City of Culver City, California
Agenda Item Report
Meeting Date: 04/05/10 Item Number: J-1
CITY COUNCIL/REDEVELOPMENT AGENCY BOARD JOINT AGENDA ITEM:
Adoption of City Council and Redevelopment Agency Board Resolutions
Transmitting the Official City and Agency Combined Response to the 2010 Draft
Supplemental Environmental Impact Report for the Proposed 2009 West Los
Angeles College Facilities Master Plan.
Contact Person/Dept.: Susan Yun/
Planning - CDD
Phone Number: (310) 253-5755
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Action Item: [x] Attachments: [x]
Commission Action Required: Yes [] No [x] Date: _______________
Public Notification: On 3/22/10 notice was mailed to Homeowners Associations of Culver
Crest, Raintree (townhome and condominiums), Tara Hills, Lakeside Village, and Blair
Hills; Property owners, occupants, and businesses along either side of Jefferson
Boulevard (from Overland Avenue to Hetzler Road); the Culver City Chamber of
Commerce, and the Culver City Unified School District. On 3/25/10 and 4/1/10 a notice
was published in the Culver City News; (Email) Meetings and Agendas – City Council
(04/01/10); (E-Mail) Meetings and Agendas – Redevelopment Agency (04/01/10).
Department Approval:
Sol Blumenfeld (03 /30/10)
Charles D. Herbertson (03/31/10)
City Attorney Approval:
Carol Schwab (by H. Baker) (04/01/10)
Agency General Counsel Approval:
Murray Kane (03/31/10)
Chief Financial Officer Approval:
Mark Scott (by M. Noller) (04/01/10)
City Manager Approval:
Mark Scott (04/01/10)
RECOMMENDATION:
Staff recommends that the City Council and Redevelopment Agency Board adopt
respective Resolutions, transmitting the official City and Agency combined response
to the 2010 Draft Supplemental Environmental Impact Report for the Proposed 2009
West Los Angeles College Facilities Master Plan.
BACKGROUND:
The West Los Angeles College (the “College”) campus is located adjacent to Culver
City near the intersection of Overland Avenue and Freshman Drive. The main area
of the 72-acre campus is in an unincorporated area of Los Angeles County and is
bordered on the north and northeast by the Baldwin Hills and the oil field area; by
Raintree, Tara Hills and Lakeside Village multi-family residential areas on the west;
and by Culver Crest single-family and two-family residential area on the south.
City of Culver City, California
Agenda Item Report
Although the main College campus is not within Culver City’s corporate limits, it is
within the sphere of influence of Culver City as identified in Culver City’s General
Plan for the purposes of addressing land use compatibility, coordinating land use
policy with adjacent jurisdictions, and proposing land use policy for areas of potential
annexation.
Following the Los Angeles Community College District’s (the “District”) approval of a
2005 Facilities Master Plan, the College purchased the 9-acre 10100 Jefferson
property located within Culver City’s corporate limits for the purpose of constructing
a secondary access road that is a required mitigation measure identified in the EIR
for the 2005 Facilities Master Plan. Further, the 10100 Jefferson site is within the
Culver City Redevelopment Agency’s Redevelopment Project Area (Component
Area 4) and is subject to the Redevelopment Plan for the Project. A Design for
Development for the Jefferson Boulevard Industrial Area has been adopted by the
Agency pursuant to the Redevelopment Plan and governs this site.
2010 Draft Supplemental Environmental Impact Report
For purposes of the California Environmental Quality Act (CEQA), the District is the
lead agency. Pursuant thereto, The District, in conjunction with the College, has
prepared and circulated a Draft Supplemental Environmental Impact Report (the
“Draft SEIR”), dated March, 2010, for the proposed 2009 Facilities Master Plan that
is intended to guide the development of the College to Year 2022. The purpose of
the Draft SEIR is to evaluate the environmental effects pursuant to the CEQA
associated with the modifications to the previously approved 2005 College Facilities
Master Plan. The 2005 Master Plan was approved, and the 2005 Final
Environmental Impact Report (the “Final EIR”) was certified by the District in January
2005.
The public comment period for the Draft SEIR started on March 8, 2010 and ends on
Wednesday, April 21, 2010. Due to the short comment period provided (45 days) on
March 10, 2010 Culver City requested the District extend the review period to 90
days in order to give City staff and the public sufficient time to review the Draft SEIR,
the College’s 2009 Master Plan, and other pertinent documents. On March 23, 2010
the City received a letter (Attachment 1) from Tina Macica of BuildLACCD,
purportedly representing the District, denying the request for additional review time.
A public workshop was held by the College on March 16, 2010 and a second
workshop is scheduled for April 8, 2010 at 6:00 p.m. on the College campus.
Due to the very short review period adopted by the District, the City was unable to
hold a separate meeting for City Council and community input on the Draft SEIR
prior to formulating detailed comments for City Council and Redevelopment Agency
Board consideration as is our standard practice. The purpose of tonight’s meeting is
to consider staff’s recommended comments, receive public comment, and then City of Culver City, California
Agenda Item Report
accept or modify these comments for transmittal to the District as Lead Agency prior
to the public comment deadline of April 21, 2010.
DISCUSSION:
Project Description
Major variations between the 2009 College Master Plan Draft SEIR and the
previously approved 2005 Master Plan Final EIR:
• The construction period has been extended from 2010 to 2013
• Projected student enrollment and College employment in the horizon planning
year 2022 has been changed. Student enrollment is now anticipated to be
greater (22,360 compared to 18,904) and College employment is anticipated
to be less (664 compared to 1,248).
• The College is now discounting impacts from increased enrollment by 31.6%
citing a rapid growth in on-line enrollment and anticipating a continuation of
that trend in the future. This, they contend, results in a reduction in on-
campus student population from the 2005 Master Plan (15,300 compared to
18,904). The 2005 Final EIR did not discount impacts from student
enrollment growth for students attending on-line classes.
• The College has altered its building plan resulting in a net increase of 62,356
square feet of building space bringing the total building space on the campus
to 741,464 square feet (Attachment 2, Table 2.2 from the Draft SEIR
summarizes the changes in building area). The changes to the building plan
include:
o A revised, larger Physical Education structure now referred to as the
Allied Health and Wellness Building (131,000 square feet compared to
63,000 square feet )
o A new central plant
o Demolition of additional modular classrooms
o Relocation and funding of the media center now referred to as the
Watson Center (400 seat theater) from south of the Math and Sciences
building to east of the north parking structure
o Redesign of the Student Services/High Tech Classroom to now be
comprised of two separate buildings: the Student Union (located at the
same location) and the expanded Technology Learning Center (75,000
square feet compared to 40,000 S.F.) now located south of the Math
and Science building. The new Technology Learning Center will be
135 feet tall.
o A smaller Student Services building in lieu of a larger combined
Student Services/Administration building
o Replacement of a planned soccer field with a new softball field
o Smaller north parking structure resulting in fewer on campus parking
spaces than anticipated in the 2005 Master Plan (2,659 compared to City of Culver City, California
Agenda Item Report
4,368, a net reduction in on campus parking spaces of 1,709 from the
number of spaces proposed in the 2005 Master Plan Final EIR)
The Draft SEIR does not consider project alternatives to the proposed Master Plan
although the original Final EIR for the 2005 Master Plan did consider three
alternatives.
Review of the Draft SEIR
A City staff team, including Community Development, Public Works, and the City
Attorney Departments evaluated and, where appropriate, prepared comments on the
adequacy of the Draft SEIR. Staff’s detailed comments are shown in “Exhibit A” of
the proposed Resolutions (Attachment 3).
The following is a summary of the major issues and concerns with the Draft SEIR:
Project Description – The College makes several assumptions in the Draft SEIR
regarding on-campus student population that they contend results in
corresponding reductions in impacts evaluated in the 2005 Final EIR. The
College assumes a reduction in on-campus student population due to an
anticipated 31.6% of students enrolling in on-line classes. The Draft SEIR fails to
substantiate this percentage reduction by adequately explaining how this
percentage figure was derived. In addition, the College assumes that students
enrolled in on-line courses will not visit the campus; however, it seems likely that
many will visit to use the campus library and other facilities as well as to visit the
campus during the registration period. This is a major discrepancy as the
magnitude of many of the impacts is based on anticipated on-campus student
population. Therefore, if this number is understated (as it appears to be), many
impacts will, therefore, be understated, and the corresponding proposed
mitigation measures will be inadequate because they are designed for a lesser
impact than actually occurs.
Traffic and Access – According to the Draft SEIR, traffic impacts are expected to
remain the same or decrease significantly in 2022 because of the following
reasons:
• More students are taking on-line courses;
• The College’s site specific trip generation rates are lower than the trip
generation rates used in the 2005 Final EIR; and,
• Employment projections have dropped with no explanation as to why.
The 2010 Draft SEIR indicates that these factors make the 2005 Final EIR
analysis conservative, and no traffic analysis (beyond that already conducted for
the 2005 Master Plan) is required. Sufficient supporting data was not provided to
justify the lower trip generation rates, the lower on-campus traffic due to on-line
courses, and the lower trip generation rates for employees.
City of Culver City, California
Agenda Item Report
In addition, since 2006, Culver City has required surrounding jurisdictions
including the District, the County of Los Angeles, and the City of Los Angeles to
use Los Angeles City Department of Transportation (LADOT) traffic impact
analysis criteria to analyze the traffic impacts of developments on intersections in
Culver City. Using LADOT criteria for the 2005 Final EIR, West Los Angeles
College would have impacted three additional intersections in Culver City. Table
3-44 in the Final EIR shows the intersections of Hannum Ave./Playa St.,
Sepulveda Bl./Playa St.-Jefferson Bl. and Bristol Parkway/Slauson Ave. would be
impacted using LADOT criteria and the traffic counts from the 2005 traffic study.
Even if the reduced on-campus student population is accepted as accurate, a
traffic study is required to analyze these three intersections. However, because
of the significant expansion of the project and the additional traffic that is likely to
be generated as a result, a full traffic study is required that analyzes all of the
intersections reviewed with the 2005 Master Plan as well as potential impacts to
the new intersection of the newly constructed secondary access road and
Jefferson Boulevard using LADOT criteria and appropriate mitigation measures,
if needed, must be specified.
The lack of or inadequate explanation for the use of lower trip generation rates
coupled with the inadequate explanation of the derivation of the percentage
reduction in on-site student population discussed above under Project
Description along with the failure of the College to conduct a traffic study and
properly analyze traffic impacts using LADOT criteria as required by Culver City
since 2006 (see Attachment 4, Letter addressed to Los Angeles Community
College District dated October 31, 2006) point to a serious inadequacy in the
Draft SEIR.
Parking – The Draft SEIR proposes to reduce on-campus parking by 1,727
spaces compared to the 2005 Final EIR. This parking reduction is based on an
assumed reduction in on-campus student population (based upon an increase in
students taking online classes) that is not adequately explained and supported
with scientific or statistical evidence. Therefore, the proposed parking may prove
to be inadequate.
In addition the Draft SEIR requires modification to the College’s parking plan only
if the cause of student parking in the neighborhood is due to a lack of parking on
campus. However, the student parking in the neighborhood is due, at least in
part, to the cost of parking on campus and the elimination of free parking on
public streets within the campus area. This impact is not discussed or analyzed
in the Draft SEIR.
Together, the lack of support data for the reduction in parking needs and the
failure of the document to analyze a major cause of parking impacts to the
surrounding residential areas constitute an inadequacy in the document.
City of Culver City, California
Agenda Item Report
Views, Light and Glare – The proposed Learning Arts Center will be the tallest
building on campus at 135 feet in height, far exceeding building height
restrictions in Culver City. Additionally, several other proposed buildings will
exceed Culver City’s 56 foot height limit including the 59 foot Allied Health and
Wellness Building, the 64 foot Watson Center, and the 66 foot North Parking
Structure. The Draft SEIR provides no view analysis to adequately access the
view impacts from these new structures.
Noise – The College proposes a significant change to a mitigation measure in the
2005 Final EIR that currently limits construction hours to between 8 a.m. and 6
p.m. weekdays and 9 a.m. and 4 p.m. Saturday, to a less restrictive time period
of between 7 a.m. to 8 pm Monday through Saturday. This is a major concern for
Culver City residents that live south and west of the College. Although the Draft
SEIR indicates this is consistent with Los Angeles County’s Noise Ordinance
(Section 12.08 of the Los Angeles County Code), Los Angeles County’s Noise
Ordinance actually restricts construction to Monday through Saturday to the
hours between 7 am and 7 pm. Therefore, the proposed construction hours are
not in compliance with Los Angeles County requirements.
Section 9.07.035 of the Culver City Municipal Code restricts construction that
may disturb residential areas to the hours of 8 am to 8 pm Monday through
Friday, 9 am to 7 pm on Saturday, and 10 am to 7 pm on Sunday. Because the
construction noise will impact Culver City residents and not unincorporated Los
Angeles County residents, the more restrictive Culver City limits should be
applied (as compared to County regulations). In any event, the failure of the
proposed construction hours in the Draft SEIR to comply with the 2005 Final EIR
Construction Hour terms and County’s or the City’s Ordinances and to properly
evaluate the environmental impacts of such a change is a major inadequacy of
the document.
Land Use - The College is bound by the land use restrictions established by the
Culver City Redevelopment Agency, a state agency, for the land area included
with the Redevelopment Project Area. The 10100 Jefferson site, where the new
access road is located and the remnant vacant 9-acre parcel, is located entirely
within the boundaries of Culver City. This site is also located within the Culver
City Redevelopment Plan (Component Area No. 4). Further a “Design for
Development (DFD) for the Jefferson Boulevard, Industrial Area” (which includes
the 10100 Jefferson site) was adopted by the Redevelopment Agency as
authorized by the Redevelopment Plan and to implement the Redevelopment
Plan to guide and govern future development of the site. The DFD includes
various land use standards and provisions and requires all new developments by
any private or public entity to be approved by the Redevelopment Agency. The
Draft SEIR fails to discuss, provide information and acknowledge the
Redevelopment Agency Plan and Design for Development for the Jefferson
Boulevard Industrial Area.
City of Culver City, California
Agenda Item Report
The Draft SEIR indicates that the 10100 Jefferson site is being added in the
proposed 2009 Facilities Master Plan. However, the Draft SEIR states nothing is
specifically proposed for the 10100 Jefferson site at this time (other than the new
road and an entry way monument) and additional environmental review will be
required once plans are identified. As such, the Draft SEIR does not contain an
in-depth project level analysis of the 10100 Jefferson site and therefore must
conduct a full CEQA analysis once a project is known.
The Draft SEIR indicates the College acquired the 10100 Jefferson site to allow
the construction of the access road to the existing College campus from
Jefferson Boulevard as shown in the 2005 Master Plan. However, the 9-acres
available on this site also presented opportunities to the College. The College
delivered two requests for proposals to prospective developers for a joint
occupancy lease of the 10100 Jefferson site. The College anticipated a mixed
use development with uses complementary to the College. When no responses
were received to either request for proposal, and based on the current economic
climate, the College determined that development of the 10100 Jefferson site as
anticipated is no longer reasonably foreseeable. As a result of this conclusion,
the College indicates in the Draft SEIR that they intend to undertake a feasibility
study for the site to identify an appropriate use. Possible uses being considered
are college-related facilities, including training classrooms, alternative energy
equipment and solar arrays. Additional environmental review will be required
once plans are identified.
The Draft SEIR does not have any discussion regarding the compatibility with the
Culver City Redevelopment Plan (Component Area No. 4) and Design for
Development (DFD) for the Jefferson Boulevard Industrial Area. Therefore, the
Draft SEIR is incomplete and must be re-circulated for public review with this
information.
Second Access Road - A valid environmental impact report is required prior to
consideration of the proposed Project by the Agency. The 2005 Final EIR is not
adequate for this purpose, and a new analysis of the access road must be
included in the Draft SEIR because, pursuant to the requirements of Public
Resources Code Section 21166, substantial changes have been proposed in the
project, substantial changes will result in major changes to the environmental
impact analysis, and new information not known in 2005 (including the massive
increase in intensity of the Project) is now available.
Use of College Facilities - The Draft SEIR would result in prohibiting Culver City
residents from using College facilities despite that fact that such use was
included in the 2005 Final EIR as a mitigation measure.
Finally, the Draft SEIR contains a number of errors and omissions that make it
difficult for the City and concerned residents to fairly evaluate the analysis and City of Culver City, California
Agenda Item Report
conclusions in the document. Specific and detailed comments of the concerns are
listed in Exhibit “A” of the proposed Resolution.
FISCAL ANALYSIS:
The Draft SEIR is not specific enough to estimate the potential fiscal impacts to the
City and the Agency from the proposed project. However, unmitigated and
significant impacts from expansion of the College could result in significant costs to
the City and its residents in the future. The types of fiscal impacts that the City can
expect if the revised Master Plan is implemented include, but are not limited to:
increased traffic delay, the need for increased parking enforcement and traffic
engineering to address student parking in residential zones, and increased demand
for emergency facilities and personnel due to increased congestion.
With respect to the Redevelopment Agency, as mentioned above, the Draft SEIR
does not even acknowledge, discuss, or analyze the land use regulations imposed
by the Agency on the 10100 Jefferson parcel. The lack of analysis is a significant
inadequacy of the Draft SEIR. Further, without this analysis, the Agency is left with
insufficient information to evaluate the potential fiscal impacts of current or future
proposed projects on the Agency. Such impacts could be significant.
ATTACHMENTS:
1. Letter from Tina Macica of BuildLACCD dated March 23, 2010
2. Table 2.2 from the 2010 Draft SEIR
3. Proposed Resolutions (City Council and Culver City Redevelopment Agency),
including Exhibit “A” containing detailed comments on the 2010 Draft SEIR
4. Letter addressed to Los Angeles Community College District dated October 31,
2006
MOTION:
That the City Council:
Adopt a Resolution, transmitting the official City and Agency combined response
to the 2010 Draft Supplemental Environmental Impact Report for the Proposed
2009 West Los Angeles College Facilities Master Plan.
That the Redevelopment Agency Board:
Adopt a Resolution transmitting the official City and Agency combined response
to the 2010 Draft Supplemental Environmental Impact Report for the Proposed
2009 West Los Angeles College Facilities Master Plan.
MEETING DATE: 4/5/2010
AGENDA ITEM: Agency Board
and Agency
Supplemental
2009 West Los
Adoption of City Council and Redevelopment
Resolutions Transmitting the Official City
Combined Response to the 2010 Draft
Environmental Impact Report for the Proposed
Angeles College Facilities Master Plan.
ATTACHMENTS
1. Letter from Tina Macica of BuildLACCD dated March 23, 2010
2. Table 2.2 from the 2010 Draft SEIR
3. Proposed Resolutions (City Council and Culver City
Redevelopment Agency), including Exhibit "A" containing
detailed comments on the 2010 Draft SEIR
4. Letter addressed to Los Angeles Community College District
dated October 31, 2006
Pages
1 -2|1010|4-17
18Build CD
litGEON
MAR
2 4 2010
cuiver Gify P4311r?ing Division
Attachme
nt No. 1
March 23, 2010
So! Blumenfeld
Community Development Director
9770 Culver Boulevard
Culver City, CA 90232
RECEIVED MAR 23 2010
Dear Sol Blumenfeld:
This letter responds to your March 10, 2010 letter wherein you requested a time
extension for the public comment period of the Draft Supplemental Environmental
Impact Report (SEIR) for the 2009 West Los Angeles College (VVLAC) Facilities
Master Plan to a minimum of 90 days. Los Angeles Community College District
(LACCD) is unwilling and unable to grant your request for an extension_ LACCD
reviewed and considered the following information, facts and CEQA guidelines before
reaching its conclusion as to your request:
I.) A Notice of Preparation (NOP) for this draft SE1R was issued on December 4,
2009 by Los Angeles Community College District. The notice was sent
certified mail to City of Culver City Manager, City of Culver City - City Hall,
9770 Culver Blvd., Culver City, CA 90232 with confirmed delivery on
December 7, 2009.
2.) A copy of the NOP was hand delivered at the request of and to Charles D.
Herbertson, Public Works Director / City Engineer on January 12, 2010, by
Robert Miller, WLAC Campus Project Manager and myself.
3.) On February 2, 2010, Dr Mark Rocha, President of WLAC and Robert Miller
met with Mayor Andrew Weissman and City Manager Nark Scott to discuss
the NOP and Draft SEIR_
4.) On March 8, 2010, the Draft SEIR was distributed to the public with a public
review period of 45 days in compliance with CEQA Section 15105 Public
Review Period for a Draft EIR or a Proposed Negative Declaration or
Mitigated Negative Declaration, which states:
"(a) 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 DR 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_"
[Emphasis added.]
915 Wilshire Boulevard • Suite 810 • Los Angeles • California • 90017ma Macica, LEED AP
Build CD
(b) Information relevant to the significant effects of a project, alternatives, and
mitigation measures which substantially reduce the effects shall be made
available as soon as possible by lead agencies, other public agencies, and
interested persons and organizations.
(c) Nothing in subdivisions (a) or (b) reduces or otherwise limits public review
or comment periods currently prescribed either by statute or in guidelines
prepared and adopted pursuant to Section 21083 for environmental documents,
including, but not limited to, draft environmental impact reports and negative
declarations_
9.) Potential financial resource costs associated with project delays as a result of
the City of Culver City request to extend the Draft SEIR comment period.
Based on our review and consideration of your request against the City of Culver
City's advanced knowledge of the release of the Draft SEW, minimum changes
contained in the Draft SEIR as compared to the 2005 FEIR, CEQA requirements, and
potential financial resource cost, LACCD is unwilling and unable to grant your request
of extension to a minimum of 90 days. In addition, as contained in the § 21003.1, we
request that the City of Culver City endeavors to make comments to LACCD as soon
as possible in the review of SEIR, in order to allow LACCD to identify, at the earliest
possible time in the environmental review process, potential significant effects of a
project, alternatives, and mitigation measures which would substantially reduce the
effects.
Thank you for your understanding and if you have any question or concerns, please
feel free to contact me at 31 0-287-4383.
Cc;
Larry Eisenberg, Executive Director, Facilities Planning and Development,
Los Angeles Community College District
D-rAstarkaacha? President, West Los Angeles College
Camille A. Goulet, General Counsel, Los Angeles Community College District
Mark Scott, City Manager
Martin Cole, Assistant City Manager
Charles Herbertson, Public Works Director/City Engineer
Heather Baker, Assistant City Attorney
Thomas Gorham, Deputy Community Development Director/Planning Manger
Susa tin, Senior Manner
- 915 Wilshire Boulevard • Suite 810 o Los Angeles • California • 90017West L.A. College Facilities Master Plan (Draft) Supplemental EIR
Page 2-10
Attachment No. 2
2.0 Project Description
TABLE 2-2:
•
WEST LOS ANGELES COMMUNITY COLLEGE CAMPUS
BUILDING AREAS
No.
Building
Abbrey
Function Existing
2003
2005
FEIR
2009
Proposed
Schedule
33 FA
Classroom 25,500 25,500 25,500
Theater
5,800 5,800 5,800
Gallery 2,123 2,123 2,123
34 HLRC Library 67,000 67,000 67,000
35 PE - M Men's 21,885 21,885 0
36 PE -.0
Other
7,600 7,600 0
Gymnasium 13,000 13,000 0
Pool 2,900 2,900 0
37 PE - W Women's 37,492 17,492 0
38 SC Science Center 8,750 8,750 8,750
39 WSE West Side Ext 1,900 0
Subtotal 389,512 327,608 244,864
Master Plan Buildings
1 SPS South Parking Structure
1,000 spaces 1,132 spaces Completed 12/1/2008
2 SMB Science & Math 0 85,200 86,000
Academic Occupancy
2/9/10
SSB Student Services 0 84,400 50,000
Academic Occupancy
8/30/10
4 GC General Classroom 0 46,000 46,000
Academic Occupancy
• 8/30/10
5 NPS North Parking Structure 1,950 spaces 1,450 spaces Complete 06/2011
6 PFC
Offices 0 0 3,600 Complete 06/2011
Shops 0 0 15,000 Complete 06/2011
7 TLC Teaching Learning Center 0 40,000 75,000 Complete 03/2012
8 WC Watson Center (Media Ails) 0 • 63,900 63,000 Complete 03/2012
9 SU Student Union 0 • 12,000 Complete 11/2012
10 AHW Allied Health and Wellness 0 0 131,000 Complete 07/2012
11 CC Community Center 0 12,000 12,1300
Subtotal
0 331,500 501,600
Building Analyzed in the 2005 EIR but not built
I PE X Phys Ed Expansion 0 20,000 0
Grand Total 389,512 679,108 738,464
* approximately 400 scats
The 2010 SEIR building heights for theproposed buildings are taller than anticipated in the 2005
FEIR. The 2005 FEIR anticipated heights of 40 feet to 72 feet. The new buildings would range in
height from 25 feet (Student Union) to 59 feet 6 inches (Allied Health and Wellness Building) to 135
feet (Teaching Learning Center). The proposed buildings would have the following heights: North
Parking Structure 66 feet 10 inches (similar to the recently completed South Parking Structure),
Watson Center 64 feet 4 inches (this building will be in the center of campus and will be shorter than28
29
Attachment No. 3
RESOLUTION NO 2010-R
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CULVER
CITY, CALIFORNIA, TRANSMITTING TO LOS ANGELES COMMUNITY
COLLEGE DISTRICT AND WEST LOS ANGELES COLLEGE, THE
OFFICIAL CITY RESPONSE TO THE 2010 DRAFT SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT FOR THE WEST LOS ANGELES
COLLEGE 2009 FACILITIES MASTER PLAN
I|101010101010|WHEREAS, the Los Angeles Community College District (the "District) is
proposing the West Los Angeles College 2009 Facilities Master Plan (the "Master Plan");
and,
10
11
WHEREAS, the West Los Angeles College campus ("the College"), consisting
12
of 72 acres, is within an unincorporated area of Los Angeles County and bordered by the City
13
of Culver City to the west, northwest and south. In addition, the 10100 Jefferson property
14
purchased by
the College for the purpose of constructing a secondary access road is located
15
within the City of Culver City and Culver City Redevelopment Plan Area (Component Area
16
No. 4), the remaining area of the College is within the City's Sphere of Influence, and the
17
impacts of its operation are of critical interest to the citizens of Culver City; and,
1B
WHEREAS, the College is bordered by single-family and two-family residences
19
(south of Stocker Street) and by townhornes and multi-family residential developments (west
20
of Freshman Drive) in Culver City; and,
WHEREAS, the College's 2009 Master Plan would add an additional 62,356
21
22
square feet of space beyond the construction contemplated in the 2005 Master Plan while
23
decreasing on-site parking from the 4,368 spaces proposed in the 2005 Master Plan to only
2,641 spaces.
24
25 WHEREAS, the District and the College have prepared a Draft SEIR dated
March 2010 to analyze the potential environmental impacts caused by the proposed
26
revisions to the Master Plan, which was released for public review and comment on March 8,
27
2010; and,
Page 1 Resolution No. 2010-R1 WHEREAS, on March 10, 2010, the City requested the College grant an
2
extension of the public review period from 45 days to at least 90 days in order to give the
3
public sufficient time and opportunity to thoroughly evaluate the Draft SE1R and prepare
4
comments; and,|109| WHEREAS, on March 24, 2010 the City received notice that its request for
6
extension had been denied; and,|109| WHEREAS, a City Staff team, consisting of various City Departments was
8 established to evaluate and comment on the adequacy of the Draft SEIR in addressing
potential impacts to Culver City; and,
10 WHEREAS, the City Council of the City of Culver City, accepted public
11
comments and considered the Draft SEIR at a public meeting on April 5, 2010.
12 NOW, THEREFORE, the City Council of the City of Culver City, California,
13
DOES HEREBY RESOLVE as follows:
14 1. Determines that a) the Draft SEIR is legally and substantially inadequate
15
and inaccurate for certification by the Lead Agency; b) a complete and proper level of
16
environmental data and analysis must be incorporated into a revised Draft SEIR addressing
17
all identified deficiencies; and c) the revised Draft SE1R must be recirculated in order to
18
provide the public with a Meaningful opportunity to comment as required by the California
19
Environmental Quality Act.
20 2_ Establishes that this Resolution, including attached Exhibit "A,"
21 .
constitutes the City of Culver City's official comments on the 2010 Draft SEIR that was
22
prepared for the proposed West LA College 2009 Facilities Master Plan.
23 ///
24 1/
25 ///
26 ///
27 /II
28 ///
29 /1/
Page 2
Resolution No. 2010-R ATTEST: APPROVED AS TO FORM:
MARTIN R. COLE, City Clerk
A10-00111
OL A. SCHWAB, City Attorney|1010| 3. Directs and authorizes staff to transmit comments of the City of Culver
City on the Draft SEIR to Los Angeles Community College District and West Los Angeles
3
College.|109| APPROVED and ADOPTED this day of , 2010.|101010|ANDREW WEISSMAN, Mayor
City of Culver City, California|1010 10
10|11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
Page 3 Resolution No. 2010-R Attachment No. 3
RESOLUTION NO. 2010-R
A RESOLUTION OF THE REDEVELOPMENT AGENCY OF THE
CITY OF CULVER CITY, CALIFORNIA, TRANSMITTING TO LOS
ANGELES COMMUNITY COLLEGE DISTRICT AND WEST LOS
ANGELES COLLEGE, THE OFFICIAL AGENCY RESPONSE TO
THE 2010 DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT
REPORT FOR THE WEST LOS ANGELES COLLEGE 2009
FACILITIES MASTER PLAN
WHEREAS, the Los Angeles Community College District (the "District") is
proposing the West Los Angeles College 2009 Facilities Master Plan (the
"Master Plan"); and,
WHEREAS, the West Los Angeles College campus (the "College"),
consisting of 72 acres, is within an unincorporated area of Los Angeles County
and bordered by the City of Culver City to the west, northwest and south. In
addition, the 10100 Jefferson property purchased by the College for the purpose
of constructing a secondary access road is located within the City of Culver City
and the Culver City Redevelopment Plan Area (Component Area No.4) and is
bound by the Culver City Redevelopment Plan (Component Area No. 4) (the
"Redevelopment Plan") established by the Culver City Redevelopment Agency
(the "Agency") and the applicable Design for Development (DFD) for the
Jefferson Blvd., Industrial Area which was adopted by the Agency as authorized
by the Redevelopment Plan and to implement the Redevelopment Plan; and,
WHEREAS, substantial changes have been made to the Project which
includes the portion in the City of Culver City and the Culver City Redevelopment
Plan Area (Component Area No. 4) and which require major revisions to the
previous EIR and the environmental analysis of the access road; and,
WHEREAS, the College is bordered by single-family and two-family
residences (south of Stocker Street) and by townhornes and multi-family
residential developments (west of Freshman Drive) in Culver City; and,
WHEREAS, the College's 2009 Master Plan would add an additional
62,356 square feet of space beyond the construction contemplated in the 2005
Master Plan while decreasing on-site parking from the 4,368 spaces proposed in
the 2005 Master Plan to only 2,641 spaces.
WHEREAS, the District and the College have prepared a Draft SEIR
dated March 2010 to analyze the potential environmental impacts caused by the
proposed revisions to the Master Plan, which was released for public review and
comment on March 8, 2010; and,
Resolution No. 2010-R Page 1WHEREAS, Agency staff evaluated and commented on the adequacy of
the Draft SEIR in addressing potential impacts to Culver City and the Culver City
Redevelopment Plan Area (Component Area No.4); and
WHEREAS, the Redevelopment Agency of the City of Culver City,
accepted public comments and considered the Draft SEIR at a public meeting on
April 5, 2010.
NOW, THEREFORE, the Redevelopment Agency of the City of Culver
City, California, DOES HEREBY RESOLVE as follows:
1. Determines that a) the Draft SEIR is legally and substantially
inadequate and inaccurate for certification by the Lead Agency; b) a complete
and proper level of environmental data and analysis must be incorporated into a
revised Draft SEIR addressing all identified deficiencies; and c) the revised Draft
SEIR must be recirculated in order to provide the public with a meaningful
opportunity to comment as required by the California Environmental Quality Act.
2. Establishes that this Resolution, including attached Exhibit "A,"
constitutes the Redevelopment Agency of the City of Culver City's official
comments on the 2010 Draft SEIR that was prepared for the proposed West LA
College 2009 Facilities Master Plan.
3. Directs and authorizes staff to transmit comments of the
Redevelopment Agency of the City of Culver City on the Draft SEIR to Los
Angeles Community College District and West Los Angeles College.
APPROVED and ADOPTED this day of , 2010.
ANDREW WEISSMAN, Chairman
Culver City Redevelopment Agency
ATTEST: APPROVED AS TO FORM:
MARTIN R. COLE, Secretary CAROL A. SCHWAB, Agency General
Counsel
KANE, BALLMER & BERKMAN,
Agency Special Counsel
Resolution No 2010-R Page 2Attachment No. 3
EXHIBIT "A" TO RESOLUTION NO. 2010- R
DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT COMMENTS
WEST LOS ANGELES COLLEGE MASTER PLAN
April 5, 2010
Introduction
The City of Culver City (the "City") and Culver City Redevelopment Agency (the
"Agency") submit to the Los Angeles Community College District (the "District")
and West Los Angeles College (the "College") the following comments in
response to the West Los Angeles College 2009 Facilities Master Plan
Supplemental Environmental Impact Report dated March 2010 (the "Draft
SEIR").
As more particularly described in the detailed comments below, the Draft SEIR is
legally and substantially inadequate in that it fails to (i) adequately address
and/or identify a number of significant environmental impacts; (ii) propose
feasible mitigation measures that would mitigate significant environmental
impacts; and (iii) provide sufficient information for the public to understand the
grounds upon which the Draft SEIR concludes that environmental impacts are
not significant and or would be adequately mitigated. As a result, the Draft SEIR
is legally and substantially inadequate and inaccurate for certification by the
District and the College, and must be recirculated in order to provide the public
with a meaningful opportunity to comment as required by the California
Environmental Quality Act ("CEQA").
General Comments
1. A footnote on Page 1-6 of the Draft SEIR indicates that the mitigation
measures listed in Table 1-1 of the Draft SE1R supersede and replace the
mitigation measures set forth in the 2005 Final Environmental Impact Report
(the "2005 Final EIR"). The Draft SE1R should not replace, eliminate, or
disregard the mitigation measures in the original 2005 Final EIR without first
identifying specifically what is being changed or deleted and evaluating
whether a mitigation measure "value" to reducing environmental impacts is
significantly impacted. The mitigation measures in the 2005 Final E1R still
apply unless they are specifically called out and superseded with a detailed
explanation for the necessity of the change. A number of mitigation
measures that are listed in the 2005 Final EIR and are not mentioned in or
modified within the text of the Draft SEIR will continue to apply. Mitigation
measures in the Draft SE1R should be considered supplemental to and not in
replacement of mitigation measures in the 2005 Final FIR unless they are
specifically discussed as modifications to the mitigations in the 2005 Final FIR
within the text of the Draft SE1R (not simply listed in Table 1-1 and within the
body of the Draft SEIR) and a detailed justification for the change is provided.
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 2 of 9
2. The Settlement Agreement entered into between the District, the College and
the City dated August 8, 2005 (the "2005 Settlement Agreement"), shall
remain in full force and effect and shall not be amended in any way by the
Draft SEIR. This point should be clearly stated in the Draft SEIR.
3. As a general mitigation measure of the 2005 Final EIR and as part of the
2005 Settlement Agreement, as well as the January 12, 2005 Memorandum
of Understanding between the District, College and various neighborhood
associations (the "2005 MOU"), the College agreed to create an Ombudsman
position to respond to questions and concerns from the surrounding
community and City staff and facilitate prompt resolution of problems resulting
from the construction and operation of the College facilities. This position
was created; however, the College is now proposing to replace this position
with a "Mitigation Hotline" eliminating a "live body" single point of contact for
residents and City staff concerned with problems stemming from College
construction activities. This is in violation of the terms of the 2005 Settlement
Agreement and 2005 MOU.
4. The City requests that any meetings of the College Board of Trustees
regarding the 2009 Master Plan or Draft SEIR be held at West Los Angeles
College or other nearby location in Culver City so that it is convenient for
concerned parties from the surrounding community to participate in the review
and approval process.
5. The College is bound by the land use restrictions established by the Culver
City Redevelopment Agency, a state agency. The 10100 Jefferson Site
which contains the new access road and remnant 9-acre parcel is being
incorporated as part of the 2009 College Master Plan area. This site is within
the jurisdiction of the Culver City Redevelopment Agency and within Culver
City limit lines. The Draft SEIR does not contain any discussions or evaluate
compatibility with the Culver City Redevelopment Plan, Component Area No.
4 or the Design for Development for Jefferson Boulevard Industrial Area.
Therefore, the Draft SEIR is incomplete and must be re-circulated for review
with this information. Furthermore, since the approval of the Redevelopment
Agency is required for the proposed Project, the Redevelopment Agency is a
Responsible Agency with respect to the Draft SEIR and the certification of the
Agency as a Responsible Agency will be required. This is improperly
unacknowledged in the Draft SEIR.
6. A valid environmental impact report is required prior to consideration of the
proposed Project by the Agency. The 2005 Final EIR is not adequate for this
purpose, and a new analysis of the access road must be included in the Draft
SE1R because, pursuant to the requirements of Public Resources Code
Section 21166, substantial changes have been proposed in the project,
substantial changes will result in major changes to the environmental impact
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SE1R Comments
April 5, 2010
Page 3 of 9
analysis, and new information not known in 2005 (including the massive
increase in intensity of the Project) is now available.
Project Description
7. The Draft SEIR indicates that the proposed revisions to the Facilities Master
Plan include the addition of the 9-acre 10100 Jefferson site to the Campus
Master Plan. The Draft SEIR indicates that nothing is specifically proposed
for the 10100 Jefferson site at this time and additional review will be required
once plans are identified. The Draft SEIR (anywhere there is a reference to
this site in the Draft SEIR) should make it clear that additional environmental
and discretionary review will be required prior to development of the 10100
Jefferson site.
8. The Draft SEIR makes certain assumptions regarding on-campus student
projections and employment that are not adequately supported by studies or
scientific or statistical analysis. These assumptions include a projected
31.6% reduction in on-campus students due to on-line enrollment and an
unexplained and unsubstantiated projected drop in on-campus employment
by a factor of nearly one-half. This is a serious flaw in the document because
subsequent projections of traffic trips and parking demand are based on the
student and employee projections. If these projections are inaccurate, then
entire sections of the Draft SEIR are called into question.
AestheticsNisual Resources/Light and Glare
9. The height of the Technology Learning Center (135 feet) would far exceed the
maximum height limit in the City of Culver City, which is 56 feet. Several
other proposed buildings including the Allied Health and Wellness Building,
the Watson Center, and the north parking structure also exceed this height
limit. The Draft SEIR fails to adequately analyze the visual impacts by
conducting a view analysis and rather simply states that the buildings will not
result in a significant view impact without providing adequate substantiation of
that statement.
10.Mitigation Measure V-3 calls for new trees to be planted to fill gaps along
Freshman Drive and Stocker Street. This measure does not specify a
timeframe, the criteria to be satisfied, or who will determine whether the
criteria have been met. To be effective, mitigation measures should include
all of these components.
11.The Draft SEIR mentions the construction of a gateway monument at the new
entrance to the College off of Jefferson Boulevard. This monument was not
studied in the 2005 Final EIR and potential impacts on land use, visual
resources and traffic are not analyzed.
Exhibit '`A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 4 of 9
Traffic Impacts
12.Trip Generation. The Draft SEIR indicates traffic impacts are expected to
remain the same or decrease significantly in 2022 because of the following
reasons: more students are taking on-line courses; the College's site specific
trip generation rates are lower than the trip generation rates used in the 2005
Final E1R; and employment projections have dropped for no stated
reason. The Supplemental EIR indicates that these factors make the 2005
Final EIR analysis conservative, and no further traffic analysis is required.
The City reviewed the Trip Generation Study West Los Angeles College 2009
Facilities Master Plan, Spring 2008 and Spring 2009 (the "Traffic Study"). We
do not agree with the conclusions that the College trip generation will be less
in 2022 than projected in the 2005 Final EIR. The data in Table B shows an
average trip rate of 1.33 daily trips per on-campus student between 2008 and
2009. Using only 2009 data, the average trip generation rate is 1.51. Also,
the first few weeks of classes typically have the greatest attendance;
therefore, the trip rate should be based on the first few weeks of the
semester. The last table in the Traffic Study shows total enrollment and on-
campus enrollment in 2008 and 2009. The data shows total enrollment
increasing, while on-campus enrollment decreasing in the two-year period.
The Traffic Study has insufficient information to draw conclusions that a
significant amount of future enrollment will be on-line students, or that on-line
students do not visit the campus. Further, traffic studies are based on a
worse- case scenario, testing the peak hour of the road system and the
highest trip generation rate of the land use. In the worse-case scenario, it
would be assumed that the on-line students would also travel to the campus,
at least during the beginning of the semester. Without supporting research
data acceptable to the City of Culver City, the trip generation rate used in the
2005 FE1R or the Institute of Transportation Engineers' (ITE) publication Trip
Generation, 8th Edition should be used to calculate trip generation.
13.Traffic Impact Analysis Criteria. In 2006, the City sent letters to the District
and other jurisdictions requiring all jurisdictions to use LADOT traffic impact
analysis criteria for developments outside of Culver City that may impact
intersections in Culver City. Using LADOT criteria for the 2005 Draft
Environmental Impact Report, West Los Angeles College would have
impacted three additional intersections in Culver City using the traffic data
from the 2005 report. Table 3-44 in the 2005 Final EIR shows the
intersections of Hannum Ave./Playa St., Sepulveda Bl./Playa St.-Jefferson Bl.
and Bristol Parkway/Slauson Ave. would be impacted using LADOT
criteria. In addition, traffic stemming from the additional development on the
campus requires a full traffic study of all intersections that were studied in .the
2005 FEIR as well as the intersection of the newly constructed secondary
access road to the College and Jefferson Boulevard. A traffic study should be
included in the Draft SEIR to analyze these intersections using LADOT
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 5 of 9
criteria and appropriate mitigation measures for any impacted intersections
should be specified.
14. Because of the long term nature of the proposed project and the difficultly in
accurately forecasting traffic operation 10 to 15 years in the future, the City
believes that the following measures should be incorporated into any
approved mitigation monitoring program for the project:
A. In order to provide assurances to Culver City that the projected number of
vehicular trips to be generated by the proposed development of the West
Los Angeles College Facilities Master Plan is consistent with the Draft
Supplemental Environmental Impact Report for the West Los Angeles
College Facilities Master Plan (State Clearinghouse No. 2004051112
("Draft SEIR"), as prepared by the Los Angeles Community College
District, the College agrees to undertake a Trip Verification Study in
accordance with the Protocol for Trip Verification Study set forth by
protocols agreed to by the City and the College to determine actual trip
generation from the College at the College street access points within the
City, in 2015 and 2022.
13. In the event the YEAR 2015 and/or YEAR 2022 trips determined in
accordance with the Protocol for Trip Verification Study as set forth in
agreed on protocols exceeds the trip generation estimates in the Final
Environmental Impact Report, the College shall prepare a traffic analysis
that evaluates whether the increased trip generation creates any
additional significant impacts in Culver City beyond the impacts previously
identified in the Final SEIR. The College shall deliver to Culver City such
additional analysis within sixty (60) days following the completion of the
traffic counts identified in the protocols. The traffic analysis shall identify
any additional measures that will avoid any such additional impacts in
Culver City. The College and Culver City shall meet and confer with
respect to the traffic analysis and additional traffic measures that may be
requested by Culver City to avoid such additional impacts identified by the
analysis.
C. In the event Culver City and the College are unable to reasonably agree
on additional traffic measures sufficient to avoid the additional significant
impacts in Culver City, the College may elect to reduce development
sufficient to avoid the additional significant impacts in Culver City. If the
College does not make any such reductions and Culver City and the
College are unable to agree on additional mitigation measures to reduce
the additional significant impacts on Culver City to a level of insignificance,
then Culver City and the College may agree to have the College pay to
Culver City an amount equal to (a) the number of Peak Hour trips (the
higher of A.M. or P.M. Peak Hour trips) required to be reduced in order to
avoid the additional significant impacts on Culver City, multiplied by (b) the
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 6 of 9
Trip Mitigation Fee, as hereinafter defined. The Trip Mitigation Fee shall
be $3,575 per trip in 2004 dollars. The basic Trip Mitigation Fee shall be
increased annually, commencing on May 1, 2005, by the percentage
increase in construction costs in the Los Angeles area based on the
Means Construction Cost Index for Transportation Projects in Southern
California or other similar index agreed to by the parties.
15.Site Access - The City continues to have concerns about the public using the
new secondary access road as part of a short-cut through the campus from
Jefferson to Overland south of Jefferson. The Draft SEIR does not analyze
this potential significant impact. The new route will be more attractive to
many motorists than traveling through the still-congested Jefferson
Boulevard/Overland Avenue intersection. Physical barriers and way finding
signs preventing "cut-through" traffic need to be incorporated into the campus
internal street circulation pattern.
16.On-Campus Circulation - The proposed changes to the on-campus circulation
are numerous and complex. The primary goal for the system, beyond safety
and accessibility, should be to prevent queuing of traffic at the Overland
Avenue/Freshman Drive intersection that could result in further congestion on
Overland Avenue and significant delays to through traffic not associated with
the College. The rate of acceptance of vehicles from the City streets into the
campus road network must be optimized. This has been a problem in the
past.
Parking
17.0n Campus Parking - The Draft SEIR proposes a reduction in the number of
on campus parking spaces by 1,727 spaces from 4,368 to 2,641. Again,
these reductions in parking spaces are based on unsupported assumptions
regarding on-line students, student and employee trip generation rates, and a
nearly 50% reduction in projected campus employment. In addition, even if
the College's on-campus student population is accepted as accurate, the
demand for parking spaces is shown to be approximately 95% of the supply.
However, on page 3.17-15 of the Draft SEIR the College states that "a
parking facility is perceived by its users to be full when occupancy levels
reach 85-95%. Once this level is exceeded, potential parkers find it difficult to
find an available space." Therefore, the Draft SEIR clearly points out that the
proposed amount of parking will be inadequate to serve future College
parking needs, yet it does not offer any mitigation measures to address this
impact. This alone is a serious flaw and points to the inadequacy of the Draft
SEIR in that it fails to accurately analyze parking impacts.
18.College Parking in the Nearby Neighborhood - The Draft SEIR requires
modification to the College's parking plan only if the cause of student parking
in the neighborhood is due to a lack of parking on campus. However,
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 7 of 9
students park on residential streets in the neighborhood due, at least in part,
to the cost of parking on campus and the elimination of free parking spaces
on public streets surrounding the campus. These causes of parking impacts
in residential areas surrounding the College are not analyzed in the Draft
SEIR and no measures to address these causes are included in the list of
proposed mitigations.
19. There is no discussion about the College charging students or faculty/staff
fees for parking on-campus. Parking fees may discourage the use of the on-
campus parking by some students and result in street and shopping center
parking use. Those will be significant impacts that should be and are not
discussed and quantified in the Draft SEIR. The Draft SEIR must analyze in
detail the potential effects of different parking strategies, such as, maintaining
free curbside parking, providing all structure parking free of charge, requiring
that all students be required to purchase and maintain parking passes, or
including the cost of parking in the base tuition rate.
20.There is inadequate explanation and documentation of the parking needs
rates in the Draft SEIR. There is no documentation as to whether the rates
are based on observed usage of the existing on-campus parking, including,
but not limited to, whether observations occurred during a peak use period;
whether special event parking needs were observed and included in the
comparison of current needs and existing supply; and whether those students
who park on the nearby public streets and in the Raintree Plaza shopping
center were included in the derivation of the parking rates.
Noise
21.The 2005 Final E1R (Mitigation Measure N-1) provides that construction
activity shall be limited to the hours of 8 am to 6 pm weekdays and 9:00 a.m.
to 4:00 p.m. Saturday, with construction prohibited on Sunday. The Draft
SEIR proposes a significant change to the permissible hours of construction
activity to 7 am to 8 pm Monday through Saturday. These hours are not
consistent with Los Angeles County noise regulations which limit construction
to the hours of 7 am to 7 pm Monday through Saturday. In addition, this
change is not consistent with the 2005 Final EIR or the Culver City Noise
Ordinances and is in violation of the 2005 MOU. Further, this change will
result in significant impacts to nearby residential areas of the City located
south and west of the campus by starting construction one hour earlier and
potentially ending construction two hours later everyday.
The Draft SEIR mentions the addition of a 20 foot tall noise barrier along
Freshman Drive, portions of Stocker and the construction access road. The
document goes on to claim that this barrier reduces noise at nearby residences
by 15 dBA below the noise levels in the 2005 Final EIR. There is no noise study
to support this assertion. Also, in an email to nearby Homeowners Associations
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SEIR Comments
April 5, 2010
Page 8 of 9
on March 31, 2010 Tina Macica of Build LACCD indicates that portions of the 20
foot noise barrier along the construction access road are being removed.
Construction traffic will be shifted to the permanent roadway upon completion.
Although a six foot sound wall constructed adjacent to the permanent roadway
may be adequate for normal vehicular traffic, it will be inadequate to protect
nearby residential areas from the noise from construction equipment and trucks
used for construction. Because of the size of these vehicles and the fact that
their exhaust emanates from a much higher point than automobiles, a much
higher sound wall is required to adequately protect the nearby residents from
noise impacts.
Land Use and Planning
22. Part of the proposed and required College activities/operations (10100
Jefferson site) is located within Component Area No. 4 of the Culver City
Redevelopment Project Area and is governed by the Design for Development
for the Jefferson Boulevard Industrial Area. That area is designated for
industrial use to assist with the economic health and growth of the Culver City
community.
23. Since the Culver City Redevelopment Agency is a State agency, the College
must comply with its rules and regulations.
24. The Draft SE1R does not contain any information or discussion regarding the
Culver City Redevelopment Plan (Component Area No. 4) and Design for
Development (DFD) for the Jefferson Blvd., Industrial Area which was
adopted by the Agency as authorized by the Redevelopment Plan and to
implement the Redevelopment Plan. Therefore, the Land Use and Planning
portions and other relevant portions of the Draft SEIR are incomplete. The
College must apply to the Agency to consider whether the proposed Project is
consistent with the Design for Development and the Redevelopment Plan;
this requirement is improperly excluded from the Draft SE1R's list of needed
Project approvals, and no such application has been made by the College.
25.Future CEQA analysis which analyzes development projects on the 10100
Jefferson site must comply with Redevelopment Agency's Design for
Development (DFD) for the Jefferson Boulevard Industrial Area. The DFD
includes various land use standards and provisions and requires all new
developments by any private or public entity to be approved by the Culver
City Redevelopment Agency.
26. The Draft SEIR proposes to revise a mitigation measure in the 2005 Final
EIR (Measure RF-1), which requires that recreation facilities on the campus
shall remain open and available for public use whenever the campus is open
and such use does not interfere with College use of the facility. The revision
would make this mitigation subject to applicable District and College policies
Exhibit "A" to Resolution No. 2010-RExhibit A - West LA College Master Plan Draft SE1R Comments
April 5, 2010
Page 9 of 9
and procedures. Since representatives of the College have advised
representatives of neighboring homeowner groups and a City representative
that District rules prohibit all non-students from entering the campus and
using its facilities, this change would effectively negate Mitigation Measure
RF-1 and prohibit Culver City residents from using College facilities. In
addition it it would be in violation of the 2005 MOU.
Utilities
27. Drainage for the new development will be contained on the College campus
and not flow back to Culver City via Jefferson Boulevard. However, drainage
will flow towards Overland Avenue and be collected in a Los Angeles County
storm drain system. Culver City does have the authority to review drainage
that might impact its right-of-way, therefore, it should be able to review all
drainage plans to insure that the design is adequate and will not impact
Culver City. Therefore, the Draft SEIR should reflect that the hydrology,
storm drain design, LSWPPP, and SUSMP should be reviewed and
approved by Culver City prior to approval for construction.
Enforcement
27. The Draft SEIR must provide for an effective monitoring, enforcement and
audit process to demonstrate continued compliance with all required
mitigation measures.
Project Alternatives
28. The Draft SEIR does not consider project alternatives to the proposed
Master Plan. CEQA mandates that an environmental impact report identify
and consider feasible project alternatives that will avoid or substantially
lessen significant effects.
Conclusion
The City and Agency trust that the District and College will carefully consider and
adequately address the City's and Agency's comments and revise and
recirculate the Draft SEIR. The City and Agency reserve the right to submit
additional written comments after the close of the public comment period, as well
as oral comments at future hearings. The City and Agency also urges the District
and College to carefully consider the comments raised by others, including the
public and other entities and organizations, including the neighborhood
associations who were parties to the 2005 MOU, who have taken the time to
submit comments.
Exhibit "A" to Resolution No. 2010-RPUBLIC WORKS DEPARTMENT
9770 CULVER BOULEVARD, CULVER CITY, CALIFORNIA 90232-0507 .
(310) 253-5535 • FAX (310) 253-5625
Char-- alerts
Director of Publi orks and City Engineer
Attachment No. 4
CHARLES D. HERSEKSON t
Public Works Diredor
and City Engineer
October 31, 2006
Mr. Larry Eisenberg
Los Angeles Couminriity College District
770 Wilshire Boulevard
Los Angeles, CA 90017
TRAFFIC IMPACT ANALYSIS FOR DEVELOPMENT PROJECTS THAT POTENTIALLY
IMPACT CULVER CITY
Dear Mr. Eisenberg:
The City of Culver City is in the process of updating our guidelines for preparing traffic impact studies. In
- the interim, for development projects in the City of Los Angeles, County of Los Angeles and other nearby
jurisdictions we have requested that as of this date thresholds of significant transportation impact identified
in LADOT's traffic impact analysis guidelines be used to analyze the impact on intersections and streets in
Culver City. Therefore; Los Angeles Community College District development projects should use
LADOT guidelines to analyze intersections in Culver City. This will simplify the preparation and review of
the traffic study, since the City of Los Angeles and Culver City share jurisdiction of several intersections
that will be analyzed as part of a traffic study_
If you have any questions please call Mx. Barry Kurtz at (310) 253-5625.
Be: Thomas Gorham
Barry Kurtz
Max Paetzold
Joseph Montoya
Culver City Employees take pride in effectively providing the highest levels of service to enrich the quality of rrfe for the community by building on
our-tradition of more than seventy-five years of public service, by our present commitment, and by our dedication to meet the challenges of the
future_
APJ747113 ON REGYCLLAI PAPER