Los Angeles City Planning Department ~~
JI_LOS t,r-lGELF..s CITY City Hall· 200 N. Spring Street, Room 750 • Los Angeles, CA 90012 PLANNING OEP;\RfMENr
FINAL ENVIRONMENTAL iMPACT REPORT
HOLL YWOOD COMMUNITY PLAN AREA
Target at Sunset and Western Case No. ENV-2008-1421-EIR SCH No. 2010121011 Council District No. 13
HIS DOCUMENT COMPRISES THE SECOND AND FINAL PART OF THE ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE PROPOSED PROJECT DESCRIBED. THE DRAFT EIR COMPRISED THE FIRST PART.
Project Address: 5520 West Sunset Boulevard, Los Angeles, CA 90028
Project Description: Demolition of a 59,561-square-foot single-story commercial structure, an electrical substation and a surface parking lot and construction of a three-story 194,749 square-foot multi-tenant commercial structure that includes a 163,862-square-foot retail store (Target) and 30,887 square feet of other smaller retail and food uses. The project would also include 458 at-grade and above-ground parking spaces.
APPLICANT: Target Stores
PREPARED BY: Environmental Review Section Los Angeles City Planning Department
June 2012 EIR NO.: ENV-2008-1421-EIR SCH NO.: 2010121011
PROJECT NAME: Target Retail Shopping Center Project (Target at Sunset and Western)
RECOMMENDATION FOR EIR CERTIFICATION
Pursuant to California Code of Regulations, Title 14, Section 15090, this ErR has been completed in compliance with the California Environmental Quality Act and current State and City Guidelines and based on information available may be accepted and considered prior to making a final decision on the project. The decision-maker or decision-making body must Certify that it has reviewed and considered the information contained in this Environmental Impact Report prior to making such decision.
Submitted by:
Srimal P. Hewawitharana KarenHoo Environmental Specialist II Supervising City Planner Environmental Review Section Environmental Review Section
7~(/-Z-+----(J/
Jon Foreman Senior City Planner Department of City Planning DEPARTMENT Of EXECUTIVE OfFICES CITY PLANNING CITY OF Los ANGELES MICHAEL J. LOGRANDE 200 N. SpruNGsrsser, RooM 525 CALIFORNIA los ANC~LES,CA 900124801 D1REcrOl: . AND (213) 978·1271 6262 VAN Nl.IYS BLVD., SUliE351 VAN NVYS, CA 91401 ALAN BELt, Ala> DEPUTY DIREClOI: CITY PLANNING COMMISSION (213}978-1272 WIlliAM ROSCH£N EVA YUAN-MCDANIEL f>R!OS1DENT DEI'tITYOlRECfOR REGINA M, fREER (213)978·1273 Vla-l'J$lDrNf SEAN O. BURTON VACANT DIEGO CARDOSO GEORGE HQVAGUIMiAN DEPUlY O!Ri!CTOl( JUSTIN KIM ANTONIO R. VILLARAIGOSA (213) 978-1274 MAYOR ROBERT LESSIN FAX: (213l978·127S BARBARA ROMERO 'MICHAEL K. WOO INfORMATION JAMES WIlliAMS www,planning.lacity.org COMMISSION EXECUnVEASSlSTANT n (Z13) 978·1300
June 7, 2012
NOTICE OF COMPLETION AND AVAILABILITY OF THE FINAL ENVIRONMENTAL IMPACT REPORT FOR THE TARGET RETAIL SHOPPING CENTER PROJECT (TARGET AT SUNSET AND WESTERN) Case No. ENV-2008-1421-EIR State Clearinghouse No. 2010121011
TO: Owners of Property and Occupants and Other Interested Parties PROJECT TITLE: Target Retail Shopping Center Project (Target at Sunset and Western) APPLICANT: Target Stores PROJECT ADDRESS: 5520 West Sunset Boulevard COMMUNITY PLAN AREA: Hollywood COUNCIL DISTRICT: 13
PROJECT DESCRIPTION:
Demolition of a 59,561-square-foot single-story commercial structure, an electrical substation and a surface parking lot and construction of a three-story 194,749 square-foot multi-tenant commercial structure that includes a 163,862-square-foot retail store (Target) and 30,887 square feet of other smaller retail and food uses, The project would also include 458 at-grade and above-ground parking spaces,
The project 'is located within the Hollywood Community Plan, the Hollywood Redevelopment Project, and the VermontiWestern Station Neighborhood Area Plan (SNAP) Specific Plan areas, The SNAP restricts all Community Center uses to C4 uses as defined by the Los Angeles Municipal Code (LAMC).
The Applicant is requesting the following ministerial and discretionary approvals from the City of Los Angeles as part of the project: Specific Plan Project Permit Compliance Review; Specific Plan Exceptions Approval; Site Plan Review Findings pursuant to LAMC Section 16,-05E; Zoning Administrator Approval of Conditional Use Permit for alcohol; demolition, grading, foundation and building permits; health department and off-site permits; Board of Public Works Approval of Street Tree Removal; and Haul Route Approval, pursuant to LAMC Section 91.7006.7.4.
DOCUMENT REVIEW AND COMMENT: If you wish to review a copy of the Final EIR or the documents referenced in the Final EIR, you may do so at the City of Los Angeles, Department of City Planning at 200 North Spring Street, Room 750, Los Angeles, CA 90012. Please call ahead to make an appointment. Copies of the Final EIR are also available at the following Los Angeles Public Library branches:
1) Central Library: 630 W 5th Street, Los Angeles, CA 90071 2) Frances Howard Goldwyn Hollywood Library: 16231var Avenue, Hollywood, CA 90028 3) John C. Fremont Library: 6121 Melrose Avenue, Los Angeles CA 90038 4) Will & Ariel Durant Library: 7140 W Sunset Blvd, Los Angeles, CA 90046
On-Line Final EIR:
The Final EIR is also available online at the Department of City Planning's website (http://cityplanning.lacity.org/,click on "Environmental" and then "Final EIR").
Final EIR CD-ROM Purchase: The Final EIR may also be purchased on CD-ROM for $7.50 per copy. To purchase a copy, contact Srimal Hewawitharana at (213) 978-1359.
Michael J. LoGrande Director of Planning
Srimal Hewawitharana Environmental Review Coordinator TABLE OF CONTENTS
Section Page
I. INTRODUCTION 1-1
II. LIST OF COMMENTERS ".,""', ..,.., ,..,', , , " " " ,.11-1
III, RESPONSESTO WRITIEN COMMENTS , , " ,", , 111-1
IV. CORRECTIONS AND ADDITIONS , ,', " " , IV-1
V. MITIGATION MONITORING AND REPORTING PROGRAM V-1
APPENDICES
A: Phase II Environmental Assessment
B: letter from los Angeles Police Department
C: Saturday Traffic Analvsis Data and Worksheets
LIST OF FIGURES
Figure 111-1 Views of ICDC College Building ,111-85
Figure 111-2 Views from South of the Project Site 111-88
Figure 111-3 Views from South of the Project Site 111-90
Figure 111-4 Views of the Covenant House Building 111-91
LIST OF TABLES
Table 111-1 Saturday Trip Generation Rates""." ,.." , , , 1I1-117
Table 111-2 Estimated Saturday Mid-day Traffic Generation 111-118
Table 111-3 Existing + Project Saturday Mid-day Traffic Conditions 111-119
Table 111-4 EXisting + Project Saturday Mid-day Traffic Conditions + Mitigation 111-120
Table 111-5 Future (2015) Cumulative + Project Saturday Mid-day Traffic
Conditions ,', ,",., ,.,", ,..,"", ,",.,', ,"", " ..,", ",111-120
Table 111-6 Future (2015) Cumulative + Project Saturday Mid-day Traffic
Conditions + Mitigation ; ,.." ,', " .., , ,', , ,,111-121
Target at Sunset and Western Table of Contents Page i I. INTRODUCTION
1. SUMMARY OF THE PROPOSED PROJECT
The project proposes the demolition of the existing 59,561 square feet of single-story buildings, electrical substation, and parking lot and development of commercial retail uses, including a Target store, retail/restaurant uses, and a parking structure containing two levels of parking. The proposed project would include a total of approximately 194,749 gross square feet of retail and associated uses. The project proposes a 163,862square foot Target store, along with 30,887 square feet of other smaller retail and food uses fronting Sunset Boulevard and Western Avenue, in a three-level, 74'-4" tall (with architectural features extending to 84'-4") retail center. Approximately 458 parking spaces are proposed to be located on the ground level and second level of the project. The proposed project also contains exterior balconies, a roof terrace on the second level, an entry plaza, open areas, and landscaping. The project proposes an FARof approximately 1.15:1.
2. ENVIRONMENTAL REVIEW PROCESS
The project was reviewed by the LosAngeles Department of City Planning, Environmental Review Unit, which determined that the proposed project required the preparation of an Environmental Impact Report (EIR).
Comments from identified responsible and trustee agencies,as well as interested parties, on the scope of the EIRwere solicited through a Notice of Preparation (NOP) process. The NOP for the EIRwas circulated for a 30-day review period starting on December 6, 2010 and ending on January 14, 2011. A scoping meeting was held on December 16, 2010. Refer to Appendix 1-1to the Draft EIRfor a copy of the Initial Study and NOP,and refer to Appendix 1-2to the Draft EIRfor written comments submitted to the Department of City Planningin responseto the NOP.
The Draft EIRwas released for public comment on January 19, 2012. The comment period ended on March 5, 2012, meeting the 45-day review period required by the California Environmental Quality Act (CEQA). During that time, the Planning Department received comments on the Draft EIRfrom ten organizations, individuals, and agencies in the form of emails and letters. Two additional letters were received after the comment period closed.
Before approving a project, CEQArequires the lead agency to 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, asfollows:
The Final fiR shall consist of:
(a) The Draft fiR or a revision of the Draft.
(b) Comments and recommendations received on the Revised Draft fiR either verbatim or in summary.
(c) A list of persons, organizations, and public agencies commenting on the Draft ElR.
Target at Sunset and Western I. Introduction Page1-1 Cityof LosAngeles June2012
[d} The responses of the lead agency to significant environmental points raised in the review and consultation process.
(e) Any other irfotmation added by the lead agency.
CEQArequires that the lead agency provide each agency that commented on the Draft EIRwith a copy of the lead agency's proposed response at least 10 days before certifying the Final EIR.
3. ORGANIZATION OF THE FINAL EIR
This document, together with the Draft EIRand the Draft EIRTechnical Appendices, constitute the "Final EIR" for the proposed project. The Draft EIRconsisted of the following:
• The Draft EIR,which included the environmental analysis for the proposed project; and
• Draft EIRTechnical Appendices, which included:
0 APPENDIX1-1: Notice of Preparation (NOP) and Initial Study
0 APPENDIX1-2: Responsesto NOP
0 APPENDIX11-1: Responses to Service Letters
0 APPENDIXIV.A-l: Landscape Tree Survey
0 APPENDIXIV.A-2: Historic Report
0 APPEDNIXIV.C-l: Traffic Report
0 APPENDIXIV.D-l: Geotechnical Study
0 APPENDIXIV.E-l: PhaseI ESAReport
0 APPENDIXIV.F-l: Hydrology Study
0 APPENDIXIV.F-2: Standard Urban Storm Water Mitigation Plan
0 APPENDIXIV.G-l: Vermont Western Transit Oriented District Specific Plan (SNAP)
0 APPENDIXIV.G-2: Vermont Western SNAP Development Standards and Design Guidelines
0 APPENDIXIV.H-l: Noise Worksheets
0 APPENDIXIV.I-l: Air Quality Worksheets
0 APPENDIXIV.L-l: Greenhouse Gas Emissions Report
This Final EIRis organized in the following sections:
I. Introduction
This Section is intended to provide a summary of the project description and CEQArequirements.
Target at Sunset and Western I. Introduction Page1-2 Cityof LosAngeles June2012
II. list of Commenters
This Section includes a list of public agencies,organizations, and individuals who submitted comments on the Draft EIR.
III. Responsesto Comments
This Section includes detailed responsesto the comment letters submitted to the City in responseto the Draft EIR.
IV. Corrections and Additions
This Section provides a complete overview of the changesto the Draft EIRthat have been incorporated into the Final EIRin responseto the comments submitted during the public review period.
V. Mitigation Monitoring and Adaptive Management Program
This Section includes a list of the required mitigation measures and includes detailed information with respect to the City's policies and procedures for implementation of the recommended mitigation measures. This Mitigation Monitoring Program (MMP) identifies the monitoring phase, the enforcement phase, and the applicable department or agency responsible for ensuring that each recommended mitigation measure is implemented.
Appendices
A: PhaseII Environmental Assessment
B: Letter from LosAngelesPoliceDepartment
C: SaturdayTraffic AnalysisData and Worksheets
Target at Sunset and Western I. Introduction Page1·3 II. LIST OF COMMENTERS
1. COMMEI'.1TS ON THE DRAFT EIR
The following organizations/persons provided written comments on the Draft EIR to the Los Angeles Department of Citv Planning during the formal 45-day public review period from January 19, 2012 through March 5, lOl2. Two additional letters were received after the comment period closed. Each comment letter is included in its entirety in Section III, Responses to Comments, along with responses, according to the numbering system below.
State Agencies
1. State of California Governor's Office of Planning and Research, March, 5, 2012
2. State of California, Native American Heritage Commission, January 23, 2012
3. State of California, Department of Toxic Substance Control, March 5, 2012
Local Agencies
4. County of Los-AngelesMetropolitan Transportation Authority, February 24, 2012
5. City of Los Angeles Bureau of Sanitation, Wastewater Engineering Services Division, February 13, 2012
6. Hollywood Studio District Neighborhood Council, February 13, 2012
Organizations and !ndividuals
7. Robert Blue/Ziggy Krause on behalf of the Citizen's Coalition, March 5, 2012
8. Doug Haines on behalf of the La Mirada Avenue Neighborhood Association of Hollywood, March 4, 2012
9. Home Depot, March 5, 2012
10. Art Kassen on behalf of the La Mirada Avenue Neighborhood Association of Hollywood, March 1, 2012
Comment Letters Received Outside The Designated Review Period
11. State of California Governor's Office of Planning and Research, March 13, 2012
12. State of California Department of Transportation, March 8, 2012
Target at Sunset and Western II. list of Commenters Page11-1 III. RESPONSES TO COMMENTS
1. COMMENTS ON THE DRAFT EIR
The City of Los Angeles, Department of City Planning received a total of ten letters that provided comments on the Draft EIRduring the designated comment period (between January 26, 2012 and March 5, 2012). Two additional letters were received after the comment period closed. Eachcomment letter has been assigned a corresponding number, and comments within each comment letter are also numbered.
Written comments made during the public review period for the Draft EIR intermixed points and opinions relevant to project approval/disapproval with points and opinions relevant to the environmental review presented in the Draft EIR. Section 15204(a) of the State CEQAGuidelines' ("CEQAGuidelines") encouragesreviewers to examine the sufficiency of the environmental document, particularly in regard to significant effects, and to suggest specific mitigation measures and project alternatives. Based on judicial interpretation of this section, the lead agency is not obligated to undertake every suggestion it is given, provided that the lead agency responds to significant environmental issues and makes a good faith effort at disclosure. Furthermore, Section lS204(c) advises reviewers that comments should be accompanied by factual support. The responses to comments provided in this section of the Final EIRprovide detailed responsesto all comments related to the environmental review and discuss, as appropriate, the points raised by commenters regarding project design and opinions relating to project approval. The latter are usually statements of opinion or preference regarding a project's design or its presence as opposed to points within the purview of an EIR:environmental impact and mitigation.
The organizations/persons that provided written comments on the Draft EIRto the City of LosAngeles Department of City Planning are listed in Section II (List of Commenters). The summary table below indicates the issue areas on which each organization/person commented.
California Code of Regulations Title 14, Chapter 3, Sections 15000-15387.
Target at Sunset and Western II!. Responses to Comments Page111-1 "0 N ~~ U C 0'" rc'" N 0. '"E c -0 E '" ~ '" 0 .;; '" co 0 u .c" c eo vi :t S c ~ ro ~ ';:: c a. ~ ro ~ '"c E'" ro 0 0'" a. u .:: ~ ~ 0" c :;!'" "0 0 cc'" ro :~ --' .c"' ~ "0 ~ C C = 'ji 0 E'" u "0 C ~ J~ s:~'" a.> .c E c 0 j u 4:''" ~ ~ u ro e "', s: "0 B », ~ u 5. c .2 ~ -0 ""c'" ~ .::'" c ~ :> -o« E'" 0 ro w ~ ~ 0 i':' ~'" '3 > " 0- .r:: -o .s: c'" I-'" ~ E :> • • • • • • • j" • • = eo • rc'" c, • • • • • • '" N '" er on co "- co '" ~ I ~ c .c C -o u >- 0 0 ~ ~ 0 rc "E -c :E s: ru c 0 co ~ ~ e t s: 0 0 0 m ~ .c cc C Q. :> u '" ~ 0 .c -o '" « ~ co c E u 0" c C 'ijj ro 0 u c1I N Z E p'" 0 C'" ~ m 'U w ,E"" u ro '" c 0 c ~ 1:: c c ~ 'v" 0 :> " co -0 C a. 0 ro '"rc :> ~ u .::'" '"> n: ~ V> C ~ -c 'C u «" C "0 0 co ~ ';;0 "" e 0 0 -o '0 I vi I- 0 ~ 'c '" 0 P .c ro u ::0 c l- ro c :;! .c .~ '" co ~ 'v 'C e; :;;: ~ co U 0 .~ .c .a 0 .E -c iE 0 ro .c '" ro ~ C c ~ ~ C 0 a. ~ ec 0 E c: c; '"E ~ "'0 'ijj 'e; rc .c 1;; -., « E'" ~ :> Z ~ ~ ~'" '" c E n: 1:: "ijj" re ~ ro '"o -o :;; " u :> ~ '" 1:: -o '"> ro :;;:'" ~ -c '0 0 S > c a. c :> -e 0 0 m ro "" vv ~ .:; >- '= "0 ~ a. '" « ro '0 "co ro C .,'" t9 Z o'" ~ s: ro ~ 0 "ijj'" vi Cl 'C ec w .c "ijj Cl '" N ~ '" .!i .~ .~ .... c 0 E -" 0" co "0 0" "" ill "0 I ~ C c: E s: E E 0 « eo'" '6 -e c c c'" er co - ~ c :> c ro 0 :> >- ~ m 0 ~ ~ ~ c ~ g ~ 0 ~ '" -c .... « ~ -C '0 0 ., ro ro ro c "0 ~ :> a. "'~ .... U ro U U :> ~ "' C '" '"c 0 ro 'u 0 '0 0 0 0 "ijj ';;; c: .... 0 iii " 0 ~ 0 ., 0 " u >- 'p co I ro " - 0 '0 '0 ~ 1:: c 'u"' - -e c 0 N i':'" i?: « ec 0 « 2' 2' ~ ~ c :> - .z- '" -0 E ro "" ro " "ro >- " 'C ~ ~ " 0 " I- ., ~ E :;! ~ 0 ~ 0 0 0 "0 ~ 0 V> V> V> U 0 I tx: ~ 0 I "' ~>-'" '"i:' « '" 0 0 '"- ~ N U ~ M c 0 ,2: N " E" c "U E " ~ 0 -" ~ u ~" ~0 .'!! ~ ~ ~ c c" "E c.0 E ~ 0 -0 tx: u ,9 " ro i; - -o c, -c~" ;< ro 1: 'S;" 0 e ~ -c ~ 2 "~ ro 0 c sz eo co 'Vi c 'C U ro " o" :5" ~ '0 "ro ~ -c" '" 'Vi~ -'= f-" "0 •
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-e ,2 .c :;; u Q. ~ ;: "~'" 's a:" " -o a: c -e" ro ec c ro" 'c c c; .!!!'~ 0- c 0 '" " '0 ±e 0 c 'w .<:" u ru f- " ::> t 0 c, ."" 75 '"C c 'Vi ~ 'c ~ ~ c c 2) ~ "0 ro ~ 0 != -o E n:'" ~ 0 -e -o 0 3" 0 >" c ~ -o ;: ,~" 0 ro C c; ~ o rc Z u " "~ "E ~ " 0 .~ ~ t I " 0 ~ "c E ro "C '" -'= c, «'" '0 e eo ~ ~ ~ C " 0 C ~ -c 0 ~ ~ a " ro ro " '"ro ';:; ~ U ro ~ '0 ~" ~ 'c OJ ,£2 c 0 U" ~ eo U OJ 0 C 0 ~ ~ 2 ~ '= ro 0 ~ "E ~ro ~ro 'iii f- « E U 0 '" U '" Comment Letter No.1
STATE OF GALll'ORNIA GOVEPJ~OR'SOFFICE C!fPLANNING AND RESMRCH
KllNAL1J:X EDMUND G. aROWN ,JR. DIRl',t;rOR GOVEltl SubJect: Target Retail Shopping Center Project SCH#: 2010121011 Dear Hadar Pl.tkin: The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the enclosed Document Details Report please note thai the 'Clearinghouse has listed the state agencies tbat reviewed your document. The review period closed on March 2, 2012, and the comments from the responding agency (ies) is (are) enclosed. If this comment package is notiu order, please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly. Please note that Section 21104{c) of the California Public Resources Codc states that: "A responsible or other public agency shall only lllake substantive comments regarding those activities involved in a project which' are within an area of expertise of the agencyor which are 1 required to be carried out or approved by the agency. Those comments shall be supported by specific documentation." These comments are forwarded for use in preparing your final environmental document Should you need more information or clarification of the enclosed comments, we recommend that you contact the commenting agency directly. This, letter aCknoWled$esthat )'OU have complied withthe State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact the State Clearinghouse al(916) 445-0613 if you have any questions regarding the environmental review process. Slll~~ sc",8'l: . , Director~State Clearinghouse Enclosures cc: Resources Agency 140DlOt\) Street p.o, Box 3044 Sacramento,California 95S\2·3044 (916) 445-0613 FAX(916) 323·3018 www.opr.cagov DOCllmellt Details Report State Clearinghouse Data Base SCH# 2010121011 Project Title Target Retail Shopping Center Project Lead Agency Los Angeles. City of Type EIR Draft EIR Oescriptlon The project consists of the demolition of the eXisting 59,561 s.f, of single-story buildings, electrical SUbstation, and surface parKing 10\for the construction of a proposed retail shopping center of 194,749 gross s.f. The project conslsts of an approximately 163,862 s.t. Target store along with 30,887 s.t of other smaller retail and food uses fronting Sunset Soulevard and Western Avenue, in a three level retail center. The project site encompasses approximately 3.88 acres on a single parcel of land, with a net area of 3.69 acres after street dedications. Lead Agency Contact Name Hadar Plafi Project Location County los Angeles City Los Angeles, City of R"I1ion L.et/Long Cross Su....ls SUnset Blvd. and Western Ave. Parcel No, Township' Range Section Bass Proximity. to: Highways Hwy 101 . Airports RailWayS WatelWl1Ys SchOols La"ci Use Vacant CommerciallCZ-lIHighway Oriented Commercial Project Issues AestheticlVisual; Air Quality; G Revi"wlnS] Resources Agency: Department of fish and Game, Region 5; Office of Historic Preservation; Agencies Department of Parks and Recreation; Department of WaW Resources; Resources, Recycling ano Recovery; Office of Emergency Management Agency, California; Caltran•• DistrJct7; Regional Waler Quality Control Board, Region 4; Department of Toxic SUDslances Control: NatiVe American Heritage Commission Date Received 0111812012 Start of RfI'Ifew 01/18/2012 End of Review 03102/2012 Note: Blanks in data fields resntr from lnsufflclent information provided by lead aqency. Cityof LosAngeles June2012 Comment Letter No.1 State of California Governor's Office of Planning and Research State Clearinghouse and Planning Unit Scott Morgan, Director, State Clearinghouse 1400 io" Street P.O. Box 3044 Sacramento, CA 95812-3044 Response to Comment 1-1 This comment is a standard statement from the State Clearinghouse of Planning and Research acknowledging the Draft EIRwas sent to state agencies for review and that the Draft EIRis in compliance with the State Clearinghouse review requirements for draft environmental documents. Commenter does not state any other specific concern or question regarding the sufficiency of the Draft EIR. No further response is required. Target at Sunset and Western III. Responses to Comments Page111-6 Comment Letter No.2 NATIVE AMERICAN HERITAGE COMMISSION \~ 915 CAPITO'- MALL, ROOM 364 SACRAMENTO, CA 95814 ::\~ 7v• (916) &53-6251 {\q\ "Fax (916) 657~5a9D 'J :-:":~~:~:'1?~~i"-"Q~ \(; REeEl VED I January 23, 2012 JAN s 2012 I Hadar Plafkin. Project Coordinator STATECLEARINGH~ City of Los Angeles City PI31nll'1lingDep31rtmell'llt - 200 North Spring Street, Room 750 Los Angeles, CA 90012 R~;SCH#2b1 0121 011 CEQANotic:~ ofCompletitm;draft tnvimhrllentallmpact Rebort (DEIR) (ENV-2008-142HIR) for the "TargetRetail·Shopping Center Project;"located on Sunset Boulevard.in the Cttyof Los Angeles; Los Angeles County. California Dear Hadar Plafkiin: The Native American Heritage Commission (NAHC) is the State of California 'Trustee Ag~ncy' for the protection and preservation of Native American cultural resources pursuant to California Public Resources Code §21070 and affirmed by the Third Appellate Court in the case of EPIC v. Johnson (1985: 170 Cal App, 3,d 604). The court held that the NAHC has jurisdiction and special expertise, as a state ag~nGy, over affect~d Native American resources, impacted by proposed proj~cts including archaeoloqical, places of religious significance to Nativ~ Americans and burial sites. The NAHC wishes to comment on the proposed project This letter includes state and federal statutes relating to Native American historic properties of r~ligious and cultural Significance to American Indian tribes and interested Native American individuals as 'consulting parties' under both state and federal law. State law also addresses the freedom of Native American Religious Expression In Public Resources Code 1 §5097.9. The Califbrhiai::nviron.r1wntal Duality Act (CEQA -GA Public ResourcesCode 21 OOb-21177, amendments .effectiv~ 3/181201 0) requires that any Project that causes.a substantial adverse change)1) the Significance of an historical resource. that includes archaeologlcal resources, is a 'significant effect' requiring the preparation of an Environmental Impact Report (EIR) perthe CEQA Guidelines defines a significant impact on the environment as 'a substanti al.or potentially substantial, adverse change in any of physical conditions within an area affected by the proposed project, including ... objects of historic or aesthetic significanre." In order to comply with this provision, the lead agency is required to assess whether the project will have an. adverse impact on these resources within the 'area. of potential effect (APE). and if sa. to mitigate that effect. The NAHC Sacred Lands FiI~ (SLF) search resulted as follows: Native American cultural resources were not identified within the project area identified. This area is known to the NAHC to be very culturally sensitive. Also. the absence of archaeoloplcal resources does notpreciuoe their existence .. California Public Resources Code §§5097.94 (a) and 5097,96 authorize the NAHC to establish a Sacred Land Inventory to record Native American sacred 2 sites and burial sites. These records are exempt from the provlsions of the California Public Records Act pursuant to. California Government Code §6254 (fl. The purpose of this code is to protect such sites from vandalism. theft and destruction. The NAHC "Sacr~d Sites: as defined by the Native American Heritage Commission and the California Leqislature in California Public Resources Code §§5097,94(a) and 50$7.96. Items intheNAHc. S EG!rlyconsultatlon with Native American trtbes.ln your area is thebest Way to E!vold :2 cont. unantlcipateddiscoveries ofculturE!IIt3~ources. or burial sites once. E!project js uncerway, ClllturE!IIYE!ffiJiated tribes and individuals may hG!veknOWled!je of the religious and .CtJltufE!1 signific!\rice oftht3. histQficprope!1lesinlhe project area (e.g. APE) .. We strong1yprgethatjlotJ m.akecontactwith the list (If Native American Contacts on the Jist DfNative American contacts, to see) your proposed project mighUmpactNativeAmerican cultural resourcesandto obtain t!leir f€!commendalionsGoncerrlingthe propo~ecl project. Special reference is made 10 the TriPal COP$ultationrequirements ofthe. California 20d6 Sella\eBiU1059: enabling.legislatipn.lojhe federalElJergy Policy Act of 2005 (P.~.109·5~},mandates consuttationwith Native American tribes (both federally recognized and non federally recognized) where electrically transmission Iines8re proposed. This is COdified in the California Public Resources Code,Chapter 4.3 and §2!5330 to Division 15. Fl)rtl)ermore, pursuant to CA Public Resources Code. § 5097.95, the.NAHC requests that tne NatiVe American consuttinqparties be provided pertinentproject information. Consultation with Native American communities is also a matter of environmental. justice as defined by.C;;Ilifornia Government code §6!5040.12(e) ...Pursuant to .CA Public Resources Code 3 ~5097,95, theNAHC requests that pertinent projectinforrnationbe provided consulting .Ifibill parties pursuant to CA Public. Resources Gode~!5097, 95. The NAHC recommends ~Vo!danCe as.d\i!finedbY CEQA Guidelines §15370(a) to pursuing a project the;twol.ll.d damaqeordestroy NatlveAmerican cultural resources and Section 2183.2 that requires documentation, data recoveryof cqljural resources. Consultation With tribes and interested Native American consulting parties, on the NAHC lisl,ifthe project is underfederal jurisdiction, should be conducted in compliance with the requirements offederalNI;:PA;;IndSectioQ 106 and 4(1) of federal NHPA (1p U.S.C, 470 at seq), $6CFR part BOO.3 (1)(2) & .5,.the Presldent'sOounoll on Environmental Quality (C8Q,42 U,S,CA371 etseq. and NAGPRA (25 U.SC. 3001-3013) as-appropriate. The .1992 SElcretary otihe Interiors Standards for the. Treatment of Historic Properties WElterevised .50 that they could.be applied to all historic resource types included in the National Register of Histone 4 Places and including cultural landscapes. Also, federal Executive Orders Nos. 11593 (preservation of cultwal environment), 13175 (coordination .& consultation) and 13007 (Sacred Sites) are helpful, SUpportive guides forSection .106collSultation, The aforementioned Secretary of the Interior's Standards include recommendations for all 'lead agencies' to consider the historic context of proposed projects and to "research" the cultural landscape that might include the 'area of potential effect.' . Confidentiality of "historic properties of religious and cultural significance" should also be considered as protected by California Government Code §6254( r) and may also be protected under Section 304 of he NHPA or at the Secretary of the Interior discretion if no! eligible for 5 listing on the National Register of Historic Places. The Secretary may also be advised by the federal Indian Religious Freedom Act (ct 42 U,S.C., 1996) in issuing a decision on whether or not to disclose items of religious and/or cultural sighificance identified in or near the APEs and posSibility threatened by proposed project activity. Furthermore, Public Resources Code Section 5097.98, California Government Code §27491 and Health & Safety Code Section 7050.5 provide for provisions for accidentally l 6 discovered archeological resources during construction and mandate the processes to be 6 cont. ""~" rntheevent of" "",'!",.I dl,,,,,,. of "Y human remains".~roj'" I,,,,," ""~ I than a 'dedicated cemetery'. To be effective, consultation on specific projects must be the result of an ongoing relationship between Native American tribes and lead agencies~ project proponents and their contractors, in the opinion of the NAHC. Regarding triba I consultation, a relationship built 7 around regular meetings and informal involvement with local tribes will lead to more qualitative consultation tribal input on specific projects. IfJllU-l1ave any questions about this response to your request, please do not hesitate to conta¢1'he ~916) 653.6~1 Attachment: Native American Contact List Calitorr!ia Native American Contacts Los Angeles County January 23, 2012 LA City/County Native American Indian Comm Gabrielino Tongva Nation Ron Andrade, Director Sam Dunlap, Chairperson 3175 West 6th St, Rm. 403 p,o, Box 8690S Gabrieliho Tonqva Los Angeles, GA 90020 Los Angeles, CA 90086 [email protected] [email protected] (213) 351-5324 (213) 386-3995 FAX (909) 262-9351 - cell Ti'At Society/Inter-Tribal Council of Pimu Gabrielino Tongva Indians of Califomia Tribal Council Clndi M. Alvitre, Chalrwomari-Manlsar Robert F. Dorame, Tribal Chair/Cultural Resources 3098 Mace Avenue, Aapt. D Gabrielino P,O. Box 490 Gabrielino Tongva Costa Mesa" CA :92626 Bellflower ,CA 90707 [email protected] [email protected] (714) 504-2468 Cell 562-761-6417 - voice 562-761-6417- fax Tongva Ancestral Territorial Tribal Nation Gabriellno-Tongva Tribe John Tommy Rosas, Tribal Admin. Bernie Acuna Private Address Gabrlelino Tongva 1875 Century Pk East #1500 Gabrielino , Los Angeles, CA 90067 [email protected] (619) 294-6660-work 310-570-6567 (310) 428-5690 - cell (310) 587-0170 - FAX [email protected] Gabrleleno/Tonova San Gabriel Band of Mission Gabrieliho-Tongva Tribe Anthony Morales, Chairperson Linda Candelaria, Chairwoman PO Box 693 Gabrlellno Tongva 1875 Century ParK East, Suite 1500 San Gabriel , CA 91778 Los Angeles, CA 90067 Gabrielino [email protected] [email protected] (626) 286-1632 626-676-1184- cell (626,286-1758 - Home (310) 587-0170 - FAX (626) 286-1262 -FAX 760-904-6533-home This list is current only as of the date of this document. Distribution osttas net ecee not relieve any person of the statutory responsibility as defined in Section 7050.5 of the Health and Safety Code, Section.5097.94 of the Public Resources Code 'and Section 5097.98 of the Public Resources Code. This list is applicable for contacting local Native Amerlcarrs with regard to cultural resources for the proposed SCH#2010091041i CEQANotice of Completion; draft I::nvironmeotaJ Impact Report (DESIR) for tte Al Larscn Boat ancp tmprovement Project; ISCH#2010121011; CEQA Notice of Completion;' draftEnvlr6hmenta! Impact Rep6rt(DEfR) for the target Retail Shopping center project: located California Native American contacts Los Angeles County January 23,2012 Gabrieleno Band of Mission Indians Andrew Salas, Chairperson p ,0, Box 393 Gabirelino Covina ,CA 91723 (626) 926-4131 gabrielenolndians@yai1oo, com This Hatls current only as of the date of this document. Distribution of this list does not relieveany person of the statutory responslburtyas definedih Section 7050.5 of the Health and Safety Code, Section 5097.94 of the Public Resources COQe and Section 5097.98 of the PUblic Resources Code. This list is applicable for contacting locel Nettve Americans with regard to cultural resources for the proposed SCH#201,0091041; CEQA NotJ"ceof Completion; draft Environmental impact Report {DEIR)for the AI LarSOIl Boat Shop 'Improvement Project; lSCH#20101.21011; CEQA Notice of Completion; crattenvjrcnmentat Impact Report (DEIR) for the Target Retail Sho'pping Center Project; located Cityof LosAngeles June2012 Comment Letter No.2 Native American Heritage Commission DaveSingleton, Program Analyst 915 Capitol Mall, Room 364 Sacramento, CA 95814 Responseto Comment 2-1 The commenter reiterates the CEQAGuidelines in relation to significant cultural resources, and states that the LeadAgency is required to assesswhether the project will have potential significant impacts on cultural resources. Regardingproject impacts related to cultural resources, Section IV.A, Impacts Found to be LessThan,Significant, of the Draft EIRincludes an analysis of project impacts related to cultural resources, including historical, archaeological, and paleontological resources. As discussed, no historical resources are located on or in proximity to the project site. Additionally, a review of the City of Los Angeles Department of City Planning, Environmental and Public Facilities Maps: Prehistoric and Historic Archaeological Sites and Survey Areas and Vertebrate Paleontological Resources in the City of Los Angeles showed that the project site is not known to contain any known significant archaeological or paleontological resources. Furthermore, through compliance with mitigation measures identified in the section, project impacts related to potential unknown resources that could be discovered during construction of the project, which as proposed does not include deep excavations, would be less than significant. Responseto Comment 2-2 The commenter states that the Native American Heritage Commission performed a Sacred Lands File (SLF)search and did not identify any Native American Cultural resources within the project's area of potential effect (APE), Furthermore, the project as proposed does not include deep excavations that would increase the potential to encounter archaeological resources, However, in the event that cultural resources are identified, Section IV.A, Impacts Found to be Less Than Significant, of the Draft EIR contains mitigation measures which would address the proper handling of such resources, Additionally, the listed Native American tribes have been added to the project mailing list and will be notified of availability of the Final EIRand future project hearings. Responseto Comment 2-3 The commenter states that pursuant to CA Public ResourcesCode § 5097,95, the NAHCrequests that the Native American consulting parties be provided pertinent project information, As discussed in Responseto Comment 2-2, the listed Native American tribes have been added to the project mailing list and will be notified of availability of the Final EIRand future project hearings, The comment does not state any other specific concern or question regarding the sufficiency of the Draft EIRin identifying and analyzing the environmental impacts of the project and ways to reduce or avoid these impacts, This comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Responseto C:Qmment2-4 The commenter reiterates the guidelines for a project under federal jurisdiction and the guidelines for CEQAGuidelines in relation to significant cultural resources. The proposed project does not include any Target at Sunset and Western III. Responses to Comments Page111·12 Cityof LosAngeles June2012 federal participation, is not under federal jurisdiction, and is not subject to NEPA. See Responseto Comments 2-1 and 2-2. Re~onse to Comment 2-5 This comment includes information about the confidentiality of a record search of the NAHCSacred Lands Inventory, but the comment does not state a specific concern or question regarding the sufficiency of the Draft EIRin identifying and analyzing the environmental impacts of the project and ways to reduce or avoid these impacts. However, the comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Responseto Comment 2-6 This comment refers to requirements of various California Codes and regulations related to the accidental discovery of human remains. Regarding encountering human remains, Section IV.A, Impacts Found to be LessThan Significant, of the Draft EIRincludes an analysis of project impacts related to the potential to disturb human remains and the statutory requirements for handling such remains if discovered. Furthermore, through compliance with the statutory requirements in this section, project impacts related to potential unknown resources that could be discovered during construction of the project would be lessthan significant. Responseto Comment 2-",- The commenter states that there should be an ongoing relationship between the NAHCand the project proponents and their contractors. The listed Native American tribes have been added to the project mailing list and will be notified of availability of the Final EIRand future project hearings. The comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Target at Sunset and Western Ill. Responses to Comments Page111-13 Comment Letter No.3 Department of Toxic Substances Control Deborah 0, Raphael, Director fI/$tfhtFWRqi$rlqt1t!? 9211 Oakdale Avenue EdrrlundG.BroWnJr, SeC:fetatyfor Governor Env.ironmental Protection Chatsworth, California 91311 iR IE CE HI IE0 CITY OF LOS ANGELES MAR 13 20ll March 2012 ENVIROI\iMEtlTAl IJI\!IT Mr. Hadar Plafkin City of Los Angeles Planning Department 200 N, Spring Street, Room 750 Los Angeles, California 90012 NOtiCE OF COMPLETION OF DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE TARGET RETAIL SHOPPING CENTER PROJECT AT SUNSET AND WESTERN, SCH NO, 201012101 'I Dear Mr. Plafkin: The Department of Toxic Substances Control (DTSC) has received your Notice of Completion of draft Environmental Impact Report (EIR) for the project mentioned above, 1 Based on the review of the document, DTSC comments are as follows: Based on the review of the document, DTSC comments are as follows: 1, The draft EIR(>tates that identified historic$ion$nd off-site land uses, such as formerclothinqcteaners: paint house and laboratory used forfilm cJeveloping, printing, polishing, cUtjing,Cind drying; oil house; gasoline stations: and automobilerepair facllities have the potential to significantly impacttre proposed 2 project site. IUs also noted that a,Phase l-Environmental Site Assessmentwas prepared for the Site" Based on the foregoing information, DTSC recommends additional environmental site investigation to evaluate whether condition at the Site pose a threat to human health and/or the environment. 2. (lJo~~~r~,~~h~,~~jl~n~~~t:~,.~~~Gf~d:~~~~~~~r~i~~~~~~~,Nu,S~~:~~~~~,~.~,~i~~i~erJa3 oversee hazardous waste cleanups, Proper investigation and/or remedial actions should be conducted at the Site prior to project implementation, 3, If during implementation of the project, soll contamination ,issuspected, construction in the area should slop, and appropriate health and safety l 4 procedures should be implemented If it is determined that contaminated soils Mr. Hadar Plafkin March 5, 2012 Page 2 4 cont. ,,"". the EIR",",M Ideo"y how any ''''''re' "'"bg,tion ,ndlo, remediation ..1 be conducted, and which government agency will provide regulatory oversight. DTSC provides guidance for Preliminary Endangerment Assessment preparation and cleanup oversight through the Voluntary Cleanup Program (VCP), For additional information on the VCP please visit DTSC's web site at www.dtsc.ca.gov. 5 Ifyou would like to meet and discuss this matter further, please contact me at (818) 717-6550 Sincerely, ~r~~ AIU~61Jr.~Valmidiano Project Manager Brownfields and Environmental Restoration Program - Chatsworth Office cc: Governor's Office of Plimning and Research State ClearingllOuse P. O. Box 3044 Sacramento, California 95812-3044 CEQA Tracking Center Office of Planning and Environmental Analysis Department of Toxic Substances Control 1001 "I" Street P.O. Box 806 Sacramento, California 95812-0806 of los June 2012 Comment letter No.3 State of California Department of Toxic Substances Control Alberto T. Valmidiano, Project Manager 9211 Oakdale Avenue Chatsworth, CA 91311 Response to Comment 3-1 This comment is an introductory statement and is acknowledged for the record. Responses to issues raised are provided below. Response to Comment 3-2 The commenter states the Draft EIR identifies on and off-site land uses that have the potential to Significantly impact the project site and recommends additional environmental site investigation to evaluate whether the condition of the project site poses a threat to human health and/or the environment. The commenter is referred to Section IV.E, Hazards & Hazardous Materials, of the Draft EIR that includes an analysis of project impacts related to on- and off-site land uses that have the potential to significantly impact the project site. The Draft EIR noted that a Phase I Environmental Site Assessment (ESA) was prepared for the project site (see Appendix IV.E-l to the Draft EIR). In addition, a Limited Phase II ESA has also been completed by Kleinfelder West, lnc., which has been included in the Final EIR (see Appendix A to the Final EIR). The Phase II ESA included soil and groundwater sampling as well as laboratory analysis and concluded that there were no significant impacts from former site operations. Specifically, the Phase II ESA investigated the presence and concentrations of TPH-CCID, VOCs, and CCRTitle 22 metals. The Phase II ESA results indicate that significant levels of contaminants are not expected to be encountered on the site during construction. Furthermore, implementation of Mitigation Measure IV.E-1 on page IV.E-13 of the Draft EIR requires specific action if excavation or grading activity on the project site reveals discolored soil or the equipment operator detects odors or fumes emanating from the soil and would address these potential conditions to ensure that conditions of contamination on the project site would not expose workers and visitors to the site to ,adverse conditions related to potential site contamination. With this mitigation and the addition of the Phase II EASto the Final EIR, the work plan and remediation referenced by DTSCwould not be warranted and no additional analysis or mitigation is necessary. Response to Comment 3-3 The commenter states an environmental investigation and/or remediation should be conducted under a Work Plan, which is approved by a regulatory agency. If required in the event that conditions requiring investigation and/or remediation are discovered on the project Site, this work would be accomplished under the oversight of the appropriate regulatory agency as set forth in Mitigation Measure IV.E-l. See Response to Comment 3-2. Target at Sunset and Western 111.Responses to Comments Page 111-16 of los June2012 Response to Comment 3-4 The commenter states that if soil contamination is suspected during project construction the appropriate health and safety procedures should be implemented and construction in the area should stop. See Response to Comment 3-2. Response to Comment 3-5 The commenter states that the Department of Toxic Substances Control (DTSC)provides guidance for Preliminary Endangerment Assessment preparation and cleanup oversight through the Voluntary Cleanup Program (VCP). This comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Target at Sunset and Western Ill. Responses to Comments Page111-17 Comment Letter No.4 R IEC EIV IE10 February 24, 2012 CITY OF LOS ANGELES Hadar Plafkin 01 Project Coordinator ENVIRONME~11N, Room 750, City Hill UNIT Department of City Planning 200 North Spring Street IIl8 Angeles, CA 90012 Re: Target Retail Shopping CerlterJ!toleCI Dear Mr. Plalkin: 111C Los Angeles County Metropolitan Transportation Authority (LACMTA) is in receipt of the Draft Environmental Impact Report (DEIR) for the Target Retail 1 Shopping Project. This letter conveys recommendations from MTA concerning a number ofissues in relation to the proposed project. In accordance with the State of California Congestion Management Program{CMP) statute, the Traffic Impact. Analysis (TIA) contained in theTargetRetail Shopping Center Project Draft EIRid",milles CMP/\rterial Monitoring Station #61 (Westem Ave and Santa Monim Blvd} which would be significantly impacted by the proposed project.. the CM.PTIAGuideIinespublished in the "2010 Congestion Management Program for Los Angeles County", Appendix D, section D.9, the ElR should include the following in relation to CMP Arterial Monitoring Station #61: 1) Cdteria for Dett;!m1inin,f§fL$ignifkant ImpQcL For purposes oftheCMl', a significant impact OCCUIS when the proposed project increases ttaHk demand. on a CMl' facilityhy2% ofcap.acity(V{C 2 0.02), catlsingLOS F (VIC> 1.00); if the facility is already at LOSF,. a significant impact occurs when the proposed project increases traffic demand on a CMP filCility by 2% of capacity 2 (VIC 2 0.02). The lead agency' may apply more stringent criteria if desired, 2} fdE?11.tificationof }l11.Egation. Once the project has been determined to cause a significant impact, the lead agency must investigate measures which will mitigate the impact of the project. Mitigation measures proposed must dearly indicate the following;'. [J Cost estimates, indicating fair share costs to mitigate the impact of the proposed project If the improvements from a proposed mitigation measure will. exceed the il11p,KI of the project, the TJA must indicate the proportion of total mitigation costs which is attributable to the project This fulfills the statutory requirement to exclude the costs of mitigating inter-regional trips: TIIR Implernentation responsibilities. the agency responsible implementing.mitigation is not the lead agency. the TIA must document consultation with the implementing agency regarding project impacts, mitigation feasibility and responsibility. selection of mitigation measures remains at the discretion agency, The TIA must, however, provide asummary of impacts and mitigation measures. Once a mitigation program is-selected-the jurlsdi.cti.on self-monitors implementation through the mitigation monitoring 2 cont. requrremenrs contained in CEQ A. 3) J2Il2KcLcontlil;>'jJtjm~ to the Plall) led HegionallmplClvemcllt';tlfthe concludes thatproject impacts will be mitigated. by anticipatedregional rransportation improvements, such as rail transit or high occupancy vehicle facilities, the TlA. must document: Any project contribution to the improvement, and The m'c,,1'15 by which trips ge:nel'ated the facility, Whil<; theDralJ: Inn identifies transportation demand management (TDM) policies and programs that would be incorporatedinto theproposed project, eMF TDM Guidelines require that projects which include a non-residential development 3 component exceeding IOO,OOO square feet incorporate a specific set ofTDM measures into project design. These 'I'Dlvirequirements arc detailed in Appendix C and summarized in Exhibit 4-1 in the 7,010 eMP. Although the proposed project is not expected to result in any long-term impacts on transit: Several transit corridors with Metro bus service could be impacted by the project. 4 Metro Bus Operations Control Special Events Coordinator should be contacted at 213-922-4632. regarding construction activities that may impact Metro bus lines, Other Municipal Bus Service Operators may also be impacted and there fine should be included in construction outreach efforts. ~"':,fJ;1""",?:::l,t:;;,ll;~!~.e:,ccmmentsplease contact meat 11j,'j~ 5 Sincerely, Scott Hartwell CEQA Review Coordinator, Long Range Planning of los June2012 Comment Letter No.4 LosAngelesCounty Metropolitan Transportation Authority Scott Hartwell, CEQAReviewCoordinator, long RangePlanning One Gateway Plaza los Angeles,CA90012-2952 Responseto Comment 4-1 This comment is an introductory statement and is acknowledged for the record. Responsesto issues raised are provided below. Re§Ponseto Comment 4-2 The commenter states, per the Congestion Management Program (CMP),the Draft EIRshould include additional discussion of the CMP Traffic Impact Analysis (TIA) Guidelines with respect to criteria for determining significant impact, identification of measures to mitigate the impact of the project and project contribution to planned regional improvements with regard to Arterial Monitoring Station #61 (Western Avenue and Santa Monica Boulevard), which would be significantly impacted by the proposed project. The CMP impact criteria are included in the Draft EIR(page IV.C-52). As noted in the Draft EIR (page IV.C-51),the CMP intersection of Western Avenue and Santa Monica Boulevard was analyzed in the proposed project's traffic analysis. As shown in Tables IV.C-8 and IV.C-ll of the Draft EIR,the proposed project would increase traffic demand by 2% under lOS F conditions and would thus constitute a significant impact under the CMP. Clarifications have been added in the Final EIRto more clearly indicate that the project's significant impact at Western Avenue/Santa Monica Boulevard under Future Cumulative Traffic Conditions (2015), as identified in the Draft EIR,would also be a significant impact per the criteria of the CMP. Although the CMP TIA Guidelines anticipate mitigation for significantly impacted CMP facilities, no feasible mitigation measures are available to address the significant impact at Western Avenue and Santa Monica Boulevard and the impact at this location was identified as significant and unavoidable (Draft EIR, page IV.C-58). A mitigation measure to widen Santa Monica Boulevard east of Western Avenue in conjunction with another project in the area was considered and rejected by lADOT due to secondary adverseimpacts on sidewalks in the area. Widening the streets at this location would require permanently narrowing the public sidewalks in the right-of-way. Policy lU.3.1 of the Hollywood Community Plan requires a minimum sidewalk width of 15 feet to support the goal of making streets walkable and supports the adoption of street standards that would preserve sidewalks that are 15 feet or wider and widening sidewalks that are less than 15 feet wide. The existing sidewalk width at this location is 10 feet. Thus, under the Community Plan policy, this sidewalk should be widened. Any widening of the streets at this location would narrow the sidewalk width further. As such, any mitigation to widen the streets at this intersection would be infeasible because it would be inconsistent with the City's General Plan. Thus, there exist no mitigation measureswhich would require a fair share contribution under the CMPTIA. The TIA does not conclude that project impacts will be mitigated by anticipated regional transportation improvements. No regional transportation improvements to which the project may contribute have been identified at this location. As noted throughout the Draft EIR,the project site is served by the existing regional rail transit system. Target at Sunset and Western III. Responses to Comments Page111-21 of los June2012 Responseto Comment 4-3 The commenter has requested, per the CMP transportation demand management (TDM) Guidelines, that the project incorporate a specific set of TDM measures into the project design. In addition to measures listed in the Draft EIR,the measures listed in Appendix Cof the 2010 CMP have been included as mitigation measures in the Final EIR. Responseto Comment 4-4 The commenter has requested the Metro Bus Operations Control Special Events Coordinator should be contacted regarding construction activities that may impact Metro bus lines. The proposed project is not expected to result in significant permanent impacts to bus lines or transit operation. However, the bus stop that is presently located on the west side of Western Avenue south of Sunset Boulevard will need to be temporarily relocated during project construction. Although relocating this bus stop will not result in a significant impact, requiring collaboration with the Metro Bus Operations Control Special Events Coordinator as a mitigation measure would further ensure that impacts remain less than significant. This additional measure will be added as a requirement of the Construction Traffic Control Planin the Final EIR. Res-ponseto Comment 4-5 This comment contains a concluding remark and contact information. The comment is acknowledged for the record. Target at Sunset and Western Ill. Responses to Comments Page1I1~22 reo Comment Letter No.5 DATE: February 13. 2012 FrEe erl.l E D Hadar Plafkin, Project Coordinator CITY OF LOS IiNGELES Environmental Review Section Department of City Planning FROM: All Poosti, Acting Division M"""'-I/.,rl Wastewater Engineering ""AIVI(CP~ LJIVISICm Bureau of Sanitation SUB,IECT: This is in response to your January 'j 9, 20 t21etter requesting a review of your proposed retail project construct a Target Shopping Center. The Bureau of Sanitation has 1 conducted a preliminary evaluation of the potential impacts -to the wastewater and storrnwater systems for the proposed project WASTEWATER REQUiREMENT The Bureau of Sanitation, Wastewater Engineering Services Division (WESO)is charged with the .task of evaluating the. local sewer conditions and to determine if available wastewater GQpacity 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. Projected Wastewater Discharges for the Proposed Project: z SEWER AVAILI\ElILITY The sewer infrastructure in the vicinity of the proposed project includes the existing 1O-inch 3 line On Sunset Blvd, existinq 8-inc!. line on S1.Andrews PI.. and existing 8-inc!. line on De Longpre Ave. The sewage from all existing lines feed into a 12-inch line on Kingsley Dr before discharging into a 33-inch West Hollywood interceptor Sewer (WHIS) line on Hadar Plan~iniDepartmentof City Planning Target FieIailShoppinn C811tet Project: - Dr3ftEH~ February 13, 2012 P~ge 2 Norrnandie Ave Figure 1 shows the details of the sewer system within thevicinity ofthe project. The current flow level (diD) in the 8"inch line cannot be determined at this time \,l,iithout additional gauging. The current approximateflow level (dID) and the design capacities at dIDo! 50% in the sewer system are as follows; 3 cont. Based on the estimated flows, it appears the sewer system might be able to accommodate the total flow for your proposed project Further detailed gauging andevaluation will be needed as part or 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 llnesto point in the sewer system with sufficient capacity, Minai approval for sewer capacity.and connection permit will be made at that time. Ultimately, this sewage flowwill be conveyed to theHyperion Treatment Plant, which has sufficient capacityforthe project If you have any questions, please call Kwasi Berko of my staff at (2,23) 342-1562, Attachments: Figure 1 Sewer Map cc: Kosta Kaports, BOS Daniel Hackney, BOS Rowena l.au, BOS File LOG8tiof1:'-Di'" Files\SCAR\CEQ/\ Reviel.'AFINAL CEOA Response L.TRs\Targ,';! Retail Shopping Center Project .-01'8ft EIH.dcc l Legel1d &. < 0.25 l r ti 0.25 - 050 t~ 0.50 ~0.75 A > 0.75 Discharge Route Outtatls -.-,-~-+ Secondary Lines ---- Primary Lines IProjHc1 Location l_,",.._ \ _.1..1 _ City of los Angeles June2012 Comment Letter No.5 City of LosAngeles,Bureau of Sanitation Wastewater Engineering Services Division Ali Poosti,Acting Division Manager !!!,~onse to Comment 5-1 This comment is an introductory statement and is acknowledged for the record. Responsesto issues raised are provided below. Responseto Comme_nt5-2 The commenter states that the Bureau of Sanitation Wastewater Engineering Services Division reviewed the potential wastewater and stormwater impacts associated with the project, and that this division is responsible for evaluating sewer conditions to determine future capacity and planning needs. The comment includes a table outlining projected wastewater discharges for the proposed project, which corresponds with the generation rates provided in the column labeled (SewageGeneration Rate [gpdJ) on Table IV.K.1-3on page IV.K.1-6of the Draft EIR. The EIRalso includes water efficiency requirement rates as agreed upon in coordination with LosAngeles Department of Water and Power (LADWP). The comment validates the information provided in the Draft EIR. No responseis necessary. Responseto Comment 5-3 The wmmenter describes the location and capacity of sewer infrastructure in the project vicinity and states that the infrastructure may be able to accommodate the project but that further gauging and evaluation may be needed. Gauging and evaluation should occur contemporaneously with project completion so that capacity is evaluated at the time the capacity is needed-when the project becomes operational. The Bureau of Sanitation states that final approval for capacity and connection will be made after gauging and any necessary upgrades are made. These comments are consistent with Mitigation Measures IV.K-l and IV.K-2 of the Draft EIR (page IV.K.1-7 and IV.K.l-S), which establish specific tests and performance standards that must be met prior to implementing the project. The comment validates the information provided in the Draft EIR. No response is necessary. Target at Sunset and Western III. Responses to Comments Page111-26 Clty cf LQSAfigele5fviail ~ Fwd: HSDNG support w/co;,diiiohs." Comment Letter NO.6 Fn,p,n",,, 1 Nu o 101 1 message Kevin Keller --"------Forwarded message ------..--- From: Steven Whiddon Dear Mr. Keller and Mr, Plafkin, The proposed Tarqet project, referenced above, is located within the boundaries of the Hollywood Studio District Neighborhood Council (HSDNC), The HSDNC is a certified City of Los Angeles Neighborhood Council with an elected Board of Governors, On Monday, February 13, 2013, the HSDNC Board of Governors, with a recommended 'vote to approve' from the HSDNC PLUM Committee, voted on a motion to support the Target project as t1ps:!/rneliLgoog!e ,cnrn!nl"H!?ui:::2&H,:!'5c57i33d78e&view=pL ,. 11 •11)/12 City of Los Ahge!es Mail - f\Vd:HSDNC support w/conditions. , . follows: HSDNC supports the proposed Target project application to construct a new Target Store, as described on the attached Exhibit A, but expressly subject to Target complying with the following conditions: 1. ThatTarget place.all of its parking in an underground parking structure, instead of the above ground structure Target has currently proposed. The Underground structure will have the effect of reducing the heigh! profile of the Target Building, and the HSDNCBoard feels thai this architectural feature will result in an important View corridor, to be maintained for the community. Furthermore, the HSDNCis concerned of the precedent above ground parking will set for future development within the HSDNC boundalies. 2. That Target participate in the Streetscape plan that was recently approved along Western Avenue. Steven Whiddon C. 323-600-4353 Kevin J. Keller, AICP Senior City Planner los Angeles Department of City Planning 200 N. Sprinq Street, Room 667 los Angeles, CA 90012 [email protected] 213.978.1211 HSDNC : Target support W CONDITIONS 2012.0213,pdf 2587K :tps:llmail.google;corn/mrlHi?I/i=2&ik::;5c5763d78e&vlew::::pt ... 21 CiTY OF LoS ANGELES HOLLYWOOD STUDIO DISTRICfNEIGHBORHOO!) OtFlCERS: COUNCil BOARD MEMBERS; CALIFORNIA Steven Whiddon Alex elfercv Kenneth Os.ttow Chair Andy Schwartz lli!;f! Vincent' Tom Meredith BiJllkie len" rcrcueeo VIce Chair Felipe Corrado !0anfly Rodriguez TBA Eh';)in Gonl"le~ NarlneChobanyan Treasurer fr\\lnkValenti r-Mhan·Ffelll.:h Jenny Weathernolb: J~nj\ifdrMoran Steven Whiddon Recordin3. secretary JenNy Weatherholt.. Thomas. Meredith MA1L:·J>.O. Box 85098 Juri Rip1rlS.~1j Los-Angeles, eli. 90012 ANTONiO R. VltLARA1GOSA PHONE: 323,46L0773 MAYOn February, 13, 1012 Kevin Keller Senior City Planner Department of City Planning City ofLos Angeles 200 N, Spring Street, #667 Los Angcles.California 90012 k£.y~n,k!;JJ!~r.rglJ1A9.H)~:.L~n~ Hadar Plafkin City Planner/EnvironmentalReview Coordinator Los Angeles Department ofCity Planning 200 North Spring Street, Room 750 Los Angeles, CA 90012 Fax: 213.978.1343 b.1d 8:>.])18fki nf7!lW[.:1' tV.J)JJ2. Herb J. Wesson, Jr. City Council President City of Los Angeles 200 North Spring Street, Room 430 Los CA 90012 Eric Garcetti Council Member, District 13 City of Los Angeles 200 North Spring Street, Room 470 Los Angeles, CA 90012 RE: Target Store 5Z20 Sunset Boulevard, Los Angeles, California 90028 Case No: APCC-200S-2703- SPE-COB-SPP-SPR Case No.ENV-2008-1421-ElR State Clearinghouse Number: 2010121011 Council District: 13 Dear 1\1.LKeller and Mr. Plafkin, proposed Target project, referenced above, is.located\rlithill- the 'boundaries of the HollywoodStudio District Neighborhood Council (HSDNe). The HSD,NC is a, certified City of Los Angeles Neighborhood Council with an elected Board of Governors, On 1 Monelay, February 13,2013, the HSnNC Board of Govemors.witha recommended 'vote to from the H.8DNC PLUM Committee, voted on a motion to support the Target as follows: HSI)NC supports the proposed Target prp]eci applicauon Store, described the attached Exhibit ~'L!~l!'j,r"g$IY.,5!!!>j~.J2L!J!.tg!2!: l , That Target place all of parking in an underground parking structure, instead. of the above 'ground structure' Targethascurrently proposed. The undergrouad structure, ~~:illhave ", " Qf reducingthe heightprofile of 2 Building, and the HSDNC Board feels that this architectural feature will result in all important vle\f corridor, to be maintained for the community. Furthermore, t!1eHSDNC is concerned of theprecedent above ground parking' will set for future development within the HSDNC boundaries. That:' Target, participate 'in the Streets cape''plan ihat reee'flily approvedxtong ] 3 Western Avenue. Tile HSDNC finds thaL the proposed. project positively affecr the surrounding neighborhood and overall Hollywood community as follows: e 111e'target project will increase newjobsin the HSDNC districtas well GS in the Cit)' of Los Angeles. e The project will resultin new construction a..nd project jobs over the. development period, and will result ina large number of permanent jobs, once the store is complete and open, 4 l! The Target project will brin? a large number, of shoppers into the H!)SNC district, and those shoppers will also support other businesses located within the HSDNC district u 11H::Target project vi/ill inject a large amount of capital into the Hollywood Community area" sln~::-_7v1~ ~ ,! -,\ /jjtevcn Whiddon Chairman Hollywood Studio District Neighborhood Council Board EXHIBIT A TARGET PROJECT DESCRIPTION Case No,ENV -20080 State Clearinghouse Number: 201012lO11 1421-ElR Council District: 13 CommunityPlan Area: Hollywood Project Address: 5520 West Sunset Boulevard, Los Angeles, CA 90()28 ProiectIYescription: The projectconsists of the demolition ofthe existing 59561 square. feet of single-story buildings, electrical.substation, and surface parking lot for the construction of a proposed retail shopping center of 194,749 gross square-feet. The project consists 01 ail approximately 163,862 square foot Target store along with 30,887 square.feet of other smaller retail and. food uses fronting' Sunset Boulevard and Western. Avenue, in a three level retail center. The project site encompasses approximately 3,88 acres on a single parcel of land, with a net area of 3,69 acres after street dedications, The first level of the proposed retail center would consist of individual retail spaces fronting on SunsetBo ulevard and Western Avenue, along wi th one level of pZlrkiiighi the interior of the site. Ingress to the parking area would be provided from a right- turn-in only driveway 011 Western Avenue and a two-way driveway on De Longpre Avenue. Vehicles exiting the facility would use either the De Longpre Avenue driveway Oraright-turn-out only driveway on SL Andrews Place. The second level of the center would provide additional parking spaces and would be accessed via a ramp located at thewestemside ofthe first level, A total of458 parking places would be provided in the first and second level parking areas, A loading dock containing up to.five truck bays would also be. provided on-the first level.with access provided from De Longpre Avenue. The third level ofthe proposed retail center would be primarily occupied by the retail Hoar ofthe proposed Target store, Access to the Target store would be through a pedestrian plaza and escalators located at the comer of Sunset Boulevard and Western Avenue or from elevators provided in various locations throughout the retail and parking areas, The retail center building would extend to a height approximately 65 feet above Sunset Boulevard, and approximately 75 teet above De Longpre A venue, with architectural and/or equipment elements that could extend to a: height approximately 78 feet above Sunset Boulevard, The project is located within the Hollywood Community Plan, the Hollywood Redevelopment Project, and the Vermont/WesternStation Neighborhood Area Plan (SNAP) Specific Plan, The SNAP restricts all Community Center uses to C4 uses as defined by the LAMC. The Project Applicant is requesting ministerial and discretionary approvals as part of the project, including but not limited to: Specific Plan Project Permit Compliance Review; Specific Plan Exceptions Approval; Site Plan Review Findings pursuant to LAMe Section 16,05-E; Zoning Administrator Approval of Conditional Use Permit for alcohol; demolition, grading, foundation, and building permits; health department and off-site permits; Board of Public Works Approval of Street Tree Removal; turd Haul Route Approval, pursuant to LAl"lC section 9i ,7006,7.4, REY.!JtW_LOCAl'IONS! The environmental impact report is available lor review at the Department of City Planning, 200 North Spring Street, Room 667, Los AngeJes,CA 901l!Z and other locations. i,Department of City Planning c 200 North Spring Street, Room 750 Los Angeles, CA 90012 2.Certtral Library - 630 West 5th Street Los Angeles, CA 90071 3..Francis Howard Goldwyn Hollywood- Regional Library "1623 North Ivar Avenue, Hollywood, CA 9002& 4. Will & Ariel Durant Library - 7140 West Sunset Boulevard, Los Angeles, CA 90046 5. John G Fremont Library - 6121 Melrose Averrue.Los Angeles, CA 9Q038 The Draft EJR may be purchased on CD.ROM for $750 per copy, To purchase a copy, contact Hadar Plafkin City Planner/Environmental, Review Coordinator LosAngeles Department of City Planning 200 North Spring Street, Room 750 Los Angeles, eA 900 12 Fax: 213.978.1343 lm~1{JLr)1~tf1\I.ni?Zitg£itY_:,Qn~ !Q.irc"I"finnJ~e ...iod: January 12, 2012 to March 05,2012 Cityof LOsAngeles June2012 Comment letter No.6 Hollywood Studio District Neighborhood Steven Whiddon, Chairman P.O.Box85098 los Angeles,CA90072 Responseto Comment 6-1 This comment is an introductory statement and is acknowledged for the record. Responsesto issues raised are provided below. Respon~eto Comment 6-2 The commenter states the project is supported by Hollywood Studio District Neighborhood (HSDNC), however there are concerns regarding the existing view corridor with the construction of the above ground parking structure. The comment states that HSDNCsupports the proposed project, but expressly subject to the condition that all parking be placed underground. Section VI, Alternatives, of the Draft EIRanalyzed three alternatives that would include one or more levels of underground parking (Alternative B, SNAP-Compliant Commercial (SNAP Commercial) Alternative; Alternative C, SNAP- Compliant Mixed Use (SNAPMixed Use) Alternative; and Alternative D, Reduced Project Alternative). The SNAP Commercial and SNAP Mixed Use Alternatives would include one level of underground parking while the Reduced Project Alternative would place both parking levels underground. Both the SNAPCommercial and ReducedProject Alternatives would comply with the SNAPheight limit of 35 feet for commercial projects. As indicated on pages VI-26 and VI-54, these Alternatives would reduce but not eliminate the significant and unavoidable impact of the proposed project regarding Aesthetics (view obstruction). View blockage impacts of these Alternatives would be lessthan the proposed project due to the reduced building height, but would have the potential to be greater than the existing building because of increased height over the existing structures. Therefore, impacts under these Alternatives with respect to views through the project site would be significant and unavoidable, although less than those associated with the proposed project. Furthermore, these Alternatives would have greater Significant and unavoidable noise (construction) impacts compared to the proposed project because of increased duration of construction required to construct the underground parking levels. The SNAP Mixed Use Alternative would be consistent with the SNAPheight limit of 75 feet for mixed-use projects and its view blockage impacts would be similar to the proposed project and significant and unavoidable (Draft EIR,page IV-40). Impacts would be significant and unavoidable. This comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Responseto Comment 6-3 The commenter further states that the support of the proposed project by HSDNCis contingent upon the project participating in the streetscape plan that was recently approved along Western Avenue. The Sunset Boulevard and Civic Center Urban Design Plan and its Guidelines establish certain standards to guide development within the Hollywood Civic Center Core and the length of Sunset Boulevard east of the 101 Freeway. The project site is located outside the boundaries of the Sunset Boulevard and Civic Center Urban Design Plan and is therefore not subject to the Streetscape Guidelines. As these Streetscape Guidelines focus primarily on Sunset Boulevard and vary from block to block, it is unclear which guidelines the commenter is requesting that the project comply with. A major goal of the Target at Sunset and Western III. Responses to Comments Page111-33 Cityof LosAngeles June 2012 Streetscape Guidelines is to make sidewalks safe and pleasant for pedestrians, The proposed project will meet this goal by providing wide sidewalks (minimum 15 feet in width), new street trees and street furniture, an outdoor plaza, and active retail uses along the ground floor. Along the proposed project's Western Avenue frontage, sidewalk widths devoted to public use vary in width from 15 to 20,67 feet, In addition, hardscape areas on private property leading to the retail uses provide additional width for public use, far exceeding even the proposed Western Avenue Streetscape Standard, Linear planters, shade trees, street trees, benches, shade overhangs and other amenities further enhance the pedestrian environment, The proposed half street roadway is 37 feet, which is consistent with the Planned Street Standards, Along the proposed project's Sunset Boulevard frontage, sidewalk width devoted to public use provides a minimum of 15 feet for public use, The half street right of way is 52 feet, plus an additional 3 feet of public sidewalk easement for a total of 55 feet, which is consistent with the Planned Street Standards, Furthermore, private Sidewalks along the retail storefronts offer additional widths varying up to 20 feet, Street trees and amenities such as bike racks, benches, and shade overhangs at the buildings serve to provide a pleasant, walkable environment for patrons visiting the center and the surrounding community. The outdoor plaza at the corner of Sunset and Western provides a continuation from the public space into the project, The plaza incorporates benches, raised planters, tables, umbrellas, seating, a transit kiosk and specialty lighting, serving to create a large community gathering space, The project is subject to the SNAP's Development Standards and Design Guidelines, a number of which pertain to streetscape. As set forth in Table IV,G-8 of the Draft EIR,the project complies with the SNAP's Development Standards and Guidelines that pertain to streets cape, including those with respect to Street Trees, Tree Well (overs, Street Bike Racks, Trash Receptacle, Public Benches, Pedestrian Entrances, and Pavement, The new Hollywood Community Plan Street Standards also encourage pedestrian activity by providing for wider sidewalks along both Western and Sunset Avenues, the project frontages: 1, The proposed planned dimension for Western Avenue along the project is 37 feet of half street and 15 feet of sidewalk for a total of 52 feet half street. 2, The proposed planned dimension for Sunset Boulevard from st. Andrews to Serrano is 40 feet of roadway and 15 feet of sidewalk, for a total of 55 feet half street, The project would be consistent with these new street standards by providing sidewalks along the two frontages of at least 15 feet through additional dedications and sidewalk easements as set forth above, Overall, the proposed project would be consistent with the applicable streetscape standards that have been adopted for Sunset Boulevard and Western Avenue, Response to Comment 6-4 The commenter states the project will positively affect the surrounding neighborhood and overall Hollywood community for specified reasons, This comment is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project, Target at Sunset and Western 111.Responses to Comments Page 111-34 Comment Letter No.7 N. March 5, 1 1 i and p3xtment ra'i t.s supposed to the communi proposed fo r . re are. our comments: or i qt nal plans r this reflected a of eighty (80) feet, opoosed bv community groups as j noi vi duo.. ' n"'fA ope r ,elU rns wi th in the height 4 (fou feet, maki it. bui 1di ng 'i n 2 East vwood area ') , on 1 1 ...... , "'aL.I,. , :::t " tof3 working with communi tv the community y spoke 2 cont. S1nee the SNAP nance. only t1'1i five for a included Owen Will of requires. local i wlli is exempted from. 3 developer continuously that the is bei n9 buH'c as" a oriented ""11,m -t- (TOO) it encourage as well of public . obvi SNAP Ordinance for s a offet"s local del ivery, to nl1rln:Y ng smi Hollywood surely proven that look area as undeserved si 1 and d receive the same and as r communi ,such west Hollywood or Los Angeles (The Beverly connection). 4 \"iestHo11 ywood a fai r1y ce TARGET with 1 of open space, whi c1'1 is corrt'iI1UOU51 y beinG improved and updated. The structure 0.1so has a subterranean parking rage, wt'd goes two "levels below gr'or.md. Pege z of 3 4 cont. 5 3 of 3 of Los June 2012 Comment letter No.7 Robert Blue and Ziggy Kruse 1001 N. Wilton Place, Apt. 1 Los Angeles, CA 90038 R.esponse to Comment 7-1 The comment is an introductory statement indicating that the commenters are submitting comments and objections on behalf of the Citizen's Coalition-Los Angeles (CC-LA). The comment is acknowledged for the record. Responses to issues raised are provided below. Response to Comment 7-2 The commenters state that the original plans for the project reflected a height of 80 feet and the Draft EIR contains an increase in height of four feet, which would make the proposed project the tallest bullding in the East Hollywood area, and states concerns about whether the developer has effectively worked with the community. The proposed project would extend to a height of approximately 61 feet, 6 inches above Sunset Boulevard, and approximately 74 feet, 4 inches above De Longpre Avenue, with architectural and/or equipment elements that could extend to a height of approximately 84 feet, 4 inches above Sunset Boulevard as measured above the lowest site grade, which is greater than the maximum height permitted for commercial-only projects. The proposed project building would be lower in height than the 12-story Metropolitan building located on Sunset Boulevard, approximately 0.35 miles west of the project site. However, the Draft EIR identifies that, when built, the proposed project building would be visually prominent in the immediate area of the project site, at least in the short term (Draft EIR, page IV.B.1-20). However, because the proposed project's location, height, scale and architectural features would be generally compatible with the existing and planned development of the area, the potential aesthetic impacts of the proposed project to the general visual character of the project area were judged to be less than significant (Draft EIR, page IV.B.1-22). The overall programmatic needs of the proposed project, providing neighborhood-serving multi-tenant retail along the Sunset Boulevard and Western Avenue street frontages, providing a plaza at grade level as well as the required pedestrian passageways, providing needed parking spaces, providing a large-scale retail store, and providing the needed articulation on the facades of the structure have necessitated a building that is taller than the height allowed by the Vermont/Western Specific Plan. To accommodate these project features, the Target retail store is being proposed on the third level. Along Sunset Boulevard, a majority of the top of the building parapet would extend to 61 feet, 6 inches above the sidewalk. Along De Longpre Avenue the top of the building parapet would extend to approximately 75 feet above the sidewalk. De longpre Avenue is approximately six feet lower than Sunset Boulevard; the additional six feet would not be evident to a person on Sunset Boulevard as the lowest grade occurs along De Longpre Avenue. The Target sales floor, located on the third level, is set back over 15 feet from the face of the building at the ground level, a setback which exceeds the Vermont/Western Specific Plan requirements of 10 feet. In addition, the setback of the sales floor is over 20 feet from the front property line. Thus, from the Sunset Boulevard street level view, the impact of the building height would be minimized. The Vermont/Western Specific Plan does allow for a maximum height of 75 feet for mixed-use projects and the requested height is therefore within the range of height that might be permitted, on the project site for a mixed-use project. Nevertheless, the proposed project necessitates the granting of a Specific Plan Exception to allow for the additional height. The commenter's opinion that the Specific Plan Exception Target at Sunset and Western Ill. Responses to Comments Page 111-38 of Los June2012 should not be granted is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Response to Comment 7-3 The commenter states that the project does not comply with the SNAPrequirement for local delivery to be provided by the developer. See Response to Comment 8-44. Response to Comment 7-4 The commenter asserts that the developer has treated the project area as a poor area that should not receive the same treatment and respect as other communities, such as West Hollywood, which has a fairly nice Target store with lots of open space and a subterranean parking garage. This comment offers an opinion about the developer's attitude toward the community, but does not address environmental impacts. The comment does reference the height of the proposed project. The Draft EIRevaluated an alternative to the proposed project (Alternative B, SNAPCommercial Alternative), that would include all components of the proposed project and would place parking underground in order to comply with the 35-foot height of the SNAPfor commercial-only projects. As discussed in the Draft EIR(page VI-33), this alternative would not meet project objectives related to pedestrian access to the project because the entrance to the ground floor retail uses would need to be located approximately six feet below the existing grade. A second feasible alternative that would include underground parking (Alternative D, Reduced Project Alternative) would not be able to accommodate the ground floor retail uses and would be inconsistent with project objectives in this regard. Re~(;!onseto Comment 7-~ The commenter urges the enforcement of the Vermont/Western SNAP on the applicant/developer so that a real Transit Oriented and Pedestrian Friendly project will be developed. This comment does not address an environmental concern, but is acknowledged for the record and will be considered by the City's decision makers in determining whether or not to approve the project. Target at Sunset and Western HI. Responses to Comments Page111·39 j Comment Letter No.8 I 1 IU£C IUVED March 4, 2012 ClIY OF IJ)S ANGELES MAR052012 VIA PERSONAL DELIVERY Doug Haines La Mirada Avenue Neighborhood Association P.O. Box 93596 Los Angeles, CA 90093·0596 Mr. Hadar Plafkin, Environmental Review Coordinator Los Angeles City Planning Department 200 N. Spring Street, Room 750 Los Angeles, CA 9OOl2 RE: Objections to the Draft Enviraumentallmpact Report fol' "Target Retail Shopping Center Project." ENV-2008-1421.EIR; located at 5520 Sunset Blvd., Hollywood. Dear Mr. Plafkin: I. INTRODUCl'IQN Iam writing this Jetter on behalf of the La Mirada Avenue Neighborhood Association of Hollywood. The La Mirada Avenue Neighborhood Association includes residents, business owners, and 1 property owners who live and work within the immediate vicinity of a proposed "Target" retail development at 5520 Sunset Blvd. in Hollywood. The members of our neighborhood association will be directly impacted by development and operation of the project, and by the extensive and significant zoning precedents that will be established if it is approved as requested by the applicant. With due respect, the La Mirada Avenue Neighborhood Association opposes the currently proposed project. Ifconstructed as-described ou·page.l-Jof the Draft EnvironmentalImpact Report ("DEIR"), "Proposed Project," the development'aexteuslve exceptions from the Vermont'Western Transit Oriented District Specific Plan ("SNAP") would allow the construction, useand maintenance of a structure more than 84feet in height in SNAP Sub Area "C" (J5-footheighflimit), with 194,749 sq. ft. of retail development and. two levels Of 225,286 sq. ft, of above-grade parking spaces totaling 458 stalls, The net lot area is 160,678 sq. ft. The primary component of the project would be a 163,862 sq. ft. Target retail store on the its third level, with 30,887 sq. ft. of unidentified retail at ground level (hereinafter the "Project"). The applicant is Target Corporation ("Applicallt"). 2 The Applicant's significant discretionary requests are extensive and. precedent setting. Not only is the Project as proposed inconsistent with the requirements and guidelines of the Vermont/Western Transit Oriented District Area Specific PIau, but if implemented the Project would cause significant and permanent adverse environmental impacts to the surrounding neighborhood that are largely glossed over in the DEIR's analysis. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 2 The Project as proposed is oversized, poorly conceived, inappropriate forits location and inconsistent withboth the Specific Plan. and proper land use and planning, The Project as proposed would further seta precedent in changes to this area's established SNAP limitations, which would likelysetin motion adomino effect where other property OWners seek similar entitlements to copy its Vastly increased, 3 height, massing, and boxy, uuarticulated design '. Futuredevelopment along this low-scale areaof east Hollywood could. therefore potentially follow the entitlement trail blazed by the proposed Project, !Jutting the carefully crafted restrictions of SNAP. T11isis a goal expressed previously at )Jllblic hearings in testimony by representatives of Council District 13, and is not merely the opinion ofthe letter writer; Furthermore, rather than being a factual document as required under the California Environmental QualityAct ("CEQA"), the Project's DElR is instead riddled with inaccuracies, ambiguities andomissions; goalsandpolicies of Los Angeles' applicable zoning regulations are cherry picked and blatautly self- serving; key iuformation is conspicuously absent from the required analysis; Wid comments raised in Ietters submitted in response to the Notice of Preparation are ignored. As such, the DElR is woefully remiss in its 4 directive to provide "adequacy, completeness, and a good faitli effort 01JMIt disclosure," Accordingly, the La Mirada Avenue Neighborhood Association respectfully submits the following objections to the Project and its Draft Environmental Impact Report. ".RRYWES, QMIS.sJDNSANDINACCURCmS ~ II" 1 describes the Project site as "currently not occupied." The site has in fact been occupied for the past year by a Fallas clothing store, which leased the former CVS/Phatmacy building at the eastern end of the complex soon lifter that tenant relocated. A Halloween-themed store also rented the former Fa11n Fresh Ranch Market building ill October of 2011. The parking lot has also been rented as a truck staging area. Additionally, as seen in Figure I1I~1illthe DEIR, a sign atop the former Farm Fresh Ranch Market rominently advertises the remises as "For Lease." 5 Mr. Hadar Plafkln, Los Angeles City Planning Department Objections to the Target Draft EIR Mllrc114, 20l2; Page 3 Page Ir-1descdbes "Surrounding Land Uses" that are north, east and.west ot the subject location, butfails to describe uses located south of the Project sile.Thesewes iImlude:thc2-story offices and teaching facilities of the Assistance League of Southern California; single-familyhcmes andapartrnentbuildings; the historic U.S Post Office building (1) Western Avenue at De Longpre AVenue; and the Covenant House, a shelter for at-risk youths, 6 Inlroed.iafelySQuth of Target site: Two-story office of non-profit Asststance.League of South em Califohliaat De Longpre Avenue and St. Andrews Place . .Bl1ge1I"8 states under the heading "Design and Architectural Features't that "the deslgnhas undergoneextensive voluntary review through the Hollywood Design Revi('!WCommittee ... and the Holiywood.Studto District Neighborhood Committee (sic)." The DEm. fails to acknowledge that both the Hollywood Design Review Committee and the 7 Hollywood Studio District Neighborhood Council have rejected the proposed Project. (The Nei ghborhood Counci I voted. at its February j 3, 2012 Board meeting to support the Project 001 y if all parking is contained in a subterranean garage). P1.lg~JI-lO,under the heading "Access and Parking," states that the. Hollywood Freeway (US-] 101) is "located less than one hal/mile east of the project site." The 101 Freeway is located west of 8 the. Project site. This error is repeated on page H1-1. ¥r.HadftrPJafkin, Los Angeles City Planning Department Objectionsto the Target Draft ErR March 4, 2012; Page 4 FageU-! 0 also states that the proposed Project "would employ approximately 250 full and part-time employees," Yet the Target store located within the West Hollywood Gateway Retail Projectat Santa "Monica Blvd. and La Brea Ave. -- which at 137,795 sq. ft. is over 26,000 sq. ft, smaller than the proposed Target store at Sunset and Western -- is described in promotional material 9 lI$havifig8OO "Fun Hire" jobs. Since Inadequate employee parking availability would severely impact thesurrounding community, especially during peak holiday shopping periods, the DEIR must provide a more accurate breakdown of employment forecasts and alternative parking plans. Page II-ii, under the beading "Open Space and Landscaping," states that the Ficus trees on Westem Ave. would be removed with implementation of the Project. However, no mention is made (If the historic Canary Island Date Palm trees (Phoenix Canariensis) lining the site's frontage on SU!1,SetBlvd, These trees, which date from approximately 1915, were previously slated for removal 10 when fheProject initially received City approval in 2010. Since these mature Palm trees are an ifflportant contributor to historic Sunset Blvd., their possible removal needs to be addressed ill the BIR.(This matter 18also listed Oilpage U-14 under "Discretionary Actions and Approvals"). PageIlI-4 references a "three-story ICDC College" to the southeast of the Project site. The rCDGfaciIity,part of the Food 4 Less bullding,is not three stories. It ill one story in height with below grade parking. The PBIR also describes the Assistance League building south ofthe Project site as three Stories when it is two stories in height (tlwDEIR on page IV.B.l-13 correctly describes the. Assistance League buildings as "one- and two-stories high"). 11 The DBJR Oil page III-4 also incorrectly describes the Horne Depot store west of the Project site as having "an attached above grade parking structure." This building has rooftop parking, Which is accessed via an attached ramp. Page U!:::l 0 provides an incomplete List of Related Projects. Our January B, 2011 letter in: responseto the DER Notice of Preparation ("NOP") noted dozens of relevant projects missing from the Initial Study, resulting in a defective baseline in that document that skewed the cumulative analysis to favor the Project. Under Ole California Environmental Quality Act, an environmental review must discuss significant cumulative impacts to which a project contributes an incremental amount, (Guidelines, § 15130, subd. (a).). "As defined in:Section 15355, a cumulative impact consists of an impact which is created as a result of the combination of the project evaluated in the EIR together with other projects causing related impacts." (ibid.) "The cumulative impact from several projects is the change in:the environment which 12 results from the incrementalimpact of the project when: added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time." (Id., § 15355, subd. (b).). As noted in the DEIR, all proposed, recently approved, under construction, or reasonably foreseeable projects that could produce a related or cumulative impact on the local environment when considered in conjunction with the proposed project are required under CEQA to be included in this EIR. However, two key projects are notably absent from the List of Related Projects, despite being described in our comments to the NOP. These are: the Hollywood Cap Park; and the NBC Universal Evolution PIau. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 5 1) HQllyWoo(l Cap Park lTWect Description: Hollywood's Central Parkis proposed over the WI Freeway from North Bronson Avenue and Hollywood Boulevard to Santa Monica Boulevard, A mill')j length, it will provide 44 acres of park space. According to the Community Redevelopment Agency's ("CRA/LN',) July I5,200gstafr report, the "Cap Park" will include at the southeast corner. of Fountain Avenueand St. Andrews Place a large plaza and baseball field; playgrounds, plaza spaces, viewing platforms, water features, picnic areas, open fields andcommunity gardens. The CRA report alsostates that the project seeks to "transform.a freeway corridorinto a destination." The park is anticipated to genel'll.te3,785 construction jobs. CUlllulative impacts from the Target project and the adjacentCap Parkdevelopmentare likely. substantial, On Nov. 2, 2006, the CRAapproved $lOO,oooJor~feasibility study (later increased to $120,205), which was made public in. November of 2008. On December IS, 'Zon, the eRA approved a Memorandum of Understanding with the Los Angeles Bureau of.Englneering to transfer $2 million to fund the EIR. 2.) The1l!:BCUniversal Evolution Plan, Case No. BNV-2007-0Z54-ElR. 100 Universal Plaza. ProjtctDescriptiou: 2,937 residential units with 2.01 million sq. ft. of commercial 12 cont, development. The Draft BIR was released in 201 L The failure of theDraft BIR to accurately account for the cumulativehnpacts associated with the Hollywood Cap Park and the NBC Universal Evolution Plan is particularly glaring in light of the signlficantenvlronmental impacts stemming from the concurrent introduction of so many other massive projects rntheHollywood area. "Proper cumulative.impacts analysis is absolutelycritical to meaningful environmental review ... " Bakersfield Citizens for Local Control v. City of Bakersfield. (2004) 124 CalApp.4ili 1184, 120;), 1217. Cumulative impacts analysis is particularly important in the urban setting. King County Farm 13ureauv. City of Hanford, supra, 221 Cal.App.3d at 720 ("absent meaningful cumulative analysis, there Would never be any awareness or control over the speed and. manner of downtown development. Without that control, 'piecemeal development would inevitably cause havoc in virtually every aspect of the urban environment'") citing San Franciscans for Reasonable G19wili v. City and County of SlUi ,Francisco (l984)J51 Cal.App3d 61. See also Los Angeles Unified School Dis!. v.City of Los Angeles (1997) 58 Cal.App.4th 1019, 1025 (a project's impacts can assume "threatening dimensions ... whenconsidered in light of the other sources with which they interact"). '''The requirement for a cumulative impact analysis must be interpreted so as to afford the fullest protection or the environment within the reasonable scope of the statutory and regulatory language." ~lti4j]!l..[.toPreserve the Qilli. V._COlluty ofVenmm (1985) 176 Cal.App.3d 421,431-431. NIr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4,2012; Page 6 Ifitis "reasonable and practical" to include other projects in a project's clll1lulativeimpayts analysis, then the lead agency is required to do so." San Franciscans For Reasonable Growth v. City and County of SanFrauciscO,IDili!1l, l51.App.3d at 77. "The Guidelines explain that a discussion of cumulative effects should encompass 'past, present, and reasonably aniicipaiedfuture projects:" lAmel Heigllli It:hprovement Assn .•y. Regents ofUniyer8ity of California (1988) 47 Cal.qd 376, 394; citing Guidelines § 15130 (i:l)(l)(A); italics in original. For example, gtizens ABsn.,§JJlID!, 172 Cal.App.Jd 151, explicitly states that while projects "currently under environmental review unequivocallyqualify as probable future projects tobe considered ina cumulative analysis; .. even projectsanticipatedbeyond the near futureshould be analyzed for their cumulative effect." Id. at 168. Aproject that is under environmental review is a "reasonably foreseeable probable futureproject" 12 within the meaning of the Guidelines. (Guidelines, § 15355, subd. (b).). This is because once review is begun, Itsignificant investment of time, money and planning has probably occurred. Thus, once cont. environmental review commences, the project is probable rather than merely possible. Frkuds offue Eel River v. Sonoma County Water A~, 108 Cal.App.4'h atp.870; San Franciscans for Reasonable Growth v. City and CounlY of San Francisco,.supra, 151 Cal,App3d atpp, 74.75 It isan abuse of discretion til fail to include projects under environmental review if the omission Will cause 111eSeverity and significance of the impacts to be gravely understated. San l'ranciscans for Rea.~onaQle Growth y. City and County, of San Francisco, supra, 151 Cal.Appfd at pp. 77-78 "Proper cumulative impacts analysis is absolutely critical. to meaningful ettvironmenial review. ... " Bakersfield Citizensfor Local Control Y,City of Bakersfield (:4004) 124Cal.App.4th 1217. "[Qjuestions concerning ... cumulative impacts constitute important issues a/broad public interest that are likely to reoccur:" (ld. at 1184, 1203). Therefore, the Project ErR must include proper analysis of all related projects, including the Hollywood Cap Park and the NBC Universal Evolution Plan. Page IV.B.i-2 states that the ICDC College is three stories in height, As noted earlier, it is a one-story building. page IV.B.l·8 describes tile commercial buildings on the site as "vacant" As noted earlier, a Fallas clothing store occupies the site, and a "For Lease" sign advertises the remaining spaces. ~_!V .B.l·11 states "there are no designated State or local scenic highways adjacent to the project site or in the project area:' Historic Route 66 follows Santa Monica Blvd. through Hollywood. Page IV Jl.l·J;? claims under the heading "Existing Viewsheds": "the existing urban. deVeiOpment~ prevents. the availability of expansive scenic views 0/ the Hollywood Hills around the project site." This 16 is incorrect. As noted in our 1/13/11 NOP comment letter, spectacular views of tile Hollywood Hills are available throughout the area and would be permanently blocked by the Project. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 7 Existing scenic vistas of Hollywood HiIL~and Griffith Park Observatory from sidewalk in front of 5528 Fernwood Ave., J-bloek south of Target site. Note Assistance League I)arking lot and rear of existing buildings on Project site. 16 cont. i , .~.__, ,.• Ei:;~ ..•.: ~.-,IIIh<;'''')~:<: .-,!!,_ :-.. " .. , ",_ .. ~J..>";o.;;;.: ... ",_ .....•. _.,;;.t;~ Spectacular viewsofHollywood Hills as seen from second floor public area at Covenant Honse building 011 FernwoodA ve., one block south of Project site. Existlng panoramic views of Hollywood Hills would be permanently blocked by construction of Target store. The Draft ElR also omits any reference to the Griffith Park Observatory, This famed landmark is an important element of the Hollywood Hills viewshed, and must be discussed in the EIR MI'. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 8 Blge IV.B.l-13 states that there currently are no expansive views through the project site to scenic or visual resources. This comment neglects the multi-acreage parking Jot as a viewing location of the Holl wood Hills. Note photo below: 16 , cent, Immediately north of the Target site: Note views of the Hollywood Hills and Griffith Park Observatory in the background. Blge IV.B.l- Vi provides a bullet-pointedlist of design elements that it credits as reducingthe impacts of the Project's massing. However, as notedearlier, the Hollywood Design Review committee - 17. whichis comprisedof professional architects and reviews all major Hollywooddevelopment within Counci! Districtl S -, has rejected the Target designfor being essentially a massive box. As ofthe date of this comment letter, Target has ref"used to considerchanges to its design in response toth18 committee. Page JV.B.l-19 states that construction of the-proposed Project would require the demolition of"all existing trees and landscaping, as well as portions of-sidewalks and other areas." However, as noted earlier, the DEIR does not clarify if this involves removal of the historic Date Palm trees. liningSunset 18 Blvd. If the Applicant repeats its request for the removal of thesenearly lOO-year'(,ld trees, the DElR must analyze the cui tural/historic impacts. Page IY,B.1-26 omits any reference to the Griffith Park Observatory when listing significant views, As noted earlier, the Observatory mUSI be included in any analysis of impacts to viewsand view corridors. The DEIR also claims that views from second floor windows of the Covenant House (located south of the 19 Project site) are limited. Note photo on page 7 of this letter showing spectacular vistas of Hollywood Hills as taken from the second floor of Covenant House. rage IY,B.1-30 states that there "are no view resources located to the southwest and therefore ] such view blockage would not be significant." Note photo on page 7 of this letter showing clear 20 views south of the Project site. I I Mr. Hadar PJatldn, Los Angeles City Planning Department .! Objections to the Target Draft EIR March 4, 2012; Page 9 PagesIV.C-33to 35 omit the Hollywood Cap Park and NBC Universal Evolution Plan from the Related Project Trip Generation Summary. These major projects need to be included, Page IV.G-2dauns erroneously that the development at the northeast comer of Sunset-Blvd. IIDd.W~sWmA.ve.is "90 feet in height." This isgrosslyinaccurate. The residential component.of this 5-story, 56cllDitWalgreens/mixed-use affordable housing development has IImaximum height of 65 feet {See 7/Z9/03APCC Determination Letter-page C-I, Condition of Approval " 8"5, Height: "Thehdght of all buildings and structures on the subject property shall nor exceed 65feet" ."), 22 PageW,G-2 also lists the height of the Home Depotstore as "approximately 60feeC This is alsogrossly inaccurate. A~ pointed out in our 1/13/11 comment letter to the NOP, the Rome Depot store lIlea~ures30 feet,.8inches in height from the lowestnatural grade.onDe Longpre Ave, to the r()Ofline,or half the height listed in theDEIR (Note surveyor's report attached at Exhibit 1). The DEIR cannot simply make wild guesses regarding a building's height witb no factual evidence of ~.Jlort Page IV.G-21, under the heading "Parking Requirements," states: "one parking space is required for every 1,000 sq. ft. of commercial." This is incorrect. The DtlIR references Los Angeles Municipal Code (''LAMC'') Section 12.21(A)(4)(i),butthis provision relates to parking downtownand is not 23 . applicable. The COl1'ectLAMCsection is 12.21(A)(4)(x)(3)(2), requiring two parking spaces per 1,(){)0 sq.ft.iParking IONhe Project is controlled under SNAP Section 9B. Page IV.G-24 states under the heading "Project Characteristics" that the Project site is ] 24 "vacant" As previously noted, thisis incorrect ~,G-25, under the heading "Designand Architectural Features," describes the proposed Project as "a convenient, pedestrian friendly shoppingcenter ... " The mainoccupanr of the site, the 25 Target store, would be located on the third level above two stories of parking. The Project cannot therefore be accurately described as convenient for pedestrian access, who must climb three levels, P'd.g.eIV,G-26erroneously states that theProject would "provide an overall FAR of approximately 1.15:1, Which is compatible with surrounding low-rise buildings in the area ... " This statement tacksfactual analysis and is clearly the opinion of the writer. The almost 9Q..foot-taIIProject is not compatible with low- 26 rise buildings, and is claiming a Floor Area Ratio of 1.15:1 only because under the LAMC parking facilities are not included in FAR calculations. If the Project's 225,286 sq. ft. of above-gradeparking were included in determining the actual floor area {DEIR p. IV.K.2-10), the overall FAR would be 2.61: I. The DEIR further states that the Project is "similar in design and use to many of the surrounding commercial uses, would be a more appropriate designfor all urban area compared to the previous suburban-style shopping center and would represent an improvement in appearance and usefulness of the project site compared to the previous use. As the proposed project would include similar uses to those of the surrounding area and be consistent with the design of surrounding development, no significant impacts 27 would resuli from the proposed project with regard to land use functional compatibility:" This statement is the opinion of the writer, has no basis in fact, and is countered by the Project's rejection by the professional architects who comprise the Hollywood Design Review committee. The conclusion of that committee was that the Project's design in no manner integrates with the surrounding community. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 10 Page IY.Q-28 states that the Project site is "approximately ],000 feet" from the Metro subway stop at the intersection of Hollywood Blvd. and Western Ave. As pointed out in our lIB/1l comment letter to the NOP, the Project site is in fact 1,402 feet from the subway street entrance, or 40% greater in distance than the estimate in the DBrR. (Note: Our measurement with a rolling footage counter started from the southwest corner of the intersection of Sunset Blvd. and Western Ave. to the southern edge of the street-level perimeter of the Metro Hollywood/Western subway entrance). The DEIR's guess of ],000 feet from the Project site to the Metro stop is repeated throughout the document. Like the wildly 28 inaccurate estimates of surrounding building heights, such off-the-cuff estimates have no place in an EIR. &;geIV.G<~8 also claims that the Project's proximity to the Metro stop "would providea: broad.geographic range in which employees couldlocatewithout requiring long vehicle commutes." This comment is sheer speculation, and no evidence is provided to support theclaim that employees will use the Metro subway to work at Target. No studies of otherlow-wage employers In the Project area are presented to substantiate such claims. . Page.IY.G-29 states: "A typical Target store ofthe sizeproposed would require 656-820 spaces, But 4signijicantly lowered parking ratio than is usually requiredby. TW'fletis.beitig 'proposed in order to promote pedestrian uses and transit uses -thqe.by reducingvehicle.tripli"· No evidenceispresented tosllPportthe claim that a typical Target requires up to 82O)?!\rkingspace~. SNAP allowsa maximum of 386 parking spaces on the site, which is consistent with the IAMCrequirementof ~parkingspa~es per 29 1,0(}()sq. ft. of commercial space. Target is requesting an exception from this restriction to allow 458 parkingstalls, or an additional 72 parking spaces. Targetistherefore requesting more parking than the Code permits. How then is seeking additional parkingsomehow geared to reducing vehicle nips?" This specious argument is repeated on .~JV.G-30. Page IV ,(l--30 cites a 1O}0 population estimate forthe Hollywood Community Plan Area of 30 24!),000 persons, 115,000 housing units, and 130, 000 jobs. These figures are taken from the DrafCEl.R for the Hollywood Community Plan Update, andhave beenacknowledged as grossly inaccurate in the Update's Final EIR. Year 2010 Census figures show a significant and consistent population decline in Hollywood over the previous two decades, with a 2010 population-of 198,228 residents, Hollywood lost over 15,000 residents between 1990 and 20] 0 (See Plan Update Final ElR p. 3-3). ~y"G-34, under the heading "Enable prosperity for all People," states: "The proposed. project wouldprovide a substantial amount of employment opportunities, and thus, would be consistent With the Compass Growth Vision principle to enable prosperity for all people:' This conclusion ignores the loss of jobs by employees of the site's previous retail tenants. The primary occupant of the proposed Project, Target Corp., is a minimum wage, non-union employer with a large contingent of part-time employees. The former main tenant of the site, the Farm Fresh Ranch Market, was a union employer offering 31 primarily full-time jobs. Grocery workers in California who belong to the United Food and Commercial Workers union eam an average hourly pay of $15.41 (Source: LA Times, 313/12 Business Section, "Wal-Mart's New Push in Groceries"). By eliminating such Jiving wage jobs, the proposed minimum wage Target store bas therefore reduced prosperity prospects for area residents, not increased it Also, since the proposed Target would include food sales, union wage positions at. nearby grocery chains may also be impacted. None of this is analyzed in the DEtR. l.\1t-,Hadatl'Jafldn,Los Angeles CityPlanning Department Obje~ti()lls tothe Target Draft EIR March4, ;?,{)~Z;Page 11 and ;:~:!Z'X~~0{~~!~~:fy~~ie~~:;!~tM~~fi:tl:46i~:t1l1etrosubway stop at HOllYWOod] 32 l?i!gelV.G-44 states under its review of.Policy LU.3.1:"The sidewalkssutroundingtheprojectsite Will maintaintheir-current width. of approximately 10 feet ... " The-site's existing Sidewalks. are not 10 feet wide.The sidewalk fronting the ProjectsiteatSunsetB!vd. is currell\lyJ5feetwide and.the 33 sidewalk.along Western Ave. is 20 feet wide. The Appllcant has previously stated that allsidewalks wouldbe J5 feet wide. 18 the Applicant nOW reducing' the sidewalk width to lO.feet? .:~e~~i~{£~~;::~~etEtt~!t~D;r.x~.!~;~~~~;~~s~:4::sPth~~~;j~~j'~~;~6r::~~;] 34 ~~i~~~gi;1i;1&f~~'F:=]35 P1!geW.G"52 also erroneously states under its review of Policy M.1.6 that"allsignijicant traffic impactswilibe reduced to a level of less thansignificunt:" Thisis incorrect. TbePEIIHraffic Analysis at page lV.C-58 identifies two intersections where the Project will resultin significant impacts 36 tbatcannot be mitigated: Santa MonicaBlvdand Western Ave. and Fountain Ave. and Western Ave. These two intersections define the La Mirada. neighborhood. Ri!g.e IV.G-53 states under its review of policyM.I.15, whicllisapolicyseekingto facilitate the rnovement.of emergency vehicles, that "allsigflijiC(JI1!trafjic impacts will beredlKedJoaleyetofless thansignificant, therebymaintaining the current movement of traffic." As noted above, this statement is incorrect The DEIR acknowledges that the Project will create significant impactsthat cannot b~ mitigated at the intersections of Santa Monica Blvd. and Western Ave. and Fountain Ave.und Westem 37 Ave., resulting in gridlock conditions on Western Ave. TheUl'Dstationrespollsible for tile La Mirada. neighborhood is Station 52, located at 4957 Melrose Ave. near Western Ave -: This. station's I I primaryaccess route for our community is via.Western Ave. Gridlock conditions on Western Ave. i would thereforeresult ill a significaut delay ill response times that cannot be mitigated by using sirens or driving in opposing Ianes, since those lanes would be full. ,I Page IV.G-54 states under its review of Policy M.1.89 that "no significant neighborhoodimpacts would occur as a result of traffic generated bythe proposed project." This is incorrect. The DEIR I traffic analysis onpage rv.C-60 identifies II significant neighborhood trafficimpact on St. Andrews 38 I Place north of Fountain Ave., and concludes that the mitigation measure of a speedhump "would not be feasible to implement and the impact at this location would be significant and unavoidable?' NOTE: I Due to the City's fiscal crisis, DOT funding for speed humps has been eliminated, I I l?i!ge IV.G-59 states fua.t the proposed Project is consistent with City policies to break up bUildil~g ,I massing. The Project is in fact requesting a number of exceptions from the SNAP guidelines created to 39 specifically address massing. and is therefore inconsistent with such policies. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 12 !1!.geIV.G-62 citesthecity.goal of preservation of mature tt~~.As noted ~rli«r,theDI3* 40 does not explain the Applicant's intent for the-historic Palm trees lining Sunset Blvd. ] PageIV.G-68 claims consistency withGoal515pfthe Hollywood RedevelopmentPlanthat, J 41 3n.)On.gothetpoiJlts, requiresthat the heigb(of abuildi."' "*,iM.lry;"""~'l'''~and ••. regulations. The Project is not consistent with this goal.as it does notcomply with "all applicable. design standards." Pages IV.G-70 to 78 regard the Project's consistency with the requirements of SNAP. The DEIR prefaces this review with a statement that the Project complies with the ordinance "10 the greatest extent possible. " and that the requested exceptions are "minor deviations." A number of 42 the requested exceptions would in fact eliminate the requirements altogether, and therefore cannot be accurately characterized as "minor." Furthermore, no evidence is cited in.the record to support the claim that Target has complied "to the greatest extent possible." I'llge IV.O-70 omits any reference to an option within the childcare requirement in SNAP Section.6G-4 for a cash paymeut in lieu of providing the floor area necessitated by Section 60-1. Target Corp. made $65 billion in revenue in 2011, and therefore bas the resources to afford such 43 payments to benefit its employees. The exception request is therefore unjustified. Page IV.G-71. states tMnargef"typica!ly carries products that. do not require deliveries because the products are generaJly small.in size." No evldence is presented tc supportthis claim. In contrast to this statement, Target's advertising places a heavy ernphesls on bulky consumer 44 electronics items suchas televisions and associated products. ne ElK must provide a breakdown of store product sales to SUPPOlt such claims. Otherwise, such statements. are mere. guesses. I'llge IV .G-71 omits mention of the Applicant's requested exceptionto perrnit a zero-foot setback above the roofline.for an additional 10 feet of vertical elements. Also, regarding the Project'sheight, on Pa~eIV.G-72 the DEIR references the Walgreen's mixed-use development at 45 the NEcorner of the intersection of Sunset Blvd. and Western Ave. as support.for buildings over 75 feet in height As noted previously, this development had a maximum heightfor its affordable housing component of65 feet. I'llge IV.C·n omits any reference to the Applicant's requested exception to exceed the maximu~ 46 allowed. number of parking spaces by n stalls. The Project's parking is not consistent with SNAP. ~ m, ENVIRONMENTAl, OBJECTIONS A. The analysis of additional police protection requirements contains inaccurate statistics and offers lUI inadequate comparative analysts, The DEIR's discussion of the potential impacts of the proposed Project on police protection services 47 is fatally flawed. The DEIR analysis utilizes the wrong statistics, ignores proper academic standards of review, aud credits a two-year-old phone interview with one LAPD offlceras the criteria for policy decisions while disregarding the proper LAPD personnel for information and commentary. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft ElR March 4,2012; Page 13 The DElR on page IV.J.l-l states that the Project site is located in Reporting District ("RD") 669. This is incorrect, The Project site is located within RD 668 (See Exhibit Z). Furthermore, the DEJR describes the Hollywood Community Police Station's boundaries as: Sunset Blvd. to the north, Santa Monica Blvd. to the south, Western Avenue to the west, and Normandie Ave. to the east. These boundaries exclude the Project site, and are actually the boundaries for RD669 and RD659. The correct borders for the Hollywood Community Police Station's service area are: Normandie Ave. to the east, West Hollywood to the west, Mulholland Dr. to the north, and Beverly Blvd. to the south. The station currently has 314 sworn officers for a population of 300.,000 people, or one officer per 955 persons. The DEIR states that there is no official standard that governs the ratio of LAPD officers per residential population, and cites a January 11,2010 phone interview with a Sergeant Morales of the LAPD Community Crime Liaison Unit as the basis for this .positlon. This interview would have been conducted almost a year prior to the Project's December 6, 2010 Notice of Preparation. Such comments therefore have questionable relevancy to the Project. The Los Angeles Department of City Planning utilizes the National Association of City Managers and Police Department standard oftour officers per 1,000 residents to determine the adequate level of deployment of police officers in Los Angeles (See Hollywood Community Plan Update Draft EIR p. 4.3- 11). Under this national standard, the Hollywood Community Police Station would require approximately 1,200 officers, or 886 more officers than currently serving the area, to provide adequatp protection for the station's 300,000 residents. 47 Attached at Exhibit 2 are year 2010 Los Angeles Police j)i'pertmeI1tCl'imesandAtTet>ts by cant. R~pottil)g Districtfigures for the Hollywood area, covering ReJ?Orting.Districts 600 .through()99. These statistics are available to the City Planning .J)oft~1inlent asthe "ABC runs," and are provided t~applicants of liquor licenses and other COnditiolltit Use Permit requests. Such detailed.infonnation should therefore have been made available to the Project, and should nothave.been suppressed from the DElE.. The Project is located in Reporting District 668.. RD 668 had a Mal of 475 PartLand PartIl crimes and arrests in the year 2010, with a high level of narcotics arrests and public drunkenness, and the highest number of gambling arrests, Los Angeles' 1,135 Reporting Districts reported 266,457 offenses am! arrests for 2010, an average of 235 crimes and arrests per Reporting District The Project's Reporting District therefore had a 2010 crime rate over 200% above the citywide average. If the Project's Reporting District currently has a crime rate exceeding 200% above the citywide average, and the existing police force is short by 886 offlcers, impacts of the Project are therefore potentiallysigniflcant, This is the official position of the LAPD as expressed in a June 2, 2008 comment letter submitted to the Project's Initial Study, As stated by Lieutenant Douglas Miller of the Office of the Chief of Police: "A project of this size would have a signffical11 impact on police services in the Hollywood Area' (see E:r.:hibit 3). Since the proposed Project is now larger than what was originally proposed in 2008, the Lieutenant's comments are even more relevant, Utilizing accepted national standards, cumulative impacts to police services and the Project's impact to the officer-to-resident ratio would require a new or expanded police station. No funding is currently available for the city to comply with such needs. Project impacts would therefore be significant. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft BfR March 4,2012; Page 14 B. .Ap.proWof llieProject W()\lJrlr~lllt ill sigmncallt impacts to Land Use and Planning. The applicant's discretionary requests are botb extensive and precedent setting. The Project as proposed is inconsistent with the requirements and guidelines of the VermontIW estern Transit Oriented District Area Specific Plan, and if developed would create adverse environmental impacts to the surrounding neighborhood that are significant, permanent and without mitigation. Sectionll.5.7.F.2 of the Los Angeles Municipal Code ("LAMC") requires that a Specific Plan exception be supported by written findings of all of the following: a) That strict application of the regulations of the specific plan would result in practical difficulties or unnecessary hardships inconsistent with the general purpose and intent of the specific plan; b) That there are exceptional circumstances or conditions applicable to the subject property involved Of to the intended use or development of the subject property that do not apply generally to other property in the specific plan area; c) That an exception from the specific plan is necessary for Ole preservation and enjoyment of a substantial property right or use generally possessed by other property within the specific plan area in tbe sam" zone and vicinity but which, because of special circumstances and practical difficulties Of unnecessary 48 hardships is denied to the property in question; d) That 111e granting of an exception will not be materially detrimental to the public welfare Of injurious to the properly or improvements adjacent to or in the vicinity of the subject property; e) That the granting of an exception will be consistent with the principles, intent and goals of the specific plan and any applicable clement of the general plan, California law requires that an exception from a zoning ordinance must show that the applicant would suffer practical difficulties and unnecessary hardships in the absence of the variance, that these hardships result from special circumstances relating to the property that are not Shared by other propertie in the area, and that the exception is necessary to bring the applicant into parity with other properly owners in the same zone and vicinity. Specific findings for granting a variation from 11mZoning Code are required under Section 65906 of the California Government Code, which states: "Variances from the terms of the zoning ordinances shall be granted only when, because of special circumstances applicable to the property. including size, shape, topography, location or surroundings, the strict application of the zoning ordinance deprives such property of privileges enjoyed by other property in the vicinity and under identical zoning classifications. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR; March 4, 2012; Page 15 "AnYl!dtiance granted shall be subfecito "tick conditions as will f!SSU1'¢ tl14t.t/1J; aa}ust/rlentthereby. authorized shall.not constitute a grant o] special privileges inconsistent.with. the limitations uponother properties-in the vicinity and zone iii Which such-property is situated," "An exception from II specific plan shall not be used to grant a special privilege, norto grant. relief from self-Imposed hardships,' The first required finding for au exception from the requirements of the Specific Plan, that the strict application of the regulations of the Specific Plan would result in practical difficulties 01' unnecessary hardships inconsistent With the general purpose and intent of the Specific Plan, is evaluated based on whether the properly can be put to effective use without the exception. The.subject.site is lI.rectangular-shapedlot coveting anentire city block toraling appr04imatel~;),69 net acresafter dedications, Current structures on the site are all one-story in height and includ~avaCl\~d CVSPharmllCYllQWopcupied bya Pallas clothing etore anda fonnerParmFresh Ranch1V!aJ'kei, ••The i s,l!bjectsit(}isiocate<1 in subarea CQftl1e Vermont/Western TransitOriented District Speclflc.Plen.which I 1imi:sth~ .bufldingheight ofcommercial-onlyprojects toamaximum 35 feel, Theun<1el'lyi.tJgzoniog is C2-J.',l'he.site was first developed io 1916 as the original lccation of the Fox movie studios, later known as)l,Oth(Jent!uyfo)(,which leftHollywood for its. Westside studio 100<\0011if 1 the Ia,lt:1960s,.Theexisting 48 sinzle-stoi commercialbuildings were developed In the 1970s, cont. i I I i I Photo foreground: Looking south along Western Ave, at Sunset Blvd., circa 1917. Note formerFox Movie Studios lot on subject site, Mr. Hadar Plafkin; Los Angeles City Planning Department Objections to the Target Draft ErR; March 4, 2012; Page 16 .~ ~ I! Existing one-story retail development and puking lot on subject site. Immediately south of the parcel is a single-story, historic US Post Office building, and the one- and two-story headqua~ers o.fthe .noh-pr~fit Assistance League of Southern California. ~)ne block further south 48 011 Fernwood Ave. IS residential housing and the non-profit Covenant House for at-risk youths, cont. Immediately westof the subject.site across St.Andrews Place ISil31-foot tallv single-story Home Depot with surface and roofto~~arki!lg. Across from the subject site at the NW intersection of Sunset Blvd. and Western Ave. is aone-story OSH hardware store whl) surface parking. At the SE corner of thls.intersectionlsa single-story Food-a-Lessgrocery store with both below-grade and surface parking. -, .. -,-.-,' i .~~, ~..~~. Immediately West of the Target site:' The 31 -foot tall, one-story Home Depot MJ', Hadar Plafk.in, Los Angeles City Planning Department Objections to the Target Draft BIR March 4, 2012; Page 17 48 cont. 1 .,... . i~~·..:"",,,;;~._;j,':::i:;- Immediately east of the site at the southeast corner of the Intersection of Sunset Blvd. and Westcl'o Ave., a sillgle'story: Food-s-Less, lenC College, and Mcbonald's, Mr, Hadar Plafkin, Los Angeles City Planning Department Objections to the TargetDraft ErR March 4,2012; Page 18 A particular characteristic of a property is not by itself sufficient to support an exception to the Specific Plan. The Applicant must instead show that such characteristics differ significantly from other similarly situated properties in the same zone and vicinity. Comments regarding superiority of project design, amenities, benefits to the community, and the superior aspects perceived of the proposed development to ones constructed in conformity with zoning regulations are irrelevant when considering the grant of ail exception. "In the absence ofa specific 'bonus' or 'merit' system of zoning enacted by the municipal or county legislature, a valiance applicant may not earn immunity from one code provision merely by over compliance with others. Otherwise, the board charged with reviewing development proposals would be empowered 10 decide which code provisions to enforce in any given case. That power does not properly repose ill any administrative I tribunal" Orinda Association v. Eo<\rd of SUpervisors of Contra Costa (1986) 182 Cal.App.3d at 1147. All of Target's programmatic needs are embodied ill a mixed-use development a quarter of a mile ,I north of the Target site at the northeast intersection of Hollywood Blvd. and Western Ave. Commonly referred to as the Ralph's Shopping Center for-its primary tenant, this development features 2J5,927 square feet of retail space and 160 units of affordable senior housing on a 3,05- acre site The project also offers extensive free subterranean and surface parking totaling 460 spaces. Pel' the requirements of the Specific Plan, the retail component is confined to two stories and the retail structure does not exceed 35-feet in heiz '. 48 cent, ! :~i~f';f~.~~,i~~~.~tt~:;i;.:::t>~\~..I" • Mixed-use development at Hollywood Blvd. and Westem Ave, across from Red Line subway stop, , By comparison, Target's proposed project would place J94,749 sq. ft. of retail on a 3.9"aere site with no housing and no subterranean parking. Target's retail building would exceed 84 feet in height. Mr. Badal' Plafkin, Los Angeles City Planning Department Objectiolls to the Target Draft ErR Mal'Oil 4, :2012; Page 19 '..!,,:;., ..../ Free subterralwlIn and surface parking Is availablef'or use by patrons auclnclghbQrs .. thf'IIlixed-useRlllpl1's Shopping Center-is located inuuediately across from a Red Line subway stqp,andA'eatlu'espeighbofl1ood serving multi-tenant retail with a Relph's supermarket, Ross Dressfor Less, AaronBrothers frame shop, and 16 smaller.retailers. The development also includes alarg~, gtade-lewlpJIlza, proudly advertises onthe side of the building-that it featurest'Iots of lower level parking", and has facade articulatl 011 throughout the structure. All of this is olfered on a site.almost an acre-smaller than the l:'ilrget. site, 48 cont. ... - Inner plaza at mixed-use development offers various neighborhood-serving retailers. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 20 Proposed Tarzet Store Ralph's Shopping Center Lot size 3.9 gross acres 3.05 gross acres Retail square footage! 194,749squarefeet retail! 215,927 square feet retail/ Number' of retail outlets (unknown;30,887 sq. ft. "other") 18 storefronts Height of retail component 84 feet, 4 inches.in height Retail: less than 35 feet Housing component NONE 100 units affordable senior Distance to subway stop 1,402:feet to Red Line Across street from Red Line 48 Parking spaces 458: two levels at above grade i 460: surface and subterranean cant. If the mixed-use development at the intersection of Hollywood Blvd. and Western Ave. can offer more square footage of retail space than the proposed Target project, on a smaller lot, and also include 100 units of affordable housing while keeping the height of the retail structures below 35 feet, how then can Target justify its requested exceptions to the Specific Plan? C. The Project. would bave a substantial adverse effect Oil aesthetics. Appendix G'tothe StateCBQAGuideUnes (THIc 14 oftheGovernmentCode) providesthata devefopment conld hsve significant environmental impaotstoaestheticsifit would "substantially degrade tile existing visual character or quality of the site and its surroundings." Furthermore, the Los AngelesCity CEQA Guidelines provide that a-factor. in determining the significance of aesthetic Impacts is the "degree of contrast between the proposed features and existing features that represent the area's valued aesthetic image." In determining whether an impact is significant, the City must considertbe currentcharacterof the area.which the Project DEIRrefers to as one to two Story commercial uses. This low-level-neighborhood characteristic is reflectedby the Specific Plan's height restrictions.Jimlting cominercial-enly.development to a maximum height of 35 feet with extensive building step-back and other design requirements. Structures in the immediate vicinity of the Project site are dominated by single-story retail fronted by 49 surface parking, with the exception of the Walgreen's mixed-use development at the northeastcorner of Sunset Blvd. and Western Ave. That project also features one-story retail fronted by surface parking, but additionally includes an affordable housing component behind it. The Walgreen's development follows the guidelines or the Specific Plan by steppingbackand breaking up the massing of its buildings, varying the rooflines, and providing subterranean parking, In contrast, Target's building design docs little to relieve the structure's overbearing massing, does not vary the rooflines, and would. tower above all other structures in its vicinity. The visual character of the proposed Project would not match the visual character ofthe surrounding low-level development, nor would it conform to the requirements of tbe Specific Plan. Tbere are no 84- foot-tall buildings in the immediate area. Therefore, the Project would not match the visual character of the surroundings and would be aesthetically unpleasing. Mr. Hadar Plafkin, Los Angeles City Planning Department Db' ections. '.. to',... the-Target'," - Draft- ',' ElR;';-':-:'March 4, 20l2;Page"~-'t?o21 49 cont. Illustrated view of proposed 84-foot-tnlI Target store at at. Andrews Place and Sunset Blvd. r '~, ""~~,,di," InlinediateJy south of Target site: Two-story office of non-profit Assistance League of Southern 49 California at De Lo e Avenue and St, Andrews Place, cont. Single. level post office south of Target site at Western and De Longpre Avenues. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target DraftEIR; March 4, 2012; Page 23 The proposed Project's significant aesthetic impacts could be mitigated by decreasedheight, stepriingthe Project's footprint back and designing a storefront with reduced massing a!10 increesed articulation. Not only is such a project possible, apparently it is what Target originally proposed. At the June 23, 2009 Central Area Planning Commission public hearing on the Target project, Ms. Kelli Bernard, Council District 13's consultant for economic development, stated that Target first came to the council office more than three years earlier and proposed a store featuring Target's traditional low-level "suburban model," "We don 't want a suburban model" stated Ms. Bernard for CD13. "We went from having a/arge parking field alit in front of it that you would see,for example, there's a Target on Rodeo and La Clenega. They (CD 13's Design Review Committee) did not want that sort oftking and neither did the council ·ce." 50 Single-JevelTarget store at Rodeo Rd. and La Cienega Blvd., that was Cited by Cl)13 representative Kelli Bernard as something CDB told Target they did not want for Hollywood. CouncilDistrict 13'3 position was reiterated OilJune 29, 2010 duringMs, Bernard's further testimony before the Los Angeles City Council's Planning and Land Use Management committee: "We challenged Target to create a more urban store" stated Ms. Bernard. "We're encouraging height and density on Sunset Blvd." Such comments conflict with tile, restrictions of the Specific Plan, which states in part at Section 2E under the heading of "Purpose": "This Specific Plan is intended to guide all development, including use. location, height and density, to assure compatibility of USIiS .. ." Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft ErR March 4, 20 12; Page 24 Compatibility of uses requires adherence to the zoning requirements of the Specific Plan. To the immediate west of the proposed Target site, Home Depot operates an 188,787 sq. ft. store on all entire city block. The height of this single-level building is 3Dfeet, 8 inches as measured from the lowest level at grade to the roofline. Parking is on a surface lot and aj roof level. By comparison, Target proposes an 84- foot tall, 194,749 square foot retail center with two above ground parking levels on a site that also covel'S an entire city block. Target's store would be incompatible not only with the Home Depot, but with every other ro ae in the same zone and vicinity. :!.:} , ' " "':'i"'~r~i"<" 51 Home Depot's single-level store has rooftop parking. Note spectacular scenic vistas of the Hollywood Hills as seen at a height of 30 feet, 8 inches above grade. ~~";'@.":J~::;';l,~ ~!iiilm~"""''''''';~£AW~'&i1~4~:~~~,~, Sunset Blvd. at Wilton, with Home Depot 8tO!"!) at photo right. Project site is at upper right Angeses City Planning Department EIR 51 cont. D. The Applicant has ptoyided no.Justification for an inctea~e in the permitted number of parking stalls. The DElRdoesn't even discuss a justiftcationfor the Project'srequestto provide 72 parking stalls more-than permitted under SNAP, other than to mention the requestand to vaguely state that a typical Targetstore would provide vastly more parking. TheAppllcant has previously claimed that the HOllywood Home Depot store immediately west of the subject site and the Food 4 Less grocery store east of the Project site are examples of national retailerswith more on-site parklng than is currently allowed under the Specific Plan. Since the DETR omits the subject altogether, our comments will focus 011 tills prior argument. The Applicant did not previously quantify whether all of the provided parking at the Home 52 Depot and Food 4 Less is actually needed, or if theparking Is excessive. In fact, a third of the rood 4 Less surface parking lot is currently restricted to employees of Deluxe Film Laboratories while that adjacent 24-110Ul" operation undergoes a multi-year expansion, confirming the site's surplus of parking. Itshould also be noted that national retailer Home Depot has rooftop parking at its Hollywood site, While national retailer Food 4 Less has subterranean parking on its Hollywood lot -- two parking options previously deemed "not feasible" by Target. The ElR must explain why the Project is being promoted as "transit friendly" while asking for a significant increase in the number of parking stalls, nod provide a proper analysis to justify exceeding the SNAP limitation. Mr, Hadar Plafk:in, Los A(lgeles City Planning Department Objections to the Target Draft EIR March 4, 2012; Page 26 ,3 :;:0~~~~fniWf~;1\jt;;,;.· Food 4 Less parking lot section restricted to Deluxe Fll background). 52 cont. m Photo showing Food 4 Less site and Deluxe parking area outlined at left (lab seen at,lower edge of photo), Mr, Hadar Plafkin, Los Angeles City Planning Department Obiectlons to the Ta t Draft EIR; March 4, 2012; Pa e27 I I I I ! f 52 I cont. I .-#1' -;'I1!li, Aerial view of Home Depot stowe located immediately west of the subject site. Note that extensive rooftop parking is largely unused while smaller, grade-level parkinglot is full. Mr. Hadar Plafkin, Los Angeles City Planning Department Objections to the Target Draft EIR March 4.2012; Page 28 E. Tbe DEIRAlternatiyesAnalysisomits Irelevapt l;ompa;ratlye informati The Project proposes a. 163,862 sq. ft. Target store with perimeter retail and two levels of above- grade parking. In contrast, the West Hollywood Target, located at La Brea Ave. and Santa Monica Blvd., is 137,500 sq. ft. , or more than 26,000 sq. ft. smaller than the proposed Project. The West Hollywood Target, which is among the lop flve grossing Target stores nationwide, shares parking with other retailers in a two-level subterranean garage. The West Hollywood location, owned and developed by the J.H. Snyder Company in 2003, was originally a Brownfield site requiring extensive and costly mitigation. The site's water table is also extremely high at 15 feet in depth, requiring pumping. In contrast, the water table beneath the'Hollywood Project site is a rox.49 feet in d th, which could accommodate several levels of underground parking. 53 AUparkh1gforWest HollywoodTarget store is in subterranean levels,as shownabove. Target Corp, has recently signed a long-term lease to open a "City Target" urban store of approximately 100,000 sq. It. at the Beverly Connection shopping center located on La Cienega Blvd. ill west Los Angeles between Beverly Blvd. and 3'" Street. City Targetstoresare designed for a smaller urban footprint (see Exhibit 4). None of the alternatives analyzed in the DEIR offer a logical combination of a smaller Target store as illustrated by the success of the West Hollywood Target or the new City Target, combined with additional retail uses and served by one level of subterranean parking and rooftop parking. Such an alternative would comply with SNAP and significantly lessen the Project's aesthetic impacts. CEQA mandates that avoidable significant environmental damage he substantially lessened OJ' avoided where feasible. Pub. Res. Code §§ 21002,21100(b)(4), Guidelines §§ 150021,15121,15126. The BlR must contain a "reasonable range of alternatives to the project which (1) offer substantial environmental advantages over the project proposal ... ; and (2) may be 'feasibly accomplished in a successful manner' considering the economic, environmental, social and technological factors involved." Citize[jil.of~;oleta VllUey v. BO_ Under CEQA, unless the administrative record clearly demonstrates that it is infeasible for economic 53 or other reasons, the lead agency is required to approve the enyironmentally superior alternative. Pub, cant. Res. Code §§ 21002, 21081. A reduced scale alternative to the Project can be developed that is completely code compliant and acceptable to this community. VI. CONCLUSION. The Project's DEIR characterizes many environmental effects that will be caused by the Project as "insignificant," "less than Significant impact," or "no impact," such that few or no serious mitigation measures are allegedly necessary. Many such determinations in the Db1R are nnsupported by facts, or 54 premised on incorrect facts, or utterly lacking of any true analysis of the facts, or consisting of a superficial "analysis" which for the most part simply assumes its conclusion. The Project as-proposed would create a myriad of significant and permanent adverse ] 55 ;::J~~~~:~~~~r~~~;:~~:scommunity. It is respectfully submitted that in its current form, the As a neighborhood, we ask that the City recognize the negative impacts associated with this and similar projects inconsistent with our community' s land use arid planning, and vote to not certify Of recommend for certification the DEIR for the Project. 56 We reserve the right tosubmit additional commentary. Thankyou for-your courtesyaud attention to this matter. Doug Haines for the La Mirada Avenue Neighborhood Association hibit 1 To Whom It May Concelfl, Regards, John Aivo Professional Land Surveyor LS 7908 I~ I \, hibit BfII1IIlf' ;.;.l ~ 0 l- Ii: ::r: I- 0 I- . ~ t: ::r: I- Iii ::r: I- 0 L,? .ic:t.. C'l N Ii: ~:~ rJ) w w ::r: :z; l- ii ~ o U.! e, ~ 0 <: l- n, :J C ..; Il.. ..; I.:: .J III 0 8~omroDom~.DO.ID~O •• rom~~~~~~m~m~~.roNm """0 E;; ~~' ~~ ...~~. ~ .~. ~~~N~~~ ~~. ~:..~:.~ N j e Jr: :J III oa NOT""" N. (f): "r- ~ ~ en "'''' 'U) cc I'- co Q) -e--' 'C'\I I.{) ill I'- co r» N (t) -o- co (Q f'-.. co 0') (0 !'--. c» 1.0' (0 I'- CO. Q) ill 1'''' 00 0"> f'- ..,.- ~~NNNNNNN~~N~~~~~!. •••••••• ~~~mmmmD~~~~m 0 Cl ~mIDIDQ"'IDmQmmQIDIDm"'mmm"'mIDm"''''mIDmID'''IDmIDmmID ~ 0:: LL ._ ..c... . ~.ro~o~onMN.o~.~D~.MNNo~p.aR ..-..- "<,:,,, . ..- .~ . . .. .' .. N .. .. "r I 000000000000000000000000000 I ONmr~~O~~~OO~IDIDm~~O~w.~~N~~~~~ OOOOOOO~OOOOQOOOOOOOOOOOOOO OO"rOPOOOOOOO?OO.....-ObODOOD90, 0 QQOOQQO----O-N~mmm_M.DD~~_NM.DD~m~M.DmNNNNNNNNMMMMM sr-: ,.....[1'- r- ~ 1_ t- t....r- 1'- t~ t-..... l"- r- 1'-- I'- t~ h r- I'- t- 1'- t--II'- l'- h- ,..... ~. _._._- . _L __._..__ L I ! . ibit r WILLIAM .1. 5RArTON P.O. Box 30158 Chief of Police los Angeles, Calif.90030 Telephone:. (2:1.3)~85410l TOO: (S77) 175-5273 Ref iI; 2.2.2 I ANTONIO R. VXUAAArGO$A Mayor I I June 2, 2008 I Ms. Michele DiGirolamo Ross Project Msnager Christopher A. Joseph & Associates I 11&49 West Olympic Boulevard Los Angeles, California 90004 I PROJECT TlTLE: Target at Sunset and Westen Dear Ms. DiGirolamo Ross: The proposed project irrvo[yes the Los Angeles Police Department's Hollywood Area. Enclosed are Area crime rates, predominant crimes, response time (0 emergency calls for service, and personnel statistics, which were obtained from Hollywood Area. 1110 Department'sresponse is based on infotmatiolJ received f,om the Area in which the project is Ioceted, Information Technology Division and input from Comniunity Relations Section, Crime Prevention Unit personnel. A project of this size would have-a signific~nt impacton police services in the Hollywood Area, The I Department is available to advise you on crime prevention features appropriate for design of the I property involved in this project The Department bi.rongly recommends developers contact Crime Prevention Unit personnel regal'dhlg these features. ;I Upon completion of the project, you are encouraged to provide the Hollywood Area Commanding Officer with a diagram of each portion of the property. The diagram should include access routes and any additional information that might facilitate police response. Should you have any questions regarding this response, please contact Sergeant Karen Leong, Crime Prevention Unit, Community RelationsSectlon, at (213)485-3134. Very truly yours, WILLIAM J. l.iRAlTON C'F>t !i£....r .... _ ... " . /~'"') DOtJOJS 'G.MIll . R, Lieutenant Officer. ii1 Charge Community Relations Section Office of the Chief of Police Enclosures /l.N EQUAL H4PtQYMENT OI'PORTUN!TY~ AFfH"li\'TlVE A(..JlON EMPLOYER WI/V'VV.LAPDo!:-:Hne .org w'Nw,jolnLAPD.o)tn I j r 1 hi it Los Angele~;CilY CounciL Nanning and Land Use Management Cornmlttee h.l!peat.pf APCC 200S-270:1.SPB-CUB-SPP-SPR,-1A; ENV -2008-14'41-MND n "., rg plans chlogesin.stores Target, the nation's.secpnp..largest listounter after W*Mart, is uavigd'· :..i:nspUmj.iJl,eli:t:~'(m~()~ic~11:neJ3?y,-p?1" shing old stores rather than opening 11,~?~\:geW',?:rle$,,0peri1Pft:~tU~Uer.:ur" oan sl;OJ:esand Joolting. out~ioe tne J-S. fOl: growth, The new store forfOat will begin ,olling out in April and reature "iJr",ced-1lJ.l home furnishing offer- ipg$-I:'~*"$·~t:gr(h:;~7~¥:-s,esti?p:f,rJ,-_p~ti~r: \1,~~:og-{llll~-~i~p:lay~a1)d.S1eJfllghtil1K in the beauty sectIon .. Company officials told investor"! at T'lI'get's analyst meeting in Phlladd- phia Thursday, which Was Webc'''"t, , t.~~tltJ,t's,:_,C~!BTlg~g-eveJ:Y:p}).ry,..of ..~_15 -$tol"ef~t<8:Il1~l~t\~~~zJ.e;~(:tlXIg:p'rof1t-and ~OD VEAL, THe·oRANGE COUNTY P.EGtSTE~ grab market share f)'om rival8. A Thirqeistore op.•ned In thfl.firea M"~k"tplae.l.st fell. The,y s~jd'iJhey will.,xwJ)d $1 billion l'eriQvat.ing 340 D,8, stOrBS whlle 'openhJg -fewer tban ]0 now ones in 1,h~new PFre&'hfood format to ,""ex- AhieriCa, 201(), 'l'hat:s mru:lYfewer than the 58 ,ist!_rw:: •.,g¢n~r;al~rn,~1'9Aa,UqJae, ,store, )"B_~ they opened in the 'tiscal year ending 'rha>; compares with $J.O million to As fot'the smaller "tOl'~3comlng to Jau: 31 and I,he91'in fiscal 20()8; convert such a .s.tnteo,ic:i;cStlperm:ru~~', urban markets, Target phns to test Key in, the renovations will be tho get. tlio concept hi th.",e:xt few ye.rs wll;h el)h~l1ce Bullseye! Beverly Connection Target Footprint Revealed i;f!i')!,"'tl~'f.. ,·~:n'!;);'("ii(*I"f.'''''''llil, 'Thillit~ 14 it ,1\;IC~~dti!l!lWr,\\"Vl;UttlUrll:md~(lll V I I I HiI,; ,.IM"''' .,'v:.:;"" (1M,. f";wiiu,,d. , l!'\·"'·i.i\.;i"i\':'Hl"llfvorhnrlol ! .\'iI~., .,', !;',., 'f," .,' '-''"\,~.~'.,~ (. ;',.' ",.oj ..",,' '.<,0.:1.;_",;. ;.',LIR"d,~~I.J «- j'rcvtous: City of los Angeles June2012 Comment letter No.8 LaMirada Avenue Neighborhood Association Doug Haines P.O.Box93596 LosAngeles, CA90093-0596 Responseto Comment 8-1 This comment is an introductory statement and is acknowledged for the record. Responsesto issues raised are provided below. Responseto Comment 8-2 The commenter states the project's discretionary requests are extensive and precedent setting, that the project as proposed is inconsistent with the requirements of the Vermont/Western Transit Oriented District Area Specific Plan (SNAP)and that the environmental impacts are largely glossed over in the DEIRanalysis. The commenter elaborates on these comments in the remainder of the comment letter. Responsesto issuesraised are provided below. Responseto Comment 8-3 The commenter states that the project is poorly conceived, inappropriate for the location, precedent- setting, and inconsistent with proper land use planning. The commenter elaborates on these comments in the remainder of the comment letter. Responsesto issuesraised are provided below. Responseto Comment 8-4 The commenter states that the project Draft EIRis flawed and inaccurate. The commenter elaborates on these comments in the remainder of the comment letter. Responses to issues raised are provided below. Responseto COl]1ment8-5 The commenter states that the Draft EIR incorrectly characterizes the project site as currently not occupied. The commenter notes that the project site is currently occupied by a clothing store and was also occupied for a time by a holiday-themed store. While the commenter is correct in noting that the project site is currently occupied (as of March 2012) by a clothing store, State CEQAGuidelines Section 15125(a) states that an EIRmust include a description of the existing physical environmental conditions as they exist at the time the Notice of Preparation (NOP)is published, which then normally constitutes the baseline physical conditions by which the lead agency determines whether an impact is significant. The NOPfor the proposed project was published in December, 2010 (Draft EIR,Appendix 1-1). At that time, the existing shopping center buildings were vacant. With only one exception (Traffic, discussed below), all of the Draft EIRanalyses reflect this baseline and do not include any offsets of potential impacts of the proposed project with impacts from existing uses. This approach provided the most conservative analysisof the potential impacts of the proposed project. Inclusion of the existing clothing store use in the analyses,as suggested by the commenter, would have resulted in reduction of the net environmental impacts for the proposed project, as compared to the Draft EIRanalysis. Target at Sunset and Western Ill. Responses to Comments Page111-81 City of Los Angeles June 2012 The one exception from this approach was the traffic study which, in accordance with the procedures of the City of Los Angeles Department of Transportation (LADOT), included credit for traffic generated by the previous CVS!pharmacy use, which was actively generating traffic within the two year period prior to publication of the NOP. However, the Draft EIRalso included an additional analysis of potential traffic impacts without taking credit for the previous use and identified impacts and mitigation measures for this scenario. As such, the analyses presented in the Draft EIR provided the most conservative assessment of the potential impacts of the proposed project and provided more conservative analysis than would have been provided if the current (March 2012) use on the project site were reflected in those analyses. No change to the Draft EIRis necessary. Response to Comment 8-6 The commenter states that the Draft EIRfails to describe land uses located south of the project site. The section of the Draft EIR referred to by the commenter was a general description of surrounding land uses that specifically stated that "additional descriptions and photographs of the land uses surrounding the project site are provided in Section III, Environmental Setting." Section III, Environmental Setting, of the Draft EIR, provides the complete description of all land uses surrounding the project site, including the uses to the south (Draft EIR, page 111-4 and Figure 111-6), and includes full descriptions of all of the uses referred to in the comment. Moreover, the descriptions of these land uses are provided in the relevant technical sections of the Draft EIR. The exclusion of these specific uses from the summary description provided in the Project Description section of the Draft EIR does not impact the conclusions provided in these analyses. No change to the Draft EIRis necessary. Response to Comment 8-7 The commenter states that the Draft EIR fails to acknowledge that the Hollywood Design Review Committee and Hollywood Studio District Neighborhood Council (HSDNC) have rejected the proposed project and that the HSDNC voted to support the project only if all parking is contained in a subterranean garage. While the outcomes of advisory body proceedings may be relevant to the policy decision of whether to approve the project, they are not evidence of environmental impact. Furthermore, the com menter's characterization of these two bodies having "rejected" the proposed project is not entirely accurate. The Hollywood Design Review Committee is an advisory body to the Councilmember of the as" District, which reviews projects, provides opinions and makes recommendations on those projects to the Councilmember. The proposed project was reviewed by this body on October 13, 2011. At this meeting, the members commented on the scale, height and massing of the project and made suggestions concerning the articulation of the building, the articulation, setback, and design of the ground floor retail spaces, and the location of the entrance and public plaza. While the project applicant has not proposed any changes from the design presented to the Committee with respect to height, overall mass, and entrance location for the proposed building, the applicant revised the ground level retail spaces and articulation of the side walls to address some of the issues raised by the Design Review Committee (Draft EIR, Figures IV.B-lO, IV.B-ll and IV.B-12). HSDNC characterized its recommendation as "support", with conditions, for the project in its February 15, 2012 comment letter (see Comment Letter No.6, above). Like the Design Review Committee, the HSDNC reviews development projects within its area, provides opinions, and makes recommendations on those projects. Because HSDNC reviewed the proposed project at its February 13, 2012 meeting, which occurred during the designated review period for the Draft EIR, the Draft EIRcould not reflect the Target at Sunset and Western III. Responses to Comments Page 111-82 Cityof LosAngeles June2012 HSNDC'sopinion and recommendations in this case. Basedon the HSDNC'saction of February 13,2012, the HSDNCwould not support the project as presently proposed because it would not meet their condition that parking be placed underground (see Comment Letter No.6). The advisory opinions of these bodies will be considered by the City's decision makers in determining whether or not to approve the project. Responseto Comment 8-8 The commenter states that the Draft EIRincorrectly describes the location of the Hollywood Freeway (US-lOl) relative to the project site. This typographical error has been corrected in the Final EIR. Responseto Comment 8-9 The commenter states that the Draft EIRincorrectly describes projected employment at the project site under the project, and that inadequate employee parking availability would result in parking impacts in the surrounding neighborhood, especially during peak holiday shopping periods. The projection of 250 full- and part-time jobs (based on a 100-150 person peak shift) at the proposed Target store was provided by the project applicant, Target Corporation (Draft EIR,page IV.A-9), which would operate the store, and is based on extensive experience in operating Target stores nationwide. This estimate is an accurate reflection of the employment levels at a store of the proposed size, whereas the promotional material referred to by the commenter, for which no source is given, does not reflect the expected operating conditions in the proposed project. No change to the employment projections associated with the proposed Target store, as presented in the Draft EIR,is necessary. The commenter also suggeststhat the Draft EIRevaluate employee parking during the holiday periods. The required parking ratio of the Los Angeles Municipal Code (LAMe) is two parking spaces per 1,000 square feet of retail or restaurant uses, or approximately 386 spacesfor the proposed project based on the proposed net floor area. This parking ratio is intended to provide required parking for both customers and employees. The project proposes 458 parking stalls, which exceedsthis requirement by 72 spaces. This is expected to be sufficient to meet the needs of both project visltors and employees. If necessary, Target can make more spaces available for customers during the peak holiday period by tandem parking employee vehicles. By contrast, the Vermont/Western Specific Plan would limit the proposed project to 386 parking spaces, and compliance with this requirement would appear to exacerbate the commenter's concerns regarding parking. Therefore, the proposed project would necessitate a Specific Plan Exception to allow for the additional 72 parking spaces(seeSection IV.G,Land Use/Planning, of this EIRfor further analysis). Responseto Comment 8-10 The commenter states that the Draft EIRdoes not address the removal of the Canary Island Date Palm trees located on the project site's SUnsetBoulevard frontage, and expresses his opinion that the palm trees contribute to the historic character of the neighborhood. As indicated in the Draft EIR(page IV.A- 4), the project would include the removal of all on-site trees, including those referred to by the commenter. As noted in the Draft EIR(page IV.A-4), the project would also include replacement of all existing trees in accordance with the requirements of the City'S Protected Tree Ordinance and City policies regarding mature non-protected trees. The Canary Island Date Palmtrees on Sunset Boulevard adjacent to the project site are not a protected species under the City's Protected Tree Ordinance, but are greater than 8-inches in diameter at breast height. As such, these trees would be replaced at a 1:1 ratio in accordance with City Policy, under the oversight of the Board of Public Works. Moreover, the Target at Sunset and Western II!. Responses to Comments Page111-83 City of LosAngeles June2012 trees referenced by the commenter do not constitute historic resources under CEQA. State CEQA Guidelines Section 15064.5(a) identifies historic resources subject to CEQAas: (1) resources listed in or determined to be eligible for listing in the California Register of Historical Resources; (2) resources included in a local register of historical resources; or (3) resources determined by the lead agency to be significant in the history of California based on substantial evidence. The survey of potential historic resources on and in the vicinity of the project site (Draft EIR,Appendix 1-2)did not identify these trees as potential historic resources based on review of the California Inventory of Historic Resources (CHRIS) and the 2003 Hollywood Redevelopment Project Area historic resource survey. In addition, review of the City of Los Angeles local register of historic resources for the Hollywood Community Plan Area (http://cityplan ning.lacity. org/ com plan/HCM/ dsp_hcm_resu It.cfm ?community=Hollywood, accessed March 19, 2012) indicates that the trees are not designated as a City Historic-Cultural Monument (HCM). Finally, there is no substantial evidence that the trees referenced by the commenter: (1) are associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; (2) are associated with the lives of persons important in our past; (3) embody the distinctive characteristics of a type, period, region, or method of construction, or represent the work of an important creative individual, or possess high artistic values; or (4) have yielded or may be likely to Yield, information important in prehistory or history. Under these criteria, the trees referenced by the commenter do not constitute historic resources under CEQA. As such, no changes to the analyses of biological resources or cultural resources presented in the Draft EIRare necessary. Response to Comment 8-11 The commenter states that the Draft EIRincorrectly describes the height of ICDCCollege and Assistance League of Southern California buildings and the Home Depot parking structure, both located in the Vicinity of the project site. The ICDC College Building is located in the Food 4 Less shopping center immediately east of the project site across Western Avenue. As shown in Figure 111-1,the ICDCbuilding is approximately two stories above ground level in the front (as shown, patrons are required to climb an approximate 10 foot stairway to access the building), and increases to three stories above ground level in the rear due to reduction in the underlying grade over the length of the building. This portion of the ICDC building is located nearest to the southeast corner of the project site. As such, the Draft EIR description of the ICDC building as three stories is accurate. Regardless, the overall height of the buildings within the Food 4 Lessshopping center is comparable to the height of the existing buildings located on the project site, which provides the relevant point of comparison for the analyses presented in the Draft EIR. No change to the Draft EIRis necessary with respect to the ICDCCollege building. The reference to the Assistance League of Southern California building on page 111-4 of the Draft EIRhas been corrected in the Final EIR. As noted by the com menter, the height of this building is correctly shown on page IV.B.l-13 of the Draft EIR. The reference to the Home Depot building on page 111-4 of the Draft EIR has been corrected in the Final EIR. Elsewhere in the Draft EIR, this building is correctly described as "one-story Home Depot home improvement store with rooftop parking" (Draft EIR, page IV.B.1-2). Response to Comment 8-12 The commenter states that the Draft EIRprovides an incomplete list of related projects. The commenter lists two specific projects, the NBC Universal Evolution Plan and the Hollywood Cap Park project as missing from the list of cumulative projects resulting in an inadequate and incomplete cumulative analysis. Target at Sunset and Western III. Responses to Comments Page111-84 View 1: View from the surface parking area looking View 2: View from Western Avenue looking north- south towards the ICDC College building. east towards the ICDC College building. V PHOTO LOCATION MAP I LEco'flerra _,"" _ro" Cityof LosAngeles June2012 The traffic study prepared for the proposed project includes all the relevant cumulative development projects for the future traffic analysisfor the project. The fifty-one (51) projects included in the related projects list (Draft EIR, Table 111-1, page 111-10) represent the complete list of projects that could cumulatively impact the local environment as of the issuance of the NOP, as required under CEQA. In addition, the cumulative impact analysis includes an ambient growth factor of 1 percent per year, as specified by LADOT,in order to account for any smaller or unknown related projects in the project Vicinity. The future conditions scenario was calculated from the existing traffic baseline, based on anticipated related projects and ambient growth in the study area. The NBCUniversal Evolution Plan project (NBCProject) prepared an environmental impact report that was considered in the development of the related project listing for the proposed project. The Draft EIR for this project shows the estimated traffic generated by the project in year 2030 would occur outside of the proposed project traffic study area. No study intersections in the proposed project traffic analysis overlap with the 164 intersections studied in the NBC Project traffic report. The closest Hollywood intersections studied by the NBCProject traffic report are located approximately one mile west of the proposed project along the CahuengaBoulevard corridor. Traffic flow projections prepared for the NBC Project were reviewed and clearly indicate that traffic from the NBC Project would have no traffic impact on the intersections analyzed in the proposed project traffic analysis. Asdocumented in the NBC Project Draft EIR,the potential NBCProject traffic generated in the proposed project study area would be nominal and can be accounted for in the ambient growth projections included in the proposed project cumulative traffic analysis. The Hollywood Cap Park Project is a concept to construct a 44-acre park over a portion of the Hollywood Freeway that is presently in the preliminary planning and conceptual evaluation stages. No environmental review for the Cap Park project has been initiated. No applications to any agencieshave been filed requesting permits and/or approvals. The Hollywood Cap Park project was not included in the related project list for the proposed project traffic analysis because it is in the conceptual stage and the details necessaryfor traffic projections have not been developed. It would be speculative to predict the potential traffic generation, distribution, impacts or mitigation that could be associated with an undefined conceptual project. In addition, the dissolution of the Community Redevelopment Agency of the City of Los Angeles (CRA/LA),the sponsoring agencyfor the CapPark project and a major source of potential funding for the project, and the associated impact on the environmental review of the project creates further uncertainty. Funding decisions for previous CRA/LA projects will be made by a Designated Local Authority (DLA)and Oversight Board,which are constrained by law to fulfilling only previous enforceable obligations of CRA/LA. As a result, it would be highly speculative to assume that both the proposed project and the Hollywood Cap Parkproject could be constructed at the same time, or that the Cap Park would be operational when the proposed project becomes operational. Therefore, cumulative impacts as a result of the CapPark are also speculative. As required by CEQA,the DEIRcumulative impacts analysis includes: (1) the effects of past projects, as part of the environmental baseline; (2) the effects of current projects, included in the related projects list and ambient growth; and (3) probable future projects, also included in the related projects list and ambient growth. No changeto the Draft EIRis necessary. Responseto COl11ment8-13 The commenter states that the Draft EIRincorrectly identifies the ICDCCollege building asthree stories in height. SeeResponseto Comment 8-11. Target at Sunset and Western III. Responses to Comments Page111-86 Cityof LosAngeles June2012 Responseto Comment 8-14 The commenter states that the Draft EIRincorrectly identifies the commercial buildings on the project site asvacant. SeeResponseto Comment 8-5. Responseto Comment 8-15 The commenter states that the Draft EIRincorrectly states that there are no designated State or local scenic highways adjacent to the project site or in the project area and states that Historic Route 66 follows Santa Monica Boulevard through Hollywood. The part of the Draft EIR referenced by the commenter addresses state and locally designated scenic highways. As noted in the Draft EIR(page IV.B.l-ll), the designation of scenic highways is provided by the Caltrans California Scenic Highway Program, and the City of LosAngeles General Plan Transportation Element. The only segment of State Route 2 (of which Santa Monica Boulevard is a part) that is designated as a scenic highway by Caltrans is "from 2.7 miles north of State Route 210 at La Canada to the San Bernardino County line" (source: Officially Designated State Scenic Highways, http://www.dot.ca.gov/hq/LandArch/scenic/schwy.htm. accesses,March 21, 2012). The City of Los Angeles General PlanTransportation Element similarly does not designate any portion of Santa Monica Boulevard as a scenic highway (source: http://cityplanning.lacity.org/cwd/gnlpln/transelt/TEMaps/E_.Scnc.gif , accessed March 21, 2012). Although Route 66 is colloquially referred to as "historic", the portion of Route 66 through Hollywood has no official historic or scenic highway status that requires particular analysisin the EIR. No change to the Draft EIRis necessary. Responseto Comment 8-16 The commenter states that the Draft EIRincorrectly states that expansivescenic views are not available around the project site. The commenter includes a photograph taken from the sidewalk in front of 5528 Fernwood Avenue to support this assertion. While the view from this location is acknowledged, it is taken out of the context of the larger area located to the south of the project site. Figure 111-2provides additional views from public locations along Fernwood Avenue. As shown in these views, if the viewer moves approximately 15 to 20 feet to the right or left of the location shown in the comment, the view to the north becomes blocked by existing buildings and/or vegetation. Similarly, as shown in Figure 111-3,views from further east on Fernwood are similarly blocked. Figure 111-3 also shows a typical view to the north from the De Longpre Avenue which is completely blocked by the project buildings. As such, the only view corridor available from Fernwood Avenue is a narrow (approximately 35 feet wide as measured via Google Earth) corridor along the entire length of Fernwood Avenue (approximately 475 feet in length) that provides views of the Hollywood Hills, including Griffith Observatory, through the project site to the north. Such a narrow viewing area would not constitute an "expansive view", but rather an "intermittent unobstructed view" such as found along Western Avenue and described in the Draft EIR(page IV.B.l-1l). This description would apply to the 5528 Fernwood location as well. The Draft EIRacknowledges that there are locations in the areas located south of the proposed project site where the proposed project could result in intermittent reduction in visual access to the Hollywood Hills and Hollywood sign from public viewing locations and concludes that this impact would be significant and unavoidable (Draft EIR,p. IV.B.1-31). Inclusion of the Griffith Observatory as an additional visual landmark would not change this analysisor conclusion. Target at Sunset and Western 111.Responses to Comments Page111-87 View 1: View from Fernwood Avenue looking north View 2: View from Fernwood Avenue looking north. towards the two-story headquarters of the non- Views to the north are largely blocked by the exist- profit Assistance League of Southern California. ing vegetation. Views to the north from this location and all locations to the west are blocked by this building. View 3: View from Fernwood Avenue looking north towards a vacant property. Views to the north are blocked by existing buildings and PHOTO LOCATION MAP vegetation. Source: ~oTierra Consulting,~arch 20~2. lena Cityof LosAngeles June2012 The commenter also provides a photograph from the second floor of the Covenant House which contains a view of the Hollywood Hills. Views from the Covenant House are discussed in the Draft EIR (page IV.B.1-26)and the potential of blockage of such views is acknowledged but determined to be less than significant because of limitations on the viewing locations and the City of LA CEQAThresholds Guide which does not consider blockage of private views to be a significant impact. Figure 111-4shows the exterior of the Covenant House buildings. While some windows do provide views to the north, most of the existing windows on the north face of the building are covered by trees. This suggeststhat the provision of views is not an integral component of the mission of Covenant House, which is providing servicesto homelessteens. No changeto the Draft EIRanalysisis required. The commenter also includes a photograph with views from the existing surface parking lot on the project site to the Hollywood Hills to the north. The design of the proposed project would preserve these views, which would continue to be available from the public view plazas and circulation areas located on the ground floor, 2"' floor and 3" floor of the project as well as windows and balconies incorporated into the 3" floor retail space for the benefit of customers and employees (Draft EIR, Figures11-3,11-4and 11-5)after project completion. Responseto Comment 8-17 The commenter states that the Draft EIRincorrectly provides a list of design elements that reduce the project's massing and reiterates that the Hollywo~d Design Review Committee has rejected the project design. As set forth in Responseto Comment 8-7, the Hollywood Design Review Committee has not rejected the project. Both the commenter's opinion and the Design Review Committee's advisory suggestions constitute disagreements with the conclusion of the EIR, but do not render the EIR inaccurate or incorrect. This opinion and the Design Review Committee's suggestions will be forwarded to the City's decision makers for consideration when they determine whether or not to approve the project. Responseto Comment 8-18 The commenter states that if the project would remove the Date Palm trees on Sunset Boulevard, the Draft EIRmust evaluate the cultural/historic impacts. SeeResponseto Comment 8-10. Responseto Comment 8-19 The commenter states that the Draft EIRomits reference to the Griffith Park Observatory when listing significant views. See Responseto Comment 8-16. Responseto Comment 8-20 The commenter states that the Draft EIRincorrectly identifies view impacts to the southwest of the project site. The commenter references the photographs of the views through the project site to the north from the south that are provided in Comment 8-16. The section of the Draft EIRreferenced by the commenter addressesviews through the project site to the southwest of the project site [i.e., from locations to the northeast of the project site). This analysiscorrectly notes that no view resources are located in this area that would be blocked for viewers located to the northeast of the project site. No change to the Draft EIRanalysisis necessary. Target at Sunset and Western III. Responses to Comments Page111-89 View 4: View from Fernwood Avenue looking north View 5: View from De Longpre Avenue looking towards a vacant property. Views to the north are north towards the southside of the Project Site. blocked by existing buildings and vegetation. Views to the north are blocked by existing buildings on the Project Site. PHOTO LOCATION MAP Source: Ecolier~~Consulting, Ma~h 2012. View 1: View from Fernwood Avenue looking south View 2: View from Fernwood Avenue looking south towards the Covenant House building showing towards the Covenant House building. This portion blockage of windows by existing vegetation. of the building would afford views to the north. View 3: View from Fernwood Avenue looking south towards the Covenant House building showing blockage of windows by the existing PHOTO LOCATION MAP vegetation. Source;~EcoTierraConsul~g, March 2012. Cityof LosAngeles June2012 Responseto Comment 8-21 The commenter states that the Hollywood Cap Park and NBCUniversal Evolution Plan were incorrectly omitted from the Related Project trip Generation Summary. SeeResponseto Comment 8-12. Responseto Comment 8-22 The commenter states that the Draft EIRincorrectly identifies the height of the development located at the northeast corner of Sunset Boulevard and Western Avenue as 90 feet and incorrectly identifies the height of the Home Depot store as 60 feet. The reference to the mixed use building at the northeast corner of Sunset Boulevard and Western Avenue as 90 feet in height in this instance is a typographical error that has been corrected in the Final EIR. Elsewhere in the Draft EIRthis building is correctly referred to as five stories in height (Draft EIR,page IV.B.1-12). Similarly, the reference to the Home Depot building as 60 feet in height is a typographical error that has been corrected in the Final EIR. Elsewhere in the Draft EIRthis building is correctly referred to as 30 feet in height (Draft EIR, page IV.B.1-12). Asthe analysisand conclusions in the Draft EIRare basedon the correct building heights, no additional changesare required. Responseto Comment 8-23 The comment states that applicable required parking ratio is misstated in the EIR. The Draft EIRstates the correct parking ratio (Draft EIR, page IV.G-79). The required parking ratio of the Los Angeles. Municipal Code (LAMe) for projects located within the Hollywood Redevelopment Project Area is two parking spaces per 1,000 square feet of retail or restaurant uses (LAMC 12.21.A.4(x)(3)), or approximately 386 spaces based on the proposed project net floor area. The project proposes 458 parking stalls, which exceedsthis requirement by 72 parking spaces. The reference on page IV.G-21has been corrected in the Final EIR. The comment also states that parking for the project is controlled by the SNAP-which is correct, but the SNAP would limit the proposed project to 386 parking spaces-and compliance with this requirement would appear to exacerbate the commenter's parking concerns expressed in Comment 8-9. As discussedbelow in Responseto Comment 8-29, the parking supply for the proposed project would accommodate the projected peak parking demand for the project, which occurs on a typical Saturday shopping day. However, the proposed project necessitates a Specific Plan Exception to allow for the additional 72 parking spacesbeyond the maximum allowed under the SNAP(refer to Section IV.G,Land Use,of this EIRfor further analysis). Responseto Comment 8-24 The commenter states that the Draft EIR incorrectly characterizes the project site as vacant. See Responseto Comment 8-5. Responseto Comment 8-25 The commenter expressesan opinion that the Draft EIRincorrectly characterizes the proposed project as a convenient pedestrian friendly shopping center becausethe Target store would be located on the third level. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. However, the proposed project has been designed to connect to the street and pedestrians through the provision of an expansive pedestrian Target at Sunset and Western II!. Responses to Comments Page111-92 Cityof los Angeles June 2012 plaza at the corner of Sunset Boulevard and Western Avenue, which also provides access to the vertical circulation system elements (elevators and escalators) that can be used to access the proposed Target store on the third level of the project. In addition, the project would provide ground floor retail to activate the sidewalks. The project would also provide lS-foot sidewalks on Western Avenue and Sunset Boulevard that will provide easy pedestrian access to the ground floor retail spaces. The project includes numerous other design features that promote walkability in accordance with Goal LU.3 (Draft EIR, pages IV.G-44 and IV.G-45) and Pedestrian Amenities Checklist for Commercial Uses (Draft EIR, pages IV.G-GOand IV.G-Gl) of the Revised Hollywood Community Plan. Response to Comment 8-26 The commenter states that the Draft EIR's statement regarding the proposed project's overall FAR being compatible with surrounding low-rise buildings in the area lacks factual analysis and that a floor area ratio of 1.15:1 is claimed only because the LAMC currently excludes parking facilities from floor area ratio calculations. The commenter states that if the proposed project's above-grade parking were included in determining the actual floor area ratio, the overall FAR would be higher (2.61:1). The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. The statement in the Draft EIRthat the project FAR, which was calculated in accordance with the standards of the LAMC, is compatible with the Community Center designation, is a factual statement. Moreover, parking is not considered part of the floor area of any surrounding buildings. The analysis presented in this section of the Draft EIR deals with functional compatibility with surrounding uses, for which the density of the proposed land use, not its design characteristics, is the relevant factor. The compatibility of the project design with surrounding uses is appropriately evaluated in Section IV.B.l, Visual Quality/Views of the Draft EIR(Draft EIR, pages IV.B.l- 19 through IV.B.1-22). No change to the Draft EIRanalysis is necessary. Response to Comment 8-27 The commenter states his opinion that the Draft EIR incorrectly characterizes the proposed project with respect to land use compatibility with other uses in the area. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. However, the Draft EIR analysis referred to by the commenter deals with the functional compatibility of the proposed project with surrounding land uses. The Draft EIR analysis notes that functional compatibility is defined as the "capacity for adjacent, yet dissimilar land uses to maintain and provide services, amenities and environmental quality associated with such uses. Potentially significant functional compatibility impacts may be generated when a proposed project hinders the functional patterns of use and relationships associated with existing land uses. Patterns of use relate to the interaction and movement of people, goods and/or information." The conclusion presented in the Draft EIRis based on these aspects of the proposed project. In this context, the fact that the proposed project is a commercial project located at a major intersection characterized by commercial uses, would provide efficient access and circulation for itself that would not interfere with the operations of the adjacent commercial uses, and would appropriately provide a project of urban scale and density in place of the existing suburban shopping center located on the project site provides the basis for the conclusion that the proposed project would be functionally compatible with the surrounding commercial development. No change to the Draft EIR analysis is necessary. As discussed in Response to Comment 8-7, the Hollywood Design Review Board did not reject the project. Target at Sunset and Western III. Responses to Comments Page 111-93 Cityof LosAngeles June2012 Responseto Comment 8-28 The commenter states that the Draft EIRinaccurately characterizes the distance between the project site and the Hollywood/Western Metro Rail Red Line station. The distance presented in the Draft EIR was intended as an approximation to indicate that the project site is accessible and within walking distance to the Metro Rail station. The distance used in the Draft EIR has been corrected to the commenter's measurement in the Final EIR. The commenter also states that the Draft EIRprovides no evidence to support the claim that employees will use the Metro subway to commute to work at the project site. The project site has been defined as being located within a transit-accessible area by virtue of its inclusion by the City in the Vermont/Western SNAParea and is consistently treated as such in the Draft EIRanalyses. The fact that the project site is within SCAG'sCompassBlueprint Growth Vision area, which aims to promote development within areas well-served by transit, indicates that regional and local planning policies and principles view the project site and surrounding areas as transit accessible areas. Promoting transit ridership in dense population and employment areas is a consistent theme of the Hollywood Community Plan Update. The additional 402 feet of walking distance indicated by the commenter would not contradict these adopted plans. As such, it is not unreasonable to assume that some of the employees of the proposed project will be able to accessfuture jobs at the project site via the regional transit system. The trip generation associated with the proposed project reflects a trip credit for transit use of 15%, which was considered an appropriate assumption by LADOT,based on its experience with traffic generation associated with projects located in transit station areas throughout the City. Responseto Comment 8-29 The commenter states that the Draft EIRincorrectly characterizes the effect of the proposed parking supply for the project and the effects on vehicle trips. The commenter suggeststhat since the proposed project parking supply would exceed the maximum parking supply permitted by the SNAP,it would be incompatible with the conclusion that the project would be transit- and pedestrian-accessible and therefore would reduce automobile trips. In fact, the two concepts are not incompatible. The proposed project has been designed to achieve a balance between the need to accommodate projected parking demand in order to not impact surrounding neighborhoods and the need, as a project located within an urban area served by a rail transit system, to accommodate accessto the project via travel modes other than the automobile. Many Target stores are located in suburban retail centers with large expansesof surface parking lots that provide parking at a rate of 4 to 5 spacesper 1,000 square feet of retail use. This ratio was the source of the 656 to 820 space estimate for a "typical" Target store. In Southern California, examples of such stores include the following: • 3535 LaCienegaBoulevard, LosAngeles • 2626 Colorado Boulevard, Glendale • 1800 W Empire Avenue, Burbank • 11051 Victory Boulevard, North Hollywood • 20801 Ventura Boulevard, Woodland Hills • 6700 Topanga Canyon Boulevard, CanogaPark 6000 Sepulveda Boulevard, Culver City • 10820 Jefferson Boulevard, Culver City This amount of parking supply provides the upper bound for any proposed Target store. However, Target was concerned in this case that the SNAP's maximum ratio of 2 spaces per 1,000 square feet Target at Sunset and Western !II. Responses to Comments Page111-94 Cityof LosAngeles June2012 would be insufficient to accommodate the demand for parking spaceswithin the project. If this demand cannot be met, potential parking spillover and impacts to the adjacent neighborhood could occur. The proposed Hollywood Community Plan's parking policies seekto provide flexibility asto how parking requirements may be satisfied in order to improve the overall utilization of parking in Hollywood. As discussed below, the proposed project would provide parking supply sufficient to accommodate its typical peak demand. The Community Planalso encouragesthe "pooling" of parking resourcesto serve clusters of uses in Hollywood (Policies M.1.93, M.1.97, M.1.100, M.1.101, M.1.106). To the extent that the proposed project's parking supply exceeds demand, excessspacescould conceivably be available to contribute to such shared parking arrangements, as land uses develop in the vicinity of Sunset and Western in the future. Newer off-street parking ordinances recognize both the necessity of parking and the need to reduce dependence on the automobile by encouraging transit and other alternative transportation modes. The proposed Target retail center can promote pedestrian/transit uses and still provide the proposed 458 parking spaces. Notwithstanding the SNAP,which allows a maximum of 386 parking spaces based on 2 parking spaces per 1,000 square feet for all commercial uses, the peak parking demand for the proposed project was calculated to provide clarifying information regarding the proposed project's potential parking impacts. Moreover, the comment does not appear to take into account that SNAP parking standards for general land use categories, such as commercial, do not necessarilyequate to peak parking demand for specific land useswhich could include office, restaurant, and retail, etc. Data presented by the Institute of Transportation Engineers (ITE) Parking Generation, 4th Edition, publication, shows that a higher parking demand would be associated with the proposed project than the maximum parking supply permitted under SNAP. Using the ITEparking demand values, Saturday peak parking demand for the proposed project would be 531 parking spaces; 2.70 parking spaces per 1,000 square feet for the Target store (442 parking spaces)and 2.87 parking spaces per 1,000 square feet for the remaining ground floor retail and restaurant uses(89 parking spaces). These peak demands do not take into account the project's proximity to transit. The proposed 458 parking spaces for the proposed project represents a 14% reduction from this peak parking demand, which reflects the project location in a transit oriented development area and the project's designfeatures to promote walkability. This reduction would be consistent with the trip reductions used in the proposed project traffic impact study (15%transit trip credit). While the proposed project includes design features to promote pedestrian access, both from the surrounding neighborhoods and from transit patrons, the Draft EIRacknowledges that the proposed project contains automobile-oriented elements that are less consistent with the SNAPthan are the pedestrian-oriented elements (Draft EIR, pages IV.G-77 and IV.G-78). However, because the automobile-oriented elements would not be included at the expense of the pedestrian-oriented elements, the Draft EIRconcludes that the project would not be substantially inconsistent with the policies of the SNAPto promote transit and pedestrian access. As such, the proposed project was designed to provide parking supply at a rate of approximately 2.35 spacesper 1,000 square feet, which would be sufficient to accommodate the anticipated peak parking demand, which would occur on a typical Saturday shopping day as discussed above, and at the same time to provide an appropriate balance between automobile and pedestrian users within the urban setting of the project site. Accordingly, the proposed project is requesting an exception to the SNAPto allow 72 additional parking spacesabove the maximum parking supply permitted under the SNAP. Target at Sunset and Western III. Responses to Comments Page111-95 Cityof LosAngeles June2012 Responseto Comment 8-30 The commenter states that the Draft EIR incorrectly used population, housing and employment estimates from the Draft EIRfor the Hollywood Community Plan Update. The Draft EIRcorrectly reflects the population, housing and employment estimates from the Draft EIRfor the Hollywood Community Plan Update. The analysis referred to by the commenter addressed the consistency of the proposed project with the Regional Comprehensive Plan and Guide objective of supporting provisions and incentives created by local jurisdictions to attract housing growth in job rich subregions and job growth in housing rich subregions. The analysis notes that the Draft Hollywood Community Plan does not reflect any attempt to attract any particular kind of use to locate within the community from outside (Draft EIR,page IV.G-30) and is therefore not applicable. This conclusion was not dependent upon the Community Plan projections as shown. Moreover, the statement that the figures taken from the Draft EIR have been acknowledged in the Hollywood Community Plan Update Final EIRas "grossly inaccurate" is incorrect. The Draft EIRfor the proposed project included the projections of Proposed Plan Reasonable Projected Development (i.e., Plan Capacity) from Table 4.2-2 in the Hollywood Community Plan Update Draft EIR. The Final EIRfor the Community Plan Update revised Table 4.2-2 to include the population and housing data from the 2010 Census,but made no change to the projections of plan capacity contained in that table (Hollywood Community Plan Update, Final EIR,Section 4.0, Corrections and Additions, page 4-4). Furthermore, the Hollywood Community Plan Update Final EIRelaborated that it was appropriate to retain the projected plan capacity figures in the Community Plan Update EIR,notwithstanding the Censusdata and other data provided by commenters on that Draft EIR, in order to promote the Updated Community Plan objectives of Focusing Growth and Preserving Residential Neighborhoods (Hollywood Community Plan Update, Final EIR,Section 3.0, Responsesto Comments, pages 3-4 and 3-5). As such, the projections presented in the Draft EIRremain valid and in conformance with the Hollywood Community Plan Update Final EIR,and no changeto the Draft EIRis necessary. Responseto Comment 8-31 The commenter states that the Draft EIRinaccurately characterizes the jobs provided by the proposed project as consistent with the CompassGrowth Vision principle of enabling prosperity for all people. The commenter claims that the analysis ignores the loss of jobs by employees of the site's pervious retail tenants, specifically grocery workers at the Farm Fresh Ranch Market. The commenter asserts that Target Corporation is a minimum wage, non-union employer with a large contingent of part-time employees. The commenter claims that the Farm FreshMarket was a union employer offering primarily full-time jobs and states that grocery workers in California who belong to the United Food and Commercial workers union earn an average hourly pay of $15.41. The commenter claims that by eliminating such living wage jobs, the proposed minimum wage Target store has reduced the prosperity prospects for area residents, not increased it; that since the proposed Target would include food sales, union wage [positions at nearby grocery chains may also be impacted; and that none of this is analyzed in the Draft EIR. As noted in Responseto Comment 8-5, the enVironmental baseline used in the Draft EIRanalysis reflected the vacant buildings on the project site that existed when the NOPwas issued in December, 2010. The Farm Fresh Ranch Market ceased conducting business on the project site on December 2, 2008, two years before the NOPfor the proposed project was issued. The Draft EIRis not required to address the characteristics of the jobs associated with this use because those jobs did not exist as part of the environmental baseline used for the Draft EIR. The Draft EIRcorrectly characterizes the jobs that would be located on the project site upon completion of the proposed project. The Target at Sunset and Western Ill. Responses to Comments Page111-96 Cityof LosAngeles June2012 proposed project will provide a substantial number of new jobs, consistent with the Compass Growth Vision principle to enable prosperity for all people. No change to the Draft EIRis necessary. Responseto Comment 8-32 The commenter states that the Draft EIRinaccurately characterizes the distance between the project site and the Hollywood/Western Metro station. See Responseto Comment 8-28. Responseto Comment 8-33 The commenter states that the Draft EIRincorrectly characterizes the sidewalk widths adjacent to the project site. The analysis referred to by the commenter suggests that the sidewalks adjacent to the proposed project building would be 10 feet in width, which is incorrect. The project would include 15- foot sidewalks on Sunset Boulevard and Western Avenue, which would be consistent with Policy LU.3-1 of the Updated Hollywood Community Plan, rather than not consistent as indicated in the Draft EIR. This correction will be included in the Final EIR. Responseto Comment 8-34 The commenter questions whether the project would remove the palm trees on Sunset Boulevard. See Response to Comment 8-10. Moreover, Policy LU.3.9 of the Updated Hollywood Community Plan referenced by the commenter encourages the planting of street trees for shade. The replacement of the existing palm trees, which are not known for providing shade, with new landscaping, including trees that provide shade, would be more consistent with this policy than would maintaining the existing trees in place. Respo"se to Comment 8-35 The commenter questions the exclusion of the intersection of Fountain Avenue and Western Avenue from upgrading of signal controllers. The intersection of Fountain Avenue and Western Avenue was not identified as a candidate for signal controller upgrade by LADOTin its review of the project traffic study (see Appendix IV.C-2 of the Draft EIR),because the signal controller had already been upgraded at this location. A proposed mitigation measure at this intersection to widen the east side of Western south of Fountain by five feet in order to provide a northbound right-turn only lane would be inconsistent with the Hollywood Community Plan due to the secondary adverse impact on the sidewalk. As discussed in Responseto Comment 4-2, Hollywood Community Plan policies do not support narrowing of sidewalks to lessthan 15 feet in width and the existing sidewalk width at this intersection is 10 feet. The LADOTSeptember 27, 20llietter only identified the intersections of Hollywood Boulevard/Russell Avenue and Sunset Boulevard/St. Andrews Place as locations where the signal controller upgrade could be accomplished and thus the only locations where such mitigation measures are included (Draft EIR, Mitigation Measure IV.C-2,page IV.C-S7and Mitigation Measure IV.C-G,page IV.C-S8). The references on page IV.G-S2 of the Draft EIR to signal controller upgrades at the intersections of Western Avenue/Santa Monica Boulevard and Wilton Place/Hollywood Boulevard in the Draft EIRare incorrect and have been corrected in the Final EIR. Responseto Comment 8-36 The commenter states that the Draft EIRincorrectly characterizes the significant traffic impacts of the proposed project in the land use policy consistency analysis. The reference in the Draft EIRLand Use Target at Sunset and Western lll, Responses to Comments Page111-97 Cityof LosAngeles June2012 section to the reduction of all traffic impacts to lessthan significant is incorrect and has been corrected in the Final EIR. As noted in Section IV.C,Traffic/Transportation/Parking of the Draft EIR,impacts at two intersections would be significant and unavoidable (Draft EIR,page IV.C-58). Nonetheless, the proposed project would include all traffic signal upgrades identified by LADOTin its September 27, 2011 letter and would thus be consistent with Policy M.1.6 of the Updated Hollywood Community Plan to utilize traffic operations techniques to increase the capacity of the roadway network in response to changing traffic conditions. Responseto Comment 8-37 The commenter states that the Draft EIRincorrectly characterizes the impacts of the proposed project related to the movement of emergency vehicles in the land use policy consistency analysis. The reference in the Draft EIRLand Use section to the reduction of all traffic impacts to less than significant is incorrect and has been corrected in the Final EIR. The movement of emergency vehicles in light of projected traffic conditions is addressed in Sections IV.J.l, Public Services/Police Protection and IV.J.2, PubliCServices/Fire Protection of the Draft EIR. The references in these sections to the reduction of all traffic impacts to lessthan significant are also incorrect and have been corrected in the Final EIR. There is no evidence to suggestthat a series of impacted intersections located approximately one-quarter mile from one another will result in "gridlock" on Western Avenue, as suggested by the commenter. Furthermore, the Draft EIR was provided to LAPDand LAFDfor review. Neither agency expressed concerns regarding the project's impact on response times. Impacts related to emergency response would be lessthan significant. Responseto Comment 8-38 The commenter states that the Draft EIRincorrectly characterizes the neighborhood traffic impacts of the proposed project in the land use policy consistency analysis. Policy M.l.89 of the Revised Draft Hollywood Community Plan does not apply to individual development projects, much less require them to mitigate all neighborhood street impacts. Rather, this policy requires the City to "monitor 'cut- through' traffic patterns and spillover parking from adjacent commercial areas as growth continues over time." The reference in the Draft EIRLandUse section to this policy is incorrect and has been corrected in the Final EIR. Responseto Comment 8-39 The commenter states that the Draft EIRincorrectly characterizes the consistency of the proposed project with City policies related to building massing. The Updated Hollywood Community Plan checklist strategy for scale, height and massing recommends multiple planes, stepbacks and architectural treatments such as recessed windows, columns, moldings and projections. The Draft EIR analysis correctly notes that the proposed project would include such elements as shown in Figures IV.B-10 through IV.B-12,which would be consistent with the strategy as described. No change to the Draft EIR analysis is necessary. As discussed in the Draft EIR(pages IV.G-74 through IV.G-76), the applicant is seeking exceptions from certain SNAP requirements related to upper floor stepbacks, transparent building elements and roof lines. As discussed in the Draft EIR (page IV.G-78), these inconsistencies would not result in impacts to adjacent uses and would not substantially conflict with the principles, intent and goals of the SNAP. Target at Sunset and Western III, Responses to Comments Page111-98 Cityof LosAngeles June2012 .Responseto Comment 8-40 The commenter refers to the City goal of preserving mature trees and states that the Draft EIRdoes not explain the Applicant's intent with respect to the palm trees on Sunset Boulevard. See Responseto Comments 8-10 and 8-34. Responseto Comment 8-41 The commenter states that the Draft EIRincorrectly characterizes the proposed project's consistency with the Hollywood Redevelopment Plan because the project does not comply with applicable design standards. With approval of the requested exceptions, the project will be consistent with the SNAP. See Responseto Comments 8-42 and 8-48. Responseto Comment 8-42 The commenter states that the Draft EIRincorrectly characterizes the proposed project's consistency with the SNAP. The analysisof the proposed project's consistency with various provisions of the SNAPis contained in the Draft EIR at pages IV.G-69 through IV.G-78. Table IV.G-8 analyzes the project's consistency specific development standards and design guidelines, while pages IV.G-77 and IV.G-78 provide an overall review of the proposed project's requested Specific Plan Exceptions from the SNAP with respect to automobile-orientation, building height and mass and design features. In this analysis, all of the proposed deviations from the requirements of the SNAPare analyzed and inconsistencies are identified. Strict consistency with all aspects of a plan is not required in order for a project to be found consistent with a plan. Rather, a project only needs to be consistent with general intent of the plans and not preclude the attainment of the primary intent of the plan. As set forth at Page IV.G-78of the Draft EIR,while the project is seeking exceptions from certain SNAPrequirements, it would not substantially conflict with the principles, intent and goals of the SNAP.Moreover, where a project in the City of los Angeles is not consistent with one or more provisions of a Specific Plan, the Planning and Zoning Code includes a process for pursuing Specific Plan Exceptions to eliminate the inconsistency with respect to any particular project. The Draft EIRanalysis indicates those characteristics of the proposed project for which Specific Plan Exceptions may be required. More importantly for CEQA,however, is identifying environmental impacts that could be associated with the granting of such exceptions. In the case of the proposed project, the granting of exceptions for height could result in aesthetic and view blockage impacts that are addressed in the Draft EIR. However, as noted in the Draft EIR(page IV.G-78),the SNAP anticipates that buildings up to 75 feet in height can be constructed in SubareaC, in mixed-use buildings. For this reason, the Draft EIR properly identifies the inconsistency with the SNAP as not including housing, rather than the height increase, which would be permitted under SNAP, along with the associated aesthetic and view impacts, if the project included housing. As such, the impacts of project height are more appropriately addressed in Section IV.B.l, Aesthetics/Views, of the Draft EIR,rather than as an issue of plan consistency. Viewed from this perspective, the requested Specific Plan Exceptions for the proposed project are properly characterized as minor with respect to plan consistency. Seealso Responseto Comment 8-48. .Responseto C"mment 8-43 The commenter states that the Draft EIRomits an option for a cash payment in lieu of providing child care facilities. The project applicant hascommitted to provide the cash payment in lieu of floor area and play area in accordance with Section 6.G.4 of the SNAP. As such, no exception to the requirements of Target at Sunset and Western Ill. Responses to Comments Page111-99 Cityof los Angeles June 2012 the SNAP would be required in this regard and the project would be consistent with this requirement. The Draft EIRanalysis has been corrected in the Final EIR. Response to Comment 8-44 The commenter states that the Draft EIR inaccurately characterizes the need for delivery services from the proposed Target store. The range of items offered at Target stores can be seen at Target's website (www.target.com). These items fall into the following categories: • Women, men, baby and kids - clothing, shoes, accessories; • Home - bath, bedding, home decor, home appliances, home improvement, kitchen & dining, storage & organization; • Furniture - bathroom, bedroom, entryway, home office, kitchen & dining, living room, lounge seating; • Patio - fire pits & patio heaters, grills & outdoor cooking, lawn & garden, outdoor lighting, patio accessories, patio furniture & sets, patio & outdoor decor; • Electronics - digital cameras & camcorders, cell phones, computers & tablets, GPS & navigation, home phones, iPods & audio, TVs & home theater, video games ... Entertainment - books, movies, music; • Toys - action figures, arts & crafts, building sets & blocks, dolls, dress up & pretend play, games & puzzles, kid's electronics, learning toys, vehicles & radio controls; • Health & Beauty - bath & body, cosmetics, fragrances, hair care, health care, home living aids, oral care, personal care, skin care, spa & massage. In addition, the proposed project Target store would provide food items. The vast majority of these products are small items that are typically carried out of the store in shopping bags. Those items that do not fall into this category (primarily furniture, fire pits & patio heaters,grills & outdoor cooking, patio furniture & sets, TVs & home theater) are available at Target.com for delivery directly to the purchaser, with most, if not all, of these items qualifying for free home delivery (see http://www.target.com/c/50- free-ship/-/N-5qOfx, accessed March 22, 2012). The Draft EIRcorrectly categorizes the proposed project as not consistent with this provision of the SNAP because it would not provide a dedicated delivery service that would be specifically associated with this store alone. No change to the Draft EIR is required. Response to Comment 8-45 The commenter states that the Draft EIR omits mention of a requested exception to permit a zero-foot setback above the roofline for an additional 10 feet of vertical elements. The Draft EIR consistently refers to the height of the proposed project as "maximum height of 74'-4" with architectural features extending to 84"-4" above the lowest grade. The proposed project is consistently analyzed against this description in the Draft EIR. Page IV.G-74 notes that the project would not be consistent with the upper floor step back requirements of the SNAP. While the specific reference provided by the commenter will be added in the Final EIR, it has no bearing on the analyses of the proposed project provided in the Draft EIR. The commenter also implies that the Draft EIR suggests that the mixed use development at the northeast corner of Sunset Boulevard and Western Avenue is 75 feet in height. This was not the intent of the Draft EIR, which only meant to suggest that this project was a mixed use project. The language Target at Sunset and Western III. Responses to Comments Page 111-100 Cityof LosAngeles June2012 has been clarified in the Final EIR. As noted in Responseto Comment 8-22, the correct reference to the height of this building used throughout the Draft EIRis five stories. Responseto Comment 8-46 The commenter states that the Draft EIRomits reference to the requested exception to exceed the maximum parking permitted under the SNAP. The Draft EIRdiscussesthe requested exception from the maximum parking supply permitted by SNAPin Section IV.C,Traffic/Transportation/Parking (page IV.C- 55) and Section IV.G, Land Use (page IV.G-77). See Responseto Comment No. 8-9. No change to the Draft EIRanalysisis required. Responseto Comment 8-47 The commenter states that the Draft EIRanalysis of police protection requirements is inaccurate and offers an inadequate comparative analysis. The information presented in the Draft EIRwith respect to police reporting district and crime statistics was based upon information provided by the Los Angeles Police Department (LAPD)in responseto an earlier version of the proposed project and was attached to the letter contained in Exhibit 3 of the commenter's letter. This environmental setting information turned out to be incorrect and has been corrected in the Final EIR. However, this correction does not affect the analysis and conclusions with respect to the project's potential impact, and no additional changes are required. Deployment and assignment of police officers in the City of LosAngeles is the responsibility of the LAPD, in accordance with the resources allocated to the LAPDby the Mayor and City Council in the annual City budget. The commenter cites the Hollywood Community Plan Update Draft EIR,which cites a National Association of City Managers and Police Department standard in claiming that the Hollywood Community Police station is understaffed by 886 officers. However, the Hollywood Community Plan Update Draft EIRlater goes on to state: "Deployment of police officers to existing stations in the City, however, is based on a number of factors and cannot be precisely calculated based on police-need-per- population standards alone (Hollywood Community Plan Update Draft EIR,page 4.3-9.)" The Hollywood Community Plan Update Draft EIR then describes the LAPD's Patrol Plan process that determines deployment levels in all police stations throughout the City, based on available resources, service needs and projected response times. As such, the number of police officers assigned to the Hollywood Community Police Station represents the optimal deployment in the judgment of the LAPD,within the allocated resource levels. The Police Department represents the largest single departmental budget in the City, 26% of the General Fund in FiscalYear 2011-2012 (City of Los Angeles - Budget Background, FiscalYear 2011-2012). The Los Angeles Police Department has reiterated the positlon it stated in response to the previous project that a project of this size could have a significant impact on police services that would be mitigated through the design features and coordination with the Police Department that is contained in Mitigation Measures IV.J-2and IV.J-3on pagesIV.J.l-10 and IV.J.l-11 of the Draft EIR(seeAppendix B to the Final EIR). Moreover, the project would generate a significant amount of General Fund revenues to the City in the form of sales and property taxes. The City could use these added revenues to enhance police servicesas needed. Responseto Comment 8-48 The commenter states that project approval would result in significant impacts to land use and planning, provides a restatement of the findings necessaryfor the City to approve Specific Plan exceptions, argues Target at Sunset and Western II!. Responses to Comments Page111-101 Cityof LosAngeles June2012 that Specific Plan exceptions are legally equivalent to variances, and then argues that the findings cannot be made. The comment addresses the merits of the requested SNAPexceptions and does not identify any omission or error in the Draft EIR. No response is warranted or appropriate in the Final EIR; however, the comment will be forwarded to the City's decision-makers for consideration. Draft EIRSection IV.G identifies every applicable land use regulation and identifies as inconsistent those policies of the Specific Plan that require exceptions. However, the findings required for Specific Plan exceptions are not thresholds of significance for purposes of CEQAreview. It is not appropriate in CEQA analysis to present the evidence in support of discretionary findings necessary to grant the project approvals. This evidence is currently provided in the land use applications filed with the City Planning Department. The Draft EIRdid not need to evaluate whether evidence supports the requisite findings for granting specific plan exceptions because the applicable threshold of significance relative to consistency with land use regulations is set forth in the City's CEQAThresholds of Significance. (See Section IV.G.3.A.fthe Draft EIR) As set forth in Section IV.G.2.A.iii, Regulatory Setting, there are 6 applicable regional plans and 9 applicable local plans or regulations. The significance of land use impacts is evaluated in part by consistency with all the applicable plans. The Draft EIRapplies all these regional and local plans, policies and regulations to the proposed project and determines that the proposed project is consistent with all or most of each applicable provision. (See Tables IV.G-1 through IV.G-8 and Section IV.G.3.B.iv) Although Specific Plan exceptions are required for the proposed project, this fact alone does not establish a significant land use impact under CEQA. With regard to General Plan and Specific Plan consistency, the City of Los Angeles CEQAthresholds state: The determination of significance levels of impacts of the proposed project related to land use consistency are determined on a case-by-case basis considering the following factors: Whether the proposal is inconsistent with the adopted land use/density designation in the Community Plan, redevelopment plan, or specific plan for the site; Whether the proposal is inconsistent with the General Plan or adopted environmental goals or policies contained in other applicable plans (emphasis added); The City's significance thresholds only require an analysis of consistency with land use/density designations and adopted environmental goals and policies. And with regard to these, the significance of impacts is evaluated on a case-by-casebasisconsidering the factors above. The Draft EIRTable IV.G-8 presents a comprehensive consistency analysis with the Vermont/Western Transit Oriented District Specific Plan - Station Neighborhood Area Plan ("SNAP") Consistency Analysis, and concludes that the proposed project is consistent with the following requirements: • Floor Area Ratio; • Bicycle Parking; • Pedestrian Throughways; • Yards;and • Development Standards& DesignGuidelines (consistent with 31 Standards & Guidelines). Target at Sunset and Western III. Responses to Comments Page111-102 Cityof LosAngeles June 2012 Draft EIR Section IV.G.3.B.iv.lO also thoroughly discusses inconsistencies with SNAP. The Draft EIR concludes that although the project is inconsistent with certain provisions of the SNAP, that these inconsistencies will not result in a significant environmental impact. Response to Comment 8·49 The commenter states his opiruon that the project would have a substantial adverse effect on aesthetics. The commenter bases this assessment on a comparison of the proposed project's height and mass with the existing buildings in the vicinity of the project site. The commenter states his opinion that the proposed project would not match the visual character of the surroundings and would be aesthetically unpleasing. The com menter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. The Los Angeles CfQA Thresholds Guide provides that the determination of significance as to visual quality shall be made on a case-by-case basis, considering the following factors: • The amount or relative proportion of existing features or elements that substantially contribute to the valued visual character or image of a neighborhood, community, or localized area, which would be removed, altered, or demolished; • The amount of natural open space to be graded or developed; • The degree to which proposed structures in natural open space areas would be effectively integrated into the aesthetics of the site, through appropriate design, etc.; • The degree of contrast between proposed features and existing features that represent the area's valued aesthetic image; • The degree to which a proposed zone change would result in buildings that would detract from the existing style or image of the area due to density, height, bulk, setbacks, signage, or other physical elements; • The degree to which a project would contribute to the area's aesthetic value; and • Applicable guidelines and regulations. The Draft EIR evaluated the potential visual impacts of the proposed project in the Draft EIR on pages IV.B.1-20 through IV.B.1-22. The Draft EIR acknowledges that, upon completion, the proposed project would increase the visibility of the project site and would be visually prominent. The project would not remove, alter or demolish any existing features or elements that substantially contribute to the valued visual character or image of a neighborhood, as the site is developed with unremarkable buildings and an asphalt parking lot. Nor would the project develop natural open space. Under the above criteria, the fact that a project may not precisely match the height and mass of certain buildings in the immediate project vlclnitv is not evidence of a significant impact. Rather, the Los Angeles CfQA Thresholds Guide requires an analysis of the degree of contrast between proposed features and existing features that represent the area's valued aesthetic image. In this case, the other buildings cited by the commenter do not represent the area's valued aesthetic image. Moreover, the project includes numerous design features, including a pedestrian-friendly plaza, wide sidewalks, high quality materials, additional landscaping, and green walls, that will positively contribute to the area's aesthetic value. Target at Sunset and Western Ill. Responses to Comments Page 111·103 Cityof LosAngeles June2012 The final factor to be considered is the project's consistency with applicable aesthetic and design guidelines and regulations contained in land use plans for the area. The Draft EIR notes that the proposed project is consistent with the vision of the Hollywood Community Plan, Hollywood Redevelopment Plan and SNAP, which all anticipate increasing urbanization, concentration of development and higher density to occur in this area of the City over time. The SNAPcontemplates the inclusion of 75-foot tall mixed use buildings in this area and the proposed project would replace the existing suburban-style shopping center that is not consistent with this vision. Overall, with the inclusion of design features that would help articulate the building facades and reduce the visual effects of the project's overall mass, the Draft EIR concludes that the potential aesthetic impacts of the proposed project to the visual character of the project area would be lessthan significant. Responseto Comment 8-50 The commenter states that the project significant impact could be mitigated by reduced height, stepping backthe project footprint and designing a storefront with reduced massingand increased articulation. The commenter claims that this was the original proposal for the project. The commenter then cites a representative of Council District 13 as being opposed to this type of design for the project site in comments made in June, 2009. Asnoted throughout the Draft EIR,the proposed project would replace the existing suburban style shopping center with a urban retail center that provides ground level retail and interior parking areas as opposed to expansive surface parking lots and provides height and density on Sunset BOUlevard,consistent with the vision expressed by the Council District representative at that time (no representation is made as to the current position of the Councilmember or Council District office with regard to the proposed project at the present time). Moreover, in addition to the No Project Alternative, the Draft EIRanalyzed three alternatives with reduced height and considered, but rejected as infeasible two others. As set forth in Chapter VI, Alternatives, of the Draft EIR,all three of these reduced height alternatives would reduce, but not avoid the project's significant impacts with respect to views. However, each of these alternatives would meet key project objectives to a lesser extent than the project. Seealso Responseto Comment 8-53. Responseto Comment 8-51 The commenter states an opinion that compatibility of uses requires adherence to the requirements of the Specific Plan. This proposed rule would render incompatible any proposed use that deviates in any way from the Specific Plan. The Draft EIRemploys a more commonly accepted method of determining compatibility-that of functional compatibility with the surrounding neighborhood. Moreover, the SNAP provides a 75-foot height limit for mixed use project. This demonstrates that a 75-foot tall building would not be incompatible with surrounding buildings that may be at a lower height. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the proposed project. Responseto Comment 8-52 The commenter states his opinion that no justification is provided for the requested increase in parking over the maximum permitted by the SNAP. The commenter maintains that the project applicant has claimed that the Home Depot and Food 4 Lessretail areas have excessiveparking supply. This claim is not included in the Draft EIRand, in any event, is not relevant to the parking demand and parking supply associatedwith the proposed project. With respect to these issues,see Responseto Comments 8-9 and 8-29. The analysis in Responseto Comment 8-29 demonstrates that the proposed project's parking Target at Sunset and Western Ill. Responses to Comments Page111-104 Cityof LosAngeles June2012 supply would be sufficient to accommodate the projected peak parking demand at the project, which occurs on a typical Saturdayshopping day. Response to Comment 8-53 The commenter states that the DEIRalternatives analysis omits relevant comparative information as it does not include the alternative of a smaller Target store and ground floor retail. The commenter cites smaller Target stores in West Hollywood (137,500 square feet, existing) and Beverly Connection (100,000 squarefeet, proposed) to support the feasibility of this concept. To be legally sufficient, the consideration of project alternatives in an EIRmust permit informed agency decision-making and informed public participation. The analysis of alternatives is evaluated against a rule of reason. An agency's discretion to choose alternatives for study should be upheld unlessthey are manifestly unreasonable. An EIRneed not consider multiple variations on the alternatives that it does consider. Alternatives are suitable for study in an EIR if they meet the following thresholds: (1) substantially reduce or avoid the project's significant environmental impacts; (2) attain most of the basic project objectives; (3) are potentially feasible; and (4) are reasonable and realistic. Candidate alternatives that do not satisfy these requirements may be excluded from further analysis. Based upon all of these factors, the range of alternatives analyzed in the EIRis reasonable. The Draft EIR considered an alternative to the proposed project (Alternative 1, Single Level Retail Project) that included a smaller Target store (115,000 square feet), along with the ground level retail and restaurant usesthat would be included under the proposed project. A site plan was prepared that included the largest possible Target store that would fit on this site in a single level project, along with the ground floor retail and restaurant uses (Draft EIR,Figure VI-2). This alternative represents the combination of a smaller Target store and the associated retail requested by the commenter. The Draft EIRanalysis concluded that this alternative would not meet the project objectives because it would reduce the range of goods available to serve the community, would not provide the public plaza and pedestrian amenities that are appropriate for the urban location of the project and would have increased environmental impacts from underground construction. As such, this alternative was considered and rejected as infeasible and did not receive further consideration in the analysis of the remainder of the alternatives to the proposed project that were evaluated in the Draft EIR. The smaller Beverly Connection store, which is being retrofitted into an existing building, would achieve the objective of serving the community with a range of goods to an even lesser degree than would this alternative that was considered and rejected as infeasible. The commenter incorrectly states that Public ResourcesCode (PRC)Sections 21002 and 21081 require the lead agencyto approve "the environmentally superior alternative". PRCSection 21002 requires that public agenciesnot approve projects as proposed if "there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects." PRCSection 21081 states that the public agency approving the project must make findings regarding feasible mitigation measures and alternatives. Contrary to the comment, under CEQA Guidelines Section 15364, the determination of feasibility includes consideration of environmental, legal, social, and technological, as well as economic, factors. The analysis presented in the EIR demonstrates that there are no additional feasible mitigation measures or alternatives that would substantially lessen the significant environmental effects of the proposed project, which will provide support for the findings required under PRCSection 21081. Target at Sunset and Western III. Responses to Comments Page111-105 City of LosAngeles June2012 Responseto Comment 8-54 The commenter makes a general statement that the Draft EIR mischaracterizes the environmental impacts of the proposed project such that mitigation measures are made unnecessary,does not support analysis with facts or uses incorrect facts and is lacking in analysis. The comment does not specify particular alleged defects in the Draft EIR, but instead expressesa general conclusion or opinion about the EIR. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. Responseto Comment 8-55 The commenter makes a general statement that the project as proposed would create numerous significant and permanent adverse impacts and as such should not be approved in its current form. The comment does not specify particular alleged defects in the Draft EIR, but instead expresses a general conclusion or opinion about the EIR. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. Responseto Comment 8-56 The commenter requests that the City consider the negative effects of this, and other projects in the neighborhood and requests that the City not certify or recommend for certification the EIR for the' project. The comment does not specify particular alleged defects in the Draft EIR, but instead expresses a general conclusion or opinion about the EIR. The commenter's opinion is acknowledged and will be considered by the City's decision makers in determining whether or not to approve the project. Target at Sunset and Western III. Responses to Comments Page111-106 IV. CORRECTIONS AND ADDITIONS 1. INTRODUCTION This Section presents corrections and additions that have been made to the text of the Draft EIR. These changes include revisions resulting from responses to comments and staff-initiated text changes to provide clarifications to the project description and analysis and to correct non-substantive errors. The revisions are organized by section and page number as they appear in the Draft EIR. Text deleted from the Draft EIR is shown in strilce'~re"gh, and new text is underlined. For corrections resulting from a response to a comment on the documents, references in parentheses refer to the comment letter and comment number. 2. CORRECTIONSAND ADDITIONS TO THE DRAFT EIR a. Section I (Introduction & Summary) 1) Mitigation Measure IV.C-l on page 1-15 of the Draft EIR has been revised to read as follows: IV.C-l. Prior to the issuance of construction permits, the applicant shall prepare Work Area Traffic Control Plans that, at a minimum, shall include: b. Section II (Project Description) !l The first paragraph, first sentence, under the subheading "Access and Parking" on page 11-10 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-8): As previously discussed, regional access to the project site would be provided by the Hollywood Freeway (US-10l) located less than one half mile ea5f west of the project site. c. Section "' (Environmental Setting) 1) The second paragraph, first sentence, under the subheading "Regional Setting" on page III-l.of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-8): Regional access to the project site is provided via the Hollywood Freeway (US-l0l), located less than one half mile ea5f west of the project site, ... 2) The fourth paragraph, first sentence, under the subheading "Surrounding Land Uses" on page 111-4of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-11): A single-story post office and a three stery the Assistance League of Southern California, consisting of one- and two-story buildings, ~ are located to the south of the project site, across De Longpre Avenue. Target at SUnset and Western IV. Corrections and Additions Page IV-l Cityof LosAngeles June2012 3) The fifth paragraph, first sentence, under the subheading "Surrounding land Uses" on page 111-4of the Draft EIRhas been revised to read as follows (refer to Responseto Comment 8-11): To the west of the project site, across St. Andrews Place, is a one-story Home Depot retail ,tare witA aR attaeRee a~ave graee ~ar"iRg ,trHetHre home improvement store with rooftop parking. d. Section IV.B.2 (Aesthetics/Visual Quality & Views) 1) Mitigation Measure IV.B-3on pages1-10and IV.B.1-31of the Draft EIRhas been revised to read asfollows: IV.B-3 The exterior of all buildings and fences shall be free from graffiti when such graffiti is visible from a public street or alley, pursuant to Municipal Code Section 91,,8104.15. e. Section IV.B.2 (Aesthetics/Shade Shadow) 1) Mitigation Measure IV.B-14on pages1-14and IV.B.2-7of the Draft EIRhas been revised to read asfollows: IV.B-14All buildings, parking structures, and signage within the project site shall be prohibited from 2) Mitigation Measure IV.B-15on pages1-14and IV.B.2-7of the Draft EIRhas been revised to read asfollows: IV.B-15 All buildings, parking structures, and signage within the project site shall be prohibited from f. Section IV.C(Traffic/Transportation/Parking) 1) After Table IV.C-Son page IV.C-14, change the heading "Freeway Capacity" to read "Congestion Management Program Facilities" (refer to Responseto Comment 4-2). 2) The first paragraph under the subheading "Congestion Management Program Facilities", on page IV.C-14of the Draft EIRhas been revised to read as follows (refer to Response to Comment 4-2): A project would normally have a significant freeway or CMPArterial Monitoring Station capacity impact if project traffic causesand increase in the demand-to-capacity (D/C) ratio on a freeway segment or freeway on- or off-ramp or CMPArterial Monitoring Station of two percent or more (D/C increase> 0.02) which causesor worsens lOS Fconditions (D/C > 1.00). 3) In Table IV.C-11on page IV.C-43,Intersection 9, Western Avenue & De longpre Avenue, under the column labeled "Future With Project Impact", on the line labeled "PM Peak Hour", the entry has been revised to read: Target at Sunset an.d Western IV. Corrections and Additions to the Draft EIR PageIV-2 Cityof LosAngeles June2012 TSWS:::' 4) The second sentence of the second paragraph under the subheading "Congestion Management Program Review" on page IV.C-S1of the Draft EIRhas been revised to read (refer to Responseto Comment 4-2): The nearest CMP intersection is Santa Monica Boulevard and Western Avenue (CMP Arterial Monitoring Station #61), which is included as study intersection No. 12. S) After the second paragraph under the subheading "Congestion Management Program Review" on page IV.C-S1 of the Draft EIR the following has been added (refer to Responseto Comment 4-2): As shown in Table IV.C-8, the project impact at CMP Arterial Monitoring Station #61 (Santa Monica Boulevard and Western Avenue) under Existing + Project conditions would be an increase in CMA (Ole) of 0.026 with a resulting CMA (Ole) of 0.911 (LOSE). This impact would not exceed the CMP significant impact criteria of a 2 percent (0.02) increase that causes or worsens LOSF. As such the project impact at CMPArterial Monitoring Station #61 would be less than significant. As shown in Table IV.C-11, the project-related impact under Future (201S) Cumulative Traffic Conditions with Project at CMP Arterial Monitoring Station #61 would be an increase in CMA (Ole) of 0.026 with a resulting CI';1Aof 1.100 (LOSF). This level of impact would exceed the CMPsignificant impact criteria of a 2 percent (0.02) increasethat causesor worsens LOSFand impacts at this location would be significant under the CMP. 6) Mitigation Measure IV.C-1on page IV.C-S6of the Draft EIRhas been revised to read as follows: IV.C-l. Prior to the issuance of construction permits, the applicant shall prepare Work Area Traffic Control Plansthat, at a minimum, shall include: • Identification of a designated haul route to be used bVconstruction trucks; • Provide an estimate of the number to _truckstrips and anticipated trips; • Identification of traffic control procedures, emergency access provisions, and construction alternative crew parking locations; • Identification of the on-site location of vehicle and equipment staging;, • Provide a schedule of construction activities;. • Limitations on anv potential lane closures to off-peak travel periods; • Scheduling the deliverv of construction materials during non-peak travel periods, to the extent possible; • Coordinating deliveries to reduce the potential of trucks waiting to unload building materials; and • Prohibiting parking by construction workers on neighborhood streets as determined in conjunction with CitVstaff. 7) After the last bullet in Mitigation Measure IV.C-1on pages 1-16,and IV.C-56of the Draft EIR,the following has been added (refer to Responseto Comments 4-4 and 9-4): Target at Sunset and Western IV, Corrections and Additions to the Draft EIR PageIV-3 Cityof LosAngeles June2012 At least one lane in each direction shall be maintained at all times on St. Andrews Placefor the duration of construction of the proposed project. o Pedestrian access and circulation shall be maintained at all times on the west side of St. Andrews Place for the duration of construction of the proposed project. o In the event of a lane closure, a Work Area Traffic Control Plan approved by LADOTshall be implemented to route traffic around any such lane closures. o The Construction Management Plan shall be implemented with oversight from an independent mitigation monitor. o The project applicant shall provide a community liaison during construction to address traffic concerns at the project site. The name and contact information for the community liaison shall be posted in a location onsite visible to the public. o The project applicant shall coordinate with the Metro Bus Operations Control Special Events Coordinator regarding temporary relocation during construction of bus stops located adjacent to the project site and any other issuesthat could affect bus service in the vicinity of the project site during construction. The project ~ot shall ~oordinate with_other f1)unicipaj busoperators.Ji2D.l', that utilize the same bus stops. 8) Mitigation Measure IV.C-8on page IV.C-58of the Draft EIRhas been revised to read as follows: IV.C-8 Implement a neighborhood traffic calming program to install speed humps along St. Andrews Place between Fountain Avenue and De Longpre Avenue, subject to the approval procedures of LADOT. 9) The following mitigation measure has been included in Table l-t on page 1-18under the column heading "Project Design Features and Mitigation Measures" and under the subheading "Mitigation Measures" on page IV.C-56of the Draft EIR(refer to Response to Comment 4-3): IV.C-9 The following rneasures shall be incorporated into the project to satisfy the requirements of the City's TDM Ordinance (LAMC Section 12.26-)) based on the gross square footage thresholds contained therein:, (a) Development in excess of 25,000 gross sguare feet of floor area: The applicant. shall provide a bulletin board, display case, or kiosk (displaying transportation information) where the greatest number of employees are likely to see it. The transportation inforf1)ation displayed should include, but is not limited to, the following: (1) Current routes and schedulesfor public transit serving the site;, .(2) Telephone numbers for referrals on transportation information including numbers for the regional ridesharing agencyand local transit operations; (3) Rideshari'1g~omotion _materi~.Jl.~_by commuter-oriented organizations; (4) Regional/local bicycleroute and facility informatiQIl; (5) A listing of on-site servicesor facilities which are available for carpoolers, Target at Sunset and Western IV. Corrections and Additions to the Draft E1R PageIV-4 Cityof LosAngeles June2012 vanpoolers, bicyclists, and transit riders. (b) Development in excessof 50,000 gross square feet of floor area: In addition !.'Lthe reg.uirement set forth in paragraph (at..Jb.€.....PJ:.Qjectapplican! shall provide: (1) A designated parking area for employee carpools and vanpools as close as practical to the main pedestrian entrance(s) of the building(s). This area shall include at least ten percent of the parking spaces required for the site. The spacesshall be signed and striped sufficient to meet the..?mployee .!:LemandfOe such spaces. The carpool/vanpool parking area shall be identified on the driveway and circulation plan upon application for a building permit: (2) One permanent, clearly identified (signed and striped) carpool/vanpool ~ing space for the first 50,000 to 100,000 square feet of grossfloor area and one additional permanent, clearly identified (signed and striped) carpool/vanpool parking spacefor any development over 100,000 square feet of gross floor area; (3) Parkingspacesclearly identified (signedand striped) shall be provided in the designated carpool/van pool parking area at any time during the building's occupancy sufficient to meet employee demand for such spaces. Absent such demand, parking spaces within the designated carpool/vanpool parking area may be used by other vehicles: (4) No signed and striped parking spaces for carpool/vanpool parking shall displace any handicapped parking: (5) A statement that preferential carpool/van pool spaces are available on·site and a description of the method for obtaining permission to use such spaces shall be included on the required transportation information board~ (6) A minimum vertical clearance of 7 feet 2 inches shall be provided for all parking spacesand accessways used by vanpool vehicle.s.whenlocat~d within a parking structure: (7) Bicycle parking shall be provided in conformance with Section 12.21A16 of this Code. c) Development in excess of 100,000 square feet of gross floor area. The project applicant shall comply with Paragraphs (a) and (b) above and shall provide: ill A safe and convenient area in which carpool/vanpool vehicles may load and unload passengersother than in their assignedparking area: (2) Sidewalks or other designated pathways following direct and safe routes from the external pedestrian circulation system to each building in the developm~ (3) If determined necessaryby the City to mitigate the project impact, bus stop !mJ:lrovementsshall be provided. The City will consult y;ith the losal bus serv]ce providers in determining appropriate improvements. When locating bus stops and/or planning building entrances, entrances shall be designed to provide safe and efficient accessto nearby transit stations/stops: (4) Safe and convenient accessfrom the external circulation system to bicycle parking facilities on·site. Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV·S Cityof LosAngeles June2012 10) The following mitigation measure has been included in Table 1-1on page 1-18under the column heading "Project Design Features and Mitigation Measures" and under the subheading "Mitigation Measures" on page IV.C-S6of the Draft EIR(refer to Response to Comment 9-3): IV.C-10A dock manager and/or flag person shall be employed to facilitate and assist delivery trucks in accessingthe loading docks. 11) The following sentence has been included after the second sentence in the first paragraph under the subheading "Level of SignificanceAfter Mitigation" on page IV.C-S8 of the Draft EIR(refer to Responseto Comment 4-2): The impact at Western Avenue and Santa Monica Boulevard lcumulati~l'. impact) would also be significant and unavoidable under the CMP. g. Section IV.F(Hydrology and Water Quality) 1) Mitigation Measure IV.F-10on pages 1-30and IV.F-14of the Draft EIRhas been revised to read asfollows: IV.F-10 All vehicle/equipment maintenance, repair, and washing shall be conducted away from storm drains. All major repairs shall be conducted off-site. Drip pans or drop ~ cloths shall be used to catch drips and spills. h. Section IV.G(land Use Planning) 1) The first paragraph, first sentence, on page IV.G-2 of the Draft EIRhas been revised to read asfollows (refer to Responseto Comment 8-22): Northeast of the project site, there is a five-story, mixed-use building a~~r8)'imatel'f gO feet iA height consisting of ground floor commercial uses (a Walgreens drug store) and four floors of multi-family residential uses. 2) The first paragraph; sixth sentence, on page IV.G-2 of the Draft EIRhas been revised to read asfollows (refer to Responseto Comment 8-22): West of the project site is a Home Depot store and associated surface and rooftop parking, approximately W 30 feet in height. 3) The first sentence, under subheading "Parking Requirements" on page IV.G-21 of the Draft EIRhas been revised to read asfollows (refer to Responseto Comment 8-23): ParldAgre~"iremeAI' far EBmmerEialeevelB~meAt are ,"aje6t 10 the PlaAAiAg aAs £aAiAgCBse. P"rs~aAI Ihe PlaAAiAgaAs £OAiAgCBee,eAe ~arl'iAg ,~a(e i, re~"iree fer every 1,gOg ,~"are feel ef (BmmerEial.* The required parking ratio of the LAMC is two parking spaces per 1,000 square feet of retail uses or approximately 386 spacesbased on the proposed net floor area.' , L'Me § lJ.2W)(4)(;}. LAMe § 12.21(A)(4)(x)(3)(2). Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV-6 Cityof LosAngeles June2012 4) Table IV.G-l (Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives) on page IV.G-28 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-l Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives Encourage local jurisdiction's efforts to achieve Consistent: This objective is primarily an economic a balance between the types of jobs they seek objective, not directly related to envir:onmental impacts. to attract and housing prices. Nevertheless, it implicates indirect environmental impacts related to population the location of commercia! uses that generate employment. The Target store and retail/restaurant uses would provide a wide variety of skilled and unskilledjobs, both high-wageand entry-level employment opportunities and career growth opportunities with potential benefits for the regional economy. Furthermore, the proposed project would generally seek to attract jobs located adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red Line (located approximately ±;GOO 1,402 feet north of the project site). The location of the project site within walking distance to a transit station and served by severa! bus lines would provide a broad geographic range in which employees could locate without requiring long vehicle commutes. As such, the proposed project would not result in an imbalance between the character of jobs created and housing prices in the market serving the project employees. Therefore, the proposed project would be consistent with this objective. Encourage existing or proposed local Consistent: The proposed project would concentrate new jurisdictions programs aimed at designing land development and jobs at a greater density than what uses which encourage the use of transit and currently exists within walking distance (approximately thus reduce the need for roadway expansion, ;J"OOll 1,402 feet north of the project site) to the reduce the number of auto trips and vehicle Hollywood/Western station and in close proximity to the miles traveled, and create opportunities for local and regional bus system, thus providing residents to walk and bike. opportunities for employees to use public transit for work trips, and walk to restaurants and shops in close proximity to the proposed project. The proposed project would also provide a nearby shopping opportunity for Hollywood community residents that is currently met by traveling to other communities. The proposed project would also include parking -for bicycles, as well as lockers and showers for proposed project employee use, as required by the LAMe. Target shoppers are expected to use conveniently located transit. Many items available at Target can be carried by pedestrians, transit riders, and even bicvcltsts. A typical Target project elsewhere would provide a higher parking ratio than this project is requiring. A typical Target store of the size proposed would require 656-820 spaces. But a significantly lowered parking ratio than is usually required by Target is being Target at SUnset and Western IV. Corrections and Additions to the Draft EIR PageIV-7 Cityof LosAngeles June2012· Table IV.G-l Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives proposed in order to promote pedestrian uses and transit use-thereby reducing vehicle trips. Therefore, the proposed project would be consistent with this objective. 5) Table IV.G-l (Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives) on page IV.G·29 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-l Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives Encourage local jurisdiction plans that maximize Consistent: The proposed project would provide lnftll the use of existing urbanized areas accessible to development in an urbanized area at a greater density transit through inflll and redevelopment. than what currently exists and would provide jobs that would be accessible to the regional bus and rail transit systems. The proposed project would concentrate new development and jobs at a site adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red Line Hollywood/Western station (located approximately 'l,{lOO 1,402 feet north of the project site), thus providing opportunities for employees to use public transit for work trips, and walk to restaurants and shops adjacent to the proposed project. Therefore, the proposed project would be consistent with this objective. Encourage p!anned development in areas least Consistent: This objective does not specify any partlcular likely to cause adverse environmental impact. environmental impacts. Any sizeable urban infil! project may cause some environmental impacts, but planned urban infi!! projects are the least likely projects to cause· adverse environmental impacts compared to development on undeveloped land or on sites where natural or cultural resources may be impacted. The proposed project would redevelop an underuti!ized site in an already urbanized area adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red Line Hollywood/Western station (located approximately 'l,{lOO 1,402 feet north of the project Site), where new development could take advantage of transit opportunities and utilize existing infrastructure, thereby reducing the likelihood of adverse impacts on transportation, air quality, noise, and public services. Therefore, the proposed project would be consistent with this objective. 6) Table IV.G-l (Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives) on page IV.G-30 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Target at Sunset and Western IV. Corrections and Additions to the Draft ErR PageIV-8 Cityof LosAngeles June2012 Table IV.G-l Project Consistency with Applicable Regional Comprehensive Plan and Guide Objectives Support local jurisdiction's strategies to Consistent: The Hollywood area is served by the Metro establish mixed-use dusters and other transit- subway system and regional and local bus and shuttle oriented developments around transit stations systems. The proposed project would support this and along transit corridors. objective in that it would provide concentrated and increased mixed-retail development and enhanced activity within the project site, where it would be located within walking distance to the Metro Rail Red line Hollywood/Western station (located approximately ±;GOO 1,402 feet north of the project site) with access to the regional transit system. Therefore, the proposed project would be consistent with this objective. '4: Achieve a substantial decrease in the growth of Consistent: The proposed project would concentrate new passenger vehicle trips and vehicle miles development and Jobs at a site adjacent to several Metro traveled in serious, severe, and extreme non- bus lines and within walking distance to LADOT Dash attainment areas. service and the Metro Rail Red line Hollywood/Western station (located approximately ~ 1,402 feet north of the project site), thus providing opportunities for employees to use transit for work trips, and encouraging the use of transit to access other destinations. A typical Target project elsewhere would provide a higher parking ratio than this project is requiring, A typical Target store of the size proposed would require 656-820 spaces. But a significantly lowered parking ratio than is usually required by Target is being proposed in order to promote pedestrian uses and transit use. This in turn would reduce the need for roadway expansion and reduce the number of auto trips and vehicle miles traveled that would otherwise occur. Therefore, the proposed project would be consistent with this objective. 7) The first paragraph, second sentence under subheading "Improve Mobility For All Residents" on page IV.G-33 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): As an infill development, the proposed project's location three blocks south of the Hollywood/Western Metro Center station (located approximately ;t, 8) Table IV.G-3 (Consistency of the Proposed Project with the Applicable Goals of Regional Transportation Plan), on page IV.G-35 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Target at Sunset and Western IV. Corrections and Additions to the Draft E1R PagelV-g Cityof los Angeles June2012 Table IV.G-3 Consistency of the Proposed Project with the Applicable Goals of the Regional Transportation Plan RTP G4: Maximize the productivity of our Consistent: The proposed project would provide infill transportation system. development in an urbanized area at a greater density than what currently exists on the site that would provide accessible to the regional bus and rail transit systems. The proposed project would concentrate new development and jobs at a site within walking distance to the Metro Rail Red Line Hollywood/Western station (located approximately ±,GOO 1,402 feet north of the project site) and served by several Metro bus lines and DASH service, thus providing opportunities for employees to use public transit for work trips, and walk to restaurants and shops within and adjacent to the proposed project. Therefore, the proposed project would be consistent with this goal. 9) Table IV.G-3 (Consistency of the Proposed Project with the Applicable Goals of Regional Transportation Plan), on page IV.G-36 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-3 Consistency of the Proposed Project with the Applicable Goals ofthe Regional Transportation Plan RTP G6: Encourage land use and growth Consistent: The proposed project would provide infltl patterns that complement our transportation development in an urbanized area at a greater density investments. than what currently exists on the site that would provide jobs accessible to the regional bus and rail transit systems. The proposed project would concentrate new development and jobs at a site within walking distance to the Metro Rail Red Line Hollywood/Western station (located approximately ±,GOO 1,402. feet north of the project site) and served by several Metro bus lines and DASH service, thus providing opportunities for employees to use public transit for work trips, and walk to restaurants and shops adjacent to the proposed project. Therefore, the proposed project would be consistent with this goal. 10) Table IV.G-4 (Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of Los Angeles General Plan Framework Element), on page IV.G-37 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV-10 Cityof LosAngeles June2012 Table IV.G-4 Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of los Angeles General Plan Framework Element* Objective 3.2: To provide for the spatial distribution Consistent: The proposed project would provide a of development that promotes an improved quality highly concentrated commercial center including of life by facilitating a reduction of vehicle trips, new development and jobs at a site adjacent to vehicle miles traveled, and air pollution. several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red Line Hollywood/Western station (located approximately ~ 1,402 feet north of the project site), thus providing opportunities for employees, visitors, and local residents to use transit and reduced vehicle trips and VMTs. A typical Target project elsewhere would provide a higher parking ratio than this project is requiring. A typical Target store of the size proposed would require 656~820 spaces. But a significantly lowered parking ratio than is usually required by Target is being proposed in order to promote pedestrian uses and transit use- thereby reducing vehicle trips. Therefore, the proposed project would be consistent with this objective. ' 11) Table IV.G-4 (Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of Los Angeles General Plan Framework Element), on page IV.G-39 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-4 Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of los Angeles General Plan Framework Element* Objective 3.9: Reinforce existing and encourage Consistent. The proposed project would reinforce new community centers, which accommodate a and enhance the existing Community Center, which broad range of usesthat serve the needs of adjacent currently accommodates a broad range of uses and residents, promote neighborhood and community job opportunities and attractions that are, and activity, are compatible with adjacent would continue to be, accessible to the region. The neighborhoods, and are developed to be desirable proposed project would provide an overall FAR of places in which to live, work and visit, both in approximately 1.15:1, which would be compatible daytime and nighttime. with the Community Center designation in the General Plan. The concentration of development adjacent to several Metro bus lines and within walking distance to lADOT Dash service and the Metro Rail Red line Hollywood/Western station (located approximately ~ 1,402 feet north of the project site) would promote the use of public transit for employees and visitors to the project site. Furthermore, the proposed project would serve the adjacent community and has incorporated design features to encourage community activity, including landscaping and a vibrant street frontage for pedestrians. Therefore, the proposed project would be consistent with this Target at Sunset and Western IV. Corrections and Additions to the Draft EIR Pageiv.n Cityof LosAngeles June2012 Table IV.G-4 Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of los Angeles General Plan Framework Element' objective. Goal SA: A livable City for existing and future Consistent. The location of the proposed project residents and one that is attractive to future adjacent to several Metro bus lines and within investment, A City of interconnected, diverse walking distance to LADOT Dash service and the neighborhoods that builds on the strengths of those Metro Rail Red line Hollywood/Western station neighborhoods and functions at both the (located approximately ~ 1.402 feet north of neighborhood and citywide scales. the project site) would support the interconnection of diverse neighborhoods, The Community Center is a multi-use, non-residential center that encourages the ,development of neighborhood- oriented uses. The proposed project supports the policy of creating a livable City for existing and possible future residents. By developing a commercial center on the project site, the proposed project would attract future investment to the area. Therefore, the proposed project would be consistent with this goal. Objective 5.2: Encourage future development in Consistent. The proposed project is located in a centers and in nodes along corridors that are served Community Center in which activity is already by transit and are already functioning as centers for concentrated and it is served by the Metro subway the surrounding neighborhoods, the community, or system and a regional and local bus system. The the region. proposed project would support this objective by providing concentrated development and enhanced activity adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red line Hollywood/Western station (located approximately ~ 1,402 feet north of the project site). Therefore, the proposed project would be consistent with this objective. 12) Table IV.G-4 [Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of los Angeles General Plan Framework Element), on page IV.G-40 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-4 Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of los Angeles General Plan Framework Element' Goal A: Adequate accessibility to work opportunities Consistent. The location of the project site and essential services, and acceptable levels of adjacent to several Metro bus lines and within mobility for all those who live, work, travel, or move walking distance to LADOT Dash service and the goods in LosAngeles. Metro Rail Red line Hollywood/Western station (located approximately ~ :!A91. feet north of the project site) would provide adequate accessibility to work opportunities and acceptable levels of mobility. Furthermore, the development of the proposed project within a Community Target at SUnsetand Western IV. Corrections and Additions to the Draft EIR PageIV-12 Cityof LosAngeles June2012 Table IV.G-4 Consistency of the Proposed Project with the Applicable Objectives and Policies of the City of Los Angeles General Plan Framework Element' Center as well as a primary transit 'corridor served by the Metro subway, Metro bus service, DASH service, and freeways supports meets this objective. Therefore, the proposed project would be consistent with this goal. 13) Table IV.G-S (Comparison of Hollywood Community Plan Objectives to Proposed Project Characteristics), on page IV.G-42 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-S Comparison of Hollywood Community Plan Objectives to Proposed Project Characteristics' Objective 1: To coordinate the development of Consistent. Development of the proposed project would Hollywood with that of other parts of the Cityof Los support continued development of Hollywood as a regional Angeles and the metropolitan area; to further the center because it would provide a three-level commercial retail development of Hollywood as a major center of use with a Target anchor store with incorporated parking, on population, employment, retail services, and Sunset Boulevard and Western Avenue, which are both entertainment; and to perpetuate its image as the considered major and secondary streets, Furthermore, the international center of the motion picture industry. proposed project would support this objective by providing concentrated development and enhanced activity adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red Line Hollywood/Western station (located approximately .:J:..;Q.OO lA02 feet north of the project site). The Proposed Project would be consistent with this objective, Objective 6: To make provision for a circulation Consistent: As discussed in Section IV,( system coordinated with land uses and densities (Traffic/Transportation/Parking) a comprehensive set of and adequate to accommodate traffic; and to transportation improvements have been required of the encourage the expansion and improvement of proposed project to mitigate the potential significant traffic public transportation service. impacts. Furthermore, the location of the project site adjacent to several Metro bus Hnes and within walking distance to LADOT Dash service and the Metro Rail Red Line Hollywood/Western station (located approximately±;llOO 1,402 feet north of the project site) would provide adequate accessibility to work opportunities and acceptable levels of mobility. Furthermore, the development of the proposed project within a Community Center as well as a primary transit corridor served by the Metro subway, Metro bus service, DASH service, and freeways supports meets this objective, Therefore, the proposed project would be consistent with this objective. 14) Table IV.G-G (Comparison of the REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-43 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV-13 City of LosAngeles June2012 Table IV.G-6 Comparison of REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics' Policy lU.2.12: lncentivize jobs and housing growth Consistent: The commercial component of the proposed around transit nodesand alongtransit corridors. project would generate approximately 250 full and part time jobs." The location of the project site adjacent to several Metro bus lines and within walking distance to LADOT Dash service and the Metro Rail Red line Hollywood/Western station (located approximately ~ 1,402 feet north of the project site) would provide adequate accessibility to work opportunities and acceptable levels of mobility. Furthermore, the development of the proposed project within a Community Center as well as a primary transit corridor served by the Metro subway, Metro bus service, DASH service, and freeways supports meets this objective. Therefore, the proposed project would be consistent with this policy. 15) Table IV.G-6 (Comparison of the REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-53 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): Table IV.G-6 Comparison of REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics* Policy M.l.28: Encourage projects located at Consistent: The location of the project site at an intersection intersections served by different transit modes, or located adjacent to several Metro bus lines and within walking intersections which Metro identifies as major distance to LADOT Dash service and the Metro Rail Red line transfer nodes, to provide transit amenities such as Hollywood/Western station (located approximately ~ 1,402 shade trees, countdown crosswalk signals, bus feet north of the project site) would provide adequate shelters, bicycle racks or lockers and stamped accessibility to work opportunities and acceptable levels of crosswalks. mobility. Furthermore, the development of the proposed project within a Community Center as well as a primary transit corridor served by the Metro subway, Metro bus service, DASH service, and freeways supports meets this policy. The proposed Qroiect includes streetscape impTovements1 shade trees and additional landscapin.g and a new Metro bus shelter along Western Avenue. Therefore, the proposed project would be consistent with this policy. 16) Table IV.G-6 (Comparison of the REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-S4 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-28): 3 Target Corporation employee counts, March 2011. Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV-14 City of LosAngeles June2012 Table IV.G-G Comparison of REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics' Policy M.l.39: Provide vehicle ingress and egress to Consistent: The location of the project site adjacent to several project sites that minimize interference with bus Metro bus lines and within walking distance to LADOT Dash traffic, Minimize driveways along streets served by service and the Metro Rail Red line Hollywood/Western station articulated buses. (located approximately J..;OOll 1,402 feet north of the project site) would provide adequate accessibility to work opportunities and acceptable levels of mobility. The main customer vehicle access points to the retail garage would be with a right in/right out access off Western Avenue, a full access driveway off De Longpre Avenue, and an exit only driveway on St. Andrews Place. None of these are located within immediate vicinity of Metro bus line stops. Therefore, the proposed project would be consistent with this policy, 17) Table IV,G-G (Comparison of the REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-44 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-33): Table IV.G-G Comparison of REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics' Policy lU.3.1: Widen sidewalks to a minimum of 15 Net Consistent: All sidewalks would be continuous and straight feet, or maintain existing sidewalk widths of 15 or relatively straight and designed to be able to accommodate feet, along major and secondary highways with high pedestrian flow and provide for pedestrian safety. The levels of pedestrian traffic. Support the adoption of sidewalks 9n the major highways adjacent to SblFF8b1RGiiRgthe Modified Street Standards for the sake of reserving project site (Western Avenue and Sunset Boulevard) will sidewalks which are already wide (is feet or Wider) maintain their current width of approximately 12 feet, which and widening sidewalks which are narrow (less than would be consistenJ with the J~.Q'!l£i.aFeE8AsiGiereGiRarrEl\~Jelf 15feet), GiefiAiti8R iR tRe ReV:!~~QQraft b8FRFAblRity!lIaR. Fl81Never, tl=le eltistiRg siGiewalk width dees R8t impede wallcaeility, In addition, the proposed ground floor retail uses would be designed specifically to accommodate and promote access by pedestrians. 18) Table IV.G-G (Comparison of the REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-52 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-35): Target at Sunset and Western IV. Corrections and Additions to the Draft EIR PageIV·15 City of Los Angeles June 2012 Table IV.G-6 Comparison of REVISED Draft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics' Policy M.1.4: Install Automated Traffic Surveillance Consistent: As discussed in Section IV,C and Control (ATSAC) at all signalized intersections (Traffic/Transportation/Parking) as part of the mitigation, the and all intersections along Major Class 11 and traffic signa! controllers will be upgraded to a type 2070 at the Secondary Highways in Hollywood. intersections of Western Avenue and Hollywood Boulevard R!;lssell '\"eAble, Western ""CAblC ana Sianta MeRica ~e1::l!evare, and Sunset Boulevard and St. Andrews Place, at-1E~Wilten Place aAe Flellyweee ~91::1!9v3re.Therefore, the proposed project would be consistent with this policy. 19) Table IV.G-6 (Comparison of the REVISED Draft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-S2 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-36): Table IV.G-6 Comparison of REVISED Draft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics' Policy M.1.6: Utilize traffic operations techniques to Consistent: As discussed in Section IV.C increase the capacity of the roadway network in (Traffic/T ranSportatlo niP arki ng) a comprehensive set of response to changing traffic volumes. transportation improvements have been required of the proposed project to mitigate the potential significant traffic impacts. Those mitigation measures consist of upgraded traffic Signals, a new' traffic Signal, larger street dedications, on-site and off-site street widening, CCTV cameras, new traffic lanes, new system loop detectors/controllers and pedestrian improvements. As part of the mitigation, the traffic signal controllers will also be upgraded to a type 2070. WitA tA9 if:Ap!eFAeAtati SA 91 ,"e prSFl9see FAitigatien FAeasyres, all signiticant tra#ic iFAFlactswill 99 reablcee ts a level 9t less tAan Significant, Even with implementation of the mitigation measures! im~acts at two intersections would be significant and unavoidable (#11, Western Avenue and Fountain Avenue (Existing + Project imQact); #12/ Western Avenue an_dSanta Monica Boulevard (Future Cumulative + Project imllact!. Nonetheless, t~_e proQosed ~roiect would include all traffic signal upgrades identified by LADOT (refer to Section IV.C ITrafficLTransQortationLParkingH and would thus be consistent with this policy to utilize traffic o~erations technigues to increase the ca~acity of the roadway network in resQonse to changing traffic conditions. Therefore, the proposed project would be consistent with this policy. 20) Table IV.G-6 (Comparison of the REVISED Draft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-S3 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-37): Target at Sunset and Western IV. Corrections and Additions to the Draft E!R Page IV-16 City of LosAngeles June2012 Table IV.G-6 Comparison of REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characteristics* Policy M.l.1S: Maintain the street system to Consistent: As discussed in Section IV.C facilitate the movement of current and future (Traff c/Transportation/Parking) a comprehensive set of traffic volumes, as well as emergency services: transportation improvements have been required of the Support the maintenance and rehabilitation of all proposed project to mitigate the potential significant traffic Highways and Streets impacts. Those mitigation measures consist of upgraded traffic signals, a new traffic signal, larger street dedications, on-site and off-site street widening, (CTV cameras, new traffic lanes, new system loop detectors/controllers and pedestrian improvements. As part of the mitigation, the traffic signal controllers will also be upgradedto a type 2070. Furthermore, increases in traffic would not greatly affect emergency vehicles since the drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using their sirens to dear a path of travel or driving' in the lanes of opposing traffic. Wft.R. tl=le iFA!3!eFAentatieA Sf tl=le f)F9f)9se€l FAitigatien meaSt&Fes, all signifiGi3nt tFa~jE impaGts will se reel::lsee t9 a !el,lel sf less tl=laA 5jgnifiEant, tl=lerelay maintaining the EI::IFFent mevement 01 tra#i€-,. Even with implementation of the mitigation measures/ im~acts at two intersections would be significant and unavoidable (#11, Western Avenue and Fountain Avenue h2roiect imQactl; #12, Western Avenue and Santa Monica Boulevard (~roiect and cumulative imRact). Regardless of these intersectionsl the oQerators of emergency vehicles are ade~t at finding alternate routes in the event of encountering traffic congestion when resQonding to emergencies. Therefore, the proposed project would be consistent with this policy. 21) Table IV.G-6 (Comparison of the REVISEDDraft Hollywood Community Plan Land Use Goals, Policies and Programs to Proposed Project Characteristics), on page IV.G-S4 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-38): Table IV.G-6 Comparison of REVISEDDraft Hollywood Community Plan land Use Goals, Policies and Programs to Proposed Project Characterlstics" Policy M.l.89: Monitor "cut-through" traffic Not Applicable: This Rolley does not appl~ to Rrivate patterns and spillover parking from adjacent develoQment Qroiects. However/ the City does monitor "cut- commercial areas as growth continues over time. though" traffic Qatterns and sQillover Qarking and has imQlemented sQeed humQs on La Mirada Avenue between Western Avenue and Hobart Boulevard! on Serrano Avenue between La Mirada Avenue and Santa Monica Boulevard and on Hobart Boulevard between Santa Monica Boulevard and Fountain Avenue( making even it less likely that Target motorists would use these local neighborhood streets. W<> 5ignifiEant neigl=l9sFI=I8ss imf)aet5 INsuls 9EEl:lr as a result sf traffic generateEf ey the flF9j30seEf preje€t. Therefore, the proposed project would be consistent with this policy. 22) Table IV.G-8 (Vermont/Western Specific Plan Consistency Analysis), on page IV.G-70 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-43): Target at SUnset and Western IV. Corrections and Additions to the Draft E!R PageIV-17 City of Los Angeles June 2012 Table IV.G-8 Vermont/Western Specific Plan Consistency Analysis * Section 6.G. Childcare Facility Requirements: In N-G-t--Consistent. +Ris gt:liseliR8 is !3Fiffiar:::ilt; a Subareas B, C and D, all commercial and Mixed Use E:8FflffHJAity atfl8Ai:j:tt gl:liEieliA8, Ret: Sif8Etly Felat:e€l te Projects, which total 100,000 net square feet or more of 8A¥iF9AFA8Atal iFR!33EtS. +Ae !3F9f:19Sea FlFsjget is non-residential floor area shall include child care r:::8Ejl:lestiRg 3A el~EeFltieR ~FeFA tAis r:::8EjblifeFReAt as tRe facilities to accommodate the child care needs of the FRajsF teA3Rt, +3Fget, t!ff3iEalllf 9985 Rst !3FEwiEle Project employees for pre-school children, including €Rilse3F8, ~qaRY Sf tl=!9 JaG 8FRJ3leyees tRat 1¥91::11E1se infants, and shall meet the following requirements: SF91dgl=lt 9A 1":J1ftRe !3F9!39seEl !3Fejee:t ¥~eI:JIEIse !3a~ tiFAe l. Calculation of Childcare Facility Requirement. eFAfJI91fees aRs we"lo AS;!; ReEe55itate tl=le \:I5ag8 f9F The size of the child care facility necessary to El=lilEiEaF8, If El=li!sEaFe s8FViEes aFe Aeeses, iRsivi9l:1a! accommodate commercial, Mixed Use, Unified eFAf;3ls1fees E8"lo bI:ti!iee a¥ailal3le f3F9ViseFs il=l IAe Hospital Development Site or Replacement In- iFflFFlesiate af:ea, iREI\:IEiiRg IAe beaFRiRg GeR:tE!:FIe, Patient Facilities Project employees' child care ¥9b1Rg GAilo'eR aRs IAe Gl=li!sFeR's GI"13 faGilitie5 needs shall be: one square foot of floor area of asseEis:t8s wilA IAe P ssistaREe beagl:le el §Iel:l:tR8FA an indoor child care facility or facilities, for every Calif9mia aRs leEates iFFlFAeEiiately S91:1:tR9f tRe.j3Fe:jeEt 50 square feet of net, usable non-residential ~ The proposed project will pay the in-lieu cash floor area; or to the satisfaction of the payment as set forth in SNAP Section 6.G.4 to satisfy Commission for Children, Youth and their the Childcare Facility requirements. Families consistent with the purpose in Section G. a. Ground Floor Play Area. In addition to the requirements specified in Subsection G 1 above, the Applicant shall provide outdoor play area per child served by the child care facility as required by the California Department of Social Services, Community Care licensing Division, Title 22. b. Setback and Throughways. The child care play area at a child care facility provided as required by this subsection, on- or off-site, or as an in lieu cash payment, shall count on a one-for-one square foot basis' toward either any building setback requirements of Section 6 l or pedestrian throughways as required in Section 9 G 2. 23) Table IV.G-8 (Vermont/Western Specific Plan Consistency Analysis), on page IV.G-71 of the Draft EIR has been revised to read as follows (refer to Response to Comment 8-45): Table IV.G-8 Vermont/Western Specific Plan Consistency Analysis * Section 9.8. Height and Floor Area: Consistent Regarding FAR; Not Consistent Regarding 1. Commercial Only Project. Projects comprised Height. The proposed project is within the allowed FAR exclusively of commercia! uses (not Hospital and range for a commercial-only project, proposing an FAR Medical Uses) shall not exceed a maximum building of approximately 1.15:1. The height requirement for height of 35 feet and a maximum FAR of 1.5, commercial only developments is not directly related to provided, however, that roofs and roof structures environmental impacts associated with building height. for the purposes specified in Section 12.21.1 B 3 of It is intended to encourage and accommodate mixed- the Code, may be erected up to ten feet above the Use projects. The SNAP would allow the height height limit established in this section, if the proposed by the project if the project included housing. structures and features are set back a minimum of Therefore, the commercial-only height requirement is Target at SUnset and Western IV. Corrections and Additions to the Draft E!R Page IV-18 City of Los Angeles June 2012 Table IV.G·g Vermont/Western Specific Plan Consistency Analysis " ten feet from the roof perimeter and screened from an economic policy designed to encourage housing view at street level by a parapet or a sloping roof. rather than mitigate the physical impacts of 75-foot structures. The proposed project would extend to a height approximately 61'6" feet above Sunset Boulevard, and approximately 74'4" feet above De Longpre Avenue, with architectural and/or equipment elements that could extend to a height approximately 84'4" feet 3SGVe S~R5et Bowlevara as measured above the lowest site grade, which is greater than the maximum height permitted for commercial-only projects. As part of this exception, the proiect applicant is seeking to permit a zero-foot setback above the roofline for the additional 10 feet of vertical elements. The overall programmatic needs of the proposed project, providing neighborhood serving multi-tenant retail along the Sunset Boulevard and Western" Avenue street frontages, providing a plaza at grade level as well as the required pedestrian passageways, providing needed parking spaces and providing a large-scale retail store and providing the needed articulation on the facades of the structure have necessitated a building that is taller than the height allowed by the Vermont/Western Specific Plan. To accommodate these project features, the Target retail store is being proposed on the third level. Along Sunset Boulevard a majority of the top of the building parapet would extend to 61.5 feet above the sidewalk. Along De Longpre Avenue the top of the building parapet would extend to approximately 75 feet above the sidewalk. De Longpre Avenue is approximately six feet lower than Sunset Boulevard; the additional six feet would not be evident to a person on SUnset Boulevard as the lowest grade occurs along De Longpre Avenue. The Target sales floor, located on the third level is set back over 15 feet from the face of the building at the ground level, a setback which exceeds the Vermont/Western Specific Plan requirements of 10 feet. In addition the setback of the sales floor is over 20 feet from the front property line. Thus, from the Sunset Boulevard street level view, the impact of the building height would be minimized. The Vermont/Western Specific Plan does allow for a maximum height of 75 feet for mixed-use projects (eae ~for example, a five-story project that is within thi~ height envelope has been built in the immediate vicinity of the project site at the northeast corner of Sunset Boulevard and Western Avenue) and the requested height is therefore Ret far e6ltsise within the range of height that might be permitted on the site for 5tI-ffi. a similar mixed use project ~hat might be constructed elsewhere in the area. Nevertheless, the proposed project necessitates the granting of a Specific Plan Target at SUnset and Western IV. Corrections and Additions to the Draft E1R Page IV-19 Cityof LosAngeles June2012 Table IV.G-8 Vermont/Western Specific Plan Consistency Analysis * I Exception to allow for the additional height. 24) Table IV.G-8 (Vermont/Western Specific Plan Consistency Analysis), on page IV.G-72 of the Draft EIRhas been revised to read as follows (refer to Response to Comment 8-46): Table IV.G-8 Vermont/Western Specific Plan Consistency Analysis * Section 9.E. Project Parking Requirements: Not Consistent. However, the required parking ratio of 3. Commercial. Notwithstanding the contrary the LosAngelesMunicipal Code (LAMe) is two parking provisions of Section 12.21 A 4 of the Code and ?paces per 1,000 square feet of retail or restaurant regardless of the underlYing zone, the following uses, or approximately. 386" spaces for the proposed parki~g standards shall 'apply to Proiects with project based on the pro.posed net floor area, This commercial uses, other than Hospital and Medical parking ratio is intended to provide required parking for Uses: (i) the maximum number of off~street parking both customers and employees. The project proposes spaces that may be provided shall be limited to two 458 parking stalls, which exceeds this requirement Qy Qarking spaces for each 1.000 square feet C?f 72 spaces in order to accommodate projected peak combined floor area of commercial uses contained parking demand associated with the project. By within all buildings on a lot; (ij) a maximum of 50% contrast, the Vermont/Western Specific Plan would of the required non-:residential spaces may be limit the proposed project to 386 parking spaces. Data providedoff-site, but within 1,500 feet of the lot for Rresented by the Institute of Transportation Engineers which they are proVided. {ITEIin the ParkingGeneration,4th Edition publication, shows a higher parking demanf:! for a discount store !han the maximum parking supply permitted under SNAP. Using the ITE parking demand values for a Saturday, peak parking demand would be 531 parking spaces, comprised of 2.70 parking spaces per 1,000 ~are feet for the Target store (442 parking spaces) and 2.87 parking spaces per 1,000 square feet for the remaining ground floor retail and restaurant uses (89 parking spaces). The proposed 458 parking spaces for the proposed project represents a 14% reduction in this peak parking demand, which would be consistent with the project location in a transit oriented development area and the project's design features to promote walkability. This reduction would be consistent with the trip reductions used in the traffic impact study (15% transit trip credit]. Compliance with the SNAP maximum parking requirement would potentially exacerbate parking overflow into surrounding neighborhoods. Thereforel the proposed project would seek a Specific Plan Exception to allow for the additional 72 parking spaces. i. Section IV.H (Noise) 1) Mitigation Measure IV.H-6 on pages 1-42and IV.H-30 of the Draft EIR has been revised to read as follows: Target at Sunset and Western tv. Corrections and Additions to the Draft EIR PageIV-20 Cityof LosAngeles June 2012 IV.H-6 The project contractor shall use power construction equipment with state-of- the-artass-noise shielding and muffling devices. j. Section IV.J.1 (Public Services-Police Protection) 1) The first paragraph under the subheading "Existing Police Stations" on page IV.J.1-1 of the Draft EIRhave been revised to read as follows (refer to Response to Comment 8-47): The Hollywood Community Police Station, which is under the jurisdiction of the West Bureau, serves a community area encompassing 17.51 square miles, including the project site, and contains a population of approximately 300,000.' The proposed project would be served by the LAPD Hollywood Community Police Station located at 1358 N. Wilcox Avenue, Hollywood, approximately 1.4 miles west of the project site, and within the Hollywood area in Reporting District 668 ~s For the purposes of the LAPD, the Hollywood Community boundaries are defined as: Griffith Park '"A5et 8e"levara to the North, Saffia Meniea Bo"le'la", Melrose Avenue and the Los Angeles City boundary to the South, Mulholland and the Los Angeles City boundary Vie5tern AveA"e to West and Normandie Avenue and Griffith Park to the East. 2) The first paragraph, first sentence and second sentence, under the subheading "Response Times" on page IV.J.1-5 of the Draft EIRhave been revised to read as follows (refer to Response to Comment 8-37): /15 ai5E"55ea iA SeEtieA 1'I.e (TraAs~ertatieA/Traffic/Parking), a#ef inn~lenneAtatieA ef traffiE nnitigati8A Ffleas",es I\'.e 2 tAr8"gh Iv.e 9, sigAificant traffic iFfl~acts will "e f"lIy nnitigatea "a5ea eA esta"lisAea bA[)OT nnetA8gelegies ana tAresA8las. Flewever, The project would result in a significant impact related to access based on the projected operational condition of the Sunset Boulevard/Western Avenue intersection under cumulative plus project traffic conditions. 3) The second paragraph, first sentence and second sentence, under the subheading "Emergency Access" on page IV.J.1-5 of the Draft EIR have been revised to read as follows (refer to Response to Comment 8-37): WAile tAe The proposed project is anticipated to affect vehicle/capacity ratios and the level of service of roadways in the project vicinitv., tAe iFfl~lenneAtatien 8f ~reject s~ecific iAtersectieR aRa ,"asway iFfl~r8venneAts we"la mitigate all ~eteAtially sigAificaAt intersectien innpaEts "a5ea en L~[)OT's esta"lisAea nnetA9aoiegy ans significance thresAela5. Fl8wever, The project would result in a significant impact related to access based on the projected operational condition of the Sunset Boulevard/Western Avenue intersection under cumulative plus project traffic conditions. a Website: http://www./apdonline. org/hollywood _ community_police_station/contenC basic , view/1665, accessed March 30, 2012_'e""er;' 14, 2011. 5 LAPD, Our Communities, Central Bureau, Central Community Police Station, About Central Area, website, http://www.lapdonline,org!centra'_community_po!ice_station!contenCbasic_view!1681, accessed March 30, 2012J-GRlifff)' 14, JQ11. Target at Sunset and Western IV. Corrections and Additions to the Draft EIR Page IV-21 Cityof LosAngeles June 2012 4) Mitigation Measure IV.J-1 on pages 1-47 and IV.J.1-10 of the Draft EIR has been revised to read as follows: IV.J-1 The proposed project contractor shall implement a Construction Management Plan that weHle shall outline provisions for on-site security during construction, which could include, but are not limited to, temporary security fencing, lighting, and providing security personnel to patrol the site. Additionally, the Construction Management Plan WffiIk!-shall ensure emergency access to the project site is maintained at all times during construction through well-marked entrances. k. Section IV.J.l (Public Services-Police Protection) 1) The first paragraph, second sentence and third sentence, under the subheading "Response Distances and Times" on page IV.J.2-6 of the Draft EIR have been revised to read as follows (refer to Response to Comment 8-37): As eisEHssee in SeEtien I'I.G (Trans~ertatien/Tr.#iE/Parking), a.fteF im~lementatien ef traffiE mitigatien me aSHres IV.G 2 tAreHgA I'I.G 9, signifieant tra#iE im~aEts will se fHlly mitigatee sasee en estaslisAee hAQOT metAeeelegies ana tAresAeles. Hewever, The project would result in a significant impact related to access based on the projected operational condition of the Sunset Boulevard/Western Avenue intersection under cumulative plus project traffic conditions. 2) The second paragraph, first sentence and second sentence, under the subheading "Emergency Access" on page IV.J.2-7 of the Draft EIR have been revised to read as follows (refer to Response to Comment 8-37): While the The proposed project is anticipated to affect vehicle/capacity ratios and the level of service of roadways in the project vicinity" the iffi~lementatien el ~rejeEt s~eeifie interseelien ana reaeway im~revements weHla mitigate all ~etentiall\, signili.ant interseetien impa6ts easeEl en hAPOr's estaelisAeEl metheaelegy ana signillean.e thresAelas. Hewever, The project would result in a significant impact related to access based on the projected operational condition of the Sunset Boulevard/Western Avenue intersection under cumulative plus project traffic conditions. 3) Mitigation Measure IV.J-4 on page IV.J.2-8 of the Draft EIR has been revised to read as follows: IV.J-4 The proposed project contractor shall implement a Construction Management Plan that WffiIk!-shall outline provisions for on-site security during construction, which could include, but are not limited to, temporary security fencing, lighting, and providing security personnel to patrol the site. Additionally, the Construction Management Plan shall ensure emergency access to the project site is maintained at all times during construction through well-marked entrances. Target at Sunset and Western IV. Corrections and Additions to the Draft E1R Page IV-22 v. MITIGATION MONITORING AND REPORTING PROGRAM Section 21081.6 of the Public Resources Code requires a Lead Agency to adopt a "reporting or monitoring program for the changesmade 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). The City of Los Angeles Department of City Planning is the Lead Agency for the Target at Sunsetand Western Project. An Environmental Impact Report has been prepared to addressthe potential environmental impacts of the proposed project. Where appropriate, this environmental document identified project design features or recommended mitigation measures to avoid or to reduce potentially significant environmental impacts of the project. This Mitigation Monitoring and Reporting Program (MMRP) is designedto monitor implementation of the mitigation measuresidentified for the project. The MMRP is subject to review and approval by the LeadAgencyas part of the certification of the EIRand adoption of project conditions. The required mitigation measures are listed and categorized by impact area, as identified in the EIR,with an accompanyingidentification of the following: • Monitoring Phase, the phase of the project during which the mitigation measure shall be monitored; o Pre-Construction,including the designphase o Construction o Occupancy(post-construction) • Enforcement Agency,the agencywith the authority to enforce the mitigation measure; and • Monitoring Agency, the agency to which reports including feasibility, compliance, implementation, and development are made. The Project Applicant shall be obligated to provide certification prior to the issuanceof site or building plansthat compliance with the required mitigation measures has been achieved. All departments listed below are within the City of Los Angeles unless otherwise noted. The Project Applicant shall be responsible for implementing all mitigation measuresunlessotherwise noted. IV.A. IMPACTS FOUND TO BE LESSTHAN SIGNIFICANT-BIOLOGICAL RESOURCES IV.A-1. Conduct tree removal activities associated with project development during the non- breeding season(in general, September 1st through January31st); OR Conduct pre-construction surveysfor nesting birds if tree removal activities are to take place during the nesting season (in general, February 1st through August 31st). Pre-construction surveys shall be conducted by a qualified biologist no more than three days prior to the initiation of tree removal activities to confirm presence or absence of active nests. If tree removal activities are delayed, then additional pre-construction surveys shall be conducted such that no more than three days will have lapsed between the survey and tree removal activities. Target at SUnset and Western V. Mitigation Monitoring and Reporting Program PageV-I City of LosAngeles June2012 If no active nests are encountered, no further mitigation would be required following submittal of a survey results letter to the City of los Angeles. However, if active nests are encountered, species-specific measures shall be prepared by a qualified biologist in coordination with the CDFGand other appropriate agencies, and implemented to prevent the direct loss or abandonment ofthe active nest. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.A. IMPACTS FOUND TO BE LESS THAN SIGNIFICANT-CULTURAL RESOURCES IV.A.-2. If unknown archaeological materials are discovered during any grading or construction activity, work in the affected area shall stop and the contractor shall immediately notify the Applicant and the City of Los Angeles. An archaeologist shall be consulted to determine the significance of the discovered artifact(s) and, if necessary, formulate a mitigation plan. Work can resume in the affected area, only with the approval ofthe archaeologist. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.A-3. If paleontological materials are discovered during any grading or construction activity, work in the affected area shall stop and the contractor shall immediately notify the Applicant and the City of Los Angeles. A paleontologist shall be consulted to determine the significance of the discovered fossil materials and, if necessary, formulate a mitigation plan. Work can resume in the affected area, only with the approval of the paleontologist Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B.lo AESTHETICS-VISUAL QUAUTY/VIEWS IV.B-l. All open areas not used for buildings, driveways, pedestrian amenities or walks shall be attractively landscaped and maintained in accordance with a landscape plan, including an automatic irrigation plan, prepared by a licensed landscape architect to the satisfaction of the decision maker. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: City Planning Department Monitoring Agency: Department of Building and Safety IV.B-2. Every building, structure, or portion thereof, shall be maintained in a safe and sanitary condition and good repair, and free from graffiti, debris, rubbish, garbage, trash, overgrown vegetation or other similar material, pursuant to Municipal Code Section 91.8104. Monitoring Phase: Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-2 Cityof LosAngeles June2012 IV.B-3. The exterior of all buildings and fences shall be free from graffiti when such graffiti is visible from a public street or alley, pursuant to Municipal Code Section 91.8104.15. Monitoring Phase: Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-4. On-site signs shall be limited to the maximum allowable under City Code. Monitoring Phase: Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-S. Multiple temporary signs in the store windows and along the building walls are not permitted. Monitoring Phase: Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-6. A landscape plan shall be prepared by a licensed landscape architect to the satisfaction of the decision maker. Monitoring Phase: Pre-Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of Building and Safety IV.B-l. The Applicant shall ensure through appropriate postings and daily visual inspections that no unauthorized materials are posted on any temporary construction barriers or temporary pedestrian walkways, and that such temporary barriers and walkways are maintained in a visually attractive manner throughout the construction period. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-8. The Applicant shall prepare a street tree plan to be reviewed and approved by the City's Department of Public Works, Street Tree Division. All plantings in the public right-of-way shall be installed in accordance with the approved street tree plan. Monitoring Phase: Pre-Construction Enforcement Agency: Department of City Planning Monitoring Agency: Department of Building and Safety IV.B-9. All new sidewalks along the project's street frontages shall be paved with pervious (permeable) concrete or interlocking pavers to create a distinctive pedestrian environment and to increase the opportunity for storm water infiltration on the site. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at SUnset and Western V. Mitigation Monitoring and Reporting Program PageV-3 Cityof LosAngeles June2012 IV.B.Z. AESTHETICS-LIGHT AND GLARE IV.B-10. All lighting related to construction activities shall be shielded or directed to restrict any direct illumination onto property located outside of the project site boundaries that is improved with light-sensitive uses. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-11. Construction hours shall generally be 7:00 AM to 9:00 PM Monday through Friday and 8:00 AM to 6:00 PM Saturday. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-12. Exterior lighting included within the proposed project shall incorporate fixtures and light sourcesthat focus light on-site to minimize light trespass. Monitoring Phase: Pre-construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-13. Proposed project lighting shall comply with LAMC Section 93.0117. As such, proposed project lighting shall not cause more than two footcandles of lighting intensity or direct glare from the light source at any residential property. Monitoring Phase: Pre-construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-14. All buildings, parking structures, and signage within the project site shall be prohibited from using highly reflective building materials such as mirrored glass in exterior facades, Examples of commonly used non-reflective building materials include cement, plaster, concrete, metal, and non-mirrored glass, and would likely include additional materials as technology advancesin the future. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B-1S. All buildings, parking structures, and signagewithin the project site shall be prohibited from using highly reflective building materials such as mirrored glassin exterior facades. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western v. Mitigation Monitoring and Reporting Program PageV-4 Cityof LosAngeles June2012 IV.B-16. The proposed project building shall not include large areas of reflective surfaces that could reflect light from signage into surrounding areas. On-site buildings, signage, or thematic elements shall not incorporate reflective building materials or provide a source of auto headlight-related glare in proximity to glare sensitive uses. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.B.3. AESTHETICS-SHADE/SHADOW No mitigation measures are required. IV.C. TRAFFIC/TRANSPORTATION/PARKING IV.C-l. Prior to the issuance of construction permits, the applicant shall prepare Work Area Traffic Control Plans that, at a minimum, shall include: • Identification of a designated haul route to be used by construction trucks; • Provide an estimate of the number to trucks trips and anticipated trips; • Identification of traffic control procedures, emergency access provisions, and construction aIternative crew parking locations; • Identification of the on-site location of vehicle and equipment staging; • Provide a schedule of construction activities; • Limitations on any potential lane closures to off-peak travel periods; • Scheduling the delivery of construction materials during non-peak travel periods, to the extent possible; • Coordinating deliveries to reduce the potential of trucks waiting to unload building materials; and • Prohibiting parking by construction workers on neighborhood streets as determined in conjunction with City staff. • At least one lane in each direction shall be maintained at all times on St. Andrews Place for the duration of construction of the proposed project. • Pedestrian accessand circulation shall be maintained at all times on the west side of St. Andrews Place for the duration of construction of the proposed project. • In the event of a lane closure, a Work Area Traffic Control Plan approved by lADOT shall be implemented to route traffic around any such lane closures. • The Construction Management Plan shall be implemented with oversight from an independent mitigation monitor. Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-S olLos June2012 • The project applicant shall provide a community liaison during construction to address traffic concerns at the project site. The name and contact information for the community liaison shall be posted in a location onsite visible to the public. • The project applicant shall coordinate with the Metro Bus Operations Control Special Events Coordinator regarding temporary relocation during construction of bus stops located adjacent to the project site and any other issuesthat could affect bus service in the vicinity of the project site during construction. The project applicant shall coordinate with other municipal bus operators, if any, that utilize the same bus stops. Monitoring Phase: Pre-construction Enforcement Agency: LosAngelesDepartment of Transportation Monitoring Agency: Department of Building and Safety IV.C-2. Hollywood Boulevard and Western Avenue: a. Restripe Western Avenue to increase the southbound curb lane from 18 feet to 20 feet in width to facilitate the southbound right-turning traffic on Western Avenue at Hollywood Boulevard (i.e., functional right-turn lane). b. Upgrade the traffic signal controller to a Type 2070 controller at the intersection of Western Avenue and Russell Avenue. c. Install additional system detector loops along both approaches of Hollywood Boulevard and Harvard Boulevard. Monitoring Phase: Pre-constructionand Construction Enforcement Agency: LosAngeles Department ofTransportation Monitoring Agency: LosAngelesBureau of Engineering IV.C-3. SunsetBoulevardand Western Avenue: a. Widen the west side of Western Avenue north of Sunset Boulevard by five feet from north of Sunset Boulevard to approximately 160 feet to allow for the installation of a southbound right-run lane on Western Avenue. The ultimate design of this improvement shall maintain a rrurumum sidewalk/parkway width of 15 feet along the west side of Western Avenue north of Sunset Boulevard, and should provide one left-turn lane, two through lanes, and one right-turn lane in the southbound direction. This is in addition to the intersection improvements required to satisfy the City street standards. b. Install a closed circuit television (CCTV)camera at this intersection. Monitoring Phase: Pre-constructionand Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngelesBureauof Engineering Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV·6 Cityof LosAngeles June2012 IV.C-4. Western Avenue and De LongpreAvenue: a. Install a new traffic signal with a northbound left-turn pocket at the intersection of Western Avenue and DeLongpreAvenue. b. Restripe De Longpre Avenue to include an eastbound left-turn lane and a right-turn lane at its intersection with Western Avenue. Monitoring Phase: Pre-construction and Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Bureau of Engineering IV.C-S. Sunset Boulevard and Van NessAvenu,£: a. Install a CCTVcamera and the necessaryinfrastructure (including fiber optic and interconnect). Monitoring Phase: Pre-construction and Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Bureau of Engineering IV.C-6. Sunset Boulevard and St.Andrews Place: a. Restripe St. Andrews Place on the northbound approach to Sunset Boulevardto accommodate a left-turn lane and a left-thru-right turn lane. b. Upgrade the traffic signal controller at this intersection to a Type 2070 with additional system detector loops along both approaches to Sunset Boulevard and St. Andrews Place. Monitoring Phase: Pre-construction and Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Bureauof Engineering IV.C-7. Wilton Placeand Hollywood Boulevard: a. Install left-turn-only lanes on the northbound and southbound approaches of Wilton Place at Hollywood Boulevard. This would accommodate a left- turn lane and a shared through/right-turn lane on the northbound and southbound approaches. Remove two parking spaces on the west side of Wilton Placenorth of Hollywood Boulevard. Monitoring Phase: Pre-construction and Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Bureau of Engineering IV.C-S. Implement a neighborhood traffic calming program to instaIJ speed humps along St. Andrews Place between Fountain Avenue and DeLongpre Avenue, subject to the approval procedures of LADOT. Monitoring Phase: Pre-construction and Construction Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Bureau of Engineering Target at Sunset and Western V. Mitigation Monitoring and Reporting Program Pagev-r Cityof LosAngeles June2012 IV.C-9. The following measures shall be incorporated into the project to satisfy the requirements of the City's TDM Ordinance (LAMC Section 12.26-J) based on the gross square footage thresholds contained therein: (a) Development in excessof 25,000 gross square feet of floor area: The applicant shall provide a bulletin board, display case, or kiosk (displaying transportation information) where the greatest number of employees are likely to see it. The transportation information displayed should include, but is not limited to, the following: (1) Current routes and schedulesfor public transit serving the site; (2) Telephone numbers for referrals on transportation information including numbers for the regional ridesharing agency and local transit operations; (3) Ridesharingpromotion material supplied by commuter-oriented organizations; (4) Regional/local bicycle route and facility information; (5) A listing of on-site services or facilities which are available for carpoolers, vanpoolers, bicyclists, and transit riders. (b) Development in excessof 50,000 gross square feet of floor area: In addition to the requirement set forth in paragraph (a), the project applicant shall provide: (1) A designated parking area for employee carpools and vanpools as close as practical to the main pedestrian entrance(s) of the building(s). This area shall include at least ten percent of the parking spaces required for the site. The spaces shall be signed and striped sufficient to meet the employee demand for such spaces.The carpool/van pool parking area shall be identified on the driveway and circulation plan upon application for a building permit; (2) One permanent, clearly identified (signed and striped) carpool/van pool parking space for the first 50,000 to 100,000 square feet of gross floor area and one additional permanent, clearly identified (signed and striped) carpool/vanpool parking spacefor any development over 100,000 square feet of gross floor area; (3) Parking spaces clearly identified (signed and striped) shall be provided in the designated carpool/vanpool parking area at any time during the building's occupancy sufficient to meet employee demand for such spaces. Absent such demand, parking spaces within the designated carpool/vanpool parking area may be used by other vehicles; (4) No signed and striped parking spacesfor carpool/vanpool parking shall displace any handicapped parking; (5) A statement that preferential carpool/vanpool spaces are available on-site and a description of the method for obtaining permission to use such spacesshall be included on the required transportation information board; (6) A minimum vertical clearance of 7 feet 2 inches shall be provided for all parking spaces and access ways used by vanpool vehicles when located within a parking structure; (7) Bicycleparking shall be provided in conformance with Section 12.21A16 of this Code. c) Development in excess of 100,000 square feet of gross floor area. The project applicant shall comply with Paragraphs(a) and (b) above and shall provide: (1) A safe and convenient area in which carpool/vanpool vehicles may load and unload passengersother than in their assignedparking area; (2) Sidewalks or other designated pathways following direct and safe routes from the external pedestrian circulation system to each building in the development; Target at Sunset and Western v. Mitigation Monitoring and Reporting Program PageV-8 City of los Angeles June2012 (3) If determined necessary by the City to mitigate the project impact, bus stop improvements shall be provided. The City will consult with the local bus service providers in determining appropriate improvements. When locating bus stops and/or planning building entrances, entrances shall be designed to provide safe and efficient accessto nearby transit stations/stops; (4) Safe and convenient accessfrom the external circulation system to bicycle parking facilities on-site. Monitoring Phase: Pre-construction and Operations Enforcement Agency: LosAngeles Department of Transportation Monitoring Agency: LosAngeles Department of Transportation IV.C-lO. A dock manager and/or flag person shall be employed to facilitate and assist delivery trucks in accessingthe loading docks. Monitoring Phase: Operations Enforcement Agency: LosAngeles Department. of Transportation Monitoring Agency: LosAngeles Department of Transportation IV.D. GEOLOGY & SOilS IV.D-l. The proposed project shall be designed and constructed in accordance with the recommendations provided in a full Geotechnical Study, which shall be approved by the Department of Building and Safety prior to issuanceof building and grading permits. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.E. HAZARDS & HAZARDOUS MATERIALS IV.E-l. In the event that excavation or grading activity on the project site reveals discolored soil or the equipment operator detects odors or fumes emanating from the soil, earth disturbance activity shall cease and an assessmentof the soil shall be conducted at the site to evaluate the potential presence of subsurface contamination as a result of historical on-site uses and proximal off-site facilities that may have impacted the soil, soil vapor, and/or groundwater beneath the site. If environmental conditions exceeding regulatory requirements are identified, remediation shall be accomplished to the satisfaction of the appropriate regulatory agency(ies)shall be completed before earth-disturbing activities may resume. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program Pagev·g Cityof LosAngeles June2012 IV.E-2. The Applicant shall conduct ACM and LBP surveys on all buildings and associated infrastructure scheduled for demolition. If asbestos and/or lead-based paint are detected, they shall be abated and removed in accordance with all applicable federal, state, and local regulations and in accordance with SCAQMD regulations. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F. HYDROLOGY & WATER QUALITY IV.F-l. The proposed project shall be designed and constructed in accordance with the recommendations provided in the geotechnical report (Appendix IV.D-l of the Draft EIR, which may be modified, if necessary as part of final project design). The geotechnical study shall be approved by the Department of Building and Safety prior to issuance of building and grading permits. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-2. The applicant shall maintain all structural or treatment control BMPs for the life of the project. Monitoring Phase: Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-3. All earthwork on the project site shall be performed in accordance with the requirements of the City of Los Angeles Building and Safety, the City of Los Angeles Civil Engineer of Record, and the Storm Water Pollution Prevention Program. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Short-Term Construction Impacts IV.F-4. The proposed project shall implement all SWPPP BMPs listed in Section 3.B.III.1.a of the Hydrology and Water Quality Chapter of the Draft EIR. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-lO of Los June2012 IV.F-S. All waste shall be disposed of properly. Use appropriately labeled recycling bins to recycle construction materials including: solvents, water-based paints, vehicle fluids, broken asphalt and concrete, wood, and vegetation. Non-recyclable materials/wastes shall be taken to an appropriate landfill. Toxic wastes shall be discarded at a licensed regulated disposal site. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety IV.F-6. Leaks, drips, and spills shall be cleaned up immediately to prevent contaminated soil on paved surfacesthat can be washed away into the storm drains. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-7. Shall not hose down pavement at material spills. Dry cleanup methods shall be used whenever possible. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-8. Dumpsters shall be covered and maintained. Place uncovered dumpsters under a roof or cover with tarps or plastic sheeting. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-9. Where truck traffic is frequent, gravel approaches shall be used to reduce soil compaction and limit the tracking of sediment into streets. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of BUildingand Safety Monitoring Agency: Department of Building and Safety IV.F-10. All vehicle/equipment maintenance, repair, and washing shall be conducted away from storm drains. All major repairs shall be conducted off-site. Drip pans or drop cloths shall be used to catch drips and spills. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-11 City of Los Angeles June 2012 Surface Water Runoff/Water Quality Impacts IV.F-ll. Project applicant(s) are required to implement stormwater BMPs to retain or treat the runoff from a storm event producing Yo inch of rainfall in a 24-hour period. The design of structural BMPs shall be in accordance with the Development Best Management Practices Handbook Part B Planning Activities. A signed certificate from a California licensed civil engineer or licensed architect that the proposed BMPs meet this numerical threshold standard is required. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Bureau of Sanitation, Watershed Division Monitoring Agency: Department of Building and Safety IV.F-12. Post development peak stormwater runoff discharge rates shall not exceed the estimated pre-development rates for developments where increased peak stormwater discharge rate will result in increased potential for downstream erosion. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Bureau of Sanitation, Watershed Division Monitoring Agency: Department of Building and Safety IV.F-13. Provide trees and other vegetation at the project site in accordance with SNAP requirements. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Bureau of Street Services, Urban Forestry Division Monitoring Agency: Department of City Planning, Bureau of Street Services IV.F-14. Any connection to the sanitary sewer must have authorization from the Bureau of Sanitation. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Bureau of Sanitation, Wastewater Division Monitoring Agency: Department of Building and Safety IV.F-1S. Any toxic wastes must be discarded at a licensed regulated disposal site. Store trash dumpsters either under cover and with drains routed to the sanitary sewer or use non- leaking and water tight dumpsters with lids. Use drip pans or absorbent materials whenever grease containers are emptied. Wash containers in an area with properly connected sanitary sewer. Monitoring Phase: Pre-construction, Construction, and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-16. Reduce and recycle wastes, including: paper, glass, aluminum, oil, and grease. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program Page V-12 Cityof LosAngeles June2012 IV.F-17. Reduce the use of hazardous materials and waste by: using detergent-based or water-based cleaning systems; and avoid chlorinated compounds, petroleum distillates, phenols, and formaldehyde. Monitoring Phase: Pre-construction, Construction and Occupancy Enforcement Agency: Department of Public Works Monitoring Agency: Department of Building and Safety IV.F-18. Utilize natural drainage systems to the maximum extent practicable. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power, Department of Building and Safety IV.F-19. Control or reduce or eliminate flow to natural drainage systems to the maximum extent practicable. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power, Department of Building and Safety IV.F-20. Protect slopes and channels and reduce run-off velocities by complying with Chapter IX, Division 70 of the Los Angeles Municipal Code and utilizing vegetation (grass, shrubs, vines, ground covers, and trees) to provide long-term stabilization of soil. Monitoring Phase: Pre-construction, Construction, and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Water and Power, Department of Building and Safety IV.F-21. All storm drains inlets and catch basins within the project area must be stenciled with prohibitive language (such as "NO DUMPING - DRAINSTO OCEAN") and/or graphical icons to discourage illegal dumping. Monitoring Phase: Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-22. Signs and prohibitive language and/or graphical icons, which prohibit illegal dumping, must be posted at public access points along channels and creeks with the project area. Monitoring Phase: Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-23. Legibility of stencils and signs must be maintained. Monitoring Phase: Construction and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at SUnset and Western Mitigation Monitoring and Reporting Program PageV-13 Cityof LosAngeles June2012 IV.F-24. Materials with the potential to contaminate stormwater must be: (1) placed in an enclosure such as, but not limited to, a cabinet, shed, or similar stormwater conveyance system; or (2) protected by secondary containment structures such as berms, dikes, or curbs. Monitoring Phase: Construction and Occupancy Enforcement Agency: Bureau of Sanitation, Wastewater Division Monitoring Agency: Department of Building and Safety IV.F-2S. The storage area must be paved and sufficiently impervious to contain leaks and spills. Monitoring Phase: Pre-construction, Construction, and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-26. The storage area must have a roof or awning to minimize collection of storm water within the secondary containment area. Monitoring Phase: Pre-construction, Construction, and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of BUilding and Safety IV.F-27. The owner(s) of the properties will prepare and execute covenant and agreement (Planning Department General form CP-6770) satisfactory to the Planning Department binding the owners to post construction maintenance on the structural BMPs in accordance with the Standard Urban Stormwater Mitigation Plan and/or per manufacturer's instructions. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.F-28. Store trash dumpsters both under cover and with drains routed to the sanitary sewer or use non-leaking and water tight dumpsters with lids. Wash containers in an area with properly connected sanitary sewer. Monitoring Phase: Pre-construction. Construction, and Occupancy Enforcement Agency: Department of BUilding and Safety Monitoring Agency: Department of BUilding and Safety IV.F-29. Incorporate appropriate erosion control and drainage devices, such as interceptor terraces, berms, vee-channels, and inlet and outlet structures, as specified by Section 91.7013 of the Building Code. Protect outlets of culverts, conduits, or channels from erosion by discharge velocities by installing a rock outlet protection. Rock outlet protection is a physical device composed of rock, grouted riprap, or a concrete rubble placed at the outlet of a pipe. Install sediment traps below the pipe-outlet. Inspect, repair, and maintain the outlet protection after each significant rain. Monitoring Phase: Pre-construction, Construction, and Occupancy Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-14 Cityof los Angeles June2012 IV.G. LAND USE PLANNING No mitigation measures are required. IV.H. NOISE IV.H-l. The project shall comply with the City of Los Angeles Noise Ordinance No. 41.40 which restricts construction and demolition activities to the hours of 7:00 AM to 9:00 PM Monday through Friday, and 8:00 AM to 6:00 PM on Saturday. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-2. Construction and demolition activities shall be scheduled so as to avoid operating several pieces of equipment simultaneously, which causes high noise levels. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-3. The use of those pieces of construction equipment or construction methods with the greatest peak noise generation potential shall be minimized to the extent feasible. Examples include the use of drills and jackhammers. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-4. Construction activities whose specific location at the site may be flexible (e.g., operation of compressors and generators, cement mixing, general truck idling) shall be conducted as far as possible from the nearest noise-sensitive land uses, and natural and/or manmade barriers (e.g., intervening construction trailers) shall be used to screen propagation of noise from such activities towards these land uses to the maximum extent possible. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-S. Equipment warm-up areas, water tanks, and equipment storage areas shall be located as far as possible from the surrounding residential uses and the Children's Learning Center. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-6. The project contractor shall use power construction equipment with state-of-the-art noise shielding and muffling devices. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-iS of Los June2012 IV.H-7. The project developer shall install temporary sound curtains of sufficient height to block the lines-of-sight of the construction activities at the project site from the Learning Center for Young Children facility. The sound curtains shall be in place from the commencement of construction activities on the project site until the exterior of the building is constructed and doors are installed. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-8. Two weeks prior to the commencement of construction at the project site, notification must be provided to the Learning Center for Children facility disclosingthe construction schedule, including the various types of activities and equipment that would be occurring throughout the duration of the construction period. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of BUildingand Safety Monitoring Agency: Department of Building and Safety IV.H-9. The project developer shall provide a liaison to coordinate construction activities with the Learning Center for Children facility such that the loudest construction activities would occur during times when children are not napping or outside. In addition, a phone number and contact name shall be provided to the Learning Center for Children for school faculty to call for noise complaints. Monitoring Phase: Pre-construction and Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.H-lO. Existing structure demolition and grading using large bulldozers shall not be permitted within 150 feet of the Learning Center for Young Children except after 4 pm Monday through Friday or anytime on Saturday. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.I. AIR QUALITY IV.1-1. The Project Developer(s) shall implement fugitive dust control measures in accordancewith SCAQMD Rule 403. The Project Developer(s) shall include in construction contracts the control measures required and recommended by the SCAQMDat the time of development. Examples of the types of measures currently required and recommended include the following: Usewatering to control dust generation during demolition of structures or break-up of pavement. Water active grading/excavation sites and unpaved surfaces at least three times daily. Target at SUnset and Western V. Mitigation Monitoring and Reporting Program PageV-16 Cityof LosAngeles June2012 • Cover stockpiles with tarps or apply non-toxic chemical soil binders. • limit vehicle speed on unpaved roads to 15 miles per hour. • Sweep daily (with water sweepers) all paved construction parking areas and staging areas. • Provide daily clean-up of mud and dirt carried onto paved streets from the site. • Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site. Suspend excavation and grading/excavation activity when winds (instantaneous gusts) exceed 15 miles per hour over a 30-minute period or more. • An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessivefugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety IV.I-2. The Project Developer(s) shall implement measures to reduce the emissions of pollutants generated by heavy-duty diesel-powered equipment operating at the project site throughout the project construction phases. The Project Developer(s) shall include in construction contracts the control measures required and recommended by the SCAQMDat the time of development. Examples of the types of measures currently required and recommended include the following: • Keep all construction equipment in proper tune in accordance with manufacturer's specifications. • Use late model heavy-duty diesel-powered equipment at the project site to the extent that it is readily available in the South Coast Air Basin(meaning that it does not have to be imported from another air basin and that the procurement of the equipment would not cause a delay in construction activities of more than two weeks). • Limit truck and equipment idling time to five minutes or less. • Rely on the electricity infrastructure surrounding the construction sites rather than electrical generators powered by internal combustion enginesto the extent feasible. Monitoring Phase: Construction Enforcement Agency: Department of Building and Safety Monitoring Agency: Department of Building and Safety Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-17 Cityof LosAngeles June2012 IV.J.1. PUBLIC SERVICES-POLICE PROTECTION IV.J-l. The proposed project shall implement a Construction Management Plan that shall outline provisions for on-site security during construction, which could include, but are not limited to, temporary security fencing, lighting, and providing security personnel to patrol the site. Additionally, the Construction Management Plan shall ensure emergency access to the project site is maintained at all times during construction through well-marked entrances. Monitoring Phase: Pre-Construction and Construction Enforcement Agency: los Angeles Police Department Monitoring Agency: los Angeles Police Department, Department of Building and Safety IV.J-2. The proposed project shall comply with the design guidelines outlined in the LAPDDesign Out Crime Guidelines, which recommend using natural surveillance to maximize visibility, natural access control that restricts or encourages appropriate site and building access, and territorial reinforcement to define ownership and separate public and private space. Specifically, the proposed project would: • Provide on-site security whose duties shall include but not be limited to the following: • Monitoring entrances and exits; • Managing and monitoring fire/life/safety systems; and • Controlling and monitoring activities in the parking facilities. • Install security industry standard security lighting at recommended locations including parking structures, pathway options, and curbside queuing areas; • Install closed-circuit television at select locations including (but not limited to) entry and exit points, loading docks, public plazasand parking areas; • Provide adequate lighting of parking structures, elevators, and lobbies to reduce areas of concealment; • Provide lighting of building entries, pedestrian walkways, and public open spacesto provide pedestrian orientation and to clearly identify a secure route between parking areas and points of entry into buildings; • Designpublic spacesto be easily patrolled and accessedby safety personnel; • Design entrances to, and exits from buildings, open spaces around buildings, and pedestrian walkways to be open and in view of surrounding sites; and • limit visually obstructed and infrequently accessed"dead zones." Monitoring Phase: Pre-Construction, Construction, and Occupancy Enforcement Agency: los Angeles Police Department Monitoring Agency: Department of Building and Safety Target at Sunset and Western v. Mitigation Monitoring and Reporting Program PageV-iS Cityof LosAngeles June2012 IV.J-3. Prior to the issuance of a certificate of occupancy for each construction phase and on-going during operations, the Applicant or its successor shall develop an Emergency Procedures Plan to address emergency concerns and practices. The plan shall be subject to review by LAPD. Monitoring Phase: Pre-Construction, Construction, and Occupancy Enforcement Agency: LosAngeles Police Department Monitoring Agency: Department of Building and Safety IV.J.2. PUBLIC SERVICES-FIRE PROTECTION IV.J-4. The proposed project shall implement a Construction Management Plan that shall outline provisions for on-site security during construction, which could include, but are not limited to, temporary security fencing. lighting, and providing security personnel to patrol the site. Additionally, the Construction Management Plan shall ensure emergericy access to the project site is maintained at all times during construction through well-marked entrances. Monitoring Phase: ,Pre-Construction and Construction Enforcement Agency: Los Angeles Fire Department Monitoring Agency: Los Angeles Fire Department, Department of Building and Safety IV.J-5. The proposed project shall comply with all State and local building codes relative to fire protection, safety, and suppression. Specifically, the project design shall incorporate the standards and requirements as set forth by: Title 24, the City of Los Angeles Safety Element, the LAMC Fire Code, and any additional code requirements established by the LAFDrelative to fire prevention, safety, suppression, and emergency access and response. Monitoring Phase: Pre-Construction and Construction Enforcement Agency: LosAngeles Fire Department Monitoring Agency: LosAngeles Fire Department IV.J-6. The project applicant shall submit a plot plan for approval of access and hydrants by the LAFD prior to the issuance of a building permit by the City. The plot plan shall include fire prevention and access features to the satisfaction of the LAFD, including the following standard requirements: Access for Fire Department apparatus and personnel to and into all structures shall be required. Any required Fire Annunciator panel or Fire Control Room shall be located within 50 feet visual line of site of the main entrance stairwell or to the satisfaction of the LAFD. • Any required fire hydrants to be installed shall be fully operational and accepted by the LAFDprior to any building occupation. • All water systems and roadways are to be improved to the satisfaction of the LAFD prior to any building occupation. • All structures shall be fully sprinkle red pursuant to LAMC Section 57.09.07(A). Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV-19 of Los June 2012 • No building or portion of a building shall be constructed more than 150 feet from the edge of a roadway of an improved street, access road, or designated fire lane. • No building or portion of a building shall be constructed more than 300 feet from an approved fire hydrant. Distance shall be computed along the path of travel. Monitoring Phase: Pre-Construction Enforcement Agency: los Angeles Fire Department Monitoring Agency: los Angeles Fire Department IV.K.1. UTILITIES-SEWER IV.K-l. As part of the normal construction/building permit process, the Applicant or its successor shall confirm with the City that the capacity of the local and trunk lines are sufficient to accommodate the proposed project's sewer flows during the construction and operation phases. Monitoring Phase: Pre-Construction Enforcement Agency: Bureau of Sanitation, Wastewater Division Monitoring Agency: Department of Building and Safety IV.K-2. The proposed project shall implement any upgrades to the sewer system serving the proposed project that could be needed to accommodate the Project's sewer generation. Monitoring Phase: Pre-Construction and Construction Enforcement Agency: Bureau of Sanitation, Wastewater Division Monitoring Agency: Department of Building and Safety IV.K.2. UTILITIES-WATER No mitigation measures are required. IV.K.3. UTILITIES-SOLID WASTE No mitigation measures are required. IV.K.4. UTILITI ES-ElECTRICITY No mitigation measures are required. IV.K.S. UTILITIES-NATURAL GAS No mitigation measures are required. IV.L GREENHOUSE GASES/GLOBAL CLIMATE CHANGE No mitigation measures are required. Target at Sunset and Western V. Mitigation Monitoring and Reporting Program PageV·20