman Avenue
and Slauson Avenue ...............................................................................................................21
13 View 5 - Residential Neighborhood at Hannum Avenue and Bush Way ............................22
14 View 6 - Residential Neighborhood at 10751 Cranks Road: Elevation 154 feet .................23
15 View 7 - Office Depot Parking Lot at 5640 Sepulveda Boulevard .......................................24
16 View 8 - Slauson Avenue at State Route 90 West Entrance ................................................25
17 View 9 - Los Angeles County Assessor’s Office at 6120 Bristol Parkway...........................26
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 1
I. INTRODUCTION
BACKGROUND
This document is an Addendum to an adopted Initial Study/Mitigated Negative
Declaration regarding the expansion and remodel of the existing Westfield Fox Hills Mall
(Mall). The Mall is located at 200 Fox Hills Mall in the City of Culver City on nearly 44 acres
of land. This property is identified in Figure 1 on page 2 and is adjoined by five public roadways
including Sepulveda Boulevard on the west and West Slauson Avenue to the north; Hannum
Avenue is easterly, and Green Valley Circle as well as Fox Hills Drive from the southern
property line. In addition, the Interstate 405 (I-405) is aligned immediately west of Sepulveda
Boulevard across from the Mall and the Marina Freeway, or State Route 90 (SR 90), actually
transects the project site in an elevated configuration.
The existing Mall was opened in 1975 and is improved with some 1,054,150 square feet
of mixed retail space including department stores, numerous smaller retail shops, restaurants, and
related uses, and also including a freestanding office building at the southwest corner of the site.
There are 4,359 parking spaces presently serving the Mall. A major objective of the City for the
Mall at the time of its opening was the hope that this large new retail development would serve
as an attractive new gateway to the City of Culver City as well as an important cachement of
sales tax revenue associated with patronage of City residents, residents from surrounding
communities and, importantly, from nearby freeway traffic. While the Mall enjoyed some
success in its early years, it has more recently fallen on slower times. This decline has been
attributable to successful introduction of newer and upgraded competing properties, limited
upgrading attention at the subject Mall, and to the fact that, despite appreciable effective freeway
frontage, only limited freeway visibility has ever been established at the Mall.
APPROVED PROJECT
Westfield Corporation, Incorporated acquired the Mall as the primary property owner in
October 1998, and as representative of all of the site’s property owners filed a complete Site Plan
Review application (Case No. SPR P-2005027) for the expansion and remodeling of the existing
Mall in August, 2005. The application proposed demolition of some 180,000 square feet of
existing space including the existing freestanding office building, and new construction of
slightly over 446,000 square feet of new retail and related space in a multi-level configuration
with rooftop parking. The total resulting floor area within the Mall after demolition and new
construction was to be 1,320,465 square feet. In addition, a Parking Demand Study determined
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I. Introduction
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 3
a minimum parking need for 4,233 spaces, which could be further reduced by 170 spaces to a
minimum of 4,074 spaces due to the existing on-site transit center and future improvements.
This latter minimum on-site parking supply was imposed on the expanded Mall project Onsite
and offsite elements were to include architectural improvements such as outdoor plazas and
signage; retail and restaurant uses with associated onsite consumption of alcoholic beverages;
revisions to vehicle access ramps and expansion of the parking structure; parking lot
improvements including striping, curbing, landscaping and handicapped parking upgrades;
relocation of two primary driveway locations and realignment of medians and left turn pockets
along Sepulveda Boulevard; and signalization of the Hannum Avenue driveway.
In compliance with the California Environmental Quality Act, the environmental
consequences of the project proposed in the Westfield application were thoroughly addressed in
an Initial Study and Mitigated Negative Declaration (MND) prepared by the City initially on
August 31, 2005 and subsequently revised September 8, 2005 and November 2, 2005. On
November 9, 2005, this MND was adopted by the Culver City Planning Commission with a
finding that the proposed project would not cause any significant adverse environmental impacts.
On the same date, the Planning Commission also approved the subject of SPR P-2005027 via
Resolution No. 2005-PO19. This approval is referred to throughout the balance of this document
as the “Approved Project.”
MASTER SIGN PROGRAM
Culver City Municipal Code (CCMC) Chapter 17.330 specifies a comprehensive system
for regulation of signs in Culver City including types of signs, maximum sign areas, maximum
sign heights, maximum number of signs, and locations of signs. The CCMC provides for master
sign programs (MSP) as a mechanism “…to modify the CCMC and to ensure the signs for a
uniquely planned or designed development or area are most appropriate for that particular
development or area.”[17.330.050(D)(2)] A MSP “…may be initiated by the City or
Redevelopment Agency for a particular area in furtherance of a specific plan, revitalization
program, overlay zone or other area wide planning tool.” [17.330.050(D)(2)(c)] Freeway-
oriented signs, or those signs that are intended to be essentially visible only from a freeway, are
prohibited by the ordinance unless the Director approves and issues a permit pursuant to the
MSP to allow such signs. Planning Commission Resolution No 2005-PO19 approving
Westfield’s expansion and remodel of the Mall ( the Approved Project), requires that Westfield
submit a MSP for the exterior signs proposed as part of the “Approved Project. Westfield did
submit such a MSP in September 2007. That MSP, specifically those signs considered freeway-
oriented signs, is the primary subject of this Addendum to the adopted IS/MND.
II. Purpose of the Addendum to the Adopted IS/MND
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 5
The purpose of this Addendum is to analyze the environmental effects associated with the
Master Sign Program (MSP) which, as part of its approval of the Approved Project, the Planning
Commission required Westfield to submit to the City's Planning Manager. If the analyses
presented herein demonstrate that the MSP will not result in new significant environmental
effects or a substantial increase in the severity of the effects identified in the Adopted IS/MND.
Pursuant to Section 15162 of the CEQA Guidelines, a Subsequent MND is not required. With
such analytic demonstration an Addendum would be the appropriate documentation to address
the potential impacts of the Westfield MSP.
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 6
III. THE CURRENT PROJECT AND THE MASTER SIGN PROGRAM
THE CURRENT PROJECT
In the two years since the Planning Commission action regarding the Approved Project,
spatial organization and design details have evolved somewhat. However, the scale, massing and
mix of previously intended uses remain unchanged. Today, the same amount of demolition is
programmed and new construction will provide some 444,130 square feet of new retail and
related floor area for a total of 1,318,450 square feet within the new Mall upon completion, or
somewhat less than approved by the Planning Commission in the Approved Project. Figures 2,
3, 4 and 5 on pages 7, 8, 9 and 10 illustrate plans for Levels 1, 2, 3 and the Roof Level in the
Current Project.
Within the Current Project, a new northwest entrance via Sepulveda Boulevard will
become a prominent “front door” entrance to the Mall. The pedestrian connection to the transit
station adjoining West Slauson Avenue will be enhanced and landscaped. The new mall floor
and sections of the existing terrazzo floor will be updated with a stone tile and polished concrete
floor, providing contrast to brighter repainted walls and ceilings in lieu of the monochromatic
palette between floor, wall and ceiling in the existing Mall. Tile pavers throughout the
expansion’s second level, and in select areas of the existing second level, will provide a needed
updating. Full height, all-glass handrails will occur though the mall expansion and will replace
the steel picket and wire mesh handrails in the existing Mall. The existing food court will be
reconfigured and re-imaged, from new amenities and updated flooring to a ceiling renovation
and expanded entry vestibule and seating areas, and a fourth level entry and sky lobby
overlooking the new court will connect shoppers via elevator and cart escalator to a second level
Target entrance. Parking will expand over the roof of a new Target store in the southwest corner
of the property providing a total of 4,152 spaces on-site, or roughly 78 spaces more than the
minimum number established by the Planning Commission in the approval of the Approved
Project. Each of these improvements within the Current Project is in substantial conformance
with the Approved Project.
MASTER SIGN PROGRAM
The Master Sign Program (MSP) anticipated in the Planning Commission’s decision to
approve the Approved Project has now been submitted to the City's Planning Manager by
Westfield. In addition to an array of site, tenant and directional signage, the MSP includes a set
of freeway-oriented signs intended to be visible from the I-405 and SR 90 Freeways. The
III. The Current Project and the Master Sign Program
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 11
locations of these freeway-oriented signs are identified in Figure 6 on page 12 and include three
types of signs. Three vertical signs (Signs AP-A) are proposed to be oriented primarily to the I-
405 Freeway and would be located atop the expanded Mall structure's western façade
overlooking Sepulveda Boulevard. Each would provide two separate display panels
approximately 70 to 80 feet high and 35 feet wide facing generally opposite directions. Refer to
Figure 7 on page 13 for an illustration of these vertical signs in conjunction with the expanded
Mall building profile and in cross-section of the property looking east.
In addition, four façade-mounted sign panels (Signs AP-B) would be located on the
expanded Mall’s western façade and on the western ends of the Mall’s northern and southern
facades. These would be oriented to both freeways as appropriate and would vary in size from
14 feet high and 48 feet wide to 29 feet high and 64 feet wide. Finally, four pole-mounted
billboard-type signs (Signs AP-C) would be located in the parking lot north of the Mall primarily
addressing the SR 90 Freeway, which is elevated over the project site approximately 27 feet.
These pole-mounted signs would each be as high as 60 feet above grade. Three of these latter
signs would provide sign panels 14 feet high and 48 feet wide, while a fourth is proposed in a
more vertical configuration with three panels 40 feet high and 24 feet wide. The content on all
eleven freeway-oriented signs would consist of fixed copy and images (that is, they would not be
digitally sequencing) and each would be illuminated. Each would be operable from 5:00 A.M. to
daylight and from dusk to midnight.
All of these signage panels will be powered with solar collectors (photovoltaic or other
systems, as appropriate) made either a part of the respective signage structures or located
elsewhere on the property. As a result, operation of all eleven freeway-oriented signs will be
power grid and carbon neutral.
The freeway-oriented signs evaluated in this document represent the Applicant's intent
with regard to locations and scale. However, the depictions presented herein represent
conceptual illustrations rather than finished designs. Each such sign would comply with
applicable city, state and federal regulation with regard to size, materials and structure,
illumination and content.
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City of Culver City Fox Hills Mall Improvement Project
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Page 14
IV. ENVIRONMENTAL ASSESSMENT
The MND regarding the Approved Project that was adopted by the Culver City Planning
Commission on November 9, 2005 was based on an Initial Study prepared by the City. The
Initial Study was comprised of the State CEQA Environmental Checklist, a formal listing of
83 separate questions organized within 18 environmental categories, each of which was
addressed with supporting analysis and discussion and each concluded with a finding that the
Approved Project would have either no impact or less than significant impact. The Approved
Project was determined to have no potentially significant impacts.
As it has evolved in the ensuing two years since the Approved Project was approved, the
Current Project is virtually the same as the Approved Project, though roughly 2,000 square feet
smaller. And, while not detailed for consideration by the Planning Commission, the Master Sign
Program (MSP) that has now been submitted by Westfield was contemplated by the Commission
which made its preparation, submittal and approval by the City a condition of approval in
Resolution No. 2005-P109. Therefore, construction and operation of the Current Project should
have the same environmental consequences as documented relative to the Approved Project in
the City’s MND, except insofar as the effects of constructing and operating the freeway-oriented
signage within the MSP are concerned.
In its own right, the MSP would not be expected to effect the conclusions reached in the
MND for the Approved Project regarding any of several resource issues (specifically
Agricultural Resources, Biological Resources, Cultural Resources, Geology and Soils, or
Mineral Resources) since no such resources are associated with the project site or because, in the
case of geology and soils, the project’s effects including the MSP effects would be identical to
those without it.
With regard to the effects of project construction and operational behaviors on on- and
off-site infrastructure, systems and elements, the Current Project including the MSP will either
have the same effects as the Approved Project because the relevant conditions are the same
(specifically Hazards and Hazardous Materials, Hydrology and Water Quality) in either case, or
because the type and magnitude of project behavior will be the same (specifically Air Quality,
Land Use and Planning, Noise, Population and Housing, Transportation/Traffic, Public Services,
Recreation, Utilities and Services Systems). Any hazardous conditions as may be associated
with the project site will be common to either the Approved Project or the Current Project and
will not change, and the Current Project including the MSP will have the same propensity to use
hazardous materials as necessary in daily operations as the Approved Project because the uses IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 15
and sizes of uses are virtually identical. The MSP will not affect the amount of rainfall that falls
on the project site nor the design of drainage improvements planned for the property or the
associated affects on water quality. The MSP will not cause the Current Project to generate more
traffic than was forecast for the Approved Project because the traffic generation for the
Approved Project evaluated in the MND assumed that the expanded Mall would attract the very
trips from the freeways that the MSP is designed to attract. Thus, air pollution emissions from
vehicles driving to and from the Mall would not change. Vehicle noise would not change.
Effects on roadway and intersection capacity would not change. Demand for public services,
public utilities and recreation would not change since the respective signs would not generate
demand for such services, facilities or utilities or because, as in the case of electric power, the
signs will be powered entirely by power grid-neutral solar energy. Similarly, the Current Project
with the MSP can be expected to have much the same land use relationship with the array of
surrounding land uses as would the Approved Project since the profile of surrounding uses is
fully compatible with major urban retail activity and expected associated advertising and
signage. With regard to population and housing, the MSP would be passive with respect to
population growth and neither the Approved Project nor the Current Project including the MSP
can be expected to displace any existing population or housing.
Notwithstanding the foregoing conclusions, the MSP could have the potential to affect
three environmental subjects: Aesthetics, Transportation Safety and Global Climate Change.
The MSP's potential effect on Aesthetics is apparent due to the MSP's evident intent to be visible
from the freeways, and questions regarding Transportation Safety arise out of concern that such
visibility could translate into driver distraction. Global climate change is included here because
it is a comparatively recent issue, was not included in the City's 2005 MND, and is not yet
included in the State CEQA Environmental Checklist. Each of these topics is addressed
separately below.
AESTHETICS
As there are no designated scenic highways or recognized scenic resources in the project
locale, implementation of the proposed MSP could not be expected to adversely affect any such
resources. However, the 11 freeway-oriented signs proposed within the MSP are intended to be
visible from the I-405 and SR 90 freeways as well as local arterials, and as a result, would likely
also be visible from other parts of the surrounding community. Therefore, this assessment is
intended to determine where such signage might be visible from and whether it could
significantly alter the visual character of the locale as seen from a wide variety of perspectives
reflecting the full range of community sensitivity IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 16
For this assessment, nine view locations were selected by City staff as representative of
widely diverse perspectives associated with different land uses and topographic character in the
locale. The nine view locations are listed as follows and are identified by number in Figure 8 on
page 17:
View 1: State Route 90 Eastbound to Interstate 405 Southbound Transition (Figure
9),
View 2: Residential Neighborhood along Westchester Bluffs at Riggs Place near
Kentwood Avenue (Figure 10),
View 3: Interstate 405 Northbound at Slauson Avenue exit (Figure 11),
View 4: Residential Neighborhood at 11505 Segrell Way (between Berryman
Avenue and Slauson Avenue (Figure 12),
View 5: Residential Neighborhood at Hannum Avenue and Bush Way (Figure 13),
View 6: Residential Neighborhood at 10751 Cranks Road: Elevation 154 feet
(Figure 14),
View 7: Office Depot Parking Lot at 5640 Sepulveda Boulevard (Figure 15),
View 8: Slauson Avenue at State Route 90 West Entrance (Figure 16), and
View 9: Los Angeles County Assessor’s Office at 6120 Bristol Parkway (Figure
17).
Three of the view locations represent freeway or arterial views: Views 1, 3 and 8. Views
2, 4, 5 and 6 are located in residential neighborhoods. Views 7 and 9 are located in retail or
business commercial districts. Collectively these vantages are believed to represent each of the
perspectives that may be characteristic of the particular community surrounding the Fox Hills
Mall property. At each of the view locations digital photographs were taken toward the Mall
property, which could be seen in the camera lens in some but not all views. Then with the aid of
global information systems technology, the digitized view locations were integrated with the
digitized Mall expansion architectural designs and the placement and dimensions of the proposed
freeway-oriented signage to produce accurate photo simulations of the expected views from each
of the nine vantages.
In addition, at the direction of City staff, each of the three taller signs proposed atop the
new west end of the expanded Mall structure along Sepulveda Boulevard were simulated at four
different heights: 120 feet above grade as proposed by the applicant, and 100 feet, 80 feet and 50
feet above grade, respectively. Theses simulations are presented in Figures 9 through 17 on
pages 18 through 26. Each of these figures is presented with the view location mapped in the
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IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 27
upper left hand position, while the photograph of existing views is presented in the upper center
position. The simulation of the signs as proposed with the three tallest signs at 120 feet above
grade is in the upper right position, and the simulations of the three taller signs at 100, 80, and 50
feet, respectively, occupy the lower left, center and right positions. In two instances, Views 4
and 9, none of the signage would be visible even at the highest heights, and in these instances
simulations at the lower heights were not completed. No copy or graphic images are represented
on any of the sign panels. Where the sign panels would be visible from the respective vantages,
they are represented in the respective figures by an artificial orange color so that they can be
made out in the figure; however, there is no intent that the actual signs would be so colored.
Also, in instances where the signs could not be visible due to intervening buildings, landscape or
topography, the hidden signs are depicted in their accurate locations in a bright yellow color so
that the reader will understand why they would not be seen.
Freeway/Arterial Views. From the two freeway views, one at the eastbound SR-90 to
the southbound I-405 transition (View Location 1) and the other at the northbound off-ramp from
the I-405 to Sepulveda Boulevard (View Location 3), the three tallest signs are plainly visible at
the proposed 120-foot height and are increasingly obscured by intervening buildings or trees at
the lower heights. At 50 and 80 feet above grade, respectively, little of any of the signs would be
visible, while at 100 feet the upper portions of each sign would be visible. At the proposed
height of 120 feet, the signs do not appear out of scale with the surrounding built environment
and during the daytime or when illuminated at night would not seem to exceed reasonable
expectations for advertising displays in an urban setting.
From the arterial location at the terminus of SR-90 at Slauson Avenue ( View Location
8), relatively little of any of the signs would be visible even at the highest proposed heights due
to intervening Mall building mass and trees. Virtually none of the tallest signs along Sepulveda
Boulevard would be visible at the lower heights, though the billboard-types sign along the SR-90
alignment would be quite visible to drivers on the freeway, itself.
Views from Residential Neighborhoods. Four views from residential neighborhoods
were simulated, two from view locations at the edge of higher terrain from which panoramic
views are available (View Locations 2 and 6) and two from view locations within
neighborhoods on the urban plain characteristic of most of Culver City (View Locations 4 and
5). From the two elevated vantages, the project site is in the intermediate distance. From the
Kentwood location (View Location 2), visibility of the three vertical signs proposed along
Sepulveda Boulevard increases from barely visible at the lowest height to plainly visible at the
highest 120-foot height, though the billboard-type signs would not be visible at all. At a
maximum height above grade of 120 feet, the three signs appear to have a height close to that of
the existing Radisson Hotel though significantly less mass. While plainly visible and they would
add new content to the view but would not substantively alter the visual character of the entire IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 28
view. They also would be visible when illuminated at night, and would be seen against a rather
highly illuminated urban backdrop. Despite being visible within that backdrop, they would not
be expected to redefine the nature of the nighttime view. It should be noted that in the event the
City approves the Entrada Office Tower Project proposed along Centinela Avenue as depicted in
the map in Figure 9, that proposed structure would obstruct views of the northern-, most sign
along the Sepulveda Boulevard frontage. As this vantage is moved northerly and westerly along
the bluff face, the Entrada structure would obstruct views of the proposed signs more completely.
From the Cranks Road vantage (View Location 6), visibility of the three vertical signs
also changes from barely visible to plainly visible as the height increases and three of the four
billboard signs would also be visible in the foreground. As in the case of views from the
Kentwood neighborhood, the visibility of the proposed signs, even at the highest heights, would
not be expected to significantly alter the character of the existing view during daytime or
nighttime.
Views from the Segrell Way and Hannun Avenue vantages ( View Location 4 and 5) will
not permit visibility of any of the sign with in the proposed MSP at any heights due to low
viewing angles, distance and the presence of taller intervening structures and trees. It is believed
that this condition is typical; of views toward the Mall from residential areas located below the
bluffs and Baldwin Hills.
Views from Commercial Areas. The two remaining view locations were taken from the
Office Depot parking lot immediately north and across Slauson Avenue from the Mall property
(View Location 7) and from within the business park east of the Mall along Bristol Parkway
(View Location 9). Due to close proximity to the northernmost proposed billboard-type sign at
the Office Depot vantage, this sign would be quite visible when not screened by trees, while the
even at 120 feet above grade the three vertical signs would maintain a relatively distant
perspective. At lower heights, the signs recede to only limited visibility at most. Due to the
relatively larger scale of structures in the Bristol Parkway area , little if any visibility of the signs
proposed in the MSP would be expected except as may be available from the higher floors of
west-facing buildings.
In conclusion, despite the intent of the proposed freeway-oriented signs in the subject
MSP to be visible, they would not be universally visible from all vantages within the surrounding
community. Evaluation of simulations of the proposed signage program from a reasonable
selection of vantages representing the range of perspectives and sensitivities in this community
indicate that it will not be visible at all from large tracts of residential neighborhoods occupying
the urban plain in Culver City, that they would not exceed current expectations for advertising
displays in the commercial sectors of an urban environment, and that while plainly visible at the IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 29
highest proposed heights they would not significantly alter the character of existing views from
hillside locations during the daytime or at night.
TRANSPORTATION SAFETY
“Outdoor advertising has been a fixture on America’s roadways since there were
roadways. From the “Burma Shave” signs and “Mail Pouch Tobacco” signs of the 1920’s, to the
jumbo neon spectaculars and computer controlled images on skyscraper curtain walls that grace
Times Square, Hollywood and Las Vegas today, outdoor advertising has always been present in
our built environment. Although the pros and cons of billboards have been debated for more
than 50 years, it is perhaps their influence on traffic flow and safety that has been most
controversial.”|1010|
Notwithstanding differences of opinion may exist regarding billboards’ and other
roadway-oriented signs’ effects on traffic safety, the Legislature of the State of California
included the following language in the Outdoor Advertising Act and Regulations, as amended:
“The Legislature finds:
(a) Outdoor advertising is a legitimate commercial use of property adjacent to roads
and highways.
(b) Outdoor advertising is an integral part of the business and marketing function, and
established segment of the national economy, and should be allowed to exist in
business areas, subject to reasonable controls in the public interest.”
The Outdoor Advertising Act precludes displays that obstruct motorists’ visibility of
traffic signs, or appear to simulate or imitate traffic safety signs giving warning to motorists, or
include red or blinking or intermittent light likely to be mistaken for a warning or danger signals,
or any associated illumination that could be considered vision impairing due to brilliance, or that
is placed upon trees or painted upon rocks or other natural features. It also limits sign animation
or message/image sequencing, sometimes called flashing, on digital or electronic signs to
changes in content frequency of not less than every four seconds. The Act also limits the size of
advertising displays that promote businesses, goods or services not located on the property on
which the advertising is displayed to a maximum area of 1200 square feet and maximum height
of 25 feet and a maximum length of 60 feet. However, no such size limitations exist for
advertising displays on the property for which businesses, goods or services are being advertised.
|1010| "Outdoor Advertising Act and Regulations,” 2005 Edition. California Department of Transportation, Division
of Traffic Operations, Outdoor Advertising Program. IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 30
The thrust of each of these restrictions is to preserve the traffic safety value of traffic signs and to
insure that advertising displays do not interfere with driver visibility or vision, as well as to
safeguard the public interest in natural features as may exist along the State’s highways, all while
preserving the right to advertise as a reasonable use of commercial property.
While the Outdoor Advertising Act appears to establish an acceptable balance between
the right to advertise and driver safety, the advent of new technologies that have introduced
large-scale, very bright, high resolution signs with changing images to the roadside have added
to the concern about advertising causing driver distraction. The subject has only begun to be
examined in the scientific literature and clear consensus has not emerged. Two studies prepared
for or submitted to the Foundation for Outdoor Advertising Research and Education were
recently released. The first, "A Study of the Relationship between Digital Billboards and Traffic
Safety in Cuyahoga County, Ohio,"|1010| concluded: “The conclusion of this study is that digital
billboards have no statistical relationship with the occurrence of accidents. The analysis and
statistics in Cuyahoga County demonstrate that accidents are no more likely to occur along
sections of Interstate routes near digital billboards than those without them.” The second study,
“Driving Performance and Digital Billboards: Final Report,”|1010| stated its conclusion as follows:
“Although there are measurable changes in driver performance in the presence of digital
billboards, in many cases these differences are on a par with those associated with everyday
driving, such as the on-premises signs located at businesses. Conventional billboards were shown
both in the current study and in the Charlotte study to be very similar to baseline and comparison
events in terms of driver behavior and performance; thus, the design of digital billboards should
be kept as similar as possible to conventional billboards.”
A third study was commissioned by the Maryland State Highway Administration
specifically to peer review the two studies just cited. This last study, “A Critical, Comprehensive
Review of the Two Studies Recently Released by the Outdoor Advertising Association of
America”|1010| concluded that acceptance of the conclusions in the two previously cited studies was
premature and inappropriate. The author concluded by saying ,”…that no research yet published
can fully answer the question of whether EBBs (electronic billboards) create a sufficient
distraction of drivers’ attention that they should be banned or strictly regulated under certain
roadway, environmental, and traffic conditions.”
|1010| "A Study of the Relationship between Digital Billboards and Traffic Safety in Cuyahoga County, Ohio," Tantala
and Associates, 2007. |1010| “Driving Performance and Digital Billboards: Final Report," Virginia Tech Transportation Institute Center for
Automotive Safety Research, 2007. |1010| “A Critical, Comprehensive Review of the Two Studies Recently Released by the Outdoor Advertising
Association of America," The Veridian Group, 2007. IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 31
Against this background of regulation and study, the MSP submitted by the Applicant
consists of 11 separate freeway-oriented sign elements: three vertically oriented sign structures to
be mounted atop the roof of the expanded Mall (two advertising panels per sign structure), four
façade mounted advertising panels, and four billboard-type advertising displays (three with two
advertising panels per billboard structure and the fourth with three panels). As each of these
advertising displays is proposed on the Fox Hills Mall property and would only be advertising
establishments located, or goods and services available, within the Mall or on the premises, these
signs do not appear to be limited in size by the Outdoor Advertising Act. While all of these signs
are intended to be seen from adjoining roadways and freeways, none would interfere with driver
visibility of traffic conditions, signals or signs. They would not simulate traffic signs in a
manner that could cause driver confusion and they would not project intense beams of light that
might interfere with driver vision. And notwithstanding insufficient evidence to conclude that
digital or electronic signs with image sequencing do not cause driver distraction leading to higher
accident risk, none of the signs proposed in the subject MSP would be digital. Even though the
Outdoor Advertising Act sanctions sign animation with changes no more frequent than every
four seconds, all freeway-oriented signs in this MSP are proposed as illuminated fixed image
advertising displays with no animation or electronic image changes.
On the basis of the foregoing circumstance, it is concluded that the freeway-oriented
signs within the proposed MSP would achieve the balance between the recognized right to
advertise in commercial areas and driver safety intended by the Outdoor Advertising Act. No
adverse impact on traffic safety is anticipated.
GLOBAL CLIMATE CHANGE
The subject of global climate change is one that has arisen relative to specific projects
since the Planning Commission's approval of the Approved Project in November 2005. Global
climate change refers to changes in average climatic conditions on Earth as a whole, including
temperature, wind patterns, precipitation and storms. Greenhouse gases (GHGs) are compounds
found in the Earth’s atmosphere that play a critical role in determining the Earth’s surface
temperature. These gases allow high-frequency solar radiation to enter the Earth’s atmosphere,
but retain the low frequency energy which is radiated back from the Earth to space, resulting in a
warming of the atmosphere. This phenomenon is known as the greenhouse effect. The
anthropogenic (human) contribution to global climate change attributable to emissions of GHGs
is currently one of the most important and widely debated scientific, economic and political
issues in the United States.
An understanding of the fundamental processes responsible for global climate change has
improved over the past decade, and predictive capabilities are advancing. However, there remain IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 32
significant scientific uncertainties, for example, in predictions of local effects of climate change,
occurrence of extreme weather events, effects of aerosols, changes in clouds, shifts in the
intensity and distribution of precipitation, and changes in oceanic circulation. Due to the
complexity of the Earth’s climate system, the uncertainty surrounding climate change may never
be completely eliminated. Because of these uncertainties, there continues to be significant
debate as to the extent to which increased concentrations of GHGs have caused or will cause
climate change, and with respect to the appropriate actions to limit and/or respond to climate
change. In addition, it is impossible to link a single development project with future specific
climate change impacts.
In response to growing scientific and political concern regarding global climate change,
California has recently adopted a series of laws to reduce both the level of GHGs in the
atmosphere and to reduce emissions of GHGs from commercial and private activities within the
State. Most importantly among these, in September 2006, Governor Arnold Schwarzenegger
signed the California Global Warming Solutions Act of 2006, also known as Assembly Bill 32
(AB32), into law. AB32 commits the State to achieve the following:
• Reduce current GHG emissions to 2000 levels by 2010 (which represents an
approximately 11 percent reduction from emissions projections if current GHG
production rates are not altered, or so called “business as usual”)
• Reduce current GHG emissions to 1990 levels by 2020 (25 percent below “business
as usual”)
• Reduce California's statewide GHG emissions to 80 percent below 1990 levels by
2050
To achieve these goals, AB32 mandates that the California Air Resources Board (CARB)
establish a quantified emissions cap, institute a schedule to meet the cap, implement regulations
to reduce Statewide GHG emissions from stationary sources, and develop tracking, reporting,
and enforcement mechanisms to ensure that reductions are achieved.
At present, there are no state or local agency greenhouse gas emission significance
thresholds. AB32 did not set a significance threshold for GHG emissions, although the EPA,
CARB or another agency may issue regulations at some point to set forth significance criteria for
CEQA analysis. In the interim, none of the CEQA Guidelines, the City of Los Angeles CEQA
Thresholds Guide, the South Coast Air Quality Management District's (SCAQMD) CEQA Air
Quality Handbook, the SCAQMD Air Quality Management Plan, or any other relevant source of
authority for air quality impacts sets forth significance thresholds for GHG emissions. IV. Environmental Assessment
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 33
AB32 suggests that there is a de minimis level of emissions below which CARB will not
regulate. AB32 directs CARB to “recommend a de minimis threshold of greenhouse gas
emissions below which emissions reduction requirements will not apply” by January 1, 2009.|1010| In
addition, AB32 charges CARB with meeting the statewide target “in a manner that minimizes
costs and maximizes benefits for California’s economy, improves and modernizes California’s
energy infrastructure and maintains the electric system reliability, maximizes additional
environmental and economic co-benefits for California, and complements the state’s efforts to
improve air quality.”|1010| It directs CARB to begin emissions monitoring and annual reporting by
January 1, 2008, starting first with those emissions sources “that contribute the most to statewide
emissions.”|1010| As a result, some projects may be permitted to emit GHGs without having a
significant impact.
Since the subject of global climate change was not addressed in the City’s 2005 MND, it
is appropriate to address it here relative to the MSP proposed for the Fox Hills Mall.
Implementation of the MSP has the potential to generate GHG emissions during construction as
well as operation. On-site construction activities related to installation of the signage would
result in GHG emissions from the combustion of fossil fuels in construction equipment.
However, due to the short duration of construction activities emissions are likely to be minimal.
Given that the design of the project has resulted in a reduction of 2,000 square feet of finished
retail space, it is expected that emissions from construction of the proposed project including the
MSP would be on the same order as those originally contemplated for the Approved Project.
Therefore, GHG emissions due to construction of the Current Project including the MSP would
be on the same order of those that would be emitted during construction of the Approved Project.
Following construction, operation of the MSP’s freeway-oriented signage will be
powered entirely via solar energy, through the installation of photovoltaic or other appropriate
collectors either as part of the signage structures, themselves, or located elsewhere on the Mall
property. As a result, the environmental consequences of the freeway-oriented signage relative
to global climate change is that it will generate no net GHG emissions, on an annual basis.
Relying on renewable energy sources, such as solar, is a proven strategy for reducing or
eliminating GHG emissions, is supportive of the State’s goals, and results in a project-related
emissions profile that is better than “business as usual”. This progressive commitment should
serve as a positive example in the transition to sustainable times.
|1010| H&SC § 38561(e). |1010| H&SC § 38501(h). |1010| H&SC § 38530(b)(1).
City of Culver City Fox Hills Mall Improvement Project
PCR Services Corporation December 2007
Page 34
V. CONCLUSION
Based on the specific environmental analyses previously presented in Section IV, the
proposed Master Sign Program would not cause new significant environmental impacts upon the
three issue areas for which the proposed project might be expected to generate concern:
Aesthetics, Transportation Safety or Global Climate Change. Moreover, when the project that
was approved by the Planning Commission in November 2005 (Approved Project) is compared
with the project as it has evolved in the subsequent two years (Current Project), the Current
Project is so similar to the Approved Project, albeit slightly smaller, that it is in substantial
conformance with the Commission’s approval. Therefore, with respect to each of the other 15
general issue areas in the State CEQA Checklist the Current Project’s impacts would not be
different from those attributed to the Approved Project by the Mitigated Negative Declaration
adopted by the Commission at the time of its approval, each of which were determined to be less
than significant.
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