Final Environmental Impact Report

Department of City Planning  Environmental Analysis Section City Hall  200 N. Spring Street, Room 750  Los Angeles, CA 90012

FINAL ENVIRONMENTAL IMPACT REPORT

NORTH HOLLYWOOD – VALLEY VILLAGE COMMUNITY PLAN AREA

NoHo West Project

Case Number: ENV-2015-888-EIR State Clearinghouse Number: 2015041001

Project Location: 6150 North Laurel Canyon Boulevard and 12001 West Oxnard Street, Los Angeles, CA 91606 Council District: 2, Paul Krekorian

Project Description: The Project includes redevelopment/reuse of the Project Site with a mix of commercial, retail and residential land uses. Approximately 16.44 acres (or 716,310 square feet) of the Project Site fronting Laurel Canyon Boulevard and Oxnard Street and near the 170 Freeway would be devoted to commercial use, with new interior access ways and private streets added for circulation. Approximately 8.26 acres (or 359,942 square feet) of the Project Site fronting Radford Avenue and Erwin Street would be developed with multi-family residential units. The Project includes the demolition of the existing 90,000-square-foot office building at the corner of Laurel Canyon and Erwin Street and the 10,000-square-foot Macy’s annex building, as well as the removal of an approximately 20,000-square- foot portion of the existing Macy’s building. The existing main Macy’s building would be expanded and re-used for approximately 500,000 square feet of office uses. The Project also involves the development of the remainder of the Project Site with approximately 300,000 square feet of commercial uses, as follows: approximately 142,513 square feet of retail land uses, 48,687 square feet of restaurant land uses, 40,000 square feet of health club/gym, and 68,800 square feet of cinema uses (with 1,750 seats). The Project also includes the development of two residential buildings fronting on Radford Avenue and Erwin Street containing a total of 742 residential units.

APPLICANT: PREPARED BY: ON BEHALF OF: MGP XI-GPI Laurel Plaza, LLC CAJA Environmental Services The City of Los Angeles Department of City Planning

Environmental Analysis Section

June 2016

Table of Contents

Page

1. INTRODUCTION ...... 1-1 2. RESPONSES TO COMMENTS ...... 2-1 3. ADDITIONS AND CORRECTIONS ...... 3-1 4. MITIGATION MONITORING PROGRAM ...... 4-1

Appendices:

Appendix A: Comment Letters Appendix B1: LADOT Letter on Alternative 4B Appendix B2: Traffic Study on Alternative 4B Appendix C: Air Quality and Greenhouse Gas Modeling for Alternative 4B Appendix D: Alternative 4B Office Variation Appendix E: Residential Street Analysis

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List of Figures and Tables

Page

Figure 1 Revised Figure 2-12, Cumulative Projects Map ...... 3-2 Figure 2 Revised Figure 4.M-13, Cumulative Projects Map ...... 3-18 Figure 4B-1 Alternative 4B, Plot Plan Level 1 ...... 3-32 Figure 4B-2 Alternative 4B, Plot Plan Level 2 ...... 3-33 Figure 4B-3 Alternative 4B, Conceptual Site Plan ...... 3-34 Figure 4B-4 Alternative 4B, Residential Site Plan ...... 3-35 Figure 4B-5 Alternative 4B, Conceptual Site Circulation Plan ...... 3-36 Figure 4B-6 Alternative 4B, Rendering, View of Plaza from Parking Structure ...... 3-37 Figure 4B-7 Alternative 4B, Rendering, View Looking North Along Laurel Plaza Drive ...... 3-38 Figure 4B-8 Alternative 4B, Rendering, Aerial View Looking Southeast ...... 3-39 Figure 4B-9 Alternative 4B, Rendering, View Looking South Along Laurel Plaza Drive ...... 3-40 Figure 4B-10 Alternative 4B, Rendering, View of Oxnard Avenue Entrance ...... 3-41 Figure 4B-11 Alternative 4B, Rendering, View of Intersection at Laurel Canyon Boulevard and Erwin Street ...... 3-42 Figure 4B-12 Alternative 4B, Rendering, View of Residential Units Along Erwin Street ...... 3-43 Figure 4B-13 Alternative 4B, Rendering, View at Corner of Radford Avenue and Calvert Place ...... 3-44 Figure 4B-14 Alternative 4B, Summer Solstice Shadows 9AM ...... 3-47 Figure 4B-15 Alternative 4B, Summer Solstice Shadows 12PM...... 3-48 Figure 4B-16 Alternative 4B, Summer Solstice Shadows 3PM...... 3-49 Figure 4B-17 Winter Solstice Shadows 9AM ...... 3-50 Figure 4B-18 Winter Solstice Shadows 12PM...... 3-51 Figure 4B-19 Alternative 4B, Winter Solstice Shadows 3PM ...... 3-52

Table 4.F-2 Emission Reductions Needed to Meet AB 32 Objectives in 2020 ...... 3-6 Table 4B-1 Comparison Table ...... 3-25 Table 4B-2 Vehicle Parking ...... 3-27 Table 4B-3 Bicycle Parking ...... 3-28 Table 4B-4 Open Space ...... 3-29 Table 4B-5 Alternative 4B – Estimated Daily Construction Emissions (Unmitigated) ...... 3-53 Table 4B-6 Alternative 4B – Estimated Daily Construction Emissions (Mitigated) ...... 3-55 Table 4B-7 Comparison of Net Regional Construction Emissions - Mitigated ...... 3-56 Table 4B-8 Comparison of Net Localized Construction Emissions - Mitigated ...... 3-56 Table 4B-9 Alternative 4B – Estimated Daily Construction Emissions (Mitigated) ...... 3-58 Table 4B-10 Alternative 4B – Comparison of Construction Greenhouse Gas Emissions (Mitigated) ...... 3-59

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List of Tables (Continued)

Page

Table 4B-11 Alternative 4B – Estimated Annual CO2e Greenhouse Gas Emissions ...... 3-60 Table 4B-12 Alternative 4B – Comparison of Operations Greenhouse Gas Emission (Mitigated) ... 3-60 Table 4B-13 Daily Vehicle Travel Reductions ...... 3-61 Table 4B-14 Project Consistency with AB 32 Scoping Plan Greenhouse Gas Emission Reduction Strategies ...... 3-63 Table 4B-15 Project Consistency with SCAG 2016-2040 RTP/SCS ...... 3-64 Table 4B-16 Alternative 4B – Estimated Population Generation ...... 3-74 Table 4B-17 Alternative 4B – Estimated Employee Generation ...... 3-74 Table 4B-18 Alternative 4B – Estimated Student Generation ...... 3-76 Table 4B-19 Alternative 4B – Trip Generation Estimates ...... 3-78 Table 4B-20 Alternative 4B – Future With Project Conditions (AM Peak Hour) ...... 3-80 Table 4B-21 Alternative 4B – Future With Project Conditions (PM Peak Hour) ...... 3-81 Table 4B-22 Alternative 4B – Future With Project With Mitigation (AM Peak Hour) ...... 3-83 Table 4B-23 Alternative 4B – Future With Project With Mitigation (PM Peak Hour) ...... 3-84 Table 4B-24 Alternative 4B – Estimated Wastewater Generation ...... 3-86 Table 4B-25 Alternative 4B – Estimated Water Demand ...... 3-88 Table 4B-26 Alternative 4B - Estimated Solid Waste Generation ...... 3-89 Table 4B-27 Alternative 4B – Estimated Electricity Demand ...... 3-90 Table 4B-25 Alternative 4B – Estimated Natural Gas Demand ...... 3-91

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1. INTRODUCTION

Purpose

Before approving a project, the California Environmental Quality Act (CEQA) requires the lead agency to complete environmental review of the project, and in some cases prepare and certify a Final Environmental Impact Report (Final EIR). The contents of a Final EIR are specified in Section 15132 of the CEQA Guidelines, as follows:

The Final EIR shall consist of:

(a) The Draft EIR or a revision of the Draft.

(b) Comments and recommendations received on the Revised Draft EIR either verbatim or in summary.

(d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process.

(e) Any other information added by the Lead Agency.

Organization of the Final EIR

Pursuant to Section 15132 of the CEQA Guidelines, this document includes the following sections, which combined with the Draft EIR, constitutes the Final EIR for the Project:

Section 1. Introduction: This section provides an introduction to the Final EIR and the list of persons and agencies that submitted comments on the Draft EIR.

Section 2. Responses to Comments: This section includes responses to each of the significant environmental points raised in the comments submitted.

Section 3. Additions and Corrections to the Draft EIR: This section provides corrections and additions to the Draft EIR, based on and in response to comments received.

Section 4. Mitigation Monitoring Program: This section includes all of the Mitigation Measures Project Design Features, and Regulatory Compliance Measures that have been identified to reduce or avoid the Project’s environmental impacts. This section also notes the monitoring phase, the enforcement phase, and the applicable department or agency responsible for ensuring that each mitigation measure is implemented.

Appendices: The appendices to this document include copies of all the comments received on the Draft EIR and additional information cited to support the responses to comments.

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City of Los Angeles June 2016

Process

As defined by Section 21067 of CEQA, the City of Los Angeles is the Lead Agency for the Project. In accordance with CEQA, the Lead Agency issued a Notice of Preparation on April 2, 2015, and prepared the Draft EIR. A Notice of Completion and Availability (NOC) of the Draft EIR was released on December 3, 2015, and the public review period on the Draft EIR took place from December 3, 2015 to February 26, 2016, which was an 85-day review period.

Comments on the Draft EIR were received during the public review period. The responses to those comments are set forth in this Final EIR. The Draft EIR and this Final EIR will be submitted to the Advisory Agency, Planning Commission, and City Council for certification in connection with action on the Project.

Review and Certification of the Final EIR

Consistent with State law (Public Resources Code 21092.5), responses to agency comments are being provided to each commenting agency more than 10 days prior to certification of the EIR.

The Final EIR is available for public review at the following locations:

Milena Zasadzien City of Los Angeles, Department of City Planning 6262 Van Nuys Boulevard, Suite 351, Van Nuys, CA 91401 Telephone: (818) 374-5054 E-Mail: [email protected]

Los Angeles Central Library 630 W. 5th Street, Los Angeles, CA 90071

Valley Plaza Branch Library 12311 Vanowen Street, North Hollywood, CA 91605

North Hollywood Regional Library 5211 Tujunga Avenue, North Hollywood, CA 91601

The Final EIR is also available online at the Los Angeles Department of City Planning’s website [http://planning.lacity.org/ (click on “Environmental Review” and then “Final EIR”)]. The Final EIR can be purchased on CD-ROM for $7.50 per copy. Contact Milena Zasadzien of the City of Los Angeles at [email protected] or (818) 374-5054 to purchase the CD-ROM.

List of Commenters

The Los Angeles Department of City Planning received 84 comment letters on the Draft EIR. Each comment letter from an agency has been assigned a number preceded by the letter “A,” and each distinct

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comment within each agency comment letter is numbered. For example, the comments in agency comment letter “A-1” are numbered “Comment A1-1”, “Comment A1-2”, “Comment A1-3”, etc. Each comment letter from an individual has been assigned a number, and each distinct comment within each comment letter is numbered. For example, the comments in comment letter “1” are numbered “Comment 1-1”, “Comment 1-2”, “Comment 1-3”, etc. In addition, multiple copies of two form letters have been received, and these form letters are designated as “Y-1,” “Y-2,” “Y-3,” etc. and “Z-1,” “Z-2,” etc.

Copies of the original comment letters are included in Appendix A to this document.

A-1. Alan Lin, Department of Transportation

A-2. Andrei Tcharssov, Los Angeles Department of Water and Power

A-3. Elizabeth Cavajal, METRO

A-4. Gwynneth Doyle, Los Angeles Unified School District

A-5. Diann Corral, Laurel Grove Neighborhood Association

A-6. Peter O’Leary, Emmanuel Lutheran Church

A-7. Ali Poosti, Wastewater Engineering Services Division

1. Disiree Levine

2. Kathleen Curry

3. Amy Ryder

4. Ron Bitzer

5. Eric Mintz

6. Nick Abdo

7. Christina Garberson

8. Annabelle Whettam

9. Patricia Lorenz

10. Jill Marx

11. Johann Peuker

12. Steven Heller

13. Jeffrey Wilkins

14. Samuel Ameen

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15. Melissa Gwynne

16. Philip and Joyce Baer

17. David Oberg

18. Kathleen Schwartz

19. Jennifer Shields

20. Kristine Koehler

21. Joel Robbins

22. Jane Macfie

23. Suzanne Stinson

24. Dylan Quirt

25. Val Diamond-Cohen and Steven Cohen

26. Ron Bitzer

27. Joyce Dillard

28. Judy and Eugene Rubin

29. Eric and Lisa Petersen

30. Walter Hall

31. Patrick Horne

32. Evan Humphreys

33. Robin Wells

34. Yoav and Theresa Getzler

35. Jay Hofstadter

36. Douglas Ross

37. Gilbert Stein

38. Todd Shea

39. Doris Tinius

40. Mark Amorello

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41. Joey Banks

42. Melissa Mariano

43. Suzette Sheets

44. Roy Stein

45. Wesley Davis

46. Patricia Jackson

47. Dennis White

48. Laurie Hobird

49. James and Fiona Garrett

50. Andrea Schmitt

51. Michelle Hobird

52. Gabriel Szasz

53. Carol Rosenthal

Y-1. Alison Brustein

Y-2. Annabelle Whettam

Y-3. Deborah and David Shapiro

Y-4. Laurie Hobird

Y-5. Jennifer McFeely

Y-6. Dennis White

Y-7. Melissa Mariano

Y-8. Patrick Horne

Y-9. Steven Heller

Y-10. Andrea Schmitt

Y-11. Michelle Hobird

Y-12. Evan and Melissa Gwynne

Y-13. Mr. and Mrs. Haugen

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Y-14. Shirley Eberts

Y-15. Anthony Mazzucchi

Y-16. Lynn Mazzucchi

Z-1. Catherine Peterson

Z-2. Annabelle Whettam

Z-3. Debra Nelson Hammons

Z-4. Dennis White

Z-5. Patrick Horne

Z-6. Laurie Hobird

Z-7. Michelle Hobird

Z-8. Shirley Eberts

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2. RESPONSES TO COMMENTS

A key purpose of the public review of the Draft EIR is to allow the public to evaluate the adequacy of the environmental analysis in terms of compliance with CEQA. Section 15151 of the CEQA Guidelines states the following regarding standards from which adequacy is judged:

An EIR should be prepared with a sufficient degree of analysis to provide decision- makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among experts. The courts have not looked for perfection but for adequacy, completeness, and a good faith effort at full disclosure.

CEQA provides a variety of opportunities for public participation, including periods for review and comment on the adequacy of the Draft EIR prior to certification. CEQA Guidelines Section 15088(a) states:

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 notice comment period and any extensions and may respond to late comments.

The purpose of each response to a comment on the Draft EIR is to address the significant environmental issue(s) that are raised by each comment. This typically requires clarification of the analysis contained in the Draft EIR. Section 15088(c) of the CEQA Guidelines describes the standards required for an adequate response to public comments:

The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the lead agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice.

Section 15204(a) of the CEQA Guidelines provides guidance to the public and public agencies to help focus their review and comments on the Draft EIR. The lead agency is not obligated to undertake every suggestion given them, provided that the agency responds to significant environmental issues and makes a good faith effort at disclosure. Section 15204(a) of the CEQA Guidelines clarifies this for public and public agency reviewers and states:

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City of Los Angeles June 2016

In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, in light of factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and the geographic scope of the project. CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.

As stated above, the CEQA Guidelines encourage the public and public agencies to examine the sufficiency of the environmental document, particularly in regard to significant effects, and to suggest specific mitigation measures and project alternatives. Section 15204(c) advises the public and public agencies that comments should be accompanied by factual support:

Reviewers should explain the basis for their comments, and, should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.

Please note that written comments submitted during the Draft EIR’s public comment period included comments relevant to the Project’s approval/disapproval along with comments relevant to the adequacy of the environmental review. The responses to comments acknowledge the comments which address Project approval, but focus responses on the comments that raise potential environmental impacts or the adequacy of the environmental review.

Note that there may be spelling and/or grammar errors in the Comment Letters. These are replicated here exactly as they were delivered to the City.

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City of Los Angeles June 2016

Letter No. Commenter Name/Agency Description Project Alternatives Project Aesthetics Air Quality Resources Cultural and Soils Geology Greenhouse Gas Emissions Materials Hazardous and Hazards Hydrology and Water Quality Land Use and Planning Noise Population and Housing Public Services Transportation and Traffic Systems and Service Utilities Other A-1 Caltrans_Lin X X A-2 LADWP_Tcharssov X A-3 Metro_Cavajal X A-4 LAUSD_Doyle X X X X A-5 LGNA_Corral X X X X X X X X X X X X X X A-6 ELC_Leary X X X X X X A-7 Wastewater_Poosti X X 1 Levine, Desiree X X X X X X X X 2 Curry, Kathleen X X X X X X X 3 Ryder, Amy X X X X X X X X 4 Bitzer, Ron B. X X X X 5 Mintz, Eric X X X 6 Abdo, Nick X X X X X X 7 Garberson, Christina X X X X X X 8 Whettam, Annabelle X X X X X X 9 Lorenz, Patricia X X X X 10 Marx, Jill X X X X X 11 Peuker, Johann X X X X X 12 Heller, Steven A. X X 13 Wilkins, Jeffery X X 14 Ameen, Samuel X X 15 Gwynne, Melissa X X X X X 16 Baer, Philip and Joyce X X X X X X 17 Oberg, David X X X X X 18 Schwartz, Kathleen X X X X X X X 19 Shields, Jennifer X X X X 20 Koehler, Kristine X X X X X X X 21 Robbins, Joel X X X X X X 22 Macfie, June X X X X 23 Stinson, Suzanne X X X X X X X X X 24 Quirt, Dylan X X X X X 25 Cohen, Val and Steven X X X X X 26 Bitzer, Ron X X X 27 Dillard, Joyce X X X X X X X X 28 Rubin, Judy and Eugene X X X X 29 Petersen, Eric and Lisa X X X X X X X X X X X 30 Hall, Walter D. X X X X X

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31 Horne, Patrick X X X X 32 Humphreys, Evan X X X X X 33 Wells, Robin X X X X X 34 Getzler, Yoav and Theresa X X X X X 35 Hofstadter, Jay X X X X X X X 36 Ross, Douglas A. X X X X 37 Stein, Gilbert X X X X X X X 38 Shea, Todd X X X X X 39 Tinius, Doris X X X 40 Amorello, Mark X X X X X X 41 Banks, Joey X X X 42 Mariano, Melissa X 43 Sheets, Suzette X X X X X X 44 Stein, Roy X X X X X 45 Davis, Wesley A. X X X X X X 46 Jackson, Patricia X X X 47 White, Dennis X X X X X 48 Hobird, Laurie X X X X X X X X X X X 49 Garrett, James and Fiona X X X X X 50 Schmitt, Andrea X 51 Hobird, Michelle X X X X X X X X X X X 52 Szasz, Gabriel X X 53 Rosenthal, Carol X X X X X Y-1 Brustein, Alison Koire X X X X X X Y-2 Whettam, Annabelle X X X X X X Y-3 Shapiro, Deborah and David X X X X X X Y-4 Hobird, Laurie X X X X X X Y-5 Mcfeely, Jennifer X X X X X X Y-6 White, Dennis X X X X X X Y-7 Mariano, Melissa X X X X X X Y-8 Horne, Patrick D. X X X X X X Y-9 Heller, Steven A. X X X X X X Y-10 Schmitt, Andrea X X X X X X Y-11 Hobird, Michelle X X X X X X Y-12 Gwynne, Evan and Melissa X X X X X X Y-13 Haugan, Mr. and Mrs. X X X X X X Y-14 Eberts, Shirley X X X X X X Y-15 Mazzucchi, Anthony T. X X X X X X Y-16 Mazzucchi, Lynn F. X X X X X X Z-1 Peterson, Catherine X X X X X Z-2 Whettam, Annabelle X X X X X Z-3 Hammons, Debra Nelson X X X X X Z-4 White, Dennis X X X X X Z-5 Horne, Patrick D. X X X X X Z-6 Hobird, Laurie X X X X X Z-7 Hobird, Michelle X X X X X Z-8 Eberts, Shirley X X X X X Table by CAJA Environmental Services, 2016.

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City of Los Angeles June 2016

LETTER NO. A1

Alan Lin, Acting Branch Chief Community Planning & LD / IGR Review Department of Transportation, District 7 100 S Main Street, MS 16 Los Angeles, CA 90012

Comment No. A1-1

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The Project includes redevelopment/reuse of the Project Site with a mix of commercial, retail, and residential land uses. The Project includes the demolition of the existing 90,000-square-foot office building at the corner of Laurel Canyon Boulevard and Erwin Street and the 10,000-square-foot Macy's annex building, as well as the removal of an approximately 20,000- square-foot portion of the existing Macy' s building.

The existing main Macy's building would be expanded and re-used for approximately 500,000 square feet of office uses. The Project also involves the development of the remainder of the Project Site with approximately 300,000 square feet of commercial uses, as follows: approximately 142,513 square feet of retail land use, 48,687 square feet of restaurant land use, 40,000 square feet of health club/gym, 68,800 square feet of cinema use (with 1,750 seats) and 742 residential units.

Response to Comment No. A1-1

The Project description information provided in the comment accurately reflects the Project as analyzed in the Draft EIR.

Comment No. A1-2

In an effort to facilitate the environmental review process, we suggest the Lead Agency work with Cal trans in advance for any future projects. According to Cal trans freeway data, few of the SR -170 freeway segments are operating at LOS E/F during the peak hours in both directions. Consultation with Caltrans to validate the LOS on the freeway would produce a more accurate analysis. In addition, the traffic analysis should include Saturday and Sunday peak hour trips since there are retails, restaurants, and cinema being proposed for this development.

Response to Comment No. A1-2

As described in the Traffic Study, the analysis of the freeway mainline segments in close proximity to the Project Site used data obtained from Caltrans. Tables E-1 and E-2 of the Traffic Study (included as Appendix J to the Draft EIR) show that the LOS for all segments analyzed was determined to be LOS D or better, with the exception of the southbound mainline segment between Victory Boulevard and Oxnard

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City of Los Angeles June 2016

Street in the AM peak hour, which operates at LOS E. For each freeway mainline segment analyzed, Project-related traffic volumes would represent 0.5% or less of the freeway mainline capacity in the AM peak hour and 0.6% or less in the PM peak hour. None of the segment values exceeded the following established thresholds for segment capacity: a 2% threshold for freeway mainline segments operating at LOS D and a 1% threshold for freeway mainline segments operating at LOS E or F. Segments operating at LOS C or better are not subject to a threshold. The traffic analysis was conducted for weekday AM and PM commute peak hours as these are the time periods when traffic volumes along the freeway mainline and off-ramps are expected to be the highest, and when the addition of Project-related traffic volumes would have the greatest potential of creating a significant impact.

With regard to advance review, the Project was evaluated according to thresholds established by agreement between Caltrans and LADOT, memorialized in a Memorandum of Understanding dated October 2013 (“the 2013 LADOT/Caltrans MOU”). In addition, Caltrans was provided with the NOP and Notice of Availability of the Draft EIR, and provided comments in response to both. Caltrans’ NOP comment letter is attached as Appendix C to the Draft EIR. Responses to Caltrans’ Draft EIR comment letter are provided here.

Comment No. A1-3

Caltrans comment letter, dated May 1, 2015, requests the nearest study locations include Oxnard St. (SB SR-170 to Laurel Canyon Blvd./Oxnard St.), Victory Blvd. and Burbank Blvd. Table E-3 of Traffic Study (TS), dated November 5, 2015, needs to include those locations. The off ramp screening criteria, referenced in Table E-3 of the agreement between Caltrans and the City of Los Angeles, of 1,500 vehicles per hour/per lane is based on free-flow speed without traffic controls, per the Highway Capacity Manual (HCM). However, the capacity for interrupted flow such as signal or stop controlled ramps is reduced. An analysis is needed to determine appropriate ramp capacity since the level of service (LOS) is based on the ramp capacity. Once the actual ramp capacity is determined, screening criteria as per the agreement will be applied. Thus, the calculated LOS would be different as indicated in the report. The existing LOS should also match the reality in the field.

Response to Comment No. A1-3

Caltrans’ May 1, 2015, scoping comment letter was reviewed and considered. The nearest study locations to the Project Site were included in the freeway threshold checks. Two of the three off-ramp locations identified in the Caltrans scoping letter (SB SR-170 to Laurel Canyon Boulevard/Oxnard Street and Victory Boulevard) were included in the threshold check for freeway off-ramps (Traffic Study Table E-3) and are labeled as locations #2 and #3, respectively. The third off-ramp location (Burbank Boulevard) was not included in the threshold check as no Project-related trips were assumed to use this facility because it was determined to be too far from the Project Site and because the northbound off-ramp located along Oxnard Street provides direct access to the Project Site and is located closer to the Project Site on a more direct path. Because no Project-related trips are assigned to this ramp, no impacts can occur and no further analysis is warranted.

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LADOT and Caltrans have entered into a series of agreements designed, among other things, to establish screening thresholds designed to identify when a project may have potential impacts to Caltrans facilities, including freeway segments and ramps. In this case, the applicable screening thresholds are established per agreement between LADOT and Caltrans, memorialized in a Memorandum of Understanding dated October 2013 (“the 2013 LADOT/Caltrans MOU”). The 2013 LADOT/Caltrans MOU sets a capacity threshold of 1,500 veh/hr/lane for freeway ramp level of service analysis. The 2013 LADOT/Caltrans MOU and the 1,500 veh/hr/lane screening threshold are applicable to the Project, based on the fact that the Project MOU for the Project’s Traffic Study was approved and signed by LADOT on March 4, 2015. Actual traffic counts in the Traffic Study for each off-ramp facility were conducted in November 2014 (see Draft EIR page 4.M-8). Thus, off-ramp level of service for the Project was calculated using the applicable 1,500 vehicles per hour/per lane capacity as specified in the 2013 LADOT/Caltrans MOU. The 2013 LADOT/Caltrans MOU establishes a threshold for all ramps and does not state that a different analysis is needed to determine appropriate ramp capacity for a controlled ramp.

The purpose of the 2013 LADOT/Caltrans MOU is to identify if there is a need for any further CEQA analysis. Per the 2013 LADOT/Caltrans MOU, the following thresholds apply for off-ramps:

 For a freeway off-ramp operating at LOS D, if Project-related vehicle trips were to exceed 2% of the assumed ramp capacity of 1,500 vehicles per hour per lane, then additional analysis is required.

 For a freeway off-ramp operating at LOS E or F, if Project-related vehicle trips were to exceed 1% of the assumed ramp capacity of 1,500 vehicles per hour per lane, then additional analysis is required.

Therefore any freeway off-ramps operating at LOS C or better do not exceed the threshold check, indicating that no significant impacts would be anticipated.

The threshold check was conducted consistent with the 2013 LADOT/Caltrans MOU using traffic count data collected in November 2014. The resulting evaluation showed that all freeway off-ramp locations identified are expected to operate at LOS C or better and therefore do not meet the criteria requiring further analysis. It should be noted that the Traffic Study identified that the existing conditions at the intersection of Oxnard Street & SR-170 Northbound Ramps are LOS C during the AM peak hour and LOS B during the PM peak hour, as shown in Table 2.2 of the Traffic Study, and based on traffic counts conducted in November 2014. In addition, the Traffic Study shows that the freeway off-ramp operates at LOS B in the AM peak hour and LOS C in the PM peak hour, as shown in Table E-3 of the Traffic Study, based on traffic counts conducted in November 2014 and analyzed using the methodology outlined in the 2013 LADOT/Caltrans MOU. The combination of the threshold check results and the existing conditions at the intersection indicate that no significant impacts would be anticipated.

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City of Los Angeles June 2016

Comment No. A1-4

Pages 27-29 of the TS (Table 4.1 NOHO WEST Project Trip Generation Estimates) indicates proposed retail credits for 15% internal trips and 30% for pass-by trips. However the existing department store only has 20% pass-by trips. We believe the existing retail credit should be higher to achieve a reasonable credit for the analysis. Nevertheless, the project still generates 7,270 daily trips, 710/759 AM/PM peak hour trips.

Response to Comment No. A1-4

All proposed trip credits were calculated in accordance with LADOT Traffic Study guidelines. Per LADOT guidelines, pass-by trip credits for retail land uses are calculated based on the overall size of the land use analyzed. Per Attachment I of LADOT’s Traffic Study guidelines, a retail use or shopping center consisting of between 300,000 square feet and 600,000 square feet is eligible for a reduction of 20%. The existing department store is approximately 465,000 square feet and therefore qualifies for a reduction of 20% based on its size. Similarly, based on LADOT guidelines, the internal trip and pass-by credits for the Project were calculated based on the size of the specified uses and components, namely retail uses of 209,648 square feet (30% pass-by per Attachment I) and cinema uses of 1,750 seats (10% pass-by per Attachment I). (See Draft EIR Table 4.M-4.)

Comment No. A1-5

From Table 3.1 Related Project List and Trip Generation Estimates, the related project will generate 22,998 daily trips, 1,254/1,983 AM/PM peak hour trips. Compared to other projects from the City of Los Angeles, the related trips seem to be unreasonably low. Those trips should be referenced, validated, and verified. There would be potential cumulative traffic impacts due to the 9 related projects in the project vicinity. The TS does not provide a cumulative traffic analysis on the mainline SR-170 and on/off ramps. As a reminder, the decision makers should be aware of this issue and be prepared to mitigate cumulative traffic impacts in the future.

Response to Comment No. A1-5

The related projects list included in the Traffic Study consists of all development projects located within a 1.5-mile radius of the Project Site that are currently under construction, already approved, or that have progressed through the approval process to a point of being considered a viable project, per LADOT Traffic Study guidelines. The number of trips generated by the identified related projects is lower compared to other projects from the City of Los Angeles simply due to the fact that there are fewer pending development projects currently proposed in this area of the City of Los Angeles. The related projects list and the trip generation estimates provided in Table 3.1 of the Traffic Study were calculated in coordination with and verified by LADOT.

The Traffic Study followed the protocol outlined under the applicable 2013 LADOT/Caltrans MOU. The Traffic Study does not provide a cumulative threshold check of the SR-170 freeway mainline and off-

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ramp facilities, because the 2013 LADOT/Caltrans MOU provides that only existing traffic conditions are used to determine whether a freeway analysis threshold has been met. A cumulative Congestion Management Program analysis for designated arterial roadway intersections and freeway monitoring stations was included in the Traffic Study, as required by LADOT Traffic Study guidelines and County of Los Angeles Congestion Management Program guidelines. None of the analyzed locations were identified as meeting the CMP criteria for additional impact analysis and therefore, no cumulative impacts are anticipated.

Comment No. A1-6

Storm water run-off is a sensitive issue for Los Angeles and Ventura counties. Please be mindful that projects should be designed to discharge clean run-off water. Additionally, discharge of storm water runoff is not permitted onto State highway facilities without a storm water management plan.

Response to Comment No. A1-6

The Project will comply with all permit procedures regarding storm water runoff. In addition, the Draft EIR includes Regulatory Compliance Measures H-1 through H-4, which would ensure that potential impacts related to storm water runoff are less than significant.

Comment No. A1-7

Transportation of heavy construction equipment and/or materials, which requires the use of oversized- transport vehicles on State highways, will require a transportation permit from Caltrans. It is recommended that large size truck trips be limited to off-peak commute periods.

Response to Comment No. A1-7

The Project will comply with all permit procedures for oversized vehicles. Regarding limiting large size truck trips to off-peak periods, Mitigation Measure M-9 (Construction Traffic Management Plan) requires construction-related deliveries to be scheduled to reduce travel during peak commute periods to the extent possible. In addition, Project entitlements include a Haul Route which will include requirements from LADOT regarding where and when haul trips are to be conducted. Nevertheless, Caltrans’ recommendations are acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. A1-8

In the Spirit of Mutual Co-operation, Caltrans would like to work with the City in an effort to evaluate traffic impacts, identify potential improvements, and establish a funding mechanism that helps mitigate cumulative transportation impacts in the project vicinity.

If you have any questions, please feel free to contact Alan Lin the project coordinator at (213) 897-8391 and refer to IGR/CEQA No. 151218AL-DEIR.

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Response to Comment No. A1-8

As discussed above, the Traffic Study followed the terms of the agreed upon 2013 LADOT/Caltrans MOU between LADOT and Caltrans, and in consultation with LADOT, it was determined that Project traffic did not meet or exceed any of the thresholds identified in the MOU. The 2013 LADOT/Caltrans MOU evidences the cooperation between Caltrans and LADOT. The 2013 LADOT/Caltrans MOU, among other things, provides criteria for identifying when freeway analysis is required and the methodology for such studies. In addition, the 2013 LADOT/Caltrans MOU indicates that LADOT and Caltrans will meet regularly to update criteria and to meet and confer regarding revisions to the City's CEQA Thresholds Guide with respect to impacts to the State Highway System. Accordingly, there are established methods of coordination between Caltrans and the City. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. A2

Andrei Tcharssov LADWP Water Resources Development 111 N. Hope Street, Room 1450 Los Angeles, CA 90012

Comment No. A2-1

Water Resources Division of the Los Angeles Department of Water and Power (LADWP) is submitting to you the following comments to the Draft Environmental Impact Report (DEIR) for the NoHo West Project (ENV-2015-888-EIR). These comments reflect our review for matters related to water resources for the project; you may receive additional comments from other divisions at LADWP, separately, referring to other respective areas in the DEIR, such as water infrastructure capacity, etc.

Our understanding is that comments are due to the City Planning Department by 1/17/16.

Water Resources Comments:

1. PAGE 4.N.2-2, Footnote 1, 4. Environmental Impact Analysis N. Utilities and Service

Systems 2. Water

Comments:

1. The link for footnote 1 does not work. Please provide the date accessed or provide a functional link with the new date accessed or navigational directions to find the appropriate website reference.

Response to Comment No. A2-1

The link for drought information has been updated (see Section 3, Additions and Corrections, of this Final EIR). Information is available by navigating to LADWP.com > About Us > Water > Water Conservation > Drought Information, and also Ordinance & Codes, or at: https://www.ladwp.com/ladwp/faces/wcnav_externalId/a-w-c-droughtinfo?_adf.ctrl- state=yqthn02n7_29&_afrLoop=484396131899223

Comment No. A2-2

2. PAGE 4.N.2-4, Municipal Water Conservation, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

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1. The first sentence of the third paragraph states that water use in the City of Los Angeles is currently less than it was 40 years ago. Indicate the time period the 40 year reference applies to such as 1970 ‐ 2010 and provide a reference.

Response to Comment No. A2-2

The time indicated is from 1970 to 2010, when the Urban Water Management Plan (UWMP) was finalized. See page 346 of the 2010 UWMP.

Comment No. A2-3

3. PAGE 4.N.2-5, Water Supply, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The numbered list in Water Supply section does not state the time period the supply percentages apply to. Indicate the time period for the reported supply percentages or update the percentages. Updated water supply 5‐year average (2010 and 2014) ratios can be accessed through the link in footnote 4.

Response to Comment No. A2-3

In response to this comment, the Water Supply percentages are updated to reflect the 5-year average from 2010-2014:

LA Aqueduct (from Eastern Sierra Nevada) – 34%

Purchased Water from Metropolitan Water District) – 53%

Groundwater – 12%

Recycled Water – 1%

The change does not affect the analysis nor the conclusions reached in the Draft EIR. This change is reflected in Section 3, Corrections and Additions, of this Final EIR.

Comment No. A2-4

2. The last sentence of the last paragraph and the first paragraph on the next page states:

“The City water system includes 114 tanks and reservoirs ranging in size from 10,000 to 60 billion gallons, with a total capacity of approximately 111 billion gallons. Water is distributed through a network of 7,225 miles of water mains ranging from 4 inches to 120 inches in diameter. Because of the size and range in elevation, the system is divided into 102 pressure zones, and has almost 90 booster pumping stations to provide water service at higher elevations.”

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Please replace with the following:

“The City water system includes 114 tanks and reservoirs within its service area and nine more reservoirs along the Los Angeles Aqueduct System, ranging in size from 10,000 to 60 billion gallons. The storage capacity within the service area is approximately 15,245 acre-feet, and the capacity of the Los Angeles Aqueduct System is approximately 300,000 acre-feet. Water is distributed through a network of approximately 7,200 miles of water mains ranging from 4 inches to 120 inches in diameter. Because of the size and range in elevation, the system is divided into 124 pressure zones, and has 78 booster pumping stations to provide water service at higher elevations.”

The latest information can be accessed on LADWP.com through the following path:

About Us>Water>Facts & Figures. Please also provide reference and date accessed.

Response to Comment No. A2-4

In response to this comment, this change is reflected in Section 3, Corrections and Additions, of this Final EIR. The change does not affect the analysis, nor the conclusions reached in the Draft EIR.

Comment No. A2-5

4. PAGE 4.N.2-6, Local Groundwater, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The second sentence of the third paragraph states that San Fernando Groudwater Basin (SFB) is accounting for nearly 80 percent of all local groundwater pumped by LADWP. Please indicate the time period this statement applies to and provide a reference. On average, SFB provided approximately 79 percent of the City’s groundwater supply during the period FYEs 2006 ‐ 2010. See Exhibit 6B on p. 123 of 2010 UWMP.

Response to Comment No. A2-5

Comment No. A2-6

5. PAGE 4.N.2-7, Local Groundwater, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

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1. The second sentence of the first paragraph states that local groundwater has been delivering approximately 71,087 AFY since 2005. Please indicate the time period this statement applies to. On average, local groundwater provided approximately 71,087 AFY during the period FYEs 2006 ‐ 2010. See p. 123 of 2010 UWMP.

Response to Comment No. A2-6

Comment No. A2-7

6. PAGE 4.N.2-7, Metropolitan Water District (MWD) Purchases, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The last sentence of the second paragraph states that MWD supplied approximately 52 percent or approximately 318,000 AFY of the City’s water supply between 2005 and 2010. The information is partially incorrect. On average, MWD supplied approximately 52 percent, or approximately 326,012 AFY, of the City’s water supply for the period FYEs 2006 ‐ 2010. See Exhibit ES‐Q, p. 19 of 2010 UWMP.

Response to Comment No. A2-7

Comment No. A2-8

2. The last sentence of the third paragraph states that LADWP’s current reliance on MWD water supply is projected to be cut in half to 24 percent of total LADWP demand by 2034 under average weather conditions. LADWP’s reliance on MWD water supply is projected to be cut in half from the five‐year average of 52 percent of the total demand for the period FYEs 2006 ‐ 2010 to 24 percent by FYE 2035 under average weather conditions. See p. 191 of 2010 UWMP. Please correct statement to include corrected time periods.

Response to Comment No. A2-8

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Comment No. A2-9

7. PAGE 4.N.2-8, Current and Future Water Use, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The last sentence of the second paragraph states that LADWP provides over 700,000 water service connections. The number of connections varies from year to year hovering above and below 700,000. Please change “over” to “approximately.”

Response to Comment No. A2-9

Comment No. A2-10

2. The first sentence of the third paragraph states: “According to the 2010 UWMP, water use in the City of Los Angeles was approximately 550,000 AFY, which represents a decrease of approximately 100,000 AFY as compared to water use 40 years ago, even though the City’s population has increased by approximately one million people during this period.” However, the information provided through the reference to p.8 of 2010 UWMP does not support that statement. For example, the time period displayed in Exhibit ES‐E spans from 1970 to 2010. For example, while the exhibit does show and approximate value of 550,000 AF for 2010, the values shown for 1970 and 1971 are both approximately 600,000 AF or below. Therefore, the decrease in water use was not close to 100,000 AF. Please revise accordingly and include time periods. For more direction, see also the narrative on the same page as well as .

Response to Comment No. A2-10

Comment No. A2-11

8. PAGE 4.N.2-8, Footnote 15, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. With respect to footnote 15, which refers to p. 20 of the 2010 UWMP, potential future water supply sources of the 2010 UWMP (see Exhibit ES‐R of p.20) do not include seawater desalination. Please revise accordingly.

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Response to Comment No. A2-11

Comment No. A2-12

9. PAGE 4.N.2-10, Water Treatment, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The fifth sentence of the first paragraph states that the current average annual flow through LAAFP is approximately 362 million gallons per day, or 405,000 AFY (averaged over CY 2013). The information is outdated. The current average annual flow through LAAFP is approximately 324 million gallons per day, or approximately 360,000 AFY, averaged over CY 2014. Please revise accordingly.

Response to Comment No. A2-12

Comment No. A2-13

2. In the second sentence of the second paragraph and throughout DEIR, consider changing CDPH to DDW. The function once held by the CA Dept. of Public Health (CDPH) has been transferred to the State Water Resources Control Board (SWRCB), Division of Drinking Water (DDW), usually notated as DDW.

Response to Comment No. A2-13

Comment No. A2-14

10. PAGE 4.N.2-12, Project Impacts Construction, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The first sentence of the paragraph under “Methodology” states: “The Project’s environmental impacts on water are based on the estimated increase in water demand and the capacity of the water infrastructure to meet that demand.” Please add “and supplies” after “infrastructure” to read: “The Project’s

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environmental impacts on water are based on the estimated increase in water demand and the capacity of the water infrastructure and supplies to meet that demand.”

Response to Comment No. A2-14

Comment No. A2-15

11. PAGE 4.N.2-12, Project Impacts Construction, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The fourth sentence of the first paragraph under “Project Impacts – Construction” section states that recycled water can be used for dust control. Recycled water is currently available from recycled water fill stations. The nearest fill station to the construction site is located in Van Nuys, however, LADWP may install additional fill stations closer to the construction site. LADWP encourages the developer to contact Mario Acevedo, Manager of the Water Recycling Group at (213) 367‐0761 or [email protected] to learn more about fill stations and the possible use of recycled water for dust control.

Response to Comment No. A2-15

This information will be added to the Final EIR. See Section 3, Corrections and Additions, to this Final EIR. The change does not affect the analysis, nor the conclusions reached in the Draft EIR.

Comment No. A2-16

12. PAGE 4.N.2-14, Operation Water Demand, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The first paragraph begins with: “The LAAFP currently has the capacity to treat and convey an additional 125 mgd of water. The Project’s net increase of 0.18 mgd represents approximately 0.14 percent of the LAAFP’s available capacity. As the current treatment plant capacity of LAAFP is estimated to be adequate for future demands, the Project would not require the construction or expansion of new water treatment facilities that could cause a significant environmental effect.”

However, stating the project’s water demand as a percentage of the total LAAFP treatment capacity is not the basis for determining the adequacy of LAAFP treatment capacity for the project. LAAFP treatment capacity for any project is generally sufficient if the project water demand is accounted for in LADWP’s

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total City demand projections. The maximum water treatment capacity at the LAAFP is 600 million gallons per day, or approximately 672,000 AFY. LAAFP typically treats water from LAA and most of the purchases through MWD. The current average annual flow through LAAFP is approximately 324 million gallons per day, or approximately 360,000 AFY, averaged over CY 2014. Exhibit 11E of 2010 UWMP shows that the total annual water supplies from LAA and MWD between years 2020 through 2035 are less than 470,000 AFY. Additionally, in accordance with the project’s Water Supply Assessment, the project’s maximum net increase in water demand is 298 AFY and it is accounted for in the City’s future projected demands as explained in the project’s Water Supply Assessment. Consequently, the current treatment capacity of LAAFP is estimated to be adequate to accommodate the project’s future water demand as the demand is included in future demand projections and the LAAFP is expected to be able to meet the requirements of treating these projected demands. Please revise accordingly.

Response to Comment No. A2-16

Comment No. A2-17

13. PAGE 4.N.2-17, Cumulative Impacts, 4. Environmental Impact Analysis N. Utilities and Service Systems 2. Water

Comments:

1. The statement beginning with the last sentence of the last paragraph and continuing through to the second sentence on the following page reads: “The total cumulative water demand (cumulative projects + Project) is approximately 0.45 mgd and represents approximately 0.36 percent of the total remaining daily capacity. Therefore, the LAAFP would have adequate capacity to treat the water demanded by the Project and cumulative projects.”

However, stating the total cumulative water demand as a percentage of the total LAAFP treatment capacity is not the basis for determining the adequacy of LAAFP treatment capacity for the total cumulative projects’ water demand. Each of the cumulative projects is required to be consistent with the SCAG RTP projections in order to be accounted for in LADWP’s 2010 UWMP current and projected available water demand. Should the related projects be accounted for in LADWP’s 2010 UWMP, no significant cumulative water supply impact is anticipated from development of the Project and the cumulative projects. Additionally, the maximum water treatment capacity at the LAAFP is 600 million gallons per day, or approximately 672,000 AFY. LAAFP typically treats water from LAA and most of the purchases through MWD. The current average annual flow through LAAFP is approximately 324 million gallons per day, or approximately 360,000 AFY, averaged over CY 2014. Exhibit 11E of 2010 UWMP shows that the total annual water supplies from LAA and MWD between years 2020 through 2035 are less than 470,000 AFY. Consequently, the current treatment capacity of LAAFP is estimated to be

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adequate to accommodate the projected over-all water demand, which includes the cumulative water demand of the Project and related projects.

Response to Comment No. A2-17

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LETTER NO. A3

Elizabeth Cavajal, Transportation Planning Manager LACMTA Development Review One Gateway Plaza MS 99-23-4 Los Angeles, CA 90012

Comment No. A3-1

Thank you for the opportunity to comment on the Draft Environmental Impact Report for the proposed NoHo West Project located at 6150 North Laurel Canyon Boulevard and 12001 West Oxnard Street in the City of Los Angeles. The project includes redevelopment/reuse of the Project Site with a mix of commercial, retail and residential land uses. This letter conveys recommendations from the Los Angeles County Metropolitan Transportation Authority (LACMTA) concerning issues that are germane to our agency's statutory responsibility in relation to our facilities and services that may be affected by the proposed project.

Metro bus lines 230 and 154 operate on Oxnard Street and Laurel Canyon Boulevard, adjacent to the proposed project. One Metro bus stop on the Oxnard Street (Oxnard/Macys stop) is directly adjacent to the proposed project. The following comments relate to bus operations and the bus stop:

1. Although the project is not expected to result in any long-term impacts on transit, the developer should be aware of the bus facilities and services that are present. The existing Metro bus stops must be maintained as part of the final project.

Response to Comment No. A3-1

The first two paragraphs of the comment provide general introductory information and are therefore acknowledged for the record.

Regarding the existing bus stop, the Project Applicant will coordinate with Metro to ensure that the existing bus stop is maintained as part of the final Project.

Comment No. A3-2

2. During construction, the stops must be maintained or relocated consistent with the needs of Metro Bus Operations. Please contact Metro Bus Operations Control Special Events Coordinator at 213-922-4632 regarding construction activities that may impact Metro bus lines at least 30 days in advance of initiating construction activities. For closures that last more than six months, Metro's Stops and Zones Department will also need to be notified at 213-922-5188, 30 days in advance of initiating construction activities. Other municipal bus may also be impacted and should be included in construction outreach efforts.

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Response to Comment No. A3-2

During construction, the Project Applicant will coordinate with Metro to ensure that existing bus stops are either maintained in their current locations or are relocated to appropriate locations, as agreed upon by Metro or other applicable agencies, to accommodate specific construction activities. No other municipal bus lines/routes will be impacted by the Project’s construction activities.

Comment No. A3-3

3. LACMTA encourages the installation of bus shelters, benches and other amenities that improve the transit rider experience. The City should consider requesting the installation of such amenities as part of the development of the site. The Developer may wish to consider the offering of transit passes for tenants to both reduce the carbon footprint of the property as well as encourage transit use.

Response to Comment No. A3-3

Although no significant impacts to transit facilities are anticipated, the Project Applicant will work with City and Metro staff to determine whether any bus shelters or transit amenities can be installed as part of the final Project.

To ensure a conservative analysis, the Traffic Study did not include a reduction in Project-related vehicle trips due to residents, patrons, or tenants using transit to travel to/from the Project Site. In addition, a new Project Design Feature has been added to the Final EIR (see PDF M-10 in Section 3, Additions and Corrections) which reiterates the Project’s incorporation of Transportation Demand Management (TDM) strategies into the Project.

Comment No. A3-4

4. Final design of the bus stops and surrounding sidewalk area must be Americans with Disabilities Act (ADA) compliant and allow passengers with disabilities a clear path of travel to the bus stop from the proposed development.

Response to Comment No. A3-4

The Project Applicant will be required by existing laws and regulations to ensure that the final designs for all bus stops and surrounding sidewalks comply with ADA regulations and requirements.

Comment No. A3-5

Beyond impacts to Metro facilities and operations, LACMTA must also notify the applicant of state requirements. A Transportation Impact Analysis (TIA), with roadway and transit components, is required under the State of California Congestion Management Program (CMP) statute. The CMP TIA Guidelines are published in the "2010 Congestion Management Program for Los Angeles County", Appendix D (attached). The geographic area examined in the TIA must include the following, at a minimum:

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1. All CMP arterial monitoring intersections, including monitored freeway on/off-ramp intersections, where the proposed project will add 50 or more trips during either the a.m. or p.m. weekday peak hour (of adjacent street traffic).

2. If CMP arterial segments are being analyzed rather than intersections, the study area must include all segments where the proposed project will add 50 or more peak hour trips (total of both directions). Within the study area, the TIA must analyze at least one segment between monitored CMP intersections.

3. Mainline freeway-monitoring locations where the project will add 150 or more trips, in either direction, during either the a.m. or p.m. weekday peak hour.

4. Caltrans must also be consulted through the NOP process to identify other specific locations to be analyzed on the state highway system. Also, Caltrans and Metro will not be responsible for noise abatement measures (i .e. noise walls) for developments built adjacent to an existing freeway.

The CMP TIA requirement also contains two separate impact studies covering roadways and transit, as outlined in Sections 0.8.1 - 0.9.4. If the TIA identifies no facilities for study based on the criteria above, no further traffic analysis is required. However, projects must still consider transit impacts. For all CMP TIA requirements please see the attached guidelines

Response to Comment No. A3-5

A CMP analysis in accordance with the CMP TIA guidelines of all arterial intersection monitoring stations and freeway mainline monitoring stations was included in the Traffic Study prepared for the Project. The results of these analyses showed that Project-related traffic volumes would not exceed the specified thresholds at any of the identified locations or facilities, and therefore no further analyses is required. As part of the project’s transportation analysis, transit use by Project residents and patrons was assumed to be negligible to ensure that the traffic impact analysis in the Traffic Study was conservative. Based on this transportation analysis approach, a CMP transit impact analysis was not required. Caltrans was notified of the publication of the NOP, as required, and provided scoping comments, which are included in Appendix C of the Draft EIR. The Project acknowledges that Metro and Caltrans are not responsible for any required noise abatement measures.

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LETTER NO. A4

Gwynneth Doyle, CEQA Project Manager, CP Los Angeles Unified School District Office of Health and Safety 333 South Beaudry Ave., 21st Floor Los Angeles, CA 90017

Comment No. A4-1

Presented below are comments submitted on behalf of the Los Angeles Unified School District (LAUSD) regarding the Draft Environmental Impact Report for the subject project. Due to the fact that Victory Boulevard Elementary School is located approximately 670 feet to the north of the proposed project site, LAUSD is concerned about the potential negative impacts of the project to our students, staff and parents traveling to and from the referenced campuses.

Based on the extent/location of the proposed development, it is our opinion that significant environmental impacts on the surrounding community (air quality, noise, traffic, pedestrian safety, etc.) will occur. Since the project will have a significant impact on LAUSD schools, mitigation measures designed to help reduce or eliminate such impacts are included in this response.

Response to Comment No. A4-1

The comment provides introductory information and general statements regarding air quality, noise, traffic, and pedestrian safety. Responses to the specific comments related these issues are provided below in Responses to Comments A4-2 through A4-5.

Comment No. A4-2

Air Quality

District students and school staff should be considered sensitive receptors to air pollution impacts. Construction activities for the proposed project would result in short term impacts on ambient air quality in the area resulting from equipment emissions and fugitive dust. To ensure that effective mitigation is applied to reduce construction air pollutant impacts on the Victory Boulevard Elementary School, we ask that the following language be included as a mitigation measure for air quality impacts:

• If the proposed mitigation measures do not reduce air quality impacts to a level of insignificance, the project applicant shall develop new and appropriate measures to effectively mitigate construction related air emissions at the affected Victory Boulevard Elementary School. Provisions shall be made to allow the school and or designated representative(s) to notify the project applicant when such measures are warranted.

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Response to Comment No. A4-2

As demonstrated in Table 4.C-8 on page 4.C-21 of the Draft EIR, the implementation of Mitigation Measures C-1 through C-5, and Regulatory Compliance Measures C-6 and C-7, would reduce construction-related air quality impacts to less than significant levels. No additional mitigation is warranted.

Comment No. A4-3

Noise

Noise created by construction activities may affect the Victory Boulevard Elementary School in proximity to the proposed project site. These construction activities include grading, earth moving, hauling, and use of heavy equipment. The California Environmental Quality Act requires that such impacts be quantified, and eliminated or reduced to a level of insignificance.

LAUSD established maximum allowable noise levels to protect students and staff from noise impacts generated in terms of Leq. These standards were established based on regulations set forth by the California Department of Transportation and the City of Los Angeles. LAUSD's exterior noise standard is 67 dBA Leq and the interior noise standard is 52 dBA Leq.

A noise level increase of 3 dBA or more over ambient noise levels is considered significant for existing schools and would require mitigation to achieve levels within 2 dBA of pre-project ambient level. To ensure that effective mitigations are employed to reduce construction related noise impacts on District sites, we ask that the following language be included in the mitigation measures for noise impacts:

• If the proposed mitigation measures do not reduce noise impacts to a level of insignificance, the project applicant shall develop new and appropriate measures to effectively mitigate construction· related noise at the affected Victory Boulevard Elementary School. Provisions shall be made to allow the school and or designated representative(s) to notify the project applicant when such measures are warranted

Response to Comment No. A4-3

As demonstrated in Table 4.J-11 on page 4.J-22 of the Draft EIR, the implementation of Mitigation Measures J-1 through J-5 and Regulatory Compliance Measure J-7 would reduce construction noise impacts to less than significant levels. Note that Table 4.J-11 identifies a sensitive receptor at 6205 Gentry Avenue, which is located at the corner of Gentry Avenue and Erwin Street, and is the closest sensitive receptor to Victory Boulevard Elementary School. After mitigation, construction noise levels at 6205 Gentry Avenue would increase by 2.1 dBA. This receptor is also closer to the Project Site than Victory Boulevard Elementary School. Therefore, impacts to Victory Elementary School from construction noise would be less than significant and no further mitigation is warranted.

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Comment No. A4-4

Traffic/Transportation

LAUSD' s Transportation Branch must be contacted at (213) 580-2950 regarding the potential impact upon existing school bus routes. The Project Manager or designee will have to notify the LAUSD Transportation Branch of the expected start and ending dates for various portions of the project that may affect traffic within nearby school areas. To ensure that effective mitigations are employed to reduce construction and operation related transportation impacts on District sites, we ask that the following language be included in the mitigation measures for traffic impacts:

• School buses must have unrestricted access to schools.

• During the construction phase, truck traffic and construction vehicles may not cause traffic delays for our transported students.

• During and after construction changed traffic patterns, lane adjustment, traffic light patterns, and altered bus stops may not affect school buses' on-time performance and passenger safety.

• Construction trucks and other vehicles are required to stop when encountering school buses using red- flashing-lights must-stop-indicators per the California Vehicle Code.

• Contractors must install and maintain appropriate traffic controls (signs and signals) to ensure vehicular safety.

• Contractors must maintain ongoing communication with LAUSD school administrators, providing sufficient notice to forewarn children and parents. when existing vehicle routes to school may be impacted.

• Parents dropping off their children must have access to the passenger loading areas.

Response to Comment No. A4-4

Construction traffic impacts to nearby schools, including Victory Elementary School, are discussed at Draft EIR pages 4.M-35 to 36. A mitigation measure for potential impacts to both public and private schools (MM M-8) is recommended in the Draft EIR. The provisions requested by the comment from LAUSD are already included in Mitigation Measure M-8 (in Draft EIR Section 4.M, Transportation/Traffic).

Comment No. A4-5

Pedestrian Safety

Construction activities that include street closures, the presence of heavy equipment and increased truck trips to haul materials on and off the project site can lead to safety hazards for people walking in the

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vicinity of the construction site. To ensure that effective mitigations are employed to reduce construction and operation related pedestrian safety impacts on District sites, we ask that the following language be included in the mitigation measures for pedestrian safety impacts:

• Contractors must maintain ongoing communication with LAUSD school administrators, providing sufficient notice to forewarn children and parents when existing pedestrian routes to school may be impacted.

• Contractors must maintain safe and convenient pedestrian routes to all nearby schools. The District will provide School Pedestrian Route Maps upon your request.

• Contractors must install and maintain appropriate traffic controls (signs and signals) to ensure pedestrian and vehicular safety.

• Haul routes are not to pass by any school, except when school is not in session.

• No staging or parking of construction-related vehicles, including worker-transport vehicles, will occur on or adjacent to a school property.

• Funding for crossing guards at the contractor's expense is required when safety of children may be compromised by construction-related activities at impacted school crossings.

• Barriers and/or fencing must be installed to secure construction equipment and to minimize trespassing, vandalism, short-cut attractions, and attractive nuisances. '

• Contractor's are required to provide security patrols (at their expense) to minimize trespassing, vandalism, and short-cut attractions.

Response to Comment No. A4-5

Construction traffic impacts to nearby schools, including Victory Elementary School, are discussed at Draft EIR pages 4.M-35 to 4.M-36. A mitigation measure for potential impacts to both public and private schools (Mitigation Measure M-8) is recommended in the Draft EIR. With the exception of the fourth bullet point, the requested language is already included in Mitigation Measure M-8 (in Draft EIR Section 4.M, Transportation/Traffic). Mitigation Measure M-8 in the Draft EIR provides that “Construction vehicles shall avoid, to the extent feasible, travel on streets immediately adjacent to Laurel Hall School.” This mitigation measure will be amended to include reference to Victory Elementary School (see Section 3, Additions and Corrections, of this Final EIR).

Comment No. A4-6

The District's charge is to protect the health and safety of students and staff, and the integrity of the learning environment. The comments presented above identify potential environmental impacts related to the proposed project that must be addressed to ensure the welfare of the students attending Victory

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Boulevard Elementary School, their teachers and the staff, as well as to assuage the concerns of the parents of these students. Therefore, the measures set forth in these comments should be adopted as conditions of project approval to offset unmitigated impacts on the affected school students and staff.

Thank you for your attention to this matter. If you need additional information please contact me at (213) 241-3433.

Response to Comment No. A4-6

This comment summarizes and concludes the commenter’s requests. The specific comments are addressed in Responses to Comment Nos. A4-2 through A4-5.

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LETTER NO. A5

Diann Corral, President Laurel Grove Neighborhood Association 6013 Carpenter Avenue North Hollywood, CA 91606

Comment No. A5-1

The following comments relate specifically to the Proposed NoHo West Project located at 6150 North Laurel Canyon Blvd and 12001 West Oxnard Street, Los Angeles, California 91606 (the 'Project") Draft Environmental Impact Report (DEIR) dated December 3, 2015. Based on a review and analysis of the DEIR and the comments received from the stakeholders of this area of North Hollywood, the Board of the Laurel Grove Neighborhood Association (the "LGNA") in its response below is conveying the concerns raised about the impact that the Project will have on our community

It is our hope and expectation that the analyses by the Department of City Planning of both the DEIR and our concerns regarding it are performed in a fair, unbiased and objective manner. We are anxious to preserve our family-friendly neighborhood. Our concerns are valid and we expect your analysis of them to be substantive and not simply dismissed as merely having been noted.

Response to Comment No. A5-1

The comment provides general introductory information, which is acknowledged for the record. Responses to the specific comments are provided below.

Comment No. A5-2

EIR Study Page No. B. Aesthetics, SCENIC VISTAS, Page I-10

The DEIR indicates No Mitigation Required and No Impact.

We do not agree that there are no scenic vistas that would be substantially affected by the development of the project. Not addressed in the DEIR are Scenic Vistas looking south from north of the proposed project. As submitted in our LGNA Initial Study comments: "[A] Potentially Significant Impact [will occur] as the proposed six-story apartments will deprive homeowners north of Erwin Street between Laurel Canyon Blvd. and Radford Avenue as well as pedestrians along Erwin Street views presently seen of Mount Lee, Los Angeles' most prominent geographic feature as well as views of the Hollywood hills to the west." Those current residents who will suffer the greatest negative visual impact from the proposed project are those living north of Erwin Street. (Please see our exhibits B-1.1, B-1.2, B-1.3, B-1.4) The EIR must address the Project's visual impact on them. Certainly the authors of the DEIR know there are southerly vistas as well as the northerly ones they do consider. This oversight is again symptomatic of a less than objective analysis.

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Currently it is an empty parking lot with no housing to obstruct the view of the mountains (see Exhibit B- 2). The site as it stands lets in light and is zoned as Parking. These two massive buildings are not similar to that of any residential buildings in the area. The size, mass and architecture of the proposed two six story buildings and two six story parking structures along Erwin Street and Radford Avenue does not fit in with the adjacent community of single family homes along Erwin Street and two story apartments along Radford Avenue (see Exhibit B-1.1, B-1.2, B-1.3, B-1.4, B-3). The impact of the proposed project would be significant and its impact at that height cannot be mitigated. The developer should not be allowed to go any higher than 3 stories (36 feet) on the portion of the property that runs along Erwin Street and Radford Ave which is currently zoned P for Parking Only.

Response to Comment No. A5-2

As stated at pages 4.B.1-2 and 4.B.1-4 of the Draft EIR, the City of Los Angeles CEQA Thresholds do not protect views available from private vantage points such as private offices or private homes. With respect to views from public roadways, the Draft EIR acknowledges that views in the Project vicinity consist of views toward the Verdugo Hills, Santa Susana Mountains, and the San Gabriel Mountains (see Draft EIR) page 4.B.1-5). Views of the Hollywood Hills and Mount Lee are also available in the general Project vicinity. There are, however, no designated scenic vistas or scenic vista viewpoints in any direction from the Project Site; such a designation requires panoramic views or vistas that provide visual access to a large geographic area for which the field of vision can be wide and extend into the distance (see Draft EIR page 4.B.1-3). Such vistas do not exist in the vicinity of the Project site, where views are currently partially obstructed due to existing development in the Project area. The Project would add additional density to the Project Site when compared to existing conditions. However, the additional buildings would not exceed the maximum height of the existing Macy’s building (the tallest structure in the Project), which would remain at 105 feet. As such, there are no scenic vistas that would be substantially affected by the Project.

The Draft EIR on page 4.B.1-7 acknowledges that the proposed building heights and massing would represent a change in the visual character of the Project Site when compared to existing conditions. However, the existing Macy’s building would remain as the tallest building in the Project. In addition, the massing of the Project's buildings would be softened by substantial landscaped setbacks, varying façade relief, articulation, and windows. The residential buildings would have a maximum height of six stories, but the portions of the buildings abutting Erwin Street would only be three stories in height. The buildings are also stepped back away from the surrounding uses, to a maximum height of six stories. Further, the placement of the multi-family residential units adjacent to the existing single-family homes provides an appropriate transition between the existing neighborhoods and the Project's commercial uses. Finally, the commenter’s request that the apartments be limited to 3 stories/36 feet is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-3

EIR Study Page No. B. Aesthetics, VISUAL CHARACTER OF DESIGN, Page I-11

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The DEIR Indicates Less than Significant Impact

We do not agree with the DEIR that the Project poses less than significant impact, as the significant impact in increasing the density of land use on the site will alter the visual character of the Project site and area. The site as it stands lets in light and is zoned as Parking. These two massive buildings are not similar to that of any residential buildings in the area. The size, mass and architecture of the proposed two six story buildings and two six story parking structures along Erwin Street and Radford Avenue does not fit in with the adjacent community of single family homes along Erwin Street and two story apartments along Radford Avenue. Nor does it conform to the North Hollywood- Valley Village Community Plan which states that "The Plan proposes that the low-density residential character of North Hollywood- Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses." (Exhibit B-4, North Hollywood-Valley Village Community).

The goal was echoed by CD 2 Councilmember Krekorian's office on his very first day in office in February 2010 in Curbed Los Angeles it was announced that he'll look at "each project on a case-by-case basis, judging them on how best they fit in with community guidelines."(Exhibit B-5, Curbed LA Article February 3, 2010)

Response to Comment No. A5-3

See Response to Comment No. A5-2 regarding the placement of the Project adjacent to existing single- family homes.

Regarding the portion of the comment about the Project’s consistency with the North Hollywood – Valley Village Community Plan, the Project would be consistent with the existing Community Commercial land use designation for the Project Site in the Community Plan. The Project’s consistency with the Community Plan is addressed in Draft EIR Table 4.I-5 (in Section 4.I., Land Use). As demonstrated in Table 4.I-5, the Project would be consistent with all applicable Community Plan policies. In addition, the Project would not encroach upon any properties zoned for or developed with single-family housing.

Comment No. A5-4

In light of same we are requesting an alternative project of mixed use development with retail on the ground floor and residential above with all new buildings being built at a maximum height of 45' feet on the entire property, similar to the Americana project in Glendale, CA (Exhibit B-6, picture of Americana 4 stories). We are also requesting that the alternative study include a substantial reduction in the number of residential units. With planned structures along Erwin Street and Radford Avenue of no more than 3 stories, 36 feet. An increase in the retail square footage to a minimum of 500,000 square feet and office space component of no more than 500,000 square feet. This lot is part of the Laurel Canyon Commercial Corridor and according to the North Hollywood Valley Village- Community Plan "the Los Angeles City Planning Commissions has approved the expansion of the Laurel Plaza Regional Shopping Center" (see Exhibit B-7). This Project site has been for decades a Commercial site and in the Community Plan it is described as a Regional Shopping Center. The alternative plan should include more retail square footage

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than residential square footage in keeping with the Community Plans description of this site as a Regional Shopping Center. Also we request that the Project include a minimum of 2 acres of Open Space for the neighborhood to gather and an additional minimum of 1 to 2 acres of open space solely for the residents of the apartment units.

Response to Comment No. A5-4

In addition, partly in response to comments received on the Draft EIR, the Project Applicant has requested the City to consider Alternative 4B to the Project. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B includes 658 residential units, instead of the 742 residential units analyzed in the Draft EIR, as well as an increase in retail and restaurant space from 191,200 square feet for the Project to 274,816 square feet. The Project and all alternatives that include residential uses would place the parking structure and commercial uses closest to the freeway to act as a buffer between the proposed residential units and the freeway. This design keeps the residential units more than 500 feet from the freeway, which is not only consistent with City policy, but also minimizes residents' exposure to vehicle exhaust and particulate matter emanating from the freeway. In addition, the location of the proposed multi-family residential units would provide an appropriate transition between the Project’s commercial uses and the adjoining single-family neighborhood, which is consistent with policy 3.2.4 of the City’s Framework Element of the General Plan.

The comment also requests a reduction in height for the Project, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration. However, as explained in Section 4.B of the Draft EIR, the heights of Project buildings would not cause significant environmental impacts. It should also be noted that the Macy’s building that currently exists on the Project Site, and would be largely retained under the Project and all Alternatives other than Alternative 2 and 2A, has a maximum height of 105 feet. In addition, as part of Alternative 4B the height of the residential units along Calvert Place has been reduced to three stories.

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would allow approximately 890 dwelling units on the 357,000 square feet of the Site that are zoned C4. The remainder of the Project Site is in the P zone, which only allows for surface parking uses. However, the Project is requesting a Zone and Height District change from C4-1L, (Q)C4-1L, and P-1L to (Q)C2-1 to make the zoning consistent throughout the Project Site.

The comment also requests a minimum of 2 acres of open space within the Project for the neighborhood to gather, and a maximum building height along Erwin Street and Radford Avenue of 36 feet. Regarding open space, both the Proposed Project and Alternative 4B include more than two acres of outdoor space where the neighborhood can gather. Regarding height, the portion of the residential building abutting Erwin Street would be three stories in height; and the building is designed to be stepped back from the surrounding residential uses to a maximum height of six stories at the interior portions of the site. Nevertheless, the commenter’s requests regarding height and open space are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-5

Rather than having the proposed swimming pools atop the residential parking structure of the Project, which with the 6 story height of the proposed 742 units would be intrusive to the adjacent neighborhood, let's keep the character of this community and include open space on the ground for the residents of the apartments to enjoy. Similar to the open space provided for the condominium units at 10715 Camarillo Street, which includes a pool, spa, bathrooms with changing rooms, barbecue area, outdoor lighting, trees, and a park/grass area for the residents (See Exhibit B-8). This will also provide a more family friendly open space for potential residents who have children. The open space for the residential units should be a minimum of 1 - 2 acres.

Response to Comment No. A5-5

The commenter’s preference regarding the location of the proposed open space does not raise a significant environmental issue, but is acknowledged for the record and will be forwarded to the decision- making bodies as part of the Final EIR for their review and consideration. As mentioned in Response to Comment No. A5-4, both the Project and Alternative 4B include more than two acres of outdoor space where the neighborhood can gather.

Comment No. A5-6

We request that the proposed project use rooftops for solar panels and commit to participation in the Million Solar Roofs Program, that is, abandon its non-participation as stated on DEIR page 4.F-21. Solar panels need to be included on the top floor of the commercial parking structure as well.

Response to Comment No. A5-6

Because the Project would not cause a significant impact with respect to greenhouse gas emissions, the comment does not raise a significant environmental issue. However, the request that the Project

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participate in the Million Solar Roofs Program and that the Project include solar panels on the roof tops is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-7

The architectural style should compliment the existing neighborhood. Absent drawings of the proposed apartment structures, "designed in a modern architectural style, with articulated building facades and accent colors to provide visual interest," are inappropriate design criteria. Any project structures neighboring existing residential homes should complement them and not contrast with them. The Final EIR must include drawings of proposed structures along Erwin Street and Radford Avenue and not a brief and vague verbal description.

Response to Comment No. A5-7

As discussed above in Response to Comment No. A5-2, the placement of the multi-family residential units adjacent to the existing single-family homes provides an appropriate transition between the existing neighborhoods and the commercial uses proposed as part of the Project. The Project is designed in a modern architectural style, which is consistent with the adjacent residential uses that are developed in a mix of architectural styles.

Comment No. A5-8

We request that a Community Advisory Committee consisting of residents adjacent (within 1,000 feet) of the property be established to review the landscaping plan.

Response to Comment No. A5-8

The comment does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the request for the formation of a Community Advisory Committee to review the landscape plans is acknowledged for the record.

Comment No. A5-9

EIR Study Page No. B. Aesthetics, VIEWS AND VIEWSHEDS, Page I-12

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation required or no impact. We request installation of poles and horizontally-placed demarcation to show - accurately ---the height and breadth of the proposed Project to include all buildings and parking structures with the exception of Macy's. This request is not an unusual request in urban planning and should take place no later than the release of a recirculated DEIR or the Final EIR, whichever occurs first.

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Response to Comment No. A5-9

The commenter’s request for installation of poles and demarcation is acknowledged for the record. The second paragraph of this comment is the same as the second paragraph of Comment No. A5-2. Therefore, see Response to Comment No. A5-2.

Comment No. A5-10

EIR Study Page No. B. Aesthetics, SHADE/SHADOWS, Page I-12

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation required and no impact. The DEIR holds strictly to the benchmark winter and summer solstice dates, 9:00AM to 3:00PM and 9:00AM to 5:00PM respectively. Additional studies are needed for hours outside these time windows. Homes to the north of Erwin Street with photo-voltaic electric panels will be negatively impacted by the project. Exhibit B-9 shows the home at the corner of Erwin Street and Radford Avenue with its extensive installation of photo-voltaic panels. California's commitment to a greener environment and reduced C02 emissions as embodied in California legislation AB 32 should guide any environmental impact report. While "The project does not include solar roofs and is not part of the proposed [Million Solar Roofs Program.]", DEIR page 4.F -21, the project should in no way interfere with the efficacy of installed or future solar panels on the roofs of homes to the north of the project.

The proposed six-story apartments along Erwin Street and Radford Avenue will cause significant shading to residences north of Erwin Street. We request that the height of these structures be reduced to 3 stories (36 feet) so that the neighboring single family residences are not impacted with shading and so that the project does not interfere with the existing solar panels on the roofs of the adjacent single family homes.

Response to Comment No. A5-10

The L.A. CEQA Thresholds Guide considers a shadow impact to be significant if shadow-sensitive uses would be shaded by Project-related structures for more than three hours between the hours of 9:00 AM and 3:00 PM during winter conditions, or for more than four hours between the hours of 9:00 AM and 5:00 PM during the summer conditions. As discussed in Draft EIR pages 4.B.2-1 through 4.B.2-3, the

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shadow lengths for the winter and summer solstices represents the extremes of the shadow pattern throughout the year. Shadows cast on the summer solstice are the shortest shadows during the year, becoming progressively longer until winter solstice, when the shadows are the longest of the year. Therefore, the selected dates and hours for which the shadows were modeled is appropriate, and no additional analysis is necessary.

Further, as shown in Figures 4.B-15 through 4.B-20, the Project would not result in a significant shadow impact on any surrounding sensitive uses, including the homes to the north of Erwin Street. In fact, as shown on these figures, the Project would cast very minimal shadows on the homes north of Erwin Street shading only a portion of some of the front yards at 3:00 PM during the winter solstice (see Figure 4.B- 17). While the neighboring single-family residences would not be impacted by Project shadows, the request that the Project be reduced to 3 stories is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-11

We also take this opportunity to request that the project rethink its non-commitment to the Million Solar Roofs Program and that the project include solar panels on the roof tops and on the top floor of the commercial parking structure as well.

Response to Comment No. A5-11

Because the Project would not cause a significant impact with respect to greenhouse gas emissions, the comment does not raise a significant environmental issue. However, the request that the Project participate in the Million Solar Roofs Program and that the Project include solar panels on the roof tops is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-12

EIR Study Page No. B. Aesthetics, NIGHTTIME LIGHT, Page I-12

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact of increase in lighting. The DEIR only mentions the lighting for the commercial portion of the project, it does not address the residential component of the project which consists of a 6 story wall of apartments facing single family homes and the lighting related to these apartments, where currently there is only an empty parking lot. The addition of the 6 story apartments and the lighting issues in relation to the existing single story family homes need to be addressed. Light pollution created by the proposed apartment structures is a serious concern. Too much light pollution has consequences: it washes out starlight in the night sky, disrupts ecosystems, has adverse health effects and wastes energy. We request that the lighting issues with regards to the apartments be addressed and that the height of the apartments be reduced to 3 story (36' feet height maximum).

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Response to Comment No. A5-12

Draft EIR page 4.B.3-3 addresses the lighting impacts of both the Project's commercial and residential components. The Draft EIR acknowledges that light generated from the interior of the proposed buildings could potentially be seen from moderate distances away from the Project Site. However, as discussed on Draft EIR page 4.B.3-3, the increase in light that would be generated would not be out-of-character with the existing light sources in the Project vicinity. Furthermore, the light generated from the Project would be designed to contain illumination on-site (Project Design Feature B-5) and would comply with applicable LAMC regulations (Regulatory Compliance Measure B-7). For these reasons, it was determined that Project impacts with respect to nighttime lighting would be less than significant.

The request that the apartments be limited to 3 stories/36 feet is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-13

EIR Study Page No. B. Aesthetics, CUMULATIVE IMPACTS, Page I-13

The DEIR indicates No Mitigation Required and No Impact.

We do not agree that there is no mitigation required and no impact from the cumulative projects in proximity to the Project. The Final EIR needs to address the adjacent Valley Plaza project and it's possible shadow impacts as this project is likely to include high rise apartments as well.

In addition to visual aesthetics, words and names have aesthetic appeal and value as well. The NoHo name is now associated with the immediate environs of the North Hollywood Redline Station. It is an urbanizing area with the great majority of residents being apartment dwellers. The great majority of residents in the immediate environs of Laurel Plaza live in single-family, owner-occupied homes. Applying the name NoHo West to the proposed development evokes an image out of character with its surroundings. A variation on the name Laurel Plaza or Laurel Grove is a far better fit. Furthermore, the name NoHo West has already been commandeered by a North Hollywood neighborhood council approximately one mile to the northwest of Laurel Plaza. See Exhibit B-10. For these reasons, the development demands a different name, a name that incorporates its history and its neighborhood, and not one subject to confusion with the footprint of an existing neighborhood council.

Response to Comment No. A5-13

The potential shadow impacts of the Valley Plaza project would be addressed in the course of that project’s environmental review. The distance of the Valley Plaza site from the Project Site (the Valley Plaza site is approximately 750 feet northwest of the Project Site) would preclude any cumulative visual or shadow impacts from the combination of the two projects.

The portion of the comment about the Project’s name does not raise an environmental issue. In addition, the City cannot lawfully control the (non-obscene) name a private property owner selects for its property.

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Comment No. A5-14

EIR Study Page No. C. Air Quality, CONSTRUCTION REGIONAL IMPACTS, Page I-13

The DEIR indicates Less than Significant Impact

We request an analysis of the local impacts on air quality. As documented in Exhibit C-1, the southeast San Fernando Valley is subject to a high frequency of south-southeasterly winds. The windscreen effect of the proposed six-story apartments on existing residences to the north-northwest of them needs to be investigated.

Response to Comment No. A5-14

As outlined in the Draft EIR at pages 4.C-12 to 4.C-17, pursuant to SCAQMD guidance, an analysis of localized criteria pollutant impacts for NO2, CO, PM10, and PM2.5 was performed that focused on a comparison of the gross emissions from the Project’s construction and operation against Localized Significance Thresholds that were established by the SCAQMD. Based on implementation of Mitigation Measures C-1 through C-5 and Regulatory Compliance Measures C-6 through C-10 for the construction phases of the Project, the Project would not result in significant impacts.

It is assumed that the “windscreen effect” refers to the commenter’s opinion that the Project buildings would influence the speed and direction of localized air pollutants in the area. Based on SCAQMD guidance and the fact that, as mitigated, Project emissions fall below SCAQMD thresholds, further dispersion modeling is not required and therefore localized wind effects are not a factor.

Comment No. A5-15

We request air filters be installed for all apartments on the project as they are within 500 feet of the existing Laurel Hall School and the 170 freeway.

Response to Comment No. A5-15

The installation of air filters for all apartments is not required to mitigate any impacts associated with construction or operation of the Project. As noted in the analysis contained in Draft EIR Section 4.C., both construction and operational impacts are less than significant following implementation of Mitigation Measures C-1 through C-5, Regulatory Compliance Measures C-6 through C-10, and Project Design Features C-11 through C-13.

Comment No. A5-16

We again request that a Community Advisory Committee consisting of residents adjacent (within 1,000 feet) of the property be established to review on-site construction activity including resolution of issues related to PM generation.

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Response to Comment No. A5-16

The request for formation of a Community Advisory Committee is acknowledged for the record. Note that pursuant to Regulatory Compliance Measures RCM-C-6, the developer is required to comply with SCAQMD Rule 403, which governs fugitive dust emissions during the construction phase, and which is enforceable directly by the SCAQMD.

Comment No. A5-17

In the DEIR it says that they shall ensure that construction vehicles avoid, to the extent feasible, travel on streets immediately adjacent (Radford Ave & Oxnard St) to Laurel Hall School. We additionally request that construction vehicles avoid all neighboring residential streets as well, and particularly Erwin Street and Radford Avenue, immediately adjacent to Laurel Plaza with its existing single family homes.

Response to Comment No. A5-17

The proximity of the Hollywood Freeway at Oxnard Street and Laurel Canyon Boulevard to the Project reduces the likelihood that construction vehicles would use neighboring residential streets such as Erwin Street. In connection with the Project approvals, the City will approve a Haul Route with conditions. The commenter’s request that construction vehicles avoid residential streets is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-18

EIR Study Page No. C. Air Quality, CONSTRUCTION LOCAL IMPACTS, Page I-16

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact. We request an analysis of the local impacts on air quality. As documented in Exhibit C-1, the southeast San Fernando Valley is subject to a high frequency of south-southeasterly winds. The windscreen effect of the proposed six-story apartments on existing residences to the northnorthwest of them needs to be investigated.

Response to Comment No. A5-18

See Response to Comment No. A5-14.

Comment No. A5-19

EIR Study Page No. C. Air Quality, CONSTRUCTION ODORS, Page I-17

The DEIR indicates No Mitigation Required and No Impact

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We do not agree that there is no mitigation required and no impact. This needs to be changed to Potentially Significant Impact. As reported in the study Diurnal and Seasonal Wind Variability For Selected Stations in Southern California Climate Regions: "Burbank (Bob Hope) Airport, at the southeast end of the San Fernando Valley, shows a very high frequency of south-southeasterly resultants . . . . From May to September, mean vector winds are oriented in this direction for virtually all hours of the day." (see Exhibit C-1) These prevailing winds have the strong potential to blanket homes north of Erwin with cooking odors proposed from the two restaurants proposed for the northwest corner of the proposed project.

Response to Comment No. A5-19

Regarding the impact of potential winds, see Response to Comment No. A5-14.

Regarding potential odors, as discussed in DEIR at page 4.C-16, the Project is not anticipated to create objectionable odors. Unpleasant odors from future restaurants would be addressed by SCAQMD Rule 402, which governs nuisance odors.

Comment No. A5-20

EIR Study Page No. C. Air Quality, OPERATIONAL REGIONAL IMPACTS, Page I-17

The DEIR indicates Less than Significant Impact

Response to Comment No. A5-20

This comment is the same as Comment No. A5-19. Therefore, please see Responses to Comment Nos. A5-14 and A5-19.

Comment No. A5-21

EIR Study Page No. C. Air Quality, OPERATIONAL ODORS, Page I-18

The DEIR indicates No Impact

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We do not agree that there is no impact, this needs to be changed to Potentially Significant Impact. As reported in the study Diurnal and Seasonal Wind Variability For Selected Stations in Southern California Climate Regions: "Burbank (Bob Hope) Airport, at the southeast end of the San Fernando Valley, shows a very high frequency of south-southeasterly resultants .... From May to September, mean vector winds are oriented in this direction for virtually all hours of the day." (see Exhibit C-1) These prevailing winds have the strong potential to blanket homes north of Erwin with cooking odors proposed from the two restaurants proposed for the northwest corner of the proposed project.

Response to Comment No. A5-21

This comment is the same as Comment No. A5-19. Therefore, please see Responses to Comment Nos. A5-14 and A5-19.

Comment No. A5-22

EIR Study Page No. C. Air Quality, CUMULATIVE IMPACTS, Page I-18

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact. Please provide actual traffic counts at all intersections along Oxnard Street, Laurel Canyon Blvd, and at the intersection of any secondary highways with any other streets of whatever size within a half mile radius of the Project site and utilize those actual counts in the calculation of the air quality impacts.

Response to Comment No. A5-22

The comment expresses the opinion that further evaluation of cumulative air quality impacts is necessary, but does not state any specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. As stated in the Draft EIR, cumulative air quality impacts were evaluated pursuant to SCAQMD’s significance thresholds. Modeling of impacts pursuant to traffic data as requested in the comment is not required.

Comment No. A5-23

EIR Study Page No. E. Geology and Soils, FAULT RUPTURE, Page I-22

The DEIR indicates No Mitigation Required and No Impact

We do not agree there no impact. We are concerned with the height of the buildings. As was evident in the 1994 earthquake commercial buildings on this site of a much lesser height were significantly damaged by that seismic disruption. Because of the significant earthquake damage, the mall attached to the Macy's building was demolished in 1994. In light of same we are requesting that any new residential buildings have a height limit of 36 feet and commercial buildings have a height limit of 45 feet.

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EIR Study Page No. E. Geology and Soils, STRONG SEISMIC GROUND SHAKING, Page I-22

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation and no impact, as the project is susceptible to ground motion as a result of potential movement along faults in the region. According to the California Institute of Technology's Earthquake Data Center, the 1994 Earthquake (See Exhibit E-1) occurred due to a rupture on a blind thrust fault. The DEIR admits that for the project, earthquake "magnitudes higher than 6.0 cannot be precluded" but nonetheless determines that such an eventuality should have No Impact on the project design. A second opinion is definitely called for here. We request that the Los Angeles Department of Building and Safety review in detail the Geology and Soils findings in the DEIR for the project.

Response to Comment No. A5-23

As discussed in the geotechnical report prepared for the Project (included as Appendix F to the Draft EIR) and on page 4.E-6 of the Draft EIR, the active fault closest to the Project Site is the North Hollywood Fault, which is located approximately 2,500 feet south of the Project Site. According to the preparers of the Geotechnical Engineering Investigation, the North Hollywood Fault does not present a ground surface rupture hazard to the Project Site. In addition, the Project would be required to be constructed in conformance with the most recently adopted California Building Code, which has been updated since the 1994 Northridge earthquake. Finally, the Project’s final geotechnical report will be reviewed and approved by the Department of Building and Safety and the conditions contained within the approval letter must be followed (see Regulatory Compliance Measure E-1). Therefore, the integrity of the Project's buildings would not result in a significant impact. The commenter’s request regarding the height of the buildings is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

In addition, it should be noted that after the Draft EIR was completed, the California Supreme Court decided California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal.4th 369 (2015). The Court decided that CEQA is not generally applicable to the impacts of the existing environment on a proposed project’s future users. In so doing, the Court specifically found “erroneous and unauthorized by CEQA” the provisions of CEQA Guidelines section 15026.2(a) stating that an EIR should address impacts of active faults on future occupants of a project. Accordingly, the City will address the potential for seismic damage to Project buildings as a code compliance issue rather than a CEQA issue.

Comment No. A5-24

EIR Study Page No. E. Geology and Soils, LIQUIFACTION, Page I-22

The DEIR indicates No Mitigation Required and No Impact

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The DEIR contention that no mitigation is required for soil liquefaction caused by earthquakes is egregiously without merit. Failure of on-site corings to detect the water table down to 60 feet taken in 2014, 3 years into a statewide 100-year drought and after significant groundwater pumping by the Los Angeles Department of Water and Power do not constitute a basis for the No Impact conclusion of the DEIR. The Los Angeles Department of Building and Safety (LADBS) Parcel Profile for the site (Exhibit E-2) indicates that YES, the area is subject to Earthquake-Induced Liquefaction. Additionally, The project is within the area identified as subject to liquefaction as shown on the State of California, Seismic Hazard Zones, Van Nuys Quadrangle, Official Map (Exhibit E-3).

Exhibit E-4 taken from the NavigateLA website shows the historic Highest Groundwater Contours in the vicinity of Laurel Plaza. This map clearly shows these groundwater depths to be between 20 and 30 feet. We also note here that the central branch of the Tujunga Wash is immediately to the west of the site. Whatever construction eventually occurs at Laurel Plaza needs to be designed to last many years, through both drought years and rainy years. As earthquakes and climate have no correlation, LADBS prudently lists the site as subject to liquefaction. Any final conclusion as to whether the Laurel Plaza site is subject to earthquake-induced liquefaction must be left up to LADBS and if any alteration is made to their present finding, we request timely notification to the Laurel Grove Neighborhood Association in order that our concerns be heard. We also note here that the mall structure to the south of the extant Macy's store that existed before the 1994 Northridge Earthquake was razed as a result of that quake. While we realize that modeling and studies based on computer-simulations are necessary for planning purposes, real-life, historical events should not be forgotten.

Response to Comment No. A5-24

As acknowledged in both the geotechnical report prepared for the Project (included as Appendix F to the Draft EIR) and on page 4.E-4 of the Draft EIR, the Seismic Hazards Maps of the State of California classify the Project Site as part of the potentially “Liquefiable” area. This determination is based on groundwater depth records, soil type, and distance to a fault capable of producing a substantial earthquake. Therefore, a site-specific liquefaction analysis was performed for the Project Site. While groundwater was not encountered during excavation to a maximum depth of 60 feet below the existing ground surface, the historic high groundwater level of 25 feet below ground surface was conservatively used for the liquefaction analysis. The results of the liquefaction analyses indicate that the soils underlying the Project Site would not be capable of liquefaction during a major seismic event. In addition, to confirm the results of the analyses, the Project’s final geotechnical report will be reviewed and approved by the Department of Building and Safety and the conditions contained within the approval letter must be followed (see Regulatory Compliance Measure E-1).

In addition, as noted above, after the Draft EIR was completed, the California Supreme Court decided California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal.4th 369 (2015). The Court decided that CEQA is not generally applicable to the impacts of the existing environment on a proposed project’s future users. In so doing, the Court specifically found “erroneous and unauthorized by CEQA” the provisions of CEQA Guidelines section 15026.2(a) stating that an EIR should address impacts of active faults on future occupants of a project. Accordingly, the City will

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address the potential for seismic damage to Project buildings as a code compliance issue rather than a CEQA issue.

Comment No. A5-25

EIR Study Page No. E. Geology and Soils, LANDSLIDE, Page I-23

The DEIR indicates No Mitigation Required and Less than Significant Impact

The neighboring 170 freeway lies atop an elevated, man-made embankment. We request that the LADBS review the landslide potential for the embankment and the integrity of the types of structures for construction immediately to its east.

Response to Comment No. A5-25

The comment requests analysis of the potential impacts of the 170 freeway on the Project. However, as noted above, CEQA requires analysis of the potential impacts of a project on the environment, not vice versa.

Comment No. A5-26

EIR Study Page No. E. Geology and Soils, SOIL STABILITY, Page I-23

The DEIR indicates Less than Significant Impact

Soil stability and the potential for liquefaction are closely related. Please see our comments above concerning the DEIR's attempt to contravene the LADBS finding regarding liquefaction potential for the sight and request that LADBS a make a fresh review of soil stability.

Response to Comment No. A5-26

Refer to Response to Comment No. A5-24 regarding the potential for liquefaction to occur at the Project Site. Soil stability is discussed on page 4.E-8 of the Draft EIR. As stated, some seismically-induced settlement of the proposed structures should be expected as a result of strong ground shaking. However, neither the soil nor the geologic conditions would preclude construction of the Project provided the recommendations of the Geotechnical Engineering Investigation are followed and implemented during design and construction to the satisfaction of the Department of Building and Safety (formally included as Regulatory Compliance Measure E-3 in the Draft EIR).

Comment No. A5-27

EIR Study Page No. F. Greenhouse Gas Emissions, CUMULATIVE IMPACTS, Page I-24

The DEIR indicates No Mitigation Required and Less than Significant Impact

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We do not agree that there is less than significant impact. The Project will have 742 apartments with 1,312 parking spaces; office and retail space with an additional 2,569 parking spaces. The Project alone will result in thousands of additional car trips per year. Please quantify numerically the cumulative impact on GHG emissions of this Project and other proposed developments in the surrounding area. The project should commit to participation in the Million Solar Roof Tops program in order to partially offset its contribution to GHG emissions.

Response to Comment No. A5-27

The GHG emissions for the Project have been quantified (see Table 4.F-3 in the Draft EIR). The Project is evaluated based on its consistency with State, regional, and local climate action plans (see analysis contained on pages 4.F-20 through 4.F-23 of the Draft EIR). The assessment of GHG emissions from other projects is not appropriate, as cumulative impacts on global climate change are not a function of calculating emissions of other localized projects. Rather, the Project's consistency with climate change plans is the basis for assessing its significance on global GHG emissions and climate change. Finally, the portion of the comment requesting participation in the Million Solar Roof Tops program is acknowledged for the record.

Comment No. A5-28

EIR Study Page No. G. Hazards and Hazardous Materials, RELEASE OF HAZARDOUS MATERIALS, Page I-25

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact, as the Macy's building and adjacent buildings may contain asbestos containing- materials and lead-based-paint. We agree that prior to the issuance of any permit for the demolition or alteration of the existing structures that the buildings be checked by a qualified asbestos consultant and lead base paint consultant and if any is found that it is safely disposed of according to OSHA regulations.

Response to Comment No. A5-28

Draft EIR pages 4.G-17 and 4.G-18 acknowledge that based on the age of the existing buildings on the Project Site, those buildings may contain asbestos-containing materials (ACM) and lead-based paint (LBP). However, as stated in Regulatory Compliance Measure G-2 on page 4.G-20, prior to the issuance of any permit for demolition or alteration of the existing structures, the Project Applicant will be required to provide a letter to the Department of Building and Safety from a qualified asbestos abatement consultant indicating that no ACMs are present. If ACMs are found, they will need to be abated in compliance with the SCAQMD’s Rule 1403 as well as other applicable State and Federal regulations. In addition, Regulatory Compliance Measure G-3 on page 4.G-20 states that prior to the issuance of any permit for demolition or alteration of the existing structures, a lead-based paint survey shall be performed to the written satisfaction of the Department of Building and Safety, and if LBP materials are identified,

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standard handling and disposal practices will be implemented pursuant to OSHA regulations. The Project’s compliance with these regulations would ensure that impacts related to ACMs and LBP are less than significant.

Comment No. A5-29

EIR Study Page No. G. Hazards and Hazardous Materials, HAZARDS WITHIN ¼ MILE OF A SCHOOL, Page I-26

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation required and no impact. The demolition currently proposed has a potentially significant impact, as it could potentially expose the Laurel Hall School which immediately adjacent to the property (within 100 feet) to hazardous waste.

The Project may emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste onto Laurel Hall School, a Kindergarten through 8th grade school which is on the same lot as the Project (see Exhibit G-1). Additionally, the Victory Boulevard Elementary School at 6315 Victory Blvd. comes within 756 feet of the Laurel Plaza site and the effects of construction activity on this elementary school must be evaluated.

Prior to the issuance of any permit for the demolition or alteration of the existing structures that the buildings be checked by a qualified asbestos consultant and lead base paint consultant and if any is found that it is safely disposed of according to OSHA regulations.

Response to Comment No. A5-29

As discussed in the Draft EIR on pages 4.G-16 and 4.G-17, the Project’s commercial component – like the existing commercial uses on the Project Site – may use and transport hazardous materials, including cleaning solvents, waxes, dyes, toners, paints, bleach, grease, and petroleum products. Because these materials are typical of non-industrial commercial, household, and institutional uses, most of the same materials would also be used at nearby schools themselves under existing conditions. The use, transport, or disposal of any of these materials is required to comply with applicable Federal, State, and local regulations to ensure that no impact would occur. Therefore, the Project would not create a hazard to the public or environment, including a neighboring school. In addition, as discussed on Draft EIR page 4.G- 18, the Phase I ESA prepared for the Project Site (included in Draft EIR Appendix G) did not identify any Recognized Environmental Conditions associated with the Project Site that would have the potential to impact any surrounding schools. Finally, as discussed in Response to Comment No. A5-28, prior to the issuance of any permit for demolition or alteration of the existing structures on the Project Site, the existing structures would be surveyed for ACMs and LBP, and if any materials are found, they would be handled and disposed of in accordance with State and Federal regulations. Therefore, these construction impacts would be less than significant.

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Comment No. A5-30

EIR Study Page No. G. Hazards and Hazardous Materials, CUMULATIVE IMPACTS, Page I-27

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is no mitigation required and less than significant impact as the demolition currently proposed has a potentially significant impact, and could potentially expose the neighborhood to hazardous waste.

Response to Comment No. A5-30

For the reasons discussed in Response to Comment Nos. A5-28 and A5-29, as well as in Draft EIR Section 4.G., the Project would result in a less than significant impact with respect to hazardous materials. In addition, any cumulative projects would be required to comply with applicable site-specific development standards, as well as the same Federal, State, and local hazardous materials regulations that apply to the Project. As a result, cumulative impacts with respect to hazardous materials would be less than significant.

Comment No. A5-31

EIR Study Page No. H. Hydrology and Water Quality, WATER QUALITY, Page I-27

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact, especially during construction and this issue needs to be addressed in the Final EIR. The city acknowledges its existing water supply infrastructure is old, inadequate and needs replacement. The Final EIR needs address the capacity of the City's water supply and infrastructures to meet the dense project's needs.

Response to Comment No. A5-31

The capacity of the City’s water supply and infrastructure to serve the Project is addressed in Section 4.N.2, Water, of the Draft EIR. Regarding water supply, the LADWP Board of Commissioners approved a water supply assessment for the Project (included as Appendix K-4 to the Draft EIR), finding that adequate water supplies would be available to meet the total demand of 298 acre feet per year for the Project for normal, single-dry, and multiple-dry years in addition to the existing and planned future demands of the LADWP.

The existing water supply infrastructure is discussed on Draft EIR pages 4.N.2-10 through 4.N.2-12. As stated on page 4.N.2-12, as part of the building permit process the City would confirm that there is sufficient capacity in the existing water supply infrastructure to accommodate the Project’s water needs. If a deficiency or service problem is discovered during the permitting process that prevents LADWP from providing an adequate level of service, the Project shall be responsible for funding the required upgrades

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to adequately serve the Project. This requirement is provided as Regulatory Compliance Measure N.2-5. Therefore, the Draft EIR adequately addresses the capacity of the City's water supply and infrastructure to meet the Project's needs, resulting in a less than significant impact.

The comment does not explain its disagreement with the Draft EIR’s conclusion that a less than significant impact to water supply and infrastructure would occur during Project construction. As stated on Draft EIR page 4.N-12, Project construction would require minimal water, and the water required for dust control would typically be provided by private purveyors and could be reclaimed/recycled water.

Comment No. A5-32

EIR Study Page No. H. Hydrology and Water Quality, DRAINAGE, Page I-28

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no impact. The storm drains on Oxnard Street in the vicinity of the Project appear inadequate as Oxnard Street currently floods during heavy rains. According to the Environmental Site Assessment - Phase I issued in October 2013 for the site for Goldstein Planting Investments (Exhibit H-1) , the site gently slopes to the southeast so that natural drainage from it will be to Oxnard Street.

EIR Study Page No. H. Hydrology and Water Quality, RUNOFF, Page I-28

The DEIR indicates Less than Significant Impact

We do not agree that there is less than significant impact. The storm drains on Oxnard Street in the vicinity of the Project appear inadequate as Oxnard Street currently floods during heavy rains. ( See immediately above.)

The increase in irrigation water from landscaping has the potential to create run offs that include pesticides and other garden chemicals. The Project needs to take measures to make sure this is mitigated.

Response to Comment No. A5-32

In its existing condition, the Project Site is almost entirely covered with impervious surfaces and slopes downward very gradually to the south, with approximately 10 feet of elevation change. Drainage across the Project Site is by sheet flow to area drains or City streets. The Project would replace the paved parking areas with new buildings and would add areas of vegetation and open space. Compared to the existing conditions, the Project would increase the amount of pervious surfaces, which would increase infiltration and help minimize runoff. Unlike the existing condition, the Project would also be required to comply with the City’s Low Impact Development Ordinance, which, among other requirements, mandates that rainwater from storms of ¾ inch and below be captured, infiltrated, or used onsite (see Draft EIR pages 4.H-8 and 4.H-9). Finally, the Project Site and surrounding areas are serviced by an MS4 system that is designed with capacity to handle 50-year storm flows (see Draft EIR page 4.H-17). As such, it was determined that the Project would not substantially alter the existing drainage pattern of the

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surrounding area in a manner that would result in substantial flooding on- or off-site (Draft EIR page 4.H- 14).

Regarding the portion of the comment about the increase in irrigation water from landscaping, Draft EIR page 4.H-13 acknowledges that runoff from the Project Site may include “nuisance flows” from landscape irrigation. However, the Project would be required to comply with the City’s Water-Efficient Landscaping Ordinance (LAMC Building Code Chapter 71), which would minimize landscape irrigation runoff and, therefore, pollutants associated with such runoff. Under existing conditions, storm water runoff from the Project Site contains similar types of urban pollutants, including landscape maintenance debris, which are currently uncontrolled and untreated. In addition, in accordance with NPDES requirements, the Project Applicant would be required to have a Project-specific storm water quality plan in place during the operational life of the Project to address the management of urban runoff from the Project Site (see Regulatory Compliance Measure H-1 on Draft EIR page 4.H-18). The storm water quality plan would include site design, source control, low-impact development, and treatment control BMPs. Accordingly, due to the fact that storm water runoff from the Project Site is currently uncontrolled and because the surface parking lot sheet flow is untreated when it enters the existing storm drain infrastructure, the quality of storm water drainage would likely improve as a result of Project development. Therefore, the Project would include measures to address pollution attributed to runoff and no impacts related to drainage would occur.

Comment No. A5-33

EIR Study Page No. H. Hydrology and Water Quality, CUMULATIVE IMPACTS, Page I-30

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is less than significant impact. The storm drains on Oxnard Street in the vicinity of the Project appear inadequate as Oxnard Street currently floods during heavy rains.

Response to Comment No. A5-33

Please see Response to Comment No. A5-32 regarding storm water drainage and runoff.

Comment No. A5-34

EIR Study Page No. I. Land Use and Planning, PHYSICALLY DIVIDE AN ESTABLISHED COMMUNITY, Page I-30

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation or no impact. The 6 story apartments located immediately adjacent to the existing single family homes would visually isolate homeowners North of Erwin Street with subsequent loss of identity with the existing single family neighborhood. We request that the apartments do not exceed 3 stories (36 feet).

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Response to Comment No. A5-34

The Project would be developed on a previously developed Site, and would not be of the size or type to physically divide an established community, nor would the Project impede access between parts of the community. A typical example of a project that would physically divide an established community is a project that involves a continuous right-of-way, such as construction of a new freeway, which would then divide a community and impede access between parts of the community. Here, the Project would improve rather than diminish physical connections because the existing residential neighborhoods would be linked to each other and to the Project’s commercial uses by tree-lined pedestrian, bicycle, and vehicle connections that would replace the Site’s existing unshaded asphalt parking lots. See Draft EIR Figures 2- 2 (Aerial Map), 3-6 (Conceptual Landscape Plan), and 3-7 (Conceptual Site Circulation Plan). In addition, the placement of the multi-family residential units adjacent to the existing single-family homes provides an appropriate transition between the existing neighborhoods and the Project's commercial component. The portion of the residential buildings abutting Erwin Street would only be three stories in height, stepping back from the surrounding uses to a maximum height of six stories. Further, as part of Alternative 4B, the height of the residential units along Calvert Place would be reduced from six stories to three stories, with the balconies facing the interior of the Project Site. Nevertheless, the commenter’s request that the apartments be limited to 3 stories/36 feet is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-35

EIR Study Page No. I. Land Use and Planning, ZONING, Page I-30

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no mitigation and no impact. The Project site is currently zoned for commercial and parking use only. It is not zoned for residential use. The addition of residential use does not conform with the North Hollywood- Valley Village Community Plan which states that "The Valley- Laurel Plaza Regional Shopping Area provides the community with retail uses contained in two malls located north and south of Victory Boulevard along Laurel Canyon Boulevard. On December 6, 1994 the City Council approved a new community redevelopment Project Area for the Laurel Canyon commercial corridor. The main focus of the redevelopment area is to assist in the rebuilding of structures damaged in the January 17, 1994 earthquake. Additionally, the Los Angeles City Planning Commission has approved the expansion of the Laurel Plaza Regional Shopping Center." (see Exhibit B-7)

In light of same and in keeping with the North Hollywood- Valley Village Community Plan's description of the site as a Regional Shopping Center and the site's current zoning as commercial, we are also requesting another alternative plan that includes Commercial use only at the site with retail square footage that is a minimum of 500,000 sq. ft. and a maximum of 500,000 sq. ft. of office space, with no residential use. We also request that the height of the buildings along Erwin Street and Radford Ave not exceed 3 stories, 36 feet and that there is a minimum of 2 acres of Open Space within the Project for the neighborhood to gather.

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Response to Comment No. A5-35

The comment is mistaken because residential uses are permitted in the North Hollywood-Valley Village Community Plan’s Community Commercial District and under the existing C4 zoning that applies to a large portion of the Project Site. The Community Plan designates the Project Site as Community Commercial. The Community Plan further states that the Community Commercial District corresponds with zoning that includes C2 and C4. Approximately 357,000 square feet of the Project Site is currently zoned C4, which according to LAMC Section 12.16, allows for development of any use permitted in the C2 zone, with some exceptions for uses such as bowling alleys, penny arcades, skating rinks, etc. The C2 zone permits uses developed in accordance with residential (R4) zoning regulations. These regulations would allow approximately 890 dwelling units on the 357,000 square feet of the Site that are zoned C4. The remainder of the Project Site is in the P zone, which only allows for surface parking uses. However, the Project is requesting a Zone and Height District change from C4-1L, (Q)C4-1L, and P-1L to (Q)C2-1 to make the zoning consistent throughout the Project Site.

The comment quotes a portion of the North Hollywood-Valley Village Community Plan describing a 1994 redevelopment plan for the Valley-Laurel Plaza Regional Shopping Area. The Project would include revitalized retail uses on the Project Site. The Project, including the proposed residential uses, is consistent with the existing Community Commercial land use designation for the Project Site, because residential uses are allowed within Community Commercial land uses. In addition, the Project Site is within the Laurel Canyon Commercial Corridor Redevelopment Project Area for the Laurel Canyon commercial corridor. The Redevelopment Plan was prepared by the Community Redevelopment Agency (CRA) in response to the 1994 Northridge Earthquake to facilitate and provide for the repair and replacement of properties damaged or destroyed by the earthquake. The Plan does not further restrict land use or add any building limitations which would be applicable to the proposed development.

The comment requests consideration of an all-commercial alternative including at least 500,000 square feet of retail and a maximum of 500,000 square feet of office space. This requested alternative closely resembles Alternative 1 analyzed in the Draft EIR at pages 6-6 through 6-12. Alternative 1, the No Project Alternative, provides 465,000 square feet of retail and 90,000 square feet of office use – nearly meeting the commenter’s proposed minimum of 500,000 square feet of retail and falling within the commenter’s proposed maximum of 500,000 square feet of office.

In addition, the Draft EIR provides an analysis of a smaller all commercial alternative (Alternative 2A discussed on pages 6-41 through 6-56 of the Draft EIR). Alternative 2A includes 150,000 square feet of office uses, 227,000 square feet of retail uses, 40,000 square feet of restaurant uses, and 100,000 square feet of cinema uses. However, Alternative 2A was rejected on the basis that it would not provide the critical mass and mix of uses necessary to activate the area, and would only meet some of the Project objectives.

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where the neighborhood can gather. Regarding height, the portion of the residential building abutting Erwin Street would be three stories in height; and the building is designed to be stepped back from the surrounding residential uses to a maximum height of six stories at the interior portions of the site. Nevertheless, the commenter’s requests regarding height and open space are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. A5-36

EIR Study Page No. I. Land Use and Planning, CUMULATIVE IMPACTS, Page I-30

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is less than significant impact. There is significant impact as cumulative consideration needs to be addressed as there are other projects within the vicinity that may overlap with the construction period of this Project. Such as the hotel proposed at Victory Boulevard and the 170 Freeway and the eventual development of the Valley Plaza site which is directly across the Laurel Canyon Boulevard from this Project (Exhibit I-1). The Laurel Grove Neighborhood Association covers an area from Victory Boulevard on the north to Burbank Boulevard on the south and east from Whitsett Avenue to Colfax Avenue. The massive apartment complex proposed is out of character with our neighborhood and will be an assault on its character. We want a project that complements our neighborhood, not one that will Balkanize it. (See Exhibit I-2)

Response to Comment No. A5-36

The comment does not identify any cumulative Land Use impact and instead suggests that simultaneous construction of the Project and other projects could cause significant cumulative impacts. The cumulative impacts of construction of the Project in relation to potential simultaneous construction projects have been fully analyzed in the Draft EIR and were found to be less than significant. The closest cumulative project to the Project Site is cumulative project #2 (Valley Plaza), which is located approximately 750 feet northwest of the Project Site. The eight other cumulative projects are located at further distances from the Project Site (see Draft EIR Figure 2-12 for the locations of the cumulative projects in relation to the Project Site). Cumulative impacts for each substantive issue have been analyzed in Draft EIR Sections 4.B through 4.N. Given the distance between the Project Site and the cumulative projects, the impacts of any overlapping construction periods would be attenuated such that impacts would be less than significant.

Regarding the Project's massing and Balkanization, please see Response to Comment No. A5-34, above.

Comment No. A5-37

EIR Study Page No. J. Noise, CONSTRUCTION NOISE, Page I-31

The DEIR indicates No Impact

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We do not agree that there is No Impact as the neighborhood is already exposed to freeway noises and has been waiting for decades for a soundwall northbound between Burbank Blvd and Oxnard Street on the 170 freeway and southbound between Victory Blvd and Burbank Blvd on the 170 freeway. Additional traffic and noise associated with the Project and construction will heighten the residential exposure to noise levels in excess of standards established.

Response to Comment No. A5-37

The Draft EIR does not conclude that the Project’s construction-related noise would have no impact. Rather, the Draft EIR analysis determined that construction-related noise impacts would be less than significant with implementation of Mitigation Measures J-1 through J-6.

Existing sound levels were measured at each sensitive receptor location shown in Draft EIR Figure 4.J-1. As a result, baseline noise measurements properly reflect the degree to which ambient noise levels at each monitored receptor are influenced by vehicular noise from the 170 Freeway.

The comment states that Project-related noise would increase residential noise levels in excess of relevant thresholds, but offers no substantial evidence in support of this conclusion. With the implementation of Mitigation Measures J-1 through J-6, construction noise at residential receptors is not projected to exceed the thresholds established in the City's L.A. CEQA Thresholds Guide, which are 10 dBA on any given day, 5 dBA for more than ten days in a three-month period, and 5 dBA over the course of construction activities. Additionally, the proposed mitigation measures would ensure that construction noise does not exceed the Los Angeles Municipal Code’s 75 dBA conditional limit for construction machinery at 50 feet of distance. Off-site vehicular noise increases were measured using the FHWA TNM 2.5 model and were not found to exceed thresholds for operational noise in any existing or future scenarios (see Draft EIR Tables 4.J-6 and 4.J-7 for existing plus Project levels, and Tables 4.J-9 and 4.J-10 for future plus Project levels). Finally, as discussed in Draft EIR pages 4.J-14 and 4.J-15, on-site operational noises that are typically associated with the Project’s land-uses were also analyzed and determined to be less than significant. Therefore, the Project would not cause noise impacts in excess of established thresholds.

Comment No. A5-38

In the DEIR it says that they shall ensure that truck deliveries and haul routes during construction will be directed away from Laurel Hall School. We additionally request that construction vehicles avoid all neighboring residential streets, Radford Avenue and Erwin Street in particular, immediately adjacent to existing single family homes.

Response to Comment No. A5-38

The comment does not dispute any findings or methods of the Draft EIR, nor does it suggest that additional impacts will occur. The commenter requests that Project Design Feature J-8 be amended so that delivery and haul routes avoid all proximate residential streets with single-family homes, specifically Radford Avenue and Erwin Street. The comment is acknowledged for the record and will be forwarded to

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decision-making bodies as part of the Final EIR for their review and consideration. In addition, as discussed in Response to Comment No. A1-7, the Project entitlements include a Haul Route which will include requirements from LADOT regarding where and when haul trips are to be conducted

Comment No. A5-39

EIR Study Page No. J. Noise, WITHIN 2 MILES OF AN AIRPORT, Page I-33

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is a less than significant impact. The neighborhood is exposed to plane noise due to the normal take off pattern from Burbank Airport. With the proposed changes at Burbank Airport this issue deserves some consideration.

Response to Comment No. A5-39

As detailed on Draft EIR page 4.J-18, while the Project Site is approximately 1.6 miles southwest of Bob Hope Airport, it is not located within the Airport Influence Area or its 65 dB, 70 dB, and 75 dB CNEL noise contours, so it is not deemed to be an incompatible use. Given that the Project Site falls outside of these zones, airport-related noises would not significantly impact the Project. This is not to say that the Project would experience no airport-related noises, but that noise from airport activities would not be considered significant.

Possible environmental noise concerns related to an expansion of airport facilities and/or uses would not be addressed by this analysis, but rather by analyses conducted specifically for any such potential future airport project.

Comment No. A5-40

EIR Study Page No. J. Noise, CUMULATIVE IMPACTS, Page I-34

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is a less than significant impact as the Project as proposed would significantly increase traffic in the neighborhood which would increase subsequent ambient noise levels, in particular that caused by additional traffic on the two residential streets of Erwin Street and Radford Ave. Additionally, the additional traffic leading into the Project on Oxnard Street and Laurel Canyon Blvd which both have access to the 170 Freeway, the Project will result in substantial permanent increase in ambient noise levels in the Project vicinity above levels currently existing without the Project.

Response to Comment No. A5-40

The Project’s traffic study projects an increase in vehicle traffic along Erwin Street and Radford Avenue as a result of Project operations. However, under 2020 cumulative conditions, there is no location where

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mobile noise generated by this additional traffic would cause ambient noise levels measured at the property lines of affected uses to increase by 5 dBA or more, which is the threshold of significance set by the L.A. CEQA Thresholds Guide.1 This is because the Project would not increase on-street volumes on Erwin Street or Radford Avenue enough to elevate ambient noise levels. Specifically, the City’s L.A. CEQA Thresholds Guide estimates that a 3 dB CNEL increase in noise generally requires a doubling of traffic volume, assuming a constant fleet mix and velocity. Therefore, Project-generated trips would not increase traffic volumes on Erwin Street or Radford Avenue to levels capable of creating a sustained 5 dBA increase over any hourly or other time period. Furthermore, given the location of the Project's driveways along Erwin Street and Radford Avenue, the majority of ingress and egress is unlikely to affect residential receptors along these streets, because Project traffic would be expected to immediately access or exit the site via arterial streets such as Laurel Canyon Boulevard and Oxnard Street, rather than drive along the segments of Erwin Street or Radford Avenue.

The Project-related traffic would not be sufficient to exceed the Noise Element’s 70 dB CNEL threshold for residential land-uses like those along Erwin Street and Radford Avenue. A 70 dB CNEL ambient noise level would be more commonly associated with busy, high-velocity arterial streets, not unlike Oxnard Street or Laurel Canyon Boulevard. Typically, streets such as these have peak hour traffic volumes in excess of 1,000 vehicles per travel direction. Erwin Street and Radford Avenue would not experience such volumes as a result of Project traffic. It is projected that no segment of Erwin Street or Radford Avenue would see traffic volumes in excess of 600 vehicles per hour in both directions. As a result, residential receptors along these streets would not experience noise levels in excess of 70 dB CNEL.

Comment No. A5-41

EIR Study Page No. K. Population and Housing, CONSTRUCTION, Page I-34

The DEIR indicates No Mitigation Required and No Impact

We do not agree that there is no impact. The Draft EIR contains only bare conclusions of the agency, and lacks sufficient details to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.

The Draft EIR as quoted above does not reflect a good faith effort to disclose and evaluate environmental impacts and to identify and describe mitigation measures and alternatives. The Draft EIR, as quoted above, states only unsupported conclusions, rather than facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. There is insufficient evidence to support the Draft EIR's conclusion that no impact related to construction-related population growth would occur.

1 The L.A. CEQA Thresholds Guide also defines a significant increase as a 3 dBA increase within “normally unacceptable” or “clearly unacceptable” categories for land use compatibility. As neither the ambient nor the projected ambient noise levels would exceed the 70 dB CNEL “Normally Unacceptable” threshold for residential land-uses set forth in the City’s Noise Element, the 3 dBA criterion would not apply.

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Given the fact that the North Hollywood/ Valley Village area is undergoing extensive redevelopment, it is reasonable to assume construction workers would relocate to the area, and as a result, cause population growth in the area.

Response to Comment No. A5-41

Page 4.K-11 of the Draft EIR acknowledges that construction of the Project could potentially result in increased population and demand for housing in the vicinity of the Project Site. However, as further discussed on Draft EIR page 4.K-11, based on the employment patterns of construction workers in Southern California, most Project-related construction workers are not likely to relocate their place of residence as a result of working on the Project. Therefore, no significant population or housing impacts from construction of the Project are anticipated.

Comment No. A5-42

EIR Study Page No. K. Population and Housing, OPERATION INFRASTRUCTURE, Page I-34

The DEIR indicates No Mitigation Required and No Impact

The Draft EIR as quoted above does not reflect a good faith effort to disclose and evaluate environmental impacts and to identify and describe mitigation measures and alternatives. The Draft EIR, as quoted above, states only unsupported conclusions, rather than facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. There is insufficient evidence to support the Draft EIR's conclusion that the project would not require additional infrastructure or roadways.

To the contrary, it is unlikely that the existing infrastructure and roadways can support the proposed residential development. Traffic on the major roadways surrounding the proposed development, from Oxnard Street to the South, Laurel Canyon Boulevard on the West, and Victory Boulevard to the North, and the 170 freeway to the West, are already gridlocked during rush hour traffic. The 170 North Oxnard Street and Victory Boulevard off-ramps cannot support the existing traffic during rush hour. Cars attempting to exit on either of these off-ramps are forced to sit in a line that backs up onto the freeway and blocks traffic lanes, because the off-ramp is jammed with cars. There are insufficient lanes of traffic on Oxnard Street to allow traffic to move, therefore traffic on Oxnard Street blocks exiting vehicles from the 170 freeway.

Adding over 1,500 additional residents creates a need for additional fire and police protection as well as schools, parks and recreation, and library development. The Draft EIR does not provide any data or evidence that existing public safety needs are addressed with the extra density proposed by the project. Are there enough fire trucks that can service the dense residential component of the Project? Also, are there enough police personnel, police vehicle, fire personnel, fire equipment, fire houses and ambulances

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to service the additional structures and people? How will the school district be able to accommodate the additional new students? The neighborhood finds non-emergency police response times inadequate as caused by street racing, prostitution, drug sales, especially those associated with the many marijuana shops in the area, as well as the Gentleman's Club on Victory Boulevard, West of Laurel Canyon Boulevard. Given the fact that the North Hollywood/ Valley Village area is undergoing extensive redevelopment, it is reasonable to assume additional infrastructure is needed to support the new developments.

Response to Comment No. A5-42

As discussed in Section 4.M., Transportation/Traffic, of the Draft EIR, the Project would result in significant and unavoidable impacts at the following intersections:

 Intersection #11: Laurel Canyon Boulevard & Oxnard Street, during the AM and PM peak hours.

 Intersection #20: Lankershim Boulevard & Oxnard Street, during the AM peak hour only.

The Draft EIR analyzes several potential mitigation measures for both of these intersections, explains why the traffic experts consider some of these potential measures to be infeasible, and then includes the measures deemed feasible in Mitigation Measures M-3 and M-7. Draft EIR pages 4.M-49 through 4.M- 54, and 4.M-60 through 4.M-61. However, implementation of these mitigation measures only partially mitigates the Project’s impacts at these intersections, resulting in the significant and unavoidable impacts identified in the Draft EIR. If the Project is approved, the City’s decision-making body will make a final determination regarding the feasibility or infeasibility of each of the potential mitigation measures identified. If the decision-makers conclude that feasible mitigation measures are not sufficient to mitigate the Project’s impacts at one or both of these intersections to a less than significant level, then the decision-makers can approve the Project only if they make a statement of overriding considerations.

In addition, as demonstrated in the Alternative 4B analysis contained in Section 3., Additions and Corrections, of this Final EIR, Alternative 4B would reduce the number of residential units from 742 to 658 and would avoid two of the Project's significant traffic impacts – at intersection #11 during the PM peak hour and at intersection #20 during the AM peak hour. Therefore, Alternative 4B would only result in one significant traffic impact – with implementation of Mitigation Measure M-3 - at intersection #11 during the AM peak hour.

All nearby freeway ramps were reviewed, but the Traffic Study only included quantitative analysis of those ramps that might reasonably be used by Project traffic and that might potentially meet the criteria thresholds contained in the applicable MOU between LADOT and Caltrans. The three ramps identified by the comment were reviewed but not analyzed in the Traffic Study because it was determined that they would not be used by Project traffic for the following reasons: (1) regarding the NB Victory Off-Ramp, no Project-related vehicle trips were assumed to use that facility because traffic traveling northbound on SR-170 would have to pass a much more convenient off-ramp (Oxnard Street) and then double-back along Laurel Canyon Boulevard to reach the Project Site; and (2) with respect to the two freeway ramps at

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Burbank Boulevard, it was assumed that no Project-related vehicle trips would travel through those facilities, because those ramps are located too far from the Project Site and more convenient facilities are located closer.

Project impacts with respect to fire protection are addressed in Draft EIR Section 4.L.1, and in Response to Comment No. A5-45. With implementation of Regulatory Compliance Measures L.1-1 through L.1-4 (to ensure conformance with the Fire Code) and Project Design Features L.1-5 through L.1-8, Project impacts with respect to fire protection would be less than significant.

Project impacts with respect to police protection are addressed in Draft EIR Section 4.L.2, and in Response to Comment No. A5-46. With implementation of Mitigation Measures L.2-1 and L.2-2, Regulatory Compliance Measures L.2-3 and L.2-4, and Project Design Features L.2-5 and L.2-6, Project impacts with respect to police protection would be less than significant.

Project impacts with respect to schools are addressed in Draft EIR Section 4.L.3, and in Response to Comment No. A5-47. With implementation of Regulatory Compliance Measure L.3-1, Project impacts with respect to schools would be less than significant.

Project impacts with respect to parks are addressed in Draft EIR Section 4.L.4, and in Response to Comment No. A5-48. With implementation of Regulatory Compliance Measure L.4-1, Project impacts with respect to parks would be less than significant.

Project impacts with respect to libraries are addressed in Draft EIR Section 4.L.5, and in Response to Comment No. A5-49. As discussed therein, Project impacts with respect to libraries would be less than significant.

Comment No. A5-43

EIR Study Page No. K. Population and Housing, POPULATION AND EMPLOYEE GENERATION, Page I-34

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is a less than significant impact. The Draft EIR contains only bare conclusions of the agency, and lacks sufficient details to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.

The Draft EIR as quoted above does not reflect a good faith effort to disclose and evaluate environmental impacts and to identify and describe mitigation measures and alternatives. The Draft EIR, as quoted above, states only unsupported conclusions, rather than facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. There is insufficient evidence to support the Draft EIR's conclusion that the Project does not represent a substantial or significant growth as compared to the existing characteristics.

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The Draft EIR fails to address the fact that redevelopment of Laurel Plaza (NoHo West) and Valley Plaza are now being developed separately by two different developers. The density of the residential component of the Laurel Plaza/NoHo West project is unreasonable and cannot be justified. No similarly sized housing unit exists anywhere in the San Fernando Valley, and the 742 apartments proposed for the residential component of the Project would destroy the mobility, livability, prosperity, and sustainability of the existing neighborhood. The Project's residential component is contrary to the North Hollywood- Valley Village Community Plan, the purpose of which is, "Preserving and enhancing the positive characteristics of existing residential neighborhoods while providing a variety of housing opportunities with compatible new housing." (Draft EIR, p. 4.K-5.)

The Project will increase the number of residents in the area. The 742 residential units as proposed would substantially increase the density in the neighborhood which now is nominally 24 single family homes per block, with a block size between 4-5 acres. (See Exhibit K-1) The 742 units over approximately 8 acres is an obvious significant increase in density. (See Exhibit K-1)

Previous to this proposed Project, redevelopment at Laurel Plaza in 2007 was combined with redevelopment at Valley Plaza, the adjacent site immediately to the west of Laurel Canyon Boulevard (Exhibit 1-1). Combined, these two sites comprise 45 acres, with 742 residential units over the 25 acres at Laurel Plaza (Exhibit K-2) and 777,142 square feet of retail space over the 20 acres at Valley Plaza (Exhibit K-3). The 2007 proposed project for the combined two sites would have had only retail/commercial redevelopment at Valley Plaza and 742 residential units at Laurel Plaza comprised of condominiums, town houses and apartments, totaling 742 units. These 742 units would have been spread over the entire 25 acre Laurel Plaza site, unlike the present proposed Project that crams the same 742 units, but here all apartments, onto 8 acres of the Laurel Plaza site that stretches along Erwin Street and Radford Avenue bordering an existing residential neighborhood. Additionally, the old design for Laurel Plaza was harmonious with the existing Laurel Grove neighborhood, placing townhomes and a 4.6 acre park adjacent to the existing residential neighborhood.

Redevelopment of Laurel Plaza (NoHo West) and Valley Plaza are now being developed separately by two different developers. And now this project's developer at Laurel Plaza is adding retail/office space to the 742 units at Laurel Plaza. With the addition of 800,000 square feet of Commercial (office and retail space) to Laurel Plaza and the retaining of the 742 units at Laurel Plaza the density of the Project is unreasonable and cannot be justified by including the number of units proposed in the old project with the addition of commercial space. Additionally, development at Valley Plaza is problematic. Residential units are now likely to be proposed for the Valley Plaza site as well, which threatens the neighborhood with a total of over 1,400 additional residences. Where with the previous 2007 proposal we would have had a maximum of 742 units between the two lots. With the addition of commercial space to Laurel Plaza the number of residential units proposed needs to be drastically reduced.

Response to Comment No. A5-43

The Valley Plaza project was included in the Draft EIR and Traffic Study as a cumulative project (see Draft EIR page 2-5, Table 3.1 on page 17 of the Traffic Study, shown on Figure 3.1, page 16, of the

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Traffic Study) based on information provided by City Planning and LADOT. Specifically, the trips generated by the Valley Plaza project, assuming 450 apartment units and 300,000 square feet of retail, were included as part of the background traffic volumes analyzed in the Future Without Project scenario and the Future With Project scenario. Cumulative construction impacts were also analyzed and addressed in Draft EIR Section 4.C, Air Quality, and 4.J, Noise. No further detailed information is available about the scope or schedule of the Valley Plaza project. In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Regarding the placement of the proposed commercial and residential uses at the Project Site, see Response to Comment No. A5-4.

Comment No. A5-44

EIR Study Page No. K. Population and Housing, CUMULATIVE IMPACTS, Page I-35

The DEIR indicates No Mitigation Required and Less than Significant Impact

The Draft EIR as quoted above does not reflect a good faith effort to disclose and evaluate environmental impacts and to identify and describe mitigation measures and alternatives. The Draft EIR, as quoted above, states only unsupported conclusions, rather than facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. There is insufficient evidence to support the Draft EIR's conclusion that the project does not represent a substantial or significant growth as compared to the existing characteristics.

To the contrary, the existing property it sparsely populated and draws very little commercial or residential traffic, yet the surrounding streets are difficult to navigate due to dense traffic. It is unlikely that the existing infrastructure and roadways can support the proposed residential development. Traffic on the major roadways surrounding the proposed development, from Oxnard Street to the South, Laurel Canyon Boulevard on the West, and Victory Boulevard to the North, and the 170 freeway to the West, are already gridlocked during rush hour traffic. The 170 North Oxnard Street and Victory Boulevard off ramps cannot support the existing traffic during rush hour. Cars attempting to exit on either of these off-ramps are forced to sit in a line that backs up onto the freeway and blocks traffic lanes, because the off-ramp is

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jammed with cars. There are insufficient lanes of traffic on Oxnard Street to allow traffic to move, therefore traffic on Oxnard Street blocks exiting vehicles from the 170 freeway. Adding over 1,500 additional residents creates a need for additional fire and police protection as well as schools, parks and recreation, and library development.

The Draft EIR does not provide any data or evidence that existing public safety needs are addressed with the extra density proposed by the project. Are there enough fire trucks that can service the dense residential component of the Project? Also, are there enough police personnel, police vehicle, fire personnel, fire equipment, fire houses and ambulances to service the additional structures and people? How will the school district be able to accommodate the additional new students? The neighborhood finds non-emergency police response times inadequate as caused by street racing, prostitution, drug sales, especially those associated with the many marijuana shops in the area, as well as the Gentleman's Club on Victory Boulevard, West of Laurel Canyon Boulevard. Given the fact that the North Hollywood/ Valley

Village area is undergoing extensive redevelopment, it is reasonable to assume additional infrastructure is needed to support the new developments.

The number of residential units proposed needs to be drastically reduced. The density of the residential component of the Laurel Plaza/NoHo West project is unreasonable and cannot be justified. No similarly sized housing unit exists anywhere in the San Fernando Valley, and the proposed residential component of the Project would destroy the mobility, livability, prosperity, and sustainability of the existing neighborhood. The Project's residential component is contrary to the North Hollywood- Valley Village Community Plan, the purpose of which is, "Preserving and enhancing the positive characteristics of existing residential neighborhoods while providing a variety of housing opportunities with compatible new housing." (Draft EIR, p. 4.K-5.)

Response to Comment No. A5-44

See Response to Comment No. A5-42 regarding the Project’s traffic impacts and the northbound off- ramps from the 170 freeway.

As stated above, Project impacts with respect to fire protection are addressed in Draft EIR Section 4.L.1, and in Response to Comment No. A5-45. With implementation of Regulatory Compliance Measures L.1- 1 through L.1-4 (to ensure conformance with the Fire Code) and Project Design Features L.1-5 through L.1-8, Project impacts with respect to fire protection would be less than significant.

As stated above, Project impacts with respect to police protection are addressed in Draft EIR Section 4.L.2, and in Response to Comment No. A5-46. With implementation of Mitigation Measures L.2-1 and L.2-2, Regulatory Compliance Measures L.2-3 and L.2-4, and Project Design Features L.2-5 and L.2-6, Project impacts with respect to police protection would be less than significant.

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As stated above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections).

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. A5-45

EIR Study Page No. L.1. Public Services Fire Protection, CUMULATIVE IMPACTS, Page I-37

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is less than significant impact due to the 742 proposed apartments and the potential increase of over 1,500 additional residents there is a need for additional fire protection. There are a significant number of assisted living and health care facilities in the surrounding area that put significant strain on 911/EMT medical response times. Please advise if there are enough fire trucks and medical emergency response vehicles that can service the dense residential component of the Project. Also are there enough fire personnel, fire equipment, fire houses and ambulances to service the additional structures and people? We request that additional fire personnel be hired to help maintain adequate services.

Response to Comment No. A5-45

The heading for this comment refers to cumulative impacts, but the comment itself does not address cumulative impacts. Accordingly, this response addresses Project impacts. The CEQA question addressed by the Draft EIR is whether the Project would add enough demand for Fire Department services that the Department would need to build or expand a fire station. As explained at pages 4.L.1-13 through 4.L.1-15 of the Draft EIR, the Los Angeles Fire Department (LAFD) provides data on its existing facilities, equipment, and average response times for several fire stations nearby.2 As shown in Draft EIR Table

2 Los Angeles Fire Department, Fire Station Directory, http://lafd.org/fire_stations/find_your_station.

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4.L.1-1, the nearest fire station with an engine and truck company (such as a Light Force) is Station No. 89, approximately 1.12 miles away. This is within the response distance of 1.5 to 2 miles for Project uses (see Draft EIR Table 4.L.1-2). Additional fire stations are within 2.0 miles (Station Nos. 60 and 102). Pursuant to Table 507.3.3 of the 2014 Fire Code, the maximum response distance between residential land uses and a LAFD fire station that houses an Engine or Truck Company is 1.5 miles. Based on the Project Site’s distance from Fire Station No. 89, the Project would meet the response distance requirements stated in the 2014 Fire Code. In response to issues that have been raised regarding emergency response times and associated reporting, LAFD has been taking steps to improve their related systems, processes, and practices including: (1) installation of automated vehicle locating systems on all LAFD apparatus; (2) replacement of fire station alerting systems that control fire station dispatch audio, signal lights, and other fire station alerting hardware and software; (3) development of a new computer aided dispatch system to manage fire and emergency medical service incidents from initial report to conclusion of an incident; and (4) use of traffic pre-emption systems. A traffic pre-emption system allows the normal operation of traffic lights to be preempted by an emergency vehicle in order to improve response times by stopping conflicting traffic in advance, thereby providing the emergency vehicle with the right-of-way. In addition to these improvements, emergency response is also routinely facilitated, particularly for high priority calls, through the use of sirens to clear a path of travel, driving in the lanes of opposing traffic, use of alternate routes, and multiple station response.

To ensure that developments are designed and operated in accordance with LAFD procedures and standards, the Project would comply with several regulatory compliance measures that the City has instituted. Regulatory Compliance Measures L.1-1 requires compliance with the LAFD Fire Code and any subsequent codes, including requirements for automatic fire sprinkler systems. Regulatory Compliance Measures L.1-2 through L.1-3 outline the requirement that LAFD review all project plans. Regulatory Compliance Measure L.1-4 requires that an emergency response plan must be reviewed and approved by the LAFD to help ensure that Project construction and operations would not impede fire access to and from the Project Site. In addition, there are several Project Design Features (L.1-5 through L.1-8) that have been incorporated to ensure that construction and operational impacts related to fire services, including access, would be less than significant.

As the Draft EIR also explains, the infill location of the Project Site does not represent a new area of development in Los Angeles that would exceed the response distance to a fire station. In addition, the Project would contribute tax revenue to the City’s General Fund to help maintain adequate fire protection facilities and services.

For the reasons listed above, it was determined on Draft EIR page 4.L.1-16 that the Project would not increase demand on the fire department to the extent that a new or significantly expanded facility is needed, the construction of which may cause a significant impact on the environment. Therefore, the Project's impacts would be less than significant.

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Comment No. A5-46

EIR Study Page No. L.2. Public Services Police Protection, CUMULATIVE IMPACTS, Page I-40

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is a less than significant impact due to the 742 proposed apartments and the potential increase of over 1,500 additional residents there is a need for additional police protection. Also are there enough police personnel, and police vehicles to service the additional structures and people?

The neighborhood finds non-emergency police response times inadequate, often to the point of meaninglessness, as caused by street racing and drug sales, especially those associated with the many medical marijuana shops in the immediate area. Within the last 2 years we have had 2 bicycle fatalities within 1 mile of the Project. With the Project as proposed police resources will be additionally strained.

Adding over 1,500 additional residents creates a need for additional police protection. The Draft EIR does not provide any data or evidence that existing public safety needs are addressed with the extra density proposed by the project. Are there enough police personnel, and police vehicles to service the additional structures and people? The neighborhood finds non-emergency police response times inadequate as caused by street racing, prostitution, drug sales, especially those associated with the many marijuana shops in the area, as well as the Gentleman's Club on Victory, West of Laurel Canyon Blvd. Given the fact that the North Hollywood/ Valley Village area is undergoing extensive redevelopment, it is reasonable to assume additional infrastructure is needed to support the new developments. We request that additional police personnel be hired to maintain service ratios and response times.

Response to Comment No. A5-46

As explained in the Draft EIR at pages 4.L.2-6 through 4.L.2-10, the Los Angeles Police Department (LAPD) provided data on its facilities, including existing facilities, the number of officers, crime rates, and average response times.3 As stated on Draft EIR page 4.L.2-8, the average response times to emergency calls for service in North Hollywood area during 2014 was 6.2 minutes, which is below the seven minute response time standard of the LAPD. Accordingly, while the comment finds police response inadequate, the LAPD response times in the North Hollywood area are within the seven-minute response time standard for the LAPD (see Draft EIR page 4.L.2-8 and also correspondence from LAPD, contained in Appendix I-2 of the Draft EIR). Non-emergency response times vary depending on the specific incident and are balanced with needs for emergency responses.

The threshold of significance for police protection is whether the Project would result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response

3 Los Angeles Police Department, http://www.lapdonline.org and http://assets.lapdonline.org/assets/pdf/cityprof.pdf.

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times, or other performance objectives for police protection. While the LAPD does not maintain minimum officer-to-population ratio objectives, as identified on page 4.L.2-12 of the Draft EIR, the existing officer-to-resident ratio is 1 officer per 799 residents (1.28 officers/1,000 residents). Thus, the additional approximately 1,848 residents that the Project would attract to the area would require approximately 2.4 (rounded up to 3) additional officers to maintain the same ratio. The North Hollywood Community Police Station currently has 262 sworn police officers. The addition of 3 officers to maintain the existing ratio represents a 1 percent increase over existing staffing levels, which is not substantial enough to require the construction of additional police facilities, the construction of which could cause a significant impact. Therefore, the demand for 3 additional officers to maintain current resident service ratios would not cause a significant impact because it would not require the expansion, consolidation, or relocation of this police station. See Draft EIR pages 4.L.2-12 and 4.L.2-13.

To secure the Project Site during construction and to provide the LAPD with access routes to ensure that police response is efficient, the Project is subject to two Mitigation Measures (L.2-1 and L.2-2). In addition, the Project would comply with required Regulatory Compliance Measures (L.2-3 and L.2-4) and Project Design Features (L.2-5 and L.2-6) which would further reduce the Project’s need for police protection services and would ensure potential construction and operation impacts are less than significant.

The Draft EIR also explains that the Project would incorporate numerous crime prevention features. See Draft EIR page 4.L.2-13. The comment’s request for additional police personnel to be hired to help maintain adequate services is a funding and policy decision of the LAPD and City administration. The Project, as well as cumulative projects, through the generation of revenue into the City’s General Fund, would help the LAPD achieve progress toward its goal to ensure adequate police facilities and protective services for existing and future population and land uses. For the reasons described in the Draft EIR, the Project's impacts on police protection would be less than significant.

Comment No. A5-47

EIR Study Page No. L.3. Public Services Schools, CUMULATIVE IMPACTS, Page I-41

The DEIR indicates Less than Significant Impact

We do not agree that there is a less than significant impact according to the DEIR the project will result in approximately 1,087 additional LAUSD students (622 elementary students, 155 middle school students, and 310 high school students). The DEIR says that Victory Boulevard Elementary School would operate over capacity by 513 students and North Hollywood High School would operate over capacity by 653 students. In light of same we request that additional school be built to accommodate the additional students, or preferably, significantly scaling back the number of proposed apartments so that the strain on school facilities can be less severe to the point of being manageable.

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Response to Comment No. A5-47

Page 4.L.3-9 of the Draft EIR discloses that with the addition of Project-generated students to potential/eligible school enrollments, Victory Elementary would operate over capacity by 533 students, Romer Middle would operate under capacity by 517 students, and North Hollywood High would operate over capacity by 653 students. Alternative 4B reduces the number of residential units, and therefore also reduces the number of students that would be generated (see Alternative 4B analysis contained in Section 3, Additions and Corrections, of this Final EIR). The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required to pay to mitigate a project’s impacts on school facilities. The maximum fees authorized under SB 50 apply to zone changes, general plan amendments, zoning permits, and subdivisions. The provisions of SB 50 are deemed to provide full and complete mitigation of potential school facilities impacts, notwithstanding any contrary provisions in CEQA or other state or local laws (Government Code Section 65996). The LAUSD School Facilities Needs Analysis has been prepared to support the school district’s levy of the fees authorized by Section 17620 of the California Education Code. Payment of these fees would be mandatory for the Project Applicant (formally provided in Regulatory Compliance Measure L.3-1), and would fully mitigate any impact upon school services generated by the Project. Therefore, the Project's impacts on schools would be less than significant.

Comment No. A5-48

EIR Study Page No. L.4. Public Services Parks, CUMULATIVE IMPACTS, Page I-42

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is less than significant impact, as the Project will increase the demand for park services. The nearest park Alexandria Park is not family friendly. The Project will increase the need for recreational facilities, which are not addressed.

The Project proposes a dog park at the corner of Radford Avenue and Erwin Street. We object to the dog park and the placement of the park and request that it be reconfigured within and/or adjacent to the commercial portion of the Project. As the proposed park does not have any parking and where it is placed now will only cause further parking issues with the adjacent neighborhood. The dog park should be repurposed for families and not dogs. With playground equipment and exercise stations. It should also be moved from the corner of Radford Avenue and Erwin Street to within the Project.

Adding over 1,500 additional residents creates a need for additional park/open green space. We request that the project include a minimum of 2 acres of Open Space in the commercial component of the project for the neighborhood to gather and an additional minimum of 1 to 2 acres of open space solely for the residents of the apartment units.

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let's keep the character of this community and include open space on the ground for the residents of the apartments to enjoy. Similar to the open space provided for the condominium units at 10715 Camarillo Street, which includes a pool, spa, bathrooms with changing rooms, barbecue area, outdoor lighting, trees, and a park/grass area for the residents (See Exhibit B-8). This will also provide a more family friendly open space for potential residents who have children. The open space for the residential units should be a minimum of 1 - 2 acres.

Response to Comment No. A5-48

The heading for this comment refers to cumulative impacts, but the comment itself does not address cumulative impacts. Accordingly, this response addresses Project impacts. The comment states that the nearest park, Alexandria Park, is not family friendly. CEQA does not require analysis of this issue; it is within the purview of the Los Angeles Department of Recreation and Parks (LADRP) and not for the Project to resolve.

Regarding the location of the proposed dog park, as part of Alternative 4B, the location of this park would be moved to the interior of the Project Site (see Section 3, Additions and Corrections, of this Final EIR). Specifically, the corner next to the existing Macy’s building (where the annex building is located and where surface parking is proposed for the Project) would contain an approximately 15,000-square-foot park, including such uses as a dog park and children’s play area under Alternative 4B. No parking impacts are anticipated due to the location of the park.

The comment also states that the Draft EIR does not address the increased demand for recreational facilities. However, both the Project (see Draft EIR Table 3-4) and Alternative 4B (see Table 4B-4 in Section 3, Additions and Corrections, of this Final EIR) would provide at least the amount of open space required by the Los Angeles Municipal Code. The demand for new parks and recreational facilities would not constitute a potentially significant impact to parks and recreational facilities, because the Project includes publically accessible features such as a park, green spaces, and plazas, and private residential amenities spaces including a pool, that would otherwise reduce or offset the additional demand for recreation and park services in the local area.

In addition to the provision of on-site open space and recreational amenities for the residents and visitors to the Project Site, the Project would be subject to LAMC requirements that are intended to address the increased demands that are created by residential development projects (formally provided as Draft EIR Regulatory Compliance Measure L.4-1):

(1) the Dwelling Unit Construction Tax imposed by LAMC Section 21.10.3; and/or

(2) the Quimby Act parkland dedication requirements or in-lieu fees as set forth in LAMC Section 17.12 and Section 12.33.

The Project’s compliance with the above-referenced Code requirements collectively address the Project’s future demand upon recreation and park facilities by requiring the dedication of parkland or contribution

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of funds to be placed in a City-controlled account to be used to acquire and develop new parkland areas within the Project’s service area. The formulas for calculating fees and/or land dedication are established to ensure that the provision of new park and recreation facilities is commensurate with the level of development that is built. Accordingly, based on the Project’s recreational features (public space, pedestrian plaza, and open space) and the regulatory compliance measures, the Project’s impacts to parks would be less than significant.

Comment No. A5-49

EIR Study Page No. L.5. Public Services Libraries, CUMULATIVE IMPACTS, Page I-42

The DEIR indicates No Mitigation Required and Less than Significant Impact

We do not agree that there is a less than significant impact. The Draft EIR indicates that the project would increase the demand for library services through its resident population. Adding over 1,500 additional residents creates a need for additional library development. In order to resolve this issue, we request a study of City library locations and sizes and their surrounding populations to determine if in fact all Los Angeles residents are being equitably served.

Response to Comment No. A5-49

The heading for this comment refers to cumulative impacts, but the comment itself does not address cumulative impacts. Accordingly, this response addresses Project impacts. The Los Angeles Public Library (LAPL) provided facility information for the libraries that could serve the Project (see correspondence included in Appendix I-5 of the Draft EIR). The LAPL does not make targeted projections but rather uses the most recent Census figures to determine if a branch should be constructed. According to the LAPL Branch Facilities Plan, Criteria for New Libraries, an additional branch is only recommended when a community reaches a population of 90,000. Consequently, the LAPL has confirmed that there are no planned improvements to add capacity through expansion of any identified branch or build any new libraries in the area.

In addition, the L.A. CEQA Thresholds Guide considers features such as on-site library facilities and direct support to LAPL that would reduce the demand for library services. It is likely that the residents of the Project would have individual access to internet service, which provides information and research capabilities that studies have shown to reduce demand at physical library locations.

Although the Project would increase the demand for library services through its resident population, it would not result in the need for new or physically altered governmental facilities. Therefore, the Project’s impacts to library services would be less than significant.

Comment No. A5-50

EIR Study Page No. M. Transportation/Traffic, CONSTRUCTION, Page I-43

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The DEIR indicates that after mitigation the level is Significant and Unavoidable

We request that traffic studies for the Project area be conducted in accordance with the Traffic Study Policies and Procedures, dated August 2014, for the City and with Caltrans study requirements as appropriate. Data collection required for these studies should be done for a peak-day, non-holiday week when schools are in session.

Response to Comment No. A5-50

The Traffic Study was conducted in accordance with LADOT’s Traffic Study Policies & Procedures, dated August 2014. An Assessment Letter was drafted and signed by LADOT staff on November 19, 2015, stating that LADOT agreed with the recommendations and findings of the Traffic Study (included in Appendix J of the Draft EIR). Data collection for all study intersections was conducted on a weekday during a non-holiday week when the local schools were in session (see Section 2.3 of the Traffic Study). Per the applicable Memorandum of Understanding (MOU) agreed to by LADOT and Caltrans, the Traffic Study also conducted a threshold check of freeway mainline segments and freeway off-ramps located in the area surrounding the Project Site and none were determined to meet or exceed the established thresholds. Therefore, no additional analysis was needed.

Comment No. A5-51

EIR Study Page No. M. Transportation/Traffic, EXISTING PLUS PROJECT, Page I-44

The DEIR indicates that after mitigation the level is Significant and Unavoidable

While we agree that impact is significant, we do not agree that it is unavoidable. It is not unavoidable if proper traffic mitigations and a reduction in the density of the project is completed. The DEIR mitigations for traffic only include the re-striping of 4 intersections and adding a CCTV camera at Laurel Canyon Blvd and Oxnard Street. This is not sufficient, more mitigations need to be installed.

Response to Comment No. A5-51

The traffic mitigation measures in the Traffic Study and Draft EIR were identified, developed, and analyzed in conjunction with LADOT. The mitigation measures reduce the impacts identified at the study intersections to a level of insignificance at all impacted locations with the exception of two locations (Laurel Canyon Boulevard/Oxnard Street (AM and PM peak hours) and Lankershim Boulevard/Oxnard Street (AM peak hour)), where the impacts are partially mitigated (see Draft EIR page 4.M-64). LADOT drafted and signed an Assessment Letter, dated November 19, 2015, stating its agreement with the findings and recommendations of the Traffic Study (the assessment letter is included in Appendix J of the Draft EIR). Detailed descriptions of the mitigation measures to be implemented at the impacted intersections, which are more extensive than the comment indicates, are provided in the Traffic Study and in Section 4.M. of the Draft EIR, along with discussions of additional measures that were considered (see Draft EIR pages 4.M-50 through 4.M-54).

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In addition, the Draft EIR analyzes six Project alternatives that would reduce both density and intersection impacts compared to the Project (see Draft EIR, Section 6).

Finally, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B, which is a reduced project, has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B includes 658 residential units, instead of the 742 residential units analyzed in the Draft EIR, as well as an increase in retail and restaurant space and a reduction in office space. As a result of these reductions in land uses, the number of vehicle trips generated by the Project would decrease. The total number of daily trips would decrease from 7,270 trips under the Proposed Project to 6,600 trips under Alternative 4B. The total number of AM peak hour trips would also decrease from 710 trips to 360 trips and PM peak hour trips would decrease from 759 trips to 573 trips. A supplemental traffic impact analysis was conducted using these trip generation estimates and it was determined that Alternative 4B would have similar significant impacts as those created by the Proposed Project (see Appendix B of this Final EIR for the Alternative 4B traffic analysis). The same set of mitigation measures (Draft EIR Mitigation Measures M-1 through M-7) that were identified for the Proposed Project were analyzed at the impacted intersection locations identified for Alternative 4B. With implementation of these mitigation measures, Alternative 4B would result in two fewer impacts than the Project (at intersection #20 during the AM peak hour and at intersection #11 during the PM peak hour). However, like the Project, Alternative 4B would still result in a significant impact at intersection #11 during the AM peak hour.

Comment No. A5-52

Both the adjacent SR-170 Freeway and the nearby US-101 Freeway are heavily congested freeways. The data used in the DEIR is from the Cal Trans 2012 report regarding the 170 fwy. The DEIR completely ignores the Cal Trans June 2015 report on the 170 fwy.

Draft EIR does not utilize the June 2015 published Caltrans report for the congestion on SR-170. In the June 2015 Cal Trans report the level of service is E, while the DEIR states it is a LOS D (see Exhibit M- 1, page 22)

Which report is accurate – Caltrans or DEIR? Peak Hours Peak Hours Caltrans Draft EIR June 2015 December 2015 Level of Service E Level of Service AM Hour is C or D (5 of 6 segments) PM Hour is C or D (all)

SR-170 " ... currently operates at LOS (Level of Service) E during the period of peak congestion," "Transportation Concept Report Route 170," Caltrans, June 2015, (Exhibit M-1, p. 22). Caltrans defines

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LOS E "operations at or near capacity and an extremely unstable flow ... " "Transportation Concept Report Route 170," Caltrans, June 2015, (Exhibit M-1, p. 29).

The pending installation of 7 additional on-ramp meters for SR-170 between Vineland Ave. and Victory Blvd. serves to document the issue of peak hour congestion near the Project area now "Transportation Concept Report Route 170," Caltrans, June 2015, (Exhibit M-1, p. 14).

US-101 ---The US-101 freeway at Laurel Canyon Boulevard is reported to be the 7th most congested freeway segment in the US with an estimate annual total travel delay of 3,600,000 hours ("Unclogging America's Arteries," 2015, seep. 16). (See Exhibit M-2)

The monitoring data (aside from the 2012 Cal Trans data described above) employed in the traffic study to determine the impact of Project traffic on freeway congestion was obtained at "some distance" from the Project, namely 2.0 and 3.3 miles away, (pp. 4M-29& 4M-36-37). The Draft EIR concludes this freeway "screening" analysis did not meet any of four thresholds for additional freeway analysis. We insist that Caltrans review these findings.

Response to Comment No. A5-52

As explained in the Draft EIR, the City uses the thresholds for freeway mainlines provided by the countywide Congestion Management Program. The CMP does not require analysis of mainline freeway impacts if anticipated project trips at all mainline freeway monitoring locations would be fewer than 150 trips at the AM and PM peak hours. The Project would not come close to meeting these thresholds. Accordingly, no further analysis of freeway mainline impacts is required. See Draft EIR at pages 4.M-29 and 4.M-30.

The referenced June 2015 Caltrans study conducted for the SR-170 freeway is a “Transportation Concept Report,” which is an initial evaluation of the entire SR-170 freeway and analyzed the entire length of SR- 170 from its junction with US-101/SR-134 to its junction with I-5. The Transportation Concept Report is a Caltrans long-term planning document that evaluates the conditions of a given State highway, and establishes a concept or vision of what that highway should look like at the end of the twenty-year planning period. Accordingly, the Transportation Concept Report for the SR-170 freeway analyzed traffic conditions projected for a horizon year of 2035, a full 15 years after the Project will be completed, and as such, the results of that analysis are too general to be applied to or compared against the results provided in the Traffic Study. The results of the analysis and potential improvements identified in the Transportation Concept Report are the first step in a process that will involve considerable further feasibility and engineering studies by Caltrans, and any improvements must then secure funding through the State’s Transportation Improvement Program before it can be constructed. Again, for these reasons, the Concept Report is not applicable to the Traffic Study.

The City and Caltrans entered into a Memorandum of Understanding in October of 2013, which identified when and how traffic impacts on the State highway system should be addressed. The traffic volume thresholds agreed upon by LADOT and Caltrans are designed to identify freeway mainline segments

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and/or freeway off-ramp facilities that require further study. The Draft EIR and supporting Traffic Study evaluated the specific freeway mainline segments and off-ramp locations using thresholds identified in the Congestion Management Plan and the signed MOU between LADOT and Caltrans, dated October 2013, to determine whether further analysis of SR-170 freeway mainline or off-ramps in the area surrounding the Project Site was needed. It was determined in consultation with LADOT that Project traffic did not meet or exceed any of the thresholds identified in the CMP or the MOU; and therefore, no further analysis was needed (see Appendix E of the Traffic Study). Caltrans was provided with the NOP and Notice of Availability of the Draft EIR, and provided comments in response to both. Caltrans’ NOP comment letter is attached as Appendix C to the Draft EIR, and responses to Caltrans’ Draft EIR comment letter are provided in Comment Letter No. A1, as part of this Final EIR. Finally, the City’s Mobility Plan represents a long term and Citywide goal. In the case of this Project, evaluation was conducted in accordance with the applicable LADOT/Caltrans MOU agreement, and there is no requirement for the Project to be responsible for any specific freeway improvements.

The referenced segment of US-101 freeway (at Laurel Canyon Boulevard) is located approximately 1.75 miles from the Project Site, and, as discussed above, the freeway threshold check conducted for freeway mainline segments showed that the thresholds requiring additional analysis were not met.

Finally, the comment incorrectly identifies the freeway monitoring locations. The locations identified as 2.0 to 3.3 miles away are CMP arterial roadway monitoring stations, not the freeway monitoring locations. Per LADOT Traffic Study and County of Los Angeles Congestion Management Program guidelines, a development project must analyze expected traffic volumes through specific arterial intersection monitoring locations (as provided in Appendix A of the 2010 CMP) where the Project could potentially add 50 or more vehicle trips in the AM or PM peak hour. The four locations identified in the Draft EIR are the closest arterial monitoring stations to the Project Site.

Comment No. A5-53

The bordering neighborhood is a quiet area that is not built for a heavy traffic flow. Many of the streets do not have sidewalks. Often you can observe people walking the neighborhood. Many children use these streets to walk to and from school (Laurel Hall School, Victory Boulevard Elementary School, Roy Romer Middle School, and North Hollywood High School). We request that traffic studies for the Project area be conducted in accordance with the Traffic Study Policies and Procedures, dated August 2014, for the City and with Cal Trans study requirements as appropriate. Data collection required for these studies should be done for a peak-day, non-holiday week when schools are in session.

Response to Comment No. A5-53

See response to Comment No. A5-50 regarding the conditions under which the Traffic Study was undertaken.

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Comment No. A5-54

Southbound on the 170 freeway the Victory Boulevard/Oxnard Street weaving lane has been the site of many accidents over the years. (Exhibit M-3) At only approximately 300 feet, it appears to be considerably shorter than current standards would find acceptable and needs to be addressed in the Final EIR. Additionally, the exit lane/off ramp at Oxnard Street on the 170 Freeway north already backs up onto the freeway during peak hour. This situation, too, will only worsen with the additional freeway traffic that this project will engender and must be addressed in the Final EIR.

Response to Comment No. A5-54

Regarding freeway impacts, see Response to Comment No. A5-52.

Comment No. A5-55

Currently the 170 freeway northbound Oxnard Street off ramp has three lanes, one lane exits to the right only, one lane exits to the left only, and the center lane has the option to exit to the left or go directly onto the Project site. (Exhibit M-4) We are requesting that an additional lane be added so that there are 4 lanes total, with one lane exiting to the left, one lane having the option to go directly into the project or exit to the left, another lane with the option to go directly into the project or exit to the right and the remaining lane will exit to the right. This will ease backup onto the freeway. an estimate annual total travel delay f 3,600,000 hours ("Unclogging America's Arteries," 2015, seep. 16). (See Exhibit M-2)

Response to Comment No. A5-55

See Response to Comment No. A5-52. The commenter has not provided any evidence as to why an extra lane is required. Nevertheless, the comment is acknowledged for the record.

Comment No. A5-56

Response to Comment No. A5-56

See Response to Comment No. A5-52.

Comment No. A5-57

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streets to walk to and from school (Laurel Hall School, Victory Boulevard Elementary School, Roy Romer Middle School, and North Hollywood High School). We request that traffic studies for the Project area be conducted in accordance with the Traffic Study Policies and Procedures, dated August 2014, for the City and with Cal Trans study requirements as appropriate. Data collection required for these studies should be done for a peak-day, non-holiday week when schools are in session.

Response to Comment No. A5-57

See response to Comment No. A5-50 regarding the conditions under which the Traffic Study was undertaken.

Comment No. A5-58

Response to Comment No. A5-58

Regarding freeway impacts, see Response to Comment No. A5-52.

Comment No. A5-59

Response to Comment No. A5-59

See Response to Comment No. A5-52.

Comment No. A5-60

Heading west on Oxnard Street along the Project site there needs to be an additional lane/entrance widening added that is the full length of a traffic lane to turn into the Project which will prevent back up onto the project. As this portion of Oxnard Street is already congested with traffic heading onto the freeway.

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Response to Comment No. A5-60

As shown in Tables 4.M-11 and 4.M-12 of the Draft EIR, the Traffic Study includes operational analyses, which were conducted at both the Oxnard Street East driveway (existing signalized intersection with SR- 170 Northbound Ramps) and the Oxnard Street West driveway (existing unsignalized driveway just east of SR-170 overpass). Both locations are expected to operate at LOS D or better in both the AM and PM peak hours under Future With Project traffic conditions. Therefore, the suggested improvement is unnecessary.

Comment No. A5-61

North on Laurel Canyon Boulevard just past the 170 freeway overpass an additional lane/entrance widening needs to be added that is the full length of a traffic lane to turn into the Project which will prevent back up onto the project at Laurel Canyon Boulevard.

Response to Comment No. A5-61

As shown in Tables 4.M-11 and 4.M-12 of the Draft EIR, the Traffic Study includes an operational analysis, which was conducted at the Laurel Canyon Boulevard driveway (existing unsignalized right- in/right-out driveway north of SR-170 overpass). This location is expected to operate at LOS B or better in both the AM and PM peak hours under Future With Project traffic conditions. Therefore, the suggested improvement is unnecessary.

Comment No. A5-62

East bound on Erwin Street along the Project site at an additional lane /entrance widening needs to be added that is the full length of a traffic lane to turn into the Project at Erwin Street and Agnes Ave this will help prevent back up onto the Project.

Response to Comment No. A5-62

As shown in Tables 4.M-11 and 4.M-12 of the Draft EIR, the Traffic Study includes an operational analysis, which was conducted at the Erwin Street West driveway (existing unsignalized driveway east of Laurel Canyon Blvd). This location is expected to operate at LOS A in both the AM and PM peak hours under Future With Project traffic conditions. Additionally, the Project will install a traffic signal at this driveway (see Draft EIR page 4.M-38). Therefore, the suggested improvement is unnecessary.

Comment No. A5-63

Restrictions must be set in place so that after 11:00 pm when the theatre lets out vehicles can only exit onto Oxnard Street and Laurel Canyon Blvd.

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Response to Comment No. A5-63

The comment requests for certain restrictions to exit the Project Site after 11:00 PM, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. The Draft EIR does not identify any significant impact from vehicle traffic after 11:00 PM.

Comment No. A5-64

The intersection of Oxnard Street and Laurel Canyon Boulevard is already congested. All of the additional cars going into and out of the NoHo West (Laurel Plaza) Project will head straight for the residential neighborhood. Erwin Street will turn into a major thoroughfare overnight. Erwin Street was never designed for heavy traffic flow. Once Erwin Street backs up, all of the side streets will become flooded with traffic. In light of same we request that Agnes Ave, Ben Ave and Gentry Ave at Erwin Street be closed off. This can be done by moving the proposed landscaped median along Erwin Street one lane over to abut the northern side of Erwin Street, this will block off the entrances to Agnes Ave, Ben Avenue and Gentry Avenue. Currently there is a 4 foot high block median along Erwin Street that does not allow cross over onto Gentry Ave, Ben Ave and Agnes Avenue from the Project site. The proposed Project reconstructs the median with landscaping but allows cross over from the Project site through Agnes Ave. We object to this, either the developer can move the median over as suggested above to block Agnes Ave, Ben Ave and Gentry Ave along Erwin Street or construct a landscaped median on Erwin Street that does not allow cross over traffic from the Project site to Agnes Ave, Ben Ave and Gentry Ave as it does not now.

Response to Comment No. A5-64

Project traffic using the Laurel Canyon Boulevard & Oxnard Street intersection will be primarily traveling to/from areas west and south of the Project Site. The vehicles traveling through that intersection that could potentially use Erwin Street would be vehicles originating from the residential portion of the Project. With the exception of these vehicles, Erwin Street does not provide any time-savings or additional connectivity to vehicles traveling to/from the Project Site when compared to either Laurel Canyon Boulevard or Oxnard Street. As with Erwin Street, none of the other neighborhood streets would provide any time-savings or mobility options that would make them attractive as an alternative “cut-thru” route for Project traffic.

With the construction of the Project, the existing median along Erwin Street will be enhanced, but will remain a deterrent to those attempting to utilize the residential streets to the north of the Project Site for access. The commenter is incorrect in stating that changes to the median will allow cross-over from the Project Site to the neighborhoods at Agnes Avenue. The proposed changes to the existing median would only provide a westbound left-turn lane for vehicles traveling from neighborhoods north of the Project Site to access the Project at Agnes Avenue. A permanent barrier will still be in place across Agnes Avenue that will prevent traffic from crossing Erwin Street and traveling to/from the neighborhoods. Vehicles traveling to/from the Project Site are not expected to use this westbound left-turn as the amount

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of time required to travel through the neighborhoods would be greater than using either Radford Avenue or Laurel Canyon Boulevard.

The changes proposed by the commenter are outside the purview of the environmental analysis for the Project. As the Traffic Study did not identify any significant impacts along Erwin Street, no additional traffic improvements along that facility above those previously identified regarding the updates to the existing median are required.

Comment No. A5-65

Due to the increase of commercial use at the Project and the density of the 742 proposed residential units, and insufficient guest parking for the residential component of the Project, we request installation of a Project-funded, no-charge-to-residents Preferential Parking District on Agnes Avenue between Erwin Street and Victory Blvd; Ben Avenue between Erwin Street and Victory Blvd; Gentry Avenue between Erwin Street and Sylvan Street; Radford Avenue between Oxnard Street and Victory Blvd; Erwin Street between Laurel Canyon Blvd and Simpson Avenue; Sylvan Street between Laurel Canyon Blvd and Simpson Ave; Carpenter Avenue between Oxnard Street and Victory Blvd; and Calvert Street between Radford Avenue and Simpson Avenue. This will address "intrusive parking" by non-residents and commuter vehicles and provide residents in the adjacent neighborhood of single family homes with permits to park. It will address some of the "negative impacts" of non-residential parking in our residential neighborhood brought by the Project.

Response to Comment No. A5-65

The comment provides a request for permit parking in neighborhoods surrounding the Project Site. The Project’s parking demand and proposed supply are discussed in greater detail in Response to Comment No. A5-81, below. As the Project would provide ample parking for all of its uses, overflow parking in the surrounding neighborhood is not anticipated. Therefore, no impacts would occur.

Comment No. A5-66

Please also investigate traffic mitigations at the entrance to Radford Avenue south of Oxnard Street. As Radford Avenue south of Oxnard Street is already used as a cut through to Colfax Ave, and the 170 freeway entrance at Burbank Blvd. The area south of Oxnard is a residential neighborhood of single family homes (Exhibits M-5, M-6, M-7, M-8) with residents who are active and walk, bike ride and play in their front yards. Non-resident traffic already cuts through and speeds down the quite streets and with the additional traffic of the Project mitigations need to be made to ensure the residents safety. With the additional traffic from the Project and the new Waze traffic application we fear that this cut-through traffic will only increase. Councilmember Krekorian is sensitive to keeping drivers away from residential streets and onto major roadways (Exhibit M-9, My News LA 4/28/15 article) and in light of same we are requesting that the Final EIR provide for the needed mitigations at Radford Ave south of Oxnard Street, along Erwin Street between Laurel Canyon Blvd and Colfax Avenue, and Radford Ave between Oxnard

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Street and Victory Blvd, to keep the traffic away from the existing residential neighborhood and onto the major roadways.

Response to Comment No. A5-66

The intersections analyzed in the Traffic Study were selected in consultation with, and approved by, LADOT. The adjacent intersections of Oxnard & Radford and Oxnard & Colfax were also studied and it was determined there would be no significant impacts at those intersections (see Tables 4.2 and 4.3 of the Traffic Study). Project traffic would be unlikely to use Tiara Street, because it does not provide a more convenient or faster route. There are unsignalized intersections at both Radford & Oxnard and Tiara & Colfax, which make it more difficult to turn into/out of the street and would therefore discourage cut through use. In addition, as shown in Figures 4.2 and 4.3 of the Traffic Study, only a very small amount of Project traffic is estimated to use Colfax Avenue. Therefore, no impacts to these residential streets are anticipated to occur and no mitigation is warranted

Both Radford Avenue and Erwin Street are classified as Collector Streets under the City of Los Angeles’ Mobility Plan 2035. As such, these facilities are not subject to residential street impact analysis (see Section H.3, LADOT’s Traffic Study policies and Procedures, August 2014).

A supplemental analysis was conducted for the Radford Avenue & Erwin Street intersection to document the existing traffic conditions and conditions expected under the Future With Project scenario (see Appendix E of this Final EIR). The results of this analysis show that the Radford Avenue & Erwin Street intersection currently operates at LOS A and is expected to continue to operate at LOS A under Future With Project conditions. As this intersection is expected to continue to operate at the same acceptable level of service, no mitigation measures are needed.

Comment No. A5-67

The Project also consumes the current drop off lot for Laurel Hall School. Currently, parking, drop-off and pick-up is solely done off of Oxnard Street (Exhibit M-10). The Project now creates a new road that wraps around the Laurel Hall School property and allows parents to come in at Oxnard Street and exit at Radford Avenue (Exhibit M- 11). Hundreds of parental cars will be pushed out onto Radford Avenue as a moving drop-off for Laurel Hall School. These problems will have an immediate and harmful impact on the safety of residents and elementary and middle school aged school children. The new route brings additional traffic to Radford Avenue which is used by local residents to exit the neighborhood and access the 170 freeway. Traffic mitigations need to be made to provide an additional drop off lane adjacent to the west side of the Laurel Hall School property at the Oxnard Street entrance, so parents dropping off and picking up kids do not back up traffic at the entrance to the Project which is already a congested area due to the adjacent 170 freeway entrance. Also traffic mitigations must be explored and made to accommodate the additional school traffic heading south on Radford Avenue.

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Response to Comment No. A5-67

Traffic counts at the surrounding study intersections were conducted on a weekday during a non-holiday week when Laurel Hall School was in session (see Section 2.3 of the Traffic Study). Thus, existing school traffic accessing the surface parking lots to drop-off/pick-up students was included in the overall traffic count data collected.

The traffic impact analysis was conducted under the assumption that the surface parking lots on which Laurel Hall School and Emmanuel Lutheran Church visitors have been parking are to be fully redeveloped as part of the Project and that all parking and/or drop-off/pick-up activities currently occurring on the surface parking lots would be relocated and conducted on-site at Laurel Hall School. There are no currently binding agreements or City requirements for the Project Site to provide parking or drop-off/pick-up areas for the school and church. Therefore, Laurel Hall School and Emmanuel Lutheran Church will need to accommodate student drop-off/pick-up and parking for church services and other special events on-site. It should be noted that the Project will provide 50 weekday daytime parking spaces for use by Laurel Hall School staff and faculty, but no student or parent parking or use is anticipated.

Comment No. A5-68

Left turn arrows need to be added all around to all traffic lights at the intersections of Laurel Canyon Blvd & Oxnard Street, Laurel Canyon Blvd & Erwin Street, Oxnard Street & Radford Ave, Oxnard Street & Colfax Ave, and Lankershim Blvd & Oxnard Street.

Response to Comment No. A5-68

With the exception of the Laurel Canyon Boulevard & Oxnard Street intersection and the Lankershim Boulevard & Oxnard Street intersection, significant traffic impacts were not identified at any of the intersections listed by the commenter. As such, no mitigation measures are required to be implemented by the Project at those locations. At the two listed locations where significant traffic impacts were identified, the mitigation measures discussed in the Traffic Study were developed and analyzed in conjunction with LADOT to specifically mitigate the traffic impact at each intersection (Mitigation Measures M-3 and M- 7, respectively). Mitigation Measure M-7 at Lankershim Boulevard & Oxnard Street includes traffic signal modifications to add protected left-turn phases. Different mitigation measures were also considered but were determined to be infeasible for the reasons described at Draft EIR pages 4.M-51 and 4.M-54.

Comment No. A5-69

EIR Study Page No. M. Transportation/Traffic, FUTURE PLUS PROJECT, Page I-47

The DEIR indicates that after mitigation the level is Significant and Unavoidable

While we agree that the impact is significant, we do not agree that it is unavoidable. It is not unavoidable if proper traffic mitigations and a reduction in the density of the project is completed. The DEIR

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mitigations for traffic only include the re-striping of 4 intersections and adding a CCTV camera at Laurel Canyon Blvd and Oxnard Street. This is not sufficient, more mitigations need to be installed.

Response to Comment No. A5-69

See Response to Comment No. A5-51.

Comment No. A5-70

The traffic study employs the following assumptions about additional traffic--- 7,720 more trips per weekday--- attributed to the Project upon completion (page 4M-20): Assumption #1---The planned demise of Macy's department store alone reduces daily trips by 8,511 and therefore are subtracted appendix J of the from the weekday trips of the Project, as shown in Table 4.1 of DEIR Appendix J. (See Exhibit M-12). This adjustment to reduce the traffic impact is absolutely unwarranted because it is not based on on-site trip counts but rather on "Gross Building Area"-- a national formula rather than site- specific counts.

The traffic study's assumption of 8,511 daily trips is unrealistic. At best the current weekday vehicle trips to Macy's to and from are no more than 500 customers per day. Assumptions about vehicle trips to and from the office building at 6150 Laurel Canyon Boulevard are likewise unjustifiable and again taken from ITE-based estimates to be used for planning purposes. The 1,694 total trips used in the study to reflect the school and office use there is totally inconsistent with the daily counts of vehicles parked in the adjacent parking lots which number in the low hundreds. Again to the advantage of the project, the Traffic Study (Page 16) assumes an annual traffic growth rate of 1.5 percent. Over five years this amounts to a 7.7 percent increase. Yet on page 4.K-7 of the DEIR the City population is given as 3,957,022 in 2015 with a projection of 3,991,700 in 2020, the hoped for in-service date for the Laurel Plaza project. This increase is a mere 0.88 percent for the entire 5-year period. As the City is actively promoting the use of public transportation, walking and bicycles as alternatives to vehicle use, the assumed 1.5 percent annual increase is particularly egregious.

Response to Comment No. A5-70

As discussed on Draft EIR pages 4.M-17 and 4.M-18, trip generation for both the existing uses and the Project were estimated using trip rates from the Trip Generation Manual – 9th Edition (Institute of Transportation Engineers (ITE), 2012). The trip generation estimates are summarized in Draft EIR Table 4.M-4. The ITE Trip Generation Manual provides rates for different uses based on factors such as square footage of office or retail uses, number of seats for uses such as a cinema, or number of residential units. In addition, all trip reductions in the Traffic Study were applied per LADOT’s Traffic Study guidelines, which permit application of existing use credits so long as the existing land use to be credited has been active for at least 6 months in last 2 years. Thus, because the existing 465,000-square-foot building is currently leased and operational as a Macy's Department store, the reduction for existing use credits based on department store use is warranted based on standard City policy. Evidence in the file (including building records, certificates of occupancy, and lease agreements) supports the use and operation of the

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building as a department store. The fact that levels of activity at the store have fluctuated over the years does not make application of the existing use credit unrealistic or otherwise inconsistent with CEQA’s requirements. In fact, the building could be re-occupied with a similar department store or retail use without the need for any further discretionary approvals or the current Macy’s Department Store activity level could increase without further City approval. Additionally, according to ITE and LADOT methodology, all trip generation estimates calculated for the proposed land uses are based on gross leasable space, as total floor area designed for tenant occupancy and exclusive use, and thus it would be an inconsistent application of LADOT’s methodology to not include all existing leasable space. Therefore, the Project's net trip generation analysis was properly conducted in accordance with accepted ITE standards and LADOT Traffic Study guidelines.

The comment compares the Draft EIR’s use of the assumed 1.5 percent annual increase in traffic (7.7 percent over five years) to a 0.88 percent growth in City population. This is not a valid comparison because there is no one-to-one correlation between a city’s residential population growth and its traffic growth. Traffic results from new jobs in the City and growth in neighboring communities, not just from residential growth within the City. The background traffic growth factor was determined in conjunction with LADOT, consistent with other studies in the San Fernando Valley.

Comment No. A5-71

Additionally, the traffic study as presented misplaces what it calls project 4 to be at the northwest corner of Whitsett Avenue and Victory Boulevard instead of its site at the west bound exit of the southbound 170 intersection with Victory Boulevard. As the Whitsett Avenue I Victory Boulevard intersection is identified as already at LOS of E, this error, along with the other unjustified assumptions made in the traffic study, must be corrected and a new study conducted. Future study results need to be presented both on paper and in a face-to-face meeting with representatives from the Laurel Grove Neighborhood Association.

Response to Comment No. A5-71

The commenter is correct that the location of Cumulative Project #4, as shown in Figure 3.1 in the Traffic Study, is in an incorrect location. However, this error is limited to the graphic, and the impact analysis was properly conducted in the Traffic Study, which is still valid. The revised graphic is included in Section 3, Additions and Corrections, of this Final EIR.

Comment No. A5-72

In general, traffic engineers recognize the limited confidence in any traffic study. In The Traffic Assignment Problem, Models & Methods by Michael Patriksson, the author specifically observes on page 28 of the Dover Publications edition, "The models are basically non-behavioral. They replicate the results of conditions existing at the time of the survey and provide little or no guidance to the effects on travel decisions of changes in travelers' circumstances or in terms upon which they are offered competing alternatives in the transportation environment." Applied here, this implies as main thoroughfares become

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more congested, e.g., Oxnard Boulevard, travelers may well seek out alternate routes, e.g., residential side streets. This phenomenon is well- documented to have occurred throughout Los Angeles, already occurs in our Laurel Grove neighborhood, and demonstrates the limited usefulness of traffic studies.

Response to Comment No. A5-72

See Response to Comment No. A5-64, above, regarding use of residential streets for alternate routes. The Traffic Study was conducted in accordance with LADOT’s Traffic Study Policies & Procedures, dated August 2014, and an Assessment Letter was drafted and signed by LADOT staff on November 19, 2015, stating that LADOT agreed with the recommendations and findings of the Traffic Study.

A vast majority of the residential streets located in the proximity of Oxnard Street are non-continuous facilities and would not offer travelers any time-saving benefits when compared to using Oxnard Street. Additionally, most of the residential streets are controlled by unsignalized intersections at major thoroughfares further discouraging their use as cut-through routes (see also Response to Comment No. A5-66 above).

Comment No. A5-73

Assumption #2 ---In contrast to the Final EIR of the Community Redevelopment Agency for Laurel (and Victory) Plaza in 2009, the Draft EIR spreads trips more evenly over four directions –thereby influencing the number of trips north and south, including freeway trips. A State highway, SR-170, and major streets direct trips north and south; the November 19, 2015 LADOT assessment letter does not address either Assumption #1 or #2 about the volume of trips to be generated by this Project.

Assumption #2

2009 EIR 2015 DEIR Laurel Plaza Laurel Plaza Table IV M-7 Appendix J, page 31 Percentage of trips NORTH 27% 30% Percentage of trips SOUTH 37% 20% SUBTOTAL 64% 50% Percentage of trips EAST 19% 20% Percentage of trips WEST 17% 30%

Response to Comment No. A5-73

The traffic analysis contained in the 2009 Draft EIR for the Laurel Plaza Project is not applicable and cannot be compared to the current Project. The project analyzed in the 2009 Draft EIR consisted of both the Laurel Plaza and Valley Plaza project sites and the Laurel Plaza site was analyzed as a purely residential project with no on-site retail, commercial, or office uses. As the current Project for the Laurel Plaza site (NoHo West) now includes retail, commercial, and office uses as well as residential uses, the

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trip distribution for patrons, residents, and tenants of the Project is based on the trip characteristics of these land uses.

The trip distribution contained in the Traffic Study reflects the anticipated origination and destination of Project-based trips based on estimated routes of travel. Trip distribution for the Project was based on several factors, including the type of land uses in the Project; the geographic location and distribution of the population from which the trips by visitors and employees of the commercial uses will originate; the geographic location and distribution of employment and commercial centers to which residents of the Project will likely make trips and the configuration; and operating characteristics of the street system in the area of the Project. The trip distribution assumptions were reviewed and approved by LADOT as part of the Traffic Study review process.

Comment No. A5-74

EIR Study Page No. M. Transportation/Traffic, CMP, Page I-47

The DEIR indicates No Mitigation Required and Less than Significant Impact

OXNARD STREET TRAFFIC .... The preparer of the Final EIR should reconsider the density of the Project and respond to the City traffic assessment, which reported a "significant and unavoidable" on Oxnard Street traffic intersections which "the proposed transportation mitigation would partially but not fully mitigate all the project's significant traffic impacts." ("Traffic Study Assessment for the Proposed NoHo West Mixed Use Project," LA Department of Transportation, p.2). (EXHIBIT M- 13) This means a "Level of Service" at category F will exist during weekday peak hours at Oxnard Street and Laurel Canyon Blvd. LOS F, as defined in the Draft EIR, "represents jammed conditions. Backups from locations downstream or the cross street may restrict or prevent movement of vehicles out of intersections .. " (Traffic Study, p. 13). More than 50 percent of Project inbound and outbound traffic will use Oxnard Street.

Response to Comment No. A5-74

The Project is expected to create a partially mitigated impact at the Laurel Canyon & Oxnard intersection in the AM peak period. This intersection currently operates at LOS E in the AM & PM peak hours under existing traffic conditions and is expected to operate at LOS F in both peak hours under the Future Without Project traffic conditions before Project-related traffic is added. Mitigation would partly, but not fully, offset the Project’s contribution to traffic at this intersection.

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The comment is incorrect in stating that “more than 50% of Project inbound and outbound traffic will use Oxnard Street.” Per the trip distribution diagram provided in the Traffic Study (Figure 4.1), a total of 10% of outbound Project trips and 13% of Project-related inbound trips are expected to use Oxnard Street to travel to/from the Project Site.

Comment No. A5-75

FREEWAY TRAFFIC .... The preparer of the Final EIR should conduct revised studies of the environmental impact of the Project on adjacent freeway segments (SR-170) and off-ramps in consultation with the State Caltrans. The City of Los Angeles and the State Department of Transportation (Caltrans) often fail to consult on freeway segment and on and off-ramp traffic studies. The lack of consultation with Caltrans is evidenced in the Draft EIR. NOTE: The City Mobility Plan 2035 states, "Where possible and feasible, the City will work with Caltrans to contribute to State highway improvements that directly contribute to ... the City's General Plan," ( Mobility Plan 2035 adopted August 11, 2015 by City Council, p. 90. See Exhibit M- 14).

A Caltrans request dated May 1, 2015 has been ignored (Exhibit M-15) and a 30-page Caltrans study of the adjacent freeway, SR- 170, published in June 2015 is missing from the Draft EIR. District 7 of Caltrans provided "Minimum Contents of Traffic Impact Study Report," (Exhibit M-15) a 4 page letter to lead agency Department of City Planning, City of Los Angeles, May 1, 2015. While the Draft EIR briefly mentions a Caltrans letter on page 4.M-37, it concentrates on data in Appendix E of the Traffic Study, Appendix J to conclude that vehicular trip thresholds leading to further study of freeway segments and off-ramps were not met (p. 4.M-38).

NOTE: A better working relationship between Caltrans and the City of Los Angeles has been promoted by City Councilman Mike Bonin, who asked at a City Council meeting reviewing a final EIR " ... what sort of procedures we can put into place to establish a better working relationship with Caltrans so they can get fed into the process sooner, July 24, 2013.

Special Circumstances of Oxnard Street Off-Ramp (Northbound SR-170) ---The northbound Oxnard Street off-ramp traffic is controlled by a signal.

The May 1, 2015 Caltrans letter refers to the October 2013 "Freeway Impact Analysis Procedures" established by the City and Caltrans to screen freeway segments and off-ramps for further traffic study. The Draft EIR employs an off-ramp allowance of 1,500 vehicles per hour per lane in that agreement (Appendix E, Table E-3 of Appendix J) and concludes that the threshold for further study of this off-ramp has not been met following a November 20, 2014 traffic count.

In the May 1, 2015 communication Caltrans explained the impact of a signal at the off-ramp, such as the one which operates at the northbound off-ramp of SR-170 at Oxnard Street.

However, if the study locations have traffic controls such as a signal or a stop sign, then the actual capacity and Level of Service (LOS) need to be determined by Highway Capacity Manual

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first before screening can be used ... . Cal trans has concerns about queuing of vehicles using offramps that will back into mainline through lanes. Dianna Watson, CEQA Branch Chief District 7, Department of Transportation, May 1, 2015 letter to Department of City Planning.

Setting aside the complication of a signal at this off-ramp, the Draft EIR and the November 19, 2015 Los Angeles Department of Transportation assessment of the traffic study (not included in the December 2015 release of the DEIR) alone substantiate the need for a revised analysis of the impact of Project trips on this off-ramp during peak hours.

1. Oxnard Street --- according to the Draft EIR --- serves as a major route to and from the Project, the vehicular traffic of which will have significant, unavoidable and only partially-mitigated impact on Oxnard Street, "Traffic Study Assessment for the Proposed NoHo West Mixed Use Project (ENV-2015- 888-EIR)," LA Department of Transportation, November 19, 2015, p. 2.and "Future with Project Levels of Service," Appendix J, Figure 4.6.

2.Traffic Study Comparisons of Future Off-Ramp Trips during Peak Hours With I Without Project--- This study reports no net increase from the Project in future trips exiting SR-170 at the northbound off ramp at Oxnard Street in the PM peak hour and turning west or east. The Project will generate a net increase of merely 19 trips per peak in the PM hour traveling northbound into the Project.

Nevertheless, the Draft EIR states that" ... the Project would result in significant impacts at the following six intersections in the PM peak hour ... SR-170 NB ramps & Oxnard Street LOS D," p. 4.M-49.Would not consultation with Caltrans help to resolve this confusion? Without such consultation, study results are without merit.

Number of Peak PM Hour Trips Northbound Off-Ramp of SR-170 at Oxnard Street A Significant Impact?

Future Without Project Future With Project Figure 3-3 Appendix J Figure 4-5 Appendix J Turn West 783 783 Turn East 207 207 Travel North 59 78

Response to Comment No. A5-75

See Response to Comment No. A5-52.

In addition, the comment is incorrect in stating that the Draft EIR and LADOT Assessment Letter substantiate the need for a revised analysis at the SR-170 NB Off – Ramp at Oxnard Street. The significant impact identified by the comment is located at the intersection of Laurel Canyon Blvd & Oxnard Street (intersection is located approximately 950 west of the freeway off-ramp intersection) and not along the Oxnard Street segment or at the Off-Ramp location.

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The referenced impacts are at the intersection of Oxnard Street and Laurel Canyon Boulevard (AM and PM peak hours) and Oxnard Street and Lankershim Boulevard (AM peak hour only) and do not indicate a significant impact on the entire street.

Finally, while the Traffic Study does state that a significant impact was identified at the Oxnard Street & SR-170 Off-ramp intersection, a mitigation measure that would reduce the impact at this intersection to a level of insignificance was identified and analyzed for this location, and approved by LADOT (Mitigation Measure M-5 in the Draft EIR). The intersection is within the City of Los Angeles jurisdiction.

Comment No. A5-76

Missing Off-Ramps ---Developer's consultant identified for screening three freeway off-ramps from SR- 170 omitting (1) the northbound off-ramp at Victory Blvd. (where the only nearby fullaccess freeway ramps exist) and (2) the northbound and southbound off-ramps at Burbank Blvd. (page 4.M-37 and p. 2, May 1, 2015 Caltrans letter to Department of City Planning.)Studies of these offramps should be included in the Final EIR.

Response to Comment No. A5-76

See Response to Comment No. A5-42 regarding the northbound off-ramps from the 170 freeway.

Comment No. A5-77

EIR Study Page No. M. Transportation/Traffic, DRIVEWAYS, Page I-47

The DEIR indicates No Mitigation Required and Less than Significant Impact

DRIVEWAY ---The East Oxnard Street driveway serves as the major inbound and outbound driveway for 1848 residents, 2114 net gain of employees and visitors to the Project (p. 4-M-38). The Draft EIR states that no mitigation measures are required for any of the driveways, including the East Oxnard Street driveway (p. 1-47).

However, at East Oxnard Street current driveway, the two lanes in each direction now measure a total road width of 40 feet --- 20 feet less than the 60 feet required by the LA Department of Transportation. "All driveways should be Case 2 driveways and 30 feet wide and 16 feet wide for two-way and one-way operations," "Traffic Study Assessment for the Proposed NoHo West Mixed Use Project (ENV- 2015- 888-EIR)," LADOT, November 19, 2015, p. 6.

Response to Comment No. A5-77

The east Oxnard Street driveway would serve as one of six driveways serving the Project. The comment is incorrect in stating that the East Oxnard Street driveway is 20 feet too narrow under LADOT driveway standards. The current configuration meets LADOT’s standards per the text cited by the comment that “All driveways should be Case 2 driveways and 30 feet wide and 16 feet wide for two-way and one-way

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operations.” Per this standard, the current driveway is a two-way facility with a width of 40 feet. All driveways would be designed and constructed to the appropriate City standards and subject to final LADOT review and approval.

Comment No. A5-78

EIR Study Page No. M. Transportation/Traffic, BICYCLE, Page I-50

The DEIR indicates No Mitigation Required and Less than Significant Impact

Mixed-use living urban "infill" areas is defined in part by the method of travel in the 21st century (see February 14, 2014, Institute of Transportation Engineers letter to California Governor's Office of Planning and Research concerning proposed amendments to CEQA guidelines for determining the transportation impact of a project).

"The mix of uses within the Project will lead to an interaction between these uses and trips that will walk or use bicycles and therefore not make a car trip," (p. 4.M-49). The Draft EIR Site Circulation Plan does not provide for bicycle paths (Figure 3-7). The private roads of the Project may ignore the State Complete Street Act; the Final EIR should then explain in more detail how travel by bicycle will work inside the Project.

Response to Comment No. A5-78

The Project is designed to encourage walking and biking both on and off-site. As discussed on page 3-2 of the Draft EIR, pedestrian access would be provided around the Project Site and internally via new pedestrian linkages to each commercial and residential building. The Project includes ample short and long-term bicycle storage and internal roadways, which may be used by bicyclists to link the commercial areas, as well as the residential buildings. However, to ensure a conservative analysis, the Traffic Study did not include a reduction in Project-related vehicle trips due to residents, patrons, or tenants walking or bicycling to/from or within the Project Site. The State Complete Street Act applies to public roadways and not to site-internal private streets such as those proposed in the Project.

Comment No. A5-79

EIR Study Page No. M. Transportation/Traffic, CUMULATIVE IMPACTS, Page I-50

The DEIR indicates that after mitigation the level is Significant and Unavoidable.

The Draft EIR analyzed 23 traffic intersections ( Figure 4.6) that " ... were identified as locations where the majority of trips associated with this Project would be focused based on the trip distribution developed for the Project," "Traffic Study" p.7.The trip distribution formula may or may not be reasonable for this Project, as stated above.

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The Draft EIR reports either 7 (p. 2-4) or 9 (p. 4-J-8 & Table 4M-8) related projects generating vehicular traffic. Notably, this published report estimates 450 apartments and 300,000 sf of commercial space to be developed at Valley Plaza. A logical and necessary request is to expand the traffic intersections to be analyzed in view of projected trips to be generated by a related mega-development less than 800 feet from the Project (actually closer to 150 feet). For example, the traffic study could benefit from study of existing and future trips at the following:

Intersection of Radford & Erwin (northwest corner of the Project) ---The 2009 Final EIR for Laurel Plaza redevelopment did study this intersection (Figure IV.M-1).

Response to Comment No. A5-79

See Response to Comment No. A5-73, above, regarding trip distribution for the Project.

The Draft EIR and Traffic Study identified a total of 9 cumulative projects, including the Valley Plaza project. As required by LADOT’s Traffic Study guidelines, the trips expected to be generated by the Valley Plaza project were assigned to the roadway network and analyzed in both the Future Without and Future With Project scenarios. The results of the analysis are documented in the Traffic Study (see Tables 3.2 and 3.3 of the Traffic Study for Future Without Project analysis results and Tables 4.2 and 4.3 of the Traffic Study for Future With Project analysis results).

Regarding the intersection of Radford Avenue & Erwin Street, per LADOT guidelines, unsignalized intersections are only to be analyzed to determine if they warrant the installation of a traffic signal. Additionally, only unsignalized intersections that are expected to operate at LOS E or F are to be analyzed to see if signal warrants are met. Nevertheless, following the publication of the Draft EIR, a supplemental analysis of the Radford Avenue & Erwin Street intersection including additional traffic counts was conducted to further analyze any potential for traffic impacts. (See Appendix E of this Final EIR.) The analysis shows that this intersection is expected to operate at LOS A under Future With Project conditions. Therefore, installation of a traffic signal at the Radford Avenue & Erwin Street intersection is not warranted.

Comment No. A5-80

Transportation Demand and Management Program --- Planning for all modes of travel should be obvious in view of the major public transportation hub at the METRO Red Line in North Hollywood and the likely development of commercial and residential space at Valley Plaza.

Response to Comment No. A5-80

Due to its proximity to major public transportation routes, the Project encourages the use of alternative modes of transportation. However, to ensure a conservative analysis, the Traffic Study did not include a reduction in Project-related vehicle trips due to residents, patrons, employees or tenants using transit to travel to/from the Project Site. In addition, the Project includes a Project Design Feature (PDF-M-10) for the incorporation of Transportation Demand Management (TDM) strategies. The Project is also subject to

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the TDM requirements of LADOT for development in excess of 25,000 square feet of gross floor area (LAMC Section 12.26-J).

Comment No. A5-81

PARKING --- "The traffic study did not indicate the total number of parking spaces to be provided to satisfy code requirements. The applicant should check with the Department of Building and Safety on the number of code-required parking spaces needed for this project." (Exhibit M-13 page 6 as stated in Traffic Study Assessment for the Proposed NoHo West Mixed Use Project.)

Response to Comment No. A5-81

Draft EIR Table 3-2 provides the vehicle parking requirements for the Project. As shown therein, per LAMC requirements, the Project would be required to provide 1,191 residential parking spaces and 2,694 commercial parking spaces, for a total of 3,885 parking spaces. However, as discussed on page 3-3 of the Draft EIR, the Project has requested approval for shared parking between the commercial uses to provide a total of 2,633 commercial parking spaces. The Project would also provide 1,312 exclusive residential parking spaces, which includes 121 residential spaces designated for guest parking.

Comment No. A5-82

While there are Bus routes along Oxnard Street and Laurel Canyon Boulevard, there is no metro or subway. There is congestion on the 170 freeway Oxnard Street on ramp and off ramp. We request that the Draft EIR analyze the current traffic patterns on streets and freeways; this information will provide for example, baseline data in the event the applicant will be required to develop a Transportation Demand Management Program and/or a multi-modal transit center. Such a center could, for example, offer DASH routing to and from this project to the North Hollywood Metro Station. We also request that traffic studies for the Project area be conducted in accordance with the Traffic Study Policies and Procedures, dated August 2014, for the City and with Caltrans study requirements as appropriate. Data collection required for these studies should be done for a peak-day, non-holiday week when schools are in session.

Response to Comment No. A5-82

See Response to Comment No. A5-50 for the parameters under which the Traffic Study was undertaken. In addition, the Project includes a Project Design Feature (PDF-M-10) for the incorporation of Transportation Demand Management (TDM) strategies.

Comment No. A5-83

EIR Study Page No. N.1. Utilities and Service Systems: Wastewater, CONSTRUCTION, Page I-50

The DEIR indicates Less than Significant Impact.

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We do not agree that there is less than significant impact. For categories 17a-f, the 742 units will significantly burden the existing water supply, which is already inadequate for the City's existing population. We believe the project would require construction of new storm water drainage. With the mandatory cutbacks of water already in place, the City's existing entitlements are being exceeded. This new project would ask to use water that does not presently exist.

Response to Comment No. A5-83

The statement that the Project would use water that does not presently exist is incorrect. The LADWP is responsible for ensuring that water demand within the City is met and that State and Federal water quality standards are achieved. On October 6, 2015, the LADWP Board of Commissioners approved a Water Supply Assessment (WSA) for the Project in accordance with the requirements of Senate Bills 610 and 221. The WSA (included as Appendix K-4 of the Draft EIR) finds that adequate water supplies will be available to meet the total demand of 298 AFY annually for the Project for normal, single-dry and multiple-dry years, in addition to the existing and planned future demands of the LADWP. Therefore, the Project is consistent with the 2010 Urban Water Management Plan (UWMP), and a less than significant impact would occur.

The Project would also comply with various regulatory measures to reduce water demand and consumption. For example, the Project would comply with the Governor’s Executive Order on drought conditions, which “prohibits new homes and developments from being irrigated with potable water unless water-efficient drip irrigation systems are used, and ban watering of ornamental grade on public street medians.” The Project would comply with the City’s Low Impact Development Ordinance (City Ordinance No. 181,899) and will implement Best Management Practices (BMPs) that have stormwater recharge or reuse benefits (as applicable and feasible). The Project would also be required to comply with the City’s Water-Efficient Landscaping Ordinance (LAMC Building Code Chapter 71), which would minimize landscape irrigation. In addition, Regulatory Compliance Measures N.2-1 to N.2-5 are provided, which are standard City measures that would further ensure that the Project’s impacts on water demand are less than significant.

The Project would not require the construction of new storm water drainage facilities or expansion of existing facilities. Regarding storm water drainage, all development and redevelopment projects that create, add, or replace 500 square feet or more of impervious area must comply with the City's Low Impact Development (LID) Ordinance, including LID Best Management Practices (BMPSs) (determined on a case by case basis by Public Works), and if not feasible, then Standard Urban Stormwater Mitigation Plan (SUSMP BMPs) would apply. LID is a storm water management strategy that seeks to prevent impacts of runoff and storm water pollution as close to the source as possible. The LID ordinance passed in 2011 amended LAMC 64.70 (the City’s storm water ordinance) and expanded on the City’s existing SUSMP requirements. LID is different from the previous SUSMP, in that it requires a larger category of development and redevelopment projects to comply with storm water measures, and incorporate new LID practices and measures. In addition, the Project would comply with the Los Angeles Green Building Code (LAGBC), which is based on the 2010 California Green Building Standards Code (CalGreen). For these reasons, the Project would not require the construction of new storm water drainage facilities or

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expansion of existing facilities other than those provided on-site as part of the Project, and impacts would be less than significant.

Comment No. A5-84

EIR Study Page No. N.1. Utilities and Service Systems: Wastewater, GENERATION, Page I-51

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Wastewater generation is based on the DEIR projected Water Demand which is 83,603 gallons per day lower than the LADWP estimate in its Water Supply Assessment. As the LADWP estimate has credibility that the DEIR estimate does not, all wastewater conclusions need to be revisited. While the Hyperion Treatment Plant may be capable of treating the Project's wastewater, as noted, the local infrastructure may not. Based on a wastewater estimate using the LADWP assessment, the local infrastructure needs to be studied to determine if and to what extent it needs to be upgraded or replace. The final EIR must have such a study and only then will a conclusion as to its Level of Significance be justified. The current determination of Less than Significant is not credible.

Response to Comment No. A5-84

The Project’s overall water demand estimate is provided and disclosed in the WSA, which is used to ensure that there is adequate water supply for the Project. The estimated water demand table in the Draft EIR (Table 4.N.2-3) was utilized as part of the overall water demand estimate for the WSA (it was part of the initial request for a WSA and included as part of the WSA), which includes additional factors for landscaping and mechanical needs such as a cooling tower. The calculated total water demand is referenced in the Draft EIR and included in the WSA.4 The initial calculation of the water demand is estimated using wastewater generation factors from the Department of Public Works and totals 182,370 gpd. This calculation assumed the removal of existing uses, which include 465,000 sf of department store and 90,000 sf of office. Further in the Water section of the Draft EIR, the formal WSA analysis is disclosed. The LADWP evaluated water demand from the Request for Water Supply Assessment and Scope Conformation (which was based on Table 4.N.2-3) using sewer generation factors, and more detailed information including outdoor landscape water demand estimates, and historical billing records to determine existing baseline water demand. The water demand using these calculations is 265,973 gpd. The larger calculated demand described in the WSA as “Projected total water demand increase for the Proposed Project is estimated to be maximum of 298 AF annually which includes annual water conservation.” 5 It is the larger calculated demand that factors into whether the LADWP could supply the Project. Since the LADWP has indicated that its water supplies will be available to meet the total additional maximum water demand of 298 AF annually, it would also be able to meet the demand of

4 See page 4.N.2-15 and Appendix K-4 of the Draft EIR. 5 See page 7 of the WSA (which is included as Appendix K-4 to the Draft EIR).

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anything below that amount as well. Accordingly, no further analysis of the Project's water demand is necessary.

Wastewater generation was calculated using rates provided by the Wastewater Engineering Services Division (WESD) and is based on the conversion of the Macy’s building square footage to office use (consistent with the traffic study). As provided on page 4.N.1-6 of the Draft EIR, the sewer infrastructure in the vicinity of the Project Site presents two options to convey Project wastewater, an existing 8-inch line on Erwin Street and an existing 8-inch line on Radford Avenue. In Option 1, sewage from the 8-inch line on Erwin Street feeds into a 21-inch line on Laurel Canyon Boulevard before discharging into two flows. The first flow discharges into a 48-inch line on Woodbridge Street and the second flow discharges into a 48-inch line on Valley Spring Lane. In Option 2, the existing 8-inch line on Radford Avenue feeds into a 12-inch line on Colfax Avenue before discharging into a 57-inch line on Acama Street. According to the Bureau of Sanitation (correspondence included in Appendix K-2 of the Draft EIR), based on the estimated flows, the sewer system would be able to accommodate the total flow of the Project using Option 1.

As part of the building permit process, the City, as the lead agency, would confirm and ensure that there is sufficient capacity in the local and trunk lines to accommodate the Project’s wastewater flows. The construction phase of the Project would need a sewer connection permit and Sewer Capacity Availability Review (SCAR) application. Further, detailed gauging and evaluation would be needed as part of the permit process to identify the specific sewer connection points. If the public sewer has insufficient capacity, then the Applicant would be required to build sewer lines to a point in the sewer system with sufficient capacity (see Regulatory Compliance Measures N.1-1 and N.1-2). The Project would also pay any required sewer connection fees.

As stated on page 4.N.1-6 of the Draft EIR, wastewater from the Project Site would be conveyed to the Hyperion Treatment Plant (HTP), which has a remaining treatment capacity of approximately 88 million gpd. The 0.15 mgd net increase in wastewater over the existing Project Site uses represents approximately 0.17 percent of the remaining capacity at the HTP (see Draft EIR page 4.N.1-10). Therefore, the HTP has enough remaining capacity to accommodate the Project.

For the reasons listed above, the Project would result in less than significant impacts regarding wastewater generation.

Comment No. A5-85

EIR Study Page No. N.1. Utilities and Service Systems: Wastewater, CUMULATIVE IMPACTS, Page I- 51 The DEIR indicates No Mitigation Required and Less than Significant Impact. We do not agree that there is less than significant impact. See Wastewater Generation above and Water Demand below. Together the non-credible estimates as used in the DEIR makes a determination of Level of Significance moot at this point. The final EIR must use credible estimates and re-study these matters before making a determination.

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Response to Comment No. A5-85

The preparation of the Draft EIR included consultation with the Bureau of Sanitation and LADWP regarding wastewater generation and water supply, respectively (correspondence is provided in Appendices K-1 through K-4 of the Draft EIR). See also Responses to Comments A5-83 and A5-84 for additional discussion of the Project’s impacts with respect to wastewater and water. The cumulative wastewater impacts are discussed on Draft EIR pages 4.N.1-11 and 4.N.1-12, and as analyzed therein, cumulative impacts would be less than significant.

Comment No. A5-86

EIR Study Page No. N.2. Utilities and Service Systems: Water, WATER DEMAND, Page I-52

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Here again, the DEIR chooses to ignore historical data in favor of using unjustifiable planning estimates. In the DEIR's own Appendix K-4, Water Supply Assessment, produced by the Los Angeles Department of Water and Power, the preferred project is found to create a Net Additional Water Demand of 265,973 gallons per day. The Project Estimated Water Demand, as shown on Table 4.N.2-3, is 182,370 gpd. The LADWP estimate is accordingly 45.6% higher than that of the project estimate. The ability of the DEIR study consultants to cherrypick data to the project's benefit clearly absolves them of any claim of objectivity. LADWP, based on its own billing data, shows the net existing water use to be 15,047 gpd. The DEIR chooses 43,584 gpd as the existing usage to be removed. How do they get this number? They use planning estimates based on the square footage of underutilized existing buildings including all 4 floors of the Macy's building, only 3 of which are in actual use. While within the over thousand pages of DEIR it might appear, we cannot find if the water-usage in the apartments will be individually metered. In light of California's ongoing water-supply difficulties, such metering is clearly to the benefit of our environment.

Response to Comment No. A5-86

The existing uses are based on the square footage of the existing buildings. As stated in the Environmental Setting section of the Draft EIR, and within the traffic study, the Project Site contains a 465,000-square-foot building that is currently fully leased to, and operates as, a Macy’s Department Store.

6 See page 4.N.2-15 and Appendix K-4 of the Draft EIR.

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wastewater generation factors from the Department of Public Works and totals 182,370 gpd. This calculation assumed the removal of existing uses, which include 465,000 sf of department store and 90,000 sf of office. Further in the Water section of the Draft EIR, the formal WSA analysis is disclosed. The LADWP evaluated water demand from the Request for Water Supply Assessment and Scope Conformation (which was based on Table 4.N.2-3) using sewer generation factors, outdoor landscape water demand estimates, and historical billing records to determine existing baseline water demand. The water demand using these calculations is 265,973 gpd. The larger calculated demand described in the WSA as “Projected total water demand increase for the Proposed Project is estimated to be maximum of 298 AF annually which includes annual water conservation.” 7 It is the larger calculated demand that factors into whether the LADWP could supply the Project. Since the LADWP has indicated that its water supplies will be available to meet the total additional maximum water demand of 298 AF annually, it would also be able to meet the demand of anything below that amount as well.

The Project’s overall wastewater generation estimate contained in Table 4.N.1-2 (on page 4.N.1-9) of the Draft EIR is based on the size of the existing uses and is calculated using the Bureau of Sanitation’s generation rates. As indicated on page 4.N.1-10 of the Draft EIR, and in Response to Comment No. A5- 80, the Project's wastewater flow would be accommodated by the HTP, which has adequate extra capacity. Any unanticipated issues with the local infrastructure's capacity would be addressed by compliance with Regulatory Compliance Measures N.1-1 and N.1-2.

The Project Applicant has committed to implement a number of water conservation measures throughout the Project, which are included in the WSA. Such measures include various low-flow fixtures, drought- tolerant plants and water efficient landscaping infrastructure, efficient water heaters, stormwater infiltration basin, and use of recycled water when a connection is feasible. Therefore, the Project's impact on water demands would be less than significant.

Comment No. A5-87

EIR Study Page No. N.2. Utilities and Service Systems: Water, FIRE FLOW, Page I-53

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Again, in light of the non-credible Water Demand total used in determining the Level of Significance her, the final EIR must restudy this matter based on the credible LADWP Water Demand finding.

Response to Comment No. A5-87

City fire-flow requirements, as established in the Fire Code, vary from 2,000 gallons per minute (gpm) in low-density residential areas, to 12,000 gpm in high-density commercial or industrial areas. In all cases, a minimum residual water pressure of 20 pounds per square inch (PSI) is required to remain in the water

7 See page 7 of the WSA (which is included as Appendix K-4 to the Draft EIR).

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system while the required gpm is flowing. All water mains and lines that are designed and sized according to LADWP standards take into account fire flow and pressure requirements. As stated on page 4.N.2-14 of the Draft EIR, the Project design includes features to increase the capacity of existing water infrastructure in accordance with LADWP standards, which take into account LAFD fire flow and pressure requirements (see Draft EIR page 4.N.2-14).

The Water Operations Division of the LADWP would perform a detailed fire flow study at the time of permit review in order to ascertain whether further water system or site-specific improvements would be necessary. Hydrants, water lines, and water tanks would be installed per Fire Code requirements. According to Regulatory Compliance Measure N.2-1, the Project Applicant will consult with the LADBS and LAFD to determine fire flow requirements for the Project, and will contact a Water Service Representative at the LADWP to order a Service Advisory Report (SAR). This system hydraulic analysis will determine whether existing LADWP water supply facilities can provide the proposed fire flow requirements of the Project. If water main or infrastructure upgrades are required, the Applicant would pay for such upgrades, which would be constructed by either the Applicant or LADWP.

In addition, proposed plot plans are required to be submitted to the LAFD for review for compliance with applicable Los Angeles Fire Code, California Fire Code, City of Los Angeles Building Code, and National Fire Protection Association standards, which would ensure that the Project would not create any undue fire hazard. Compliance with the code, including the 2014 Fire Code and any updates, would ensure that adequate fire flow is provided. Therefore, the Project's impact on fire flow would be less than significant and no mitigation is required.

Comment No. A5-88

EIR Study Page No. N.2. Utilities and Service Systems: Water, WATER SUPPLY, Page I-53

The DEIR indicates No Mitigation Required and Less than Significant Impact.

We do not agree that there is a less than significant impact. Again, in light of the non-credible Water Demand total used in determining the Level of Significance her, the final EIR must restudy this matter based on the credible LADWP Water Demand finding.

Response to Comment No. A5-88

See Response to Comments A5-83, A5-84, and A5-86 regarding the Project’s water demand.

Comment No. A5-89

EIR Study Page No. N.2. Utilities and Service Systems: Water, CUMULATIVE IMPACTS, Page I-53

The DEIR indicates No Mitigation Required and Less than Significant Impact.

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Response to Comment No. A5-89

See Response to Comments A5-83, A5-84, and A5-86 regarding the Project’s water demand.

Comment No. A5-90

EIR Study Page No. N.2. Utilities and Service Systems: Solid Waste, CONSTRUCTION, Page I-54

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Without an affirmative statement given by the operators of The Mesquite Landfill that in fact it has adequate capacity to accept the Project's demolition and construction waste, less than significant is not justified.

Response to Comment No. A5-90

The Draft EIR explains, with citations to evidence, why it concludes that there is adequate landfill capacity to serve the portion of the Project’s demolition and construction waste that is not recycled. See Draft EIR pages 4.N.3-10 through 4.N.3-17. This evidence includes the statement on the Mesquite Regional Landfill website that this facility has 600 million tons of capacity and a lifespan of 100 years. CEQA requires only that its conclusions be supported by substantial evidence and does not require the lead agency to obtain individual affirmative statements of capacity from all providers of services to a proposed project.

Comment No. A5-91

EIR Study Page No. N.2. Utilities and Service Systems: Solid Waste, OPERATION, Page I-55

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Missing here is the manner in which solid wastes will be picked up and on what schedule. A once-a-week pick-up for the 742 apartments as proposed seems very problematic. Where will the holding bins be located? How will trucks access them? How often will pick-ups be made and on what schedule? Such matters are of paramount concern to the project's home-owner neighbors as they affect matters of noise, noisome odors and traffic congestion. Without a finding in these matters, less than significant is unjustified.

Response to Comment No. A5-91

This comment pertains to noise, odor, and traffic concerns associated with solid waste pickup, rather than the topics addressed in the Utilities and Service Systems – Solid Waste section of the Draft EIR. LAMC

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Section 113.01 describes the allowable hours for rubbish and garbage collection. If the trash bin is within 200 feet of residential uses, the collection is allowed between 6:00 AM and 9:00 PM. If the trash bin is more than 200 feet from residential uses, then it can be picked up anytime.

Holding bins would be located internally on the Project Site, and within each residential area. Views of the trash receptacles would be screened using methods that typically shield mechanical and operational items such as HVAC, utilities, and trash. Traffic congestion would be minimal due to the temporary nature of trash pickup, the use of the Project's internal roadways to reach the trash receptacles, and the negligible amount of truck trips as compared to peak hour trips in the area. The waste would be collected by a private waste hauler through the City’s Waste Hauler Permit Program, which requires the haulers to pay applicable AB 939 compliance fees, which are used to provide funding and operation for recycling and diversion of waste from landfills. It is not known at this time how often the pickups would be made, but compliance with the LAMC's limitations on hours of operations is anticipated. Therefore, the Project's noise, odor, and traffic impacts from solid waste operations would be less than significant.

Comment No. A5-92

EIR Study Page No. N.2. Utilities and Service Systems: Solid Waste, COMPLY WITH REGULATIONS, Page I-56

The DEIR indicates No Mitigation Required and Less than Significant Impact.

We do not agree that there is a less than significant impact. Protocols for adherence to the regulations as stated need to be created. Understaffed Los Angeles City departments are already hard-pressed to enforce existing solid waste regulations. While scavenging recycle bins is illegal, it is a constant problem throughout the City. Bins are to be a curbside for limited time windows consistent with the pick-up schedule, but enforcement of regulations is spotty to non-existent. A promise to comply with regulations is empty minus protocols the project's neighbors can cite in the absence of compliance. The final EIR must include such protocols.

Response to Comment No. A5-92

The Los Angeles Department of Building and Safety is responsible for investigating Code violations. CEQA does not require an environmental analysis of whether illegal activity or willful violations are currently taking place in the City or will take place in the future. The Draft EIR discloses the legal requirements and the Project’s compliance with applicable codes and regulations is assumed. In addition, as noted in Response to Comment No. A5-91 above, the Project proposes holding bins internal to the Project Site and not curbside or on the perimeter of the Project Site. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

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Comment No. A5-93

EIR Study Page No. N.2. Utilities and Service Systems: Energy Conservation, OPERATION ELECTRICITY, Page I-56

The DEIR indicates Less than Significant Impact.

We do not agree that there is less than significant impact. Notwithstanding LADWP's ability to serve the project's electricity needs, we note here that an increased total load on its system incurs higher costs for all, as new sources are the most expensive and rates do not consider the vintage of when load was added, e.g., load added in 1950 pays the same rate as similar load added in 2020. The project's load on the LADWP system would decrease, rates would benefit, and the global warming effect of C02 would be reduced if the project committed to the Million Solar Roofs initiative. We want to see such a commitment in the final EIR.

Response to Comment No. A5-93

As discussed on page 4.N.4-12 of the Draft EIR, the Project's annual electricity consumption would represent approximately 0.037 percent of the LADWP’s forecasted electricity demand in 2020. Thus, the Project is within the anticipated demand of the LADWP system. CEQA does not require the environmental analysis to analyze issues regarding LADWP’s pricing rate system.

The Project is not required to include solar panels, but would receive electricity supply from LADWP, which obtains a portion of its electricity supplies from renewable sources. The Project would comply with LA City’s Green Building Code Section 99.04.211.5, by providing a minimum of 250 square feet of contiguous unobstructed roof area on each building for the installation of future solar photovoltaic or other electrical solar panels. Therefore, the Project's impacts on energy conservation regarding operation electricity would be less than significant.

Comment No. A5-94

Based upon the Laurel Grove Neighborhood Association's review of the Draft Environmental Impact Report and input received from stakeholders, we request that the Final Environmental Impact Report be amended to consider our concerns as stated in this review and to incorporate them into it when your unbiased analysis finds them appropriate. We appreciate your consideration of our community's concerns about the Project.

Response to Comment No. A5-94

Responses to the Laurel Grove Neighborhood Association’s specific concerns are provided herein in Responses to Comment Nos. A5-2 through A5-93.

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LETTER NO. A6

Peter O’Leary, Council President Emmanuel Lutheran Church 6020 Radford Avenue North Hollywood, CA 91606

Comment No. A6-1

Emmanuel Lutheran Church is the owner and operator of several properties located adjacent to or near the proposed NoHo West Project (the "Project"). More specifically, Emmanuel Lutheran Church owns and operates: (a) Laurel Hall School, a K-8 private school located immediately adjacent the Project, at the southeast corner of West Oxnard Street and Radford Avenue; (b) Emmanuel Lutheran Church of North Hollywood ("ELC"), located at 6020 Radford Avenue (immediately east of Laurel Hall School and on the east side of Radford Avenue); (c) the Early Childhood Center, a pre-school facility ("ECC"), and (d) four single family homes lying adjacent to ELC and ECC on the west side of Carpenter Avenue. For 70 years, Emmanuel Lutheran Church has been located at West Oxnard Street and Radford Avenue, serving as both a house of worship and a church-affiliated private school. Today, Laurel Hall School and the ECC serve approximately 600 children between the ages of 2 and 14 at these locations.

The purpose of this letter is to submit our Comments to the Draft Environmental Impact Report for the proposed NoHo West Project. Because of the large scope of the Project and its location immediately adjacent to our day school and pre-school, the impact of the Project, during redevelopment, construction and operation is of concern to our entire community of students, families of students, staff and parishioners. We appreciate the opportunity to submit these comments to you, and anticipate that you will consider and address our concerns and request for additional investigation and analyses prior to the adoption of the Final Environmental Impact Report.

We want to acknowledge the courtesy shown to us already by Applicant MGP XI-GPI Laurel Plaza, LLC and its affiliate, Merlone Geier Partners. We also want to acknowledge the extensive work completed and described in the Draft Environmental Impact Report. We look forward to working with the Applicant to address the concerns we summarize below. We are genuinely excited about the prospects of our pre- school and K-8 educational programs serving the new residents of NoHo West, as well as those working within the Project

Response to Comment No. A6-1

The comment provides general introductory information and also information about the Emmanuel Lutheran Church facilities, including the Laurel Hall School, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. The comment is therefore acknowledged for the record.

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Comment No. A6-2

Aesthetics - Visual Resources and Views

Pg 4.B.1 -7

The evaluation of height and massing of the Project does not include the evaluation of the impact of the Project on the adjacent Laurel Hall School, nor does it appear to consider the impact of school operations, particularly the activities on the athletic field (south of the residential component of the project), on the Project. Strategies for mitigation of the visual impact of the Project on Laurel Hall School, and of school use of its athletic fields on the residential component of the Project, should be included. Mitigation measures should be evaluated and discussed.

Response to Comment No. A6-2

The Project’s potential aesthetic (shade/shadow) impacts on the Laurel Hall athletic field are discussed on Draft EIR pages 4.B.2-2 and 4.B.2-3. As shown on Draft EIR Figures 4.B-15 through 4.B-20, the shade and shadow studies demonstrate that the Project would have no shade and shadow impact on a sensitive use, including the Laurel Hall School and its athletic field. In addition, the massing of the Project’s buildings would be softened by substantial landscaped setbacks, varying façade relief, articulation, and windows.

In response to public comments received on the Draft EIR, the Project Applicant is considering changes to the Project. Accordingly, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). As part of Alternative 4B, the height of the residential units along Calvert Place has been reduced to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School. Abundant landscaping would also be provided between Alternative 4B and the Laurel Hall School. See also Response to Comment No. A5-4 for additional specifics regarding Alternative 4B.

Comment No. A6-3

Air Quality

Pg 4.C-9

The air quality analysis erroneously locates the Early Childhood Center ("ECC") at the Laurel Hall School location. The ECC is located at the southeast corner of the intersection of Calvert Street and Radford Street. There are approximately 126 preschool aged children in the program at this location, some 60 feet east of the eastern boundary of the Project. The ECC should be separately acknowledged and studied in the air quality analysis.

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Pg 4.C-9

The report notes "As illustrated on Table 4. C-6, these nearby receptors could be exposed to substantial concentrations of localized pollutants N02, PM10, and PM2.5 from construction of the Project. Specifically, construction activities would exceed SCAQMD LST thresholds for N02, PM10 and PM2.5 resulting in a potentially significant impact." There is no discussion of the impact of these pollutants on children that are active outdoors (outside the classroom) using the open space and athletic fields of Laurel Hall School, or separately, outdoor activities at the ECC. There is no discussion of mitigation measures or strategies for impacts on Laurel Hall School or the ECC and their respective programs other than "the funding for replacement of air filters at ... Laurel Hall School' (PDF-C-12 at page 4.C-20). Both the in- classroom and outdoor activities of school children and staff at both Laurel Hall School and the Early Childhood Center should be specifically studied in this air quality analysis, and appropriate mitigation measures evaluated and proposed.

Response to Comment No. A6-3

Regarding the location of the ECC, the Final EIR will note the correction (see Section 3, Additions and Corrections, of this Final EIR). The potential impact on this location is analyzed in the Draft EIR’s assessment of gross localized emissions of CO, NO2, PM10, and PM2.5. Specifically, the Draft EIR compared projected emissions against the SCAQMD’s closest screening distance of 25 meters (see footnote contained in Draft EIR Table 4.C-6). While the ECC is located about 60 feet away (18 meters), the SCAQMD recommends that “[p]rojects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.”8 The provided mitigation measures (C- 1 through C-5), regulatory compliance measure (C-6), and voluntary construction measures (C-11 through C-13) would address potential impacts on the ECC’s location at Calvert and Radford. Mitigation Measures C-1 through C-4 provide specifications for equipment and haul trucks to be used during Project construction, Mitigation Measure C-5 requires the Applicant to lengthen the period for the application of architectural coatings, and Regulatory Compliance Measure C-6 requires compliance with SCAQMD Rule 403. With implementation of these measures, impacts would be less than significant.

The Draft EIR compares projected emissions against the SCAQMD’s LST thresholds takes into account any potential impacts on outdoor play. Specifically, the location of the ECC’s play area to the potential construction activities is addressed by the LSTs, which address any projects with boundaries closer than 25 meters, pursuant to SCAQMD guidance. Further, ambient air quality standards for localized pollutants are based on exposure times that are longer than any potential outdoor play sessions (i.e., 24-hours for

PM10 and PM2.5 and 1-hour for NO2). In addition to PDF-C-12 described in the comment, two additional voluntary construction measures have been provided by the Applicant: PDF-C-11 which requires construction vehicles, to the extent feasible, to avoid travel on the streets immediately adjacent to the Laurel Hall School, and PDF-C-13 which calls for the Applicant to provide notification of site grading

8 South Coast Air Quality Management District, “Final Localized Significance Threshold Methodology”, July 2008. http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst- methodology-document.pdf

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and preparation periods to avoid or minimize overlaps with school activities, particularly outdoor play periods. It is of note that even without these measures, impacts to the Laurel Hall School and ECC would be less than significant.

Comment No. A6-4

Noise Pg 4.J-12

Omission of the identification of the Early Childhood Center as a "sensitive receptor". The ECC is located at the southeast corner of the intersection of Calvert Street and Radford Street. There are approximately 126 pre-school aged children in the program at this location, some 60 feet east of the eastern boundary of the Project.

Response to Comment No. A6-4

The Draft EIR contains analysis of a variety of sensitive receptors, some of which are chosen specifically so as to be representative of other sensitive receptors around their general locations. 6120 Radford Avenue was chosen for detailed study as its general location and setting is similar to that of other receptors along the northbound side of Radford Avenue, including the Early Childhood Center. The ambient noise levels at both 6120 Radford Avenue and the Early Childhood Center are largely influenced by vehicular traffic along Radford Avenue, and both are located at a similar distance from the Project Site. The residence at 6120 Radford Avenue is approximately 80 feet east of the Project Site and the Early Childhood Center playgrounds are approximately 70 feet east of the Project Site, while building facilities at the Early Childhood Center are located, at their nearest, approximately 95 feet east of the Project Site. Based on the similarities between the two locations, projected construction noise and vibration impacts for the Early Childhood Center would be largely analogous to those projected for 6120 Radford Avenue.

Mitigation Measures J-1 through J-6 have been provided to reduce construction noise impacts to the maximum extent possible. These measures require installation of a temporary sound barrier, exhaust mufflers on powered construction equipment, portable noise sheds for smaller, noisy equipment, for the haul route to minimize travel on residential streets, and for notification to be provided to off-site residential and school uses two weeks prior to construction, notifying them of the construction. As shown in Table 4.J-11 of the Draft EIR, implementation of Mitigation Measures J-1 through J-6, would reduce construction noise impacts at 6120 Radford Avenue to 3.5 dBA. This is below the 5.0 dBA increase threshold for construction occurring more than 10 days in a 3-month period, as set forth by the City’s CEQA Thresholds Guide. Mitigation Measures J-1 through J-6 would also ensure that Project-related construction noise does not exceed the Los Angeles Municipal Code’s 75 dBA limit for construction machinery. Likewise, these measures would also mitigate such impacts at the Early Childhood Center. Mitigation Measure J-2, in particular, would limit construction noise impacts to below levels of significance by requiring temporary noise barriers to be installed along the easternmost boundary of the Project Site. The temporary noise barriers would serve to obstruct line-of-sight sound travel from Project- related construction activities to 6120 Radford Avenue, as well as the Early Childhood Center.

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Concerning vibration impacts from construction, the Early Childhood Center would experience ground- borne vibration levels similar to 6120 Radford Avenue of 76 VdB and 0.024 inches per second PPV. These levels were calculated using the methods described in Table 4.J-8 of the Draft EIR. As stated on page 4.J-8 of the Draft EIR, the structural integrity threshold for non-engineered timber and masonry buildings is 0.2 inches per second PPV. From the same page, consideration for significant human annoyance impacts begins at 83 VdB for institutional buildings such as schools. Projected ground-borne vibration levels would not exceed these thresholds, and as a result, vibration impacts at the Early Childhood Center would be less than significant.

Comment No. A6-5

Pg 4.J-17

Excessive vibration at portable classrooms at Laurel Hall School. Strong vibrations are anticipated at these class rooms during construction; no mitigation measure is specified. The duration and extent of this vibration, as well as the scheduling of this work is not specified. Vibration like that anticipated (94 VdB) is well in excess of the standard suitable for an educational building. Mitigation measures or strategies should be evaluated and proposed.

Response to Comment No. A6-5

As stated on page 4.J-8 of the Draft EIR, the Federal Transit Administration (FTA) has established vibration impact thresholds for human annoyance caused by long-term operational activities. For the portable classrooms at Laurel Hall School, this threshold would be 83 VdB. However, this threshold is intended to apply to long-term operational vibration from transit projects, not from temporary events such as construction activities. There are no criteria for assessing the significance of short-term vibration impacts.

Vibration impacts were modeled using reference levels of equipment to be operated during the Project’s grading phase. Other construction phases would not utilize equipment as disruptive as those required for site grading activities. Therefore, the analysis examines a “worst-case-scenario”; the vibration impacts of all other construction phases would not exceed those analyzed here and in the Draft EIR.

Additionally, when calculating potential off-site vibration levels at Laurel Hall School's portable classrooms, the vibration analysis only assumed a 15-foot distance from the Project Site boundary to the receptor. The resultant 94 VdB projection thus represents a conservative approach, because the majority of construction activities would not occur at such a close distance (i.e., at the property line), but would be spread across the entirety of the Project Site. As a result, most vibration-causing activities would occur at much greater distances and have imperceptible vibration impacts on the portable classrooms, meaning those activities would be below 65 VdB.

Furthermore, the portable classrooms are located at a lower elevation than the adjacent Project Site and behind a retaining wall. Similar to how barriers attenuate noise by obstructing its line-of-sight travel,

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voids and trenches obstruct direct source-to-receptor ground-borne vibration paths. Given this, surface- traveling vibrations generated by heavy equipment such as bulldozers and other tractor-type vehicles would not be capable of reaching Laurel Hall School's portable classrooms via direct paths unobstructed by this retaining wall and the void behind it. Instead, only weaker diffracted vibrations would be capable of reaching these receptors. In addition, since these portable classrooms do not have subsurface foundations, they would be even less susceptible to any vibrations occurring below surface level. There would be no capability of subsurface foundations transmitting subsurface level vibrations into the structures, as portable classrooms lack these types of supports.

Given all of these considerations, vibration impacts at Laurel Hall School are not likely to exceed any relevant FTA criteria. And, most importantly, any exceedances would be temporary and not evaluated against FTA standards for long-term transit operations. Therefore, no significant impacts would occur and no mitigation measures are necessary.

Comment No. A6-6

Public Services – Police Protection

Pg 4.L.2-11

Security Patrols. Because of the attractive nuisance of the construction site and the possibility of both theft and of vandals or vagrants on the Project site, mitigation measure MM-L.2-1 should be modified to include the perimeter of Laurel Hall School and the ECC, to provide for added security for the facility and, during the school day, school children and staff.

Response to Comment No. A6-6

The request for mitigation measure L.2-1 to be modified is acknowledged for the record and will be forwarded to the decision-making bodies for their review and consideration.

Comment No. A6-7

Traffic

Pg 4.M-3

The intersection of Erwin Street and Radford Avenue has not been studied. It will be heavily impacted by the proposed project. Signalization may be required when considering the addition of future trips. Thus, a peak hour Signal Warrant Analysis should be provided, following MUTCD guidelines.

Response to Comment No. A6-7

The intersection of Radford Avenue & Erwin Street is unsignalized and therefore not included in the impact analysis conducted in the Traffic Study.

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In response to the comment, however, a supplemental analysis of the Radford Avenue & Erwin Street intersection has been conducted. This supplemental analysis determined that the intersection currently operates at LOS A during both the AM and PM peak hours. (See Appendix E of this Final EIR.) The analysis also determined that the intersection is expected to operate at LOS A in both the AM and PM peak hours under Future With Project traffic conditions. As the level of service at the intersection is not expected to be LOS E or F, a traffic signal would not be warranted, per LADOT Traffic Impact Study Guidelines, which provide that unsignalized intersections should be evaluated solely to determine the need for the installation of a traffic signal or other traffic control device. Only if the intersection is expected to operate at LOS E or F under Future With Project traffic conditions, would a signal warrant analysis be conducted to determine if a signal is warranted.

Comment No. A6-8

Pg 4.M-19

Because of the under-utilization of the existing Macy's store and office building, we believe that use of the ITE Rates from Trip Generation has the effect of overstating the existing trips to and from the project site, and, as a result, the analysis of the net trip generation of the Project is understated. We encourage the use of updated actual trip count surveys of the existing condition in the DEIR and traffic analyses.

Response to Comment No. A6-8

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. A6-9

Pg 4.M-35

The traffic analysis does not adequately describe the existing conditions wherein Laurel Hall School uses a portion of the Project site for both daily parking and dropoff/ pick-up operations, nor does it provide any information about the changes in traffic flow and driveway conditions that will result from the relocation of daily parking and for drop-off/pick up operations. Under long-standing existing agreements, Laurel Hall School and Emmanuel Lutheran Church have parked on this property and conducted drop-off/pick- up operations for many years.

Response to Comment No. A6-9

See Response to Comment No. A5-67 regarding the Laurel Hall School drop-off/pick-up.

Comment No. A6-10

Pg 4.M-38

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The driveway analysis (project site access) does not provide existing conditions information (either total trips or peak hour trips); there will be a significant increase in total trips on Radford Avenue due to the Project. These additional trips will interact with the existing drop-off/pick-up trips generated by the Early Childhood Center (with access only on Radford) as well as Radford trips related to Laurel Hall School. ECC and Church existing demand should be considered in the traffic analysis of Radford Avenue. The additional trips on Radford resulting from the Project should have caused the traffic study to evaluate the need for a signalized pedestrian cross-walk mid-block on Radford Avenue to provide a safe pedestrian crossing for school children passing between the ECC and LHS, and between LHS and Church. Such an evaluation is warranted by the increased traffic on Radford due to the Project, which would result in a reduction in adequate crossing gaps for children and parents.

Response to Comment No. A6-10

As shown in the Draft EIR Figures 4.M-7 and 4.M-8, the Project is expected to generate a total of 106 southbound trips along Radford Avenue in the AM peak hour and a total of 54 southbound trips in the PM peak hour. These additional volumes would add less than two cars per minute to the traffic volumes traveling southbound along Radford Avenue in the AM peak hour and approximately one car per minute in the PM peak hour. As these are low traffic volumes, the increase in traffic volumes due to the construction of the Project would not result in a significant impact.

As shown in Section 2.3 of the Traffic Study, traffic counts were conducted at the Oxnard Street & Radford Avenue intersection during a weekday on a non-holiday week when both the Laurel Hall School and the ECC were in session. Therefore, traffic volumes associated with school- and ECC-related trips that use this intersection during the peak hours were included in the baseline data collection and traffic impact analysis conducted as part of the Traffic Study.

In response to this and other comments, however, a supplemental traffic count of the daily traffic traveling along Radford Avenue between Erwin Street and Oxnard Street was conducted (see Appendix E of this Final EIR). This supplemental traffic count found that the highest total traffic volumes for both directions along Radford Avenue was 296 vehicles (7:30am – 8:30am). With the additional AM peak hour Project traffic (106 southbound vehicles), the total Future With Project traffic volume would be 402 vehicles. These volumes are well within the capacity of the roadway.

The installation of a pedestrian traffic control device is a decision that is made by the City of Los Angeles. It typically requires that traffic conditions at the location in question meet or exceed specific thresholds provided in the Manual on Uniform Traffic Control Device (MUTCD). To meet the MUTCD criteria to warrant the installation of a pedestrian traffic control device, based on the projected 402 AM peak hour vehicles on Radford Avenue between Erwin Street and Oxnard Street, the pedestrian volume crossing Radford Avenue would have to exceed approximately 650 pedestrians (see supplemental analysis provided in Appendix E of this Final EIR). Based on the size and activity levels of the school and church, it is not anticipated that the number of pedestrians will exceed the thresholds, and therefore no traffic control device is warranted.

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Comment No. A6-11

Pg 4.M-38

The driveway analysis does not appear to consider the change to driveway conditions along Oxnard or along Radford resulting from the need for relocation of the existing Laurel Hall School drop-off/pick-up traffic away from the Project site (where existing drop-off and pick-up operations are located) to one or more alternative locations.

Response to Comment No. A6-11

See Response to Comment No. A6-9.

Comment No. A6-12

Pg 4.M-60

MM-M5: Mitigation measure; SR-170 Northbound Ramps & Oxnard Street (Intersection #13). We believe that it is appropriate to study the addition of a westbound turn lane into the Project at this intersection, to facilitate the entry of westbound traffic into the Project site, and as partial mitigation for the loss of off-site drop-off/pick-up for school children at Laurel Hall School. Among the options we are evaluating for our relocated drop-off/pick-up operations is entry into our property from the driveway at Oxnard and the SR 170 ramp.

Response to Comment No. A6-12

As described in the Draft EIR at page 4.M-53, Mitigation Measure M-5 was reviewed and approved by LADOT and found to fully mitigate Project impacts in the PM peak hour at the SR-70 NB Ramp and Oxnard Street. Therefore, the proposed westbound turn lane would not be required or needed to serve the Project or mitigate Project impacts. As further described in the Draft EIR, three alternative mitigation measures for this intersection were evaluated but not selected.

The addition of an exclusive right turn lane would not serve as mitigation, but could facilitate school access. The addition of an exclusive right-turn lane here to the westbound approach of the Oxnard Street & SR-170 NB Ramps intersection would require reconfiguration of the street and a feasibility study. In addition, the on-street parking along the southern edge of Oxnard Street may have to be moved between the driveway intersection and Radford Avenue and possibly to Tiara Street. This could cause impacts to the residents who live along Oxnard Street and utilize on-street parking on a daily basis.

Comment No. A6-13

As you can see from the above summary of our concerns, there may be significant physical, operational and financial impacts upon the properties and programs of Emmanuel Lutheran Church that arise from the construction and operation of the Project that have not been fully evaluated in the Draft EIR. We believe

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that each of these areas of concern needs to be addressed in the Draft EIR, and appropriate responses be incorporated into any revisions and/or the Final EIR. The Project should be executed in a manner that reduces or eliminates any adverse impact on our properties and programs.

We should also note that our own evaluation of the potential impacts continues, and that as our own evaluation continues, our assessment of the type and extent of impact may change. We have undertaken several steps to carefully and appropriately review the Draft EIR, but we reserve the right to amend our comments above. Should we choose amend our comments, we will notify you promptly.

Thank you for the opportunity to provide these comments on the Draft EIR to the Department and the Applicant.

Response to Comment No. A6-13

Responses to each of the individual comments in this letter have been provided above. The remainder of the comment provides concluding information, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, this comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. A7

Ali Poosti, Division Manager Wastewater Engineering Services Division LA Sanitation

Comment No. A7-1

This is in response to your December 3, 2015 letter requesting a review of your proposed project located at 6150 North Laurel Canyon Blvd, and 12001 West Oxnard St, Los Angeles, CA 91606. LA Sanitation has conducted a preliminary evaluation of the potential impacts to the wastewater and storrnwater systems for the proposed project.

Response to Comment No. A7-1

This comment includes a general introduction and does not state a specific concern or question regarding the adequacy of the Draft EIR in identifying and analyzing the environmental impacts of the Project. Responses to the Bureau of Sanitation’s specific comments are provided below.

Comment No. A7-2

WASTEWATER REQUIREMENT

LA Sanitation, Wastewater Engineering Services Division (WESD) is charged with the task of evaluating the local sewer conditions and to determine if available wastewater capacity exists for future developments. The evaluation will determine cumulative sewer impacts and guide the planning process for any future sewer improvements projects needed to provide future capacity as the City grows and develops.

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Projected Wastewater Discharges for the Proposed Project:

Type Description Average Daily Flow per Proposed No. of Average Daily Flow Type Description Units (GPO) (GPO/UN IT) Existing Office Building 120 GPD/ 1000 SQ.FT 90,000 SQ.FT (10,800) Macy 's 50 GPD/ 1 000 SQ.FT 30,000 SQ.FT (1,500) Proposed Office Building 120 GPD/ 1000 SQ.FT 500,000 SQ.FT 60,000 Retail 50 GPD/1000 SQ. FT 142,513 SQ.FT 7,126 Restaurant 300 GPD/ 1000 SQ.FT 48,687 SQ.FT 14,606 Health Club (Gym) 200 GPD/1 000 SQ. FT 40,000 SQ.FT 8,000 Theater: Cinema 3/ Seat 1,750 Seat 5,250 Residential: Studio 75/ DU 119 DU 8,925 Residential: 1-BDRM 110/ DU 348 DU 38,280 Residential: 2-BDRMS 150/ DU 275 DU 41,250 Total 171,137

Response to Comment No. A7-2

The comment provides a table showing the projected wastewater discharges for the Project. The table largely matches Table 4.N.1-2 of on page 4.N.1-9 of the Draft EIR. The comment letter mistakenly calculates the existing Macy’s department store generation based on 30,000 square feet of floor area as 1,500 gpd rather than the correct generation of 23,250 gpd, which is based on the entire Macy’s building’s floor area. Thus, the net increase of the comment letter is erroneously higher than the estimate of the Draft EIR.

Despite these changes, the Hyperion Treatment Plant has adequate capacity for the Project under either calculation as described in the Bureau of Sanitation’s responses in the Draft EIR dated April 14, 2015, and May 19, 2015, and discussed in Section 4.N.1 of the Draft EIR. Accordingly, the Project would not result in significant impacts to wastewater.

Comment No. A7-3

SEWER AVAILABILITY

The sewer infrastructure in the vicinity of the proposed project includes an existing 8-inch line on Erwin St. The sewage from the 8-inch line on Erwin St feeds into a 21-inch line on Laurel Canyon Blvd before splitting into a 48-inch line on Woodbridge Stand a 48-inch line on Valley Spring Ln. Figure 1 shows the details of the sewer system within the vicinity of the project.

The current approximate flow level (d/D) and the design capacities at d/D of 50% in the sewer system are as follows:

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Pipe Diameter (in) Pipe Location Current Gauging d/D(%) 50% Design Capacity 8 Erwin St. 18 229,323 GPD 21 Laurel Canyon Blvd. 37 3.68 MGD 48 Woodbridge St. 45 17.77 MGD 48 Valley Spring Ln. 48 31.08 MGD

Based on the estimated flows, it appears the sewer system might be able to accommodate the total flow for your proposed project using only option one (1) of the two options that was mentioned in the first letter (part 1) of the Notice of Preparation of an Environmental Impact Report and Public Scoping Meeting letter. Further detailed gauging and evaluation will be needed as part of the permit process to identify a specific sewer connection point. If the public sewer has insufficient capacity then the developer will be required to build sewer lines to a point in the sewer system with sufficient capacity. A final approval for sewer capacity and connection permit will be made at that time. Ultimately, this sewage flow will be conveyed to the Hyperion Treatment Plant, which has sufficient capacity for the project.

If you have any questions, please call Kwasi Berko of my staff at (323) 342-1562.

Response to Comment No. A7-3

The comment provides a table showing the sewer availability for the Project. The table largely matches Table 4.N.1-1 of the DEIR, which was provided by the Bureau of Sanitation in their letter dated May 19, 2015 (included as Appendix K-2 of the Draft EIR). However, the text and table has been corrected and revised in Section 3, Additions and Corrections, of this Final EIR, to reflect the information contained in this comment.

The comment states that detailed gauging is necessary as part of the permit process to determine the sewer capacity. This is consistent with the sewer capacity analysis included in the Draft EIR on page 4.N.1-10, which states: “Further detailed gauging and evaluation would be needed as part of the permit process to identify specific sewer connection point. If the public sewer has insufficient capacity, then the developer would be required to build sewer lines to a point in the sewer system with sufficient capacity. The Project would also pay any required sewer connection fees.” The construction phase of the Project would need a sewer connection permit and Sewer Capacity Availability Review (SCAR) application, which is included as part of Draft EIR Regulatory Compliance Measure N.1-2. Therefore, further detailed gauging and evaluation would occur at that time.

Comment No. A7-4

STORMWATER REQUIREMENTS

LA Sanitation, Watershed Protection Division (WPD) is charged with the task of ensuring the implementation of the Municipal Stormwater Permit requirements within the City of Los Angeles. We anticipate the following requirements would apply for this project.

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POST -CONSTRUCTION MITIGATION REQUIREMENTS

The project requires implementation of stormwater mitigation measures. These requirements are based on Stormwater Low Impact Development (LID) requirements. The projects that are subject to LID are required to incorporate measures to mitigate the impact of stormwater runoff. The requirements are outlined in the guidance manual titled "Development Best Management Practices Handbook - Part B: Planning Activities". Current regulations prioritize infiltration, capture/use, and then biofiltration as the preferred stormwater control measures. The relevant documents can be found at: www.lastormwater.org. It is advised that input regarding LID requirements be received in the early phases of the project from WPD's plan-checking staff.

Response to Comment No. A7-4

The comment states that the Project requires stormwater measures based on the Standard Urban Stormwater Mitigation Plan (SUSMP) and the Low Impact Development (LID) requirements. All development and redevelopment projects that create, add, or replace 500 square feet or more of impervious area must comply with the LID Ordinance. Projects must comply with the LID Best Management Practices (BMPSs) (determined on a case by case basis by Public Works), and if not feasible, only then do SUSMP BMPs apply. As described in Section 4.N.2, Water, of the Draft EIR, the Project would comply with Regulatory Compliance Measure N.2-4 related to the LID Ordinance and Stormwater BMPs. In addition, the Project would be required to obtain a NPDES water quality permit from the LARWQCB. The Project would also receive input regarding SUSMP requirements from WPD’s plan-checking staff.

Comment No. A7-5

GREEN STREETS

The City is developing a Green Street Initiative that will require projects to implement Green Street elements in the parkway areas between the roadway and sidewalk of the public right-of-way to capture and retain stormwater and urban runoff to mitigate the impact of stormwater runoff and other environmental concerns. The goals of the Green Street elements are to improve the water quality of stormwater runoff, recharge local ground water basins, improve air quality, reduce the heat island effect of street pavement, enhance pedestrian use of sidewalks, and encourage alternate means of transportation. The Green Street elements may include infiltration systems, biofiltration swales, and permeable pavements where stormwater can be easily directed from the streets into the parkways and can be implemented in conjunction with the LID requirements.

Response to Comment No. A7-5

The comment states that the Green Streets elements may include infiltration systems, biofiltration swales, and permeable pavements where stormwater can be directed from streets and into parkways. These elements can be implemented in conjunction with the SUSMP/LID requirements. As described in Section

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4.N.2, Water, of the Draft EIR, the Project would comply with Regulatory Compliance Measure N.2-4 related to the LID Ordinance and Stormwater BMPs.

Comment No. A7-6

CONSTRUCTION REQUIREMENTS

The project is required to implement stormwater control measures during its construction phase. All projects are subject to a set of minimum control measures to lessen the impact of storm water pollution. In addition for projects that involve construction during the rainy season that is between October 1 and April 15, a Wet Weather Erosion Control Plan is required to be prepared. Also projects that disturb more than one-acre of land are subject to the California General Construction Stormwater Permit. As part of this requirement a Notice of Intent (NO I) needs to be filed with the State of California and a Storm Water Pollution Prevention Plan (SWPPP) needs to be prepared. The SWPPP must be maintained on-site during the duration of construction.

If there are questions regarding the storm water requirements, please call Kosta Kaporis at (213) 485- 0586, or WPD's plan-checking counter at (213) 482-7066. WPD's plan-checking counter can also be visited at 201 N. Figueroa, 3rct Fl, Station 18.

Response to Comment No. A7-6

The comment lists the construction requirements to implement stormwater control measures to lessen the impact of pollution. As described in Section 4.H., Hydrology and Water Quality, of the Draft EIR, the Project Applicant would be required to obtain coverage under the General Construction Activity Storm Water Permit (GCASP), which requires development and implementation of a Storm Water Pollution Prevention Plan (SWPPP).

Construction projects that include grading activities during the rainy season must also develop a Wet Weather Erosion Control Plan (WWECP). The Project will comply with LAMC Chapter IX, Division 70, which addresses grading, excavations, and fills. Compliance with the LAMC would ensure that construction would not violate any water quality standards or discharge requirements, or otherwise substantially degrade water quality. Therefore, through compliance with NPDES requirements and City grading regulations, Project impacts related to water quality during construction would be less than significant.

Comment No. A7-7

SOLID RESOURCE REQUIREMENTS

The City has a standard requirement that applies to all proposed residential developments of four or more units or where the addition of floor areas is 25 percent or more, and all other development projects where the addition of floor area is 30 percent or more. Such developments must set aside a recycling area or

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room for onsite recycling activities. For more details of this requirement, please contact Daniel Hackney of the Special Project Division at (213) 485-3684.

Response to Comment No. A7-7

The comment describes the solid resources requirements, such as a recycling area or room for onsite recycling activities. The Draft EIR includes Regulatory Compliance Measure N.3-3, which requires operational recycling, including recycling bins to be provided at appropriate locations.

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LETTER NO. 01

Desiree and Paul Levine Laurel Glenn Townhomes HOA 11848 Erwin Stret North Hollywood, CA 91606

Comment No. 01-1

We are writing to you because of our deep concern and fear of the proposed development directly across the street from our property. We as homeowners (24 years) have been promised time and time again of a rebirth of our beloved retail mall post 1994 earthquake. What was suppose to be done on the forsaken Valley Plaza section is being pushed onto our quaint and residential area. This project is not in compliance and negatively impacts our area. Too many apartments and tall buildings with minimal retail is not what we need. High traffic, congestion and noise is not what we need. We need safe, green, shopping, food etc.... Open air. Our home would be directly and visually affected by this monster. The sight and sound alone would be miserable. I am forwarding this letter to all appropriate parties. Please take our concerns on this issue seriously. It is important to satisfy the neighborhood and the potential clients and customers that may patronize this project.

Response to Comment No. 01-1

Regarding the statement that the Project is not in compliance, see Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s compliance with the North Hollywood – Valley Village Community Plan. See Response to Comment No. A5-35 for a discussion of impacts with respect to zoning.

In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

See Response to Comment No. A5-4 regarding the proposed height.

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Responses to Comment Nos. A5-37 and A5-40 regarding the Project’s noise impacts.

See Responses to Comment Nos. A5-2 through A5-13 for a discussion of the Project’s visual impacts.

Finally, see Response to Comment No. A5-46 for a discussion of Project impacts with respect to police protection services.

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The remainder of the comment provides the commenter’s opinions about the Project, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. 02

Kat Curry

Comment No. 02-1

I will be revising my comments below. You may put them in with the EIR Revised comments:

I fail to understand why Mr. Krekorian's highest priority is disrupting my peaceful neighborhood with this unreasonable over‐development. Let's not pretend that the current EIR is an honest study of the impact of this project on the surrounding environment. It completely ignores the fact that it sits on a liquefaction zone. It is full of flat out lies, such as the bogus math that 10000 people a day already go in and out of the Macy's. That's patently ridiculous and you know it. It doesn't include even a half‐hearted attempt to do a traffic study. With that many people coming off the 170 and trying to take a left onto Radford north of Oxnard, this project will cause so much congestion at the Oxnard exit that people will be backed up for miles on the 170, spewing ever more toxins and anger into the air. I tried to do it myself the other day at 6 PM and and it was a miserable experience and there aren't hundreds of other people trying to do it at about the same time.

Response to Comment No. 02-1

See Response to Comment No. A5-24 regarding the Project’s impact with respect to liquefaction.

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the Project’s impacts to freeway ramps. The mitigation measure proposed at the intersection of SR-170 Northbound Ramps & Oxnard Street (Draft EIR Mitigation Measure M-5) fully mitigates the Project’s impact at this location.

In addition, the Draft EIR was prepared under the direction of and reflects the independent judgment of the City of Los Angeles Department of City Planning.

Finally, the Project’s impacts with respect to mobile source emissions are addressed on Draft EIR pages 4.C-14 through 4.C-16. As discussed therein, Project impacts would be less than significant.

Comment No. 02-2

I saw nothing in the EIR that addressed the additional infrastructure and public service needs. It does not give me any confidence that this developer is going to abide by actual laws that exist and will build something unsuitable and dangerous.

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Response to Comment No. 02-2

Project impacts with respect to public services (fire, police, schools, parks, and libraries) were analyzed in Draft EIR Sections 4.L.1 through 4.L.5. As discussed in those sections, with implementation of the Mitigation Measures, Regulatory Compliance Measures, and Project Design Features outlined on pages 4.L.1-18 through 4.L.1-20, 4.L.2-15 to 4.L.2-16, 4.L.3-13 to 4.L.3-14, and 4.L.5-10 of the Draft EIR, impacts to all public services would be less than significant.

Project impacts with respect to utilities (wastewater, water, solid waste, electricity, and natural gas) were analyzed in Draft EIR Sections 4.N.1 through 4.N.4. As discussed in those sections, with implementation of Mitigation Measures, Regulatory Compliance Measures, and Project Design Features outlined on pages 4.N.1-12 to 4.N.1-13, 4.N.2-18 to 4.N.2-19, 4.N.3-18 to 4.N.3-19, and 4.N.4-22 to 4.N.4-23 of the Draft EIR, impacts to all utilities would be less than significant.

Comment No. 02-3

If this plan isn't accompanied by a really clever traffic solution, the effects on air quality and carbon emissions will be exacerbated. The ostensible force behind this new passion for density is *supposed* to be able solving traffic and climate problems. Be real, the 742 units full of people are not taking public transportation to their jobs, and most of them won't live and work in this development. That's pure wishful thinking and/or propaganda.

Response to Comment No. 02-3

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Project impacts with respect to air quality and greenhouse gas emissions are analyzed in Sections 4.C. and 4.F. of the Draft EIR, respectively. As discussed in those sections, all Project impacts with respect to air quality and greenhouse gas emissions would be less than significant.

Comment No. 02-4

Perhaps y'all truly believe the developer will create something awesome that will rival NoHo Arts district. What makes NoHo so successful is in large part, the access by train, which NoHoWest will not have. This project and the traffic nightmare attending it, will make the area surrounding it an undesirable place to live.

Response to Comment No. 02-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

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Comment No. 02-5

The wanton destruction of actual neighborhoods in this administration, without regard to zoning and traffic and quality of life, throughout the Valley, is simply deplorable. If you want a great cautionary tale of the perils of untrammeled development without regard to the environment, and the people impacted, read up on William Mulholland and the disaster of the St Francis Dam.

I fail to understand why Mr.Krekorian's highest priority is disrupting my peaceful neighborhood with this travesty. Why on earth would anyone, let alone the 1000+ people you plan to move into this neighborhood if not for it's quiet? Certainly not because of that awesomely quaint stretch of Laurel Canyon/Erwin that just sits there pathetically unused? And the nasty park full of some of the most hopeless‐looking homeless people I have ever seen in my life? Honestly, what young, hip people with money in their pockets are going to want to live next to that? People move here to know and respect their neighbors and you propose a couple thousand people a day MORE will move in and out of this neighborhood for shopping and drinking and movies and generally not giving a crap about my neighborhood as they race through it. I would love to hear how this ISN'T my worst nightmare. How do you answer to that?

Response to Comment No. 02-5

The comment provides the commenter’s opinions about the Project, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 02-6

And seriously, 742 new residential units and no traffic mitigation? Even HALF that would be a bit much. Is this some sort of horrid joke?

Response to Comment No. 02-6

Mitigation measures have been provided to address the Project’s traffic impacts (Draft EIR Mitigation Measures M-1 through M-7). As discussed in Response to Comment No. A5-42, implementation of these measures would mitigate the Project’s impacts at all but the following two intersections, where impacts would be partially mitigated:

 Intersection #11: Laurel Canyon Boulevard & Oxnard Street, during the AM and PM peak hours.

 Intersection #20: Lankershim Boulevard & Oxnard Street, during the AM peak hour only.

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restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 02-7

So, maybe you think you'll create something awesome that will rival NoHo Arts district. But I would wager that NoHo West proceeding at a similar time frame to all the construction around Chandler and Lankershim will virtually guarantee that all of the higher priced renters and economic interest will go over there. Higher quality stores will not want to set up shop at NoHoWest because the people who live in that monster you just build won't be able to afford to shop there. What makes NoHo so successful is in large part, the access by train, which NoHoWest will not.

The only reason I can think of that this is Mr. Krekorian's highest priority is that it advances his personal interests and career. Just another career politician trampling over other humans who are less wealthy and less connected.

Response to Comment No. 02-7

The comment provides the commenter’s opinions about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. 03

Amy Ryder 6031 Simpson Avenue North Hollywood, CA 91606

Comment No. 03-1

An unprecedented population density backed up by a false and outdated DEIR cannot be allowed to take place on the proposed NOHO West Laurel Plaza site.

Every politician, city planner and builder needs to take a good hard look in the mirror as they spout the lies they are currently serving up to the tightly knit, quiet, single family community of Laurel Plaza.

It takes some kind of crazy nerve for you to use outdated EIR traffic information that was not even done during high traffic hours. You have an out of touch thought process to think that it’s even feasible to shove a population density into this neighborhood that is so high and does not exist anywhere in Los Angeles.

Response to Comment No. 03-1

The comment provides opinions about the Project, as well as general statements about population, traffic, and the date of data used in the EIR. Responses to specific comments regarding these issues are provided in Response to Comment Nos. 3-4 and 3-6, below. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 03-2

The lack of water alone is enough to put an end to this project.

Response to Comment No. 03-2

See Responses to Comment Nos. A5-83, A5-84, and A5-86 regarding the Project’s water demand.

Comment No. 03-3

We can point out each and every inaccuracy in the current DEIR but all you will do to address it is to say, “duly noted”. That is pathetic.

Response to Comment No. 03-3

The comment does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinion is

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acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 03-4

The developer got a very good deal on this piece of property. They have the money to do a proper and accurate independent report based on real time data instead of false and misleading information.

Is there any one of you reading this letter that would allow a project of such a scale to end up in your own back yard? Please give us the same consideration.

Commission a current 2016 EIR (not from 2012) that is honest and accurate and includes the following:

A traffic study done during high volume traffic time. The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are indeed unavoidable, then obviously the scope of the project needs to be reduced.

Response to Comment No. 03-4

The portion of the comment regarding the price paid for the property does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

The analysis contained in the Draft EIR contains current information that was compiled and prepared in conjunction with the City of Los Angeles Department of City Planning specifically for this Project, and the Draft EIR reflects the independent judgment of the City of Los Angeles Department of City Planning.

In addition, the Traffic Study is dated November 2015 and was prepared using the ITE 9th Edition (2012), which is the most current edition for trip generation estimates. Data collection for the Traffic Study was taken during peak traffic times and the estimates for Project-generated traffic are based on peak AM and peak PM hours. As discussed in Response to Comment No. A5-50, data collection for all study intersections was conducted on a weekday during a non-holiday week when schools are in session. See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Finally, regarding transit use, as discussed in Response to Comment No. A3-3, to ensure a conservative analysis, the Traffic Study did not include a reduction in Project-related vehicle trips due to residents, patrons, or tenants using transit to travel to/from the Project Site. In addition, a new Project Design Feature has been added to the Final EIR (see PDF M-10 in Section 3, Additions and Corrections) which reiterates the Project’s incorporation of Transportation Demand Management (TDM) strategies into the Project.

Comment No. 03-5

Please provide the DOT with the correct number of parking spaces required to comply with the City code.

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Response to Comment No. 03-5

See Response to Comment No. A5-81 regarding the number of parking spaces required for the Project, as well as the number of spaces that would be provided.

Comment No. 03-6

Reduce the living population to reflect the single-family residential population that has been here, some for over 100 years (those homes can apply as historic landmarks).

Response to Comment No. 03-6

The comment requests a reduction in population. Partly in response to comments received on the Draft EIR, the Project Applicant is considering changes to the Project. Therefore, an analysis of Alternative 4B has been added to this Final EIR, which analyzes a reduction in residential units, and therefore also a reduction in population, when compared to the Project. As discussed in the Alternative 4B analysis (see Section 3, Additions and Corrections, of this Final EIR), Alternative 4B would generate approximately 1,638 residents, which is a reduction compared to the 1,848 residents generated by the Project.

Comment No. 03-7

Increase the amount of parking on site.

Response to Comment No. 03-7

See Response to Comment No. A5-81 regarding the Project's parking supply.

Comment No. 03-8

Increase the amount of public space

Response to Comment No. 03-8

See Response to Comment No. A5-4 regarding the proposed amount of outdoor public space.

Comment No. 03-9

Reduce the commercial building height to 45 feet and the residential and commercial buildings along Erwin and Radford to not exceed 3 stories.

Response to Comment No. 03-9

See Response to Comment No. A5-4 regarding the proposed height.

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Comment No. 03-10

Please go back to the drawing board and provide us with an alternative plan that reflects fewer residential units integrated with commercial units spread over the entire site.

Thank you for your prompt attention to this very important matter.

Response to Comment No. 03-10

See Response to Comment No. A5-4 for a discussion of Alternative 4B, which has been added to this Final EIR (see Section 3, Additions and Corrections) partly in response to comments received on the Draft EIR. Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

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LETTER NO. 04

Ron Bitzer 6245 Gentry Avenue North Hollywood, CA 91606

Comment No. 04-1

Thank you for the opportunity to submit community comments about traffic and transportation issues for the mega-development — NoHo West in North Hollywood.

Please refer to the attachment.

I will address Other issues before the February 12, 2016 deadline for comments.

Response to Comment No. 04-1

The comment provides general introductory information and references traffic comments, for which responses are provided in Responses to Comment Nos. 4-5 through 4-29, below.

Comment No. 04-2

One stated strategy of the NoHo West Project is to create a customer base for the commercial tenants (gym, restaurant, etc.) by developing a NoHo West tenant base (1848 residents) who will enjoy a "mixed- use" lifestyle, (Draft EIR, p. 4M-49).

Mixed-use development is appropriate for aging shopping centers. "The weak bricks and mortar shopping climate is forcing landlords to think outside the big box ... some owners are converting struggling malls into apartments, office and industrial space ... " Wall Street Journal, November 27, 2015 (emphasis added). Such proposed mixed-use development such as NoHo West should not look to the past (using outdated, dubious or incomplete studies as explained below) but should plan for the future (as promoted by the City's chief sustainability officer). Matt Petersen, chief sustainability officer, City of Los Angeles, has said developers can anticipate future solutions and create efficient buildings from the start instead of waiting for a crisis (States News Service, March 12, 2015).

Response to Comment No. 04-2

The comment provides general information about mixed-use projects, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

Comment No. 04-3

Summary

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At the time of the release of a recirculated draft EIR or the release of a final EIR, whichever comes first, I request the following:

• --- Public release on the City Planning website of the Los Angeles Department of Transportation 13- page assessment dealing solely with projected traffic issues for the NoHo West mixed-use project sent to Bob Duenas, Senior City Planner, Department of City Planning, on November 19, 2015.

Response to Comment No. 04-3

The LADOT assessment letter was available on the City’s website on approximately January 19, 2016, and is available for public download and review. The public comment period for the Draft EIR was extended to February 26, 2016, to allow for ample time to review the Draft EIR and revised appendix information.

Comment No. 04-4

Installation of poles and horizontally-placed demarcation to show accurately---the height and breadth of the proposed Project to include all buildings and parking structures with the exception of Macy's. This request is not an unusual request in urban planning.

Response to Comment No. 04-4

See Response to Comment No. A5-4 regarding the height of the Project. The commenter’s request for story poles and demarcation is acknowledged for the record.

Comment No. 04-5

OPPORTUNITIES TO PROMOTE SEVERAL MODES OF TRANSPORTATION—Planning for all modes of travel should be more developed in the Final EIR in view of (a) the mixed used project bringing a large number of residents to a densely developed project, (b) a public transportation hub at the METRO Red & Orange Lines in North Hollywood and (c) Councilmember Paul Krekorian's commitment to public transportation- evidenced by his 2015 vote in favor of a public bus line from the Red Line in North Hollywood to Pasadena. In lieu of such planning, the impact of the Project on private vehicular traffic must be scrutinized even more.

Response to Comment No. 04-5

The Project will promote walking and the use of bicycles for internal trips to reduce number of overall vehicle trips through the inclusion of ample bike racks, walking paths, and connections between the residential and commercial buildings. To ensure a conservative analysis, the Traffic Study did not include a reduction in Project-related vehicle trips due to residents, patrons, or tenants using transit to travel to/from the Project Site. In addition, a new Project Design Feature has been added to the Final EIR (see PDF M-10 in Section 3, Additions and Corrections) which reiterates the Project’s incorporation of Transportation Demand Management (TDM) strategies into the Project.

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Comment No. 04-6

OXNARD STREET TRAFFIC .... The preparer of the Final EIR should reconsider the density of the Project and respond to the City traffic assessment, which reported a "significant and unavoidable" "partially-mitigated impact" on Oxnard Street traffic intersections by the proposed Project, ("Traffic Study Assessment for the Proposed NoHo West Mixed Use Project," LA Department of Transportation, p.2). This means a "Level of Service" at category F will exist during weekday peak hours at Oxnard Street and Laurel Canyon Blvd. LOS F, as defined in the Draft EIR, "represents jammed conditions. Backups from locations downstream or the cross street may restrict or prevent movement of vehicles out of intersections .. " (Traffic Study, p. 13). More than 50 percent of Project inbound and outbound traffic will use Oxnard Street.

Response to Comment No. 04-6

The comment is the same as Comment No. A5-74. Therefore, see Response to Comment No. A5-74.

Comment No. 04-7

FREEWAY TRAFFIC .... The preparer of the Final EIR should conduct revised studies of the environmental impact of the Project on adjacent freeway segments (SR-170) and off-ramps in consultation with the State Caltrans. The City of Los Angeles and the State Department of Transportation (Caltrans) often fail to consult on freeway segment and on and off-ramp traffic studies. The lack of consultation with Caltrans is evidenced in the Draft EIR. NOTE: The City Mobility Plan 2035 states, "Where possible and feasible, the City will work with Caltrans to contribute to State highway improvements that directly contribute to ... the City's General Plan," (Mobility Plan 2035 adopted August 11, 2015 by City Council, p. 90}.

Response to Comment No. 04-7

See Response to Comment No. A5-52.

Comment No. 04-8

A MAJOR PROJECT AT VALLEY PLAZA ADJACENT TO NOHO WEST .... The "unavoidable" impact of the Project on traffic and other environmental degradations should be reported in the context of a related project at Valley Plaza, which will add density to the immediate neighborhood, as reported in the Draft EIR (Appendix J, Figure 3.1). The Draft EIR raises concurrent construction of Valley Plaza as a possibility--- thereby increasing adverse environmental impact by both projects (p. 4c-17). The Final EIR should provide more details about this Valley Plaza related project, where real property is already owned by developers of NoHo West.

Response to Comment No. 04-8

See Response to Comment No. A5-43 regarding development at the Valley Plaza property.

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Comment No. 04-9

Comment Section

• GAPS IN THE PUBLIC RECORD ----A Caltrans request dated May 1, 2015 has been ignored and a 30- page Caltrans study of the adjacent freeway, SR-170, published in June 2015 is missing from the Draft EIR. District 7 of Caltrans provided "Minimum Contents of Traffic Impact Study Report," a 4 page letter to lead agency Department of City Planning, City of Los Angeles, May 1, 2015. See Attachment A. While the Draft EIR briefly mentions a Caltrans letter on page 4.M-37, it concentrates on data in Appendix E to conclude that vehicular trip thresholds leading to further study of freeway segments and off-ramps were not met (p. 4.M-38).

Response to Comment No. 04-9

The referenced May 1, 2015 letter (“Minimum Contents of Traffic Study Impact Report”) is from Caltrans’ guidelines for traffic studies when Caltrans is the lead agency. The City of Los Angeles is the lead agency for this Project, thus the City’s guidelines, as well as the applicable MOU between LADOT and Caltrans, were followed in preparing the Traffic Study. In addition, the Caltrans letter dated May 1, 2015, outlines the process that should be followed if it is determined that additional traffic analyses are necessary for the freeway system. The Draft EIR and Traffic Study documented the results of the evaluation of thresholds for freeway segments and ramps against thresholds established by the CMP, LADOT and Caltrans and showed none were met. LADOT, as the lead agency’s experts, reviewed the methodology and results of the threshold checks and deemed them complete and accurate. Therefore, it was determined that the Traffic Study does not need to include any additional freeway analyses. For these reasons, additional traffic analyses procedures that were identified in the May 1, 2015, letter are not applicable.

See also Response to Comment No. A5-52.

Comment No. 04-10

A better working relationship between Caltrans and the City of Los Angeles has been promoted by City Councilman Mike Bonin, who asked at a City Council meeting reviewing a final EIR " ... what sort of procedures we can put into place to establish a better working relationship with Caltrans so they can get fed into the process sooner, July 24, 2013.

Response to Comment No. 04-10

See Response to Comment No. A5-52 regarding the MOU between LADOT and Caltrans. In addition, as discussed in Response to Comment No. A5-52, the City consulted properly with Caltrans. Caltrans was provided both the Notice of Preparation and the Notice of Availability of the Draft EIR, and provided comments on both.

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Comment No. 04-11

A. GAPS & ASSUMPTIONS IN THE FREEWAY TRAFFIC STUDIES

The traffic study does not fully analyze the traffic impacts that the Project will contribute to the State Highway System and US-101. The DEIR asserts that the Project's additional trips---- as determined in a screening test---- fail to trigger a traffic study done in cooperation with Caltrans (p. 4M-38}.

Response to Comment No. 04-11

See Response to Comment No. A5-52 regarding the Project’s less than significant impacts to the freeway system.

Comment No. 04-12

The traffic study employs the following assumption about additional traffic---7,720 more trips per weekday--- attributed to the Project upon completion (page 4M-20):

Assumption #1---The planned demise of Macy's department store alone reduces daily trips by 8,511 and therefore are subtracted from the weekday trips of the Project (Table 4-M4). This adjustment to reduce the traffic impact is unwarranted because it is not based on onsite trip counts but rather on ”Gross Building Area” --a national formula rather than site-specific counts.

Response to Comment No. 04-12

The number of daily trips expected to be generated by the Project is 7,270 trips, not 7,720 trips, as stated in the comment. In addition, see Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 04-13

Assumption #2 ---In contrast to the Final EIR of the Community redevelopment Agency for laurel (and Victory) Plaza in 2009, the Draft EIR spreads trips more evenly over four directions--- thereby influencing the number of trips north and south, including freeway trips. A State highway, SR-170, and major streets direct trips north and south; the November 19, 2015 LADOT assessment letter does not address either Assumption #1 or #2 about the volume of trips to be generated by this Project.

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Assumption #2

2009 EIR Laurel 2015 DEIR Plaza Table Laurel Plaza IV M-7 Appendix J, Page31 Percentage of Trips NORTH 27% 30% Percentage of Trips SOUTH 37% 20% Subtotal 64% 50% Percentage of Trips EAST 19% 20% Percentage of Trips WEST 17% 30%

Response to Comment No. 04-13

This comment is the same as Comment No. A5-73. Therefore, see Response to Comment No. A5-73.

Comment No. 04-14

• Analysis of the Impact of the Project on Freeway Segment Congestion is Inadequate

Both the adjacent SR-170 Freeway and the nearby US-101 Freeway are heavily congested freeways. SR- 170 ---The Draft EIR does not utilize the June 2015 published Caltrans report for the congestion on SR- 170, for example

Peak Hours Peak Hours Caltrans Draft EIR (Attachment B) June 2015 December 2015 Level of Service is E Level of Service AM Hour is C or D (5 or 6 segments) PM Hour is C or D (all)

SR-170 " ... currently operates at LOS (Level of Service) E during the period of peak congestion," "Transportation Concept Report Route 170," Caltrans, June 2015, p. 22. Caltrans defines LOSE "operations at or near capacity and an extremely unstable flow ... " "Transportation Concept Report Route 170," Caltrans, June 2015, p. 29.

Response to Comment No. 04-14

See Response to Comment No. A5-52 regarding the Project’s less than significant impacts to the freeway system and applicability of the referenced 2015 Caltrans Transportation Concept Report.

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Comment No. 04-15

Response to Comment No. 04-15

See Response to Comment No. A5-52 regarding the Project’s less than significant impacts to the freeway system and applicability of the referenced 2015 Caltrans Transportation Concept Report. As discussed therein, the improvements identified in the referenced 2015 Transportation Concept Report are very preliminary in nature and must undergo further detailed review by Caltrans before they are considered as “pending” or approved improvements that could affect the Project.

Comment No. 04-16

US-101---The US-101 freeway at Laurel Canyon is reported to be the 7th most congested freeway segment in the US with an estimate annual total travel delay of 3,600,000 hours ("Unclogging America's Arteries," 2015, p. 16).

Response to Comment No. 04-16

The referenced segment of US-101 freeway is located approximately 1.75 miles from the Project Site, and, as discussed in Response to Comment No. A5-52, the freeway threshold check conducted for freeway mainline segments showed that the thresholds requiring additional analysis were not met.

Comment No. 04-17

The monitoring data (aside from the 2012 Caltrans data described above) employed in the traffic study to determine the impact of Project traffic on freeway congestion was obtained at "some distance" from the Project, namely 2.0 and 3.3 miles away, (pp. 4M-29 & 4M-36-37).The Draft EIR concludes this freeway "screening" analysis did not meet any of four thresholds for additional freeway analysis; Caltrans should review these findings.

Response to Comment No. 04-17

See Response to Comment No. A5-52 regarding the Project’s less than significant impacts to the freeway system and Caltrans’ review.

Comment No. 04-18

Missing Off-Ramps ---Developers consultant identified for screening three freeway off-ramps from SR- 170 omitting (1) the northbound off-ramp at Victory Blvd. (where the only nearby full-access freeway ramps exist) and (2) the northbound and southbound off-ramps at Burbank Blvd. (page 4.M-37 and p. 2,

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May 1, 2015 Caltrans letter to Department of City Planning.) Studies of these offramps should be included in the Final EIR.

Response to Comment No. 04-18

See Response to Comment No. A5-42 regarding the northbound off-ramps from the 170 freeway.

Comment No. 04-19

Special Circumstances of Oxnard Street Off-Ramp (Northbound SR-170) ---The northbound Oxnard Street off-ramp traffic is controlled by a signal (Attachment C).

The May 1, 2015 Caltrans letter refers to the October 2013 “Freeway Impact Analysis Procedures" established by the City and Caltrans to screen freeway segments and off-ramps for further traffic study. The Draft EIR employs an off-ramp allowance of 1,500 vehicles per hour per lane in that agreement (Appendix E, Table E-3 of Appendix J) and concludes that the threshold for further study of this off-ramp has not been met following a November 20, 2014 traffic count.

In the May 1, 2015 communication Caltrans explained the impact of a signal at the off-ramp, such as the one which operates at the northbound off-ramp of SR-170 at Oxnard Street.

However, if the study locations have traffic controls such as a signal or a stop sign, then the actual capacity and Level of Service (LOS) need to be determined by Highway Capacity Manual first before screening can be used.... Co/trans has concerns about queuing of vehicles using oft- ramps that will back into mainline through lanes. Dianna Watson, CEQA Branch Chief District 7, Department of Transportation, May 1, 2015 letter to Department of City Planning (Attachment A)

Setting aside the complication of a signal at this off-ramp, the Draft EIR and the November 19, 2015 Los Angeles Department of Transportation assessment of the traffic study alone substantiate the need for a revised analysis of the impact of Project trips on this off-ramp during peak hours.

Response to Comment No. 04-19

See Responses to Comment Nos. A5-52 and A5-75.

Comment No. 04-20

1. Oxnard Street--- according to the Draft EIR ---serves as a major route to and from the Project, the vehicular traffic of which will have significant, unavoidable and only partially-mitigated impact on Oxnard Street, "Traffic Study Assessment for the Proposed NoHo West Mixed Use Project (ENV- 2015- 888-EIR)," LA Department of Transportation, November 19, 2015, p. 2 and Attachment D "Future with Project Levels of Service," Appendix J, Figure 4.6.

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Response to Comment No. 04-20

See Response to Comment No. A5-75.

Comment No. 04-21

2.Traffic Study Comparisons of Future Off-Ramp Trips during Peak Hours With / Without Project--- This study reports no net increase from the Project in future trips exiting SR-170 at the northbound off-ramp at Oxnard Street in the PM peak hour and turning west or east. The Project will generate a net increase of merely 19 trips per peak in the PM hour traveling northbound into the Project.

Nevertheless, the Draft EIR states that " ... the Project would result in significant impacts at the following six intersections in the PM peak hour ... SR-170 NB ramps & Oxnard Street LOS D," p. 4.M-49. Would not consultation with Caltrans help to resolve this confusion?

Number of Peak PM Hour Trips Northbound Off-Ramp of SR-170 at Oxnard Street A Significant Impact?

Future Without Project Future With Project Figure 3-3 Appendix J Figure 4-5 Appendix J Turn West 783 783 Turn East 207 207 Travel North 59 78

Response to Comment No. 04-21

See Response to Comment No. A5-75.

Comment No. 04-22

C. DRIVEWAY I RESIDENTIAL STREET I PARKING

However, at East Oxnard Street current driveway, the two lanes in each direction now measure a total road width of 40 feet--- 20 feet less than the 60 feet required by the LA Department of Transportation. "All driveways should be Case 2 driveways and 30 feet wide and 16 feet wide for two-way and one-way operations," "Traffic Study Assessment for the Proposed NoHo West Mixed Use Project (ENV-2015- 888-EIR)," LADOT, November 19, 2015, p. 6.

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Response to Comment No. 04-22

This comment is the same as Comment No. A5-77. Therefore, please see Response to Comment No. A5- 77.

Comment No. 04-23

RESIDENTIAL STREET---- The Draft EIR analyzed 23 traffic intersections (Attachment D ---Figure 4.6) that " ... were identified as locations where the majority of trips associated with this Project would be focused based on the trip distribution developed for the Project," "Traffic Study" p.7. The trip distribution formula may or may not be reasonable for this Project, as stated above.

Response to Comment No. 04-23

See Response to Comment No. A5-73, above, regarding trip distribution for the Project.

Comment No. 04-24

The Draft EIR reports either 7 (p. 2-4) or 9 (p. 4-J-'8 & Table 4M-8) related projects generating vehicular traffic (Attachment E). Notably, this published report estimates 450 apartments and 300,000 sf of commercial space to be developed at Valley Plaza. A logical and necessary request is to expand the traffic intersections to be analyzed in view of projected trips to be generated by a related mega- development less than 800 feet from the Project. For example, the traffic study could benefit from study of existing and future trips at the following:

• Intersection of Radford & Erwin (northwest corner of the Project) ----The 2009 Final EIR for Laurel Plaza redevelopment did study this intersection (Attachment E ----Figure IV.M-1).

Response to Comment No. 04-24

See Response to Comment No. A5-79.

Comment No. 04-25

PARKING--- "The traffic study did not indicate the total number of parking spaces to be provided to satisfy code requirements. The applicant should check with the Department of Building and Safety on the number of code-required parking spaces needed for this project," "Traffic Study Assessment for the Proposed NoHo West Mixed Use Project (ENV-2015-888-EIR)," LADOT, November 19, 2015, p. 6

Response to Comment No. 04-25

See Response to Comment No. A5-81 regarding the number of parking spaces that would be included as part of the Project.

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Comment No. 04-26

D. ALTERNATIVE TRAVEL CHOICES IN THE PROJECT/ REGION

"The mix of uses within the Project will lead to an interaction between these uses and trips that will walk or use bicycles and therefore not make a car trip," (p. 4.M-49). The Draft EIR Site Circulation Plan does not provide for bicycle paths (Figure 3-7 and Attachment F). The private roads of the Project may ignore the State Complete Street Act; the Final EIR should then explain in more detail how travel by bicycle will work inside the Project.

Response to Comment No. 04-26

This comment is the same as Comment No. A5-78. Therefore, please see Response to Comment No. A5- 78.

Comment No. 04-27

Transportation Demand and Management Program--- Planning for all modes of travel should be obvious in view of the major public transportation hub at the METRO Red Line in North Hollywood and the likely development of commercial and residential space at Valley Plaza -less than 800 feet from the Project.

Response to Comment No. 04-27

This comment is the same as Comment No. A5-80. Therefore, please see Response to Comment No. A5- 80.

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LETTER NO. 05

Eric Mintz

Comment No. 05-1

We are long time homeowners in the Laurel Grove neighborhood, one block from the proposed NoHo West Project. While, we are excited about the prospects of the project, we also have some concerns. First, the 742 planned residential units are somewhat concerning. Has any study been done that such a large scale residential project is necessary in this area? What will be added to assist in the increase in traffic that will occur? Second, and very importantly, the parking on the residential streets located in Laurel Grove on Agnes, Ben, Gentry need to be changed for permit parking only on peak hours. Already, a number of businesses use our neighborhood as a parking lot, which makes it difficult for the actual homeowners to park. We should not have to subsidize these businesses with parking. The businesses should have to pay for parking for their employees. The city is losing tax revenue because of this, and it is falling on the homeowners who already pay taxes. These employees and businesses do not pay anything for parking. And, if no permit parking is put in, this problem will only get worse with all of these new businesses moving in with the planned project. This is an absolute necessity in order to prevent the neighborhoods from becoming parking lots. It is very dangerous for us because while residents are trying to get to their cars and get their kids to school‐‐ employees of these businesses are driving through our streets looking for parking. If you want this to be a successful project, you need to maintain the value of the homeowners in the area and permit parking for residents is a key feature. Visit Beverly Hills or Westwood or other high end communities where there is commercial and residential and you will find that permit parking keeps the neighborhoods safe and maintains the integrity of the neighborhood. We lived a few blocks from the Grove in Los Angeles when that neighborhood was being transformed and the residential areas near their had permit parking to retain their character and not impact the neighborhood with employees and patrons using their neighborhood as a parking lot. This is an absolute necessity if this project is going to succeed and transform this area. This is the largest underdeveloped area in the East Valley and if it is going to be a project that kicks off the transformation of this area and increases the tax base, it needs to be done in a way that maintains the property values and encourages home ownership by creating safe neighborhoods that are not just parking lots for neighboring businesses. The businesses must not be allowed to use our neighborhood as a parking lot and escape paying for such needs and avoid paying taxes.

Response to Comment No. 05-1

See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR.

The Project’s traffic impacts are analyzed in Section 4.M. of the Draft EIR and in the accompanying Traffic Study (Appendix J of the Draft EIR). Mitigation Measures M-1 through M-9 have been provided to reduce the Project’s traffic impacts, although impacts would still be considered significant at two

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intersections. See Response to Comment No. A5-42 for additional information about the Project’s traffic impacts.

In addition, the Project’s parking demand and proposed supply are discussed in Response to Comment No. A5-81. As the Project would provide ample parking for its uses, overflow parking into the surrounding neighborhood is not anticipated.

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LETTER NO. 06

Nick Abdo 6057 Morella Ave North Hollywood, CA 91602

Comment No. 06-1

In May 2015 and in response to the Initial Study for the proposed NoHo West (Laurel Plaza) Project, many neighbors to the project wrote to you that, as envisioned, it is inconsistent with the North Hollywood Valley Village Community Plan. We asked that the project be altered to agree with the Plan's objective "that the low-density residential character of North Hollywood -Valley Village be preserved and that single - family neighborhoods be protected from encroachment by other types of uses." The preferred project as analyzed in the Draft Environmental Impact Report (DEIR) fails to meet this request. We request a significant reduction in the number of apartments.

Response to Comment No. 06-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan. Regarding the request for a reduction in the number of residential units, partly in response to comments received requesting such a reduction, the Project Applicant has requested that the City consider Alternative 4B. See Response to Comment No. A5-4, which discusses Alternative 4B and its reduction in units when compared to the Project.

Comment No. 06-2

We also requested that a true mixed-use development with retail on the ground floor and residential above with all new commercial and residential buildings built to a height of no more than 45 feet, except that along Erwin Street and Radford Avenue adjacent to the existing residential new structures be limited to three stories no higher than 36 feet. The 5 Alternatives presented in the DEIR do not address our request. The DEIR provides for an All Commercial Alternative (2A) which has a total floor space of 517,000 that is less than the currently existing 555,000 sq. ft. of floor space at the Laurel Plaza site. It is clear that the DEIR did not take our requests for a true mixed use development, an all commercial development and height restriction requests seriously. We request that the final project should adhere to the height requirements given here and that the Final EIR include the true mixed-use development alternative we requested.

Response to Comment No. 06-2

Regarding the placement of the Project's residential and commercial components, please see Response to Comment No. A5-4.

Regarding the height of the Project, please also see Response to Comment No. A5-4.

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In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced density project, which includes less office use, fewer residential units and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 06-3

We neighbors of Laurel Plaza know without a doubt that the traffic study's assumption of present, weekday vehicle trips to and from the Macy's store of 10,639 is unrealistic. At best the current weekday vehicle trips to Macy's to and from are no more than 500 customers per day. Other cherry-picked traffic assumptions, including failure to use the most current June 2015 Caltrans study of the 170 freeway are similarly unsupportable. The Department of Planning needs to request that both the City Department of Transportation and Caltrans review the DEIR traffic study. The apartment development as proposed and sited will inevitably cause commuters to seek alternatives within the adjacent residential streets to avoid the already congested Oxnard Street. The traffic study in the DEIR did not address increased traffic flow along Radford Ave and Erwin Street, it only evaluated Oxnard St and Laurel Canyon Blvd. We request that the Final EIR include a traffic study along Radford Avenue and Erwin Street. We request that the study also include neighboring residential streets and intersections between Victory Blvd, Colfax Ave, Laurel Canyon Blvd and Burbank Blvd during peak hours. The DEIR listed the influx of traffic as significant and unavoidable, providing no real solutions to the significant increase in traffic that this project will bring.

Response to Comment No. 06-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports. In addition, Caltrans was provided with the NOP and Notice of Availability of the Draft EIR, and provided comments in response to both. Caltrans’ NOP comment letter is attached as Appendix C to the Draft EIR, and responses to Caltrans’ Draft EIR comment letter are provided in Comment Letter No. A1, as part of this Final EIR.

Regarding the intersection of Radford Avenue & Erwin Street, this intersection is unsignalized and therefore not included in the impact analysis of signalized intersections conducted in the Traffic Study according to LADOT Traffic Impact Study Guidelines. An unsignalized intersection is studied under different criteria to determine if traffic volumes warrant signalization. A supplemental analysis of the Radford Avenue & Erwin Street intersection has been conducted and this supplemental analysis determined that the intersection currently operates at LOS A during both the AM and PM peak hours (the supplemental analysis is included as Appendix E to this Final EIR). The analysis also determined that the intersection is expected to operate at LOS A in both the AM and PM peak hours under Future With Project traffic conditions. As the level of service at the intersection is not expected to be LOS E or F, a

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traffic signal would not be warranted. (Per LADOT Traffic Impact Study Guidelines, unsignalized intersections should be evaluated solely to determine the need for the installation of a traffic signal or other traffic control device. If the intersection is expected to operate at LOS E or F under Future With Project traffic conditions then a signal may be warranted but a warrant analysis should be considered).

Regarding the potential for traffic to cut through residential streets, a majority of the streets located in close proximity to the Project Site are non-continuous streets due in large part to the location and borders of the Project itself. The local streets to the immediate north of the Project (Agnes Avenue, Ben Avenue and Gentry Avenue) are physically separated from the Project Site by an existing raised median located along Erwin Street. As such, vehicle traffic using these streets cannot access the Project Site and would therefore not provide any time-savings or connectivity above that afforded by Radford Avenue or Laurel Canyon Boulevard. The local streets to the immediate east of the Project (Carpenter Avenue, Morella Avenue and Simpson Avenue) do not provide direct access to the Project Site, as they are all oriented in a north-south direction. Again, these streets would not provide any time-savings or increased connectivity that is not available from Radford Avenue. Calvert Street is a local street located east of the Project Site and north of Oxnard Street. This street is also physically separated from the Project by an existing raised median prohibiting direct access into the Project Site. As vehicles entering the Project would be required to travel either north along Radford Avenue to Erwin Street or south to Oxnard Street to gain access, the use of Calvert Street does not provide any time-savings above that provided by Oxnard Street.

Finally, the Draft EIR does conclude that impacts would be significant and unavoidable at two intersections which can only be partially mitigated; the impacts to the remaining intersections impacted would be less than significant with implementation of the mitigation measures provided in the Draft EIR.

Comment No. 06-4

The DEIR makes unsupportable assumptions about present water and sewage usage at Laurel Plaza. A new assessment needs to be performed using easily obtained historical data from the Department of Water and Power, rather than the square footage of a less than fully used Macy's building.

Response to Comment No. 06-4

See Responses to Comment Nos. A5-83 through A5-86 regarding water and sewage estimates for the existing uses.

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LETTER NO. 07

Christina Garberson 6024 Carpenter Avenue North Hollywood, CA 91606

Comment No. 07-1

Let me preface this letter letting you know that I am excited about the Laurel Plaza project I am just NOT excited about the present plan being put forward. There are huge issues that must be addressed before I and a majority of this neighborhood can fully support this project. Please let me tell you what I think needs to be addressed.

Response to Comment No. 07-1

The comment provides general statements about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 07-2

#1 - There are simply too many apartments in an extremely condensed area in the present proposal. Are you aware that if this present layout went forward this would be the largest apartment complex in the entire San Fernando valley. Plopped right into a large single family, primarily one story neighborhood. That alone should give you pause.

Response to Comment No. 07-2

Regarding the number of residential units contained in the Project, see Response to Comment No. A5-4.

Comment No. 07-3

#2 - The height of these proposed buildings are just too obtrusive to the 99% single family homes that already make up this neighborhood. These will stick out like a sore thumb and alter the 75 year old landscape this area was built around.

Response to Comment No. 07-3

See Response to Comment No. A5-4 regarding the height of the Project and Response to Comment No. A5-2 regarding the scale of the Project with the neighboring single-family homes.

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Comment No. 07-4

#3 - In regards to the Draft EIR completed on this project there are many, many issues either not addressed or addressed incorrectly. a. the traffic study was only completed on Oxnard and Laurel Canyon. Radford Avenue and Erwin Street are going to be greatly effected by an additional 742 plus cars in this one block radius. The report must be extended to include these streets or else the report is a lie.

Response to Comment No. 07-4

See Response to Comment No. 6-3 regarding potential impacts to Radford Avenue & Erwin Street.

Comment No. 07-5 b. the traffic study also presents a number of 10,639 trips already going into the Macy's lot in one day. That is 100% inaccurate. That might me one week at Christmas time but never one regular work day. The count I would estimate is more like 500 or less. Please make sure this is properly addressed

Response to Comment No. 07-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 07-6 c. the EIR states "that many of the traffic issues are significant and unavoidable" if that is the case then at least try to address this with either reducing the amount of the living area and spread the living area throughout, (i.e. mixed-use) so the massive concentration of it is not in one small corner.

Response to Comment No. 07-6

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including the impacts of Alternative 4B, which has been added to this Final EIR and is a reduced project which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Regarding the location of the residential units within the Project Site, see Response to Comment No. A5-4.

Comment No. 07-7 d. no where in the Draft EIR does it state how many parking spaces they will be including. The streets and neighborhoods around this area do not have the infrastructure to accommodate extra parking for residents and their guests. The street I live on, Carpenter Avenue does not even have sidewalks so resident parking may not even be an option for us.

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Response to Comment No. 07-7

See Response to Comment No. A5-81 regarding the number of parking spaces that would be included as part of the Project. As the Project would provide ample parking for its uses, overflow parking into the surrounding neighborhood is not anticipated.

Comment No. 07-8 e. the project is not even close to being consistent with the North Hollywood-Valley Village community plan. The plan specifically specifies that the low-density residential character of North Hollywood should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses. Are you just throwing this community plan out the window or did someone rewrite it without us being told.

Response to Comment No. 07-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 07-9

Please understand that I will support a project at Laurel Plaza that takes the needs and interest of the existing neighborhood into consideration NOT just the bottom line dollar this Development company is going to make.

Lastly please note that every single apartment, ALL 742 proposed are going to be rentals. I understand that there is no option on this issue, but please understand that those 742+ occupants are not going to be here for 2 or 5 or even 10 years when we, the resident homeowners of this area have to choose our next elected officials. We will remember who helped us and who did not.

We chose to live here, we chose to buy our houses, we pay our property taxes because we like the area and the neighborhoods please help us to continue to love living in Laurel Grove.

Response to Comment No. 07-9

The comment contains opinions about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. 08

Annabelle Whettam 12358 Sylvan Street North Hollywood, CA 91606

Comment No. 08-1

I am writing to beg you to consider the following problems before this project is allowed to continue.

1) Traffic study is inaccurate. I have lived here since 1972, and 1 exit the freeway going north every weekday at 6 p.m. at Oxnard. There is no way that the exit there can handle the traffic that is proposed for this site.

Response to Comment No. 08-1

See Response to Comment No. A5-52 regarding the Oxnard Street exit from the 170 freeway north.

Comment No. 08-2

2) The number of parking spaces is NOT sufficient for the number of apartments and public transportation is lacking in that area. Cars will be parked on all the neighborhood streets.

Response to Comment No. 08-2

See Response to Comment No. A5-81 regarding the Project’s demand for parking as well as the proposed supply. As the Project would provide ample parking for its uses, overflow parking into the surrounding neighborhood is not anticipated.

Comment No. 08-3

3) In all the years I have been here, including when there was a full enclosed mall including an ice skating rink, there were never 10,639 vehicles traveling into and out of that mall.

Response to Comment No. 08-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 08-4

Please do a current live traffic study before this is permitted.

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Response to Comment No. 08-4

See Responses to Comment Nos. A5-50 and A5-70 regarding the parameters under which the Traffic Study was prepared.

Comment No. 08-5

1) The number of apartments and the six story height of the buildings are too much for the quiet residential neighborhood.

2) REDUCE THE NUMBER OF APARTMENTS.

Response to Comment No. 08-5

See Response to Comment No. A5-4 regarding the height of the Project.

Comment No. 08-6

3) The types of businesses are questionable too. There are already two gyms within a few blocks, and two movie theaters close by.

Response to Comment No. 08-6

The comment provides the commenter’s opinion about the proposed commercial uses, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinion is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 08-7

I think this is enough to show you that things need to change. Please protect the citizens of the Laurelgrove area of North Hollywood.

Response to Comment No. 08-7

The comment provides the commenter’s opinion, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

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LETTER NO. 09

Patricia Lorenz 6204 Morella Ave North Hollywood, CA 911606

Comment No. 09-1

On Wednesday, January 27th, I attended a neighbourhood meeting which dealt in large part with the current development proposal for what is being call "NoHo West". None of the concerns that I listed below appear to have been addressed by the developer or the city - it appears to be exactly the same plan that was presented last year.

Thanks to our very effective association president and board members and their efforts to understand the impact of the proposed development, an number of questions and concerns have arisen. When can we expect to see someone actually take our concerns into account and address them in a public forum?

Response to Comment No. 09-1

The comment provides general introductory information and notes that the commenter has specific concerns, which are addressed in Responses to Comment Nos. 9-2 through 9-4, below. The comment does not state any specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 09-2

First and foremost is the impact of the significant additional traffic in our neighbourhood (see below) - We need an actual traffic study not only of Laurel Canyon and Oxnard, but the interior streets as well (particularly Erwin and Radford) - the 10,000 plus trips extrapolated from the size of the Macy's building has absolutely no basis in current reality. Anyone that lives in the neighbourhood would be able to tell you that. How can the draft EIR state that many of the traffic issues are "significant and unavoidable" and not have the people reviewing this project insist that the scope of the project be substantially reduced?

Response to Comment No. 09-2

Regarding the Radford Avenue & Erwin Street intersection, please see Response to Comment No. 6-3.

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-42 regarding the Project’s significant and unavoidable traffic impacts, as well as the reduction of some of those impacts based on potential changes to the Project.

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Comment No. 09-3

Secondly, what benefit does this project as planned provide for the neighbourhood and the east end of the Valley? We need and want commercial development - what other spaces of this size are available in the east valley? The proposed plan seems to concentrate on high density rental units and office space. A huge opportunity is being lost with a large sacrifice being asked of the residents in the area.

Response to Comment No. 09-3

The comment provides the commenter’s opinion about what should be developed at the Project Site, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration. In addition, in response to comments received on the Draft EIR, the Project Applicant is considering changes to reduce the size of the Project, including fewer residential units, less office space, and more retail/restaurant space. See Response to Comment No. A5-4 for additional information regarding these potential changes.

Comment No. 09-4

We want this property developed! However, it must be in a responsible way that meet the needs of the East Valley and is in keeping with the North Hollywood - Valley Village Community Plan and does not destroy a lovely neighbourhood of single family homes.

Response to Comment No. 09-4

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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LETTER NO. 10

Jill Marx-Peuker 6234 Morella Avenue North Hollywood, CA 91606

Comment No. 10-1

I attended the Laurel Grove Neighborhood Association meeting last Wednesday, 1/27/16 to review the draft DEIR submitted to the LGNA board.

Diane Corral outlined all the details.

Many of the people at this meeting were very concerned about the lack of response from the developer about the number of apartments compared to the mixed use that is proposed for this project.

My husband and I have been residents of this area for 32 years and we are very worried about the impact on our neighborhood.

Following are our immediate concerns

Response to Comment No. 10-1

The comment provides general introductory information but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Regarding the number of apartments proposed, see also Response to Comment No. A5-4.

Comment No. 10-2

1) The Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial. We request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail space.

Response to Comment No. 10-2

See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR. See also Response to Comment No. A5-4 regarding the placement of the residential uses on the Project Site.

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Comment No. 10-3

2) We request that the residential/commercial buildings for the proposed final Project not exceed 45’ feet in height. Residential and/or commercial buildings along Erwin Street and Radford Ave should not exceed 3 stories.

Response to Comment No. 10-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 10-4

3) We request that the traffic study in the Final EIR address the traffic flow along Redford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project’s 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 10-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

As shown in Table 4.M-7 of the Draft EIR, the Traffic Study includes an operational analysis of all Project driveways. In addition, as shown in Tables 4.M-11 and 4.M-12 of the Draft EIR, the Traffic Study includes an operational analysis at the intersections of Radford Avenue & Victory Boulevard and Radford Avenue & Oxnard Street. The results indicated that all driveway locations are expected to operate at LOS D or better, and both intersections were shown to currently operate at LOS A and are expected to continue to operate at LOS A with the construction of the Project.

Comment No. 10-5

4) We, the neighbors of Laurel Plaza, know without a doubt that the traffic study’s assumption of weekday vehicle trips to and from Macy’s store of 10,639 is unrealistic. This Macy’s is old and rundown and, at best, current weekday vehicle trips to and from this Macy’s location is no more than 500 customers per day. We suggest contacting this Macy’s location and getting their daily customers counts. We additionally request that a traffic study be conducted using realistic assumptions and the the latest June 2015 Cal Trans report on the 170 Freeway be used instead of the 2012 Cal Trans report which was used in the Draft EIR

Response to Comment No. 10-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

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See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 10-6

5) The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are indeed unavoidable then the scope of the project needs to be re scaled to accommodate traffic issues. We request that the Final EIR mitigate the traffic issues and/or reduce the residential scope of the project to address significant traffic issues described in the Draft EIR.

Response to Comment No. 10-6

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including the reduced impacts of Alternative 4B, which has been added to this Final EIR.

Comment No. 10-7

6) The Department of Transportation (DOT) report says the Draft EIR did not indicate the total number of parking spaces required to comply with the City code. We request that the DOT be provided with the number of parking spaces required to comply with the City code.

Response to Comment No. 10-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 10-8

7) The Project is not consistent with the North Hollywood - Valley Village Community Plan. The Plan specifies that the low density residential character of North Hollywood - Valley Village should be preserved and that single family residential neighborhoods be protected from encroachment by other types of uses (i.e. a densely populated apartment “city” with 742 units).

Response to Comment No. 10-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 10-9

Thank you in advance for your prompt attention to all of the above mentioned concerns. We look forward to the Final DEIR incorporating our requests.

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Response to Comment No. 10-9

The comment provides general concluding statements, which are acknowledged for the record.

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LETTER NO. 11

Johann-Peuker 6234 Morella Avenue North Hollywood, CA 91606

Comment No. 11-1

I attended the Laurel Grove Neighborhood Association meeting last Wednesday, 1/27/16 to review the draft DEIR submitted to the LGNA board.

Diane Corral outlined all the details.

Many of the people at this meeting were very concerned about the lack of response from the developer about the number of apartments compared to the mixed use that is proposed for this project.

My husband and I have been residents of this area for 32 years and we are very worried about the impact on our neighborhood.

Following are our immediate concerns

Response to Comment No. 11-1

Comment No. 11-2

Response to Comment No. 11-2

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Comment No. 11-3

Response to Comment No. 11-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 11-4

Response to Comment No. 11-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Comment No. 11-5

Response to Comment No. 11-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

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See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 11-6

Response to Comment No. 11-6

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the reduced impacts of Alternative 4B, which has been added to this Final EIR.

Comment No. 11-7

Response to Comment No. 11-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 11-8

7) The Project is not consistent with the North Hollywood Valley Village Community Plan. The Plan specifies that the low density residential character of North Hollywood Valley Village should be preserved and that single family residential neighborhoods be protected from encroachment by other types of uses (i.e. a densely populated apartment “city” with 742 units). Attached is a map of the proposed structures. PLEASE REVIEW AT YOUR EARLIEST CONVENIENCE.

Response to Comment No. 11-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 11-9

Thank you in advance for your prompt attention to all of the above mentioned concerns. We look forward to the Final DEIR incorporating our requests.

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Response to Comment No. 11-9

The comment provides general concluding statements, which are acknowledged for the record.

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LETTER NO. 12

Steven Heller

Comment No. 12-1

Attached please find my signed and dated letter explaining my position on the proposed project for the Laurel Canyon Blvd area of North Hollywood which, in my opinion, will adversely affect our community with increased traffic, population density, and as explained in this letter, an assortment of other issues.

It is my sincere hope that you will take the time to consider my position and take the necessary steps to reconsider how this valuable real estate will be more beneficially developed for the good of the entire North Hollywood community.

Response to Comment No. 12-1

The comment provides introductory information and references a signed form letter, which is included as Comment Letter No. Y9. For responses to the form letter, see Responses to Comment Letter No. Y1.

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Responses to Comment Nos. A5-41 through A5-44 regarding the Project’s population increase.

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LETTER NO. 13

Jeffrey Wilkins 6156 Simpson Ave. North Hollywood, CA 91606

Comment No. 13-1

This letter is intended to express my concern regarding The New Laurel Plaza Development Plans.

First and foremost, I AM NOT IN FAVOR OF THIS PLAN. If there is any way I can protest this development, please let me know whom to contact.

Response to Comment No. 13-1

The comment provides a statement of opposition to the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 13-2

Some of my concerns are as follows:

1. I trust by adding 1,300 parking spaces and well over 700 units to a small high density area…. the vehicular movement will overload the community. I had purchased in this neighborhood because of the quaint, quiet single‐family homes to be able to get away from the congestion of the heavy volume of traffic in the LA area.

Response to Comment No. 13-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, as well as the reduction of some of those impacts based on potential changes to the Project.

Comment No. 13-3

2. I can only surmise that by the heavy increase, not only in moving vehicles, but foot traffic can only lead to safety issues, crime issues, and an overall influx of what this community was originally designed for.

Response to Comment No. 13-3

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

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Comment No. 13-4

3. The overflow and increase of this project will also lead to frustration, and added time for this community to an already heavy commute they face

Response to Comment No. 13-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Comment No. 13-5

4. I’m concerned that with the addition of low income rental units, will lead to more of a chance of burglaries, drug traffic, and gang activity.

Response to Comment No. 13-5

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

Comment No. 13-6

What the area needs is a park or more open space for the community, who work and live here in the neighborhood.

There are additional points of interest that I would like to address, at a later date, if given an opportunity.

Response to Comment No. 13-6

See Responses to Comment Nos. A5-4 and A5-48 regarding the open space and public space in the Project.

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City of Los Angeles June 2016

LETTER NO. 14

Sam Ameen 5966 Graciosa Dr. Los Angeles, CA 90068

Comment No. 14-1

This letter is intended to express my concern regarding The New Laurel Plaza Development Plans.

First and foremost, I AM NOT IN FAVOR OF THIS PLAN. If there is any way I can protest this development, please let me know whom to contact.

Response to Comment No. 14-1

The comment provides general introductory information and an opinion about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 14-2

Some of my concerns are as follows:

Response to Comment No. 14-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, as well as the reduction of some of those impacts based on Alternative 4B.

Comment No. 14-3

Response to Comment No. 14-3

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

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Comment No. 14-4

3. The overflow and increase of this project will also lead to frustration, and added time for this community to an already heavy commute they face

Response to Comment No. 14-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Comment No. 14-5

4. I’m concerned that with the addition of low income rental units, will lead to more of a chance of burglaries, drug traffic, and gang activity.

Response to Comment No. 14-5

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

Comment No. 14-6

What the area needs is a park or more open space for the community, who work and live here in the neighborhood.

There are additional points of interest that I would like to address, at a later date, if given an opportunity.

Response to Comment No. 14-6

See Responses to Comment Nos. A5-4 and A5-48 regarding the open space and public space in the Project.

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City of Los Angeles June 2016

LETTER NO. 15

Evan and Melissa Gwynne 5730 Gentry Ave Valley Village, CA 91607

Comment No. 15-1

The Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial. We request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail space.

Response to Comment No. 15-1

See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR.

Comment No. 15-2

We request that the residential/commercial buildings for the proposed final Project not exceed 45’ feet in height. Residential and/or commercial buildings along Erwin Street and Radford Avenue should not exceed 3 stories.

Response to Comment No. 15-2

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 15-3

We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 15-3

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at the Project driveways, see Response to Comment No. 10-4.

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Comment No. 15-4

Response to Comment No. 15-4

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 15-5

The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are in deed unavoidable then the scope of the project needs to be reduced. We request that the Final EIR mitigate the traffic issues and/or reduce the residential scope of the project to address the significant traffic issues described in the Draft EIR.

Response to Comment No. 15-5

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the reduced impacts of Alternative 4B, which has been added to this Final EIR. Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. See also Response to Comment No. A5-4 for additional specifics regarding Alternative 4B.

Comment No. 15-6

The Department of Transportation (DOT) report says the Draft EIR did not indicate the total number of parking spaces required to comply with the City code. We request that the DOT be provided with the number of parking spaces required to comply with the City code.

Response to Comment No. 15-6

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 15-7

The Project is not consistent with the North Hollywood - Valley Village Community Plan. The Plan specifies that the low‐density residential character of North Hollywood ‐ Valley Village should be

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preserved and that single‐family residential neighborhoods be protected from encroachment by other types of uses.

Response to Comment No. 15-7

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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City of Los Angeles June 2016

LETTER NO. 16

Phillip Baer

Comment No. 16-1

As life-long residents of North Hollywood, and presently the Laurel Grove Neighborhood, we are alarmed by the proposed redevelopment of the Macy property at Oxnard Blvd. and Laurel Canyon Blvd. The plan in its present form weighs heavily towards dense residential versus commercial development. As we are sure you are aware, we already live near a large expanse of abandoned commercial space west of Laurel Canyon Blvd., thanks to previously- unrealized proposals by Snyder Corp. The present plans for the Macy property allot a pathetic 300,000 sq. ft. for commercial purposes, tucked behind behemoth of SIX-STORY apartment blocks. How is the existing community served by this soi distant redevelopment, other than by a loss of open space, an increase in traffic a (subject insufficiently addressed by the proponents of this project), and a continued degradation of our community by the failure to attract businesses that current residents would unquestionably patronize? This project is not consistent with the North Hollywood-Valley Village Community Plan, which specifies a low-density residential community. We have patiently participated in several iterations of planning for the redevelopment of the Laurel Plaza and Macy properties. Please pay attention to our needs, as residents and constituents.

Response to Comment No. 16-1

Partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

See also Response to Comment No. A5-4 regarding the proposed height of the Project.

See Responses to Comment Nos. A5-4 and A5-48 regarding the public space and open space proposed as part of the Project.

See Response to Comment No. A5-42 regarding the traffic impacts of the Project, and Response to Comment No. A5-50 for the parameters under which the traffic study was prepared.

Finally, see Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

The remainder of the comment provides the commenter’s opinions of the Project, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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City of Los Angeles June 2016

LETTER NO. 17

David Oberg

Comment No. 17-1

I'm writing in earnest to ask you to consider your actions regarding the development of the property in North Hollywood currently occupied by Macys and the nearby properties along Laurel Canyon. (No Ho West (Laurel Plaza) Project. case#ENV-2015-888-EIR

For years the neighbors in the surrounding area have been looking forward to a mixed use area that would both enhance the immediate area and would enhance the quality of life in all of North Hollywood. One all of Los Angeles could enjoy and be proud of.

Please don't lose the window to build something which will serve the people, enrich the area and elevate the city. All should realize the uniqueness of this and the adjacent property along Laurel Canyon Blvd. and understand that this is an opportunity to build a legacy, in a way that will serve the people, not just the developers and contractors.

Response to Comment No. 17-1

The comment provides general statements of opinion about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 17-2

What is being proposed is more like the failed high density housing projects of the 60's and 70's and have the potential to destroy the surrounding area. Too many people packed too close together. I realize the Mayor's office is eager to build more housing in LA. This proposal is the wrong direction.

The draft EIR illuminates the disparity between this proposed project and the Valley Village Community Plan. This is an area of low-density single family homes. That should be protected from encroachment.

The construction of high rise apartments is a poor choice here. High density is a poor choice here. People don't want to live in projects, surrounding neighbors don't want to live near future tenements.

Response to Comment No. 17-2

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan as well as its compatibility with the surrounding single- family homes.

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The remainder of the comment provides the commenter’s opinions about the density of the Project, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 17-3

Buildings here should be no higher than 3 stories. There places better suited for high density, closer to transit, better able to accommodate the huge increase in additional traffic.

Response to Comment No. 17-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 17-4

This high density and traffic need further evaluation. We request that a traffic study be conducted using the latest June 2015 Caltrans report on the 170 Freeway be used, instead of the 2012 Cal Trans report which was used in the Draft EIR

Response to Comment No. 17-4

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 17-5

The draft EIR also states that many of the traffic issues are significant and unavoidable! If they are significant and unavoidable then the scope of the project needs to be reduced. The Final EIR needs to address and mitigate the traffic issues and/or reduce the residential scope of the project to address the significant traffic issues described in the Draft EIR.

Response to Comment No. 17-5

Comment No. 17-6

We request that the DOT be provided with the number of parking spaces required in order to comply with the City code.

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Response to Comment No. 17-6

See Response to Comment No. A5-81 regarding the number of parking spaces required for the Project, as well as the number of spaces that would be provided.

Comment No. 17-7

Response to Comment No. 17-7

See Response to Comment No. 6-3 regarding the Radford Avenue & Erwin Street intersection as well as other residential streets.

Comment No. 17-8

Again, this Project is not consistent with the North Hollywood - Valley Village Community Plan. We welcome development, but please give this more consideration.

Response to Comment No. 17-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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LETTER NO. 18

Kathleen Schwartz 6556 Ethel Avenue North Hollywood, CA 91606

Comment No. 18-1

My name is Kathleen Schwartz and I am a neighbor living next to the immediate community that will be affected by the massive development proposed by Case # ENV-2015-888-EIR (NoHo West Project).

The developers are asking for a zone change to accommodate their over-development of the site. And what do you think their motives are: for the benefit of the neighborhood or for profit?

If the developers build what the property is zoned for, there would be no residential units at all. The developers are looking for entitlements that do not come with the site. Recall, Laurel Plaza was a Mall before the 1994 earthquake. Our current retail options now are Sherman Oaks, Burbank or Glendale. I myself drive to Glendale because in addition to needed retail, North Hollywood in this area has no restaurants except for a plethora of fast-food options and Sizzler.

Response to Comment No. 18-1

The comment is mistaken because residential uses are consistent with the existing C4 zoning that applies to a large portion of the Project Site. See Response to Comment No. A5-35 for an additional discussion of the Project Site’s zoning.

The remainder of the comment provides the commenter’s opinions, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 18-2

I am not against additional housing. The City of Los Angles needs more affordable housing, senior housing and senior LGBT housing. I do not support unreasonably massive housing. These 742 units are not near the Red or Orange lines. The folks living in these 742 units will generate a tremendous amount of traffic. Two of the buildings would be three stories tall and then go up to five or six stories. Can you imagine having something like that in your front or back yard if you live on Erwin or Radford?

I grew up in The Fairfax District. Park La Brea is not next to single-family homes. It runs between 3rd (commercial) and 6th (apartments) and Ogden (commercial and a school) and Alta Vista (apartments). There are traffic issues, and now bumper-to-bumper traffic, particularly after The Grove (retail) was built. The footprint of Park La Brea is much larger than Laurel Canyon to Radford, Erwin to Oxnard. No Ho West sits on 24.75 acres. Park La Brea has 4,255 units on 160 acres. Using that ratio, No Ho West would

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need 27.9 acres and only housing, or the residential would need to be reduced to 658 units with nothing else.

Response to Comment No. 18-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including reductions to these impacts as a result of potential changes to the Project.

See Response to Comment No. A5-4 regarding the proposed height and Responses to Comment Nos. A5- 2 and A5-3 regarding visual impacts related to the Project.

The remainder of the comment provides a comparison to Park La Brea, which is acknowledged for the record, but does not state a specific question or concern regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

Comment No. 18-3

No Ho West, with its proposed residential, retail and business square footage and height, and lack of parking and dedicated green space is way too large for this location and inappropriate for this neighborhood.

Response to Comment No. 18-3

As discussed above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Alternative 4B also includes additional park area. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

In addition, see also Responses to Comment Nos. A5-4 and A5-48 regarding the proposed open space.

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LETTER NO. 19

Jennifer Shields

Comment No. 19-1

I live at the 6000 block of Simpson Ave. I'm extremely concerned about the number and height of the apartments. I'd like to see more homeownership rather than rentals. People who own take better care of their neighborhood. Please have condos for sale.

Response to Comment No. 19-1

Regarding the height of the Project, please see Response to Comment No. A5-4.

Regarding the number of residential units, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

The commenter’s request for homeownership in the Project is acknowledged for the record.

Comment No. 19-2

I'm also concerned with the look of the development. I hope it doesn't look like a stucco mini mall that you'd find in Valencia CA. I hope it resembles The Grove or The Americana.

Response to Comment No. 19-2

Project plans and renderings that depict the style of the Project are provided in Draft EIR Figures 3-1 through 3-13.

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City of Los Angeles June 2016

LETTER NO. 20

Kristine Koehler

Comment No. 20-1

As a life long resident on Laurelgrove in North Hollywood I wish to voice my opinions about the development at Laurel Plaza. Obviously, I know it has been purchased and there will be changes on that site. However, the proposed development is far beyond anything that this bedroom community can support.

Response to Comment No. 20-1

Partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded as part of the Final EIR to the decision-making bodies for their review and consideration.

Comment No. 20-2

1. The Draft EIR seems to have glossed over the traffic issues both as they are presently and as they would be significantly increased after their project. If they are counting cars in the Macy's parking lot, then since they own the property they should know that 90% of those cars are overflow that a dealership has parked there, I assume with the permission of the property owner. They aren't moving in and out at all. Their estimate of 10,639 vehicle trips currently to and from Macys is ludicris. I would request that they use the latest June 2015 Caltrans report on the 170 Freeway.

Response to Comment No. 20-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding use of the 2015 Caltrans report.

Comment No. 20-3

2. This neighborhood is overwhelmingly single family homes. The addition of apartments to six stories would be far in excess of the North Hollywood ‐ Valley Village Community Plan. There should be a

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reduction in the number of apartments to accommodate the limit to three stories or less for residential building.

Response to Comment No. 20-3

As stated above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project.

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 20-4

3. The Draft EIR does not indicate the total number of parking spaces required to comply with City code. The Department of Transportation should be provided with figures for parking that are adequate. And if they cannot provide adequate parking that is another reason they should be required to reduce the number of apartment units.

Response to Comment No. 20-4

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed. As discussed therein, the amount of parking proposed would be sufficient to accommodate the proposed uses.

Comment No. 20-5

4. The developer has not in any way addressed the reasonable concerns of the local residents. There is a consensus that what this neighborhood is in need of is good retail space. With the loss of Valley Plaza, we are in desperate need of useful retail space. We have always maintained that a Mixed Use Plan for this property would be acceptable. But that means a substantial reduction in the number of residential units and that they be integrated within the commercial space.

Response to Comment No. 20-5

As stated above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project.

Regarding the placement of the residential and commercial uses within the Project, see Response to Comment No. A5-4.

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Comment No. 20-6

5. Does the Draft EIR have data to back up the addition of 500,000 square feet of office space on the property? That would seem to be tens of thousands more than this area could support. Unless they can show that all the office space within a short distance is near capacity, then 500,000 square feet is overkill.

Response to Comment No. 20-6

It is beyond the scope of an EIR to analyze the marketability of a proposed project. The EIR analyzes the environmental impacts of Project alternatives that include office space ranging from 90,000 square feet (Alternatives 1 and 3) up to 500,000 square feet (Project). As discussed above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use (approximately 189,000 square feet), fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 20-7

6. Having survived a few earthquakes in the decades I've lived here, I remember the skating rink and shopping mall that was part of the May Company (now Macys) property. I know that we are on a riverbed. Any reference to earthquake rating in the Draft EIR must be in error if they are not acknowledging that fact and the fact that an entire shopping mall collapsed in a previous earthquake. There is data to show that their earthquake information is incorrect.

Response to Comment No. 20-7

See Responses to Comment Nos. A5-23 through A5-26 regarding the Project’s impacts with respect to seismic hazards.

Comment No. 20-8

7.We are not a community set around a Metro or major bus route. This is NOT NoHo Station with it's masses of apartments for Subway riders. This is a neighborhood of Single Family Homes and cannot support vehicle traffic for the number of residents that would be moving in and out of the Laurel Plaza property. Any future EIR should include a detailed traffic flow study for the intersection of Radford and Erwin onto which three of the six project's driveways will empty. There is a school a block north at Victory and Radford as well as the school right there at Oxnard and Radford. The morning and afternoon congestion would be dangerous for children being dropped off and picked up. These are things that haven't been addressed to my knowledge.

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Response to Comment No. 20-8

As stated on page 4.M-8 of the Draft EIR, the Project Site is in close proximity to existing bus lines, including Metro lines 230, 224, 165, 164, 152/153, and 154. Therefore, alternatives to driving individual vehicles are available for Project residents, employees, and visitors. The Project also encourages bicycle use through the provision of ample bike parking and linkages between the project’s residential and commercial components.

See Response to Comment No. A5-42 for a general discussion of the Project’s traffic impacts.

See Response to Comment No. 6-3 regarding the impacts at Radford Avenue & Erwin Street.

In addition, in order to minimize impacts to nearby public and private schools, Mitigation Measure M-8 requires construction activities to be coordinated with both Laurel Hall School and Victory Boulevard Elementary School. Further, as stated on Draft EIR page 4.M-36, the Project Applicant is actively working with the Laurel Hall School to help develop a new drop-off and pick-up plan.

Comment No. 20-9

8. Finally, I have nothing but sympathy for those home owners at or near the intersection of Radford and Erwin. I live on Laurelgrove off of Oxnard and know that at certain times of day you just don't try and drive out onto Oxnard. The traffic is lined up to Whitsett and farther some times waiting to get on the freeway. If the construction that is moving north on Whitsett blocks the intersection like it did at Magnolia, we will be trapped in our homes. Any development at Laurel Plaza must realistically address the traffic issues that will increase exponentially. I don't have any idea how they will be able to mitigate that huge problem, but it must be part of the report. Just noting that it would be "significant and unavoidable" is not a solution, merely an observation. We who have lived here long before Macys and even the 170 Freeway along with those that have chosen to live here even now, can not be expected to just accept the coming Armageddon that 740 apartments and their 1500 to 2000 or more residents will bring.

Response to Comment No. 20-9

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street.

See also Response to Comment No. A5-42 regarding the Project’s traffic impacts.

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LETTER NO. 21

Joel Robbins 6235 Gentry Ave North Hollywood, CA 91606

Comment No. 21-1

I was excited! I was looking forward to the return of one of our two shopping centers in North Hollywood. Then I read the EIR, and found some major concerns.

Response to Comment No. 21-1

The comment provides general opinions about the EIR, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 21-2

First, the large number and density of the apartments is not consistent with the North Hollywood‐Valley Village Community Plan. This would be the largest and most dense apartment project in the entire San Fernando Valley, and is not compatible with our area of single‐family homes. The proposed height of the buildings is likewise not consistent with the existing neighborhood.

Response to Comment No. 21-2

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Please also see Response to Comment No. A5-4 regarding the proposed height and the compatibility with the neighboring single-family homes.

Comment No. 21-3

Second, traffic mitigation is a concern. The EIR did not use the most recently available traffic information, and therefore the conclusions based on this information are invalid. It is unrealistic to expect that a new shopping center would generate no more traffic than an existing 60‐year‐old single store. Traffic leading in to the new apartments was not addressed at all.

Response to Comment No. 21-3

See Responses to Comment Nos. A5-50 and A5-70 regarding the parameters under which the traffic study was prepared.

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See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. 10-4 regarding the Project driveways.

Comment No. 21-4

The demise of our shopping centers began in 1994, with the Northridge earthquake. We have been waiting over 20 years to get our shopping back. The Laurel Plaza site, and the nearby Valley Plaza site, represent two of the larger parcels in the Valley that can accommodate shopping. This provides an opportunity to return a once thriving district, and return the commercial sales‐tax base to the residents of Los Angeles.

Response to Comment No. 21-4

Comment No. 21-5

While I recognize the need for new housing in the Valley, the current project, as proposed, does not meet the needs of anyone except the developer. Our community needs, and deserves, a project with less housing, more commercial space, and an EIR which uses realistic data to address the effect of any project on our neighborhood.

Do the right thing.

Response to Comment No. 21-5

Partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more restaurant/retail uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

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LETTER NO. 22

Jane Macfie 6248 Simpson Ave North Hollywood, CA 91606

Comment No. 22-1

My name is Jane Macfie, and I am a homeowner on Simpson Ave. in the Laurel Grove neighborhood of North Hollywood. I am very concerned about the proposed impact of the high density housing proposed in the DEIR for Laurel Plaza.

Response to Comment No. 22-1

The comment provides the commenter’s opinion about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 22-2

1. The traffic impact on Erwin Street, a small residential street, is not being considered. We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 22-2

See Response to Comment No. 6-3 regarding potential impacts to Radford Avenue & Erwin Street and other residential streets.

Comment No. 22-3

2. The study makes a very inaccurate assumption about the traffic flow to and from Macy' s currently. Macy's is very underused, and there are not even close to 10,639 vehicle trips to and from it a month. We

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request that a traffic study be conducted using realistic assumptions, and that the latest June 2015 Caltrans report on the 170 Freeway be used, instead of the 2012 Cal Trans report which was used in the Draft EIR.

Response to Comment No. 22-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 22-4

3. Significant and unavoidable traffic issues don't cut it for those of us who live here. The housing would nearly double the human density of our neighborhood, which has currently 762 residents, while the new plan proposes an additional 7 42 apartments.

Response to Comment No. 22-4

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the reduced impacts of Alternative 4B, which has been added to this Final EIR and is a reduced project which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

Comment No. 22-5

4. The DEIR is not a description of a mixed-use project. It is a description of a housing project. Our blighted neighborhood needs more businesses that are active and thriving far more than it needs 742 more housing units. The Project is not consistent with the North Hollywood- Valley Village Community Plan. The Plan specifies that the low-density residential character of North Hollywood- Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses.

Response to Comment No. 22-5

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan, and Response to Comment A5-4 regarding potential changes to the Project based on comments received on the Draft EIR.

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LETTER NO. 23

Suzanne Stinson 6218 Gentry Ave North Hollywood, CA 91606

Comment No. 23-1

This letter is in response to the Draft EIR for the NO HO West project, Case Number ENV 2015 888 EIR and State Clearinghouse Number 2015041001.

In reviewing this document I find that it is filled with so many inaccuracies and untruths I hardly know where to begin. The clear overriding conclusion one cannot help but form from reading this document, is that the developer cares nothing for the wishes of the people that this development will directly affect – we the people that live in the surrounding neighborhood. None of the following items we requested of the developer were included in this draft plan. These include but are not limited to:

Response to Comment No. 23-1

The comment provides general introductory information and also opinions of the commenter, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 23-2

An alternative plan showing and incorporating a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial. Although there were five alternatives presented, it was immediately clear that not more than five minutes of thought was given to any of the alternatives, and there was no mixed use shown. By mixed use we mean a development where the retail and housing are integrated, i.e., stores on the bottom of the structure and dwellings on the second and third floors.

Response to Comment No. 23-2

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

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restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 23-3

We requested that the proposed final Project not exceed 45’ in height and that Residential/commercial buildings along Erwin Street and Radford Avenues not exceed three stories. This is in keeping with the general character of the neighborhood which consists of a majority of single family owner occupied homes. There are a few three story apartment buildings along Radford Avenue and we do not wish the Project not exceed the height of those current buildings.

Response to Comment No. 23-3

Regarding the height of the Project, please see Response to Comment No. A5-4.

Comment No. 23-4

Inclusion in the traffic study of a thorough examination of the traffic flow on the side streets directly adjacent to the project. No study was conducted on Radford and Erwin Avenues where three of the six proposed Projects driveways will feed into. These streets will be severely impacted by the Project and we request that traffic studies include those streets.

Response to Comment No. 23-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at the Project driveways, see Response to Comment No. 10-4.

Comment No. 23-5

In no page of the 742 page document does it say exactly how many parking spaces will be allocated to the total residential project. Because of the proximity of the Project to my home (within 500 feet), the parking question is of great concern. I have no desire to have folks coming and going at all hours of the night while parked on my street. Parking permits are not the answer; adequate parking at the Project itself is the answer. Please make sure there are more than the minimum required by law parking spaces for any residential component. And no, the parking structure for the retail portion is not the answer. This will not be utilized by the residents unless extremely convenient. As the Project is shown now, this is not the case.

Response to Comment No. 23-5

The Project’s parking demand and proposed supply are discussed in Response to Comment No. A5-81. As the Project would provide ample parking for its uses, overflow parking into the surrounding neighborhood is not anticipated.

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Comment No. 23-6

Currently (and for a few years past), the Macy’s building is mostly empty, only three stories (1st and 2nd floors and basement) of the total building is occupied with the Macy’s retail store. The rest is empty space. However, throughout this draft EIR it is clear that the preparers ignored this very important fact and assumed that the building is fully operational and that all square footage is currently occupied and in use. That is simply not true. Consequently all the ‘facts’ (and I do use the term lightly) currently used throughout this draft EIR for water use, traffic to and from the site, waste generation, utility usage, police and fire usage, etc. etc. ad infinitum, are based on erroneous information. Of course that is to the developer’s advantage, and we know the developer is paying for this draft EIR. Instead of actually studying the proposed site, the company preparing the draft EIR started with the conclusion that the developer wanted and worked backwards to make the ‘facts’ fit the desired findings. This is pure deception and only works to show the incompetence of the preparers.

The draft EIR concludes that the Project as proposed will result in less trips to the site than is currently happening by basing the estimated number of trips to the site daily on the square footage of the Macy’s building. Macy’s would be thrilled if there were over 10k trips per day to the site. In reality, they are lucky if there are 350 trips per day. Rather than counting empty square footage, how about stationing folks outside the property to actually COUNT the number of trips occurring now to the site per day? This would give the most accurate information. Additionally we need the June 2015 Cal Trans report used to study the 170 Freeway traffic which will be severely impacted, rather than the three year old 2012 Cal Trans report that was used in the draft EIR.

Response to Comment No. 23-6

See Response to Comment No. A5-83 regarding water and sewage estimates for the existing uses. Existing electricity and natural gas consumption were calculated using generation rates provided in the SCAQMD Air Quality Handbook for the same amount of existing uses as discussed in Response to Comment No. A5-83 for water and wastewater.

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

See Response to Comment No. A5-45 regarding impacts to fire protection services and A5-46 regarding impacts to police protection services.

The EIR reflects the independent judgment of City of Los Angeles staff.

Comment No. 23-7

The draft EIR states that the impact of the project on scenic views is less than significant. I can see all the way to Mullholland drive from the corner of Erwin and Gentry looking south. How will I be able to see

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that with massive six story apartment buildings in the way? The impact on scenic views is SIGNIFICANT.

Response to Comment No. 23-7

See Response to Comment No. A5-2 regarding impacts to scenic views.

Comment No. 23-8

This Project is not in keeping with the North Hollywood – Valley Village Community Plan, which specifies that any development preserve the low-density, single-family character of the neighborhood.

Response to Comment No. 23-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 23-9

What’s wrong with having some units for ownership in the Project? Why must all the housing be rental in nature? Renters have no stake in the property and are not likely to take care of the neighborhood because renters are mostly of a transient nature. We want something that will improve the neighborhood, not a potential tenement.

Response to Comment No. 23-9

The comment provides the commenter’s request that the Project include for-sale units, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s request is acknowledged for the record.

Comment No. 23-10

Also the report states that liquefaction is not a concern. Anyone that has dug down 6” into the soil in this area knows we are on an ancient lake bed due to the fact that our soil is mostly SAND. If the development is allowed to proceed with the current plan, the weight of the apartment buildings is a disaster waiting to happen. The draft EIR does not even reference the correct lot when siting geologic studies

Response to Comment No. 23-10

See Response to Comment No. A5-24 regarding the Project’s impacts with respect to liquefaction.

Comment No. 23-11

We certainly want a development on this lot, but we want the right development. We are not willing to incorporate over 2K more residents into our neighborhood when what we really need is a replacement

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shopping center so that we can WALK to do our shopping. And we need a diverse choice of stores and restaurants to patronize. Giving us 742 apartments with a strip mall (which is essentially the Plan now) is not what we need. We urge you to please consider the neighborhood when reviewing this Plan and please consider our wishes.

Response to Comment No. 23-11

In addition, the Draft EIR analyzes two alternatives that would provide retail without any housing; these are Alternatives 1 and 2A.

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LETTER NO. 24

Dylan Quirt 6201 Colfax Ave North Hollywood, CA 91606

Comment No. 24-1

I support the overall idea of the project, however if not executed with consideration for the neighborhood the effects on the community could be detrimental. The primary concern I have, as well as many of my neighbors is the effect 750+ apartment units and the traffic it will create will have on this single family home residential neighborhood. This Neighborhood CAN NOT sustain this sort of impact.

Response to Comment No. 24-1

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the impacts of Alternative 4B, which has been added to this Final EIR and is a reduced project which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

Comment No. 24-2

• • We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 24-2

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at the Project driveways, see Response to Comment No. 10-4.

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Comment No. 24-3

• Placing exits/entrances to and from the plaza on smaller side streets like Erwin and Redford without doing a traffic study for these streets is irresponsible to the neighborhood and people that live on or near these streets. These are small residential streets and CAN NOT sustain the impact the plaza will create. There needs to be a partition or signs that only allow traffic to move towards Laurel Canyon or Oxnard Blvd (via Erwin or Redford ).

Response to Comment No. 24-3

See Response to Comment No. 6-3 regarding potential impacts to Radford Avenue & Erwin Street and other residential streets.

See Response to Comment A5-64 regarding the potential for “cut-thru” traffic.

Comment No. 24-4

• We neighbors of Laurel Plaza know without a doubt that the traffic study’s assumption of present, weekday vehicle trips to and from the Macy’s store of 10,639 is unrealistic. At best the current weekday vehicle trips to Macy’s to and from are no more than 500 customers per day. We request that a traffic study be conducted using realistic assumptions, and that the latest June 2015 Caltrans report on the 170 Freeway be used, instead of the 2012 Cal Trans report which was used in the Draft EIR.

Response to Comment No. 24-4

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 24-5

• The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are indeed unavoidable then the scope of the project needs to be reduced. We request that the Final EIR mitigate the traffic issues and/or reduce the residential scope of the project to address the significant traffic issues described in the Draft EIR.

Response to Comment No. 24-5

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Comment No. 24-6

• The Department of Transportation (DOT) report says the Draft EIR did not indicate the total number of parking spaces required to comply with the City code. We request that the DOT be provided with the number of parking spaces required to comply with the City code.

Response to Comment No. 24-6

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 24-7

• The Project is not consistent with the North Hollywood ‐ Valley Village Community Plan. The Plan specifies that the low‐density residential character of North Hollywood ‐ Valley Village should be preserved and that single‐family residential neighborhoods be protected from encroachment by other types of uses.

Response to Comment No. 24-7

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 24-8

• The Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial. We request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail space.

Response to Comment No. 24-8

Comment No. 24-9

• We request that the residential/commercial buildings for the proposed final Project not exceed 45’ feet in height. Residential and/or commercial buildings along Erwin Street and Radford Avenue should not exceed 3 stories.

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Response to Comment No. 24-9

See Response to Comment No. A5-4 regarding the proposed height.

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LETTER NO. 25

Val Diamond-Cohen and Steven Cohen 5842 Radford Ave. North Hollywood, CA 91607

Comment No. 25-1

We have owned a home at 5842 Radford Ave, North Hollywood, CA 91607, for 12 years. We are disappointed to hear that the current developer doesn’t plan to build a project that includes all commercial/retail buildings.

We’re a small community and the NoHo West project is not consistent with the North Hollywood – Valley Village Community Plan. The Plan specifies that the low-density residential character of North Hollywood – Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses.

We would like to shop in North Hollywood instead of Studio City, Sherman Oaks or Burbank with our own grocery and retail stores. The proposed movie theatre complex is an excellent idea.

Response to Comment No. 25-1

The comment provides introductory information and the commenter’s preference for an all-commercial project, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 25-2

• We do NOT need more apartment buildings in our residential community.

Response to Comment No. 25-2

Alternatives 1 and 2A, analyzed in the Draft EIR, would include no residential units. In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

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Comment No. 25-3

• We value our privacy and don’t want apartment residents looking down into our neighboring back yards.

Response to Comment No. 25-3

See Response to Comment No. A5-4 regarding the proposed height of the Project and Response to Comment No. A5-2 regarding the Project’s compatibility with neighboring single-family homes.

Comment No. 25-4

Please consider converting the NoHo West (Laurel) Project to become fully retail/commercial. North Hollywood needs it!

Response to Comment No. 25-4

The comment states the commenter’s preference for an all-commercial project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration. In addition, Alternative 2A analyzed in the Draft EIR considers an all-commercial development of the Project Site.

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LETTER NO. 26

Ron Bitzer

Comment No. 26-1

The proposed project as currently proposed employs obsolete methods to mitigate even partially--- the adverse environmental impacts during construction and then operation.

Example of Vagueness in DEIR Building Standards

The Draft EIR repeatedly refers to the use of “LEED --- Leadership in Energy and Environmental Design ---qualified equivalent" strategies (emphasis added). This terminology is objectionable to administrators of the LEED Rating System, who seek to maintain the integrity of the LEED rating system for buildings (Platinum / Gold / Silver etc.)

Mr. David Sheridan, Green Building Specialist, Green Business Certification Inc., Washington, D.C. has explained to me that the US Green Building Council will not allow the term LEED to be associated with any project that is not either (a) going through the application and review process, or that has (b) achieved an actual certification in a LEED rating system," Attachment A, February 12, 2016 email to Ron Bitzer.

The Final EIR for the NoHo West project should (a) explain the term “LEED qualified equivalent," (b) discard the use of this term or (c) preferably commit to a Gold or Platinum level of LEED certification to be sought from the US Green Building Council.

Response to Comment No. 26-1

The Project does not plan to seek LEED certification. The term “LEED-qualified equivalent” is used in Project Objective #7 (see Draft EIR page 3-7) to mean that the Project will incorporate LEED principles without formally seeking LEED certification. However, the Project would comply with CalGreen requirements of the California Building Code and also the Los Angeles Green Building Code.

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LETTER NO. 27

Joyce Dillard PO Box 31377 Los Angeles, CA 90031

Comment No. 27-1

HYDROLOGY AND WATER QUALITY and UTILITIES AND SERVICE SYSTEMS have inaccurancies that lead to errors in Mitigation Measures and Regulatory Compliance.

YOU STATE:

H. Hydrology and Water Quality

Water Quality - Implementation of appropriate project design features and compliance with local, state and federal regulations, code requirements, and permit provisions would prevent significant impacts related to the release of potentially polluted discharge into surface water. In order to prevent both short term (construction) and long-term (operational) impacts to water quality, the Project would be required to obtain a NPDES water quality permit from the LARWQCB, and would be designed and constructed to comply with the requirements of the LARWQCB Order No. 01-182 NPDES Permit No. CAS004001; the Construction General Permit Water Quality Order 2009-0009-DWQ as amended by Order No. 2010- 0014-DWQ; and the City of Los Angeles, Department of Public Works, Bureau of Sanitation, Watershed Protection “How to Build Protection for Mother Nature Into Your Project, Standard Urban Stormwater Urban Mitigation Plans (SUSMP) Site-Specific Mitigation Plans.” Requirements of the SUSMP are enforced through the City’s plan approval and permit process

COMMENTS:

LARWQCB Order NO. R4-2012-0175 NPDES PERMIT NO. CAS004001 is the current permit with compliance issues that differ what is stated. It reads as follows:

D. Permit Coverage and Facility Description

The Los Angeles County Flood Control District, the County of Los Angeles, and 84 incorporated cities within the Los Angeles County Flood Control District with the exception of the City of Long Beach (see Table 5, List of Permittees), hereinafter referred to separately as Permittees and jointly as the Dischargers, discharge storm water and non-storm water from municipal separate storm sewer systems (MS4s), also called storm drain systems. For the purposes of this Order, references to the “Discharger” or “Permittee” in applicable federal and state laws, regulations, plans, or policy are held to be equivalent to references to the Discharger, or Permittees herein depicting the major drainage infrastructure within the area covered under this Order are included in Attachment C of this Order.

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Upper Los Angeles River Watershed Group is in the Upper Los Angeles River Watershed Management Area with the City of Los Angeles as the Lead Agency in the preparation of the EWMP Enhanced Watershed Management Plans and the CIMP Coordinated Integrated Monitoring Program. There exists responsibility for the Receiving Water compliance issues:

• Los Angeles River Watershed Trash TMDL

• Los Angeles River Nitrogen Compounds and Related Effects TMDL

• Los Angeles River and Tributaries Metals TMDL

• Los Angeles River Watershed Bacteria TMDL

• Los Angeles Area Lakes TMDLs

Response to Comment No. 27-1

The permit number has been corrected. See Section 3, Additions and Corrections, of this Final EIR for this correction. In addition, as stated in Regulatory Compliance Measure H-1 (in Section 4.H. Hydrology and Water Quality, of the Draft EIR), the Project Applicant shall comply with all mandatory storm water permit requirements (including, but not limited to, NPDES, SWPPP and SUSMP, and LID requirements) at the Federal, State, and local level, which would minimize impacts to water quality. Therefore, impacts to water quality would be less than significant.

Comment No. 27-2

YOU STATE:

Environmental Setting

Los Angeles County MS4 Permit

In 2001, the LARWQCB issued an NPDES Permit and Waste Discharge Requirements (Order No. 01- 182) under the Clean Water Act and the Porter-Cologne Act for discharges of urban runoff in public storm drains in Los Angeles County. The Permit was most recently amended on April 14, 2011, pursuant to the peremptory writ of mandate in L.A. Superior Court Case No. BS122724, which voided and set aside a 2006 amendment. The Permittees are the Los Angeles County incorporated cities (including the City of Los Angeles but excluding the City of Long Beach) and the County (collectively, the Copermittees).

COMMENTS:

All conclusions following that statement make this document incorrect.

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Response to Comment No. 27-2

The Draft EIR analyzes the Project's potential impacts to hydrology and water quality in Section 4.H. With the implementation of Regulatory Compliance Measures H-1 through H-4 on pages 4.H-18 and 4.H- 19 of the Draft EIR, which ensure compliance with applicable regulations, the Project's impacts to hydrology and water quality would be less than significant.

Comment No. 27-3

YOU STATE:

Existing Conditions

The Project Site is almost entirely covered with impervious surfaces. There are some small areas of vegetation for decorative purposes throughout the Project Site consisting primarily of isolated trees, planters, and grasses. These areas are negligible compared to the impervious surface on the entire Project Site. The Project Site slopes downward very gradually to the south, with approximately 10 feet of elevation change. Drainage across the Project Site is by sheetflow to area drains or City streets.

A 30-foot wide easement for the Central Branch of the Tujunga Wash Aqueduct is located along the west property line and the Hollywood (170) Freeway. Based on the Geotechnical Engineering Investigation prepared by Geotechnologies on August 15, 2014 (included as Appendix F to this Draft EIR), the Tujunga Wash transitions from an open rectangular channel (west of Laurel Canyon Boulevard) to an underground reinforced concrete box channel below the west side of the Project Site. The underground concrete box channel extends southward from Laurel Canyon Boulevard past Oxnard Street and the Hollywood Freeway entrance and exit ramp. According to the plans, the section of the underground box channel located along the west side of the Project Site is 10 feet wide and 7 feet high.

COMMENTS:

Please identify the responsible parties for urban runoff from the development including any pollutant loads. Appendix F-Geotechnical Report states that proper surface drainage is critical to the future performance.

Response to Comment No. 27-3

See Response to Comment No. 27-2. The Project developer would be the responsible party for urban runoff. Compliance with applicable regulations would ensure that impacts related to urban runoff are less than significant.

Comment No. 27-4

YOU STATE:

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ALTERNATIVES

Alternative 1: No Project

Alternative 2: Existing Zoning/All Residential

Alternative 2A: Existing Zoning/All Commercial

Alternative 3: Existing Development Plus Residential

Alternative 4: Reduced Density Mixed Use Project with Larger Retail Component

Alternative 5: Reduced Density Mixed Use Project with Larger Retail Component and Fewer Residential Units

COMMENTS:

There is no adopted Circulation Element which is a comprehensive infrastructure plan addressing the circulation of people, goods, energy, water, sewage, storm drainage, and communications. The Circulation Element is required by the State of California.

Response to Comment No. 27-4

The comment incorrectly states that there is no adopted Circulation Element, and does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. The City’s circulation element is known as the Mobility Plan 2035. On January 20, 2016, the City adopted the Mobility Plan 2035, which updates the 1999 Transportation Element and integrates the 2010 Bicycle Plan. The Mobility Plan also responds to recent State legislation: Complete Streets Act (AB 1358), Sustainable Communities and Climate Protection Act (SB 375), Global Warming Solutions Act (AB 32), and CEQA / Level of Service (SB 743). The City is also updating its Integrated Resources Plan (IRP) called One Water LA 2040 Plan. The One Water Plan combines facilities plans for water, stormwater, and wastewater. The energy plan is provided by the LADWP.

Comment No. 27-5

The project is not consistent with Framework Element Policy No. 3.3.2. Framework Element Policy No. 3.3.2 is the monitoring aspect of CEQA for the General Plan. It reads:

3.3.2 Monitor population, development, and infrastructure and service capacities within the City and each community plan area, or other pertinent service area. The results of this monitoring effort will be annually reported to the City Council and shall be used in part as a basis to: a. Determine the need and establish programs for infrastructure and public service investments to accommodate development in areas in which economic development is desired and for which growth is focused by the General Plan Framework Element.

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b. Change or increase the development forecast within the City and/or community plan area as specified in Table 2-2 (see Chapter 2: Growth and Capacity) when it can be demonstrated that (1) transportation improvements have been implemented or funded that increase capacity and maintain the level of service,

(2) demand management or behavioral changes have reduced traffic volumes and maintained or improved levels of service, and (3) the community character will not be significantly impacted by such increases. Such modifications shall be considered as amendments to Table 2-2 and depicted on the community plans. c. Initiate a study to consider whether additional growth should be accommodated, when 75 percent of the forecast of any one or more category listed in Table 2-2 (see Chapter 2: Growth and Capacity) is attained within a community plan area. If a study is necessary, determine the level of growth that should be accommodated and correlate that level with the capital, facility, or service improvements and/or transportation demand reduction programs that are necessary to accommodate that level. d. Consider regulating the type, location, and/or timing of development, when all of the preceding steps have been completed, additional infrastructure and services have been provided, and there remains inadequate public infrastructure or service to support land use development. (P42, P43)

Response to Comment No. 27-5

The comment discusses Framework Element Policy No. 3.3.2, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, as analyzed in Sections 4.K., 4.L., and 4.N. of the Draft EIR, Project impacts related to population and housing, public services, and utilities, respectively, would all be less than significant. In addition, as discussed on pages 5-3 and 5-4 of the Draft EIR, while the Project would provide new residential, commercial, and office uses, it would not necessitate the extension of roads or other infrastructure.

Comment No. 27-6

Needed is an assessment of the infrastructure as to age and remaining life and the developer’s responsibility for any infrastructure improvements or development improvement fees.

We cannot determine how the Project Description or Alternatives effect the infrastructure.

Response to Comment No. 27-6

As analyzed in Sections 4.L. and 4.N. of the Draft EIR, Project impacts related to public services and utilities, respectively, would be less than significant. In addition, as provided in Regulatory Compliance Measure N.1-2 on page 4.N.1-13 of the Draft EIR, if the public sewer has insufficient capacity, the Project Applicant shall be required to build sewer lines to a point in the sewer system with sufficient capacity. Similarly, Regulatory Compliance Measure N.2-5, the Project Applicant shall be required to implement any upgrade to the water infrastructure serving the Project Site that is needed to accommodate the Project’s water consumption needs.

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Comment No. 27-7

YOU STATE:

Project Consistency with the 2008 RCP Policies

LU-4.1 Local governments should adopt and implement General Plan Housing Elements that accommodate housing needs identified through the Regional Housing Needs Assessment (RHNA) process. Affordable housing should be provided consistent with RHNA income category distributions adopted for each jurisdiction. To provide housing, especially affordable housing, jurisdictions should leverage existing State programs such as HCD’s Workforce Incentive Program and density bonus law and create local incentives (e.g., housing trust funds, inclusionary zoning, tax-increment-financing districts in redevelopment areas and transit villages) and partnerships with nongovernmental stakeholders.

Consistency Discussion

Consistent. As discussed in Section 4.K (Population and Housing), the Project would provide market-rate housing that is consistent with housing needs called out in he RHNA.

COMMENTS:

We do not see how the RHNA justifies the increase of housing units in this Community Plan. You show no calculations of distribution amongst Community Plans. The City of Los Angeles accounts for 19.9% of the SCAG region’s growth.

Response to Comment No. 27-7

As stated on page 4.K-3 of the Draft EIR, the City of Los Angeles was assigned a RHNA of 95,023 units for the 2014-2021 planning period. There is no process for allocating the Citywide total to City subareas, such as a Community Plan Area. Therefore, the Project helps meet the RHNA minimum allocation by providing residential units at the Project Site.

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LETTER NO. 28

Judy & Eugene Rubin

Comment No. 28-1

1. Traffic will be impacted in a bad way. Our street (Tiara St - south of Oxnard and Radford) is used as a shortcut to Colfax already, and if humps are put in they will affect our cars and health. As seniors it is difficult to drive over them. We also have a lot of young children living on the block and surrounding areas and we worry about their safety.

Response to Comment No. 28-1

The intersections analyzed in the Traffic Study were selected in consultation with LADOT and approved by LADOT. Although Tiara Street was not evaluated in the Traffic Study, the adjacent intersections of Oxnard & Radford and Oxnard & Colfax were studied and it was determined there would be no significant impacts at those intersections. Project traffic would be unlikely to use Tiara Street, as it does not provide an advantageous or faster route for those accessing or exiting the Project, primarily because there are unsignalized intersections at both Radford & Oxnard and Tiara & Colfax which would slow the traffic and make it harder to turn into or out of the street. Generally, Project traffic will seek routes with signalized intersections. As shown in Figures 4.2 and 4.3 of the Traffic Study (Figures 4.M-7 and 4.M-8 of the Draft EIR), only a very small amount of Project traffic is estimated to use Colfax Avenue and none is assumed to utilize Tiara Street. In addition, the Project does not propose to add speed humps or other devices to any of the streets in the neighborhood.

Comment No. 28-2

2. This would involve too many people in a too small an area. Why not look at the vacated shops on Laurel Canyon on the west side between Alexandria Park (North of Gold's Gym) and Victory. These would be perfect for development and would not impact residents in the area.

Response to Comment No. 28-2

As explained in the Draft EIR, page 6-4, alternative sites were determined to be infeasible for failure to meet basic Project objectives, insufficient size, and unlikelihood of avoiding significant environmental impacts.

Comment No. 28-3

3. Would this overwhelm Victory Boulevard Elementary School and the nearby Junior High near Sears?

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Response to Comment No. 28-3

See Response to Comment No. A5-47 regarding the Project’s impacts to Victory Elementary School and Romer Middle School.

Comment No. 28-4

4. Employees of the retail stores planned would park their cars in our area inviting thieves and bringing leftover food and drink cartons thrown from vehicles.

Response to Comment No. 28-4

The Project’s parking demand and proposed supply are discussed in Response to Comment No, A5-81. As the Project would provide ample parking for its uses, overflow parking in the surrounding neighborhood is not anticipated.

Comment No. 28-5

5. The 170 freeway gets congested during peak traffic hours now so it would severly hamper people trying to get to work and doctor appointments with all the new traffic.

Response to Comment No. 28-5

See Response to Comment No. A5-52 regarding potential impacts to the 170 freeway.

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LETTER NO. 29

Eric and Lisa Petersen 11747 Collins St Valley Village, CA 91607

Comment No. 29-1

This letter is in reference to the proposed NoHo West (Laurel Plaza) Project and the recently released DEIR (Draft Environmental Impact Report). I am very excited about the development as both a resident living just south of Oxnard Street on Radford Avenue and as a parent with two children at Laurel Hall School located on Radford Avenue. This neighborhood has been waiting for a substantial retail development at this site since the Laurel Plaza shopping center was lost in the 1994 earthquake.

That said, please be advised that the NoHo West (Laurel Plaza) Project is not consistent with the North Hollywood ‐ Valley Village Community Plan. Quoting the Community Plan, the Plan “proposes that the low density residential character of North Hollywood ‐ Valley Village should be preserved and that single‐family residential neighborhoods be protected from encroachment by other types of uses.” I am greatly concerned that the largest component of the NoHoWest (Laurel Plaza) project, as it is currently being presented by the developer, is the 742 apartments totaling 816,200 sq. feet. The smallest portion of the project is the retail component at a mere 300,000 sq. feet. This should not be a residential project with some retail, it needs to be a retail project with some residential.

Response to Comment No. 29-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 29-2

As a neighborhood association, we asked for an Alternative Study consisting of a mixed use development with retail on the ground floor and residential above with all new commercial and residential buildings being built at a maximum height of 45’ feet on the entire property, except that new buildings along Erwin Street and Radford Avenue adjacent to the existing residential neighborhood not exceed three stories, which was not done. We’ve seen the beautiful Palazzo Apartments on 3rd Street near Park La Brea and they are four stories high. They are huge at four stories…NoHo West is proposing adding an additional

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two stories on top of that totaling six stories in a neighborhood of single family homes and small apartment buildings that stand no more than two stories high. Six stories is too high, it’s too intrusive, and will not at all blend in with the character of our neighborhood. Again, we request that the apartments be no higher than three stories. No one wants people peering into the school next door.

Response to Comment No. 29-2

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Regarding the height of the Project, please also see Response to Comment No. A5-4.

In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). The design of Alternative 4B reduces the height of the residential units along Calvert Place from six stories to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School. Abundant landscaping would also be provided between the Project Site and the Laurel Hall School.

Comment No. 29-3

The proposed Project will significantly increase traffic in the area. The Draft EIR claims that there will be a net increase of only 19 cars per day during peak traffic hours. This is complete hogwash! As I understand it, the numbers are based on square footage of the existing Macy’s building…a building that is way less than fully utilized as it is a retail store, not actual automobile counts, and converting it to 500,000 square feet of office space will OBVIOUSLY increase the daily person count and therefore daily car count and traffic. This Macy’s has been in decline for years and years and traffic to and from Macy’s totals 500 vehicles per day or less, if even that many. I find it completely irresponsible of the developer to honestly believe that adding 742 apartments plus all the proposed retail will only bring in an additional 19 cars per day during peak traffic hours. This is irrational and unbelievable. The added vehicle traffic is going to be a complete nightmare without serious traffic mitigation. Combined commercial and residential vehicles at the Project site will generate a minimum of 3,000 additional vehicles per day in the area, if not more. As it currently stands, traffic during the weekday mornings and afternoons (starting at 4/4:30pm and into the early evening) is backed up on Oxnard Street heading westbound, blocking Radford Avenue and trailing to Colfax Avenue. I request that data collection for the traffic studies be done during peak‐days and peak‐hours, non‐holiday weeks, and when schools are in session so that traffic mitigations are appropriately implemented. I request that the traffic study for the final EIR be conducted at several affected intersections, not just at Oxnard and Laurel Canyon. Traffic flow also needs to be studied at Oxnard and Radford (where traffic is already a nightmare during morning drive time and evening drive time), Radford and Erwin, and Laurel Canyon and Erwin. I would like to have left turn arrows added all around to all traffic lights at the intersections of Laurel Canyon & Burbank Blvd, Laurel Canyon & Oxnard Street, Colfax & Burbank, Colfax & Oxnard, and at Lankershim Blvd at Oxnard.

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Response to Comment No. 29-3

See Response to Comment No. A5-42 regarding the Project’s traffic impacts and Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Traffic counts were conducted in accordance with all requirements specified in LADOT’s Traffic Study Policies and Procedures, dated August 2014, which includes the requirements that counts be conducted on a weekday during the peak periods of 7:00 – 10:00 AM and 3:00 – 6:00 PM, when schools are in session.

Of the three intersections listed by the commenter as needing to be analyzed in the Traffic Study, two intersections were analyzed as part of the Traffic Study: Laurel Canyon Boulevard & Erwin Street (Intersection #10) and Oxnard Street & Radford Avenue (Intersection #15). These intersections were determined to currently operate at LOS A in both the AM and PM peak hours, and are expected to continue to operate at LOS A with the construction of the Project. See Response to Comment No. 6-3 regarding the supplemental analysis prepared for the Erwin Street & Radford Avenue intersection.

The commenter provided a list of intersections at which they would like left-turn arrows added to all approaches. Of the locations listed, the Project is either not expected to create a significant traffic impact, or for locations where a significant impact has been identified, the Project, in conjunction with LADOT, has identified mitigation measures that will reduce the impact to a level of insignificance.

Comment No. 29-4

Specifically relating to Radford Avenue south of Oxnard Street, I would like to have Radford Avenue at Oxnard Street blocked off to vehicular traffic heading south on Radford from Oxnard and heading north on Radford to Oxnard. Considering the amount of new traffic that this development will bring to the area, and considering that this area of Radford Avenue is already used a cut through to Colfax, Burbank Blvd, and the 170 freeways on ramps (both north and south), our 100% residential Radford Avenue should not be used for traffic flow for NoHo West (Laurel Plaza). The enclave of Radford Avenue south of Oxnard Street is filled with young families and older original homeowners who walk the neighborhood, walk to and from school with their small children, bike ride, ride scooters, cross the street to neighbors’ houses, play in their front yards, etc. We are a very active pedestrian neighborhood. Non‐resident traffic already flies down the street regularly at speeds from 35‐50 mph with no regard for residents, children, and pets. We simply cannot afford any additional traffic without great risk to the residents, and specifically to the children.

Radford Avenue is also used by many students from North Hollywood High School who live north of Oxnard Street, many who cut through our neighborhood on foot, on bikes, and many on skateboard. We have witnessed several near misses of cars almost hitting students. Any additional vehicular traffic would put these young people at risk of being hit as they often are wearing earbuds and are walking in the street both to and from school. Blocking off Radford Avenue at Oxnard Street to vehicular traffic would be another way to ensure the safety of all pedestrians who enjoy our neighborhood.

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This can be accomplished while still keeping the crosswalk for pedestrians. For instance, ideally the street would be blocked off by putting in a nice median with medium size trees (perhaps in large pots or large wine barrels or large wooden tree boxes) for beautification and to help clean the air and add shade. Trees would be a nice touch and in keeping with the beauty of the new development. As an alternative, the street can be blocked with k‐rails (which would be our last choice solution since K‐rails are unattractive and a magnet for graffiti). We could even be satisfied with a northbound, right hand (east) exit only onto eastbound Oxnard Ave from Radford Ave.

With Radford Avenue blocked off at Oxnard Street, there are still plenty of ways in and out for vehicles of residents who live in this enclave. Residents can enter and exit from Hatteras off of Colfax and from Collins off of Colfax. Both police and fire stations are located on Burbank Blvd and Chandler respectively so they would have ready access to entering and exiting our enclave from the south as they currently do. Blocking off Radford Avenue at Oxnard Street would have no negative effect on emergency vehicles accessing our neighborhood, and would greatly increase the safety of our neighborhood. For the Laurel Hall School, for children in 1st grade and above, there needs to be a designated drop off lane for any drop off students within the proposed development located on the west side of the school. Drop off on Radford Avenue is not a viable option. Parents need a safe, dedicated lane protected from traffic, not a traffic flow street, on which they can safely drop their children off and not affect street traffic. It would also be appreciated to have a designated parking area for all Laurel Hall parents (and staff) since, understandably for safety concerns, parents of Transitional Kindergarten and Kindergarten students (4, 5 & 6 year olds) are not allowed to drop their children at the gate at school. They must park their vehicle and walk their children to their classroom. Also, for pickup of all children, the parking area needs to be safe and a reasonable distance from the school without traipsing through NoHo West (Laurel Plaza). It is unrealistic to have parents park in a parking structure far from the school to walk their TK and Kindergarteners to and from school and to pick up their older kids.

Response to Comment No. 29-4

As discussed in Response to Comment No. 29-3, the Oxnard Street & Radford Avenue intersection (Intersection #15 in the Traffic Study) was determined to currently operate at LOS A in both the AM and PM peak hours, and would continue to operate at LOS A with the construction of the Project. Therefore, no mitigation is required for impacts associated with Project traffic.

Regarding cut through traffic, see Response to Comment No. A5-64.

The Traffic Study and EIR were conducted under the assumption that the surface parking lots on which Laurel Hall School and Emmanuel Lutheran Church visitors have been parking are to be fully redeveloped as part of the Project, and that all drop off/pick-up activities currently occurring on the surface parking lots would be conducted on-site at Laurel Hall School. In addition, the Project would provide 50 parking spaces located in the parking structure by lease agreement for use by Laurel Hall teachers and staff.

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Comment No. 29-5

The Draft EIR claims that there will be no impact or less than significant impact on Population and Housing, Public Service Fire Protection, Police Protection, Water Usage, Utilities and Service Systems Wastewater, Solid Waste, Energy Conservation, Air Quality, Geology and Soils, etc. How can this be? Any logical person can easily determine that with an increase of 742 apartments, which will likely house at least 1,500 people, plus the added retail, there will be a significant increase and impact upon those things listed above, most specifically, water, waste, utilities, air quality and fire/police protection.

Response to Comment No. 29-5

Project impacts with respect to population and housing are addressed in Draft EIR Section 4.K., and as provided therein, impacts would be less than significant.

Project impacts with respect to water are addressed in Draft EIR Section 4.N.2, and in Responses to Comment Nos. A5-83 through A5-86. With implementation of Regulatory Compliance Measures N.2-1 through N.2-5 and Project Design Feature N.2-6, Project impacts with respect to water would be less than significant.

Project impacts with respect to wastewater are addressed in Draft EIR Section 4.N.1, and in Responses to Comment Nos. A5-83 through A5-86. With implementation of Regulatory Compliance Measures N.1-1 and N.1-2 and Project Design Feature N.1-3, Project impacts with respect to wastewater would be less than significant.

Project impacts with respect to solid waste are addressed in Draft EIR Section 4.N.3, and in Responses to Comment Nos. A5-90 through A5-92. With implementation of Regulatory Compliance Measures N.3-1 through N.3-3 and Project Design Feature N.3-4, Project impacts with respect to solid waste would be less than significant.

Project impacts with respect to energy conservation are addressed in Draft EIR Section 4.N.4, and in Response to Comment No. A5-93. With implementation of Regulatory Compliance Measures N.4-1 through N.4-3 and Project Design Feature N.4-4, Project impacts with respect to energy conservation would be less than significant.

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Project impacts with respect to air quality are addressed in Draft EIR Section 4.C, and in Responses to Comment Nos. A5-14 through A5-22. With implementation of Mitigation Measures C-1 through C-5, Regulatory Compliance Measures C-6 through C-10, and Project Design Features C-11 through C-13, Project impacts with respect to air quality would be less than significant.

Project impacts with respect to geology and soils are addressed in Draft EIR Section 4.E, and in Responses to Comment Nos. A5-23 through A5-26. With implementation of Regulatory Compliance Measures E-1 and E-2 and Project Design Feature E-3, Project impacts with respect to geology and soils would be less than significant.

Comment No. 29-6

In addition to these requests, with any increase in residents with the apartments that are to be built and with the increase of people shopping at the retail, we would like to see an additional community police station and fire station added at the expense of the developer covering the facilities and adequate necessary initial vehicles. We already have too few police available covering the large area that the North Hollywood division currently covers. With additional residents and retail, unfortunately comes additional crime that will need to be dealt with.

With new apartments and new retail, there will undoubtedly be many false alarms reported during the first couple of years due to any number of circumstances. Each of those calls will have to be investigated by emergency personnel, even if they assumed or are confirmed to be false alarms upon initial response. This takes valuable emergency personnel away from their stations for when someone calls in with a true emergency such as a heart attack, seizures, accidents, etc. Our neighborhood has many older residents, original home owners who have called on emergency personnel often. There are several families of young children who have had to call for medical emergencies more than once (including our family). If these emergency medical personnel are evacuating and otherwise investigating false fire alarms, etc. they will not be available for the real medical emergencies. It is of extreme importance to make sure that all residents and shoppers are kept safe, in addition to those of us already here. The City of Glendale had to add additional police and fire stations with their residential and retail growth because of these very circumstances and examples, and our community deserves the same with the developer picking up the tab and not the taxpayers.

Response to Comment No. 29-6

See Response to Comment No. A5-45 regarding Project impacts with respect to fire protection (including emergency response) and Response to Comment No. A5-46 regarding Project impacts with respect to police protection.

Comment No. 29-7

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wrong and ridiculous! – while ignoring and not including the negative data or other very important data from the likes of CalTrans, DOT, proper geology report, correct earthquake/liquefaction information, and/or using old and out dated traffic information.

Response to Comment No. 29-7

The Draft EIR was prepared under the direction of and reflects the independent judgment of the City of Los Angeles Department of City Planning. The comment references alleged inaccuracies in the Draft EIR concerning Caltrans, DOT, geologic data, and traffic data, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

The geotechnical report is included as Appendix F to the Draft EIR and the analysis contained in the geotechnical report is summarized in Draft EIR Section 4.E., Geology and Soils. In addition, Project impacts with respect to geology and soils (including seismic impacts and liquefaction) are addressed in Responses to Comment Nos. A5-23 through A5-26.

Finally, see Response to Comment No. A5-50 regarding traffic data.

Comment No. 29-8

We must not lose this opportunity at NoHo West (Laurel Plaza) and Valley Plaza to create a shopping destination for the Southeast Valley. While housing is being built all over North Hollywood, we need to create a place where new and current Southeast Valley residents can shop and support the City of Los Angeles with their tax dollars!

Thank you for helping us create the shopping destination we all have been waiting for and so desperately need, while still keeping the Community Plan intact and ensuring the best interest of our neighborhood and City.

Response to Comment No. 29-8

The comment provides the commenter’s opinion about the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinion is acknowledged for the record and will be forwarded as part of the Final EIR to the decision-making bodies for their review and consideration.

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LETTER NO. 30

Walter Hall 12301 Debby Street North Hollywood, CA 91606

Comment No. 30-1

Incorporated into my comments here are the comments submitted by the Laurel Grove Neighborhood Association (LGNA). In addition I stress the following:

The DEIR's assertion that public transportation options for the project site "provide an alternative to driving individual vehicles9 " is made without criteria to evaluate this assertion. While the document otherwise asserts that "It is impossible to know at this time whether Project residents, employees, and visitors would have longer or shorter trips relative to their destinations10 ," a few simple tests using the Destination Option of Google Maps, shows that driving a personal car is inevitably significantly faster than using public transportation. Please see the attached table, CAR VS. PUBLIC TRANSPORTATION TRAVEL TIMES. Indeed, THE OUTSTANDING FEATURE OF THE LAUREL PLAZA SITE IS ITS IMMEDIATE ACCESS TO THE HOLLYWOOD FREEWAY (SR-170). It defies common sense to think that this would not be a prime consideration for those considering apartment rental at the proposed project. The Laurel Plaza site is simply not public-transportation friendly and is not an appropriate site for concentrating a large number of new apartments.

Response to Comment No. 30-1

The commenter accurately indicates that, as stated on page 4.F-20 of the Draft EIR, it is impossible to know whether people would have shorter or longer trips relative to their destination based on the Project’s location. The Draft EIR does not analyze the amount of time it takes to reach a particular destination as part of the greenhouse gas analysis. The Draft EIR merely acknowledges that greenhouse gas emissions are difficult to estimate based on a number of factors, including the possibility that as a result of the Project, some Project residents, employees, and visitors may have shorter or longer trips to their residences, workplace, or shopping destination.

9 Draft EIR page 4.N.4-16, -17. 10 Draft EIR page 4.F-20.

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Comment No. 30-2

It is near impossible to stress, as highlighted in the LGNA comments, the fabricated nature of the minimal traffic impacts of the proposed project as detailed in the DEIR. Using Institute of Transportation Engineers (ITE) planning number in place of historical traffic volumes, as is shown in Attachment 2 of Appendix J (Traffic Study), is but one example of the study's non-objectivity. To assert 10,639 present- day total trips to a department store housed in a building using only three of four floors that is poorly patronized, and when equivalent but better-stocked same brand stores are available in nearby Burbank and Sherman Oaks, belies any credibility the traffic study might have. Computer simulations are no better than the credibility of the input data. In this case it truly is: nonsense in, nonsense out.

Response to Comment No. 30-2

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 30-3

Permit me to highlight just one more of many examples of the DEIR cooking the books in order to obtain the result that the project sponsors would obviously prefer. The Los Angeles Department of Water and Power did a Water Supply Assessment for the project (Appendix K-4 of the DEIR) based on historical usage as metered (15,047 gpd) and future usage as determined by industry-accepted figures for the needs of the project as proposed. The DEIR, to the project's advantage, ignores the historical figure and instead concocts one based on generic water use based on square-footage of the existing structures on the site (43,584 gpd). The DEIR is thus able to demonstrate a significantly reduced increase in water demand by the project. Just as water flows downhill, the DEIR is skewed with assumptions designed to flow to the result the project sponsor wants.

Response to Comment No. 30-3

See Responses to Comment Nos. A5-83 through A5-86 regarding the Project’s impacts with respect to water.

Comment No. 30-4

We neighbors of Laurel Plaza know that development at Laurel Plaza (and Valley Plaza) is coming. But unlike the NoHo West Project proposed in this DEIR, we are asking for development consistent with the historical nature of our neighborhood. Large structures, housing many apartments are an inappropriate fit for the single-family, owner-occupied homes which characterize the Laurel Grove neighborhood. Laurel Plaza (and Valley Plaza) were our historical shopping destinations. While a smaller number of apartments than proposed could prove tolerable, commercial development at these sites is what is needed and highly- preferred. Bring back to Los Angeles and the East Valley the shopping that now by necessity has migrated to Burbank and Glendale and with it the tax revenues that the City always seems in need of.

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Response to Comment No. 30-4

Partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

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LETTER NO. 31

Patrick Horne

Comment No. 31-1

I'm voicing my concerns about the poorly executed Draft Environmental Impact Report (DEIR) for the NoHo West (Laurel Plaza) Project. As a neighborhood resident within literal earshot of the aforementioned project, this is of great concern to myself and my family.

I support the development of a thriving commercial space in this area of both the San Fernando Valley and specifically this portion of North Hollywood. I believe that bringing in businesses to this area will be a great benefit to the residents and will, over time, drive up home prices and rental property costs, which in turn generates significant tax revenue to the city. I also support the inclusion of some residential properties being included as part of the developer's plan. However, I do not agree with the project's plan to add so many residential units into such a small area, effectively doubling the housing count in that area, adding commercial space where there is currently very little and then trying to tell the community that it shouldn't worry because, according to the Environmental Impact Report, it will have very little effect to traffic, crime rates, and fire/police protection. This is a bold-faced lie, and nobody in our community will stand for this.

Response to Comment No. 31-1

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Response to Comment No. A5-45 regarding the Project’s impact to fire protection services and Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

The commenter’s opinions provided in the comment are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 31-2

We are more than willing to work with the developer on this project to come to an agreement on what is both profitable to the developer and reasonable for the current community. But we will not be treated as though we have no voice in this matter, and we will use our rights as voters as our leverage.

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Please see the formal letters of protest attached to this email.

Thank you for your time and community support in this effort.

Response to Comment No. 31-2

Finally, the attached letters referenced in the comment are form letters Y8 and Z5. See Response to Comment Letters Y1 and Z1 for responses to these form letters.

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LETTER NO. 32

Evan Humphreys 5841 Corretta Ave North Hollywood, CA 91607

Comment No. 32-1

The project's proposed 742 residential units is far too large for this former entirely retail/commercial property that's all zoned for that intended use. This site should be redeveloped as entirely retail and commercial because that's what the site is zoned for and that's what this community needs instead of high‐ density residential apartments that will reduce the quality of life for the existing surrounding residents.

Response to Comment No. 32-1

In addition, as discussed in Response to Comment No. A5-35, residential uses are consistent with the existing C4 zoning for the Project Site, and are also consistent with the proposed C2 zoning for the Project Site.

Comment No. 32-2

The proposed 742 residential units also have excessive height and reduced setbacks. The massive residential buildings would unacceptably front on local streets and face much lower profile single‐family homes or at most, two‐story residential buildings. These massive structures are out of character for the surrounding neighborhood and would be a grossly excessive concession (planning variance) for this project. It is an unwelcome and severely obnoxious intrusion to the existing surrounding single‐family residential community. I understand that this outsized apartment project would be the largest of any similar development in the entire valley.

Response to Comment No. 32-2

See Responses to Comment Nos. A5-2 and A5-4 regarding the proposed height, setbacks, character, and compatibility with the surrounding residential uses. The Project includes a request for a Zoning Administrator’s Adjustment to allow a portion of one residential building along Erwin Street to observe a 12.5-foot rear yard in lieu of an 18-foot rear yard required by the LAMC due to the configuration of the

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existing subsurface basement (see Draft EIR page 3-7). At grade, the full 18-foot rear yard will be maintained. No other reduced setbacks are proposed.

Comment No. 32-3

By calling this 742 residential units "NOHO West" the developer indicates that this project is like the NOHO area near the Red Line station. It's not the same and our community doesn't want to be another NOHO‐developed area of many hundreds of rental units. The large apartments in the area now called NOHO are immediately next to the Red Line subway, an area that was largely commercial, car dealers, and industrial and previous apartments. Our community has no intention of becoming a "NOHO west”, which implies changing our single‐family home community into something like what's near the Red Line station. The 742 units is much too big and it needs to be significantly fewer residential units with a significant portion should be owned units (condo, townhouse) and not a project of all rental units.

Response to Comment No. 32-3

The comment provides the commenter’s opinions about the Project name, NoHo West, which are acknowledged for the record.

The commenter’s preference for the Project to include some individually owned units is acknowledged for the record.

Comment No. 32-4

The traffic along Oxnard is regularly at a full stop (completely jammed ) during weekday rush‐hours and this project as planned will cause significantly more traffic. The traffic element of this DEIR is insufficient and makes unfair comparisons. I can't entirely discern the clever presentation of traffic data but some of it appears to be suspect to me and needs to be made thorough and accurate.

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An example of a clearly underestimated traffic increase is for intersection 15, Oxnard and Radford. Already, cars speed through the housing tract south of Oxnard at Radford with Tiara and Radford acting as their shortcut around the crowded major streets. The DEIR appears to show NO increase in Development‐caused traffic going directly north and south on Radford across Oxnard (intersection 15). Since there very clearly would be an increase, I think the DEIR finding intentionally understates the traffic increase for this intersection and is probably just as understated at other intersections.

This traffic study appears to be wrong and needs to show the increased traffic correctly. I, and my family, live immediately south of Oxnard from this proposed 742 rental units and I reject having more cars using our quiet streets for their high‐speed shortcut and that's what will occur with residents of 742 units being late for work. High‐density rentals often are accompanied by increasing degradation to a neighborhood. This project need a big reduction in those rentals.

Response to Comment No. 32-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Regarding intersection #15, as shown in Draft EIR Tables 4.M-11 and 4.M-12, the Project would result in a less than significant impact at this intersection. Even with the addition of Project traffic, this intersection would continue to operate at LOS A during both the AM and PM peak hours. See also Response to Comment No. 6-3 regarding traffic on the residential streets surrounding the Project Site and Response to Comment No. 28-1 regarding traffic on Tiara Street.

The remainder of the comment provides the commenter’s opinions about the Traffic Study, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 32-5

I don't have the time to try to find all errors and misstatements in this DEIR but from what I can see, it look like a set‐up, managed‐outcome document that underplays problems with a lot of words appearing to cover the environmental issues but that actually lacks legitimacy.

Response to Comment No. 32-5

The comment provides the commenter’s opinion about the EIR, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinion is acknowledged for the record. In addition, the EIR reflects the independent judgment and analysis of the City of Los Angeles Department of City Planning.

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Comment No. 32-6

This project has too many rental units and not enough retail when this community needs more retail and clearly no monster apartment project. The project needs to be fundamentally changed to more closely comply with the underlying zoning and replace the former retail mall with new retail.

Response to Comment No. 32-6

As discussed above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4. Further, as discussed in Response to Comment No. A5-35, residential uses are consistent with the existing C4 zoning that applies to a large portion of the Project Site, and are also consistent with the proposed C2 zoning for the Project Site.

Comment No. 32-7

Alternative 4 has more retail but the same 742 residential units so it's still unacceptable. Alternative 4 needs to be further changed with a significant portion of the rentals replaced with individually‐owned units. Alterative 4 also needs to reduce the total number of units significantly including a lower profile and more setback. This can't be some small, ineffective reduction, that the developer and their governmental friends try to convince the community that "it's can't be reduced or the project will be cancelled".

At a community meeting, the council aide implied that some minor reduction might be done but that the councilman had limits (of reductions and changes he’d support) to avoid having the whole project cancelled. This aide seemed those attending to be setting the stage for effectively siding with the developer. The community won't be bullied by these kinds of veiled threats (to cancel the project) while heating politician's claims of "working with the community" when they're actually helping the developer make the community accept this awful 742 rental units, maybe less a few units that the councilman would proudly tell us he got reduced. This project needs much more than a tacit change. It needs a significant change. I and virtually all our local neighbors won't be satisfied by minor reductions or improvements. We accept some added traffic due to rebuilding the retail that existed until the early 1990's and we'll walk to the retail. I don't accept this development forcing significant quality‐ of‐life loss on our neighborhood from the proposed 742 high‐density apartment units in my neighborhood.

The city should not allow this almost‐entirely single‐family home neighborhood to be ruined by this huge multi‐unit rental residential project right next to us. It's too much.

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Response to Comment No. 32-7

The commenter’s preference for the Project to include some individually owned units is acknowledged for the record.

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LETTER NO. 33

Robin Wells 6156 Simpson Ave North Hollywood, CA 91606

Comment No. 33-1

This letter is intended to express my concern regarding The New Laurel Plaza Development Plans. First and foremost, I AM NOT IN FAVOR OF THIS PLAN. If there is any way I can protest this development, please let me know whom to contact.

Response to Comment No. 33-1

The comment provides the commenter’s opposition to the Project, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 33-2

Some of my concerns are as follows:

Response to Comment No. 33-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, as well as the reduction of some of those impacts that would occur if Alternative 4B were selected.

Comment No. 33-3

Response to Comment No. 33-3

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

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Comment No. 33-4

3. The overflow and increase of this project will also lead to frustration, and added time for this community to an already heavy commute they face

Response to Comment No. 33-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Comment No. 33-5

4. I’m concerned that with the addition of low income rental units, will lead to more of a chance of burglaries, drug traffic, and gang activity.

Response to Comment No. 33-5

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

Comment No. 33-6

What the area needs is a park or more open space for the community, who work and live here in the neighborhood. There are additional points of interest that I would like to address, at a later date, if given an opportunity.

Response to Comment No. 33-6

See Responses to Comment Nos. A5-4 and A5-48 regarding the proposed public open space in the Project.

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LETTER NO. 34

Yoav and Theresa Getzler 5934 Carpenter Ave Valley Village, CA 91607

Comment No. 34-1

My wife Theresa and I have lived at 5934 Carpenter Ave south of Oxnard for 19 years. After reviewing the Draft EIR I noticed our street Carpenter Ave and its intersection with Oxnard was not studied for the impacts that will effect us. We have many cars that speed down our street cutting over from Colfax to Oxnard. With the construction of NoHo West I can only imagine this project will increase traffic on our street. Please ask the developers to include Carpenter Ave between Colfax and Oxnard and all the intersection. The maps of the traffic studies conveniently leave Carpenter Ave off the maps.

Response to Comment No. 34-1

The intersections analyzed in the Traffic Study were selected in consultation with, and approved by, LADOT. Although Carpenter Avenue was not analyzed in the Traffic Study, the adjacent intersections of Oxnard & Radford and Oxnard & Colfax were studied and it was determined there would be no significant impacts at those intersections. Project traffic would be unlikely to use Carpenter Avenue as it does not provide an advantageous or faster route for those accessing or exiting the Project, primarily because there are unsignalized intersections at both Oxnard and Colfax making it harder to turn into or out of the street. As shown in Figures 4.2 and 4.3 of the Traffic Study (Figures 4.M-7 and 4.M-8 of the Draft EIR), only a very small amount of Project traffic – 8 AM peak hour trips and 12 PM peak hour trips - is estimated to use Colfax Avenue and no Project traffic is estimated to utilize Carpenter Avenue.

Comment No. 34-2

We want more commercial space and less residential, the residential should be mixed with the commercial space not jammed into a corner.

Here are some of my other concerns. The Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial.

I request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail space.

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Response to Comment No. 34-2

See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR as well as regarding the placement of the residential uses on the Project Site.

Comment No. 34-3

I request that the residential/commercial buildings for the proposed final Project not exceed 45’ feet in height. Residential and/or commercial buildings along Erwin Street and Radford Avenue should not exceed 3 stories.

Response to Comment No. 34-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 34-4

I request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets . The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 34-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Comment No. 34-5

Response to Comment No. 34-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

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Comment No. 34-6

Response to Comment No. 34-6

Comment No. 34-7

Response to Comment No. 34-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 34-8

The Project is not consistent with the North Hollywood ‐ Valley Village Community Plan. The Plan specifies that the low‐density residential character of North Hollywood ‐ Valley Village should be preserved and that single‐family residential neighborhoods be protected from encroachment by other types of uses.

Response to Comment No. 34-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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LETTER NO. 35

Jay Hofstadter 6238 Ben Avenue North Hollywood, CA 91606

Comment No. 35-1

I am only a renter in the area and have no vested interest as I probably would have moved by the time that the subject development would have been completed. However, I believe that the proposed project as presented would negative impact the community for the reasons outlined in the letter attached herewith.

I am a resident who lives one-half block from the proposed redevelopment of the Macy’s property, as referenced above. As a real estate broker, I am not opposed to redevelopment of the property, and, indeed, I would welcome development to its highest and best use, but I believe that the proposal that has been submitted to the Planning Department does not fulfill that objective nor is it conformity with the Community Plan and I therefore respectfully request that the project be rejected for the following reasons:

I believe that much of the data supplied by the developer is highly suspect, that it grossly misrepresents the impact to the community by substantially overstating the number of trips generated by shoppers to and employees of Macy’s, and even factoring in the traffic generated by the other tenants of the property, Kaplan College and Laurel Hall, the figures provided are exponentially off, with some speculating that the intent was to underestimate the impact it would have on the community, thereby lessening the traffic mitigation that would be required of them.

Response to Comment No. 35-1

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

The remainder of the comment provides general introductory information, which is acknowledged for the record, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

Comment No. 35-2

The proposed development would be one of the highest density projects in the City, with the residential income (apartment) component alone being many times larger than any currently in the East San Fernando Valley and, indeed more than doubling the number of dwelling units for the entire multi-block neighborhood bounded by the major streets in the area. Moreover, the developers propose a community dog park, which I believe would be barely adequate to service the needs of the proposed tenants, and

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without any consideration for the parking that would be necessary were it to be available to the public. Add to that the commercial uses of the project, and one can envision a traffic nightmare dwarfing almost anything in the Greater Los Angeles area, even without considering what would be created in any redevelopment of the Valley Plaza property or the property north of Victory in and around Sears Valley Plaza. I believe that consideration be given to revising the Specific Plan to something like the Ventura Corridor.

Response to Comment No. 35-2

See Responses to Comment Nos. A5-4 and A5-48 regarding the open space proposed as part of the Project.

See Response to Comment No. A5-81 regarding the Project’s parking demand as well as the proposed parking supply.

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Finally, see Response to Comment No. A5-43 regarding potential development of the Valley Plaza property.

Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 35-3

The developers propose a restriping of the roadways and installation of a CCTV camera to mitigate traffic, a totally ridiculous solution. I believe that, at a bare minimum, Laurel Canyon Boulevard and Oxnard Street would need to be widened to three full-width lanes in each direction, plus on-street metered parking during non-peak hours and no parking during peak hours, as well as right turn lanes and traffic signals, including directional arrows. The island to the north of the project on Erwin Street should be repaired and redesigned to retain the buffer that separates the single-family residential area from the commercial, and Erwin Street to the south of the island and Radford Avenue to the east of the project should be widened to two lanes in each direction, plus on-street metered parking.

Response to Comment No. 35-3

The mitigation measures identified in the Draft EIR (Mitigation Measures M-1 through M-7) were shown to be effective and to fully mitigate the traffic impacts at all impacted intersections, with the exception of Oxnard Street and Laurel Canyon Boulevard, where the impact is only partially mitigated. LADOT has reviewed and approved all of the included mitigation measures. To implement the improvements proposed by the commenter along Laurel Canyon Boulevard and Oxnard Street, a significant amount of additional right-of-way would need to be acquired, resulting in the potential demolition of existing businesses and the loss of a substantial amount of on street parking relied upon by nearby businesses. For these reasons, among others, additional mitigation at the intersection of Oxnard Street and Laurel Canyon

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Boulevard was deemed infeasible by LADOT (see Draft EIR, pages 4.M-31 and 4.M-32). The scope of the improvements proposed by the commenter are also substantially greater than the Project is required to implement to mitigate Project-related traffic impacts. As such, the improvements suggested by the commenter for Oxnard Street and Laurel Canyon Boulevard are not feasible.

As suggested by the commenter, the island median currently located within the Erwin Street roadway will be repaired and updated to continue to act as a buffer separating the residential neighborhoods to the immediate north of the Project Site from the proposed commercial and multi-family segments of the Project.

Widening Radford Avenue and Erwin Street would require substantially more right-of-way than is currently available and is a substantially greater improvement than is required to mitigate the Project’s traffic impacts. As such, the improvements suggested by the commenter for Radford Avenue and Erwin Street are not feasible.

Comment No. 35-4

The onramp and off-ramp to the 170 freeway should be widened to three lanes each and traffic signals, including directional arrows. The City might also want to consider an extension of Metrorail and a station on the property or nearby, with the developer contributing to the cost to mitigate traffic, most especially since it is envisioned as a mini-city.

Response to Comment No. 35-4

The mitigation measures proposed at the intersection of SR-170 Northbound Ramps & Oxnard Street (Draft EIR Mitigation Measure M-5, which includes restriping the eastbound approach to provide an exclusive right-turn lane and modifying the existing traffic signal to include an eastbound right-turn overlap phase) fully mitigate the Project’s impact at this location. LADOT reviewed and approved the proposed mitigation. Therefore, no additional improvements are needed at this location. The scope of the improvements proposed by the commenter are also substantially greater than what is required of the Project to mitigate Project-related traffic impacts. Additionally, see Response to Comment No. A1-3 regarding the applicable screening thresholds for potential impacts to Caltrans facilities, including freeway segments and ramps.

The commenter’s suggestions regarding extension of the Metro rail system are beyond the scope of analysis for this Project, but are acknowledged for the record.

Comment No. 35-5

The traffic to and from the development itself should also be addressed. I believe that a project of this scope requires more than the six driveways that are proposed. I note that there are more in the current development. Also, half of those proposed access/exit points would be onto Erwin Street and Radford Avenue, and I believe that the traffic from just the residential component of the project would overburden and create a traffic nightmare for the surrounding residential areas.

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Response to Comment No. 35-5

As stated in the Draft EIR at pages 4.M-38 and 4.M-39, the Traffic Study analyzed all of the Project driveways and found that they would operate at LOS D or better (with many operating at LOS A and LOS B) and without any significant impacts. LADOT has conducted a review of the Project Site and has determined that the proposed number of driveway locations is adequate.

As part of the Traffic Study, impact analyses were conducted at all Project driveways on Erwin Street and Radford Avenue, and at the intersections of Radford Avenue & Victory Boulevard and Radford Avenue & Oxnard Street. The analysis indicates that all driveway locations are expected to operate at LOS D or better, which has been confirmed by LADOT. In addition, both intersections were shown to currently operate at LOS A and are expected to continue to operate at LOS A with the construction of the Project. As discussed in Response to Comment No. 6-3, a supplemental traffic analysis was conducted at the Radford Avenue & Erwin Street intersection which shows that the intersection also currently operates at LOS A and is expected to continue to operate at LOS A with the construction of the Project.

Comment No. 35-6

The submitted parking proposal seems woefully inadequate, with the developer requesting concessions for shared parking below those minimally required by code. If this were not an aggregate lot, there would be multiple city streets and blocks within the site currently anchored by Macy’s. Such a configuration would provide some semblance of guest parking for visitors to the proposed residential development. The only parking for such purpose under the currently proposed plan would only be on Erwin Street and on Radford Avenue. It is likely that guests and, in many cases, additional tenants, as well as spillover shoppers and employees of the commercial establishments, under the proposed development would use the adjoining streets for parking. Therefore, streets to the north of the island on Erwin Street, and perhaps on the east side of Radford Street, should also be permit parking available to residents only, and any parking fees for any such permits should be paid by the developer or any subsequent owner of the property. Additionally, it should be noted that NBC-Universal tries to be a good neighbor to Studio City residents by providing them free parking passes.

Response to Comment No. 35-6

See Response to Comment No. A5-81 regarding the number of parking spaces proposed for the Project, as well as the number of spaces that would be provided. As the Project would provide ample parking for its uses, overflow parking into the surrounding neighborhood is not anticipated.

Comment No. 35-7

The developer is insulting the intelligence of the City and public by claiming that there will be no appreciable increase in water consumption and waste water in any redevelopment from an underutilized and underperforming mall to a very high density development. Putting aside the increase in the size of the commercial component of the project and the fact that the use would change from a mall with very little

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traffic save seasonally to commercial and offices with many more people there year-round, I anticipate that there would be much higher water usage from the proposed restaurants, health club/gym, theatres, etc. Additionally, there would also be 742 apartments, each with at least one toilet and sink, as well as a shower and/or bathtub, plus community laundries, etc. I would imagine that the City will be requiring landscaping for the project in excess of the blacktopped lot surface that is currently there, adding to water usage.

Response to Comment No. 35-7

See Responses to Comment Nos. A5-83 through A5-86 regarding the Project’s impacts with respect to water and wastewater.

Comment No. 35-8

On a personal note, I and my neighbors would lose whatever views we have of the mountains to the south because of the proposed height of the improvements, and the developer wants a waiver to build higher than what is allowed by code. I propose that any development along Erwin Street or Radford Avenue be stepped from a maximum height of three stories or 45’ to mitigate any impact to the adjacent residential community.

Response to Comment No. 35-8

See Response to Comment No. A5-2 regarding Project impacts with respect to views. In addition, see Response to Comment No. A5-4 regarding the height of the Project.

Comment No. 35-9

Lastly, at the end of the day, I would like whatever development to be there to be successful, and my observation is that the most successful projects in the City of Los Angeles and surrounding municipalities, such as Santa Monica, Glendale, etc., and in other areas throughout California and internationally are mixed-use, creating a more pedestrian friendly environment than those such as the proposed project with separate commercial and residential components.

For all of the above reasons, and more, I humbly request that the project as submitted be denied.

Response to Comment No. 35-9

Regarding the placement of the proposed commercial and residential components on the Project Site, see Response to Comment No. A5-4.

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LETTER NO. 36

Douglas A Ross 5854 Radford Ave Valley Village, CA 91607

Comment No. 36-1

As a 16 year resident of Valley Village and a member of the Laurel Grove Neighborhood Association, I am writing to urge you to help me and my neighbors by ensuring that the proposed development of the Macy’s lot — currently called the NoHo West Project — will be managed by the city with care and respect for the current residences of the area.

We take great pride in our peaceful, safe and friendly neighborhood and it would be devastating to our community to have careless and excessive development at the Macy’s lot.

Response to Comment No. 36-1

The comment provides the commenter’s opinion, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 36-2

Most concerning to me is the potential for increased traffic, parking issues on my street, and even the potential for increases in crime in the neighborhood.

Response to Comment No. 36-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

Comment No. 36-3

I respectfully ask you to request a traffic study for the traffic flow along my street ‐ Radford Ave — and the adjacent residential streets.

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Response to Comment No. 36-3

See Response to Comment No. 6-3 regarding traffic on Radford Avenue and other residential streets.

Comment No. 36-4

Please make sure that the proposed development has adequate parking to comply with the city code

Response to Comment No. 36-4

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 36-5

Please make sure that the number of apartment units approved is reasonable for the neighborhood. Certainly the current plan to build over 700 units on that tiny parcel of land does not make sense for the neighborhood when there are only approximately 700 single family homes in the many blocks surrounding the proposed development. Please limit the number of approved apartment units to a realistic number.

Response to Comment No. 36-5

Comment No. 36-6

Also, please work to ensure that the new develop is genuinely “mixed use” so that as the neighborhood is developed, it is done with an eye toward a healthy, sustainable and safe future.

Response to Comment No. 36-6

The Project is considered a mixed-use development as it includes both residential and commercial uses. Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

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LETTER NO. 37

Gilbert Stein 6205 Gentry Ave North Hollywood, CA 91606

Comment No. 37-1

I own the property at the corner of Erwin and Gentry and would be greatly affected by the conversion of the Macy property to a residential park. Adding over 700 units on that property will change the community character. It will create noise and traffic that is not acceptable in our community. the EIR report says that traffic will be unmitigated. I assume that means that it will be a nightmare. Allowing residential buildings of the height envisioned in the plan is unreasonable. It should be no more than 3 stories high and should be on a busy street, not adjacent to existing residential property. If it must be done, then the condos should be on Laurel Canyon or Oxnard.

Response to Comment No. 37-1

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Responses to Comment Nos. A5-37 through A5-40 regarding Project impacts with respect to noise.

See Responses to Comment No. A5-4 regarding the proposed height of the Project and the placement of the residential and commercial uses on the Project Site.

Comment No. 37-2

Without a separate off-ramp from the Freeway, or local streets will be clogged to the point that emergency vehicles may not be able to navigate them.

Response to Comment No. 37-2

As discussed in Response to Comment No. 35-4, Mitigation Measure M-5 would fully mitigate the Project’s impact at the intersection of SR-170 Northbound Ramps & Oxnard Street. LADOT has reviewed and approved this mitigation, accordingly no additional improvements are needed at this location. In addition, see Response to Comment No. A5-42 for a general discussion of the Project’s traffic impacts. Finally, as discussed on Draft EIR pages 4.L.1-16 through 4.L.1-19, with compliance with applicable provisions of the Fire Code, Project impacts with respect to emergency access would be less than significant.

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Comment No. 37-3

I actually look forward to a multi-use project. Theaters and restaurants would be welcome. However, the idea of that many new residents without a new traffic plan is not acceptable to me. Adding over a thousand new residents will have an adverse affect on the existing population and infrastucture.

Response to Comment No. 37-3

See Responses to Comment Nos. A5-41 through A5-44 regarding impacts with respect to population and infrastructure.

The comment states that adding residents without a “new traffic plan” is unacceptable. It is unclear what kind of traffic plan the commenter is requesting. Therefore, please see Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Comment No. 37-4

I urge the city to reject the current plans and demand that the developers either reduce the number of residential units or pay for the cost of improving the infrastructure

Response to Comment No. 37-4

The Project would be responsible for certain infrastructure improvements, including traffic mitigation (Draft EIR Mitigation Measures M-1 through M-7), any required public right-of-way improvements and street dedication, and upgrades to water and wastewater infrastructure (Regulatory Compliance Measures N.1-2 and N.2-1) if necessary to serve the Project.

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LETTER NO. 38

Todd Shea 6240 Morella Avenue North Hollywood, CA 91606

Comment No. 38-1

It is with concern that I submit this email. The Laurel Grove Neighborhood Association provided its members with a detailed review of the draft DEIR submitted to the LGNA board. The Association did an excellent job of explaining the report in detail and outlining a number of concerns

I purchased a single-family home in Laurel Grove a little over 2 years ago. The area was attractive due to low-traffic congestion, charming and quaint single family homes, and reasonably-priced housing.

As a purchaser, I understood the potential for development in the area. However, after living in Toluca Lake for many years, I moved with the confidence that our city council representatives would provide this area with the same protections against over development that I had experienced with Tom LeBonge's office in Toluca Lake, diligently working to protect the character of the area while encouraging reasonable and controlled development.

Furthermore, I am shocked as are many of my neighbors by the lack of response from the developer about the number of apartments compared to the mixed use that is proposed for this project and about the developers apparent dis-concern over issues that have been raised.

Response to Comment No. 38-1

The comment provides general introductory information but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comment is acknowledged for the record.

Comment No. 38-2

Following are our immediate concerns:

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City of Los Angeles June 2016

Response to Comment No. 38-2

Partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR.

Comment No. 38-3

Response to Comment No. 38-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 38-4

Response to Comment No. 38-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding the impacts at the Project driveways, see Response to Comment No. 10-4.

Comment No. 38-5

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Response to Comment No. 38-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 38-6

5) The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are in deed unavoidable then the scope of the project needs to be re-scaled to accommodate traffic issues. We request that the Final EIR mitigate the traffic issues and/or reduce the residential scope of the project to address significant traffic issues described in the Draft EIR.

Response to Comment No. 38-6

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the reduced impacts of Alternative 4B, which has been added to this Final EIR and which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

Comment No. 38-7

Response to Comment No. 38-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 38-8

7) The Project is not consistent with the North Hollywood - Valley Village Community Plan. The Plan specifies that the low-density residential character of North Hollywood - Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses (i.e. a densely populated apartment “city” with 742 units).

Your offices immediate attention in addressing these issues prior to the Final DEIR would be appreciated.

Response to Comment No. 38-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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City of Los Angeles June 2016

LETTER NO. 39

Doris Tinius 12335 Califa St Valley Village, CA 91607

Comment No. 39-1

Dear Milena Zasadzien - I feel compelled to write you again regarding Project NoHO West. This time I'm referring to the statement within the "Notice of Completion and Availability Draft Environmental Impact Report ENV-2015-888-EIR, SCH NO. 2015041001,"ANTICIPATED SIGNIFICANT EFFECTS".

It's stated that this Project "would have significant unmitigated traffic impact at two intersections in the future plus project condition". It is impossible to ascertain exactly how many people will be occupying this property, under consideration, at any one given time. However considering the description currently drawn, including multi family residences, office spaces, theater, gym, shops, restaurants etc. I can guesstimate that the figure would be approximately 5,000 people. This number equals 200 people per acre, an enormous number for a parcel this size.

Response to Comment No. 39-1

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

The remainder of the comment provides the commenter’s opinion about the number of people who would occupy the Project Site at any given time, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 39-2

How will these cars traveling to and from this project get onto the freeway at Oxnard? How will they exit off the 170 freeway at Oxnard coming from both the south and/or north? The northern Oxnard off ramp is extremely short and already dangerous in its design nearly colliding with Victory's on ramp onto the 170. Both sides of the freeway will be majorly negatively impacted complete with danger and tragic consequences! Needless to say the volume of traffic on the surface streets, both large and smaller streets, will increase dramatically with negative repercussions. Oxnard will move at a snails pace in both directions as well as Laurel Canyon and surrounding streets. I mention these streets because these are the ones I am very familiar with. Radford and Erwin will be a nightmare.

Response to Comment No. 39-2

Vehicles traveling between the Project Site and SR-170 Freeway would use the Project driveway on Oxnard Street to the existing on- and off-ramps located in close proximity to the Project Site. Vehicles traveling south would access the SR-170 Freeway using the southbound on-ramp located west of the

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freeway and east of Laurel Canyon Boulevard. Vehicles traveling north would access the freeway using the northbound on-ramp located immediately south of the Project’s East Oxnard entrance.

Vehicles traveling to the Project Site from the north would either exit at Victory Boulevard and travel south along Laurel Canyon Boulevard, or exit at Laurel Canyon Boulevard and continue south to Oxnard Street. Vehicles traveling to the Project Site from the south would exit at Oxnard Street and travel directly into the Project via the East Oxnard Street entrance.

The Traffic Study evaluated the specific freeway mainline and off-ramp thresholds using thresholds identified in the signed MOU between LADOT and Caltrans, dated October 2013, to determine whether further analysis of SR-170 freeway mainline or off-ramps in the area surrounding the Project Site was needed. It was determined in consultation with LADOT that Project traffic did not meet or exceed any of the applicable thresholds; and therefore, no Project impacts to the freeway are anticipated.

As documented in the Traffic Study, impacts of Project traffic have been fully analyzed on nearby street intersections. Mitigation measures were identified and analyzed at all impacted locations and these improvements were shown to reduce the incremental increase in traffic volumes generated by the Project to a level of insignificance at all locations with the exception of Laurel Canyon Boulevard & Oxnard Street and Lankershim Boulevard & Oxnard Street. At those two locations, the proposed mitigation measures would partially mitigate the impact.

Specific impact analyses were conducted at the intersections of Radford Avenue & Victory Boulevard and Radford Avenue & Oxnard Street as part of the Traffic Study. Both intersections were shown to currently operate at LOS A and are expected to continue to operate at LOS A with the construction of the Project. Additionally, in response to comments on the Draft EIR, a supplemental impact analysis was conducted at the Radford Avenue & Erwin Street intersection which shows that the intersection also currently operates at LOS A and is expected to continue to operate at LOS A with the construction of the Project. This supplemental analysis is contained in Appendix E of this Final EIR.

The remainder of the comment about the freeway design is acknowledged for the record.

Comment No. 39-3

May I ask why are we trying to ruin the quality of life in this vicinity? Why are we placing people's lives in jeopardy? If the statement reads "UNMITIGATED TRAFFIC IMPACT" why would this particular project ever be allowed to develop? Why would building zone changes be allowed? How could any responsible person allow plans of such a magnitude to be advanced in an area inadequate in size?

All of this scares me. I now understand why non typical political candidates seem to be currently in favor. People are feeling voiceless and helpless in their communities with big business having the final word. We need our community leaders, many of which we voted for, to stand up for us and do what is inherently right.

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City of Los Angeles June 2016

Response to Comment No. 39-3

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including a discussion of the reduction of these impacts for Alternative 4B.

The remainder of the comment provides the commenter’s opinion, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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City of Los Angeles June 2016

LETTER NO. 40

Mark Amorello 11885 Tiara Street Valley Village, CA 91607

Comment No. 40-1

Upon review, the Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in the number of residential units integrated with the commercial. I along, with my neighbors request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail space, and should not exceed 3 stories, with the commercial buildings to not exceed 45 feet in height.

Response to Comment No. 40-1

See also Response to Comment No. A5-4 regarding the proposed height.

Comment No. 40-2

We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets . The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 40-2

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at Project driveways, please see Response to Comment No. 10-4.

Comment No. 40-3

With my property so close to Laurel Plaza, I can confidently say that the traffic study’s assumption of present, weekday vehicle trips to and from the Macy’s store of 10,639 is highly fabricated and at

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best the current weekday vehicle trips to Macy’s to and from are no more than 500 customers per day. We again request that a traffic study be conducted using realistic assumptions, and that the latest June 2015 Caltrans report on the 170 Freeway be used, instead of the 2012 Cal Trans report which was used in the Draft EIR.

Response to Comment No. 40-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 40-4

Response to Comment No. 40-4

Comment No. 40-5

Response to Comment No. 40-5

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 40-6

The Project is not consistent with the North Hollywood - Valley Village Community Plan. The Plan specifies that the low-density residential character of North Hollywood - Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses.

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Response to Comment No. 40-6

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 40-7

This project has the potential to be a positive improvement to the area and community, but certain provisions MUST be provided by the City and Developer to insure the integrity of the surrounding neighborhoods, not to mention overall safety/crime concerns

Response to Comment No. 40-7

See Response to Comment No. A5-46 regarding the Project’s impacts to police protection services.

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City of Los Angeles June 2016

LETTER NO. 41

Joey Banks

Comment No. 41-1

My name is Joey Banks and I have lived in the Laurel Grove area for 11 years and I moved here for the quite no sidewalks or street light feel of my street. Morella. What you wanting to do is insane. Think about the people in this area that will be impacted in the RESIDENTIAL area. The company that did the environmental report is stoned. If you think that this project will not impact us is foolish. You cannot allow the amount of people that your proposing to integrate into our quite neighborhood. I oppose it, the earthquake fault line intersect with the apt complex. And the amount of people will be overwhelming for the Oxnard exit

Response to Comment No. 41-1

See Response to Comment No. A5-23 regarding the location of the closest active fault to the Project Site.

See Response to Comment No. A5-52 regarding Project impacts on the Oxnard exit from the 170 freeway.

The remainder of the comment provides the commenter’s opinions about the Project and the EIR, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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City of Los Angeles June 2016

LETTER NO. 42

Melissa Mariano 11912 Tiara Street Valley Village, CA 91607

Comment No. 42-1

I just want to take this opportunity to thank you in advance for your support and assistance during this lengthy and complex process. As one of many proud homeowners who will be significantly impacted by the proposed project, I look to your office (as well as other city offices and officials) to help protect our community of almost entirely modest, single family homes. We are all genuinely excited at the prospect of redevelopment of this site, but we hope that our wishes and concerns of the currently proposed plan, as addressed in the attached letter, will be at the forefront as your office addresses this project moving forward.

One last point if I may ‐ After viewing the Draft Environmental Impact Report and Alternative plans put forth by the developer of this project, I do not feel the developer and its contractors put in the care and effort this community deserves. This was very disappointing. Please help us create the beautiful and responsible development that we all want and need for this community.

Response to Comment No. 42-1

The comment provides the commenter’s opinions about the Project and the EIR, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

The attached letter referenced in the comment refers to form letter Y7. Please see Responses to Comment Letter Y1 for responses to this form letter.

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City of Los Angeles June 2016

LETTER NO. 43

Suzette Sheets LGNA 6031 Simpson Avenue North Hollywood, CA 91606

Comment No. 43-1

The Laurel Grove/NoHo West proposed project is an opportunity to be a significant and important addition to this area of Los Angeles. This is a strong community with many historic homes in very desirable "pocket neighborhoods" with genuine pride in ownership. The project could enhance this neighborhood and other neighborhoods surrounding it. It could unite all of the neighborhoods with a community gathering place and perhaps tum into a real retail and cultural destination which requires much thinking, planning and designing with a broader perspective than currently portrayed in the Draft EIR. The developers for The Grove and Americana Brand achieved this. Look what happened to a couple of tired and forlorn areas of Los Angeles that now aid the local economy which is crucial for a city that is so cash strapped.

But this ideal can't happen with the addition of 742 apartment type residential units. Now the project becomes an unrealistic idea that will ultimately only serve to raise crime (as mentioned in the DElR), traffic, parking and overcrowding. How can you explain the logic of cramming this multitude of housing into such a small area of the project? Please have the Final EIR provide an alterative plan with fewer residential units spread over the entire site as well as being integrated with the retail and commercial space.

Response to Comment No. 43-1

See Response to Comment No. A5-46 regarding the Project’s impacts with respect to police protection services.

See Response to Comment No. A5-42 regarding the Project’s traffic impact, including the impacts of Alternative 4B, which has been added to this Final EIR and is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

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See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Finally, see also Response to Comment No. A5-4 regarding the proposed open space.

The remainder of the comment provides the commenter’s opinion about the Project, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 43-2

Please do another realistic and current traffic study in the Final EIR and include the traffic along Radford Avenue and Erwin Street not to mention the neighboring residential streets which will be getting all of the overflow traffic from the main streets due to over population with the new project and also retail and commercial customers. Also to be included in this study are intersections between Victory Blvd, Colfax Ave, Laurel Canyon Blvd and Burbank Blvd but most importantly, during peak hours. Please note that 3 of the project's 6 driveways directly affect the residential streets adjacent to the project.

Response to Comment No. 43-2

See Responses to Comment Nos. 6-3 and 34-1 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at the Project driveways, see Response to Comment No. 10-4.

Comment No. 43-3

When doing the new traffic study with realistic data, make sure to use the latest June 2015 Caltrans report on the 170 freeway instead of the 2012 Caltrans report which was used in the Draft EIR erroneously. The traffic study's assumption of present, weekday vehicle trips to and from the Macy's store of 10,639 is false and misleading. Honestly, it is more like 500 customers to and from Macy's per day.

Response to Comment No. 43-3

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

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Comment No. 43-4

The Final EIR should mitigate the traffic issues which the Draft EIR stales are significant and unavoidable. If this is in indeed the case, then obviously the project needs to be downsized. Especially the residential aspect. Something has to give here or we will be faced with the ultimate and unnecessary ghettoization of this area This kind of oversight would be unacceptable.

Response to Comment No. 43-4

Comment No. 43-5

The Draft EIR did not indicate the total number of parking spaces required to comply with the City Code, according to the Department of Transportation (DOT). The DOT must be provided with the correct number of parking spaces required to comply with the City Code. Even the City Codes cannot possibly accommodate the actual parking needs.

Response to Comment No. 43-5

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 43-6

The Project needs to take into serious consideration the North Hollywood- Valley Village Community Plan. This plan specifies that the low density residential character of North Hollywood- Valley Village should be preserved and also that single family residential neighborhoods be protected from encroachment by other types of uses. The project as analyzed in the Draft EIR fails to meet this request.

Response to Comment No. 43-6

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 43-7

The DElR makes unrealistic assumptions about present water and sewage usage at Laurel Plaza new study needs to be done using historical data from the Department of Water and Power.

Response to Comment No. 43-7

See Response to Comment No. A5-83 regarding water and sewage estimates for the existing uses.

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City of Los Angeles June 2016

Comment No. 43-8

DO NOT TURN OUR NEIGHBORHOOD INTO A MINI CITY/GHETTO.

We are currently facing a dramatic homeless situation here with open sewage from mobile homes being dumped along Laurel Canyon Blvd. There was a recent murder on Laurel Canyon Blvd in the vast homeless encampment between Oxnard Blvd and Victory Blvd. The proposed project will only continue to perpetuate these kinds of problems. Please use this prime opportunity for a development that can unify and improve the surrounding area and neighborhood.

Response to Comment No. 43-8

See Response to Comment No. A5-46 regarding the Project’s impacts with respect to police protection services. The remainder of the comment provides the commenter’s opinion about existing conditions in the neighborhood, which is acknowledged for the record.

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City of Los Angeles June 2016

LETTER NO. 44

Roy Stein 6205 Gentry Ave North Hollywood, CA 91606

Comment No. 44-1

I am writing this letter to express my concerns regarding the NoHo West development plan. There are certain elements of the plan that are welcomed and others that are not. I hope that you and your colleagues pay attention to the concerns of the citizens who are contacting you about this project.

I welcome the fact that this project would bring a restaurant, movie theater, grocery store and generally be a place to congregate. I like that a giant parking lot is going to some use as well.

My issues with the proposal are simple and should be addressed before it goes any further. ‐ The lot is zoned Commercial, and this project will not only add residential units, it will be incredibly dense.

‐ The plan to place all of the residential units in one corner of the lot, which happens to be away from the major streets that border the project, is insulting. Major apartment building, especially of the scale and magnitude of those proposed, are always bordering major thoroughfares. It would be out of character for the neighborhood and an affront the people living in single family homes right next to them.

Response to Comment No. 44-1

Regarding the zoning of the Project Site, as discussed in Response to Comment No. A5-35, residential uses are consistent with the existing C4 zoning for the Project Site, and are also consistent with the proposed C2 zoning for the Project Site. Regarding density, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

See also Response to Comment No. A5-4 regarding the placement of the proposed residential and commercial uses on the Project Site.

Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 44-2

‐ The height of the proposed buildings is taller than any residential buildings for miles. Why so huge?

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Response to Comment No. 44-2

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 44-3

‐ 742 homes in a tiny space like that, surrounded by single family homes is in‐congruent with proper city planning and goes directly against the North Hollywood‐Valley Village Community plan.

Response to Comment No. 44-3

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan. In addition, as discussed above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 44-4

‐ The draft EIR is completely flawed and borderline fraudulent when assessing daily trips to/from the current Macy's lot. This absurdly false number of 10,000 daily trips has impacted other numbers in the study and must be corrected.

Response to Comment No. 44-4

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 44-5

‐ Traffic is not addressed in any way. I know development brings people with it, that's one of the points of this whole projects. But the fact that there has been no mention of how traffic will be addressed in ANY way is absurd and a total failure on the part of the developer. Traffic will increase regardless, but there must be something done to avoid it being an unmitigated to the current and future residents of the neighborhood.

Response to Comment No. 44-5

The Draft EIR contains analysis of traffic impacts based on the Traffic Study including proposed mitigation measures (Draft EIR pages 4.M-60 through 4.M-63), reviewed and approved by LADOT. See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including reductions in traffic impacts if Alternative 4B is selected.

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City of Los Angeles June 2016

Comment No. 44-6

PLEASE take these concerns seriously and alter this project to better serve the city and residents of my neighborhood. I don't want this project stopped, just changed. You can help make that happen and benefit not only my little neighborhood but the entire west San Fernando valley.

Suggestions include reducing the amount of residences allowed on the property, addressing the traffic issues in some way, making the project mixed‐use throughout instead of parceling out sections of the lot, and adding more commercial space.

Please help make this happen.

Response to Comment No. 44-6

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

See Response to Comment No. A5-4 regarding the placement of the proposed residential and commercial uses on the Project Site.

Nevertheless, the commenter’s opinions and suggestions are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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City of Los Angeles June 2016

LETTER NO. 45

Wesley Davis 6333 Carpenter Avenue North Hollywood, CA 91606

Comment No. 45-1

In May 2015 and in response to the Initial Study for the proposed NoHo West (Laurel Plaza) Project, many neighbors to the project wrote to you that, as envisioned, it is inconsistent with the North Hollywood – Valley Village Community Plan. We asked that the project be altered to agree with the Plan’s objective “that the low-density residential character of North Hollywood – Valley Village be preserved and that single – family neighborhoods be protected from encroachment by other types of uses.” The preferred project as analyzed in the Draft Environmental Impact Report (DEIR) fails to meet this request. We request a significant reduction in the number of apartments.

Response to Comment No. 45-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 45-2

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Response to Comment No. 45-2

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Regarding the height of the Project, please also see Response to Comment No. A5-4.

Comment No. 45-3

We neighbors of Laurel Plaza know without a doubt that the traffic study’s assumption of present, weekday vehicle trips to and from the Macy’s store of 10,639 is unrealistic. At best the current weekday vehicle trips to Macy’s to and from are no more than 500 customers per day. Other cherrypicked traffic assumptions, including failure to use the most current June 2015 Caltrans study of the 170 freeway are similarly unsupportable. The Department of Planning needs to request that both the City Department of Transportation and Caltrans review the DEIR traffic study. The apartment development as proposed and sited will inevitably cause commuters to seek alternatives within the adjacent residential streets to avoid the already congested Oxnard Street. The traffic study in the DEIR did not address increased traffic flow along Radford Ave and Erwin Street, it only evaluated Oxnard St and Laurel Canyon Blvd. We request that the Final EIR include a traffic study along Radford Avenue and Erwin Street. We request that the study also include neighboring residential streets and intersections between Victory Blvd, Colfax Ave, Laurel Canyon Blvd and Burbank Blvd during peak hours. The DEIR listed the influx of traffic as significant and unavoidable, providing no real solutions to the significant increase in traffic that this project will bring.

Response to Comment No. 45-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. 6-3 regarding the potential impacts to Erwin Street and Radford Avenue, as well as other residential streets.

Finally, while the Draft EIR does conclude that impacts would be significant and unavoidable, this is only at two intersections whereas the impacts to the remaining intersections would be less than significant with implementation of the mitigation measures provided in the Draft EIR. See also Response to Comment No. A5-42 regarding the Project’s traffic impacts.

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Comment No. 45-4

Response to Comment No. 45-4

See Responses to Comment Nos. A5-83 through A5-86 regarding water and sewage estimates for the existing uses.

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City of Los Angeles June 2016

LETTER NO. 46

Patricia Jackson

Comment No. 46-1

I share the concerns raised by the Laurel Grove Neighborhood Association (LGNA) about the above proposed project. It is very kind for developers to propose this, but I very strongly concur with LGNA’s concerns. In particular, I think it is foolish to be thinking about building more housing before addressing serious infrastructure failures in our area. These include:

· Very poor quality retail at Victory Boulevard and above. There appear to be a substantial number of landlords doing nothing to improve properties. Businesses in these areas are a jumbled mess. In instances where there are national retailers here and in other parts of Los Angeles my experience has been that the national retailer in our general area always underperforms relative to other areas. Local shops fail to do things like post opening hours, clearly identify products offered or prices charged. Basically by bringing in this many people you are going to place even heavier demands on the little bits of retail OUTSIDE of our area that support residents in this area. This is going to have a very negative impact on me and my family.

Response to Comment No. 46-1

Responses to the concerns raised by the Laurel Grove Neighborhood Association are contained in Responses to Comment Letter A5.

The comments about other retail opportunities in the area does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the comments are acknowledged for the record.

Comment No. 46-2

· Traffic is heavily bottlenecked at various points in this area. The few functional retail areas (such as Vallarta Markets or Olive Market on Oxnard Ave.) create near‐traffic disasters during peak travel time right now without all the cars and traffic you will be bringing in with this development.

Response to Comment No. 46-2

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

The locations mentioned in the comment, Vallarta Market and Olive Market, are located at approximately study intersections #1 (Victory Boulevard and Coldwater Canyon Avenue) and #5 (Whitsett Avenue and Oxnard Street), respectively. However, even with the addition of Project traffic, impacts at each of these intersections would be less than significant (see Draft EIR Tables 4.M-11 and 4.M-12).

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Comment No. 46-3

· My children have not benefited from a single development project in this area. The most spectacular failure was in the VNSO park several years ago when construction grade fill was used in the soccer fields resulting in STONES yes, STONES being dumped onto soccer playing fields. I tried to be involved with a recent installation of artificial turf in VNSO, another poorly‐conceived project. Somehow there were no public hearings ever held pointing out that the effect of this project would be to BISECT the entire VNSO park. This has substantial implications for park planning. THIS AREA HAS NO TEMPLATE FOR FUNCTIONAL PUBLIC SPACE PLANNING. This is particularly disasterous when a large development is built such as what is being proposed. Park and sports facilities in this area are way, way oversubscribed. I don’t see where this issue is addressed in the proposal, but it should be.

Response to Comment No. 46-3

See Responses to Comment Nos. A5-4 and A5-48 regarding the open space proposed as part of the Project. The remainder of the comment about the VNSO is regarding an off-site property and issues that are not related to the Project, and does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, this comment is acknowledged for the record.

Comment No. 46-4

· No progress on a proposed development on Victory Blvd. There is a major development project on Victory Boulevard that continues to stall out. Why that billboarded are has not been turned into a park in the meantime is beyond me. I am tired of developers having eminent domain to create placarded dead spaces in major public areas.

Response to Comment No. 46-4

The comment about a proposed development on Victory Boulevard is regarding an off-site property and issues that are not related to the Project, and does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, this comment is acknowledged for the record.

Comment No. 46-5

· Our family uses very, very few resources in this area. I wonder if the same thing would happen with a large‐scale development like this. The problem of “rotted retail” also includes Van Nuys Boulevard which has tent cities of homeless people and basically entire rows of vacant storefronts.

Response to Comment No. 46-5

The comment provides the commenter’s opinions but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

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Nevertheless, this comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 46-6

· Where is there an overall plan for this area that addresses public spaces? This is a gaping need. However I am well familiar with the fact that these public spaces get “loved to death” and run down typically in under 6 months in this area. What is it about our area that makes it so difficult for people to come together and manage public space so that we all benefit? I see this in other parts of Los Angeles, but at this time it is very uneven and/or absent in this area. It makes it difficult to really consider a project like this one, as there is abundant evidence of failed developer visions in our midst.

Response to Comment No. 46-6

See Responses to Comment Nos. A5-4 and A5-48 regarding the open space proposed as part of the Project. The comments about the need for an overall plan for public spaces does not state a specific concern or question about the Project or Draft EIR.

Comment No. 46-7

Sorry, wish I had more positive to say about this, but it is very frustrating to live in an area where there is so much pervasive mismanagement of public space. Why is it so difficult to maintain things others have already built that do have some architectural beauty and interest?

Response to Comment No. 46-7

The comment provides the commenter’s opinions but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, this comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. 47

Dennis White

Comment No. 47-1

My Name is Dennis White. I live at 6239 Ben Ave, in the shadow of the Macy’s building. This project is of the utmost concern to me and my neighbors, and we all appreciate your help in representing our interests to the city and the developer.

This is not a form/ cut/ paste letter, so please take the time to read it if you get a moment.

While I know that I speak for most of us when I say that we welcome the project to our neighborhood, we do have areas of concern. This is overwhelmingly an owner occupied neighborhood there are no fewer than 4 homes on my block alone where the owners have lived here since the 70’s. We take pride in our neighborhood, and we all feel pretty burned by that last developer Snyder that put on a show about how nice his development was going to be, bought most of the buildings on laurel between erwin and victory, let them sit vacant and get run down over a number of years, and now we’ve got to live with this straight‐ up blight on the street‐ which really brings our neighborhood down in terms of perception and home values. We really don’t want to be screwed over by another developer, and with the greatest respect, when I got to the part of the EIR that stated their report was based on an "estimated 10,000 weekday vehicle trips to and from Macy’s” Alarm bells went off in my head because I live here and work out of my home, walking my dog twice a day, and I don’t think that traffic in an out of that place could even be half of that. So, this tells me that the Developer’s report lacks credibility, and respect for our neighborhood.

Response to Comment No. 47-1

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

The remainder of the comment provides introductory information as well as the commenter’s opinions, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 47-2

As a matter of urgency and civic duty, I respectfully request that you strenuously represent out major concerns on this project, which are:

Fewer apartments than the proposed 742. our neighborhood simply can’t sustain that.

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Response to Comment No. 47-2

Comment No. 47-3

Mixed Use throughout the development

Response to Comment No. 47-3

The Project is considered a mixed-use development in that it includes both commercial and residential uses in a unified development. Regarding the placement of the proposed commercial and residential uses on the Project Site, see Response to Comment No. A5-4.

Comment No. 47-4

Traffic Abatement

Response to Comment No. 47-4

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Comment No. 47-5

Parking consideration. The best thing about this neighborhood is the fact that there is ample parking here. WE CAN’T ROLL OVER AND LET THE DEVELOPER TURN THE PARKING SITUATION HERE IN TO THAT OF KOREA TOWN OR HOLLYWOOD, WHERE RESIDENTIAL STREET PARKING IS STATISTICALLY CLOSE TO IMPOSSIBLE TO FIND.

Response to Comment No. 47-5

Comment No. 47-6 and Height Restrictions on the apartments. I think they are proposing 6 stories?? that’s crazy for this neighborhood.

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Response to Comment No. 47-6

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 47-7

Again‐ we really want a development here, but we don’t want our neighborhood and lifestyle ruined in the process. ANYONE on the other side of this equation would feel the exact same way

Please submit the attached letters to the pile.

Many thanks for your time‐ please don’t hesitate to call me at any time about this

Response to Comment No. 47-7

The comment provides the commenter’s opinions, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

The attached letters referenced in the comment are form letters Y6 and Z4. See Response to Comment Letters Y1 and Z1 for responses to these form letters.

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LETTER NO. 48

Laurie Hobird 57611 Radford Avenue Valley Village, CA 91607

Comment No. 48-1

That said, please be advised that the NoHo West (Laurel Plaza) Project is not consistent with the North Hollywood - Valley Village Community Plan. Quoting the Community Plan, the Plan “proposes that the low-density residential character of North Hollywood - Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses.”

I am greatly concerned that the largest component of the NoHo West (Laurel Plaza) project, as it is currently being presented by the developer, is the 742 apartments totaling 816,200 sq. feet. The smallest portion of the project is the retail component at a mere 300,000 sq. feet. This should not be a residential project with some retail, it needs to be a retail project with some residential.

Response to Comment No. 48-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 48-2

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they are four stories high. They are huge at four stories…NoHo West is proposing adding an additional two stories on top of that totaling six stories in a neighborhood of single family homes and small apartment buildings that stand no more than two stories high. Six stories is too high, it’s too intrusive, and will not at all blend in with the character of our neighborhood. Again, we request that the apartments be no higher than three stories. No one wants people peering into the school next door.

Response to Comment No. 48-2

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Regarding the height of the Project, please also see Response to Comment No. A5-4.

In addition, partly in response to comments requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). The design of Alternative 4B reduces the height of the residential units along Calvert Place from six stories to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School. Abundant landscaping would also be provided between the Project Site and the Laurel Hall School.

Comment No. 48-3

The proposed Project will significantly increase traffic in the area. The Draft EIR claims that there will be a net increase of only 19 cars per day during peak traffic hours. This is complete hogwash! As I understand it, the numbers are based on square footage of the existing Macy’s building…a building that is way less than fully utilized as it is a retail store, not actual automobile counts, and converting it to 500,000 square feet of office space will OBVIOUSLY increase the daily person count and therefore daily car count and traffic. This Macy’s has been in decline for years and years and traffic to and from Macy’s totals 500 vehicles per day or less, if even that many. I find it completely irresponsible of the developer to honestly believe that adding 742 apartments plus all the proposed retail will only bring in an additional 19 cars per day during peak traffic hours. This is irrational and unbelievable. The added vehicle traffic is going to be a complete nightmare without serious traffic mitigation. Combined commercial and residential vehicles at the Project site will generate a minimum of 3,000 additional vehicles per day in the area, if not more. As it currently stands, traffic during the weekday mornings and afternoons (starting at 4/4:30pm and into the early evening) is backed up on Oxnard Street heading westbound, blocking Radford Avenue and trailing to Colfax Avenue. I request that data collection for the traffic studies be done during peak-days and peak-hours, non-holiday weeks, and when schools are in session so that traffic mitigations are appropriately implemented. I request that the traffic study for the final EIR be conducted at several affected intersections, not just at Oxnard and Laurel Canyon. Traffic flow also needs to be studied at Oxnard and Radford (where traffic is already a nightmare during morning drive time and evening drive time), Radford and Erwin, and Laurel Canyon and Erwin. I would like to have left turn

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arrows added all around to all traffic lights at the intersections of Laurel Canyon & Burbank Blvd, Laurel Canyon & Oxnard Street, Colfax & Burbank, Colfax & Oxnard, and at Lankershim Blvd at Oxnard.

Response to Comment No. 48-3

See Response to Comment No. A5-42 regarding the Project’s traffic impacts and Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

Comment No. 48-4

Specifically relating to Radford Avenue south of Oxnard Street, I would like to have Radford Avenue at Oxnard Street blocked off to vehicular traffic heading south on Radford from Oxnard and heading north on Radford to Oxnard. Considering the amount of new traffic that this development will bring to the area, and considering that this area of Radford Avenue is already used a cut through to Colfax, Burbank Blvd, and the 170 freeways on ramps (both north and south), our 100% residential Radford Avenue should not be used for traffic flow for NoHo West (Laurel Plaza). The enclave of Radford Avenue south of Oxnard Street is filled with young families and older original homeowners who walk the neighborhood, walk to and from school with their small children, bike ride, ride scooters, cross the street to neighbors’ houses, play in their front yards, etc. We are a very active pedestrian neighborhood. Nonresident traffic already flies down the street regularly at speeds from 35-50 mph with no regard for residents, children, and pets. We simply cannot afford any additional traffic without great risk to the residents, and specifically to the children.

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put these young people at risk of being hit as they often are wearing earbuds and are walking in the street both to and from school. Blocking off Radford Avenue at Oxnard Street to vehicular traffic would be another way to ensure the safety of all pedestrians who enjoy our neighborhood.

This can be accomplished while still keeping the crosswalk for pedestrians. For instance, ideally the street would be blocked off by putting in a nice median with medium size trees (perhaps in large pots or large wine barrels or large wooden tree boxes) for beautification and to help clean the air and add shade. Trees would be a nice touch and in keeping with the beauty of the new development. As an alternative, the street can be blocked with k-rails (which would be our last choice solution since K-rails are unattractive and a magnet for graffiti). We could even be satisfied with a northbound, right hand (east) exit only onto eastbound Oxnard Ave from Radford Ave.

Response to Comment No. 48-4

Regarding cut through traffic, see Response to Comment No. A5-64.

Comment No. 48-5

For the Laurel Hall School, for children in 1st grade and above, there needs to be a designated drop off lane for any drop off students within the proposed development located on the west side of the school. Drop off on Radford Avenue is not a viable option. Parents need a safe, dedicated lane protected from traffic, not a traffic flow street, on which they can safely drop their children off and not affect street traffic.

It would also be appreciated to have a designated parking area for all Laurel Hall parents (and staff) since, understandably for safety concerns, parents of Transitional Kindergarten and Kindergarten students (4, 5 & 6 year olds) are not allowed to drop their children at the gate at school. They must park their vehicle and walk their children to their classroom. Also, for pickup of all children, the parking area needs to be safe and a reasonable distance from the school without traipsing through NoHo West (Laurel Plaza). It is

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unrealistic to have parents park in a parking structure far from the school to walk their TK and Kindergarteners to and from school and to pick up their older kids.

Response to Comment No. 48-5

The Traffic Study and Draft EIR were conducted under the assumption that the surface parking lots on which Laurel Hall School and Emmanuel Lutheran Church visitors have been parking are to be fully redeveloped as part of the Project, and that all drop off/pick-up activities currently occurring on the surface parking lots would be conducted on-site at Laurel Hall School. In addition, the Project would provide 50 parking spaces located in the parking structure by lease agreement for use by Laurel Hall teachers and staff. However, the commenter’s opinions about the Laurel Hall School drop-off are acknowledged for the record and will be forwarded as part of this Final EIR to the decision-making bodies for their review and consideration.

Comment No. 48-6

Response to Comment No. 48-6

Project impacts with respect to population and housing are addressed in Draft EIR Section 4.K., and as provided therein, impacts would be less than significant.

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Comment No. 48-7

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residents and shoppers are kept safe, in addition to those of us already here. The City of Glendale had to add additional police and fire stations with their residential and retail growth because of these very circumstances and examples, and our community deserves the same with the developer picking up the tab and not the taxpayers.

Response to Comment No. 48-7

Comment No. 48-8

We want and need Laurel Plaza developed. We are not opposed to development. What we are opposed to is a Draft EIR that seems to have cherry picked the best data available – and some data just downright wrong and ridiculous! – while ignoring and not including the negative data or other very important data from the likes of CalTrans, DOT, proper geology report, correct earthquake/liquefaction information, and/or using old and out dated traffic information.

Response to Comment No. 48-8

The Draft EIR was prepared under the direction of and reflects the independent judgment of the City of Los Angeles Department of City Planning. The comment references alleged inadequacies in the Draft EIR concerning Caltrans, DOT, geologic data and traffic data, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

Finally, see Response to Comment No. A5-50 regarding traffic data.

Comment No. 48-9

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Response to Comment No. 48-9

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LETTER NO. 49

James and Fiona Garrett 6054 Rhodes Ave North Hollywood, CA 91606

Comment No. 49-1

I’ve been a resident/home owner on 6054 Rhodes Ave. North Hollywood, 91606 location for 30 years. I have been waiting for constructive improvements in my area especially at the Laurel Plaza and the Valley Plaza areas for several years. The NoHo (Laural Plaza) Residential/Commercial Project Proposal has recently been brought to my attention by the Laurel Grove Neighborhood Association.

I would like to express the following concerns I have with this proposal.

Response to Comment No. 49-1

The comment provides general introductory information but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR.

Comment No. 49-2

First of all the Draft EIR does not consider the alternative as requested by LGNA of a true mixed use project with a substantial reduction in number of residential units integrated with the commercial. The proposed 700 units is too much for our small residential area. This should be at most half that. We request that the Final EIR provide an alternative with fewer residential units spread over the entire site and integrated within the retail area.

Response to Comment No. 49-2

See Response to Comment No. A5-4 regarding the number of units proposed and potential changes to the Project based on comments received on the Draft EIR.

Comment No. 49-3

2nd We requested that the residential/commercial buildings along Erwin Street and Radford Avenue should not exceed 3 stories.

Response to Comment No. 49-3

See Response to Comment No. A5-4 regarding the proposed height.

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Comment No. 49-4

3rd We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laural Canyon Blvd. As proposed, 3 of the project’s 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 49-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

Regarding impacts at the Project driveways, see Response to Comment No. 10-4.

Comment No. 49-5

4th We neighbors if Laurel Plaza know without a doubt that the traffic study’s assumption of present, weekday vehicle trips to and from the Macy’s store of 10,639 is unrealistic. At best current weekday vehicle trips to Macy’s to and from are no more than 500 customers per day. We request that a traffic study be conducted using realistic assumptions, and that the latest June 2015 Caltrans report on the 170 Freeway be used, instead of the 2012 Cal Trans report which was used in the Draft EIR.

Response to Comment No. 49-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 49-6

5th The Draft EIR states that many of the traffic issues are significant and unavoidable. If they are in deed unavoidable then the scope of the project needs to be reduced. We request that the Final EIR mitigate the traffic issues and/or reduce the residential scope of the project to address the significant traffic issues described in the Draft EIR. Heck, have you ever gotten off the 170 Freeway at Oxnard during high peak times? This should give you a clue to an already congested area.

Response to Comment No. 49-6

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See Responses to Comment Nos. A5-52 and A5-75 regarding the Project’s impacts with respect to the Oxnard Street & SR-170 Off-ramp intersection.

Comment No. 49-7

6th The department of Transportation (DOT) report says the Draft EIR did not indicate the total number of parking spaces required to comply with the City code. We request that the DOT be provided with the number of parking spaces required to comply with the City code.

Response to Comment No. 49-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 49-8

7th The project is not consistent with the North Hollywood – Valley Village Community Plan. The plan specifies that the low-density residential character o North Hollywood – Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment be other types of uses.

Response to Comment No. 49-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. 49-9

Finally, it is my opinion that the character of our community be upgraded esthetically and be considered as a viable middle class neighborhood with successful commercial shopping areas and perhaps the inclusion of Trader Joes and/or Whole Foods. This community is rich with middle class families with average income above $75,000 who live in single family homes. It is an organic community that wishes to have safe schools, good clean successful retail shops close by, excellent transportation with reduced auto traffic and an esthetically pleasing well landscaped environment in which to live. It should be an area in which even the developers would want to live in. This consideration should be the main goal of any future projects in our area.

Response to Comment No. 49-9

See Responses to Comment Nos. A5-2 through A5-13 regarding the Project’s impacts with respect to aesthetics. The comment provides the commenter’s opinions about the neighborhood and the Project, which are acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

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LETTER NO. 50

Andrea Schmitt 12318 Erwin Street North Hollywood, CA 91606

Comment No. 50-1

Please see the signed letter attached. The proposed scale of this project will overwhelm the already limited ability of this area of North Hollywood to absorb the traffic overflow. The Oxnard exit ramp on the 170 Northbound Freeway is already frequently backed up at peak periods, due to westbound traffic on Oxnard. This creates a traffic hazard on the freeway, as well as impacting the livability and accessibility of the neighborhood.

I am happy to answer any questions you may have. I look forward to your response.

Response to Comment No. 50-1

The attached letter referenced in the comment refers to Form Letter Y10. Please see Responses to Comment Letter Y1 for responses to this form letter.

See Response to Comment No. A5-42 for a discussion of the Project’s traffic impacts, including the reduced impacts of Alternative 4B.

See Responses to Comment Nos. A5-52 and A5-75 regarding the Project’s impacts with respect to the Oxnard Street & SR-170 Off-ramp intersection.

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LETTER NO. 51

Michelle Hobird 5761 Radford Avenue Valley Village, CA 91607

Comment No. 51-1

Response to Comment No. 51-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

In addition, partly in response to comments requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail/restaurant uses when compared to the Project. Additional specifics about Alternative 4B are provided in Response to Comment No. A5-4.

Comment No. 51-2

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Response to Comment No. 51-2

Regarding the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Regarding the height of the Project, please also see Response to Comment No. A5-4.

In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). The design of Alternative 4B reduces the height of the residential units along Calvert Place from six stories to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School.

Comment No. 51-3

The proposed Project will significantly increase traffic in the area. The Draft EIR claims that there will be a net increase of only 19 cars per day during peak traffic hours. This is complete hogwash! As I understand it, the numbers are based on square footage of the existing Macy’s building…a building that is way less than fully utilized as it is a retail store, not actual automobile counts, and converting it to 500,000 square feet of office space will OBVIOUSLY increase the daily person count and therefore daily car count and traffic. This Macy’s has been in decline for years and years and traffic to and from Macy’s totals 500 vehicles per day or less, if even that many. I find it completely irresponsible of the developer to honestly believe that adding 742 apartments plus all the proposed retail will only bring in an additional 19 cars per day during peak traffic hours. This is irrational and unbelievable. The added vehicle traffic is going to be a complete nightmare without serious traffic mitigation. Combined commercial and residential vehicles at the Project site will generate a minimum of 3,000 additional vehicles per day in the area, if not more. As it currently stands, traffic during the weekday mornings and afternoons (starting at 4/4:30pm and into the early evening) is backed up on Oxnard Street heading westbound, blocking Radford Avenue and trailing to Colfax Avenue. I request that data collection for the traffic studies be done during peak-days and peak-hours, non-holiday weeks, and when schools are in session so that traffic mitigations are appropriately implemented. I request that the traffic study for the final EIR be conducted at several affected intersections, not just at Oxnard and Laurel Canyon. Traffic flow also needs to be studied at Oxnard and Radford (where traffic is already a nightmare during morning drive time and evening drive time), Radford and Erwin, and Laurel Canyon and Erwin. I would like to have left turn arrows added all around to all traffic lights at the intersections of Laurel Canyon & Burbank Blvd, Laurel Canyon & Oxnard Street, Colfax & Burbank, Colfax & Oxnard, and at Lankershim Blvd at Oxnard.

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Response to Comment No. 51-3

See Response to Comment No. 48-3.

Comment No. 51-4

Specifically relating to Radford Avenue south of Oxnard Street, I would like to have Radford Avenue at Oxnard Street blocked off to vehicular traffic heading south on Radford from Oxnard and heading north on Radford to Oxnard. Considering the amount of new traffic that this development will bring to the area, and considering that this area of Radford Avenue is already used a cut through to Colfax, Burbank Blvd, and the 170 freeways on ramps (both north and south), our 100% residential Radford Avenue should not be used for traffic flow for NoHo West (Laurel Plaza). The enclave of Radford Avenue south of Oxnard Street is filled with young families and older original homeowners who walk the neighborhood, walk to and from school with their small children, bike ride, ride scooters, cross the street to neighbors’ houses, play in their front yards, etc. We are a very active pedestrian neighborhood. Non-resident traffic already flies down the street regularly at speeds from 35-50 mph with no regard for residents, children, and pets. We simply cannot afford any additional traffic without great risk to the residents, and specifically to the children.

This can be accomplished while still keeping the crosswalk for pedestrians. For instance, ideally the street would be blocked off by putting in a nice median with medium size trees (perhaps in large pots or large wine barrels or large wooden tree boxes) for beautification and to help clean the air and add shade. Trees would be a nice touch and in keeping with the beauty of the new development. As an alternative, the street can be blocked with k-rails (which would be our last choice solution since K-rails are unattractive and a magnet for graffiti). We could even be satisfied with a northbound, right hand (east) exit only onto eastbound Oxnard Ave from Radford Ave.

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Response to Comment No. 51-4

See Response to Comment No. 48-4.

Comment No. 51-5

Response to Comment No. 51-5

See Response to Comment No. 48-5.

Comment No. 51-6

Response to Comment No. 51-6

See Response to Comment No. 48-6.

Comment No. 51-7

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Hollywood division currently covers. With additional residents and retail, unfortunately comes additional crime that will need to be dealt with.

Response to Comment No. 51-7

See Response to Comment No. A5-45 regarding Project impacts with respect to fire protection (including emergency response), and Response to Comment No. A5-46 regarding Project impacts with respect to police protection.

Comment No. 51-8

Response to Comment No. 51-8

See Response to Comment No. 48-8.

Comment No. 51-9

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Response to Comment No. 51-9

See Response to Comment No. 48-9.

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LETTER NO. 52

Gabriel Szasz 6127 Colfax Ave North Hollywood, CA 91606

Comment No. 52-1

I am a long time resident of this neighborhood and I'm in support of the NoHo West project! It's very much needed in this neighborhood. There is nothing walking distance in the area and the current Macy's lot is a depressing old eyesore.

Response to Comment No. 52-1

The comment provides the commenter’s opinion of support for the Project, which is acknowledged for the record and will be forwarded to the decision-making bodies as part of the Final EIR for their review and consideration.

Comment No. 52-2

I do believe the amount of residential units should be scaled back in order to be more acceptable to the immediate neighbors. I rather see increased retail and open air space over residential units. In any case, I would love some version of the plans to move forward and fast as possible.

Response to Comment No. 52-2

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City of Los Angeles June 2016

LETTER NO. 53

Carol Rosenthal 6248 Morella Avenue North Hollywood, CA 91606

Comment No. 53-1

There was a meeting of the Laurel Grove Neighborhood Association on Wednesday, 1/27/16 to review the draft DElR submitted to the Laurel Grove Neighborhood Association board.

Diane Corral of the LGNA board outlined all the details at this meeting. Many of the people in our neighborhood are very concerned about the lack of response from the developer about the number of apartments compared to the mixed use that is proposed for this project.

I have been a resident of this neighborhood for the past 35 years and I am very worried about the impact on our neighborhood.

Following are my immediate concerns

Response to Comment No. 53-1

The comment provides general introductory information, which is acknowledged for the record. Regarding the number of apartments proposed, see Response to Comment No. A5-4.

Comment No. 53-2

Response to Comment No. 53-2

Comment No. 53-3

2) We request that the residential/commercial buildings for the proposed final Project not exceed 45' feet in height. Residential and/or commercial buildings along Erwin Street and Radford Ave should not exceed 3 stories.

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City of Los Angeles June 2016

Response to Comment No. 53-3

See Response to Comment No. A5-4 regarding the proposed height.

Comment No. 53-4

3) We request that the traffic study in the Final EIR address the traffic flow along Radford Avenue and Erwin Street and neighboring residential streets. The Draft EIR only addressed traffic along Oxnard Street and Laurel Canyon Blvd. As proposed, 3 of the project's 6 driveways directly affects the residential streets adjacent to the project.

Response to Comment No. 53-4

See Response to Comment No. 6-3 regarding impacts to the intersection of Radford Avenue & Erwin Street and other residential streets.

See Response to Comment No. 10-4 regarding impacts associated with the Project’s driveways.

Comment No. 53-5

4) We, the neighbors of Laurel Plaza, know without a doubt that the traffic study's assumption of weekday vehicle trips to and from Macy's store of 10,639 is unrealistic. This Macy's is old and rundown and, at best, current weekday vehicle trips to and from this Macy's location is no more than 500 customers per day. We suggest contacting this Macy's location and getting their daily customers counts. We additionally request that a traffic study be conducted using realistic assumptions and the latest June 2015 Cal Trans report on the 170 Freeway be used instead of the 2012 Cal Trans report which was used in the Draft EIR.

Response to Comment No. 53-5

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

See Response to Comment No. A5-52 regarding the difference between the 2012 and 2015 Caltrans reports.

Comment No. 53-6

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Response to Comment No. 53-6

See Response to Comment No. A5-42 regarding the Project’s traffic impacts, including the reduced impacts of Alternative 4B, which has been added to this Final EIR.

Comment No. 53-7

Response to Comment No. 53-7

See Response to Comment No. A5-81 regarding the parking requirements as well as the amount of parking proposed.

Comment No. 53-8

7) The Project is not consistent with the North Hollywood- Valley Village Community Plan. The Plan specifies that the low-density residential character of North Hollywood- Valley Village should be preserved and that single-family residential neighborhoods be protected from encroachment by other types of uses (i.e. a densely populated apartment "city" with 742-units).

Thank you in advance for your prompt attention to all of the above mentioned concerns. We look forward to the Final DEIR incorporating our requests.

Response to Comment No. 53-8

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

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City of Los Angeles June 2016

LETTER NO. Y1

Alison Koire Brustein 5630 Vantage Ave Valley Village, CA 91607

Comment No. Y1-1

In May 2015 and in response to the Initial Study for the proposed NoHo West (Laurel Plaza) Project, many neighbors to the project wrote to you that, as envisioned, it is inconsistent with the North Hollywood - Valley Village Community Plan. We asked that the project be altered to agree with the Plan's objective "that the low-density residential character of North Hollywood - Valley Village be preserved and that single - family neighborhoods be protected from encroachment by other types of uses." The preferred project as analyzed in the Draft Environmental Impact Report (DEIR) fails to meet this request. We request a significant reduction in the number of apartments.

Response to Comment No. Y1-1

See Responses to Comment Nos. A5-3 and A5-4 regarding the Project’s consistency with the North Hollywood – Valley Village Community Plan.

Comment No. Y1-2

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City of Los Angeles June 2016

Response to Comment No. Y1-2

The Draft EIR considers an alternative with a substantial reduction in the number of residential units. Project Alternative 5, analyzed in depth in Section 6, Alternatives to the Project, of the Draft EIR, would reduce the number of residential units to 200, compared to 742 units for the Project, and would increase commercial space to 440,000 square feet of retail, restaurant, health club, and cinema uses, compared to 300,000 square feet for the Project. In addition, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B includes 658 residential units, instead of the 742 residential units analyzed in the Draft EIR, as well as increased commercial space.

Regarding the height of the Project and the placement of the residential and commercial components of the Project on the Project Site, please see Response to Comment No. A5-4.

Comment No. Y1-3

We neighbors of Laurel Plaza know without a doubt that the traffic study's assumption of present, weekday vehicle trips to and from the Macy's store of 10,639 is unrealistic. At best the current weekday vehicle trips to Macy's to and from are no More than 500 customers per day. Other cherry-picked traffic assumptions, including failure to use the most current June 2015 Caltrans study of the 170 freeway are similarly unsupportable. The Department of Planning needs to request that both the City Department of Transportation and Caltrans review the DEIR traffic study. The apartment development as proposed and sited will inevitably cause commuters to seek alternatives within the adjacent residential streets to avoid the already congested Oxnard Street. The traffic study in the DEIR did not address increased traffic flow along Radford Ave and-Erwin Street, it only evaluated Oxnard St and Laurel Canyon Blvd. We request that the Final EIR include a traffic study along Radford Avenue and Erwin Street. We request that the study also include neighboring residential streets and intersections between Victory Blvd, Colfax Ave, Laurel Canyon Blvd and Burbank Blvd during peak hours. The DEIR listed the influx of traffic as significant and unavoidable, providing no real solutions to the significant increase in traffic that this project will bring.

Response to Comment No. Y1-3

See Response to Comment No. A5-70 regarding the number of trips applicable to the existing uses.

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City of Los Angeles June 2016

See Response to Comment No. 6-3 regarding the potential impacts to Erwin Street and Radford Avenue, as well as other residential streets.

While the Draft EIR does conclude that traffic impacts would be significant and unavoidable, these significant impacts are located at two of the study intersections. See also Response to Comment No. A5- 42 regarding the Project’s traffic impacts, including the reduced traffic impacts as a result of Alternative 4B.

Comment No. Y1-4

Response to Comment No. Y1-4

See Responses to Comment Nos. A5-83 through A5-86 regarding water and sewage estimates for the existing uses.

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LETTER NO. Y2

Annabelle Whettam 12358 sylvan St. North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Y3

Deborah and David Shapiro 5841 Radford Avenue Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-282

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LETTER NO. Y4

Laurie Hobird 5761 Radford Ave Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-283

City of Los Angeles June 2016

LETTER NO. Y5

Jennifer McFeely 5760 Radford Avenue Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-284

City of Los Angeles June 2016

LETTER NO. Y6

Dennis White 6239 Ben Avenue North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-285

City of Los Angeles June 2016

LETTER NO. Y7

Melissa Mariano 11912 Tiara Street Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-286

City of Los Angeles June 2016

LETTER NO. Y8

Patrick Horne 11912 Tiara Street Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-287

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LETTER NO. Y9

Steven Heller 5930 Carpenter Avenue Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-288

City of Los Angeles June 2016

LETTER NO. Y10

Andrea Schmitt 12318 Erwin St. North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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City of Los Angeles June 2016

LETTER NO. Y11

Michelle Hobird 5761 Radford Ave Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-290

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LETTER NO. Y12

Evan and Melissa Gwynne 5730 Gentry Ave Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Y13

Mr. and Mrs. Haugen 5642 Beck Ave North Hollywood, CA 91601

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Y14

Shirley Eberts 6123 Carpenter Ave North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Y15

Anthony Mazzucchi 6160 Rhodes Ave North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Y16

Lynn Mazzucchi 6160 Rhodes Ave North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Y1. Therefore, please see the Responses to Comments provided for Letter No. Y1.

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LETTER NO. Z1

Catherine Peterson 5806 Bucknell Avenue

Comment No. Z1-1

We need your help. We are overwhelmingly a neighborhood of single-family, owner-occupied homes. The character of our area and our quality-of-life is threatened by the proposed development at Laurel Plaza of 742 apartments in buildings towering to six-stories in height immediately adjacent to many of our homes. Your support of our concerns is vital to the protections we seek. We request that you work to have the number of apartment units substantially reduced.

Response to Comment No. Z1-1

Comment No. Z1-2

The Laurel Plaza site is a scarce and valuable resource that should be preserved to the greatest extent possible as a retail and commercial destination for the Southwest San Fernando Valley. Its commercial potential needs to be fully developed. The Draft Environmental Impact Report (DEIR) now under review for development there fails to deliver to the local neighborhood the kind of communal, family-friendly gathering spot that has been missing there in the aftermath of the 1994 earthquake. We request that you work with the developer to ensure that the commercial component of this project is significantly increased.

Response to Comment No. Z1-2

As mentioned above, partly in response to comments received requesting a reduction in the number of residential units, the Project Applicant has requested that the City consider Alternative 4B. Therefore, an analysis of Alternative 4B has been added to this Final EIR (see Section 3, Additions and Corrections). Alternative 4B is a reduced project, which includes less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. The Alternative 4B design continues to include a central plaza for community gatherings and commercial components such as cinema and restaurants, as well as a park area for use by the community.

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Comment No. Z1-3

WE WANT development at Laurel Plaza but we know that with development there come both positive and negative results. Inevitably we know there will be increased stress on our already inadequate transportation infrastructure. The massive apartment complex that is proposed is the largest and densest development proposed in the San Fernando Valley. If built, it will lead to ever greater rush-hour congestion as residents of the project go to and from work. An alternative of true mixed-use development with more retail and commercial space and fewer apartments would help ease the extra burden on our local streets. At the same time, with more shopping space and amenities, it could be the community- enhancing addition we seek.

Response to Comment No. Z1-3

See Response to Comment No. A5-42 regarding the Project’s traffic impacts.

Further, as discussed above, the Project Applicant is considering changes to the Project, which include less office use, fewer residential units, and more retail and restaurant uses when compared to the Project.

Comment No. Z1-4

The amount of retail space being proposed for Laurel Plaza is inadequate for it to be a viable alternative to the wide spectrum of shopping choices available in nearby Burbank and Glendale. We don’t understand why Los Angeles does not make the effort to recapture the sales tax revenue now going to those cities by actively soliciting and supporting robust retail redevelopment at both Laurel Plaza and the adjacent and largely vacant Valley Plaza. Short-sighted concentration on large luxury apartment construction should be replaced with far-sighted retail development that brings both long-term benefits to the Southeast Valley and increased tax revenues to a cash-strapped Los Angeles.

Response to Comment No. Z1-4

As mentioned above, the Project Applicant is considering changes to the Project, which include less office use, fewer residential units, and more retail and restaurant uses when compared to the Project. This new Alternative 4B meets one of the Project Objectives - to create a viable balance of commercial and residential uses to economically sustain the Project.

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The comment provides the commenter’s opinions about both the Project and Valley Plaza, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded as part of the Final EIR to the decision-making bodies for their review and consideration.

Comment No. Z1-5

As is well known, The Village at Westfield Topanga, which is exclusively retail, was made possible in part, by a tax-incentive offered its developer by the City, which was UNANIMOUSLY approved by the City Council. If a similar incentive can result in development at Laurel Plaza that is more in line with the desires of the Laurel Grove Neighborhood would you please legislate to get for the East Valley what the council gave to the West Valley.

As our City Councilperson, we are asking you to support your constituents and encourage redevelopment at Laurel Plaza that will make it a commercial destination that is a community-oriented, family-friendly gathering spot for its neighbors and all Angelinos.

Response to Comment No. Z1-5

The comment provides the commenter’s opinions, but does not state a specific concern or question regarding the adequacy of the analysis of environmental impacts contained in the Draft EIR. Nevertheless, the commenter’s opinions are acknowledged for the record and will be forwarded as part of the Final EIR to the decision-making bodies for their review and consideration.

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LETTER NO. Z2

Annabelle Whettam 12358 Sylvan St North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

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LETTER NO. Z3

Debra Nelson Hammons 5853 Bucknell Avenue Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

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LETTER NO. Z4

Dennis White 6239 Ben Avenue North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-301

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LETTER NO. Z5

Patrick Horne 11912 Tiara Street Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-302

City of Los Angeles June 2016

LETTER NO. Z6

Laurie Hobird 5761 Radford Ave Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

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LETTER NO. Z7

Michelle Hobird 5761 Radford Ave Valley Village, CA 91607

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-304

City of Los Angeles June 2016

LETTER NO. Z8

Shirley Eberts 6123 Carpenter Ave North Hollywood, CA 91606

This comment letter is a signed form letter, which is the same as Comment Letter No. Z1. Therefore, please see the Responses to Comments provided for Letter No. Z1.

NoHo West Project 2. Responses to Comments Final Environmental Impact Report Page 2-305

3. ADDITIONS AND CORRECTIONS TO THE DRAFT EIR

INTRODUCTION

This section provides corrections and additions that have been made to the text of the Draft EIR. These changes include revisions, which have been made in response to comments, revisions that are necessary to clarify the Project description, the environmental analysis, or to correct non-substantive errors in the text of the Draft EIR. The corrections and additions are organized by section and page number as they appear in the Draft EIR. Text deleted from the Draft EIR is shown in strikethrough and new text is underlined. None of the following additions or corrections to the Draft EIR disclose a new significant impact or a substantial increase in the severity of a significant and unavoidable impact disclosed in the Draft EIR.

SECTION 1. INTRODUCTION/SUMMARY

No corrections required.

SECTION 2. ENVIRONMENTAL SETTING

The location of Cumulative Project No. 4 has been corrected on Figure 2-12:

NoHo West Project 3. Additions and Corrections to the Draft EIR Final Environmental Impact Report Page 3-1

Source: The Mobility Group, 2016.

Revised Figure 2-12 Cumulative Projects Map City of Los Angeles June 2016

SECTION 3. PROJECT DESCRIPTION

The list of discretionary actions and approvals on pages 3-7 and 3-8 are revised as follows:

1. Zone Change from P-1L, QC4-1L, and C4-1L to (Q)C2-1;

2. Conditional Use Permit for Major Development Project Review;

3. Master CUB for alcohol service in Project restaurants and cinema;

4. Transitional Height determination to allow heights of 63.5 feet in lieu of 61 feet;

5. Conditional Use for Commercial Corner Review determination to allow a height over 45 feet and hours of operation before 7:00 AM and after 11:00 PM;

6. Conditional Use Permit to allow FAR averaging in a unified development project for the Project;

7. Zoning Administrator’s Adjustment to allow a portion of one residential building to observe a 12.5- foot rear yard in lieu of an 18-foot rear yard;

8. Vesting Tentative Tract Map to subdivide the Project Site into five commercial and two residential lots;

9. Site Plan Review for a project over 50,000 square feet and 50 dwelling units;

10. Adoption of a Sign District;

11. Zoning Administrator’s Determination for Shared Parking Approval to allow for shared off-street parking between commercial uses; and

12. Haul Route Approval.

The following is added to the list on page 3-8 under the “Intended Use of the EIR” heading:

 Administrative Review by Successor Agency for Consistency with the Laurel Canyon Commercial Corridor Redevelopment Project Area.

SECTION 4.A. IMPACTS FOUND TO BE LESS THAN SIGNIFICANT

No corrections required.

SECTION 4.B. AESTHETICS

No corrections required.

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SECTION 4.C. AIR QUALITY

The following list on page 4.C-9 is revised as follows:

There are several existing or reasonably foreseeable sensitive receptors near the Project Site, including the following:

 Laurel Hall School and the Early Childhood Center; 11919 Oxnard Street; directly east and south of the Project Site.

 The Early Childhood Center; southeast corner of Calvert Street and Radford Avenue; approximately 60 feet east from the Project Site.

 Emmanuel Lutheran Church; 6020 Radford Avenue, approximately 88 feet southeast of the Project Site.

 11926 Oxnard Street, a single-family residence about 135 feet from the Project Site.

 6120 Radford Avenue, a multi-family residential building between Erwin Street and Calvert Street, 80 feet east of the Project Site.

 6205 Gentry Avenue, a single-family residence, 90 feet east of the Project Site.

The following list on page 4.C-13 is revised as follows:

Construction of the Project could produce air emissions that impact several existing sensitive receptors near the Project Site, including the following:

 Laurel Hall School and the Early Childhood Center; 11919 Oxnard Street; directly east and south of the Project Site.

 The Early Childhood Center; southeast corner of Calvert Street and Radford Avenue; approximately 60 feet east from the Project Site.

 Emmanuel Lutheran Church; 6020 Radford Avenue, approximately 88 feet southeast of the Project Site.

 11926 Oxnard Street, a single-family residence about 135 feet from the Project Site.

 6120 Radford Avenue, a multi-family residential building between Erwin Street and Calvert Street, 80 feet east of the Project Site.

 6205 Gentry Avenue, a single-family residence, 90 feet from the Project Site.

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SECTION 4.D. CULTURAL RESOURCES

No corrections required.

SECTION 4.E. GEOLOGY AND SOILS

No corrections required.

SECTION 4.F. GREENHOUSE GAS EMISSIONS

The following changes outline additional regulatory actions that have been taken to address GHG emissions. These changes are made to Section 4.F of the Draft EIR and would also apply to the analysis of all Project Alternatives.

The following paragraph on page 4.F-5 is revised as follows:

State

California has adopted a series of laws and programs to reduce emissions of GHGs into the atmosphere. Assembly Bill (AB) 1493 was enacted in September 2003 and requires regulations to achieve “the maximum feasible reduction of greenhouse gases” emitted by vehicles used for personal transportation. On June 1, 2005, Governor Schwarzenegger issued Executive Order S-3- 05, which set the following GHG emission reduction targets: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; and by 2050, reduce GHG emissions to 80 percent below 1990 levels. The California Environmental Protection Agency formed a Climate Action Team that recommended strategies that can be implemented by State agencies to meet GHG targets. The CAT reported several recommendations and strategies for reducing GHG emissions and reaching the targets established in the Executive Order. Furthermore, the report that CAT issued in 2006 indicated that smart land use and increased transit availability should be a priority in the State of California. According to the California Climate Action Team, smart land use is an umbrella term for strategies that integrate transportation and land-use decisions. Such strategies generally encourage jobs/housing proximity, promote transit-oriented development (TOD), and encourage high-density residential/commercial development along transit corridors. These strategies develop more efficient land-use patterns within each jurisdiction or region to match population increases, workforce, and socioeconomic needs for the population.

The following information is added to page 4.F-7 above the “State Bill 1368” heading:

As shown in Table 4.F-2, these reductions are to come from a variety of sectors, including energy, transportation, high-global warming potential sources, waste, and the State’s cap-and- trade emissions program.

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Table 4.F-2 Emission Reductions Needed to Meet AB 32 Objectives in 2020

Million Metric Percent of Tons of CO e Statewide CO e Sector 2 2 Summary of Recommended Actions Reduction Inventory

Energy -25 -4.9% Reduce State’s electric and energy utility emissions, reduce emissions from large industrial facilities, control fugitive emissions from oil and gas production, reduce leaks from industrial facilities

Transportation -23 -4.5% Phase 2 heavy-duty truck GHG standards, ZEV action plan for trucks, construct High Speed rail system from SF to LA, coordinated land use planning, Sustainable Freight Strategy

High Global -5 -1.0% Reduce use of high-GWP compounds from Warming Potential refrigeration, air conditioning, aerosols

Waste -2 -0.4% Eliminate disposal of organic materials at landfills, in-State infrastructure development, address challenges with composting and anaerobic digestion, additional methane control and landfills

Cap and Trade -23 -4.5% Statewide program that reduces emissions from Reductions regulated entities through performance-based targets

Total -78 -15.3%

Source: California Environmental Protection Agency, “First Update to the Climate Change Scoping Plan.” May 2014.

Nearly all reductions are to come from sources that are controlled at the statewide level by State agencies, including CARB, Public Utilities Commission, High Speed Rail Authority, and California Energy Commission. The few actions that are directly or indirectly associated with local government control are in the Transportation sector, which is charged with reducing 4.5% of baseline 2020 emissions. Of these actions, only one (GHG reductions through coordinated planning) specifically identifies local governments as the responsible agency.

Cap And Trade

CARB adopted a California Cap-and-Trade Program pursuant to its authority under AB 32. The Cap-and-Trade Program is designed to reduce GHG emissions from major sources (deemed “covered entities”) by setting a firm cap on statewide GHG emissions and employing market mechanisms to achieve AB 32's emission-reduction mandate of returning to 1990 levels of emissions by 2020. The statewide cap for GHG emissions from the capped sectors (e.g.,

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electricity generation, petroleum refining, and cement production) commenced in 2013 and will decline over time, achieving GHG emission reductions throughout the program's duration.

The Cap-and-Trade Program applies to entities that emit more than 25,000 metric tons CO2e per

year. The 25,000 metric tons CO2e per year “inclusion threshold” is measured against a subset of emissions reported and verified under the California Regulation for the Mandatory Reporting of Greenhouse Gas Emissions (Mandatory Reporting Rule or “MRR”). CARB issues allowances equal to the total amount of allowable emissions over a given compliance period. Covered entities are allocated free allowances in whole or part (if eligible), and may buy allowances at auction, purchase allowances from others, or purchase offset credits equal to the amount of Co2e they emit each year.

In sum, the Cap-and-Trade Program will achieve aggregate, rather than site-specific or project- level, GHG emissions reductions. Also, due to the regulatory framework adopted by CARB in AB 32, the reductions attributed to the Cap-and-Trade Program can change over time depending on the State’s emissions forecasts and the effectiveness of direct regulatory measures. As of January 1, 2015, the Cap-and-Trade Program covered approximately 85 percent of California’s GHG emissions. The Cap-and-Trade Program covers the GHG emissions associated with electricity consumed in California, whether generated in-state or imported. Accordingly, GHG emissions associated with CEQA projects’ electricity usage are covered by the Cap-and-Trade Program. Similarly, petroleum refineries and other large industrial facilities are regulated by this Statewide program, ensuring that stationary source emissions from these industrial processes are managed over time. It should be noted that lowered tailpipe emissions from cleaner fuels over time are accounted for separately in the State’s emissions inventory.

The following information is added to page 4.F-11 above the “Executive Order B-30-15” heading:

On April 7, 2016, SCAG adopted its 2016-2040 Regional Transportation Plan Sustainable Communities Strategy update, calling for a continuation of integrated planning for land use and transportation that will help achieve the State’s goal of reducing per capita GHG emissions by eight percent by 2020 compared to 2005 levels, by 18 percent by 2035, and 21 percent by 2040. The RTP/SCS update calls for public transportation improvements that will reduce GHG emissions per household by up to 30 percent. The RTP/SCS would obtain a further one percent reduction in GHG emissions by 2040 from increased use of zero emission vehicles, neighborhood vehicles, and carsharing/ridesourcing.

The RTP/SCS also includes a number of mitigation measures designed to reduce the potential of development to conflict with AB 32 or any other plan designed to reduce GHG. These mitigation measures are particularly important where streamlining mechanisms under SB 375 are utilized. Examples of GHG emissions reduction mitigation measures include the following:

 MM-GHG-3(a)(4): SCAG shall work with utilities, sub-regions, and other stakeholders to promote accelerated penetration of zero- (and/or near zero) emission vehicles in the region, including developing a strategy for the deployment of public charging infrastructure.

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 MM-GHG-3(a)(5): SCAG shall in its capacity as a Clean Cities Coalition establish coordinated, creative public outreach activities, including publicizing the importance of reducing GHG emissions and steps community members may take to reduce their individual impacts.

 MM-GHG-3(a)(6): SCAG shall work with local community groups and business associations to organize and publicize walking tours and bicycle events, and to encourage pedestrian and bicycle modes of transportation such as the “Go Human” Campaign.

 MM-GHG-3(a)(7): SCAG shall support and/or sponsor workshops on water conservation activities, such as selecting and planting drought tolerant, native plants in landscaping, and installing advanced irrigation systems.

 MM-GHG-3(a)(8): SCAG shall in coordination with local jurisdictions (as practicable) support and/or sponsor a periodic Climate Protection Summits or Fairs, to educate the public on current climate science, projected local impacts, and local efforts and opportunities to reduce GHG emissions, including exhibits of the latest technology and products for conservation and efficiency.

 MM-GHG-3(a)(9): Schools Programs: SCAG shall develop and implement a program in coordination with school districts to present information to students about climate change and ways to reduce GHG emissions, and will support school-based programs for GHG reduction, such as school-based trip reduction and the importance of recycling.

 MM-GHG-3(a)(11): SCAG shall encourage local jurisdictions to support the following transportation-related strategies to reduce emissions:

o Support the planning and development of HQTAs, jobs and housing balance, transit oriented development, and infill development through transportation investments and other funding decisions.

o Offer incentives such as free or low-cost monthly transit passes to employees or free ride areas to residents and customers

o Coordinate the funding of low carbon transportation with smart growth development.

o Promote parking management measures that encourage walking and transit use in smart growth areas.

o Develop comprehensive parking policies that encourages the use of alternative transportation

o Incorporate bicycle lanes, routes and facilities into street systems, new subdivisions, and large developments, and create transit, bicycle, and pedestrian connections.

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o Require amenities for non-motorized transportation, such as secure and convenient bicycle parking.

 MM-GHG-3(a)(10): As part of SCAG’s Sustainability Program, SCAG shall assist local jurisdictions in developing Climate Action Plans (CAPs, also known as Plans for the Reduction of Greenhouse Gas Emissions), as appropriate and feasible.

The SCAG RTP/SCS also identifies a number of recommended project-level mitigation measures in its EIR’s Mitigation Measure MM-GHG-3(b), including:

 Measures in an adopted plan or mitigation program for the reduction of emissions that are required as part of the Lead Agency’s decision.  Reduction in emissions resulting from a project through implementation of project features, project design, or other measures, such as those described in Appendix F of the State CEQA Guidelines.  Off-site measures to mitigate a project’s emissions.  Measures that consider incorporation of Best Available Control Technology (BACT) during design, construction and operation of projects to minimize GHG emissions, including but not limited to: o Use energy and fuel efficient vehicles and equipment; o Deployment of zero- and/or near zero emission technologies; o Use lighting systems that are energy efficient, such as LED technology; o Use the minimum feasible amount of GHG-emitting construction materials that is feasible; o Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production; o Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse; o Incorporate design measures to reduce energy consumption and increase use of renewable energy; o Incorporate design measures to reduce water consumption; o Use lighter-colored pavement where feasible; o Recycle construction debris to maximum extent feasible; o Plant shade trees in or near construction projects where feasible; and o Solicit bids that include concepts listed above.  Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to, transit-active transportation coordinated strategies, increased bicycle carrying capacity on transit and rail vehicles;  Incorporating bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; providing adequate bicycle parking and planning for and building local bicycle projects that connect with the regional network;

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 Improving transit access to rail and bus routes by incentives for construction of transit facilities within developments, and/or providing dedicated shuttle service to transit stations; and  Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs.  Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles;  Land use siting and design measures that reduce GHG emissions, including: o Developing on infill and brownfields sites; o Building high density and mixed use developments near transit; o Retaining on-site mature trees and vegetation, and planting new canopy trees;  Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles; and  Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse.

The following information is added to page 4.F-13 above the “Methodology and Significance Criteria” heading:

Local (City of Los Angeles)

Green LA Plan

In May 2007, the City released its Green LA Plan that sets a goal to reduce the generation of GHG emissions 35 percent below 1990 levels by 2030. Key strategies include increasing the generation of renewable energy, improving energy conservation and efficiency, and changing land use patterns to reduce dependence on autos. This Plan included goals for energy, water, transportation, land use, waste, port, airport, and related sources:

Energy

 Increase the generation of renewable energy;

 Encourage the use of mass transit;

 Develop sustainable construction guidelines;

 Increase City-wide energy efficiency; and

 Promote energy conservation.

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Water

 Decrease per capita water use to reduce electricity demand associated with water pumping and treatment.

Transportation

 Power the City vehicle fleet with alternative fuels; and

 Promote alternative transportation (e.g., mass transit and rideshare).

Other Goals

 Create a more livable City through land use regulations;

 Increase recycling, reducing emissions generated by activity associated with the Port of Los Angeles and regional airports;

 Create more City parks, promoting the environmental economic sector; and

 Adapt planning and building policies to incorporate climate change policy.

ClimateLA Implementation Plan

To implement the Green LA Plan, the City published “ClimateLA”, which included a baseline GHG emissions inventory for the City, identified enforceable strategies, and provided a means to monitor and report on progress toward the 2030 goal of reducing GHG emissions by 35 percent from 1990 levels. To achieve these goals, the City developed the following objectives:

 Green Building: The program includes a goal calling for Los Angeles to be a worldwide leader in green buildings. Action E6 calls for a comprehensive set of green building policies to guide and support private sector development.  Energy: Increase the amount of renewable energy provided by the Los Angeles Department of Water and Power, present a comprehensive set of green building policies to guide and support private sector development, reduce energy consumed by City facilities, utilize solar heating where applicable, and help citizens to use less energy.  Waste: Reduce or recycle 70 percent of trash by 2015.  Open Space and Greening: Create 35 new parks, revitalize the Los Angeles River to create open space opportunities, plant one million trees, identify opportunities to “daylight” streams, identifying promising locations for stormwater infiltration to recharge groundwater aquifers, and collaborate with schools to create more neighborhood parks.

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Mobility 2035 Plan

On January 20, 2016, the City adopted its Mobility 2035 Plan, the Circulation Element of its General Plan. The Mobility 2035 Plan focuses on developing a multi-modal transportation system that can address the City’s mobility needs through 2035. The Plan calls for strategies that advance five goals: 1) Safety First, 2) World Class Infrastructure, 3) Access for All Angelenos, 4) Collaboration, Communication, and Informed Choices, and 5) Clean Environments and Healthy Communities. The Mobility 2035 Plan includes key policy initiatives that strengthen the link between land use and transportation planning, targeting GHG reductions through a more sustainable transportation system. The Mobility 2025 Plan also includes a key strategy, Program No. D7, which calls for the development of a GHG tracking program that would quantify reductions in GHG from reductions in vehicle miles traveled.

Green Building Ordinance

The City adopted a Green Building Ordinance in April 2008 that calls for reduction of the use of natural resources for new development. Larger projects must be certified at the Leadership in Energy and Environmental Design (LEED) certified level. LEED certification generally ensures that projects exceed Title 24 (2013) standards by at least 10 percent. The City’s ordinance affects the following types of development:

 New non-residential building or structure of 50,000 gross square feet or more of floor area;

 New mixed-use or residential building of 50,000 gross square feet or more in excess of six stores;

 New mixed-use or residential building of six or fewer stories consisting of at least 50 dwelling units in a building, which has at least 50,000 gross square feet of floor area, and in which at least 80 percent of the building’s floor area is dedicated to residential units;

 The alternation or rehabilitation of 50,000 gross square feet or more of floor area in an existing non-residential building for which construction costs exceed a valuation of 50 percent of the replacement cost of the existing building;

 The alteration of at least 50 dwelling units in an existing mixed-use or residential building, which has at least 50,000 gross square feet of floor area, for which construction costs exceed a valuation of 50 percent of the replacement cost of the existing building.

The City’s Green Building Ordinance includes several requirements that call for reductions in GHG emissions from reducing in energy use, water use, and solid waste generation from new non-residential and high-rise residential buildings, including:

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Section 99.04.304.1. Irrigation Controllers. When automatic irrigation system controllers for landscaping are provided and installed at the time of final inspection, the controllers shall comply with the following:

1. Controllers shall be weather- or soil moisture-based controllers that automatically adjust irrigation in response to changes in plants' needs as weather conditions change;

2. Weather-based controllers without integral rain sensors or communication systems that account for local rainfall shall have a separate wired or wireless rain sensor that connects or communicates with the controller(s). Soil moisture-based controllers are not required to have rain sensor input. Buildings on sites with over 2,500 square feet of cumulative irrigated landscaped areas shall have irrigation controllers that meet the criteria in Section 99.04.304.1.

Section 99.04.303.4. Wastewater Reduction. Each building shall reduce by 20 percent wastewater by one of the following methods:

1. The installation of water conserving fixtures (water closets, urinals). 2. Utilizing non-potable water systems (captured rainwater, graywater, and municipally treated wastewater) complying with the current edition of the Los Angeles Plumbing Code or other methods.

Section 99.04.304.2. Outdoor Potable Water. Building on sites with 1,000 square feet or more of cumulative landscaped areas shall have separate meters or submeters for indoor and outdoor potable water use.

Section 99.04.304.3. Irrigation Design. Buildings on sites with 1,000 square feet or more of cumulative irrigated landscaped areas shall have irrigation controllers and sensors which include the following criteria and the manufacturer’s recommendations.

Section 99.05.407.1. Weather Protection. Provide a weather-resistant exterior wall and foundation envelope as required by the Los Angeles Building Code section 1403.2 (Weather Protection) and California Energy Code Section 150, manufacturer’s installation instructions, or local ordinance, whichever is more stringent.

Section 99.05.408. Construction Waste Reduction, Disposal And Recycling. Construction Waste Reduction of at Least 50 Percent. Comply with Section 66.32 et seq. of the LAMC.

Section 99.05.408.4. Excavated Soil and Land Clearing Debris. 100 percent of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled. For a phased project and when approved by the Department, such material may be stockpiled on site until the storage site is developed.

Section 99.05.410.1. Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage, and collection of non-hazardous

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materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, and metals.

Section 99.05.504.3. Covering of Duct Openings and Protection of Mechanical Equipment During Construction. At the time of rough installation, or during storage of the construction site and until final startup of the heating and cooling equipment, all duct and other related air distribution component openings shall be covered with tape, plastic, sheetmetal or other methods acceptable to the Department to reduce the amount of dust or debris which may collect in the system.

Section 99.05.504.4.6. Resilient Flooring Systems. For 50 percent of floor area receiving resilient flooring, install resilient flooring complying with the VOC-emission limits defined in the 2009 Collaborative for High Performance Schools criteria and listed on its Low-emitting Materials List or certified under the Resilient Floor Covering Institute FloorScore program.

The discussion on page 4.F-14 above the “Methodology” heading is revised as follows:

This analysis recognizes that the AB 32 Scoping Plan represents the most significant plan for reducing GHG emissions. In calling for a return to 1990 levels of GHG emissions by 2020, the Scoping Plan contains strategies targeting direct regulations, market-based incentives, voluntary actions, and other strategies that would reduce Statewide GHG emissions. These goals encourage local governments to adopt a reduction goal for municipal operations emissions and community emissions of 15 percent from current levels by 2020. In the 2011 Scoping Plan, the Statewide emissions reduction goal was revised to 15.3 percent. SCAG recommends reduction targets specific to land use decisions at much lower levels, approximately eight to 13 percent below “business-as-usual” emissions. Therefore, demonstrating consistency with the more aggressive AB 32 Statewide targets is considered to be conservative. Considering that the CEQA Guidelines do not establish a threshold of significance, Lead agencies are to establish thresholds, and can rely on thresholds developed by other public agencies, or suggested by other experts, so long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7(c)).

In addition, the CEQA Guidelines clarify that the effects of GHG emissions are cumulative. The CEQA Guidelines were amended in response to Senate Bill 97 to specify that compliance with a GHG emissions reduction plan renders a cumulative impact insignificant. To qualify, such a plan or program must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency. Examples of such programs include a “water quality control plan, air quality attainment or maintenance plan, integrated waste management

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plan, habitat conservation plan, natural community conservation plans [and] plans or regulations for the reduction of greenhouse gas emissions.”1

CARB, SCAQMD, and the City of Los Angeles have not adopted quantitative project-level significance thresholds for GHG emissions that would be applicable to the Project.2 However, per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project will comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of the project.3

Consequently, the Project’s impact on climate change would be significant if Thus, in the absence of any adopted, quantitative threshold, the Project would not have a significant effect on the environment if it is found to be consistent with the following regulatory plans and policies which are designed to reduce GHG emissions:

1. It conflicts with or obstructs implementation of the AB 32 Scoping Plan;

2. SCAG’s Sustainable Communities Strategy; and

3. Appropriate transportation and air quality plans from the City of Los Angeles, including the Green Building Ordinance, ClimateLA Implementation Plan, and Mobility Plan 2035.

4. It does not constitute an equivalent or larger break from “business-as-usual” than has been determined by the CARB to be necessary to meet the AB 32 goals (15.3 percent for community emissions).

The following information is added to page 4.F-14 above the “Environmental Impacts” heading:

Emissions calculations for the Project include credits or reductions for the regulatory compliance measures and project design features set forth throughout this analysis, such as reductions in energy or water demand. In addition, as mobile source GHG emissions are directly dependent on the number of vehicle trips, a decrease in the number of Project generated trips as a result of project features will provide a proportional reduction in mobile source GHG emissions. This scenario conservatively did not include actions and mandates that are not already in place but are

1 Id. (emphasis added).

2 The South Coast Air Quality Management District formed a GHG Significance Threshold Working Group. Information on this Working Group is available at www.aqmd.gov/home/regulations/ceqa/air-quality- analysis-handbook/ghg-significance-thresholds/page/2

3 14 CCR § 15064(h)(3).

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expected to be in force in 2020 (e.g., Pavley II), which could further reduce GHG emissions from use of light-duty vehicles by 2.5 percent.

SECTION 4.G. HAZARDS AND HAZARDOUS MATERIALS

No corrections required.

SECTION 4.H. HYDROLOGY AND WATER QUALITY

The following paragraph on pages 4.H-11 to 4.H-12 is revised as follows:

The Project Site is almost entirely covered with impervious surfaces. The Project would involve the construction and operation of a new development, which would replace the paved parking areas and small areas of vegetation substantially with new buildings and surfaces. Implementation of appropriate project design features and compliance with local, state and federal regulations, code requirements, and permit provisions would prevent significant impacts related to the release of potentially polluted discharge into surface water. In order to prevent both short-term (construction) and long-term (operational) impacts to water quality, the Project would be required to obtain a NPDES water quality permit from the LARWQCB, and would be designed and constructed to comply with the requirements of the LARWQCB Order No. 01-182 R4-2012-0175, NPDES Permit No. CAS004001; the Construction General Permit Water Quality Order 2009-0009-DWQ as amended by Order No. 2010-0014-DWQ; and the City of Los Angeles, Department of Public Works, Bureau of Sanitation, Watershed Protection “How to Build Protection for Mother Nature Into Your Project, Standard Urban Stormwater Urban Mitigation Plans (SUSMP) Site-Specific Mitigation Plans.” Requirements of the SUSMP are enforced through the City’s plan approval and permit process.

SECTION 4.I. LAND USE AND PLANNING

No corrections required.

SECTION 4.J. NOISE

Mitigation Measure J-4 on page 4.J-20 is revised as follows:

MM-J-4 All construction areas for staging and warming-up equipment shall be located as far away as possible from adjacent residences and sensitive receptors.

SECTION 4.K. POPULATION AND HOUSING

No corrections required.

SECTION 4.L. PUBLIC SERVICES

No corrections required.

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SECTION 4.M. TRANSPORTATION AND TRAFFIC

The location of Cumulative Project No. 4 has been corrected on Figure 4.M-13:

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Source: The Mobility Group, 2016.

Revised Figure 4.M-13 Cumulative Projects Map City of Los Angeles June 2016

Mitigation Measure M-8 on page 4.M-61 is revised as follows:

MM-M-8 LAUSD Transportation Branch shall be contacted at (213) 580-2950 regarding the potential impact upon existing school bus routes. Laurel Hall School shall also be contacted regarding the potential impact upon existing school bus routes.

 School buses must have unrestricted access to schools.  During the construction phase, truck traffic and construction vehicles may not cause traffic delays for transported students.  During and after construction changed traffic patterns, lane adjustment, traffic light patterns, and altered bus stops may not affect school buses’ on-time performance and passenger safety.  Pursuant to the California Vehicle Code, other trucks and construction vehicles that encounter school buses using red-flashing-lights must-stop-indicators shall stop.  The Project Manager or designee shall have to notify the LAUSD Transportation Branch and Laurel Hall School of the expected start and ending dates for various portions of the project that may affect traffic within nearby school areas.  Contractors shall maintain safe and convenient pedestrian routes to all nearby schools. The applicable Pedestrian Route to School map can be found at http://www.lausd-oehs.org/saferoutestoschools.asp and a pedestrian route map shall also be requested from Laurel Hall School.  Contractors shall maintain ongoing communication with LAUSD school administrators, providing sufficient notice to forewarn children and parents when existing pedestrian and vehicle routes to school may be impacted.  Contractors shall maintain ongoing communication with Laurel Hall School administrators, providing sufficient notice to forewarn children and parents when existing pedestrian and vehicle routes to school may be impacted.  Installation and maintenance of appropriate traffic controls (signs and signals) to ensure pedestrian and vehicular safety.  Construction vehicles shall avoid, to the extent feasible, travel on streets immediately adjacent to Laurel Hall School and Victory Elementary School.  No staging or parking of construction-related vehicles, including worker- transport vehicles, shall occur on or adjacent to a school property. The staging and parking of construction-related vehicles shall be located as far away from Laurel Hall School as feasible.  Funding for crossing guards (at contractor’s expense) is required when safety of children may be compromised by construction-related activities at impacted school crossings.  Barriers and/or fencing shall be installed to secure construction equipment and to minimize trespassing, vandalism, short-cut attractions, and attractive nuisances.

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 Contractors are required to provide security patrols (at their expense) to minimize trespassing, vandalism, and short-cut attractions.

A new Project Design Feature has been incorporated into the Project, which is designed to reduce vehicle trips and vehicle miles traveled and promote public transportation and alternative modes of transportation. Therefore, the following Project Design Feature is added to page 4.M-63:

PDF-M-10 The Project shall incorporate Transportation Demand Management (TDM) strategies, which could include, but are not limited to:

 Provide an Internal Transportation Management Coordination Program with on-site transportation coordinator;  Implement enhanced pedestrian connections (e.g., improve sidewalks, widen crosswalks adjacent to the Project, install wayfinding signage and pedestrian level lighting, etc.);  Design the Project to ensure a bicycle, pedestrian, and transit friendly environment;  Include a provision that all retailers over 10,000 square feet and office users are required to comply with the state parking cash-out law;  Provide on-site car share amenities;  Provide rideshare program and support for Project employees and tenants;  Allow for subsidized transit passes for eligible Project employees and tenants;  Coordinate with LADOT to determine if the site would be eligible for one or more of the services to be provided by the future Mobility Hubs program (secure bike parking, bike share kiosks, and car-share parking spaces;  Provide on-site transit routing and schedule information;  Upgrade bus shelters immediately adjacent to the Project Site;  Provide a program to discount transit passes for residents/employees possibly through negotiated bulk purchasing of passes with transit providers;  Guaranteed Ride Home Program; and  Preferential parking for HOVs, carpools, and vanpools.

Prior to occupancy, a comprehensive TDM program tailored specifically for the Project will be developed.

SECTION 4.N. UTILITIES AND SERVICE SYSTEMS

Section 4.N.2 – Utilities and Service Systems - Water

On page 4.N.2-5, the percentages are revised as follows:

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City water supplies are derived from the following sources:4

(1) the Los Angeles Aqueduct (LAA), approximately 3734 percent;

(2) groundwater, approximately 1112 percent;

(3) purchases from the Metropolitan Water District (MWD), approximately 5153 percent; and

(4) recycled water (for industrial and irrigation purposes), approximately one percent.

On page 4.N.2-5, the sentence is revised as follows:

The City water system includes 114 tanks and reservoirs within its service area and nine more reservoirs along the Los Angeles Aqueduct System, ranging in size from 10,000 to 60 billion gallons, with a total capacity of approximately 111 billion gallons.5 The storage capacity within the service area is approximately 15,245 acre-feet, and the capacity of the Los Angeles Aqueduct System is approximately 300,000 acre-feet. Water is distributed through a network of 7,2257,200 miles of water mains ranging from 4 inches to 120 inches in diameter. Because of the size and range in elevation, the system is divided into 102124 pressure zones, and has almost 9078 booster pumping stations to provide water service at higher elevations.6

On page 4.N.2-6, the sentence is revised as follows:

The San Fernando Groundwater Basin (SFB) is the largest of these resources, accounting for nearly 80approximately 79 percent of all local groundwater pumped by the LADWP.7

On page 4.N.2-7, the sentence is revised as follows:

Local groundwater has been delivering approximately 71,087 AFY since 2005during the period FYEs 2006-2010.8

4 Los Angeles Department of Water and Power, website: https://www.ladwp.com/ladwp/faces/ladwp/aboutus/a- water/a-w-factandfigures?_adf.ctrl- state=j27f6ybei_4&_afrLoop=485154606155320&_afrWindowMode=0&_afrWindowId=null#%40%3F_afrWi ndowId%3Dnull%26_afrLoop%3D485154606155320%26_afrWindowMode%3D0%26_adf.ctrl- state%3Dyqthn02n7_71, accessed March 17, 2016. 5 Total storage capacity is 315,245 acre-feet. One acre-foot is 325,851 gallons. 6 City of Los Angeles, L.A. CEQA Thresholds Guide, 2006. Information is available by navigated to LADWP.com > About Us > Water > Facts and Figures: https://www.ladwp.com/ladwp/faces/ladwp/aboutus/a-water/a-w- factandfigures?_adf.ctrl- state=j27f6ybei_4&_afrLoop=485154606155320&_afrWindowMode=0&_afrWindowId=null#%40%3F_afrWi ndowId%3Dnull%26_afrLoop%3D485154606155320%26_afrWindowMode%3D0%26_adf.ctrl- state%3Dyqthn02n7_71, accessed March 17, 2016. 7 During the period FYEs 2006-2010. See Exhibit 6B on page 123 of the 2010 UWMP.

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On page 4.N.2-7, the sentence is revised as follows:

On average, tThe MWD supplied approximately 52 percent or approximately 318,000326,012 AFY of the City’s water supplies between 2005 and 2010for the period FYEs 2006-2010.9

On page 4.N-7, the sentence is revised as follows:

In light of this, LADWP’s current reliance on MWD water supply is projected to be cut in half to 24 percent of total LADWP demand by 2034 from the five‐year average of 52 percent of the total

demand for the period FYEs 2006 ‐ 2010 to 24 percent by FYE 2035 under average weather conditions.10

On page 4.N.2-8, the sentence is revised as follows:

LADWP, which provides over approximately700,000 water service connections, most recently updated its UWMP in April 2011, covering 2010 to 2035 (2010 UWMP).

On page 4.N.2-8, the sentence is revised as follows:

According to the 2010 UWMP, water use in the City of Los Angeles was approximately 550,000 AFY in 2010, which represents a decrease of approximately 10050,000 AFY as compared to water use 40 years ago in 1970, when it was approximately 600,000 AFY, even though the City’s population has increased by approximately one million people during this period.

On page 4.N.2-8, footnote number 15 revised as follows:

15 Ibid at p. 20. Potential future water supply sources include seawater desalination, water transfer, recycled water, and beneficial use of urban runoff.

On page 4.N.2-10, the sentence is revised as follows:

The current average annual flow through LAAFP is approximately 362324 million gallons per day, or 405360,000 AFY (averaged over CY 20132014).

8 During the period FYEs 2006-2010. See Exhibit 6B on page 123 of the 2010 UWMP.

9 During the period FYEs 2006-2010. See Exhibit ES-Q on page 19 of the 2010 UWMP. 10 See page 191 of the 2010 UWMP.

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On pages 4.N.2-1, 4.N.2-7, and 4.N.2-10, the following reference is revised as follows:

Functions once held by the California Department of Public Health (CDPH) have been transferred to the State Water Resources Control Board (SWRCB), Division of Drinking Water (DDW). References to CDPH are changed to DDW.

On page 4.N.2-11, the sentence is revised as follows:

The Project’s environmental impacts on water are based on the estimated increase in water demand and the capacity of the water infrastructure and supplies to meet that demand.

On page 4.N.2-12, a footnote is added as follows:

Reclaimed/recycled water can be used for dust control.11

On page 4.N.2-13, the paragraph is revised as follows:

The LAAFP currently has the capacity to treat and convey an additional 125 mgd of water. The Project’s net increase of 0.18 mgd represents approximately 0.14 percent of the LAAFP’s available capacity. The maximum water treatment capacity at the LAAFP is 600 million gallons per day, or approximately 672,000 AFY. LAAFP typically treats water from LAA and most of the purchases through MWD. The current average annual flow through LAAFP is approximately 324 million gallons per day, or approximately 360,000 AFY, averaged over CY 2014. Exhibit 11E of 2010 UWMP shows that the total annual water supplies from LAA and MWD between years 2020 through 2035 are less than 470,000 AFY. Additionally, in accordance with the project’s Water Supply Assessment, the project’s maximum net increase in water demand is 298 AFY and it is accounted for in the City’s future projected demands as explained in the project’s Water Supply Assessment. Consequently, the current treatment capacity of LAAFP is estimated to be adequate to accommodate the project’s future water demand as the demand is included in future demand projections and the LAAFP is expected to be able to meet the requirements of treating these projected demands. As the current treatment plant capacity of LAAFP is estimated to be adequate for future demands, the Project would not require the construction or expansion of new water treatment facilities that could cause a significant environmental effect.

11 Recycled water is currently available from recycled water fill stations. The nearest fill station to the construction site is located in Van Nuys, however, LADWP may install additional fill stations closer to the construction site. LADWP encourages the developer to contact Mario Acevedo, Manager of the Water Recycling Group at (213) 367‐0761 or [email protected] to learn more about fill stations and the possible use of recycled water for dust control.

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On page 4.N.2-17, the paragraph is revised as follows:

The total cumulative water demand (cumulative projects + Project) is approximately 0.45 mgd and represents approximately 0.36 percent of the total remaining daily capacity.12 The maximum water treatment capacity at the LAAFP is 600 million gallons per day, or approximately 672,000 AFY. LAAFP typically treats water from LAA and most of the purchases through MWD. The current average annual flow through LAAFP is approximately 324 million gallons per day, or approximately 360,000 AFY, averaged over CY 2014. Exhibit 11E of 2010 UWMP shows that the total annual water supplies from LAA and MWD between years 2020 through 2035 are less than 470,000 AFY. Consequently, the current treatment capacity of LAAFP is estimated to be adequate to accommodate the projected over-all water demand, which includes the cumulative water demand of the Project and related projects. Therefore, the LAAFP would have adequate capacity to treat the water demanded by the Project and cumulative projects.

SECTION 5. GENERAL IMPACT CATEGORIES

No corrections required.

SECTION 6. ALTERNATIVES

ALTERNATIVE 4B PROJECT DESCRIPTION

Alternative 4B includes the demolition of the existing 90,000-square-foot office building at the corner of Laurel Canyon and Erwin Street, the 10,000-square-foot Macy’s annex building, a 13,000-square-foot portion of the Macy’s building, as well as the removal of an approximately 20,000-square-foot portion of the existing Macy’s building. Alternative 4B would re-use approximately 205,000 square feet of the main Macy’s building for office uses (on the second through fourth floors) and restaurant uses (on the second floor). The remainder of the main Macy’s building would be converted to 316 parking spaces in the basement (in approximately 150,000 square feet) and approximately 60,000 square feet of retail on the ground floor. In total, Alternative 4B would include the following commercial uses: 189,184 square feet of office uses; 208,171 square feet of retail uses; 66,645 square feet of restaurant uses; 40,000 square feet of health club/gym uses; and 68,000 square feet of cinema uses (with 1,750 seats).13 In addition to the

12 0.45 mgd / 125 mgd x 100% = 0.36% 13 Potential variations in the mix of uses for the commercial portion of the project would include the replacement of up to 65,000 square feet of retail use on the ground floor of the Macy’s building with 65,000 square feet of office use, and the replacement of up to 40,000 square feet of health club use in Building G with 40,000 square feet of office. These variations in the mix of uses within the commercial center would not significantly change any impacts and would not alter the design or building envelope.

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City of Los Angeles June 2016 commercial uses, the Project Site would also be developed with 658 residential units in two buildings. Alternative 4B plans and renderings are provided in Figures 4B-1 through 4B-13.

A comparison between the Proposed Project, Alternative 4, and Alternative 4B is provided in Table 4B-1.

Table 4B-1 Comparison Table Proposed Project Alternative 4 Use Alternative 4B (EIR) (EIR) Existing Uses Office 90,000 sf 90,000 sf 90,000 sf Macy’s Department Store 465,000 sf 465,000 sf 465,000 sf Total Existing 555,000 sf 555,000 sf 555,000 sf Amount of Demolition (120,000 sf) (120,000 sf) (133,000 sf) Amount Remaining 435,000 sf 435,000 sf 422,000 sf

Proposed Uses Commercial Land Uses Office 500,000 sf 200,000 sf 189,184 sf Retail 142,513 sf 240,000 sf 208,171 sf Restaurant 48,687 sf 60,000 sf 66,645 sf Health Club/Gym 40,000 sf 40,000 sf 40,000 sf Cinema 68,800 sf 100,000 sf 68,000 sf Total Commercial 800,000 sf 640,000 sf 572,000 sf Residential Land Uses Multi-Family Residential 742 units 742 units 658 units Total Residential 816,200 sf 816,200 sf 713,904 sf

Under Alternative 4B, the Macy’s building would be programmed differently than for the Proposed Project. For the Proposed Project, the Macy’s building would contain office uses from the basement level through the 4th level mezzanine. Alternative 4B would re-use approximately 205,000 square feet of the main Macy’s building for office uses (on the second through fourth floors) and restaurant uses (on the second floor). The remainder of the main Macy’s building would be converted to 316 parking spaces in the basement (in approximately 150,000 square feet) and approximately 60,000 square feet of retail on the ground floor. In addition, the northeast corner next to the Macy’s building (where the annex building is located and where surface parking was proposed for the Project) would contain an approximately 15,000- square-foot park, containing such uses as a dog park and children’s play area.

Appendix D of this Final EIR provides analysis of traffic and other potential impacts which could be affected by the variation in use mix.

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Since the basement of the Macy’s building would be used for parking under Alternative 4B, and because the total commercial area would be reduced, the height of the multi-story parking structure on the west side of the Project Site would be reduced from the Proposed Project (from seven levels to three and four levels). In addition, the main drive aisle would be shifted slightly to the east.

In comparison to the Proposed Project, there would be an overall reduction in the number of residential units, and the design would include deeper courtyards. The height of the residential units along Calvert Place would be reduced from six stories to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School. Abundant landscaping would be provided between the Project Site and the Laurel Hall School. In addition, the Project would provide 50 parking spaces located in the parking structure by lease agreement for use by Laurel Hall teachers and staff.

Finally, under Alternative 4B, construction of the Project may be phased so that not all buildings and uses are completed at the same time. Due to such phasing, certain mitigation measures may be apportioned or scheduled according to the Project phasing schedule. The phasing would be as follows, although the order of the phases may change based on market conditions:

- Phase I would include Laurel Plaza Drive improvements, the parking structure, and Commercial Buildings D, E, F, and G. - Phase II would include Commercial Buildings J and H. - Phase III would include Commercial Buildings A, B, and BA. - Phase IV would include Residential Buildings A and B.

Height

Commercial building heights would vary from 24 feet for one-story elements to a maximum of 105 feet, 9 inches for the existing Macy’s building remaining on-site. Residential heights vary from 33 feet to 75 feet.

Floor-Area-Ratio

Commercial uses on the Site would total approximately 572,000 square feet with a floor area ratio (FAR) of 0.80:1.14 The proposed residential floor area would be 713,904 square feet, for an FAR of 1.98:1.15 The overall FAR of the Site would be 1.19:1.16

Access

Vehicle access for Alternative 4B would be provided by a total of six driveways: two driveways (one commercial and one residential) along Erwin Street; one residential driveway along Radford Avenue; two

14 572,000 square feet / 716,310 commercial lot area = 0.80 15 713,904 square feet / 359,942 residential lot area = 1.98 16 1,285,904 square feet / 1,076,251 total lot area = 1.19

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City of Los Angeles June 2016 commercial driveways along Oxnard Street; and one commercial driveway along Laurel Canyon Boulevard. Pedestrian access would be provided around the Project Site and internally via new pedestrian linkages to each commercial and residential building.

Vehicle Parking

As shown in Table 4B-2, pursuant to the LAMC, Alternative 4B is required to provide 1,060 residential parking spaces and 2,628 commercial parking spaces. However, based on the requested shared parking between commercial uses, a total of 2,138 commercial spaces would be required (including the 50 spaces for Laurel Hall teachers and staff). Alternative 4B would provide 2,162 commercial spaces in the existing Macy’s basement, at grade throughout the Project Site, and in a new parking structure along the 170 Freeway frontage. Alternative 4B would also provide 1,138 exclusive residential parking spaces within the residential component of Alternative 4B.

Table 4B-2 Vehicle Parking Type Quantity/Size Rate1 Total Spaces Residential Studio 55 units 1.0 spaces / unit 55 1-Bedroom 403 units 1.5 spaces / unit 605 2-Bedroom 200 units 2.0 spaces / unit 400 Residential Parking Required (LAMC) 1,060 Residential Parking Provided 1,138

Commercial Office 189,184 sf 1.0 spaces / 500 sf 378 Retail 208,171 sf2 1.0 spaces / 250 sf 833 Restaurant 66,645 sf2 1.0 spaces / 100 sf 667 Health Club 40,000 sf 1.0 spaces / 100 sf 400 Cinema 1,750 seats 1.0 spaces / 5 seats 350 Commercial Parking Required (LAMC) 2,628 Commercial Parking Required (Shared Parking) 2,088 Laurel Hall School Parking 50 Commercial Parking Provided 2,162 1Based on LADBS P/ZC 2002-11 Summary of Parking Regulations. 2Retail and restaurant, parking is based on gross leasable area (GLA). Thus, the square footage for these two uses is based on the GLA. 3Based on parking analysis (per Shared Parking, 2nd Edition, Urban Land Institute, 2005). Table by CAJA Environmental Services, 2016.

Bicycle Parking

LAMC Section 12.21 A.16 requires new projects to provide bicycle parking spaces. General retail stores, restaurants, and health clubs require one short-term and one long-term bicycle space per 2,000 square feet of floor area. All other commercial uses require one short-term and one long-term bicycle space per 10,000 square feet of floor area. Office uses require one short-term bicycle space per 10,000 square feet

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City of Los Angeles June 2016 and one long-term space per 5,000 square feet of floor area. Multi-family residential units require one long-term bicycle parking space per unit and one short-term bicycle parking space per 10 units. Short- term bicycle parking shall consist of bicycle racks that support the bicycle frame at two points. Long-term bicycle parking shall be secured from the general public, enclosed on all sides, and protect bicycles from inclement weather.

Table 4B-3 lists the required bicycle parking. Alternative 4B is required to provide 1,068 bicycle parking spaces (237 short-term spaces and 831 long-term spaces), and Alternative 4B would provide these spaces according to Code requirements.

Table 4B-3 Bicycle Parking Required Required Use Amount Rate Total Short-term Long-term 1 per 10 units (short-term) Residential 658 units 66 658 724 1 per unit (long-term) 1 per 10,000 sf (short-term) Office 189,184 sf 19 38 57 1 per 5,000 sf (long-term) Retail, 1 per 2,000 sf (short-term) 104,800 sf 52 52 104 General 1 per 2,000 sf (long-term) Other 1 per 10,000 sf (short-term) 103,371 sf 11 11 22 Commercial 1 per 10,000 sf (long-term) 1 per 2,000 sf (short-term) Restaurant 66,645 sf 34 34 68 1 per 2,000 sf (long-term) 1 per 2,000 sf (short-term) Health Club 40,000 sf 20 20 40 1 per 2,000 sf (long-term) 1 per 50 seats (short-term) Cinema 1,750 seats 35 18 53 1 per 100 seats (long-term) Total (Project) 237 831 1,068 LAMC Section 12.21 A.16. Retail general, restaurants (greater than 1,000 sf), and health clubs are 1 per 2,000 sf (short and long-term). All other commercial uses are 1 per 10,000 sf (short and long-term), except for the cinema, which is based on the number of seats. Table by CAJA Environmental Services, 2016.

Open Space

See Table 4B-4, Open Space, for the open space requirements, as well as amounts provided. Alternative 4B is required to provide 90,875 square feet of residential open space and would provide 110,850 square feet of residential open space.

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Table 4B-4 Open Space

Type Quantity Rate Total Required Total Provided Residential Building A

100 sf/unit (<3 10 studio 1,000 sf habitable rooms)

Courtyards: 6,400 sf 11,625 sf 125 sf/unit (=3 Perimeter Open Space: 5,800 sf Outdoor Area 93 1-bed habitable rooms) Amenities: 5,200 sf 7,350 sf Private Decks: 5,800 sf 42 2-bed ______175 sf/unit (≥3 ______19,975 sf habitable rooms) Total: 23,200 sf 145 units

Residential Building B

100 sf/unit (<3 Courtyards: 23,600 sf 45 studio 4,500 sf habitable rooms) Courtyard/Park: 10,300 sf

Perimeter Open Space: 14,500 sf 38,750 sf 125 sf/unit (≥3 Amenities: 1,500 sf Outdoor Area 310 1-bed habitable rooms) Private Decks: 20,750 sf 27,650 sf Roof Terrace: 17,000 sf 158 2-bed ______175 sf/unit (≥3 ______70,900 sf habitable rooms) Total: 87,650 sf 513 units

Totals 90,875 sf outdoor area 190,073 sf outdoor area Source: Architects Orange, 2016. Table by CAJA Environmental Services, 2016.

Signage

Like the Project, Alternative 4B would include a Sign District, which would permit a variety of signage types and styles, including tenant and Project identification, on- and off-site commercial displays, digital displays, kiosks, and monument signs. The proposed Sign District would apply to all signs with sign faces visible from any public right-of-way. Alternative 4B proposes to include the following types of signs:

 Architectural Entry Signs

 Wayfinding Signs

 Wall-Mounted Commercial Display

 Monument Signs

 Tenant Shopfront Signs

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 Tenant Blade Signs

 Residential Building Identification

 Cinema Signage

 Project Identity Signs

 Advertising Kiosks

Lighting

Night lighting for security, wayfinding, and commercial sign illumination would be provided.

Environmental Design Features

Alternative 4B will comply with the Los Angeles Green Building Code (LAGBC), which is based on the 2010 California Green Building Standards Code (CalGreen).

Construction

Construction of Alternative 4B would be completed in approximately 31 months, with operation beginning in 2020. Key assumptions include the import of 60,000 cubic yards of soil, demolition phase (three months), site preparation phase (one month), grading phase (two months), construction phase (20 months), a paving phase (three months), and architectural coatings phase (four months). Some of the construction phases may overlap.

Haul Route

Trucks leaving the Project Site are expected to exit the Project Site to the south onto Oxnard Street, and enter the CA-170 north or south from Oxnard Street. Trucks traveling to the Project Site are expected to exit the CA-170 onto Oxnard Street and enter the Project Site from the south.

Discretionary Actions And Approvals

In order to implement Alternative 4B, the Project Applicant is requesting approval of the following discretionary actions from the City:

1. Vesting Zone Change from P-1L, QC4-1L, and C4-1L to (Q)C2-1; 2. Master CUB for alcohol service in Project restaurants and cinema and alcohol sales at grocery store; 3. Transitional Height determination to allow heights to exceed allowances within 199 feet of R1 zoned property; 4. Vesting Conditional Use Permit to allow FAR averaging in a unified development project for the Project;

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5. Zoning Administrator’s Adjustment to allow a portion of one residential building to observe a 13.5 -foot rear yard in lieu of an 18-foot rear yard; 6. Vesting Tentative Tract Map to subdivide the Project Site into five commercial and two residential lots; 7. Site Plan Review for a project over 50,000 square feet and 50 dwelling units; 8. Adoption of a Sign District; 9. Zoning Administrator’s Determination for Shared Parking Approval to allow for shared off-street parking between commercial uses; and 10. Haul Route Approval.

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0 100 200

Source: Altoon Partners, 3.11.16. Scale (Feet)

Figure 4B-1 Alternative 4B, Plot Plan Level 1 0 100 200

Source: Altoon Partners, 3.11.16. Scale (Feet)

Figure 4B-2 Alternative 4B, Plot Plan Level 2 0 100 200

Source: Altoon Partners, 3.11.16. Scale (Feet)

Figure 4B-3 Alternative 4B, Conceptual Site Plan 0 60 120

Source: Altoon Partners, 3.11.16. Scale (Feet)

Figure 4B-4 Alternative 4B, Residential Site Plan 0 100 200

Source: Altoon Partners, 3.11.16. Scale (Feet)

Figure 4B-5 Alternative 4B, Conceptual Site Circulation Plan Source: Altoon Partners, 3.11.16.

Figure 4B-6 Alternative 4B, Rendering, View of Plaza from Parking Structure Source: Altoon Partners, 3.11.16.

Figure 4B-7 Alternative 4B, Rendering, View Looking North Along Laurel Plaza Drive Source: Altoon Partners, 3.11.16.

Figure 4B-8 Alternative 4B, Rendering, Aerial View Looking Southeast Source: Altoon Partners, 3.11.16.

Figure 4B-9 Alternative 4B, Rendering, View Looking South Along Laurel Plaza Drive Source: Altoon Partners, 3.11.16.

Figure 4B-10 Alternative 4B, Rendering, View of Oxnard Avenue Entrance Source: Altoon Partners, 3.11.16. Figure 4B-11 Alternative 4B, Rendering View of Intersection at Laurel Canyon Boulevard and Erwin Street Source: Altoon Partners, 3.11.16.

Figure 4B-12 Alternative 4B, Rendering, View of Residential Units Along Erwin Street Source: Altoon Partners, 3.11.16.

Figure 4B-13 Alternative 4B, Rendering, View at Corner of Radford Avenue and Calvert Place City of Los Angeles June 2016

IMPACT ANALYSES AND MITIGATION

Aesthetics

Under Alternative 4B, the Macy’s building would be retained and approximately 205,000 square feet of the main Macy’s building would be re-used for office and restaurant uses; the remainder would be converted to 316 parking spaces in the basement (in approximately 150,000 square feet) and approximately 60,000 square feet of retail uses on the ground floor. Like the Project, new commercial structures, including a cinema, would be built around a central plaza, and pedestrian and vehicular linkages to all commercial and residential uses would be provided. A sign district would be enacted and the site would be activated with new signage and lighting. Due to the reduction in office space and the additional basement parking, the size and height of the parking structure would be reduced from the seven levels for the Project to three and four levels for Alternative 4B. Two residential buildings would be constructed with a reduction in the number of residential units, from 742 to 658. The residential design would include deeper courtyards. The height of the residential units along Calvert Place would be reduced from six stories to three stories, with the units and balconies facing the interior of the Project and away from the Laurel Hall School. In addition, abundant landscaping would be provided between the Project Site and the Laurel Hall School.

With respect to summer shadows, as shown in Figure 4B-14, Alternative 4B would cast shadows to the west at 9:00 AM on the summer solstice. These shadows would fall on the Project Site itself. At 12:00 PM on the summer solstice, Alternative 4B would cast very minimal shadows to the north, which would fall on the Project Site (see Figure 4B-15). Finally, at 3:00 PM on the summer solstice, Alternative 4B would cast shadows to the east, shading the Project Site and a portion of Radford Avenue (see Figure 4B- 16). As shown, no sensitive uses would be shaded for more than four hours between the hours of 9:00 AM and 3:00 PM. Consequently, Alternative 4B would have no impact with respect to summer shadows.

The longest shadows of the year occur during the winter solstice, with peak shadows occurring shortly after sunrise and before sunset. As shown in Figure 4B-17, at 9:00 AM Alternative 4B would cast shadows to the west and northwest, shading the Project Site, Erwin Street, and the sidewalk on the north side of Erwin Street. At 12:00 PM on the winter solstice, Alternative 4B would cast shadows directly north, shading the Project Site and a portion of Erwin Street (see Figure 4B-18). Finally, at 3:00 PM on the winter solstice, Alternative 4B would cast shadows to the north, east, and northeast, shading the Project Site, Erwin Street, the sidewalk and a portion of the homes on the north side of Erwin Street, Radford Avenue, and a portion of the multi-family residential uses on the east side of Radford Avenue (see Figure 4B-19). As shown, no sensitive uses would be shaded for more than three hours between the hours of 9:00 AM and 3:00 PM. As such, Alternative 4B would have no impact with respect to winter shadows. Like the Project, Alternative 4B would cause no impact to scenic vistas, scenic resources, views, consistency with applicable policies or regulations, or shade/shadow, and would cause less than significant impacts to visual character and compatibility and light and glare. Alternative 4B would also implement Project Design Feature B-1 to include temporary fencing during construction, Project Design Feature B-2 to screen mechanical and electrical rooftop equipment, and Project Design Feature B-3 to ensure there are no impacts related to utility equipment. Alternative 4B would also implement Project

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Design Features B-5 and B-6 to ensure that impacts with respect to light and glare are less than significant. With respect to visual character, Alternative 4B, like the Project, would be designed in a modern architectural style that would be complementary and appropriate to the scale of the Project Site and adjacent existing buildings. As Alternative 4B would provide a similar mix of uses as the Project, Alternative 4B would provide the same level of pedestrian linkages and activation as the Project. Overall, Alternative 4B’s impacts with respect to aesthetics would be less than significant. For the same reasons, Alternative 4B’s contribution to cumulative aesthetics impacts would also be less than cumulatively significant.

Agricultural and Forestry Resources

The Project Site is currently fully developed with an existing office building, Macy’s Department Store, and surface parking. The office building and the 10,000-square-foot Macy’s annex would be demolished under Alternative 4B. The remainder of the Macy’s building would remain on-site and be re-used as part of Alternative 4B. The Site does not contain any agricultural or forestry uses. Like the Project, Alternative 4B would develop the entire Site and would have no impact to agricultural and forestry resources. For the same reasons, Alternative 4B’s contribution to cumulative agricultural and forestry resources impacts would also be less than cumulatively significant.

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SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST.

Source: Altoon Partners, 3.17.16.

Figure 4B-14 Alternative 4B, Summer Solstice Shadows 9AM SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST.

Source: Altoon Partners, 3.17.16.

Figure 4B-15 Alternative 4B, Summer Solstice Shadows 12PM SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST. Source: Altoon Partners, 3.17.16.

Figure 4B-16 Alternative 4B, Summer Solstice Shadows 3PM SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST.

Source: Altoon Partners, 3.17.16.

Figure 4B-17 Alternative 4B, Winter Solstice Shadows 9AM SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST. Source: Altoon Partners, 3.17.16.

Figure 4B-18 Alternative 4B, Winter Solstice Shadows 12PM SINGLE FAMILY RESIDENTIAL

ERWIN AVE. MULTI-FAMILY RESIDENTIAL

170 FREEWAY

LAUREL HALL RADFORD AVE. SCHOOL LAUREL CANYON BLVD.

OXNARD ST. Source: Altoon Partners, 3.17.16.

Figure 4B-19 Alternative 4B, Winter Solstice Shadows 3PM City of Los Angeles June 2016

Air Quality

Air Quality Impacts During Construction

Construction-related emissions were estimated using the SCAQMD’s CalEEMod 2013.2.2 model. Table 4B-5 provides the estimated daily construction emissions for Alternative 4B.

Table 4B-5 Alternative 4B - Estimated Daily Construction Emissions (Unmitigated)

Pounds Per Day Construction Phase VOC NOX CO SOX PM10 PM2.5 Demolition On-Site Emissions 14 127 104 <1 20 9 Off-Site Emissions 1 5 12 <1 1 <1 Total Emissions 15 132 115 <1 21 9 Site Preparation On-Site Emissions 19 185 124 <1 29 20 Off-Site Emissions 1 6 12 <1 1 <1 Total Emissions 20 191 136 <1 30 20 Grading On-Site Emissions 12 133 83 <1 13 9 Off-Site Emissions 1 8 14 <1 1 <1 Total Emissions 13 141 97 <1 14 9 Building Construction On-Site Emissions 32 295 197 <1 18 17 Off-Site Emissions 1 7 19 <1 3 1 Total Emissions 33 302 217 <1 21 18 Paving On-Site Emissions 4 37 36 <1 2 2 Off-Site Emissions <1 1 3 <1 <1 <1 Total Emissions 4 38 39 <1 2 2 Architectural Coatings On-Site Emissions 415 12 14 <1 1 <1 Off-Site Emissions <1 <1 1 <1 <1 <1 Total Emissions 415 12 15 <1 1 <1

Maximum Regional Total 415 302 217 <1 30 20 Regional Significance Threshold 75 100 550 150 150 55 Exceed Threshold? Yes Yes No No No No

Maximum Localized Total 415 295 197 <1 29 20 Localized Significance Threshold -- 172 1,434 -- 14 8 Exceed Threshold? N/A Yes No N/A Yes Yes Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. LST analyses based on 5 acre site with 25 meter distances to receptors in East San Fernando Valley source receptor area. Modeling provided in Appendix C to this Final EIR.

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Regional Impacts

As shown in Table 4B-5, the construction of Alternative 4B would produce CO, SOX, PM10 and PM2.5 emissions that do not exceed the SCAQMD’s regional thresholds. However, NOX emissions from operation of diesel-fueled construction equipment would exceed the SCAQMD’s recommended thresholds of significance. In addition, VOC emissions from application of architectural coatings would produce fugitive emissions that exceed the SCAQMD’s thresholds for this ozone precursor. As a result, construction of Alternative 4B could contribute to an existing violation of air quality standards for a regional pollutant (i.e., ozone). This impact is therefore considered potentially significant.

Localized Impacts

As shown in Table 4B-5, Alternative 4B would produce emissions that do not exceed the SCAQMD’s recommended localized standards of significance for CO during the construction phase. However, construction activities would produce NOx, PM10, and PM2.5 emissions that exceed localized thresholds recommended by the SCAQMD, primarily from vehicle exhaust and fugitive dust emissions from off- road construction vehicles during the site preparation and building construction phases. As a result, construction impacts on localized air quality are considered potentially significant.

Like the Project, Alternative 4B would implement Mitigation Measures C-1 through C-4, which call for the use of construction equipment that uses EPA-certified Tier 4 engines to reduce combustion-related

PM10 and PM2.5 emissions. Regulatory Compliance Measure C-5 addresses fugitive dust emissions of

PM10 and PM2.5 that would be regulated by SCAQMD Rule 403, which calls for Best Available Control Measures (BACM) that include watering portions of the site that are disturbed during grading activities and minimizing tracking of dirt onto local streets. It should be noted that Table 4B-5 conservatively does not assume the application of BACMs to control fugitive dust. Regulatory Compliance Measure C-6 would call for the use of lower-VOC content coatings that would be applied to the interior and exterior of building surfaces, while Regulatory Compliance Measure C-7 would reduce the amount of coatings applied each day along with the associated emissions from applying these coatings.

Construction Phase Mitigation Measures

Like the Project, Alternative 4B would implement Mitigation Measures C-1 through C-4 and Regulatory Compliance Measures C-5 through C-7.

Impacts After Mitigation

As shown in Table 4B-6, implementation of Mitigation Measures C-1 through C-4 and Regulatory

Compliance Measure C-5 would substantially reduce on-site NOx, PM10 and PM2.5 emissions during the construction process. Similarly, implementation of Regulatory Compliance Measures C-6 and C-7 would reduce VOC emissions below SCAQMD’s recommended threshold of significance for regional ozone precursor emissions. As a result, with mitigation construction activities would represent a less than significant impact.

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Table 4B-6 Alternative 4B - Estimated Daily Construction Emissions (Mitigated)

Pounds Per Day Construction Phase VOC NOX CO SOX PM10 PM2.5 Demolition On-Site Emissions 4 39 108 <1 6 2 Off-Site Emissions 1 5 12 <1 1 <1 Total Emissions 5 44 120 <1 7 2 Site Preparation On-Site Emissions 2 16 104 <1 7 4 Off-Site Emissions 1 6 12 <1 1 <1 Total Emissions 3 22 116 <1 8 4 Grading On-Site Emissions 2 9 69 <1 3 1 Off-Site Emissions 1 8 14 <1 1 <1 Total Emissions 3 17 83 <1 4 2 Building Construction On-Site Emissions 4 23 195 <1 <1 <1 Off-Site Emissions 1 7 19 <1 2 1 Total Emissions 5 30 214 <1 2 1 Paving On-Site Emissions 1 8 38 <1 <1 <1 Off-Site Emissions <1 1 3 <1 <1 <1 Total Emissions 1 9 41 <1 <1 <1 Architectural Coatings On-Site Emissions 73 4 14 <1 <1 <1 Off-Site Emissions <1 <1 1 <1 <1 <1 Total Emissions 73 4 15 <1 <1 <1

Maximum Regional Total 73 44 214 <1 8 4 Regional Significance Threshold 75 100 550 150 150 55 Exceed Threshold? No No No No No No

Maximum Localized Total 73 39 195 <1 7 4 Localized Significance Threshold -- 172 1,434 -- 14 8 Exceed Threshold? N/A No No N/A No No Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. LST analyses based on 5 acre site with 25 meter distances to receptors in East San Fernando Valley source receptor area. Modeling provided in Appendix C to this Final EIR.

Comparison to the Proposed Project

Regional Impacts

As shown in Table 4B-7, construction of Alternative 4B would generate lower amounts of regional emissions of pollutants when compared to the Project.

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Table 4B-7 Comparison of Net Regional Construction Emissions - Mitigated

Comparison of Pollutant Proposed Project Alternative 4B Alternative 4B to Proposed Project VOC 73 73 0 NOx 55 44 -11 CO 272 214 -58 SOx <1 <1 0 PM10 9 8 -1 PM2.5 6 4 -2 Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. Shading represents Significant Unavoidable Impact

Localized Impacts

Construction of Alternative 4B would generate lower amounts of localized emissions of pollutants when compared to the Project, as shown in Table 4B-8.

Table 4B-8 Comparison of Net Localized Construction Emissions - Mitigated

Comparison of Alternative 4B to Pollutant Proposed Project Alternative 4B Proposed Project

NO2 48 39 -9 CO 248 195 -53 PM10 8 7 -1 PM2.5 5 4 -1 Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. Shading represents Significant Unavoidable Impact

Air Quality Impacts During Operation

Regional Impacts

Alternative 4B would also produce long-term air quality impacts to the region primarily from motor vehicles that access the Project Site. Alternative 4B could add 6,600 net vehicle trips to and from the Project Site on a peak weekday at the start of operations in 2020, compared to existing conditions. This is a reduction of 670 daily trips when compared to the Project. Thus, like the Project, net operational emissions would not exceed SCAQMD’s regional significance thresholds for CO, PM10 and PM2.5 emissions. As a result, the Project’s operational impacts on regional air quality are considered less than significant. Because the SCAQMD thresholds are used for evaluating both project-specific and

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City of Los Angeles June 2016 cumulative impacts, neither Alternative 4B nor the Project would make a cumulatively considerable contribution to significant regional air quality impacts.

Localized Impacts

With regard to localized air quality impacts, Alternative 4B would emit minimal emissions of NO2, CO,

PM10, and PM2.5 from area and energy sources on-site. These localized emissions would not approach the SCAQMD’s localized significance thresholds that signal when there could be human health impacts at nearby sensitive receptors during long-term operations. Therefore, Alternative 4B’s operational impacts on localized air quality are considered less than significant. Because the SCAQMD thresholds are used for evaluating both project-specific and cumulative impacts, neither Alternative 4B nor the Proposed Project would make a cumulatively considerable contribution to significant local air quality impacts.

Comparison to the Proposed Project

Regional Impacts

Neither the Project nor Alternative 4B would have significant impacts on regional air quality. Long-term operations of Alternative 4B would generate regional emissions of pollutants that are less than the Project due to the reduction in daily vehicle trips.

Localized Impacts

Similarly, long-term operations of Alternative 4B would generate less localized emissions of pollutants from on-site area and energy sources than the Project because of its smaller development footprint.

Biological Resources

The Project Site is currently fully developed with an existing office building, Macy’s Department Store, and surface parking. The office building and 10,000-square-foot Macy’s annex would be demolished under Alternative 4B. The Project Site contains ornamental landscaping. The Project Site does not contain any natural open spaces, act as a wildlife corridor, contain riparian habitat, wetland habitat, migratory corridors, trees protected under the City’s tree ordinance or areas subject to a Habitat Conservation Plan, or possess any areas of significant biological resource value. Like the Project, Alternative 4B would develop the entire Site and would have no impact with respect to biological resources. For the same reasons, Alternative 4B’s contribution to cumulative biological resources impacts would also be less than cumulatively significant.

Cultural Resources

There are no historic resources at the Project Site and as such, there would be no impact to historic resources under either the Project or Alternative 4B. Like the Project, Alternative 4B would re-use the majority of the existing main Macy’s building. Therefore, Alternative 4B would include the same amount of demolition and grading as compared to the Project, and as such, Alternative 4B would have similar potential to encounter unknown buried archaeological and paleontological resources or human remains as

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City of Los Angeles June 2016 the Project. Similar to the Project, Alternative 4B would have a less than significant impact to cultural resources (with regulatory compliance measures for archaeology, paleontology, and human remains). For the same reasons, Alternative 4B’s contribution to cumulative cultural resources impacts would also be less than cumulatively significant.

Geology and Soils

The Project Site is currently fully developed with an existing office building, Macy’s Department Store, and surface parking. The Project Site presents the same potential geologic and geotechnical conditions for the Project or Alternative 4B. Any development (including development under Alternative 4B) would be subject to the same geotechnical considerations and would be required to occur in conformance with the City’s building code standards. Similar to the Project, Alternative 4B would have a less than significant impact to geology and soils (with a regulatory compliance measure and project design feature related to compliance with the recommendations contained in the geotechnical report). For the same reasons why the Project’s individual geology and soils resources impacts are less than significant, Alternative 4B’s contribution to cumulative geology and soils impacts would also be less than cumulatively significant.

Greenhouse Gas Emissions

Emissions During Construction

As shown in Table 4B-9, construction emissions of CO2e would peak in 2017, when up to 34,736 lbs/day of CO2e are anticipated. These estimates assume implementation of Mitigation Measures C-1 through C-4 and Regulatory Compliance Measure C-6 (provided in Section 4.C, Air Quality of the Draft EIR), which would reduce combustion-related emissions associated with off-road construction equipment. These emissions are incorporated in the assessment of long-term operational impacts by amortizing them over a 30-year period.

Table 4B-9 Alternative 4B - Estimated Daily Construction Emissions (Mitigated)

Construction Year CO2 CH4 N2O CO2e 2017 34,587 7 0 34,736 2018 34,176 7 0 34,322 2019 33,759 7 0 33,903 Source: DKA Planning 2016, based on CalEEMod 2013.2.2. Modeling provided in Appendix C to this Final EIR.

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Table 4B-10 Alternative 4B - Comparison of Construction Greenhouse Gas Emissions (Mitigated)

Comparison of Alternative 4B to Pollutant Proposed Project Alternative 4B Proposed Project

CO2 43,758 34,587 -9,171 CH4 9 7 -2 N2O 0 0 0 CO2e 43,947 34,736 -9,211 Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. Modeling provided in Appendix C to this Final EIR. Shading represents Significant Unavoidable Impact

Emissions During Operation

The analysis in this section estimates potential emissions under NAT scenarios and from the Project at build-out based on actions and AB 32-related mandates for reducing statewide GHG emissions that are approved for implementation by 2020. Early-action measures identified in the Climate Change Scoping Plan that have not been approved were not credited in this analysis. By not speculating on potential regulatory conditions, the analysis takes a conservative approach that likely overestimates the Project’s GHG emissions at build-out.

The NAT scenario is used to establish a comparison with project-generated GHG emissions. The NAT scenario does not consider site-specific conditions, project design features, or prescribed mitigation measures. As an example, a NAT scenario would apply a base ITE trip-generation rate for the project and would not consider site-specific benefits resulting from the proposed mix of uses or close proximity to public transportation. The analysis below establishes NAT as complying with the minimum performance level required under Title 24. The NAT scenario also considers State mandates that were already in place when CARB prepared the Supplemental FED (e.g., Pavley I Standards, full implementation of California’s Statewide Renewables Portfolio Standard beyond current levels of renewable energy, and the California Low Carbon Fuel Standard).

Greenhouse gas emissions were calculated for long-term operations. As shown in Table 4B-11, the emissions for Alternative 4B and its associated CARB 2020 NAT scenario are estimated to be 25,717 and

37,568 MTCO2e per year, respectively, which shows that Alternative 4B would reduce emissions by 31 percent from the CARB 2020 NAT scenario. Based on these results, Alternative 4B meets the reduction target as a numeric threshold (15.3 percent) set forth in the 2014 Revised AB 32 Scoping Plan, as does the Project.

When compared to the Project, as shown in Table 4B-12, Alternative 4B would produce about 3,579 fewer metric tons of CO2e per year.

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Table 4B-11

Alternative 4B - Estimated Annual CO2e Greenhouse Gas Emissions

Reduction from No Change from No Action Action No Action Taken As Proposed Taken Taken Scenario and Source Scenario* Scenario Scenario Scenario Area Sources 170 170 - 0% Energy Sources 10,699 6,206 -4,494 -42% Mobile Sources 24,688 17,331 -7,357 -30% Waste Sources 368 368 - 0% Water Sources 1,374 1,374 - 0% Construction 268 268 - 0% Total Emissions 37,568 25,717 -11,851 -31% Daily construction emissions amortized over 30-year period pursuant to SCAQMD guidance. Annual construction emissions derived by taking total emissions over duration of activities and dividing by construction period. To ensure a conservative estimate, emissions from existing development were not included in the calculation of net emissions increases.

* NAT scenario does not assume 30% reduction in in mobile source emissions from Pavley emission standards (19.8%), low carbon fuel standards (7.2%), vehicle efficiency measures 2.8%); does not assume 42% reduction in energy production emissions from the State’s renewables portfolio standard (33%), natural gas extraction efficiency measures (1.6%), and natural gas transmission and distribution efficiency measures (7.4%).

Source: DKA Planning, 2016. Modeling provided in Appendix C to this Final EIR.

Table 4B-12 Alternative 4B - Comparison of Operations Greenhouse Gas Emissions (Mitigated)

Comparison of Alternative 4B to Pollutant Proposed Project Alterative 4B Proposed Project

CO2e 29,296 25,717 -3,579 Source: DKA Planning, 2016 based on CalEEMod 2013.2.2 model runs. Modeling provided in Appendix C to this Final EIR. Shading represents Significant Unavoidable Impact

The analysis in this section uses the 2014 Revised AB 32 Scoping Plan's statewide goals as one approach to evaluate the Project’s impact (i.e., 15.3 percent reduction from NAT). The methodology is to compare the Project’s emissions as proposed to the Project’s emissions if the Project were built using a NAT approach in terms of design, methodology, and technology. This means the Project's emissions were calculated as if it were constructed with project design features to reduce GHG and with several regulatory measures adopted in furtherance of AB 32.

NAT comparison based on the Scoping Plan is appropriate because the proposed project would contribute to statewide GHG reduction goals. Specifically, the Project’s mixed-use nature and location in an

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City of Los Angeles June 2016 existing urban setting provide opportunities to reduce transportation-related emissions. First, it would capture vehicle travel on-site that would have normally been destined for off-site locations. This produces substantial reductions in the amount of vehicle trips and vehicle miles traveled that are no longer made. Second, it would attract existing trips on the street network. Table 4B-13 Daily Vehicle Travel Reductions Reduction from Reduction from Reduction from Land Use Internal Capture Pass-By Trips Transit/Walk-In Trips Apartments 15% 0% 0% Movie Theater 0% 10% 0% Office 5% 0% 0% Retail 15% 30% 0% Source: The Mobility Group, January 2016.

As illustrated in Table 4B-13, the Project’s profile as an urban infill, mixed-use project will produce substantial reductions over land uses that are located in a more typical community that has not coordinated its land use and transportation planning. The projected reductions in vehicle trips and VMT would range from 0-30 percent in reductions from pass-by trips and up to 15 percent reductions from the internal capture of trips between land uses. These would result in concomitant reductions in CO2e emissions that far exceed the State’s AB 32 Scoping Plan goal of a 4.5 percent reduction from the overall transportation sector by 2020. It should be noted that each source category of GHG emissions is subject to a number of regulations that directly or indirectly reduce climate change-related emissions:

 Stationary and area sources. Emissions from small on-site sources are subject to specific emission reduction mandates and/or are included in the State’s Cap and Trade program.

 Transportation. Both construction and operational activities from the Project site would generate transportation-related emissions from combustion of fossil fuels whose production is covered in the State’s Cap and Trade program.

 Electricity Use. Both construction and operational activities from the Project site would generate energy-related emissions that are covered by the State’s renewable portfolio mandates, including SB 350, which requires that at least 50 percent of electricity generated and sold to retail customers from renewable energy sources by December 31, 2030. Generation of non-renewable energy is covered in the State’s Cap-and-Trade program.

 Natural Gas and other energy sources. The Project’s emissions from natural gas combustion would be mitigated from new appliance and building efficiency standards that will be the product of collaboration with the U.S. Department of Energy and investor-owned utilities that will be implementing further energy efficiency programs. Further, energy use in the future would include improved storage of energy from renewable sources like solar and wind that would reduce reliance on fossil fuels.

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 Building structures. Operational efficiencies will be built into the Project that reduce energy use and waste, as mandated by the City’s Green Building code.

 Water and wastewater use. The Project would be subject to drought-related water conservation emergency orders, related State Water Quality Control Board restrictions, and Water Efficient Landscaping requirements.

 Major appliances. The Project would include major appliances that are regulated by California Energy Commission requirements for energy efficiency.

 Solid waste management. The Project would be subject to solid waste diversion policies administered by CalRecycle that reduce GHG emissions.

Consistency with the AB 32 Scoping Plan

The AB 32 Scoping Plan provides the basis for policies that will reduce cumulative GHG emissions within California to 1990 levels by 2020. Table 4B-14 evaluates the Project’s consistency with the AB 32 Scoping Plan and shows that the Project is consistent with the AB 32 Scoping Plan’s focus on emission reductions from several key sectors:

 Energy Sector: Continued improvements in California’s appliance and building energy efficiency programs and initiatives, such as the State’s zero net energy building goals, would serve to reduce the Project’s emissions level.17 Additionally, further additions to California’s renewable resource portfolio would favorably influence the Project’s emissions level.18

 Transportation Sector: Anticipated deployment of improved vehicle efficiency, zero emission technologies, lower carbon fuels, and improvement of existing transportation systems all will serve to reduce the Project’s emissions level.19

 Water Sector: The Project’s emissions level will be reduced as a result of further desired enhancements to water conservation technologies.20

 Waste Management Sector: Plans to further improve recycling, reuse and reduction of solid waste will beneficially reduce the Project’s emissions level.21

17 CARB, First Update, pp. 37-39, 85, May 2014.

18 CARB, First Update, pp. 40-41, May 2014.

19 CARB, First Update, pp. 55-56, May 2014.

20 CARB, First Update, p. 65, May 2014.

21 CARB, First Update, p. 69, May 2014.

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Table 4B-14 Project Consistency with AB 32 Scoping Plan Greenhouse Gas Emission Reduction Strategies Strategy Project Consistency California Cap-and-Trade Program. Implement a broad-based Not Applicable. The Project is not subject to California cap-and-trade program to provide a firm limit on the cap-and-trade program. emissions. California Light-Duty Vehicle Greenhouse Gas Standards. Implement adopted Pavley standards and planned second phase Not Applicable. The development of of the system. Align zero-emission vehicle, alternative and standards is not applicable to the Project. renewable fuel and vehicle technology programs with long-term climate change goals. Energy Efficiency. Maximize energy efficiency building and Consistent. The Project is designed to meet appliance standards and pursue additional efficiency efforts Cal Green building standards by including including new technologies, and new policy and mechanisms. several measures designed to reduce energy Pursue comparable investment in energy efficiency from all retail consumption. providers of electricity in California. Consistent. The Project will utilize energy Renewables Portfolio Standard. Achieve 33 percent renewable from the Los Angeles Department of Water and energy mix statewide. Power, which is subject to the Renewables Portfolio Standard. Low-Carbon Fuel Standard. Develop and adopt the Low Not Applicable. This is a statewide program, Carbon Fuel Standard. which is not applicable to the Project. Regional Transportation-Related Greenhouse Gases. Not Applicable. The development of regional Develop regional greenhouse gas emissions reduction targets for planning goals is not applicable to the Project. passenger vehicles. Not Applicable. State agencies are responsible Vehicle Efficiency Measures. Implement light-duty vehicle for implementing vehicle efficiency measures, efficiency measures. therefore, this is not applicable to the Project. Not Applicable. State agencies are responsible Goods Movement. Implement adopted regulations for the use of for implementing regulations and promoting shore power for ships at berth. Improve efficiency in goods efficiency in goods movement, therefore, this is movement activities. not applicable to the Project. Neutral. The Project does not include solar Million Solar Roofs Program. Install 3,000 MW of solar- roofs and is not part of the proposed Statewide electric capacity under California’s existing solar programs. initiative. Not Applicable. State agencies are responsible Medium/Heavy-Duty Vehicles. Adopt medium and heavy-duty for implementing efficiency measures, vehicle efficiency measures. therefore, this is not applicable to the Project. Industrial Emissions. Require assessment of large industrial sources to determine whether individual sources within a facility Not Applicable. This measure addresses can cost-effectively reduce greenhouse gas emissions. Reduce industrial facilities, which are not included in greenhouse gas emissions from fugitive emissions from oil and the Project. gas extraction and gas transmission. Not Applicable. This calls for the California High Speed Rail Authority and stakeholders to High Speed Rail. Support implementation of a high speed rail develop a statewide rail transportation system. system. The Project does not include a High Speed Rail component. Therefore, this is not applicable to the Project. Green Building Strategy. Expand the use of green building Consistent. The Project is designed to meet practices to reduce the carbon footprint of California’s new and the City’s Green Building Ordinance and Cal existing inventory of buildings. Green building standards. Not Applicable. State agencies are responsible High Global Warming Potential Gases. Adopt measures to for implementing these measures, therefore, reduce high global warming potential gases. this is not applicable to the Project.

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Strategy Project Consistency Recycling and Waste. Reduce methane emissions at landfills. Increase waste diversion, composting and other beneficial uses of Consistent. The Project would comply with organic materials and mandate commercial recycling. Move the City’s waste diversion ordinances. toward zero waste. Not Applicable. Resource Agency departments are responsible for implementing Sustainable Forests. Preserve forest sequestration and this measure and the Project site is not forested; encourage the use of forest biomass for sustainable energy therefore, this is not applicable to the Project. generation. The Project would, however, result in a substantial increase in the number of trees on the Project site. Consistent. The Project would comply with all Water. Continue efficiency programs and use cleaner energy water conservation requirements of state and sources to move and treat water. local law, including water-efficient landscaping. Agriculture. In the near-term, encourage investment in manure Not Applicable. The Project does not include digester and at the five-year Scoping Plan update determine if the agricultural facilities. program should be made mandatory by 2020. Source: DKA Planning, 2016.

Based on this evaluation, the Project would be consistent with all feasible and applicable strategies recommended in the AB 32 Scoping Plan.

Consistency with SCAG’s 2016-2040 RTP/SCS

At the regional level, the 2016-2040 RTP and Sustainable Communities Strategy defines strategies for reducing GHGs. This section analyzes the Project’s land use profile for consistency with those in the Sustainable Communities Strategy. Table 4B-15 Project Consistency with SCAG 2016-2040 RTP/SCS Responsible Actions and Strategies Party(ies) Consistency Analysisa Land Use Strategies Reflect the changing Local Consistent. The Project would include residences that would population and demands, jurisdictions add to the supply of housing in metropolitan Los Angeles including combating County. gentrification and displacement, by increasing housing supply at a variety of affordability levels. Focus new growth around Local Consistent. The Project is an infill development that would transit. Jurisdictions be consistent with the 2016 RTP/SCS focus on growth near transit facilities. Plan for growth around livable SCAG, Local Consistent. The Project is an infill development that would corridors, including growth on Jurisdictions be consistent with the 2016 RTP/SCS focus on locating the Livable Corridors growth in areas with sufficient transportation infrastructure. network. Provide more options for short SCAG, Local Consistent. The project is consistent with the RTP’s trips through Neighborhood Jurisdictions Complete Communities initiative that focuses on creation of

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Responsible Actions and Strategies Party(ies) Consistency Analysisa Mobility Areas and Complete mixed-use districts in growth areas that would produce shorter Communities. trips by virtue of improved jobs/housing balances. Support local sustainability Local Consistent. This strategy calls on local governments to adopt planning, including Jurisdictions General Plan updates, zoning codes, and Climate Action Plans developing sustainable to further sustainable communities. The Project would be planning and design policies, consistent with the City’s adopted sustainable planning and sustainable zoning codes, and design policies. Climate Action Plans. Protect natural and farm lands, SCAG Consistent. The Project is an infill development that would including developing Local help reduce demand for growth in greenfields and open conservation strategies. Jurisdictions spaces. Transportation Strategies Preserve our existing SCAG Not Applicable. This strategy calls on investing in the transportation system. County maintenance of our existing transportation system The Project Transportation would be consistent with the strategy. Commissions Local Jurisdictions Manage congestion through County Consistent. The Project is an infill development that would programs like the Congestion Transportation minimize congestion impacts on the region because of its Management Program, Commissions proximity to public transit, Complete Communities, and Transportation Demand Local general density of population and jobs. Management, and Jurisdictions Transportation Systems Management strategies. Promote safety and security in SCAG Not Applicable. This strategy aims to improve the safety of the transportation system. County the transportation system and protect users from security Transportation threats, which does not apply to the Project. Commissions Local Jurisdictions Complete our transit, SCAG Not Applicable. This strategy calls for transportation passenger rail, active County planning partners to implement major capital and operational transportation, highways and Transportation projects that are designed to address regional growth, which arterials, regional express Commissions does not apply to the Project. lanes, goods movement, and Local airport ground transportation Jurisdictions systems. Technological Innovation and 21st Century Transportation Promote zero-emissions SCAG Consistent. This action/strategy is not necessarily applicable vehicles. Local on a project-specific basis, however, the Project would Jurisdictions include pre-wiring for electric vehicle charging infrastructure. Promote neighborhood SCAG Consistent. This action/strategy is not necessarily applicable electric vehicles. Local on a project-specific basis, however, the Project would Jurisdictions include pre-wiring for electric vehicle charging infrastructure. Implement shared mobility SCAG Not Applicable. This strategy is designed to integrate new programs. Local technologies for last-mile and alternative transportation Jurisdictions programs, which does not apply to the Project. While projects can implement such programs, the initiative is designed to be developed and implemented through jurisdiction-level strategies that promote community-level mobility options.

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Responsible Actions and Strategies Party(ies) Consistency Analysisa Source: Southern California Association of Governments; 2016–2040 RTP/SCS, Chapter 5: The Road to Greater Mobility and Sustainable Growth; April 2016.

Table 4B-15 demonstrates the Project’s consistency with the Actions and Strategies set forth in the 2016- 2040 RTP/SCS. The Project would also be consistent with the applicable goals and principles set forth in the 2016-2040 RTP/SCS. Therefore, the Project would be consistent with the GHG reduction related actions and strategies contained in the 2016-2040 RTP/SCS.

Consistency with the City of Los Angeles ClimateLA Implementation Plan

Construction of the Project would be consistent with the “ClimateLA” implementation plan, including its goal of making Los Angeles a worldwide leader in green buildings. Specifically, compliance with the City’s LEED-based requirements will produce energy savings for construction projects envisioned in Action E6 (Present a comprehensive set of green building policies to guide and support private sector development).

Construction of the Project is consistent with the “ClimateLA” plan’s goal of reducing or recycling 70 percent of trash (including construction waste) by 2015. The Project would promote this goal by complying with waste reduction measures mandated by CALGreen and City’s Green Building Code, as well as solid waste diversion policies administered by CalRecycle that in turn reduce GHG emissions.

The Project's long-term operations are also consistent with the “ClimateLA” focus on transportation, energy, water use, land use, waste, open space and greening, and economic factors to achieve emissions reductions.

With regard to transportation, the Project is consistent with the “ClimateLA” focus on reducing emissions from private vehicle use. Specifically, the site’s infill location with immediate access to public transit facilities results in a transit-oriented development that will help to reduce vehicle use. Further, the mixed- use nature of the Project is consistent with “ClimateLA” land use policies that promote high density near transportation, transit-oriented development, and making underutilized land available for housing and mixed-use development, especially when near transit.

To reduce emissions from energy usage, the Project would be consistent with “ClimateLA” and its focus on increasing the amount of renewable energy provided by the LADWP; presenting a comprehensive set of green building policies to guide and support private sector development; and helping citizens to use less energy. Both construction and operational activities at the Project Site would use electricity generated substantially by renewable energy sources under the State’s renewable portfolio mandates, including SB 350, which requires that at least 50 percent of electricity generated and sold to retail customers come from renewable energy sources by December 31, 2030. In addition, as described below, emissions from energy usage would be reduced through compliance with the City’s Green Building Ordinance.

With regard to water, the Project would be consistent with the “ClimateLA” goal of reducing water from

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City of Los Angeles June 2016 growth through water conservation and recycling; reducing per capita water consumption by 20 percent; and implementing the City’s water and wastewater integrated resources plan that will increase conservation, and maximize the capture and reuse of storm water. Specifically, the Project would be subject to drought-related water conservation emergency orders and related State Water Quality Control Board restrictions, as well as CALGreen and City Green Building Code that call for water-conserving fixtures and processes, and the City’s Water Efficient Landscaping ordinance.

With regard to waste, the Project would be consistent with the “ClimateLA” goal of reducing or recycling 70 percent of trash. Operational efficiencies would be built into the Project that reduce energy use and waste, as mandated by the City’s Green Building Code and CALGreen building code. With regard to ongoing operations, the Project would be subject to solid waste diversion policies administered by CalRecycle that reduce GHG emissions.

With regard to open space and greening, the Project would not interfere with “ClimateLA” and its focus on creating 35 new parks; revitalizing the Los Angeles River to create open space opportunities; planting one million trees throughout the City; identifying opportunities to “daylight” streams; identifying promising locations for stormwater infiltration to recharge groundwater aquifers; and collaborating with schools to create more parks in neighborhoods. The Project would decrease existing impervious surfaces on the Project site and would add trees.

Consistency with the City of Los Angeles Green Building Ordinance

The Los Angeles Green Building Ordinance requires that all projects filed on or after January 1, 2014 comply with the Los Angeles Green Building Code as amended to comply with the 2013 CALGreen Code. Mandatory measures under the Green Building Ordinance that would help reduce GHG emissions include short and long term bicycle parking measures; designated parking measure; and electric vehicle supply wiring. The Project would comply with these mandatory measures, as the Project would provide on-site bicycle parking spaces. Furthermore, the Green Building Ordinance includes measures that would increase energy efficiency on the Project Site, including installing Energy Star rated appliances and water-conserving fixtures. Therefore, the Project is consistent with the Los Angeles Green Building Ordinance.

The Project will comply with the City of Los Angeles’ Green Building Ordinance standards that compel LEED certification, reduce emissions beyond a “Business-as-Usual” scenario, and are consistent with the AB 32 Scoping Plan’s recommendation for communities to adopt building codes that go beyond the State’s codes. Under the City’s Los Angeles Green Building Code, the Project must incorporate several measures and design elements that reduce the carbon footprint of the development, including:

1. GHG Emissions Associated with Planning and Design. The Project will have measures to reduce storm water pollution, provide designated parking for bicycles and low-emission vehicles, have wiring for electric vehicles, reduce light pollution, and design grading and paving to keep surface water from entering buildings, such as:

 Reduced parking based on compliance with the City’s bicycle parking ordinance.

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 Access to several public transportation lines. The area is well-served by public transit, include the following routes:

o Metro 230 serves Laurel Canyon Boulevard on weekdays and Saturdays.

o Metro 165 serves Vanowen Street on weekdays and Saturdays.

o Metro 164 serves Victory Boulevard on weekdays and weekends.

o Metro 154 serves Oxnard Street on weekdays only.

 Located near residential neighborhoods. The Project Site’s proximity to medium- and high- density residential neighborhoods increases the likelihood that more travel to and from the development will be made by non-motorized modes that will reduce potential GHG emissions.

2. GHG Emissions Associated with Energy Demand. The Project will meet Title 24 2013 standards and include Energy Star appliances, have pre-wiring for future solar facilities, and off- grid pre-wiring for future solar facilities. This includes:

 Use of low-emitting paints, adhesives, carpets, coating, and other materials.

 Equipment and fixtures will comply with the following where applicable:

o Installed gas-fired space heating equipment will have an Annual Fuel Utilization Ratio of .90 or higher.

o Installed electric heat pumps will have a Heating Seasonal Performance Factor of 8.0 or higher.

o Installed cooling equipment will have a Seasonal Energy Efficiency Ratio higher than 13.0 and an Energy Efficiency Ratio of at least 11.5.

o Installed tank type water heaters will have an Energy Factor higher than .6.

o Installed tankless water heaters will have an Energy Factor higher than .80.

o Perform duct leakage testing to verify a total leakage rate of less than 6 percent of the total fan flow.

o Building lighting in the kitchen and bathrooms within the dwelling units will consist of at least 90 percent ENERGY STAR qualified hard-wired fixtures (luminaires).

 An electrical conduit will be provided from the electrical service equipment to an accessible location in the attic or other location suitable for future connection to a solar system. The conduit shall be adequately sized by the designer but shall not be less than one inch. The

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conduit shall be labeled as per the Los Angeles Fire Department requirements. The electrical panel shall be sized to accommodate the installation of a future electrical solar system.

 A minimum of 250 square feet of contiguous unobstructed roof area will be provided for the installation of future photovoltaic or other electrical solar panels. The location shall be suitable for installing future solar panels as determined by the designer.  Appliances will meet ENERGY STAR if an ENERGY STAR designation is applicable for that appliance.

3. GHG Emissions Associated with Water Use. The Project would be required to provide a schedule of plumbing fixtures and fixture fittings that reduce potable water use within the development by at least 20 percent. The Project will also provide irrigation design and controllers that are weather- or soil moisture-based and automatically adjust in response to weather conditions and plants’ needs. Wastewater reduction measures will be included that help reduce outdoor potable water use. This would include:

 A schedule of plumbing fixtures and fixture fittings that will reduce the overall use of potable water within the building by at least 20 percent shall be provided. The reduction shall be based on the maximum allowable water use per plumbing fixture and fitting as required by the California Building Standards Code. The 20 percent reduction in potable water use shall be demonstrated by one of the following methods:

o Each plumbing fixture and fitting shall meet reduced flow rates specified on Table 4.303.2; or

o A calculation demonstrating a 20 percent reduction in the building “water use” baseline will be provided.

 When single shower fixtures are served by more than one showerhead, the combined flow rate of all the showerheads will not exceed specified flow rates.

 When automatic irrigation system controllers for landscaping are provided and installed at the time of final inspection, the controllers shall comply with the following:

o Controllers shall be weather- or soil moisture-based controllers that automatically adjust irrigation in response to changes in plants' needs as weather conditions change;

o Weather-based controllers without integral rain sensors or communication systems that account for local rainfall shall have a separate wired or wireless rain sensor that connects or communicates with the controller(s).

4. GHG Emissions Associated with Solid Waste Generation. The Project is subject to construction waste reduction of at least 50 percent. In addition, Project Site operations are

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subject to AB 939 requirements to divert 50 percent of solid waste to landfills through source reduction, recycling, and composting. The Project is required by the California Solid Waste Reuse and Recycling Access Act of 1991 to provide adequate storage areas for collection and storage of recyclable waste materials.

5. GHG Emissions Associated with Environmental Quality. The Project must meet strict standards for any fireplaces and woodstoves, covering of duct openings and protection of mechanical equipment during constructions, and meet other requirements for reducing emissions from flooring systems, any CFC and halon use, and other project amenities. This would include:

o Openings in the building envelope separating conditioned space from unconditioned space needed to accommodate gas, plumbing, electrical lines and other necessary penetrations must be sealed in compliance with the California Energy Code.

o Provide flashing details on the building plans which comply with accepted industry standards or manufacturer’s instructions around windows and doors, roof valley, and chimneys to roof intersections.

Consistency with the City of Los Angeles Mobility 2035 Plan

The Mobility 2035 Plan focuses on developing a multi-modal transportation system, and its key policy initiatives include considering the strong link between land use and transportation and targeting GHG reductions through a more sustainable transportation system. The Project is fully consistent with these general objectives, including the most relevant strategy, Program No. D7, which calls for the development of GHG tracking program that would quantify reductions in GHG from reductions in vehicle miles traveled.

In sum, the GHG strategies referenced in this section encourage providing recreational, cultural, and a range of shopping, entertainment and services all within a relatively short distance; providing employment near current and planned transit stations and neighborhood commercial centers; and supporting alternative fueled and electric vehicles. The analysis provided shows that the project would be consistent with (1) the AB 32 Scoping Plan; (2) SCAG's Sustainable Communities Strategy; and (3) the City's Green Building Ordinance, ClimateLA Implementation Plan, and Mobility 2035 Plan. As a result, the Project would be consistent with applicable State, regional and local GHG reduction strategies. Therefore, the Project would generate GHG emissions that are less than significant because they would not make a cumulatively considerable contribution to climate change.

Hazards and Hazardous Materials

The Project Site is currently fully developed with an existing office building, Macy’s Department Store, and surface parking. The office building, 10,000-square-foot Macy’s annex building, and 13,000 square feet of the Macy’s building would be demolished, and an additional 20,000 square feet of the Macy’s building would be removed under Alternative 4B. The remainder of the Macy’s building would remain on-site and be re-used as part of Alternative 4B. This Alternative would also add 658 residential units,

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189,184 square feet of office, and 382,816 square feet of commercial (retail, restaurant, health club, and cinema uses). Like the Project, Alternative 4B would have the potential to result in impacts with respect to asbestos, PCBs, and lead-based paint at the Project Site. During Alternative 4B’s demolition phase, asbestos, PCBs, and lead-based paint could be encountered. Regulatory Compliance Measures G-1 through G-3 were identified in the Draft EIR for the Project to ensure that no significant impacts related to the accidental release of these materials would occur. Alternative 4B would also be required to comply with these recommendations.

In addition, the Project Site would be developed with residential and commercial land uses that would involve the use and storage of small quantities of potentially hazardous materials in the form of cleaning solvents, paints, and pesticides for landscaping. All transport, use, and disposal of all hazardous materials would be done in accordance with all applicable City, state, and federal regulations related to transport, use, and disposal of hazardous materials that ensure that no significant impacts related to this issue would occur.

With implementation of Regulatory Compliance Measures G-1 through G-3, impacts related to hazards and hazardous materials under Alternative 4B would be less than significant, and the same as the Project’s impacts. For the same reasons why the Project’s cumulative hazards impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative hazards impacts would also be less than cumulatively significant.

Hydrology and Water Quality

Under Alternative 4B, demolition and construction would occur, and the Project Site would be developed with new commercial and residential land uses. The existing Site is nearly entirely covered with impervious surface. Like the Project, Alternative 4B would also develop the entire Site. Through compliance with NPDES requirements and City grading regulations, Alternative 4B’s impacts related to water quality during construction would be less than significant, similar to the Project. Alternative 4B would be served by the municipal water and sewer system and no production wells for a source of water would be installed. Drainage and runoff would be similar to the Project, as Alternative 4B would develop the entire Site. Overall, Alternative 4B would have a less than significant impact to hydrology and water quality (with regulatory compliance measures for storm water pollution control, grading and erosion control, stormwater best management practices, and low impact development), and the impacts would be the same as for the Project. For the same reasons why the Project’s cumulative hydrology impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative hydrology impacts would also be less than cumulatively significant.

Land Use and Planning

The Project Site is currently fully developed with an existing office building, Macy’s Department Store, and surface parking. The office building, 10,000-square-foot Macy’s annex building, and 13,000 square feet of the Macy’s building would be demolished, and an additional 20,000 square feet of the Macy’s building would be removed under Alternative 4B. The remainder of the Macy’s building would remain on-site and be re-used as office, parking, restaurant, and retail as part of Alternative 4B. In total,

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Alternative 4B would add 658 residential units, 189,184 square feet of office, and 382,816 square feet of commercial (retail, restaurant, health club, and cinema uses). As such, and as listed above, development of Alternative 4B would require similar discretionary approvals as the Project. Because Alternative 4B would provide a similar mix of uses as the Project, it would meet policy objectives relating to walkability, pedestrian activation, and reduction in vehicle miles traveled to the same extent as the Project. Finally, similar to the Project, Alternative 4B would not physically divide an established community nor would it conflict with a habitat conservation plan. Overall, this Alternative would result in no significant impact with respect to land use. For the same reasons why the Project’s cumulative land use and planning impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative land use and planning impacts would also be less than cumulatively significant.

Mineral Resources

The Project Site is not located within a City-designated oil field or oil drilling area, or a City-designated Mineral Resource Zone (MRZ-2). Similar to the Project, Alternative 4B would have no impact on mineral resources. For the same reasons why the Project’s cumulative mineral resources impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative mineral resources impacts would also be less than cumulatively significant.

Noise

Noise During Construction

Under Alternative 4B, the office building, 10,000-square-foot Macy’s annex building, and 13,000 square feet of the Macy’s building would be demolished, and an additional 20,000 square feet of the Macy’s building would be removed. While the scope of construction would differ from the Project, Alternative 4B would employ the same types of construction equipment near off-site sensitive receptors and produce the same impacts on ambient noise levels at off-site sensitive receptors. As such, Alternative 4B would produce on-site construction-related noise impacts that would be considered potentially significant.

Mitigation Measures J-1 through J-7 are recommended to reduce the incremental increase in noise levels below the 5 dB noise increase significance threshold at sensitive receptors and reduce resulting ambient noise impacts from construction equipment below 75 dBA. Implementation of Mitigation Measures J-1 through J-7 would minimize ambient noise increases at the nearby residential and school receptors below the 5 dBA threshold of significance, and impacts would be less than significant. For the same reasons why the Project’s cumulative construction noise impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative construction noise impacts would also be less than cumulatively significant.

Noise During Operation

Like the Project, Alternative 4B would produce both direct noise impacts on the site from residential and commercial-related activities, as well as indirect noise impacts from vehicles traveling on local roads to access the site. Direct sources of on-site noise include HVAC systems, intermittent landscape

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City of Los Angeles June 2016 maintenance, residential activities, and auto-related activities, and would not be expected to individually or collectively elevate ambient noise levels substantially at nearby sensitive receptors. The potential noise impact from these on-site operational sources would be considered less than significant.

Alternative 4B would add 6,600 net daily trips on an average day. However, this is a reduction of approximately 670 daily trips when compared to the Project. Since the Project would increase ambient noise levels on local roadways no more than 0.5 dBA Leq, Alternative 4B would also have no audible impact on local roadway noise levels, based on a reduction in the number of trips. The potential noise impact from indirect traffic sources would therefore be considered a less than significant impact.

For the same reasons why the Project’s cumulative operational noise impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative operational noise impacts would also be less than cumulatively significant.

Population, Housing, and Employment

Alternative 4B would add 658 residential units, 189,184 square feet of office, and 382,816 square feet of commercial (retail, restaurant, health club, and cinema uses) to the Project Site. As shown in Table 4B-16, Alternative 4B - Estimated Population Generation, Alternative 4B would generate approximately 1,638 residents, which is reduced when compared to the Project’s residential population, based on the reduction in the number of residential units. Like the Project, Alternative 4B would represent a small percent of the estimated population and housing growth in the City, and would be within the City’s growth estimates and RHNA allocation. In addition, Alternative 4B would help respond to the unmet housing demand in both the North Hollywood Community Plan and the City as a whole. Specifically, Alternative 4B would help achieve a portion of the household growth forecast for the City of Los Angeles, while also being consistent with regional policies to reduce urban sprawl and efficiently utilize existing infrastructure. Thus, while Alternative 4B does propose additional housing units, it would not induce housing growth beyond forecasted levels.

As shown in Table 4B-17, Alternative 4B – Estimated Employee Generation, Alternative 4B would generate 1,122 net employees after the removal of the existing uses. As for the Project, the addition of employees to the Project Site could come from the Project area and other areas in Los Angeles, especially since the types of land uses (retail, restaurant, and office) are not specialized so as to compel a net increase in employees from a region outside the local area (or Los Angeles). Thus, the employees are assumed to be housed in the local area or Los Angeles, and can access the Project Site through multiple modes of transit.

As such, implementation of Alternative 4B would not cause substantial, unplanned growth, and no impact to population and housing. For the same reasons why the Project’s cumulative population, housing, and employment impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative population, housing, and employment impacts would also be less than cumulatively significant.

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Table 4B-16 Alternative 4B - Estimated Population Generation

Land Use Quantity Generation Rates Total Proposed Uses Residential 658 units 2.49 person / unit 1,638 RCLCO, March 2015. Household size is based on American Communities Survey. Table: CAJA Environmental Services, 2016.

Table 4B-17 Alternative 4B - Estimated Employee Generation

Land Use Size Generation Rates1 Total Proposed Uses Office 189,184 sf 4 employees / 1,000 sf 757 Retail 208,171 sf 3 employees / 1,000 sf 625 Restaurant 66,645 sf 3 employees / 1,000 sf 200 Health Club/Gym 40,000 sf 3 employees / 1,000 sf 120 Cinema 68,000 sf 30 employees / theater 30 Subtotal Proposed 1,732 Existing Uses (Removed) (610) Total Net (Proposed – Existing) 1,122 Note: sf = square feet 1RCLCO, March 2015. Employment density is based on RCLCO assumptions. Table: CAJA Environmental Services, 2016.

Public Services

Fire Protection

As shown in Table 4B-16, Alternative 4B would result in fewer residents when compared to the Project, based on a reduction in residential units. In addition, as shown in Table 4B-17, Alternative 4B would result in a net increase of 1,122 employees at the Project Site, compared to the 2,114 employees who would be generated by the Project. Therefore, Alternative 4B would result in a lesser demand for fire protection when compared to the Project, based on the reduction of residents and employees. In addition, Alternative 4B would be subject to Regulatory Compliance Measures L.1-1 through L.1-4 and Project Design Features L.1-5 through L.1-8, which would ensure conformance with the Fire Code and would ensure that construction and operational impacts related to fire services, including access, remain less than significant. Overall, Alternative 4B would have a less than significant impact with respect to fire

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City of Los Angeles June 2016 protection. For the same reasons why the Project’s cumulative fire protection impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative fire protection impacts would also be less than cumulatively significant.

Police

As shown in Table 4B-16, Alternative 4B would result in fewer residents at the Project Site when compared to the Project, based on the reduction in residential units. In addition, as shown in Table 4B-17, Alternative 4B would result in a net increase of 1,122 employees at the Project Site, compared to the 2,114 employees who would be generated by the Project. Therefore, Alternative 4B would result in a lesser demand for police protection when compared to the Project based on the reduction in residents and employees. In addition, Alternative 4B would be subject to the same mitigation measures to ensure that impacts to police services are less than significant. With implementation of Mitigation Measures L.2-1 and L.2-2 and Project Design Features L.2-3 through L.2-6, impacts related to police protection under Alternative 4B would be less than significant. For the same reasons why the Project’s cumulative police impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative police impacts would also be less than cumulatively significant.

Schools

As shown in Table 4B-18, Alternative 4B - Estimated Student Generation, based on LAUSD demographic analysis, Alternative 4B would result in approximately 763 LAUSD students (436 elementary students, 109 middle school students, and 218 high school students), compared to the Project’s 1,087 students (622 elementary, 155 middle, and 310 high school students). Thus, Alternative 4B would generate fewer students than the Project. Under Alternative 4B, Victory Elementary and North Hollywood High School would become over capacity. Romer Middle School would have capacity to accommodate the students generated by Alternative 4B. Similar to the Project, Alternative 4B would be subject to the California Government Code, which states that payment of school facilities fees would, by law, mitigate any impacts resulting from a development of a project. With implementation of Regulatory Compliance Measure L.3-1 (school fees payment), impacts related to schools under Alternative 4B would be less than significant. As Alternative 4B would generate fewer students than the Project, its impacts are less than the Project’s impacts, and both would be less than significant. The cumulative projects would be served by a variety of schools, depending on the location. All the cumulative projects that add students would pay school fees and cumulative impacts would therefore be less than significant. For the same reasons why the Project’s cumulative schools impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative schools impacts would also be less than cumulatively significant.

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Table 4B-18 Alternative 4B - Estimated Student Generation

Student Generation Land Use Amount Elementary Middle High Total Multi-Family Dwelling Units 658 263 66 132 461 Non-Residential Uses 1,1221 173 43 86 302 Total 436 109 218 763 1 1,122 employees generate 302 students, using 0.2691 students per employee rate from 2012 Developer Fee Justification Study. Commercial/office rates are for total number of students, not broken down by elementary, middle, or high school. Thus, the total will be broken down by the same relative rate as households: 4:1:2. Source: CAJA Environmental Services, 2016.

Parks and Recreation

Based on Alternative 4B’s estimated population of 1,638 persons and the combined neighborhood and community parkland per population ratio of four acres per 1,000 persons, Alternative 4B would generate a demand of approximately 6.6 acres of new neighborhood and community parkland. Based on six acres of regional parkland per 1,000 residents, Alternative 4B would generate an additional demand for approximately 9.8 acres of regional parkland, for a total demand of 16.4 acres of new parks and recreational facilities, which is less than the Project’s demand for new parkland. Alternative 4B proposes an approximately 15,000-square-foot park, containing such uses as a dog park and children’s play area to be located in the corner next to the Macy’s building (where the annex building is located and where surface parking was proposed for the Project). However, like the Project, Alternative 4B would comply with Regulatory Compliance Measure L.4-1 for the payment of Quimby Fees or the Dwelling Unit Construction Tax. Therefore, Alternative 4B would have a less than significant impact related to parks and recreation, which would be reduced when compared to the Project’s impact. For the same reasons why the Project’s cumulative parks impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative parks impacts would also be less than cumulatively significant.

Libraries

Compared to the Project, Alternative 4B would generate fewer residents and employees. It is not anticipated that Alternative 4B would result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities, or need for new or physically altered library facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for library services. Therefore, like the Project, Alternative 4B would a less than significant impact with respect to libraries. For the same reasons why the Project’s cumulative libraries impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative libraries impacts would also be less than cumulatively significant.

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Traffic and Transportation

The following analysis summarizes information from the following document, which is included as Appendix B to this Final EIR:

 Traffic Study, The Mobility Group, January 11,2016.

Trip Generation

As shown in Table 4B-19, Alternative 4B is expected to generate 6,600 daily trips, 360 AM peak hour trips, and 573 PM peak hour trips. When compared to the Project, Alternative 4B’s trip generation would be 670 fewer daily trips, 350 fewer AM peak hour trips, and 186 fewer PM peak hour trips.

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Table 4B-19 Alternative 4B – Trip Generation Estimates

A.M. Peak Hour PM Peak Hour Daily Trip Equation / Rate Total Trips Trip Equation / Rate Total Trips Source 1 Quantit Trip Equation/ Total Land Use Assumptions & Code y Units Average Rate Trips In Out Total In Out Total In Out Total In Out Total Existing Uses Junior/Community College2 ITE 540 620 ST 1.23 -763 0.10 0.02 0.12 -62 -12 -74 0.08 0.04 0.12 -47 -27 -74 Net College -763 -62 -12 -74 -47 -27 -74 Office3 ITE 710 63,646 SF Ln(T) = 0.76Ln(X) + 3.68 -931 Ln(T) = 0.80Ln(X) + 1.57 -117 -16 -133 T = 1.12(X) + 78.45 -26 -124 -150 Net Office -931 -117 -16 -133 -26 -124 -150 Department Store4,5 ITE 875 465,000 SF 22.88 -10,639 0.37 0.21 0.58 -173 -97 -270 0.98 0.92 1.87 -443 -427 -870 (Reduction for pass-by trips – 20%) 2,128 35 19 54 89 85 174 Net Department Store -8,511 -138 -78 -216 -354 342 -696 Net Existing Uses -10,205 -317 -105 -423 -427 -493 -920 Proposed Use Apartments6 ITE 220 658 DU T = 6.06(X) + 123.56 4,111 T = 0.49(X) + 3.73 65 261 326 T = 0.55(X) + 17.65 247 133 380 (Reduction for Internal trips – 15%) -617 -10 -39 -49 -37 -20 -57 Net Apartments 3,494 55 222 277 210 113 323 Movie Theater7,8,9 ITE 444 1,750 seats 1.76 3,080 0.01 0.01 0.01 9 9 18 0.03 0.05 0.08 51 89 140 (Reduction for pass-by trips – 10%) -308 -1 -1 -2 -5 -9 -14 Net Movie Theater 2,772 8 8 16 46 80 126 Office3 ITE 710 189,184 SF Ln(T) = 0.76Ln(X) + 3.68 2,131 Ln(T) = 0.80Ln(X) + 1.57 281 38 319 T = 1.12(X) + 78.45 49 241 290 (Reduction for Internal Trips – 5%) -107 -14 -2 -16 -3 -12 -15 Net Office 2,024 267 36 303 46 229 275 Retail10,11 ITE 820 314,816 SF Ln(T) = 0.65Ln(X) + 5.83 14,311 Ln(T) = 0.61Ln(X) + 2.24 195 119 314 Ln(T) = 0.67Ln(X) + 3.31 620 672 1,292 (Reduction for Internal Trips – 15%) -2,147 -29 -18 -47 -93 -101 -194 (Reduction for pass-by trips – 30%) -3,649 -50 -30 -80 -158 -171 -329 Net Retail 8,515 116 71 187 369 400 769 Net Proposed 16,805 446 337 783 671 822 1,493 Net Total 6,600 129 231 360 244 329 573 1. ITE Trip Rates from Trip Generation, 9th Edition, Institute of Transportation Engineers, Washington, DC, 2012, except otherwise noted. 2. Source: Average trip rates for ITE 540 – Junior/Community College.

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3. Source: Trip rate equations for ITE 710 – Office. 4. Source: Average trip rates for ITE 875 – Department Store. 5. Department Store land use was adjusted to account for pass-by trips (20%) per LADOT Traffic Study Policies and Procedures, Attachment I – LADOT Policy on Pass-by Trips, August 2014. 6. Source: Trip rate equations for ITE 220 – Apartment. 7. Source: Average trip rates for ITE 444 – Movie Theater With Matinee. 8. Daily trip rates for ITE 444 are not available. Daily rates for ITE 443 – Movie Theater Without Matinee were used. 9. Cinema land use was adjusted to account for pass-by trips (10%) per LADOT Traffic Study Policies and Procedures, Attachment I – LADOT Policy on Pass-by Trips, August 2014. 10. Source: Trip rate equations for ITE 820 – Shopping Center, 11. Retail land use was adjusted to account for pass-by trips (20%) per LADOT Traffic Study Policies and Procedures, Attachment I – LADOT Policy on Pass-by Trips, August 2014. 12. AM peak hour trip rates for ITE 444 are not available. AM peak hour rates for ITE 443 – Movie Theater Without Matinee were used.AM peak hour trip rates for ITE 444 are not available. AM peak hour rates for ITE 443 – Movie Theater Without Matinee were used.

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Intersection Impacts

Future With Project

Tables 4B-20 and 4B-21 provide the intersection impacts under the Future With Project scenario for the AM and PM peak hours, respectively. As shown, Alternative 4B would result in significant impacts at four intersections during the AM peak hour (intersections #8, 11, 12, and 20) and six intersections during the PM peak hour (intersections #4, 8, 11, 12, 13, and 17). The Project would also result in significant impacts at these same intersections. Alternative 4B would also implement Mitigation Measures M-1 through M-7, provided below. As shown in Tables 4B-22 and 4B-23, implementation of Mitigation Measures M-1 through M-7 would reduce all impacts with the exception of intersection #11 during the AM peak hour. Therefore, Alternative 4B would result in two fewer significant impacts (at intersection #20 during the AM peak hour and at intersection #11 during the PM peak hour) than the Project.

Table 4B-20 Alternative 4B - Future With Project Conditions (AM Peak Hour)

Future Without Future With Project Project Change Conditions Conditions in Significant No. Intersection V/C LOS V/C LOS V/C Impact 1 Coldwater Canyon Ave & Victory Blvd 0.936 E 0.940 E 0.004 No 2 Coldwater Canyon Ave & Oxnard St 0.861 D 0.869 D 0.008 No 3 Whitsett Ave & Vanowen St 1.003 F 1.006 F 0.003 No 4 Whitsett Ave & Victory Blvd 0.945 E 0.950 E 0.005 No 5 Whitsett Ave & Oxnard St 0.923 E 0.930 E 0.007 No 6 Whitsett Ave & Burbank Blvd 0.877 D 0.885 D 0.008 No 7 Laurel Canyon Blvd & Vanowen St 0.801 D 0.809 D 0.008 No 8 Laurel Canyon Blvd & Victory Blvd 0.936 E 0.957 E 0.021 Yes 9 Laurel Canyon Blvd & Sylvan St 0.519 A 0.529 A 0.010 No 10 Laurel Canyon Blvd & Erwin St 0.465 A 0.484 A 0.019 No 11 Laurel Canyon Blvd & Oxnard St 1.079 F 1.100 F 0.021 Yes 12 Laurel Canyon Blvd & Burbank Blvd 0.928 E 0.938 E 0.010 Yes 13 SR 170 NB Ramps & Oxnard St 0.740 C 0.754 C 0.014 No 14 Radford Ave & Victory Blvd 0.499 A 0.520 A 0.021 No 15 Radford Ave & Oxnard St 0.380 A 0.421 A 0.041 No 16 Lankershim Blvd & Vanowen St 0.633 B 0.635 B 0.002 No Lankershim Blvd/Colfax Ave & 0.848 D 0.857 D 0.009 No 17 Victory Blvd 18 Colfax Ave & Oxnard St 0.682 B 0.698 B 0.016 No 19 Colfax Ave & Burbank Blvd 0.807 D 0.810 D 0.003 No 20 Lankershim Blvd & Oxnard St 0.781 C 0.803 D 0.022 Yes 21 Tujunga Ave & Victory Blvd 0.629 B 0.633 B 0.004 No 22 Tujunga Ave & Oxnard St 0.499 A 0.501 A 0.002 No 23 Tujunga Ave & Burbank Blvd 1.165 F 1.168 F 0.003 No Source: The Mobility Group, 2016.

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Table 4B-21 Alternative 4B - Future With Project Conditions (PM Peak Hour)

Future Without Future With Project Project Change Conditions Conditions in Significant No. Intersection V/C LOS V/C LOS V/C Impact 1 Coldwater Canyon Ave & Victory Blvd 0.956 E 0.962 E 0.006 No 2 Coldwater Canyon Ave & Oxnard St 0.776 C 0.787 C 0.011 No 3 Whitsett Ave & Vanowen St 0.848 D 0.855 D 0.007 No 4 Whitsett Ave & Victory Blvd 1.047 F 1.058 F 0.011 Yes 5 Whitsett Ave & Oxnard St 0.875 D 0.887 D 0.012 No 6 Whitsett Ave & Burbank Blvd 0.803 D 0.815 D 0.012 No 7 Laurel Canyon Blvd & Vanowen St 0.856 D 0.863 D 0.007 No 8 Laurel Canyon Blvd & Victory Blvd 0.984 E 0.999 E 0.015 Yes 9 Laurel Canyon Blvd & Sylvan St 0.501 A 0.520 A 0.019 No 10 Laurel Canyon Blvd & Erwin St 0.455 A 0.539 A 0.084 No 11 Laurel Canyon Blvd & Oxnard St 1.021 F 1.039 F 0.018 Yes 12 Laurel Canyon Blvd & Burbank Blvd 0.833 D 0.862 D 0.029 Yes 13 SR 170 NB Ramps & Oxnard St 0.727 C 0.775 C 0.048 Yes 14 Radford Ave & Victory Blvd 0.495 A 0.520 A 0.025 No 15 Radford Ave & Oxnard St 0.380 A 0.413 A 0.033 No 16 Lankershim Blvd & Vanowen St 0.825 D 0.833 D 0.008 No Lankershim Blvd/Colfax Ave & 0.880 D 0.908 E 0.028 Yes 17 Victory Blvd 18 Colfax Ave & Oxnard St 0.621 B 0.644 B 0.023 No 19 Colfax Ave & Burbank Blvd 0.851 D 0.855 D 0.004 No 20 Lankershim Blvd & Oxnard St 0.728 C 0.743 C 0.015 No 21 Tujunga Ave & Victory Blvd 0.733 C 0.743 C 0.010 No 22 Tujunga Ave & Oxnard St 0.523 A 0.526 A 0.003 No 23 Tujunga Ave & Burbank Blvd 1.032 F 1.037 F 0.005 No Source: The Mobility Group, 2016.

Mitigation Measures

M-1 Whitsett Avenue & Victory Boulevard (Intersection #4): Restripe the northbound approach of Whitsett Avenue to provide an exclusive right-turn lane, restripe the southbound approach of Whitsett Avenue to provide an exclusive right-turn lane and modify the existing traffic signal to include both eastbound and westbound left-turn phases and northbound and southbound right-turn overlap phases. These improvements would change both the northbound and southbound approaches from one left-turn lane, one thru lane, and one shared thru/right lane to one left-turn lane, two thru lanes, and one exclusive right-turn lane. These improvements can be accommodated without any roadway widening but would require the removal of approximately two on-street parking spaces along the west side of Whitsett Avenue.

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overlap phase. These improvements would change the southbound approach from one left- turn lane, one thru lane and one shared thru/right lane to two left-turn lanes, two thru lanes and one exclusive right-turn lane.

M-3 Laurel Canyon Boulevard & Oxnard Street (Intersection #11): Install a CCTV camera at this location, in coordination with LADOT staff.

M-4 Laurel Canyon Boulevard & Burbank Boulevard (Intersection #12): Install protected left-turn phasing in all four approaches at this intersection.

M-5 SR-170 Northbound Ramps & Oxnard Street (Intersection #13): Restripe the eastbound approach to provide an exclusive right-turn lane and to modify the existing traffic signal to include an eastbound right-turn overlap phase. These improvements would change the eastbound approach from one left-turn lane, one thru lane and one shared thru/right lane to one left-turn lane, two thru lanes and one exclusive right-turn lane.

M-6 Lankershim Boulevard/Colfax Avenue & Victory Boulevard (Intersection #17): Restripe the southbound approach to provide an exclusive right-turn lane and to modify the existing traffic signal to include a southbound right-turn overlap phase. These improvements would change the southbound approach from one left-turn lane, one thru lane and one shared thru/right lane to one left-turn lane, two thru lanes and one exclusive right-turn lane.

M-7 Lankershim Boulevard & Oxnard Street (Intersection #20): Restripe the eastbound approach to provide an exclusive right-turn lane, restripe the westbound approach to provide an exclusive right-turn lane and modify the existing traffic signal to include both northbound and southbound left-turn phases and eastbound and westbound right-turn overlap phases. These improvements would change both the eastbound and westbound approaches from one left- turn lane, one thru lane and one shared thru/right lane to one left-turn lane, two thru lanes and one exclusive right-turn lane. These improvements can be accommodated without any roadway widening but would require the relocation of a bus stop along the south side of Oxnard Street. As a condition of approval, LADOT has stated that the lead/lag combination phasing for the eastbound and westbound protected left-turn movements would be required as part of the final traffic signal design to avoid the possibility of “interlock.”

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Table 4B-22 Alternative 4B - Future With Project With Mitigation (AM Peak Hour) Future Without Future With Future With Project Project Project With Conditions Conditions Change Significant Mitigation Change Significant No Intersection V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact Mitigates? 1 Coldwater Canyon Ave & 0.936 E 0.940 E 0.004 No Victory Blvd 2 Coldwater Canyon Ave & 0.861 D 0.869 D 0.008 No Oxnard St 3 Whitsett Ave & Vanowen 1.003 F 1.006 F 0.003 No St 4 Whitsett Ave & Victory 0.945 E 0.950 E 0.005 No Blvd 5 Whitsett Ave & Oxnard St 0.923 E 0.930 E 0.007 No 6 Whitsett Ave & Burbank 0.877 D 0.885 D 0.008 No Blvd 7 Laurel Canyon Blvd & 0.801 D 0.809 D 0.008 No Vanowen St 8 Laurel Canyon Blvd & 0.936 E 0.957 E 0.021 Yes 0.908 E -0.028 No Fully mitigates Victory Blvd 9 Laurel Canyon Blvd & 0.519 A 0.529 A 0.010 No Sylvan St 10 Laurel Canyon Blvd & 0.465 A 0.484 A 0.019 No Erwin St 11 Laurel Canyon Blvd & Partially 1.079 F 1.100 F 0.021 Yes 1.090 F 0.011 Yes Oxnard St mitigates 12 Laurel Canyon Blvd & 0.928 E 0.938 E 0.010 Yes 0.928 E 0.000 No Fully mitigates Burbank Blvd 13 SR 170 NB Ramps & 0.740 C 0.754 C 0.014 No Oxnard St 14 Radford Ave & Victory 0.499 A 0.520 A 0.021 No Blvd 15 Radford Ave & Oxnard St 0.380 A 0.421 A 0.041 No 16 Lankershim Blvd & 0.633 B 0.635 B 0.002 No Vanowen St 17 Lankershim Blvd/Colfax 0.848 D 0.857 D 0.009 No

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Ave & Victory Blvd 18 Colfax Ave & Oxnard St 0.682 B 0.698 B 0.016 No 19 Colfax Ave & Burbank 0.807 D 0.810 D 0.003 No Blvd 20 Lankershim Blvd & 0.781 C 0.803 D 0.022 Yes 0.776 C -0.005 No Fully mitigates Oxnard St 21 Tujunga Ave & Victory 0.629 B 0.633 B 0.004 No Blvd 22 Tujunga Ave & Oxnard St 0.499 A 0.501 A 0.002 No 23 Tujunga Ave & Burbank 1.165 F 1.168 F 0.003 No Blvd Source: The Mobility Group, 2016.

Table 4B-23 Alternative 4B - Future With Project With Mitigation (PM Peak Hour) Future Without Future With Future With Project Project Project With Conditions Conditions Change Significant Mitigation Change Significant No Intersection V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact Mitigates? 1 Coldwater Canyon Ave & 0.956 E 0.962 E 0.006 No Victory Blvd 2 Coldwater Canyon Ave & 0.776 C 0.787 C 0.011 No Oxnard St 3 Whitsett Ave & Vanowen 0.848 D 0.855 D 0.007 No St 4 Whitsett Ave & Victory 1.047 F 1.058 F 0.011 Yes 0.984 E -0.063 No Fully mitigates Blvd 5 Whitsett Ave & Oxnard St 0.875 D 0.887 D 0.012 No 6 Whitsett Ave & Burbank 0.803 D 0.815 D 0.012 No Blvd 7 Laurel Canyon Blvd & 0.856 D 0.863 D 0.007 No Vanowen St 8 Laurel Canyon Blvd & 0.984 E 0.999 F 0.015 Yes 0.940 E -0.044 No Fully mitigates

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Victory Blvd 9 Laurel Canyon Blvd & 0.501 A 0.520 A 0.019 No Sylvan St 10 Laurel Canyon Blvd & 0.455 A 0.539 A 0.084 No Erwin St 11 Laurel Canyon Blvd & 1.021 F 1.039 F 0.018 Yes 1.029 F 0.004 No Fully mitigates Oxnard St 12 Laurel Canyon Blvd & 0.833 D 0.862 D 0.029 Yes 0.852 D 0.019 No Fully mitigates Burbank Blvd 13 SR 170 NB Ramps & 0.727 C 0.775 C 0.048 Yes 0.715 C -0.012 No Fully mitigates Oxnard St 14 Radford Ave & Victory 0.495 A 0.520 A 0.025 No Blvd 15 Radford Ave & Oxnard St 0.380 A 0.413 A 0.033 No 16 Lankershim Blvd & 0.825 D 0.833 D 0.008 No Vanowen St 17 Lankershim Blvd/Colfax 0.880 D 0.908 E 0.028 Yes 0.886 D 0.006 No Fully mitigates Ave & Victory Blvd 18 Colfax Ave & Oxnard St 0.621 B 0.644 B 0.023 No 19 Colfax Ave & Burbank 0.851 D 0.855 D 0.004 No Blvd 20 Lankershim Blvd & 0.728 C 0.743 C 0.015 No Oxnard St 21 Tujunga Ave & Victory 0.733 C 0.743 C 0.010 No Blvd 22 Tujunga Ave & Oxnard St 0.523 A 0.526 A 0.003 No 23 Tujunga Ave & Burbank 1.032 F 1.037 F 0.005 No Blvd Source: The Mobility Group, 2016.

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Utilities

Wastewater

As shown in Table 4B-24, Alternative 4B - Estimated Wastewater Generation, Alternative 4B would result in a net increase of 110,760 gallons of wastewater per day (gpd) at the Project Site over existing conditions. This is a reduction of approximately 38,627 gpd as compared to the Project’s wastewater generation of 149,387 gpd. Thus, Alternative 4B would generate less wastewater than the Project and would result in less than significant impacts to wastewater treatment capacity. Similar to the Project, Alternative 4B would be subject to Regulatory Compliance Measures N.1-1 (requiring incorporation of green building practices) and N.1-2 (to ensure that infrastructure is sufficient to support the generation), as well as Project Design Feature N.1-3. Given the excess capacity at Hyperion Treatment Plant (HTP) and the recommended expansion to accommodate the potential of the Integrated Resource Plan (IRP), the impacts would be less than significant. Overall, the impacts of Alternative 4B would be less than significant and less than the Project’s less than significant impacts. The cumulative projects would also have a wastewater generation that could be accommodated within the HTP. For the same reasons why the Project’s cumulative wastewater impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative wastewater impacts would also be less than cumulatively significant.

Table 4B-24 Alternative 4B - Estimated Wastewater Generation

Land Use Size Wastewater Generation Rates Total (gpd) Existing (to be removed) Department Store 465,000 sf 50 gallons / 1,000 sf (23,250) Office 90,000 sf 120 gallons / 1,000 sf (10,800) Existing Subtotal (to be removed) (34,050) Proposed Residential – Studio 55 units 75 gallons / unit 4,125 Residential – 1-Bedroom 403 units 110 gallons / unit 44,330 Residential – 2-Bedroom 200 units 150 gallons / unit 30,000 Office 189,184 sf 120 gallons / 1,000 sf 22,702 Retail 208,171 sf 50 gallons / 1,000 sf 10,409 Restaurant 66,645 sf 300 gallons/ 1,000 sf 19,994 Health Club 40,000 sf 200 gallons / 1,000 sf 8,000 Cinema 1,750 seats 3 gallons / seat 5,250 Proposed Subtotal 144,810 Total (Proposed – Existing) 110,760

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Table 4B-24 Alternative 4B - Estimated Wastewater Generation

Land Use Size Wastewater Generation Rates Total (gpd) Note: sf = square feet; gpd = gallons per day Note: To provide a more conservative estimate of impacts, the same generation rates are used for both the existing uses and the new buildings, although in reality, the new buildings would be more efficient than the existing buildings. Source: Correspondence from Ali Poosti, Division Manager, Wastewater Engineering Services Division, Bureau of Sanitation, April 14, 2015. Included in the Appendices to the Draft EIR. City of Los Angeles CEQA Thresholds Guide, 2006, Exhibit M.2-12 Sewage Generation Factors. Restaurant: representative based on a rate per square footage is for Restaurant: Take Out 300 gallons/1,000 sf Health Club: Health club/spa includes lobby area, workout floors, aerobic rooms, swimming pools, Jacuzzi, sauna, locker rooms, showers, and restrooms. Table: CAJA Environmental Services, 2016.

Water

As shown in Table 4B-25, Alternative 4B - Estimated Water Demand, Alternative 4B would result in a net increase of 133,927 gallons of water demand per day (gpd) at the Project Site over existing conditions. This is a reduction of approximately 48,443 gpd as compared to the Project’s water demand of 182,370 gpd. Thus, Alternative 4B would demand less water than the Project and would result in less than significant impacts to water treatment capacity. Similar to the Project, Alternative 4B would be subject to Regulatory Compliance Measures N.2-1 through N.2-5, which are standard City measures to ensure that impacts to the water conveyance system would be less than significant. Alternative 4B would also implement Project Design Feature N.2-6, which would ensure that construction of any water infrastructure would not affect the traffic flow and there would be sufficient water infrastructure to serve the Project. Overall, the impacts of Alternative 4B would be less than significant and less than the Project’s less than significant impacts. For the same reasons why the Project’s cumulative water impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative water impacts would also be less than cumulatively significant.

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Table 4B-25 Alternative 4B - Estimated Water Demand

Land Use Size Water Demand Rates Total (gpd) Existing (to be removed) Department Store 465,000 sf 64 gallons / 1,000 sf (29,760) Office 90,000 sf 153.6 gallons / 1,000 sf (13,824) Existing Subtotal (to be removed) (43,584) Proposed Residential – Studio 55 units 88.5 gallons / unit 4,868 Residential – 1-Bedroom 403 units 129.8 gallons / unit 52,309 Residential – 2-Bedroom 200 units 177 gallons / unit 35,400 Office 189,184 sf 153.6 gallons / 1,000 sf 29,059 Retail 208,171 sf 64 gallons / 1,000 sf 13,323 Restaurant 66,645 sf 384 gallons/ 1,000 sf 25,592 Health Club 40,000 sf 256 gallons / 1,000 sf 10,240 Cinema 1,750 seats 3.84 gallons / seat 6,720 Proposed Subtotal 177,511 Total (Proposed – Existing) 133,927 Note: sf = square feet; gpd = gallons per day Note: To provide a more conservative estimate of impacts, the same generation rates are used for both the existing uses and the new buildings, although in reality, the new buildings would be more efficient than the existing buildings. Water consumption rates are assumed as 128 percent (nonresidential) and 118 percent (residential) of the wastewater generation rates. a Source: Correspondence from Ali Poosti, Division Manager, Wastewater Engineering Services Division, Bureau of Sanitation, April 14, 2015. Correspondence contained in the appendices to the Draft EIR. b City of Los Angeles CEQA Thresholds Guide, 2006, Exhibit M.2-12 Sewage Generation Factors. c Restaurant: representative based on a rate per square footage is for Restaurant: Take Out 300 gallons/1,000 sf Health Club: Health club/spa includes lobby area, workout floors, aerobic rooms, swimming pools, Jacuzzi, sauna, locker rooms, showers, and restrooms.

d Table: CAJA Environmental Services, 2016.

Solid Waste

As shown in Table 4B-26, Alternative 4B - Estimated Solid Waste Generation, Alternative 4B would result in a net increase of 11,061 pounds per day (ppd) at the Project Site compared to existing conditions. This is a reduction of approximately 2,500 ppd as compared to the Project’s solid waste generation of 13,561 ppd. Thus, Alternative 4B would generate less solid waste than the Project and would result in less than significant impacts to solid waste landfill capacity due to demolition, construction, and operational

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waste (with Regulatory Compliance Measures N.3-1 through N.3-3 and Project Design Feature N.3-4, related to the recycling of construction materials and the inclusion of a designated recycling area and recycling bins during operation). Overall, the impacts of Alternative 4B would be less than significant and less than the Project’s less than significant impacts. The cumulative projects would have a solid waste generation that could also be accommodated within the various landfills and MRFs. For the same reasons why the Project’s cumulative solid waste impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative solid waste impacts would also be less than cumulatively considerable.

Table 4B-26 Alternative 4B - Estimated Solid Waste Generation

Land Use Size Solid Waste Generation Rates Total (pounds) Existing (to be removed) Department Store 465,000 sf 5 pounds / 1,000 sf (2,325) Office 90,000 sf 6 pounds / 1,000 sf (540) Existing Subtotal (to be removed) (2,865) Proposed Residential 658 units 12.23 pounds / unit 8,047 Office 189,184 sf 6 pounds / 1,000 sf 1,135 Retail 208,171 sf 5 pounds / 1,000 sf 1,041 Restaurant 66,645 sf 5 pounds / 1,000 sf 333 Health Club 40,000 sf 31.2 pounds / 1,000 sf 1,248 Cinema 68,000 sf 31.2 pounds / 1,000 sf 2,122 Proposed Subtotal 13,926 Total (Proposed – Existing) 11,061 Note: sf = square feet Note: To provide a more conservative estimate of impacts, the same generation rates are used for both the existing uses and the new buildings, although in reality, the new buildings would be more efficient than the existing buildings. Rates: CalRecycle Estimated Solid Waste Generation Rates: http://www.calrecycle.ca.gov/wastechar/wastegenrates/ Residential – 12.23 pounds/unit; source: City of Los Angeles CEQA Thresholds Guide: Your Resource for Preparing CEQA Analyses in Los Angeles (DRAFT). Retail – 5 pounds/1,000 sf; source: City of LA Dept. of City Planning doc "EIR Manual for Private Projects". Restaurant: using Restaurant rate of 5 pounds per 100 sf: source: Draft EIR for North Hills Development (Santa Clarita). EIR cites City of LA Bureau of Solid Waste, 1989, as source. Office: using Office rate of 6 pounds per 1,000 sf: source: Draft EIR for North Hills Development (Santa Clarita). EIR cites City of LA Bureau of Solid Waste, 1989, as source. Other services: includes Health Club and Theater: 31.2 pounds per 1,000 sf. Table: CAJA Environmental Services, 2016.

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Energy Conservation

Electricity

As shown in Table 4B-27, Alternative 4B - Estimated Electricity Consumption, Alternative 4B would result in a net increase of approximately 5,802,942 kw-h of electricity per year at the Project Site over existing conditions. This is a reduction of approximately 2,764,320 kw-h/yr as compared to the Project’s electricity consumption of 8,567,262 kw-h/yr. Thus, Alternative 4B would consume less electricity than the Project. Overall, like the Project, Alternative 4B would result in no impacts with respect to electricity demand. The cumulative projects would also have an electrical demand that could be accommodated within LADWP system. For the same reasons why the Project’s cumulative electricity impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative electricity impacts would also be less than cumulatively significant.

Table 4B-27 Alternative 4B - Estimated Electricity Demand

Land Use Size Electricity Demand Rates Total (kw-h/yr) Existing (to be removed) Department Store 465,000 sf 13.55 kw-h / sf (6,300,750) Office 90,000 sf 12.95 kw-h / sf (1,165,500) Existing Subtotal (to be removed) (7,466,250) Proposed Residential 658 units 5,626.50 kw-h / unit 3,702,237 Office 189,184 sf 12.95 kw-h / sf 2,449,933 Retail 208,171 sf 13.55 kw-h / sf 2,820,717 Restaurant 66,645 sf 47.45 kw-h / sf 3,162,305 Health Club 40,000 sf 10.5 kw-h / sf 420,000 Cinema 68,000 sf 10.5 kw-h / sf 714,000 Proposed Subtotal 13,269,192 Total (Proposed – Existing) 5,802,942 sf =square feet; kw-h = kilowatt-hour; yr = year Note: To provide a more conservative estimate of impacts, the same generation rates are used for both the existing uses and the new buildings, although in reality, the new buildings would be more efficient than the existing buildings. Source: SCAQMD Air Quality Handbook, 1993, Table A9-11-A Electricity Usage Rate The LADWP does not provide or comment on generation rates to provide an estimate of demand. In addition, the Los Angeles City Planning Department has consistently accepted use of the SCAQMD rates in its EIRs. Table: CAJA Environmental Services, 2016.

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Natural Gas

As shown in Table 4B-28, Alternative 4B - Estimated Natural Gas Consumption, Alternative 4B would result in a net increase of approximately 2,599,602 cubic feet of natural gas per month at the Project Site over existing conditions Thus, Alternative 4B would consume 718,431 cf/mo less natural gas than the Project’s natural gas consumption of 3,318,033 cf/mo. Overall, like the Project, Alternative 4B would result in no impacts with respect to natural gas demand. The cumulative projects would also have a natural gas demand that could be accommodated within the SCG system. For the same reasons why the Project’s cumulative natural gas impacts are less than cumulatively considerable, Alternative 4B’s contribution to cumulative natural gas impacts would also be less than cumulatively significant.

Table 4B-28 Alternative 4B - Estimated Natural Gas Demand

Land Use Size Natural Gas Demand Rates Total (cf/mo) Existing (to be removed) Department Store 465,000 sf 2.9 cf / sf (1,348,500) Office 90,000 sf 2.0 cf / sf (180,000) Existing Subtotal (to be removed) (1,528,500) Proposed Residential 658 units 4,011.5 cf / unit 2,639,567 Office 189,184 sf 2.0 cf / sf 378,368 Retail 208,171 sf 2.9 cf / sf 603,696 Restaurant 66,645 sf 2.9 cf / sf 193,271 Health Club 40,000 sf 2.9 cf / sf 116,000 Cinema 68,000 sf 2.9 cf / sf 197,200 Proposed Subtotal 4,128,102 Total (Proposed – Existing) 2,599,602 sf =square feet; cf = cubic feet; mo = month Note: To provide a more conservative estimate of impacts, the same generation rates are used for both the existing uses and the new buildings, although in reality, the new buildings would be more efficient than the existing buildings. Source: SCAQMD Air Quality Handbook, 1993, Appendix 9, Table A9-12-A, Natural Gas Usage Rate The SCG does not provide or comment on generation rates to provide an estimate of demand. In addition, the Los Angeles City Planning Department has consistently accepted use of the SCAQMD rates in its EIRs. Table: CAJA Environmental Services, 2016.

Relationship of Alternative 4B to the Project Objectives

Alternative 4B was developed in response to public comments received on the Draft EIR, which requested a project with fewer residential units, more retail opportunities, and fewer traffic impacts.

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Alternative 4B includes development of the Project Site with a mix of uses, similar to the Project. Therefore, Alternative 4Bwould provide the same critical mass of uses necessary to activate the area. As such, Alternative 4B would meet all of the Project objectives to approximately the same extent as the Project; Alternative 4B would provide more retail and less office employment compared to the Project. Specifically, Alternative 4B would:

 Redevelop a currently underutilized site into a mixed-use, transit-oriented development that combines retail, office, and residential uses.

 Create a sustainable balance of commercial and housing uses to encourage mixed-use living.

 Support infill development and redevelopment in existing urban areas to reduce “greenfield” development and urban sprawl.

 Provide the opportunity to maintain and re-use the existing Macy’s Building.

 Activate and encourage pedestrian and bicycle activity by developing a mix of complementary land uses, and by providing bicycle parking and pedestrian linkages within the Project site; an attractive pedestrian experience on Erwin Street, Radford Drive and within the open and green spaces, walkways, plazas, and other gathering spaces.

 Improve the aesthetic quality of the Project Site by removing or upgrading outdated buildings by designing an integrated unified architectural commercial center with linkages to adjacent housing.

 Incorporate sustainable and green building design and construction to promote resource conservation, including waste reduction, efficient water management techniques, and conservation of energy to achieve a LEED-qualified equivalent.

 Create a range of construction and permanent jobs.

 Improve public safety by creating a development that provides the level of density and mix of uses necessary to activate the area both day and night, which provides natural surveillance.

 Improve the job-housing balance in the eastern San Fernando Valley area by providing new housing within a major employment center.

 Redevelop the Project Site in a manner that promotes and enhances a healthy and diverse economy in North Hollywood.

 Provide retail, office, and housing along a major transit-served transportation corridor in furtherance of City’s goals and policies to reduce vehicle miles traveled (VMT) and to reduce pollutant emission, including greenhouse gas emissions.

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Summary of Alternative 4B Impacts Compared to Project Impacts

The Project would result in three significant traffic impacts at two intersections under future year 2020 conditions. Alternative 4B would result in a fewer number of daily, AM, and PM peak hour trips when compared to the Project. In addition, this Alternative would result in two fewer significant impacts (at intersection #20 during the AM peak hour and at intersection #11 during the PM peak hour) than the Project. In addition, Alternative 4B would result in reduced impacts with respect to Public Services and Utilities when compared to the Project, as Alternative 4B would generate fewer residents and employees at the Project Site than the Project. Overall, Alternative 4B includes development of the Project Site with a mix of uses, similar to the Project. Therefore, this Alternative would provide the same critical mass of uses necessary to activate the area, while at the same time reducing two of the Project’s significant intersection impacts. Finally, Alternative 4B would meet all of the Project objectives to approximately the same extent as the Project.

7. PREPARERS OF THE EIR AND PERSONS CONSULTED

No corrections required.

8. ACRONYMS AND TERMS

No corrections required.

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MITIGATION MONITORING PROGRAM

NoHo West Project

Case Number: ENV-2014-888-EIR State Clearinghouse Number: 2015041001

Section 21081.6 of the Public Resources Code requires a Lead Agency to adopt a “reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment” (Mitigation Monitoring Program, Section 15097 of the CEQA Guidelines provides additional direction on mitigation monitoring or reporting). This Mitigation Monitoring Program (MMP) has been prepared in compliance with the requirements of CEQA, specifically Public Resources Code Section 21081.6, and Section 15097 of the CEQA Guidelines. The City of Los Angeles is the Lead Agency for this project.

An Environmental Impact Report (EIR) has been prepared to address the potential environmental impacts of the Project. Where appropriate, the EIR identified Project design features, regulatory compliance measures, or recommended mitigation measures to avoid or to reduce potentially significant environmental impacts. This Mitigation Monitoring Program (MMP) is designed to monitor implementation of the mitigation measures identified in the EIR.

The MMP is subject to review and approval by the City of Los Angeles as the Lead Agency as part of the approval process of the project, and adoption of project conditions. The required mitigation measures are listed and categorized by impact area, as identified in the EIR.

The Project Applicant shall be responsible for implementing all mitigation measures, unless otherwise noted; and shall be obligated to provide documentation concerning implementation of the listed mitigation measures to the appropriate monitoring agency and the appropriate enforcement agency. All departments listed below are within the City of Los Angeles, unless otherwise noted. The entity responsible for the implementation of all mitigation measures shall be the Project Applicant unless otherwise noted.

As shown on the following pages, each required mitigation measure for the proposed Project is listed and categorized by impact area, with accompanying discussion of:

Enforcement Agency – the agency with the power to enforce the Mitigation Measure.

Monitoring Agency – the agency to which reports involving feasibility, compliance, implementation and development are made, or whom physically monitors the project for compliance with mitigation measures.

Monitoring Phase – the phase of the Project during which the Mitigation Measure shall be monitored.

- Pre-Construction, including the design phase

- Construction ENV-2014-888-EIR June 2016

- Pre-Operation

- Operation (Post-construction)

Monitoring Frequency – the frequency of which the Mitigation Measure shall be monitored.

Action Indicating Compliance – the action of which the Enforcement or Monitoring Agency indicates that compliance with the required Mitigation Measure has been implemented.

The MMP shall be monitored annually to determine the effectiveness of the measures implemented in any given year, and to reevaluate the mitigation needs for the upcoming year.

It is the intent of this MMP to:

Verify compliance of the EIR’s required mitigation measures;

Provide a methodology to document implementation of required mitigation;

Provide a record and status of mitigation requirements;

Identify monitoring and enforcement agencies;

Establish and clarify administrative procedures for the clearance of mitigation measures;

Establish the frequency and duration of monitoring and reporting; and

Utilize the existing agency review processes’ wherever feasible.

This MMP shall be in place throughout all phases of the proposed Project. The entity responsible for implementing each mitigation measure is set forth within the text of the mitigation measure. The entity responsible for implementing the mitigation shall also be obligated to provide certification to the appropriate monitoring agency and the appropriate enforcement agency that compliance with the required mitigation measure has been achieved.

After review and approval of the final MMP by the Lead Agency, minor changes and modifications to the MMP are permitted, but can only be made by the Applicant or its successor, and are subject to approval by the City of Los Angeles, in most cases through a public hearing process. The Lead Agency, in conjunction with any appropriate agencies or departments, will determine the adequacy of any proposed change or modification. No changes will be permitted unless the MMP continues to satisfy the requirements of CEQA, as determined by the Lead Agency.

2 ENV-2014-888-EIR June 2016 Mitigation Measures

Biological Resources

A-1 See Regulatory Compliance Measures

No Mitigation Measures required.

Aesthetics

B-1 to B-6 See Project Design Features

B-7 See Regulatory Compliance Measures

No Mitigation Measures required.

Air Quality

C-1 All off-road construction equipment greater than 50 hp shall meet U.S. EPA Tier 4 emission

standards, where available, to reduce NOx, PM10, and PM2.5 emissions at the Project site. In addition, all construction equipment shall be outfitted with Best Available Control Technology devices certified by CARB. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine as defined by CARB regulations.

Enforcement Agency: Los Angeles Department of Building and Safety; SCAQMD

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

C-2 Require the use of 2010 and newer diesel haul trucks (e.g., material delivery trucks and soil import/export) and if the Lead Agency determines that 2010 model year or newer diesel trucks

cannot be obtained, the Lead Agency shall require trucks that meet U.S. EPA 2007 model year NOx emissions requirements.

Enforcement Agency: Los Angeles Department of Building and Safety; SCAQMD

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

3 ENV-2014-888-EIR June 2016

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

C-3 At the time of mobilization of each applicable unit of equipment, a copy of each unit’s certified tier specification, BACT documentation, and CARB or SCAQMD operating permit shall be provided.

Enforcement Agency: Los Angeles Department of Building and Safety; SCAQMD

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Once, during field inspection

Action Indicating Compliance: Field inspection sign off

C-4 Encourage construction contractors to apply for SCAQMD “SOON” funds. Incentives could be provided for those construction contractors who apply for SCAQMD “SOON” funds. The “SOON” program provides funds to accelerate clean up of off-road diesel vehicles, such as heavy duty construction equipment. More information on this program can be found at: http://www.aqmd.gov/home/programs/business/business-detail?title=off-road-diesel- engines&parent=vehicle-engine-upgrades.

Enforcement Agency: Los Angeles Department of Building and Safety; SCAQMD

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

C-5 Lengthen the period for the application of architectural coatings to four months or limit application of coatings to no more than 35,156 square feet of surface area per day to minimize any daily emissions of VOC that could exceed SCAQMD thresholds of significance.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

4 ENV-2014-888-EIR June 2016

C-6 to C-10 See Regulatory Compliance Measures

C-11 to C-13 See Project Design Features

Cultural Resources

D-1 If any archaeological materials are encountered during the course of Project development, all further development activity shall be halted in the area of the discovery and:

a. The services of an archaeologist shall then be secured by contacting the South Central Coastal Information Center located at California State University Fullerton, or a member of the Society of Professional Archaeologists (SOPA), or a SOPA-qualified archaeologist, who shall assess the discovered material(s) and prepare a survey, study, or report evaluating the impact.

b. The archaeologist’s survey, study, or report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource.

c. The applicant shall comply with the recommendations of the evaluating archaeologist, as contained in the survey, study, or report.

d. Project development activities may resume once copies of the archaeological survey, study, or report are submitted to the South Central Coastal Information Center at California State University Fullerton.

e. Prior to the issuance of any building permit, the applicant shall submit a letter to the case file indicating what, if any, archaeological reports have been submitted, or a statement indicating that no material was discovered.

f. A covenant and agreement binding the applicant to this condition shall be recorded prior to issuance of a grading permit.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: If materials are encountered

Action Indicating Compliance: Field inspection sign-off

D-2 If any paleontological materials are encountered during the course of Project development, all further development activities shall be halted in the area of the discovery and:

a. The services of a paleontologist shall then be secured by contacting the Center for Public Paleontology – USC, UCLA, California State University Los Angeles, California State

5 ENV-2014-888-EIR June 2016

University Long Beach, or the Los Angeles County Natural History Museum – who shall assess the discovered material(s) and prepare a survey, study, or report evaluating the impact.

b. The paleontologist’s survey, study, or report shall contain a recommendation(s), if necessary, for the preservation, conservation, or relocation of the resource.

c. The applicant shall comply with the recommendations of the evaluating paleontologist, as contained in the survey, study, or report.

d. Project development activities may resume once copies of the paleontological survey, study, or report are submitted to the Los Angeles County Natural History Museum.

e. Prior to the issuance of any building permit, the applicant shall submit a letter to the case file indicating what, if any, paleontological reports have been submitted, or a statement indicating that no material was discovered.

f. A covenant and agreement binding the applicant to this condition shall be recorded prior to the issuance of a grading permit.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: If materials are encountered

Action Indicating Compliance: Field inspection sign-off

D-3 In the event that human remains are discovered during excavation activities, the following procedure shall be observed:

a. Stop immediately and contact the County Coroner.

b. The coroner has two working days to examine human remains after being notified by the responsible person. If the remains are Native American, the coroner has 24 hours to notify the Native American Heritage Commission.

c. The Native American Heritage Commission will immediately notify the person it believes to be the most likely descendant of the deceased Native American.

d. The most likely descendant has 48 hours to make recommendations to the owner, or representative, for the treatment or disposition, with proper dignity, of the human remains and grave gods.

e. If the descendant does not make recommendations within 48 hours, the owner shall reinter the remains in an area of the property secure from further disturbance.

6 ENV-2014-888-EIR June 2016

f. If the owner does not accept the descendant’s recommendations, the owner or the descendant may request mediation by the Native American Heritage Commission.

Enforcement Agency: Los Angeles Department of Building and Safety, Los Angeles County Coroner

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: If human remains are encountered

Action Indicating Compliance: Coroner or Native American Heritage Commission sign-off

Geology and Soils

E-1 to E-2 See Regulatory Compliance Measures

E-3 See Project Design Features

No Mitigation Measures required.

Greenhouse Gas Emissions

No Mitigation Measures required.

Hazards and Hazardous Materials

G-1 to G-3 See Regulatory Compliance Measures

No Mitigation Measures required.

Hydrology and Water Quality

H-1 to H-4 See Regulatory Compliance Measures

No Mitigation Measures required.

Land Use and Planning

I-1 See Regulatory Compliance Measures

No Mitigation Measures required.

Noise

J-1 Two weeks prior to commencement of construction, notification shall be provided to the off-site residential and studio uses within 500 feet of the Project site that discloses the construction

7 ENV-2014-888-EIR June 2016

schedule, including the types of activities and equipment that would be used throughout the duration of the construction period.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Two weeks prior to construction

Monitoring Frequency: Once, at notification

Action Indicating Compliance: Contractor sign-off

J-2 Temporary sound barriers, capable of achieving a sound attenuation of at least 10 dBA (e.g., construction sound wall with sound blankets) at 50 feet of distance, and capable of blocking the line-of-sight from ground level construction equipment powered by internal combustion engines to the adjacent sensitive receptors shall be installed.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Once, during field inspection

Action Indicating Compliance: Field inspection sign-off

J-3 All powered construction equipment shall be equipped with exhaust mufflers or other suitable noise reduction devices capable of achieving a sound attenuation of at least 3 dBA at 50 feet of distance.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Once, during field inspection

Action Indicating Compliance: Field inspection sign-off

J-4 All construction areas for staging and warming-up equipment shall be located as far away as possible from adjacent residences and sensitive receptors.

Enforcement Agency: Los Angeles Department of Building and Safety

8 ENV-2014-888-EIR June 2016

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

J-5 Portable noise sheds for smaller, noisy equipment, such as air compressors, dewatering pumps, and generators shall be provided where feasible.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Once, during field inspection

Action Indicating Compliance: Field inspection sign-off

J-6 A haul route for exporting demolition materials from the site to a nearby landfill shall access the Hollywood Freeway (SR-170) via Oxnard Street and should minimize travel on residential streets with sensitive receptors. Similarly, import of materials should use the SR-170 off-ramp at Oxnard Street.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

J-7 See Regulatory Compliance Measures

J-8 See Project Design Features

Population and Housing

No Mitigation Measures required.

Public Services – Fire Protection

L.1-1 to L.1-4 See Regulatory Compliance Measures

9 ENV-2014-888-EIR June 2016

L.1-5 to L.1-8 See Project Design Features

No Mitigation Measures required.

Public Services – Police Protection

L.2-1 The Project Applicant shall provide for the deployment of a private security guard to monitor and patrol the Site, appropriate to the phase of construction throughout the construction period. The patrol shall be deployed at times that are typical within the local-area construction industry for a Project of this size.

Enforcement Agency: Los Angeles Department of building and Safety

Monitoring Agency: Los Angeles Department of building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspections during construction

Action Indicating Compliance: Field inspection sign-off

L.2-2 The Project Applicant shall provide the LAPD with a diagram of each portion of the Project Site, showing access routes and additional access information as requested by the LAPD, to facilitate police response.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Occupancy

Monitoring Frequency: Once, prior to occupancy

Action Indicating Compliance: Police Department confirmation of receiving diagram

L.2-3 to L.2-4 See Regulatory Compliance Measures

L.2-5 to L.2-6 See Project Design Features

Public Services – Schools

L.3-1 See Regulatory Compliance Measures

No Mitigation Measures required.

Public Services – Parks

L.4-1 See Regulatory Compliance Measures

10 ENV-2014-888-EIR June 2016

No Mitigation Measures required.

Public Services – Libraries

No Mitigation Measures required.

Transportation/Traffic

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

M-2 Laurel Canyon Boulevard & Victory Boulevard (Intersection #8): Restripe the southbound approach of Laurel Canyon Boulevard to provide a second left-turn lane and an exclusive right-turn lane and to modify the existing traffic signal to include a southbound right-turn overlap phase. These improvements would change the southbound approach from one left-turn lane, one thru lane and one shared thru/right lane to two left-turn lanes, two thru lanes and one exclusive right-turn lane.

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

M-3 Laurel Canyon Boulevard & Oxnard Street (Intersection #11): Install a CCTV camera at this location, in coordination with LADOT staff.

11 ENV-2014-888-EIR June 2016

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

M-4 Laurel Canyon Boulevard & Burbank Boulevard (Intersection #12): Install protected left-turn phasing in all four approaches at this intersection.

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

Enforcement Agency: LADOT

12 ENV-2014-888-EIR June 2016

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

M-7 Lankershim Boulevard & Oxnard Street (Intersection #20): Restripe the eastbound approach to provide an exclusive right-turn lane, restripe the westbound approach to provide an exclusive right- turn lane and modify the existing traffic signal to include both northbound and southbound left-turn phases and eastbound and westbound right-turn overlap phases. These improvements would change both the eastbound and westbound approaches from one left-turn lane, one thru lane and one shared thru/right lane to one left-turn lane, two thru lanes and one exclusive right-turn lane. These improvements can be accommodated without any roadway widening but would require the relocation of a bus stop along the south side of Oxnard Street. As a condition of approval, LADOT has stated that the lead/lag combination phasing for the eastbound and westbound protected left- turn movements would be required as part of the final traffic signal design to avoid the possibility of “interlock.”

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

M-8 LAUSD Transportation Branch shall be contacted at (213) 580-2950 regarding the potential impact upon existing school bus routes. Laurel Hall School shall also be contacted regarding the potential impact upon existing school bus routes.

13 ENV-2014-888-EIR June 2016

 Contractors shall maintain safe and convenient pedestrian routes to all nearby schools. The applicable Pedestrian Route to School map can be found at http://www.lausd- oehs.org/saferoutestoschools.asp and a pedestrian route map shall also be requested from Laurel Hall School.  Contractors shall maintain ongoing communication with LAUSD school administrators, providing sufficient notice to forewarn children and parents when existing pedestrian and vehicle routes to school may be impacted.  Contractors shall maintain ongoing communication with Laurel Hall School administrators, providing sufficient notice to forewarn children and parents when existing pedestrian and vehicle routes to school may be impacted.  Installation and maintenance of appropriate traffic controls (signs and signals) to ensure pedestrian and vehicular safety.  Construction vehicles shall avoid, to the extent feasible, travel on streets immediately adjacent to Laurel Hall School and Victory Elementary School.  No staging or parking of construction-related vehicles, including worker-transport vehicles, shall occur on or adjacent to a school property. The staging and parking of construction-related vehicles shall be located as far away from Laurel Hall School as feasible.  Funding for crossing guards (at contractor’s expense) is required when safety of children may be compromised by construction-related activities at impacted school crossings.  Barriers and/or fencing shall be installed to secure construction equipment and to minimize trespassing, vandalism, short-cut attractions, and attractive nuisances.  Contractors are required to provide security patrols (at their expense) to minimize trespassing, vandalism, and short-cut attractions.

Enforcement Agency: LAUSD

Monitoring Agency: LAUSD

Monitoring Phase: During construction

Monitoring Frequency: Ongoing, during construction

Action Indicating Compliance: LAUSD confirmation

M-9 Construction Traffic Management Plan

The Project shall prepare a Construction Traffic and Parking Management Plans for all stages of construction activity at the Project Site. These will be developed in close coordination with LADOT and will include specific provisions for truck routes and staging and construction worker parking. These plans should include but not be limited to the following, as appropriate:

 Identification of truck staging areas, and management of truck access/egress to minimize truck impacts on the street system.

14 ENV-2014-888-EIR June 2016

 Development of Worksite Traffic Control Plans, including temporary traffic controls, lane reconfigurations, temporary traffic signal operation, signage, detour plans as appropriate, and provisions for flag personnel, etc.

 Development of a construction worker transportation demand management plan to encourage use of ridesharing and minimize parking needs.

 Development of a construction worker Parking Management Plan to provide sufficient on-site parking and to minimize temporary impacts to the local street network as a result of construction worker traffic entering or exiting the Project Site.

 An adequate provision for alternate routing, protection barriers, covered walkways where necessary and feasible, and other safety precautions for pedestrians and bicyclists through the Project Area.

 To the extent possible schedule construction-related deliveries, other than concrete and earthwork-related deliveries, to reduce travel during peak commute periods.

 Develop and submit a Freeway Truck Management Plan to Caltrans.

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

Utilities and Service Systems – Wastewater

N.1-1 to N.1-2 See Regulatory Compliance Measures

N.1-3 See Project Design Features

No Mitigation Measures required.

Utilities and Service Systems – Water

N.2-1 to N.2-5 See Regulatory Compliance Measures

N.2-6 See Project Design Features

No Mitigation Measures required.

Utilities and Service Systems – Solid Waste

15 ENV-2014-888-EIR June 2016

N.3-1 to N.3-3 See Regulatory Compliance Measures

N.3-4 See Project Design Features

No Mitigation Measures required.

Utilities and Service Systems – Energy Conservation

N.4-1 to N.4-3 See Regulatory Compliance Measures

N.4-4 See Project Design Features

No Mitigation Measures required.

16 ENV-2014-888-EIR June 2016 Project Design Features

In addition to the required Mitigation Measures, the Project also includes Project Design Features that are measures incorporated into the Project Description, which are designed to prevent any potentially significant impacts from occurring. These Project Design Features are conditions of the Project that must be monitored and enforced in the same manner as Mitigation Measures. These Project Design Features may not be deleted or substantially modified except by the Applicant with approval of the Lead Agency, in most cases following a public hearing process.

Biological Resources

A-1 See Regulatory Compliance Measures

No Project Design Features required.

Aesthetics

B-1 Temporary fencing would be installed around the Project Site during construction.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

B-2 All mechanical and electrical equipment that is located on the rooftops would be screened from public view.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

B-3 Utility equipment would be placed underground, screened from public view, or incorporated into the design of the Project.

Enforcement Agency: Los Angeles Department of Building and Safety

17 ENV-2014-888-EIR June 2016

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

B-4 All landscaped areas would be maintained in accordance with a landscape plan, including an automatic irrigation plan, prepared by a licensed landscape architect in accordance with LAMC Sections 12.40 and 12.41. The final landscape plan shall be reviewed and approved by the City of Los Angeles Department of City Planning during the building permit process.

Enforcement Agency: Los Angeles Department of City Planning

Monitoring Agency: Los Angeles Department of City Planning

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permit

B-5 All exterior lighting would be designed with internal and/or external glare control and would be designed, arranged, directed, or shielded to contain illumination on-site.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

B-6 The exterior of the proposed structures shall be constructed of materials such as, but not limited to, high-performance and/or non-reflective tinted glass (no mirror-like tints or films) and pre-cast concrete or fabricated wall surfaces to minimize glare and reflected heat.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

18 ENV-2014-888-EIR June 2016

Action Indicating Compliance: Plan approval

B-7 See Regulatory Compliance Measures

Air Quality

C-1 to C-5 See Mitigation Measures

C-6 to C-10 See Regulatory Compliance Measures

C-11 The Project Applicant shall ensure that construction vehicles avoid, to the extent feasible, travel on streets immediately adjacent to the Laurel Hall School. The City shall ensure that haul routes are designed to comply with this measure.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

C-12 The Project Applicant shall provide for the funding for the replacement of air filters at the beginning and at the end of construction in any air conditioning units at Laurel Hall School.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

C-13 The Project Applicant shall provide advance notification of the Project’s anticipated general construction schedule and a specific schedule for site grading and preparation activities.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

19 ENV-2014-888-EIR June 2016

Action Indicating Compliance: Field inspection sign-off

Cultural Resources

D-1 to D-3 See Mitigation Measures

No Project Design Features required.

Geology and Soils

E-1 to E-2 See Regulatory Compliance Measures

E-3 Geological Engineering Investigation Recommendations

The Project shall comply with the Conclusions and Recommendations found on pages 11 through 49 of the Geotechnical Engineering Investigation, prepared by Geotechnologies, Inc., August 15, 2014, to the satisfaction of the Bureau of Engineering.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

Greenhouse Gas Emissions

No Project Design Features required.

Hazards and Hazardous Materials

G-1 to G-3 See Regulatory Compliance Measures

No Project Design Features required.

Hydrology and Water Quality

H-1 to H-4 See Regulatory Compliance Measures

No Project Design Features required.

Land Use and Planning

I-1 See Regulatory Compliance Measures

20 ENV-2014-888-EIR June 2016

No Project Design Features required.

Noise

J-1 to J-6 See Mitigation Measures

J-7 See Regulatory Compliance Measures

J-8 The City shall require that truck deliveries and haul routes during construction, to the extent feasible, shall be directed away from Laurel Hall School.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

Population and Housing

No Project Design Features required.

Public Services – Fire Protection

L.1-1 to L.1-4 See Regulatory Compliance Measures

L.1-5 The construction contractors and work crews shall (1) properly maintain the mechanical equipment according to best practices and the manufacturers’ procedures; (2) ensure proper storage of flammable materials; and (3) cleanup of spills of flammable liquid.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

L.1-6 If there are partial closures to streets surrounding the Project Site, flagmen shall be used to facilitate the traffic flow until the street closure around the construction is complete.

Enforcement Agency: Los Angeles Department of Building and Safety

21 ENV-2014-888-EIR June 2016

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Demolition and construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

L.1-7 During demolition and construction, LAFD access from major roadways shall remain clear and unobstructed.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Demolition and construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

L.1-8 The design of the Project Site shall provide adequate access for LAFD equipment and personnel to the structures.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

Public Services – Police Protection

L.2-1 to L.2-2 See Mitigation Measures

L.2-3 to L.2-4 See Regulatory Compliance Measures

L.2-5 Emergency access shall be maintained to the Project Site during construction through marked emergency access points approved by the LAPD.

Enforcement Agency: Los Angeles Police Department

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

22 ENV-2014-888-EIR June 2016

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign-off

L.2-6 The Project shall provide for on-site security measures and controlled access systems for residents and tenants to minimize the demand for police protection services.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

Public Services – Schools

L.3-1 See Regulatory Compliance Measures

No Project Design Features required.

Public Services – Parks

L.4-1 See Regulatory Compliance Measures

No Project Design Features required.

Public Services – Libraries

No Project Design Features required.

Transportation/Traffic

M-1 to M-9 See Mitigation Measures

M-10 The Project shall incorporate Transportation Demand Management (TDM) strategies, which could include, but are not limited to:

23 ENV-2014-888-EIR June 2016

 Include a provision that all retailers over 10,000 square feet and office users are required to comply with the state parking cash-out law;  Provide on-site car share amenities;  Provide rideshare program and support for Project employees and tenants;  Allow for subsidized transit passes for eligible Project employees and tenants;  Coordinate with LADOT to determine if the site would be eligible for one or more of the services to be provided by the future Mobility Hubs program (secure bike parking, bike share kiosks, and car-share parking spaces;  Provide on-site transit routing and schedule information;  Upgrade bus shelters immediately adjacent to the Project Site;  Provide a program to discount transit passes for residents/employees possibly through negotiated bulk purchasing of passes with transit providers;  Guaranteed Ride Home Program; and  Preferential parking for HOVs, carpools, and vanpools.

Prior to occupancy, a comprehensive TDM program tailored specifically for the Project will be developed.

Enforcement Agency: LADOT

Monitoring Agency: LADOT

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once; prior to issuance of Certificate of Occupancy

Action Indicating Compliance: LADOT approval

Utilities and Service Systems – Wastewater

N.1-1 to N.1-2 See Regulatory Compliance Measures

N.1-3 In the event of full or partial public street closures, such as during the construction of new wastewater lines, the Construction Traffic Management Plan shall be in implemented.

Enforcement Agency: Los Angeles Department of Building and Safety; LADOT

Monitoring Agency: LADOT

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

Utilities and Service Systems – Water

24 ENV-2014-888-EIR June 2016

N.2-1 to N.2-5 See Regulatory Compliance Measures

N.2-6 In the event of full or partial public street closures, such as during the construction of new water lines, the Construction Traffic Management Plan shall be in implemented.

Enforcement Agency: Los Angeles Department of Building and Safety; LADOT

Monitoring Agency: LADOT

Monitoring Phase: Construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

Utilities and Service Systems – Solid Waste

N.3-1 to N.3-3 See Regulatory Compliance Measures

N.3-4 To the maximum extent feasible, demolition and construction debris including, but not limited to, concrete, asphalt, wood, drywall, metals, and other miscellaneous and composite materials shall be recycled and salvaged.

Enforcement Agency: Los Angeles Bureau of Sanitation

Monitoring Agency: Los Angeles Bureau of Sanitation

Monitoring Phase: Demolition and construction

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

Utilities and Service Systems – Energy Conservation

N.4-1 to N.4-3 See Regulatory Compliance Measures

N.4-4 The Project shall use Energy Star appliances where available.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

25 ENV-2014-888-EIR June 2016 Regulatory Compliance Measures

In addition to the Mitigation Measures and Project Design Features, the Project is also required to adhere to any applicable Regulatory Compliance Measures required by law. Listed below are the Regulatory Compliance Measures listed in the EIR, which have been identified as ensuring that the Project will avoid any potentially significant impacts.

Biological Resources

A-1 The Project may result in the removal of vegetation and disturbances to the ground and therefore may result in take of nesting native bird species. Migratory nongame native bird species are protected by international treaty under the Federal Migratory Bird Treaty Act of 1918 (50 C.F.R. Section 10.13). Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit take of all birds and their active nests including raptors and other migratory nongame birds (as listed under the Federal MBTA).

Project activities (including disturbances to native and non-native vegetation, structures, and substrates) should take place outside of the breeding bird season, which generally runs from March 1 – August 31 (as early as February 1 for raptors) to avoid take (including disturbances which would cause abandonment of active nests containing eggs and/or young). Take means to hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill (Fish and Game Code Section 86).

If Project activities cannot feasibly avoid the breeding bird season, beginning 30 days prior to the disturbance of suitable nesting habitat, the applicant shall:

 Arrange for weekly bird surveys to detect any protected native birds in the habitat to be removed and any other such habitat within properties adjacent to the Project Site, as access to adjacent areas allows. The surveys shall be conducted by a qualified biologist with experience in conducting breeding bird surveys. The surveys shall continue on a weekly basis with the last survey being conducted no more than three days prior to the initiation of clearance/construction work.  If a protected native bird is found, the applicant shall delay all clearance/construction disturbance activities within 300 feet of suitable nesting habitat for the observed protected bird species until August 31.  Alternatively, the qualified biologist could continue the surveys in order to locate any nests. If an active nest is located, clearing and construction within 300 feet of the nest, or as determined by a qualified biological monitor, shall be postponed until the nest is vacated and juveniles have fledged and when there is no evidence of a second attempt at nesting. The buffer zone from the nest shall be established in the field with flagging and stakes. Construction personnel shall be instructed on the sensitivity of the area.  The applicant shall record results of the recommended protective measures described above to document compliance with applicable State and Federal laws pertaining to the protection of

26 ENV-2014-888-EIR June 2016

native birds. Such record shall be submitted and received into the case file for the associated discretionary action permitting the Project.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Weekly surveys, if during the breeding bird season

Action Indicating Compliance: Biologist inspection sign-off

Aesthetics

B-1 to B-6 See Project Design Features

B-7 The Project would comply with the applicable provisions of the City of Los Angeles Municipal Code and Building Code related to signage.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

Air Quality

C-6 Construction activities shall comply with SCAQMD Rule 403, including the following measures:

o Apply water and/or soul binders to disturbed areas of the site to minimize dust three times a day

o Require the use of a gravel apron or other equivalent methods to reduce mud and dirt trackout onto truck exit routes

o Appoint a construction relations officer to act as a community liaison concerning on-site construction activity including resolution of issues related to PM generation.

o Limit soil disturbance to the amounts analyzed in the Final EIR.

o All materials transported off-site shall be securely covered.

27 ENV-2014-888-EIR June 2016

o Apply non-toxic soil stabilizers according to manufacturers’ specifications to all inactive construction areas (previously graded areas inactive for ten days or more).

o Traffic speeds on all unpaved roads to be reduced to 15 mph or less.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

C-7 Architectural coatings and solvents applied during construction activities shall comply with SCAQMD Rule 1113, which governs the VOC content of architectural coatings.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Field inspection

Action Indicating Compliance: Field inspection sign off

C-8 All diesel-fueled commercial heavy- and medium-duty vehicles shall comply with CARB’s regulations limiting idling (Title 13 Section 2485). This includes no idling of primary diesel engines for more than five minutes and not using diesel-fueled auxiliary power systems to power cab functions (e.g., heating, air conditions) for more than five minutes when within 100 feet of restricted areas.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

C-9 Any stationary sources of emissions shall comply with SCAQMD rules and regulations, including Regulation XIII, which governs New Source Review for major stationary sources.

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Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Field inspection

Action Indicating Compliance: Field inspection sign off

C-10 Any restaurants that include chain-driven charbroilers shall comply with SCAQMD Rule 1138, which requires use of catalytic oxidizer controls.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Field inspection

Action Indicating Compliance: Field inspection sign off

C-1 to C-5 See Mitigation Measures

C-11 to C-13 See Project Design Features

Cultural Resources

D-1 to D-3 See Mitigation Measures

No Regulatory Compliance Measures required.

Geology and Soils

E-1 The Project shall comply with the conditions contained within the Department of Building and Safety’s Geology and Soils Report Approval Letter for the proposed project, and as it may be subsequently amended or modified.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Prior to the issuance of grading or building permits

Monitoring Frequency: Ongoing during construction

Action Indicating Compliance: Field inspection sign-off

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E-2 The Project shall comply with all applicable standards of South Coast Air Quality Management District Rule 403, the requirements of a Stormwater Pollution Prevention Plan, in accordance with the National Pollutant Discharge Elimination System, and the City’s grading permit regulations, which require the implementation of grading and dust control measures.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspection

Action Indicating Compliance: Field inspection sign off

E-3 See Project Design Features

Greenhouse Gas Emissions

No Regulatory Compliance Measures required.

Hazards and Hazardous Materials

G-1 Poly-chlorinated Biphenyls

Prior to issuance of a demolition permit, all fluorescent light ballasts shall be inspected for PCB content and shall be disposed of at a permitted facility in compliance with state and federal rules and regulations.

Enforcement Agency: Los Angeles Department of Building and Safety.

Monitoring Agency: Los Angeles Department of Building and Safety.

Monitoring Phase: Prior to demolition activities

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of a building permit

G-2 Asbestos

Prior to the issuance of any permit for the demolition or alteration of the existing structures, the Applicant shall provide a letter to the Department of Building and Safety from a qualified asbestos abatement consultant indicating that no ACMs are present in the building. If ACMs are found to be present, it will need to be abated in compliance with the SCAQMD's Rule 1403 as well as all other applicable State and Federal rules and regulations.

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Enforcement Agency: Los Angeles Department of Building and Safety.

Monitoring Agency: Los Angeles Department of Building and Safety.

Monitoring Phase: Prior to demolition activities

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of a building permit

G-3 Lead-Based Paint

Prior to issuance of any permit for the demolition or alteration of the existing structures, a lead- based paint survey shall be performed to the written satisfaction of the Department of Building and Safety. Should lead-based paint materials be identified, standard handling and disposal practices shall be implemented pursuant to OSHA regulations.

Enforcement Agency: Los Angeles Department of Building and Safety.

Monitoring Agency: Los Angeles Department of Building and Safety.

Monitoring Phase: Prior to demolition activities

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of a building permit

Hydrology and Water Quality

H-1 National Pollutant Discharge Elimination System General Permit

Prior to issuance of a grading permit, the Applicant shall obtain coverage under the State Water Resources Control Board National Pollutant Discharge Elimination System General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities (Order No. 2009-0009-DWQ, National Pollutant Discharge Elimination System No. CAS000002) (Construction General Permit). The Applicant shall provide the Waste Discharge Identification Number to the City of Los Angeles to demonstrate proof of coverage under the Construction General Permit. A Storm Water Pollution Prevention Plan shall be prepared and implemented in compliance with the requirements of the Construction General Permit. The Storm Water Pollution Prevention Plan shall identify construction Best Management Practices to be implemented to ensure that the potential for soil erosion and sedimentation is minimized and to control the discharge of pollutants to storm water runoff as a result of construction activities.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

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Monitoring Phase: Pre-grading

Monitoring Frequency: Once, at permit application submittal

Action Indicating Compliance: Issuance of grading permit

H-2 Low Impact Development Plan

Prior to issuance of grading permits, the Applicant shall submit a Low Impact Development Plan and/or Standard Urban Stormwater Mitigation Plan to the City of Los Angeles Bureau of Sanitation Watershed Protection Division for review and approval. The Low Impact Development Plan and/or Standard Urban Stormwater Mitigation Plan shall be prepared consistent with the requirements of the Development Best Management Practices Handbook.

Enforcement Agency: Los Angeles Bureau of Sanitation

Monitoring Agency: Los Angeles Bureau of Sanitation

Monitoring Phase: Pre-grading

Monitoring Frequency: Once, at LID Plan submittal

Action Indicating Compliance: Issuance of grading permit

H-3 Development Best Management Practices

In accordance with the Development Best Management Practices Handbook Part B Planning Activities, the BMPs shall be designed to retain or treat the runoff from a storm event producing 0.75 inch of rainfall in a 24-hour period. A signed certificate from a licensed civil engineer or licensed architect confirming that the proposed BMPs meet this numerical threshold standard shall be provided.

Enforcement Agency: Los Angeles Bureau of Sanitation

Monitoring Agency: Los Angeles Bureau of Sanitation

Monitoring Phase: Pre-grading

Monitoring Frequency: Once, at submittal of Best Management Practices certificate

Action Indicating Compliance: Issuance of grading permit

H-4 The Project Applicant shall comply with all mandatory storm water permit requirements (including, but not limited to NPDES, SWPPP and SUSMP, and LID requirements) at the Federal, State and local level.

Enforcement Agency: Los Angeles Department of Building and Safety

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Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Prior to construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of a building permit

Land Use and Planning

I-1 Further consistency with each applicable component of the commercial and residential Citywide design guidelines will be assured during the City review process.

Enforcement Agency: Los Angeles Department of City Planning

Monitoring Agency: Los Angeles Department of City Planning

Monitoring Phase: Prior to construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of a building permit

Noise

J-1 to J-6 See Mitigation Measures

J-7 The Project shall comply with the City of Los Angeles Building Regulations Ordinance No. 178048, which requires a construction site notice to be provided that includes the following information: job site address, permit number, name and phone number of the contractor and owner or owner’s agent, hours of construction allowed by code or any discretionary approval for the site, and City telephone numbers where violations can be reported. The notice shall be posted and maintained at the construction site prior to the start of construction and displayed in a location that is readily visible to the public.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Once during construction

Action Indicating Compliance: Field inspection sign-off

J-8 See Project Design Features

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Population and Housing

No Regulatory Compliance Measures required.

Public Services – Fire Protection

L.1-1 The Project shall comply with the 2014 Fire Code and any subsequent codes at the time of building permits, including the requirements for automatic fire sprinkler systems and any other fire protection devices deemed necessary by the Fire Chief (e.g., fire signaling systems, fire extinguishers, smoke removal systems, etc.).

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

L.1-2 The plot plan shall be submitted to the LAFD for review and approval, and shall include the following minimum design features: fire lanes, where required, shall be a minimum of 20 feet in width; all structures must be within 300 feet of an approved fire hydrant, and entrances to any dwelling unit or guest room shall not be more than 150 feet in distance in horizontal travel from the edge of the roadway of an improved street or approved fire lane.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

L.1-3 A plot plan shall be submitted to the LAFD for review and approval prior to occupancy of the Project, which shall provide the capacity of the fire mains serving the Project Site. Any required upgrades shall be identified and implemented prior to occupancy of the Project.

Enforcement Agency: LAFD

Monitoring Agency: LAFD

Monitoring Phase: Pre-operation

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Monitoring Frequency: Once, prior to operation

Action Indicating Compliance: Plan approval prior to operation (Pre-operation)

L.1-4 Prior to occupancy of the Project, an emergency response plan shall be submitted to the LAFD. The emergency response plan would include, but not be limited to, the following: mapping of emergency exits, evacuation routes for vehicles and pedestrians, location of nearest hospitals, and fire stations. Any required modifications shall be identified and implemented prior to occupancy of the Project.

Enforcement Agency: LAFD; Los Angeles Department of Building and Safety

Monitoring Agency: LAFD; Los Angeles Department of Building and Safety

Monitoring Phase: Pre-operation; Operation

Monitoring Frequency: Once, for Plan approval prior to operation

Action Indicating Compliance: Plan approval prior to operation (Pre-operation)

L.1-5 to L.1-8 See Project Design Features

Public Services – Police Protection

L.2-1 to L.2-2 See Mitigation Measures

L.2-3 Temporary construction fencing shall be placed along the periphery of the active construction areas to screen as much of the construction activity from view at the local street level and to keep unpermitted persons from entering the construction area.

The perimeter fence shall have gates installed to facilitate the ingress and egress of equipment and the work force. The perimeter and silt fence shall be maintained while in place. Where applicable, the construction fence shall be incorporated with a pedestrian walkway. Temporary lighting shall be installed and maintained at the pedestrian walkway. Should sections of the site fence have to be removed to facilitate work in progress, barriers and or K – rail shall be utilized to isolate and protect the public from unsafe conditions.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Construction

Monitoring Frequency: Periodic field inspections during construction

Action Indicating Compliance: Field inspection sign-off

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L.2-4 The plans shall incorporate the design guidelines relative to security, semi-public and private spaces, which may include but not be limited to access control to buildings, secured parking facilities, walls/fences with key systems, well-illuminated public and semi-public space designed with a minimum of dead space to eliminate areas of concealment, location of toilet facilities or building entrances in high-foot traffic areas, and provision of security guard patrol throughout the project site if needed. Please refer to "Design Out Crime Guidelines: Crime Prevention Through Environmental Design", published by the Los Angeles Police Department. Contact the Community Relations Division, located at 100 W. 1st Street, #250, Los Angeles, CA 90012; (213) 486-6000. These measures shall be approved by the Police Department prior to the issuance of building permits.

Enforcement Agency: Los Angeles Police Department

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-Construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Issuance of building permits

L.2-5 to L.2-6 See Project Design Features

Public Services – Schools

L.3-1 Payment of School Development Fee

Prior to issuance of a building permit, the General Manager of the City of Los Angeles, Department of Building and Safety, or designee, shall ensure that the Applicant has paid all applicable school facility development fees in accordance with California Government Code Section 65995.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Unified School

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once, at payment

Action Indicating Compliance: Receipt of payment; issuance of certificate of occupancy

Public Services – Parks

L.4-1 Increased Demand For Parks Or Recreational Facilities

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 (Subdivision or Zone Change) Pursuant to Section 17.12-A, 17.58, or 12.33 of the Los Angeles Municipal Code, the applicant shall pay the applicable Quimby fees for the construction of dwelling units.  (No Subdivision) Pursuant to Section 21.10 of the Los Angeles Municipal Code, the applicant shall pay the Dwelling Unit Construction Tax for construction of apartment units.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-occupancy

Monitoring Frequency: Once, at payment

Action Indicating Compliance: Receipt of payment; issuance of certificate of occupancy

Public Services – Libraries

No Regulatory Compliance Measures required.

Transportation/Traffic

M-1 to M-9 See Mitigation Measures

No Regulatory Compliance Measures required.

Utilities and Service Systems – Wastewater

N.1-1 The Project shall comply with City Ordinance No. 179,820 (Green Building Ordinance), which establishes a requirement to incorporate green building practices into projects that meet certain threshold criteria.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.1-2 As part of the City plan check/building permit process, the Project Applicant shall confirm with the City that the capacities of the local and trunk lines are sufficient to accommodate the Project’s wastewater flows during the construction and operation phases. If the public sewer has insufficient capacity, then the Project Applicant shall be required to build sewer lines to a point in the sewer system with sufficient capacity.

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Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.1-3 See Project Design Features

Utilities and Service Systems – Water

N.2‐1 Fire Water Flow

The Project Applicant shall consult with the LADBS and LAFD to determine fire flow requirements for the Project, and will contact a Water Service Representative at the LADWP to order a Service Advisory Report (SAR). This system hydraulic analysis will determine if existing LADWP water supply facilities can provide the proposed fire flow requirements of the Project. If water main or infrastructure upgrades are required, the Applicant would pay for such upgrades, which would be constructed by either the Applicant or LADWP.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.2-2 Green Building Code

The Project shall implement all applicable mandatory measures within the LA Green Building Code that would have the effect of reducing the Project’s water use.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

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N.2-3 Water Management Ordinance

The Project shall comply with Ordinance No. 170,978 (Water Management Ordinance), which imposes numerous water conservation measures in landscape installation and maintenance (e.g., use drip irrigation and soak hoses in lieu of sprinklers to lower the amount of water lost to evaporation and overspray, set automatic sprinkler systems to irrigate during the early morning or evening hours to minimize water loss due to evaporation, and water less in the cooler months and during the rainy season).

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.2-4 LID Ordinance and Stormwater BMPs

The Project shall comply with the City of Los Angeles Low Impact Development Ordinance (City Ordinance No. 181,899) and implement Best Management Practices that have stormwater recharge or reuse benefits for the Project (as applicable and feasible).

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

M.2-5 As part of the City plan check/building permit process, the Project Applicant shall confirm with the City that the capacity of the existing water infrastructure can supply the domestic needs of the Project during the construction and operation phases. The Project Applicant shall implement any upgrade to the water infrastructure serving the Project Site that is needed to accommodate the Project’s water consumption needs.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

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Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.2-6 See Project Design Features

Utilities and Service Systems – Solid Waste

N.3-1 Designated Recycling Area

In compliance with Los Angeles Municipal Code, the Project shall provide readily accessible areas that serve the entire building and are identified for the depositing, storage, and collection of nonhazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, and metals.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.3-2 Construction Waste Recycling

In order to meet the diversion goals of the California Integrated Waste Management Act and the City of Los Angeles Solid Waste Planning Background Studies Summary Report goal of 70 percent diversion by 2020, the Project shall salvage and recycle construction and demolition materials to ensure that a minimum of 70 percent of construction-related solid waste that can be recycled is diverted from the waste stream. Solid waste diversion would be accomplished though the on-site separation of materials and/or by contracting with a solid waste disposal facility that can guarantee a minimum diversion rate of 70 percent. In compliance with the Los Angeles Municipal Code, the General Contractor shall utilize solid waste haulers, contractors, and recyclers who have obtained an Assembly Bill (AB) 939 Compliance Permit from the City of Los Angeles Bureau of Sanitation.

Enforcement Agency: Los Angeles Bureau of Sanitation

Monitoring Agency: Los Angeles Bureau of Sanitation

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, prior to construction

Action Indicating Compliance: AB 939 Compliance Permit issuance

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N.3-3 Commercial/Multifamily Mandatory Recycling

To comply with AB 341, recycling bins shall be provided at appropriate locations to promote recycling of paper, metal, glass and other recyclable material. These bins shall be emptied and recycled in accordance with the Project’s regular solid waste disposal program. The Project Applicant shall only contract for waste disposal services with a company that recycles solid waste in compliance with AB 341.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Prior to occupancy

Monitoring Frequency: Once, prior to occupancy

Action Indicating Compliance: Issuance of Certificate of Occupancy

N.3-4 See Project Design Features

Utilities and Service Systems – Energy Conservation

N.4-1 The Project shall comply with City Ordinance No. 179,820 (Green Building Ordinance), which establishes a requirement to incorporate green building practices into projects that meet certain threshold criteria.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.4-2 The Project shall implement all applicable mandatory measures within the LA Green Building Code that would have the effect of reducing the Project’s energy use.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

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Action Indicating Compliance: Plan approval

N.4-3 The Project shall comply with the lighting power requirements in the California Energy Code, California Code of Regulations (CCR), Title 24, Part 6.

Enforcement Agency: Los Angeles Department of Building and Safety

Monitoring Agency: Los Angeles Department of Building and Safety

Monitoring Phase: Pre-construction

Monitoring Frequency: Once, at plan check

Action Indicating Compliance: Plan approval

N.4-4 See Project Design Features