III. RESPONSES TO WRITTEN COMMENTS III. RESPONSES TO WRITTEN COMMENTS CEQA Guidelines Section 15088(a) states that “The lead agency shall evaluate comments on environmental issues received from persons who reviewed the Draft EIR and shall prepare a written response. The lead agency shall respond to comments that were received during the noticed comment period and any extensions and may respond to late comments.” In accordance with these requirements, this Section of the Final EIR provides responses to each of the written comments received regarding the Draft EIR during the comment period. Table III-5, which starts on page III-51 provides a summary of the issues raised in response to the Draft EIR. Before Table III-5 are topical responses that have been prepared in order to address certain questions and summarize certain analyses regarding topics raised during the public comment. These topical responses include the following: Topical Response 1: Traffic Impacts and Mitigation Measures Topical Response 2: Traffic Analysis Study Area Topical Response 3: Baseline Traffic Conditions Topical Response 4: Project Trip Generation Topical Response 5: Transportation Demand Management Plan Topical Response 6: Shared Parking Demand Analysis Topical Response 7: Project Site Access, Circulation and Loading Operations Topical Response 8: Construction Impacts Topical Response 9: Project Consistency with the Century City North Specific Plan Topical Response 10: Century City North Specific Plan Cumulative Automotive Trip Generation Potential Topical Response 11: Shading Impacts Topical Response 12: Water Supply City of Los Angeles New Century Plan State Clearinghouse No. 2006061096 July 2008 Page III-1 PRELIMINARY WORKING DRAFT – Work in Progress TOPICAL RESPONSE 1: TRAFFIC IMPACTS AND MITIGATION MEASURES Section IV.J, beginning with Table 61 on page 593 of Volume I of the Draft EIR summarizes the forecast operational significant transportation impacts anticipated with the completion of the New Century Plan project. Specifically, page 603 of Volume I of the Draft EIR summarizes that the following four, of the 55 study intersections analyzed, are expected to be significantly impacted by the project during the weekday P.M. peak hour: • Westwood Boulevard/Olympic Boulevard • Overland Avenue/Santa Monica Boulevard • Century Park West/Santa Monica Boulevard • Westfield Shopping Center Driveway/Santa Monica Boulevard The following two additional study intersections are anticipated to be significantly impacted during the weekend (i.e. Saturday) mid-day peak hour: • Westwood Boulevard/Santa Monica Boulevard • Overland Avenue/Pico Boulevard As discussed on page 603 of Volume I of the Draft EIR, no significant transportation impacts would occur until development of Phase E (which is comprised of 106,523 square feet of office uses and 19,000 square feet of retail uses) is completed and all other phases of the New Century Plan project have been developed. Section IV.J, Subsection 5.b.1, beginning on page 625 provides a summary of the Mitigation Measures J-3, J-4, and J-5 for the above locations. As noted on page 627 of Volume I of the Draft EIR, no significant transportation impacts are expected at any of the neighborhood street segments or mainline freeway segments. The Draft EIR proposes physical mitigation measures for two of the six significantly impacted intersections listed above: Century Park West and Santa Monica Boulevard, and Westfield Shopping Center Driveway and Santa Monica Boulevard. The proposed mitigation measure for the Century Park West and Santa Monica Boulevard intersection includes the installation of an additional northbound lane to provide two left-turn lanes and two right-turn lanes. The proposed mitigation measure for the Westfield Shopping Center Driveway and Santa City of Los Angeles New Century Plan State Clearinghouse No. 2006061096 July 2008 Page III-2 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Written Comments Monica Boulevard intersection includes widening of the driveway to provide an additional exiting lane. The resulting northbound configuration would provide two left-turn lanes and two right-turn lanes. A traffic signal modification and roadway restriping will also be required. Implementation of these mitigation measures are expected to reduce the project’s impacts at these two intersections to less than significant levels. The opportunity to mitigate the New Century Plan’s significant impacts at the remaining four intersections through physical mitigation measures are quite limited due to the recent completion of the Santa Monica Boulevard Transit Parkway Project and the lack of availability of additional right-of-way beyond what currently exists, as well as the City’s completed upgrades to the area-wide intersections with both the Automated Traffic Surveillance and Control System (ATSAC) and Adaptive Traffic Control System (ATCS) enhancements. Therefore, in order to mitigate the project’s impacts at the remaining four intersections, a Transportation Demand Management (TDM) Plan will be implemented. The New Century Plan’s TDM Plan is expected to reduce the forecast significant impacts to less than significant levels through a combination of trip reduction measures. Westfield’s TDM program is proposed to include measures for both the New Century Plan project site, and include a Century City-wide element aimed at reducing trips to and from other businesses, which may likewise reduce impacts to the intersections listed above. See Topical Response No. 5 for further details regarding the TDM Plan. The TDM Plan is expected to reduce the New Century Plan’s total P.M. peak hour commercial trips by six percent, and thereby reduce the project’s traffic impacts to less than significant levels at the remaining four intersections. However, as the exact level of trip reduction cannot be quantified at this time, it has been conservatively concluded that significant and unavoidable transportation impacts would occur at a total of four intersections. As discussed above, these significant impacts would not occur until development of Phase E (comprised of 106,523 square feet of office uses and 19,000 square feet of retail uses) is completed and all other uses proposed by the New Century Plan have already been developed. The analysis parameters for the New Century Plan traffic study were based on the approved Memorandum of Understanding (MOU) with LADOT dated February 9, 2007. A copy of the approved MOU is contained in the Final EIR as Appendix A7. LADOT subsequently approved the New Century Plan traffic study and found that it adequately describes the impacts of the New Century Plan project, as concluded in LADOT’s November 20, 2007 departmental clearance letter to the Department of City Planning. A copy of this clearance letter is contained in Appendix J (of Appendix G contained within Volume V of the Draft EIR). City of Los Angeles New Century Plan State Clearinghouse No. 2006061096 July 2008 Page III-3 PRELIMINARY WORKING DRAFT – Work in Progress TOPICAL RESPONSE 2: TRAFFIC ANALYSIS STUDY AREA Section IV.J, beginning on page 547 of Volume I of the Draft EIR, provides a summary of the Traffic and Circulation analysis associated with the New Century Plan’s traffic study. Appendix G within Volumes III, IV, and V of the Draft EIR contains a complete copy of the traffic analysis prepared for the New Century Plan. Pages 547 through 554 of Volume I of the Draft EIR contain a summary of the existing regional highway and street system. The traffic impact analysis study area originally included a total of 44 intersections. However, after issuance of the June 19, 2006 Notice of Preparation (NOP) and after the June 29, 2006, NOP public scoping meeting was held, interested community members requested that additional analysis locations be added to the study area. Specifically, community members requested that the study area include locations along Olympic Boulevard immediately west of the I-405 (San Diego) Freeway; locations along Overland Avenue near the Westwood Charter Elementary School; the Westholme Avenue/Santa Monica Boulevard intersection; and locations near the I-10 (Santa Monica) Freeway. In response to these NOP comments, and to ensure the preparation of a comprehensive traffic impact analysis, the traffic analysis study area was expanded to include the above locations as well as additional locations along the major corridors (e.g., Wilshire Boulevard, Santa Monica Boulevard, Olympic Boulevard, etc.) used to travel to and from Century City. The preliminary traffic analysis study area was thus expanded from 44 study intersections to 55 study intersections and eight study street segments. Three mainline freeway segments were also included as part of the traffic analysis and consist of the I-10 (Santa Monica) Freeway east of Overland Avenue and the I-405 (San Diego) Freeway both north of Venice Boulevard and south of Mulholland Drive. Project vehicular trips are primarily anticipated to utilize the arterial roadways and are not anticipated to traverse through residential areas, however, a total of eight residential street segments were included in the analysis as required by City of Los Angeles Department of Transportation staff. The study area is also summarized in greater detail beginning on page 28 of Appendix G within Volume III of the Draft EIR. This analysis includes the locations required for annual congestion monitoring in the Los Angeles County Metropolitan Transportation Authority (Metro) Congestion Management Program (CMP). Refer to Section 16.0, pages 137 through 140, Appendix G of Volume III of the Draft EIR for a summary of the CMP traffic impact assessment. The applicable CMP threshold criteria for a traffic impact assessment are whether a project will add 50 or more trips during either the A.M. or P.M. peak hours at CMP monitoring intersections or 150 or more trips during either the A.M. or P.M. peak hours at CMP freeway monitoring locations. Neither the proposed project nor the project alternatives will exceed these City of Los Angeles New Century Plan State Clearinghouse No.