City of Culver City, California
Agenda Item Report
RECOMMENDATION:
Staff recommends the City Council adopt a resolution transmitting to the County of
Los Angeles the official City response to the June 2013 Initial Study/Mitigated
Negative Declaration for the proposed Stoneview Nature Center Project located at
5950 Stoneview Drive.
BACKGROUND:
The County of Los Angeles (County) has prepared an Initial Study/Mitigated
Negative Declaration (MND), dated June 2013, for the Stoneview Nature Center
project (Project). On June 24, 2013, the County released for public review the MND
consisting of the environmental review of and mitigation measures for the Project.
The public comments to the MND are due to the County on August 23, 2013.
The Project site is located in the Blair Hills Neighborhood within the City of Culver
City and is located on the south side of Stoneview Drive, near Wrighcrest Drive and
La Cienega Boulevard. Although the Project site is within the boundaries of the City,
the County has determined they are the approving body on the Project, as well as
the “Lead Agency” for purposes of conducting the environmental review for this
Project under the California Environmental Quality Act (CEQA). The County Parks
and Recreation Department will be operating and maintaining the Project. The
Meeting Date: 8/12/13 Item Number: A-3
CITY COUNCIL AGENDA ITEM: Adoption of a Resolution Transmitting to the
County of Los Angeles the Official City Response to the June 2013 Initial
Study/Mitigated Negative Declaration for the Proposed Stoneview Nature Center
Project Located at 5950 Stoneview Drive.
Contact Person/Dept.: Charles D.
Herbertson, Public Works Dept. and
Susan Yun, Planning Division
Phone Number: (310) 253-5760 and (310)
253-5755
Fiscal Impact: Yes [x] No [] General Fund: Yes [x] No []
Public Hearing: [] Action Item: [x] Attachments: [x]
Commission Action Required: Yes [ ] No [x] Date: N/A
Public Notification: On 07/29/13 a public notice was mailed to property owners and
occupants within the Blair Hills Neighborhood in Culver City and published in the Culver
City News (08/01/13 and 08/08/13); Meetings and Agendas – City Council (08/06/13).
Department Approval:
Charles D. Herbertson (08/06/13)
City Attorney Approval:
Carol Schwab (by H. Baker) (08/06/13)
Chief Financial Officer Approval :
Jeff Muir (08/06/13)
City Manager Approval:
John M. Nachbar (08/06/13) City of Culver City, California
Agenda Item Report
Project site is currently owned by the Baldwin Hills Regional Conservation Authority
(BHRCA) which, according to the County, plans to transfer the property to the
County in the near future.
Culver City received the MND on Tuesday, June 25, 2013. Staff immediately
distributed it to City Departments for review. The purpose of tonight’s item is for the
City Council to consider staff’s recommended comments, and provide an opportunity
for public comment. After receiving public comment, the City Council is requested to
consider adoption of a resolution accepting or modifying these comments and
authorizing the City Manager to transmit them to the County.
According to County staff, the Project and related MND are tentatively scheduled to
be considered by the County Board of Supervisors (County Board) in September-
October, 2013.
DISCUSSION:
Project Description
The Project site consists of five-acres located at 5950 Stoneview Drive in the City of
Culver City, adjacent to the Kenneth Hahn State Recreation Area. The Project site
was formerly operated as an elementary school (Ohr Eliyahu Academy) from 1995
to 2010, and was acquired by the Baldwin Hills Regional Conservation Authority
(BHRCA) in 2011. The proposed Project includes demolition of the existing
structures and the construction of a 4,000 square foot, one-story building with a
multi-purpose room, staff office, restrooms, and a terrace with an observation area.
A trail would connect the one-story building to various outdoor elements including an
interpretive signage area, a botanical garden, nature grove, yoga deck, native
garden area, demonstration/community garden, seating area, passive meadow, and
an exercise area. Access to the Project is proposed off of Stoneview Drive. A total
of 61 parking spaces on a surface parking lot will be provided with a gate that
separates a small 16-space parking area from a larger 45-space parking area.
Adequacy of the Initial Study/Mitigated Negative Declaration
A City staff team, consisting of representatives from the Planning Division, the Public
Works, Fire and Police Departments, and the City Attorney’s Office evaluated and
prepared proposed comments on the adequacy of the MND. Staff’s proposed
detailed comments are set forth in Exhibit A of the proposed resolution (Attachment
No. 1).
City of Culver City, California
Agenda Item Report
The following is a brief summary of the major issues and concerns with the MND,
which are set forth in more detail in Exhibit A of the proposed resolution:
1. Traffic/Parking/Access:
• The MND is inadequate as it does not include a traffic study.
• A traffic study using Culver City’s criteria should be conducted to address
the following areas:
? Trip generation – accurate assessment of the projected number of
daily visitors.
? Trip assignment – analysis of alternate routes.
? Potential impacts to the residential streets in Culver City, including
speeding, parking, calming measures and access to the Project
site.
• Inadequate information as to how the proposed number of parking spaces
was derived.
• Insufficient information regarding use, criteria and any contingencies of the
$100,000 traffic mitigation fund, the operation of the shuttle system and
follow-up traffic and parking studies
2. Potential Impacts During Construction:
• Traffic study should identify potential impacts on traffic during construction
and potential mitigation measures.
• The MND does not indicate any staging plans or routes that trucks will
take during construction.
• It is not clear in the MND what construction hours the County will follow—
whether they will use Culver City’s construction hours or the County’s.
• A point person or ombudsman should be appointed by the County to deal
with construction related complaints.
• The County should provide the City with the funds required to make the
necessary repairs for any wear or tear on City streets as a result of Project
construction.
• Insufficient information as to whether construction impacts to the area in
the northwest corner of Project site that has been designated as a
landslide hazard zone have been addressed.
• Geotechnical report should be appended to the MND.
3. Other Areas of Concern:
• Inadequate estimation of the number of daily visitors to the Project site.
• Incomplete information regarding the abutting parcels that may be owned
by BHRCA.
• Lighting impacts not sufficiently described or addressed. City of Culver City, California
Agenda Item Report
• Insufficient information regarding landscaping proposed for the Project.
• Insufficient information regarding high-pressure petroleum pipeline that
traverses the Project site (i.e. depth, whether the pipeline is active,
whether impacts from Project construction on the pipeline have been
addressed).
• Project site soil should be tested for any contamination by past oil drilling
activities. It is unclear whether a Phase I or Phase II soils study was
performed.
• The City should have opportunity to review the geotechnical study
referenced in the MND.
• Inadequate analysis regarding mitigation of Project impacts in relation to
the Project location within an Alquist Priolo Earthquake Fault Zone.
• Fails to include cumulative impact analysis addressing related larger
project components (One Big Park Master Plan and Park to Playa Plan).
• The City should have opportunity to review drainage of the Project site. A
plan showing the existing and proposed contours needs to be submitted to
the City for review.
• More information is needed regarding programming and uses of the
Project to better understand Project impacts.
4. Jurisdictional Roles:
• Who has jurisdiction over the Project? Is the County claiming an exemption
from local zoning and building codes? The MND lacks any discussion of this
important issue. It is important that the MND adequately and accurately
address jurisdictional responsibilities and identify the appropriate agency(ies)
that have jurisdiction over issuing permits and enforcing policies and codes.
This is a substantial flaw in the document that requires the MND to be revised
and recirculated for comment.
• The MND states the Project site is governed by the Culver City General Plan
and concludes that the Project will not conflict with such Plan. Pursuant to
Government Code Section 65402, the Project site may not be acquired and
the Project may not be constructed, until the location, purpose and extent of
such acquisition and construction has been submitted to and reported upon
by the City’s “planning agency.” As of this date, the City has not received
from the County a request for conformity.
• The City should be included as a Responsible Agency under CEQA.
• The MND states Culver City Fire Department currently serves the Project site
and will serve this site when the Project is completed. The City’s Fire
Department should be given the opportunity to review the plans and approve
any permitting that is needed to ensure adequate fire flow, fire access, and
response times. City of Culver City, California
Agenda Item Report
• Culver City Police Department concern over potential increased workload for
the Department from parking enforcement should permit parking be instituted
in the neighborhood to address Project impacts.
• Unclear as to whether Culver City Sanitation or the County will service the
Project site. If the City, the County should pay the City for trash and sewer
services. The Culver City Municipal Code requires that solid waste handling
and recycling be performed exclusively by the City.
• Nuisance Problems both on-site and off-site (crimes, noise, loitering,
trash/debris, spill-over parking into the neighborhood). Who will respond to
these issues and if there are any costs, who is responsible?
5. Process: Although not required under CEQA, due to the extent of City
comments and inadequacies of the MND, staff strongly believes the County
should provide a response to public comments on the MND and a fully revised
and recirculated MND should be prepared by the County for City review and
further comment. In addition, prior to the County Board’s consideration of the
Project and MND, City staff would like an opportunity to meet with County staff to
resolve the City’s concerns and memorialize any commitments in writing through
a memorandum of understanding.
FISCAL ANALYSIS:
The MND is not specific enough to estimate the potential fiscal impacts to the City
from the Project. However, unmitigated and significant impacts from the Project
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 Project is implemented include but
are not limited to: increased street infrastructure maintenance, increased demand for
emergency, code enforcement and other City staff services due to Project
operations.
ATTACHMENTS:
1. Proposed Resolution, including Exhibit A containing detailed comments on
the June 2013 MND
MOTION:
That the City Council:
City of Culver City, California
Agenda Item Report
Adopt a resolution transmitting the official City response to the June 2013 Initial
Study/Mitigated Negative Declaration for the proposed Stoneview Nature Center
Project located at 5950 Stoneview Drive.
MEETING DATE: 8112/13
AGENDA ITEM: Adoption of a Resolution Transmitting to the County of
Los Angeles the Official City Response to the June 2013
Initial Study/Mitigated Negative Declaration for the
Proposed Stoneview Nature Center Project located at
5950 Stoneview Drive.
ATTACHMENTS
Pages
1. Proposed Resolution, including Exhibit A containing detailed
1-14
comments on the June 2013 MND. 1 RESOLUTION NO. 2013-R
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A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CULVER CITY, CALIFORNIA, TRANSMITTING TO THE
COUNTY OF LOS ANGELES, THE OFFICIAL CITY
RESPONSE TO THE JUNE 2013 INITIAL STUDY AND
MITIGATED NEGATIVE DECLARATION FOR THE
PROPOSED STONEV1EW NATURE CENTER PROJECT
LOCATED AT 5950 STONEVIEW DRIVE.
WHEREAS, the County of Los Angeles ("County") is proposing the Stoneview
Nature Center Project located at 5950 Stoneview Drive (the "Project"),
boundaries of the City of Culver City; and,
WHEREAS, the Project consists of the construction of a 4,000 square foot,
one-story building with a multi-purpose room, staff office, restrooms, and terrace with an
observation area on a five-acre property. A trail would connect the one-story building to
various outdoor elements including an interpretive signage area, ' a botanical garden,
nature grove, yoga deck, native garden area, demonstration/community garden, seating
area, passive meadow, and an exercise area. Access to the Project is proposed off of
Stoneview Drive. A total of 61 parking spices on a surface parking lot will be provided with
a gate that separates a small 16-space parking area from a larger 45-space parking area;
and,
WHEREAS, the County has prepared an Initial Study/Mitigated Negative
Declaration ("MND") dated June 2013 to analyze potential environmental impacts caused
by the proposed Project, which was released for public review and comment on June 24,
2013; and,
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WHEREAS, a City staff team, consisting of various City Departments was
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established to evaluate and comment on the adequacy of the MND in addressing potential
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WHEREAS, the City Council of the City of Culver City, accepted public
comments and considered the MND at a public meeting ,on August 12, 2013.
NOW, THEREFORE, the City Council of the City of Culver City, California,
DOES HEREBY RESOLVE as follows:
1. Establishes that this Resolution, including attached Exhibit A,
constitutes the City of Culver City's official comments on the MND that was prepared for
the Project.
2. Directs and authorizes staff to transmit the City's comments on the
MND to the County.
APPROVED and ADOPTED this day of 2013.
JEFFREY COOPER, MAYOR
City of Culver City, California
APPROVED AS TO FORM:
A13-00502
ATTEST:
MARTIN COLE, City Clerk
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-2- EXHIBIT A - CITY OF CULVER CITY RESOLUTION NO. 2013- RO .
Stoneview Nature Center Project
Draft Initial Study/Mitigated Negative Declaration Comments
(5950 Stoneview Drive, Culver City, California)
August 12, 2013
TRAFFIC /PARKING
1. Traffic Study is Necessary: The proposed project, located at 5950 Stoneview
Drive in the City of Culver City, includes demolition of the existing structures
and the construction of a 4,000-square-foot one-story building that will include
a multi-purpose room, staff office, restrooms, and a terrace and observation
area (the "Project"). A total of 61 parking spaces will be provided in a surface
parking lot with a gate that separates a small 16-space parking area from a
larger 45-space parking area. Access to and from the Project site will be from
Stoneview Drive. Figure 2-3 shows a future trail connection with the Park to
Playa Regional trail system.
The City's review indicates the traffic and transportation portion of the Initial
Study/Mitigated Negative Declaration ("MND") dated June 2013 is
inadequate. A traffic study must be conducted according to Culver City's
Traffic Study Criteria for the Review of Proposed Development Projects
Within the City of Culver City, July 2012. The traffic study and the MND must
identify potential significant impacts during construction and the potential
impacts of the completed Project. Additionally, when studying potential
project traffic impacts, it is critical to make the correct assumptions regarding
traffic generation.
2. Trip Generation: The MND on Page 3-4 indicates that in the baseline year
there were about 231 daily trips. Table 4.16-1: Vehicle Trips- School Site vs.
Proposed Nature Center shows a comparison of the School in 2010 and the
Proposed Nature Center in 2014 with 0.2% increase in vehicle trips from 2010
to 2014. The daily trip generation numbers in the MND were obtained using
the CalEEMod air emissions model. The MND's comparison of the project's
traffic generation to the previous use is not relevant to the potential traffic
impact of the Project. According to Culver City's Traffic Study Criteria, Page
7, Trip credits may be approved for an existing land use if the use was in
operation at the time the base year traffic counts were taken. As such, no
credit is allowed for the previous school use because it is no longer in use
and has not been since 2010. Therefore, all the traffic generated by the
Project is considered new traffic.
Based on the City's experience with the nearby Baldwin Hills Scenic Overlook
in Culver City, this Project may well generate much more traffic than would be
expected using the CalEEMod air emissions model or the standard trip Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 2 of 12
August 12, 2013
generation rates in the publication, Institute of Transportation Engineers (ITE)
Trip Generation Manual. As shown in the Conceptual Site Plan in Figure 2-3,
the Project will provide a "Future Trail Connection." This connection will be
part of a 13-mile Park to Playa system of parks and trails connecting the
Stocker Corridor, Ruben IngoId Park, Norman 0. Houston Park, Kenneth
Hahn State Recreational Area, the Baldwin Hills Scenic Overlook, Culver City
Park and the Ballona Creek Bike Path to the beach. For unique uses such as
this Project, Culver City requires site-specific trip generation data.
Accordingly, the traffic study and MND should develop site-specific trip
generation rates using the traffic generated by the Baldwin Hills Scenic
Overlook and other similar uses, if available, to apply to this Project. The
Baldwin Hills Scenic Overlook generates high daily and weekend traffic
volumes and heavy parking demand by hikers and people wanting a
challenging workout. This Project has the potential to generate similar
automobile traffic and a high parking demand by both visitors to the Project
site and by those en route to the Park to Playa trail system. The traffic study
and MND should include the amount of traffic the Project would generate on
weekdays and weekends, including daily, AM and PM trip generation rates.
It is unclear how the County estimated the projected number of daily visitors
(referenced on page 2-2, Table 2-1). The number of visitors to the State Park
Scenic Overlook on Jefferson Boulevard should be considered when
calculating this number given the potential attraction of a large number of
visitors to this site for the purpose of accessing the trail network that connects
to the Project site.
3. Trip Assignment: The traffic study and MND should analyze alternate routes
via La Cienega Boulevard on/off ramps and the bridge to Kenneth Hahn State
Recreational Area for construction vehicles and for permanent access to and
from the Project site. It is noted that the alignment of the future trail system
crosses the bridge to the Kenneth Hahn State Recreational Area and follows
an existing dirt road that connects to the south side of the Project site. Use of
this route would avoid Project generated traffic from traversing and potentially
impacting several residential streets in the Blair Hills community. The Blair
Hills community should have an opportunity to learn the pros and cons of
having alternative access from the south and weigh in on the alternatives.
4. Potential Impacts to the Residential Streets in Culver City: Stoneview Drive,
the proposed main access to the site, is a narrow residential street with 25
feet, 10 inches between curbs. There are segments along Stoneview Drive
where parking is allowed on both sides of the street, leaving about 10 feet of
roadway, which is insufficient to accommodate two-way traffic. This causes
motorists to pull over to let a car pass in the opposite direction. The Project
will generate additional traffic and potentially additional parking on Stoneview Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 3 of 12
August 12, 2013
Drive exacerbating a difficult condition. The traffic study and MND should
identify the amount of traffic the project would add to Stoneview Drive and the
other affected local residential streets. Using Culver City's Traffic Study
Criteria, the traffic study should determine if the Project's additional traffic can
be accommodated on Stoneview Drive, and if the additional traffic would have
a significant impact on Stoneview Drive and the other affected local
residential streets. Similar to the traffic generated by Baldwin Hills Scenic
Overlook, the Project has the potential to generate traffic by park visitors as
well as a significant amount of traffic by hikers and people wanting a
challenging workout. The sidewalks on both sides of Stoneview are 4 feet
wide. If hikers'and other visitors to the park site walk two abreast or more
along Stoneview Drive, they would walk in the street and interfere with
automobile traffic. The traffic study and MND should indicate potential traffic
calming measures to address the increase in traffic on the residential streets,
including limiting or eliminating access to the trail network from the Project
site should significant traffic and parking problems materialize. Preferential or
permit parking is not a desirable solution as it will tend to push the problem
deeper into the neighborhood and will inconvenience the residents and
overtax the Culver City Police Department who has responsibility for parking
enforcement.
5. Speeding is a Concern in the Neighborhood: Speeding has been an ongoing
concern in the neighborhood, and in particular on Stoneview Drive because of
its narrow roadway width and narrow sidewalks. The traffic study and MND
should address this concern and the potential for the Project to attract
motorists who are not familiar with the neighborhood. The traffic study and
MND should indicate potential traffic calming measures, including speed
humps, to slow traffic on the residential streets, particularly on Stoneview
Drive.
6. Potential impacts on Parking in the Neighborhood: There is the potential for a
significant parking demand on the nearby residential streets by users of the
Park to Playa Regional trail system in addition to the parking demand
generated by the proposed Project. To consider this additional parking
demand, the traffic study and MND should specify the parking locations along
the Park to Playa Regional trail system, and estimate the amount of parking
that will be generated at the Project site by users of the Park to Playa trail
system in addition to the users of the Project site. It has been the City's
experience that parks and trails generate parking on nearby streets when the
parking lots are full or if there is a charge for parking on the site. The
County's presentation indicated that on-site parking for the Project will be free
of charge. The traffic study and MND should indicate mitigation measures to
reduce or eliminate park visitors from parking on the nearby local residential
streets. These measures should include closing access to the regional trail Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 4 of 12
August 12, 2013
from the Project site should parking demand routinely exceed the supply
available at the Project site, and/or providing free parking at the new parking
lot in Kenneth Hahn Park that will be developed as part of the Park to Playa
trailhead. The County's presentation also indicated that a Traffic/Parking
Mitigation Fund would be established. The traffic study and MND should
indicate the source of funds and how the funds will be accessed to effectuate
traffic mitigation. The County's presentation also indicated that there will be
quarterly reviews of the traffic/parking concerns. Culver City will require
quarterly reports for the first year and annually after the first year. The traffic
study and MND should indicate who will conduct the follow-up reports, and
that they will be provided to the City of Culver City. The traffic study and
MND should indicate any necessary follow-up mitigation measures and that
the County is responsible to mitigate the impacts.
7. Preferred Alternate Site Access: In order to mitigate traffic through the
residential neighborhood, alternate access to the Project site from La Cienega
Boulevard and the bridge to Kenneth Hahn State Recreational Area should be
considered, analyzed and discussed in the MND.
8. Parking Calcuation: The MND does not adequately justify nor does it explain
what calculation was used to derive the number of parking spaces that are
being proposed. It is unclear if the ratio is based on building size or other
criteria. The parking proposed must anticipate usage of the new 4,000
square foot building as well as all outdoor activities at the Project site, any
special events or programming anticipated at the Project site, and the high
potential that users of the Park to Playa Regional trail system will use the
Project site as a trailhead to access the trail system.
9. Parking Lot Design/Configuration: Due to a lack of information or explanation
in the MND, it can only be assumed that the 16 space parking area is
intended for normal park use and the 45 space parking area is planned for
use primarily for special events or overflow parking at the Project site. This
information as to how the parking lot will be operated is critical to be included
in the MND as there will be potentially significant parking impacts and the
public needs to know how these impacts will be minimized or eliminated.
Separating the parking lots with a gate may further impact the situation rather
than be beneficial. The proposed use and reason for the two separate
parking areas as opposed to one bigger parking area is not explained or
analyzed at all in the MND.
10. Other Traffic/Parking Issues: More detailed information is needed about use,
criteria and any contingencies for the $100,000 traffic mitigation fund (What if
the fund is not enough to cover the costs of studies and any physical
improvements due to Project impacts?); the operation of the shuttle system Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 5 of 12
August 12, 2013
(How often does it run? What is the route? Is there a shuttle stop within the
Project site or will it stop on the street?); and follow-up traffic and parking
studies that the County promised to the community at earlier workshops, as
this information is not memorialized in the MND. Some of these promises, if
intended to "mitigate" an impact should be identified as a mitigation measure
in the MND. And even if it is not intended to mitigate an impact, it should still
be discussed and identified in the MND as a requirement of the Project.
CEQA documents need not only contain mitigation measures. It can contain
conditions of approvals, code and development standard requirements, and
policies that also help minimize or alleviate potential impacts.
CONSTRUCTION IMPACTS
11. Potential Impacts During Construction: The MND indicates the
demolition of the existing facility is expected to take two to three months and
the construction is anticipated to take 13-15 months. The traffic study and
MND must identify potential impacts on traffic during construction and
potential mitigation measures. The MND does not indicate any staging plans
or routes that trucks will take during construction. The likely route will be
through Wrightcrest Drive, Lenawee Avenue and Stoneview Drive which
could potentially have significant impacts to the residents if not mitigated such
as parking, noise, and traffic. The traffic study and MND should include a
construction management plan, including the haul route, the number of
construction vehicles and where construction workers will park and the
construction staging location. The traffic study and MND must indicate that
the County shall be responsible to repair any damage to streets in Culver City
caused by construction vehicles or activities. Culver City will conduct a
before and after evaluation of the streets to determine the level of impact to
the streets caused by heavy construction traffic.
12. The MND acknowledges that the Project potentially will have a negative
impact of vibration intrusion caused by trucks hauling building materials to
construction sites where the haul routes pass through residential
neighborhoods on streets with bumps or potholes. However, the suggestion
that the City should take action and expend its resources to repair existing
bumps and potholes to alleviate this problem is an inadequate and improper
mitigation measure for an impact created by the County's Project. As a
result, the MND fails to address this potentially significant impact and should
be revised and recirculated.
13. Construction Hours: It is not clear in the MND what construction hours the
County will follow—whether they will follow Culver City's construction hours or
the County's. In addition to the City's hours of construction for developments
in the City, the City further prohibits dirt hauling and construction material Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 6 of 12
August 12, 2013
delivery or removal during the morning (7:00am to 9:00am) and afternoon
(4:00pm to 6:00pm). In order to minimize potential impacts to the residents
adjacent to the Project site, the City strongly recommends the County
incorporate the City's construction hours and restrictions on delivery and
removal as mitigation measures in the MND and/or conditions of Project
approval. Also, a point person or ombudsman should be appointed by the
County to deal with construction related complaints.
14. Geotechnical Report: Also, it is unclear whether construction activities, which
may generate heavy vibrations, will disturb the area in the northwest corner of
the Project site that has been designated as a landslide hazard zone. A
detailed discussion of this should be included •in the MND and in a
geotechnical report. The geotechnical report should be appended to the
MND.
OTHER AREAS OF CONCERN
Section 2.2.2 - Proposed Buildings and Facilities.
15. The Project description does not include the total acreage for the Project site.
It estimated that this area is five acres.
Table 2-1: Project Number of Daily Visitors.
16. The method of estimating the number of daily visitors should be explained in
the document.
17. The MND fails to estimate the number of visitors to the Project site during
peak hours.
18. The total weekly number of visitors is incorrect; it should be 1050, not 1025.
19. Based on Section 2.2.4, the Project site will be available to the public from
dawn to dusk. During the summer months, dawn to dusk occurs earlier and
later than 8:00 a.m. to 5:00 p.m. Reasonable hours to assume from dawn to
dusk during the summer would be 6:00 a.m. to 8:00 p.m., which would add an
additional 5 hours per day. The total hours per day would increase from 9
hours to 14 hours and the total hours per week would increase from 63 hours
to 98 hours. This would then increase the number of visitors by a factor of
98/63 = 1.56 over the number estimated in the MND.
Figure 2-1: Project Location Map
20. The scale of this map is closer to 1"=300', not 1"=200'. Exhibit A to Resolution No. 2013-R0
Stoneview Nature Center IS/MND
Page 7 of 12
August 12, 2013
21 Based on the current Assessor's Map, Baldwin Hills Regional Conversation
Authority ("BHRCA") owns a 1.0 acre parcel that is contiguous to the east
side of the Project site as well as other parcels abutting the Project site. Any
BHRCA owned property surrounding the Project site should be identified in
the MND. Knowing the locations of these properties could influence the
responses concerning the mitigations to the proposed Project.
Section 4.1 Aesthetics
22. Lighting Impacts: There is no mention of the type, height, and intensity of
outdoor or exterior lighting proposed as part of this Project that might cause
glare in the evening. There needs to be assurances in the MND that any
lighting or glare from the lighting shall be shielded sufficiently so as to prevent
impacts to the residents in this neighborhood. The City should be given an
opportunity to review a lighting plan in order to ensure that its residents are
adequately protected from Project lighting impacts.
23. Landscaping: It is unclear in the MND how there will be a "buffer" area
between residences and the Project site. What types of trees are proposed?
How tall will they be at planting? How long will they take to mature? The City
should be given an opportunity, to review a landscaping plan in order to
ensure that its residents are adequately protected from Project visual and
noise impacts.
Section 4.6 Geology and Soils
24. The MND states that two-thirds of the Project is located within the Alquist-
Priolo Earthquake Fault Zone. Because a geotechnical report was not
provided as part of the MND and a summary or discussion of the conclusions
or findings of the geotechnical report was not provided in the MND regarding
the Alquist-Priolo Zone, it is unknown how this potentially significant impact is
addressed. A geotechnical report and boring explorations should be
undertaken to determine the location of this fault. The report should address
any mitigation factors that may need to be implemented for the design of the
Project, during construction of the Project, and after completion of the Project.
A major concern in constructing buildings and landscape areas within an
earthquake fault zone is the future settling of the ground due to increase
loads and watering within the fault zone area.
Section 4.8 Hazards and Hazardous Materials
25.The MND indicates that oil drilling was highly active at the Project site
between 1928 through 1948, but hazardous wastes from the oil drilling will not
be a problem since a layer of fill 16 feet in depth has been placed over the
Project site. A geotechnical report appears to have been completed but
because it was not provided as part this MND, the City was not able to review
the study and it is not known if the geotechnical report adequately addressed Exhibit A to Resolution No. 2013-R0
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this issue and whether it verified the depth of fill and tested the soil for any
hazardous material that might be closer to the surface and any mitigation to
the soil that might be needed. It is also not clear if there is any evidence of
methane gas that would leak to the surface. This is not mentioned in the
MND. Also it is unclear whether a Phase 1 or Phase II soils study was
performed. A summary of the results and findings of the geotechnical report
should be included in Section 4.8 to demonstrate and disclose how these
potential impacts are addressed, what mitigations are required by the
geotechnical study and what further testing the study recommends or
requires.
26.A high-pressure petroleum pipeline traverses the site but no analysis is
conducted nor detailed explanation is provided in the MND as to the location
of the pipeline, how deep it is, whether it is active or not, whether the
construction of the Project will impact this pipeline and what precautions need
to be taken during construction of the Project to protect the pipeline from
damage or potential rupture. The MND only states that the pipeline would
comply with safety requirements of the U.S. Department of Transportation
Pipeline and Hazardous material Safety Administration and the Office of State
Fire Marshall, Pipeline Safety Division. This general statement, without more
information as to how the pipeline will be monitored and protected during
construction of the Project, does not provide substantial evidence that a
potentially significant impact has been mitigated to a level of insignificance.
Section 4.9 Hydrology and Water Quality
27. The impact analysis states that post-construction best management practices
(BMPs) will be identified in the Stormwater Pollution Prevention Plan
(SWPPP). A SWPPP is the report and plan that details the handling of storm
and non-storm water runoff during construction. Post Construction BMPs
should be identified in a Standard Urban Storm Water Mitigation Plan
(SUSMP).
28. Since this project will disturb an area that is greater than one acre, a State
SWPPP and Notice of Intent (NO!) will be required.
29. Since this project will disturb an area greater than 5,000 SF, a SUSMP will
also be required.
30.1n order to comment on the drainage of the Project site, a plan showing the
existing and proposed contours needs to be submitted for review by the City.
Section 4.10 Land Use and Planning
31. The MND states incorrectly that the Project, as a "public recreational facility,"
is an allowed use in the R1 zoning district. A public recreational facility is a Exhibit A to Resolution No. 2013-R0
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library, museum, outdoor theatre or similar type of facility. The Project, as
described in the MND, is a park and not a public recreational facility. The
MND must be revised to state that the proposed use is a park.
Section 4.17 Utilities and Service Systems
32. The MND should indicate whether the Project site will be served by Los
Angeles County or Culver City for trash collection. The Culver City Municipal
Code requires that solid waste handling and recycling shall be performed
exclusively by the City.
33. The MND should indicate whether or not the Project will be subject to Culver
City's rules and regulations. Who will review the adequacy of the drainage
study, SWPPP, SUSMP and other required reports?
General
34. The Stoneview Nature Center is one component of a larger project: the One
Big Park Master Plan and The Park to Playa Plan, which taken as a whole
could result in significant impacts to parking and traffic within Culver City.
The MND fails mitigate this potentially significant impact by not including a
cumulative impact analysis addressing these related project components
(One Big park Master Plan and Park to Playa Plan).
35.A more detailed description of the programming and uses of the Project are
needed to better understand how many people will potentially use the Project
site. The MND should identify whether there will be special events allowed
(i.e. private parties, exercise groups, regular personal trainers/trainees,
birthday parties, picnics.). If special events are contemplated, the MND
should also include information as to the size (numbers in attendance) and
type of events that will be allowed, whether the County will rent out the
building facility, and the process by which the parking demand and availability
will be monitored such that there will not be a parking impact on
neighborhood streets.
JURISDICTIONAL ROLES
36. Who has jurisdiction over the Project? Is the County exempt from local
zoning and building codes? The MND should discuss this important issue
and document the legal authority regarding jurisdiction over the Project.
Statements throughout the MND indicate the Project is subject to Culver
City's Codes and adopted General Plan. S,uch statements are inconsistent
with and contrary to information the County provided to City staff indicating
that the County will take full control over permitting and approvals for the
Project and, specifically, that the County Board of Supervisors ("County
Board") will be authorizing the demolition of existing buildings and approval of Exhibit A to Resolution No. 2013-R0
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the Project sometime in September or October of this year. In addition,
certain analysis and conclusions contained in the MND that the Project does
not have a significant impact are based on application of City codes and
regulations, yet the County claims it is not subject to Culver City's codes. It is
important that the MND adequately and accurately address jurisdictional
responsibilities and identify the appropriate agency that will have jurisdiction
over issuing permits and enforcing policies and codes. City staff requests an
opportunity to meet with County staff to discuss the numerous inconsistencies
in the MND regarding this issue. This is a substantial flaw in the document
that requires the MND to be revised and recirculated for comment.
37. Section 4.10 Land Use and Planning of the MND states the Project site is
governed by the Culver City General Plan and concludes that the Project will
not conflict with such Plan. Pursuant to Government Code Section 65402,
the Project site may not be acquired and the Project may not be constructed,
until the location, purpose and extent of such acquisition and construction has
been submitted to and reported upon by Culver City's "planning agency" as to
conformity with the City's General Plan. As of this date, the City has not
received from the County a request for conformity. This is a significant
deficiency, which prevents the acquisition of property and construction of the
Project from moving forward.
38. If Culver City is responsible for enforcing any aspect of the Project or MND or
reviewing any of the plans for fire safety, and because the County is required
to request from the City a finding of conformity with the City's General Plan,
the City should be included as a Responsible Agency.
39.The MND should address potential nuisance problems both on-site and off-
site (crimes, noise, loitering, trash/debris, spill-over parking into the
neighborhood), who will respond to these issues, and if there are any costs,
who is responsible to pay for these costs?
40. Police Service — The MND states County Sheriff currently serves the Project
site and will serve the Project site when the Project is completed. In
reviewing the MND for the Project, the Culver City Police Department has
serious concerns regarding traffic and parking enforcement. In examining the
daily vehicle trips, Culver City believes that there is a distinct difference
between a private school and a nature park in regards to parking. The school
only had to have enough parking spaces for their staff and since the school
was a private school the public did not have access to the school grounds.
So the impact of over flow parking was nonexistent. With only 61 parking
spaces available at the Project site, if they are all occupied this will cause the
overflow traffic to park on the surrounding residential streets. As it is today,
there is limited street parking available due to the street width and Blair Hills Exhibit A to Resolution No. 2013-R0
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Park which is located on the same street. The second concern is that if
permit parking is implemented as mitigation for over flow parking, this would
cause an increase in workload for the Culver City Police Department. As it is,
there are 95 special parking permit areas in the City and adding an additional
area would have a significant impact to the Police Department's workload for
parking enforcement.
41. Fire Service - The MND states Culver City Fire currently serves the Project
site and will serve this site when the Project is completed. If Culver City Fire
Department is to serve the Project site, then the City's Fire Department
should be given the opportunity to review the plans and approve any
permitting that is needed to ensure adequate fire flow, fire access, and
response times. A concern expressed by Culver City Fire Department is
adequate access (minimum 20') to the Project site on Stoneview Drive as well
as having adequate access on-site. As the Culver City Fire Department
(CCFD) will be the responding agency for emergencies, fires and other life
safety needs and the Project is within Culver City Jurisdiction, the County
should comply with the following minimum life safely requirements and
include these requirements as conditions of approval for the Project:
a. Compliance with the California Code of Regulations, Title 24, Part 9, 2010
California Fire Code (CFC) and the Culver City Municipal Code CCMC
9.02.
b. 2010 CFC Chapter 3, GENERAL PRECAUTIONS AGAINST FIRE.
c. 2010 CFC Chapter 4, EMERGENCY PLANNING AND PREPAREDNESS.
d. 2010 CFC Chapter 5, FIRE SERVICE FEATURES to include minimum 20
foot clear width on all fire apparatus access roads (includes public streets)
to the Project site, all trails associated with the Project site, Kenneth Hahn
Park and the Baldwin Hills Scenic Overlook. Access to the Project site
should be modified to provide the 20 foot wide unobstructed clear path
which may change or limit parking on narrow roadways and concerns of
opposing traffic, to include a minimum 13' 6" vertical clearance, access to
building openings and roofs, premises identification, KNOX boxes (as
required), fire protection water supplies and fire protection equipment
identification and access. A hydrant capable of flowing 1500 GPM should
be placed on the southeast corner of the parking lot and the fire
department connections (FDC) that serve the structure shall be placed
within 15 feet of the hydrant. Both should be accessible and comply with
the 2010 CFC Chapter 9, Section 912.
e. 2010 CFC Chapter 7, FIRE RESISTIVE-RATED CONSTRUCTION. All
structures should be constructed of Fire Resistive—Rated Construction,
and roof assembly should be a Class A rated assembly. Project
construction shall comply with LA County FD requirements for plants,
plantings, clear areas and construction for an Urban Wildland Interface
3 Exhibit A to Resolution No. 2013-R0
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area and the requirements of being in a designated Cal Fire, High hazard
Fire Zone.
f. 2010 CFC Chapter 9, FIRE PROTECTION SYSTEMS. Per CCMC 9.02,
full coverage fire sprinkler systems(s) are required in all buildings and
shall be maintained, tested and inspected per the 2010 CFC Chapter 9,
Section 901 and installed per the 2010 NFPA Standard 13 as amended by
the Building Standards Commission and California State Fire Marshal.
Plan check, permits and inspections are required by the Culver City Fire
Department.
g. 2010 CFC Chapter 10, MEANS OF EGRESS.
h. 2010 CFC all chapters pertaining to the use and occupancy, hazardous
materials mix, use, dispensing and storage.
i. Compliance with CCFD requirements for maintenance of Fire Department
access, and fire life safety systems.
j. Establish a method of addressing additional medical and emergency calls.
PROCESS
42. County staff stated at the Public Meeting on July 17, 2013, that they do not
intend to prepare a "Response to Comments" to public comments received on
the MND, as it is not required under the California Environmental Quality Act
(CEQA). Due to the extent of the City's comments and inadequacy of the
MND, Culver City strongly believes a response to comments and a fully
revised and recirculated MND should be prepared by the County. In addition,
the County should provide the City an adequate opportunity to review and
comment on the County's response to comments to the MND and a revised
MND prior to the County Board's consideration of the adoption of the MND
and approval of the Project. Further, after City comments are provided and
before the County Board considers this matter, City staff would like an
opportunity to meet with County staff to resolve these issues and memorialize
any commitments in writing through a memorandum of understanding.