APPENDIX IV.I-2 School Capacity Study

HAMILTON, RABINOVITZ & ALSCHULER, INC. Policy, Financial & Management Consultants

AN ASSESSMENT OF THE SCHOOLS IMPACTS OF PONTE VISTA AT SAN PEDRO

A Technical Appendix to the Draft Environmental Impact Report

Prepared for: The Department of City Planning City of Los Angeles

September 2006

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T A B L E O F C O N T E N T S

Page

List of Figures...... iv

List of Tables ...... iv

I. EXECUTIVE SUMMARY ...... 1

II. PURPOSE AND SCOPE OF THE ANALYSIS...... 8

A. Introduction...... 8

B. Project Description...... 8

C. CEQA Issues Related to School Impacts...... 14

D. Organization of the Report ...... 14

III. PROJECT IMPACTS...... 15

A. Introduction...... 15

B. Environmental Setting: Existing and Future Conditions Without the Project ...... 15

C. Project Impacts ...... 24

D. Cumulative Impacts ...... 26

E. Mitigation Measures...... 32

F. Level of Significance After Mitigation...... 32

Page

Ponte Vista at San Pedro Page ii School Impacts Technical Report Draft EIR September 2006

Table of Contents

IV. IMPACTS OF PROJECT ALTERNATIVES ...... 33

A. Introduction...... 33

B. Impacts of Six Project Alternatives ...... 33

Appendices

A. Qualifications of Hamilton, Rabinovitz & Alschuler, Inc.

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Table of Contents

L I S T O F F I G U R E S

No. Title Page

II-1. Project Location and Regional Vicinity Map ...... 9

II-2. Conceptual Site Plan...... 11

III-1. School Locations Map ...... 17

L I S T O F T A B L E S

No. Title Page

II-1 Proposed Development Phasing, Ponte Vista at San Pedro...... 12

III-1. LAUSD School Capacities and Enrollment...... 16

III-2. Private Schools in the Project Area ...... 23

III-3. Estimated Student Generation by the Proposed Project ...... 25

III-4. Project Impacts on LAUSD Schools ...... 26

III-5. Cumulative Impacts to LAUSD Elementary and Middle Schools ...... 28

III-6. LAUSD 5-Year Projected School Capacities and Enrollment ...... 30

IV-1. Characteristics of the Project Alternatives ...... 34

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I. EXECUTIVE SUMMARY

This Report presents an assessment of the public school enrollment and facilities impacts of the Ponte Vista at San Pedro, a 2,300-unit condominium development (“Project”) proposed for a 61.5-acre site along Western Avenue in the Wilmington-San Pedro area of the City of Los Angeles. The site is owned by Bisno Development Company. This assessment is intended to provide data and analysis for use in preparing an Environmental Impact Report (EIR) on the Project, pursuant to the California Environmental Quality Act (CEQA). This Report was prepared by Hamilton, Rabinovitz & Alschuler, Inc., a policy, financial and management consultant.

The public school system serving the Project site is the Los Angeles Unified School District (LAUSD). Neighborhood schools that would be attended by students generated from the Project include Taper Elementary School (1824 Taper Avenue, San Pedro), Dodson Middle School (28014 S. Montereina Drive, Rancho Palos Verdes) and Narbonne High School (24300 S. Western Avenue, Harbor City). Taper Elementary, Dodson Middle, and Narbonne High Schools are currently operating under capacity by 383, 578, and 53 students, respectively.

LAUSD is currently engaged in the planning and construction of 185 new schools by 2012 to accommodate its student population growth forecast within and surrounding the City of Los Angeles. In the project area, LAUSD has also announced a project known as new South Region High School (#14). The planned South Region High School #14 has a projected capacity of 2,025 students and would serve the area in which the Project is located. The planned South Region High School #14 would commence operations in 2011. On December 13, 2005, the LAUSD Board of Education adopted a resolution approving the Project site as the preferred site for the planned South Region High School #14, although LAUSD has subsequently stated that only 24 acres will be required for the school. The approval of the resolution authorizes LAUSD

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Executive Summary staff to study the Project site as the potential site for South Region High School #14, for planning and feasibility purposes, including the preparation on an environmental impact report by LAUSD. However, it does not approve or authorize the development of South Region High School #14 at the Project site or any other site. After such studies are completed, the LAUSD Board of Education may decide to proceed or not proceed with development of South Region High School #14.

The option to attend “magnet” programs is also available to students living within the service boundaries of LAUSD. Magnet programs provide specialized curriculums and instructional approaches to attract a voluntary integration of students from a variety of neighborhoods in a metropolitan area. Two of the schools that serve the Project site, Dodson Middle School and Narbonne High School, have magnet programs on their campuses (Dodson Gifted and Narbonne Math Science, respectively). Additional LAUSD magnet schools and programs in the area that are expected to be available to Project residents include South Shores Performing Arts (Grades 1-5), Harbor Math Science Gifted (Grades 1-5), San Pedro Marine/Math Science Tech (Grades 9-12), Lomita Math Science (Grades 1-5), and Glenn Hammond Curtiss Math/Science Technology (Grades 6-8).

There are also a number of private schools in the Project area that would serve as alternatives to LAUSD schools, should Project residents elect this option. In addition to existing private schools, there are two planned private schools immediately adjacent to the Project site, Mary Star of the Sea High School and Rolling Hills Preparatory School, which are anticipated to be in operation upon buildout of the Project and therefore could also serve Project residents.

In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant effect on the environment if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives of the school district.

The project site is vacant and, therefore, does not currently contribute to the existing school enrollment.

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Executive Summary the potential need to enroll any school-aged children into LAUSD schools would increase the demand for school services. Based on LAUSD demographic analysis, a stabilized community of 1,725 townhome units and 575 senior units (aged 55 and above only) would generate 99 elementary students, 50 middle school students, and 50 high school students, or a totals of 199 additional LAUSD students.

Adding Project-generated students to existing school enrollments, Taper Elementary School would operate under capacity by 284 students, Dodson Middle School would operate under capacity by 528 students, and Narbonne High School would operate under capacity by 3 students. Therefore, Project-generated students could be accommodated by Project Area schools without the construction of new facilities, and hence no substantial adverse physical impacts associated with the provision of new or physically altered school facilities, or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts. The Project’s environmental impacts related to schools would therefore be less than significant.

Nevertheless, LAUSD is authorized under state law to levy a fee against construction of the Project for the purpose of funding the construction or reconstruction of school facilities. LAUSD’s current fees are $3.60 per square foot of new residential construction and $0.34 per square foot of new commercial construction. Space occupied by units reserved for seniors age 55 and over are assessed at the commercial construction fee rate. Based on 2,587,500 square feet of family residential floor area and 862,500 square feet of seniors residential and 10,000 square feet of convenience retail floor area, the Project’s total fee will be $9,611,650.

Development of the related projects analyzed in the Project’s Draft EIR, in conjunction with the proposed Project, would increase the number of school-aged children who potentially would attend LAUSD schools in the Project Area. Of the 174 related projects, four related projects are located within the jurisdictional boundary of Taper Elementary School, ten related projects are located within the jurisdictional boundary of Dodson Middle School, and 58 related projects are located within the jurisdictional boundary of Narbonne High School. Development of the related projects and the proposed Project would result in the generation of 139 students at Taper Elementary School, 72 students at Dodson Middle School, and 78 students at Narbonne High School. By 2010, LAUSD anticipates that Taper Elementary and Dodson Middle Schools will operate under capacity by 419 and 270 students (respectively), while Narbonne High School will operate over capacity by 821 students. Thus, cumulative development would not exceed the available student capacities of Taper Elementary or Dodson Middle Schools, but would further contribute to anticipate overcrowding conditions at Narbonne High School.

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Executive Summary

Whether, when or where new facilities may be constructed to relieve anticipated overcrowding is undetermined at this time, although LAUSD has announced a new school project related to such needs, known as South Region High School #14, a general high school proposed to serve 2,025 students. The Project site has been selected as the preferred site for South Region High School #14. However, this designation authorizes feasibility and planning studies only (including an EIR which will study potential alternatives), and such designation does not mean that South Region High School #14 will be constructed at the Project site. If South Region High School #14 (or other facilities accommodating the student enrollment growth forecast by LAUSD) is not constructed, there is a range of possible solutions, all of which are under LAUSD control. Such solutions include increasing average class size (subject to any teacher contract limitations), changing to a different school calendar, modifying school attendance boundaries, adding modular classrooms, adding onto existing buildings at existing schools (such as Narbonne High School and San Pedro High School), and building new schools. Such programmatic decisions would be made at the sole discretion of LAUSD.

Because the Project would have a less-than-significant impact on schools, mitigation measures are not required. The Project Applicant would still be required to pay school fees in compliance with state law, notwithstanding the less-than-significant impact on school facilities. This fee provides full and complete mitigation of any potential school impacts.

The Draft Environmental Impact Report for the Project analyzes the implications of six alternatives to the Project, and compares the relative impacts of the alternatives with the proposed Project. One alternative is the mandated No Project alternative (Alternative A). Two other alternatives involve variations of the Project’s proposed land uses: one with a larger proportion of seniors units (Alternative B) and one that is a scaled back version of the proposed Project (Alternative C). Two more alternatives involve different combinations of land uses: one with high-density residential and regional retail (Alternative D) and one with a biomedical research facility and high-density residential (Alternative E). The last alternative consists of the Project, but at a different location.

From the perspective of housing and population the alternatives compare to the Project as follows:

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Executive Summary

Alternative A: No Project

In accordance with the existing Community Plan designation and LAMC zoning, Alternative A assumes that a maximum of 429 single-family homes would be built on the Project site. All of these homes would be developed for sale at market rates without any below-market or seniors units. Under this alternative, it is also assumed that the Little League baseball diamonds and public park component of the Project would not be implemented. Thus, the 429 single-family homes would be spread across the site in a manner typical of other residential subdivisions in southern California.

This alternative would result in an 81 percent reduction in dwelling units compared to the proposed Project, but just about the same total student generation (191) as the Project (199), due to the higher rates that apply to detached single-family units. Like the proposed Project, this alternative would not result in a significant impact on schools. Payment of school fees would still be required, but they would also be substantially less than for the proposed Project.

Alternative B: Increased Senior Housing

This alternative would result in the same number of dwelling units as the proposed Project, but would result is less student enrollment, because of the reduction in family units. This alternative would generate 133 total LAUSD students, or 66 fewer than the proposed Project. Like the proposed Project, this impact would not be significant. This alternative would also generate a lower school fee, because of the smaller number of family residential units.

Alternative C: Reduced Density

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Executive Summary

This alternative represents a 26 percent reduction in units. Accordingly, it would generate 147 LAUSD students, or 52 fewer than the proposed Project. Like the proposed Project, this impact would not be significant. This alternative would also generate a lower school fee, because of the smaller number of family residential units.

Alternative D: Mixed Commercial and Residential Alternative

Under Alternative D, the site would be developed with a mixture of retail commercial and multi-family residential uses. An approximately 500,000 square-foot community shopping center would be developed on the northerly 40 acres of the site. The southerly 21.5 acres of the site would be developed with a separate residential complex consisting of 560 market-rate condominium and townhome units.

This alternative would result in 76 percent fewer dwelling units than the proposed Project. It would generate 65 LAUSD students from residential units and 15 students from the shopping center, for a total of 80 students, or 119 fewer than the proposed Project. Like the proposed Project, this impact would not be significant. This alternative would also generate a significantly lower school fee, because of the smaller number of family residential units and the smaller fee per square foot for commercial uses.

Alternative E: Mixed Biomedical and Residential

This alternative would develop the site in the spirit of the recommendations contained in July 1999 City of Los Angeles Proposed Reuse Plan for Surplus Navy Property in the San Pedro area (Base Reuse Plan). Specifically, Alternative E would develop a 400,000 square-foot biomedical research facility on 24 acres of the northern portion of the site. A separate residential development consisting of 1,050 condominium and townhome units would be developed on the southerly 37.5 acres of the site. No senior housing or retail space would be included under this alternative.

This alternative would generate 121 LAUSD students from residential units and 16 students from the biomedical facility, for a total of 137 students, or 62 fewer than the proposed Project. Like the proposed Project, this impact would not be significant. This alternative would also generate a significantly lower school fee, because of the smaller number of family residential units and the smaller fee per square foot for commercial uses.

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Executive Summary

Alternative F Alternative Site

This alternative would seek to develop a different site with the same land uses and densities as the Project. The only underutilized or vacant site within the Wilmington-Harbor City Community Plan that is large enough to accommodate the scale of development associated with the Project is a site in the Wilmington Industrial Park. Inasmuch as this alternative has the same number and distribution of units among families and seniors, its student generation profile would be the same as for the proposed Project, and would likewise not result in a significant impact.

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II. PURPOSE AND SCOPE OF THE ANALYSIS

A. INTRODUCTION

This Report presents an assessment of the housing and population impacts of Ponte Vista at San Pedro, a 2,300-unit condominium development (“Project”) proposed for a 61.5-acre site located along Western Avenue in the Wilmington-San Pedro area of the City of Los Angeles (“City”). The site is owned by Bisno Development Company (“Applicant”), which is applying for various land use entitlements from the City. The assessment reported herein is intended to provide data and analysis for use in preparing an Environmental Impact Report (EIR) on the Project pursuant to State law1 and City requirements, prior to City consideration of certain permit approvals required to construct the Project. This Report was prepared by Hamilton, Rabinovitz & Alschuler, Inc. (HR&A) for the City’s use in preparing the Project’s EIR. A summary of HR&A’s qualifications is included as Appendix A.

The need to analyze school impacts of the Project is rooted in the CEQA Guidelines,2 which identify schools and other public services as potential categories of project-related impacts which may merit investigation, depending upon the specific features of a proposed development project. The Initial Study completed for the Project concluded that there was a potential for the Project to have a significant impact on schools.3

B. PROJECT DESCRIPTION

The following is a synopsis of the Project. A more detailed Project Description is contained in the Project’s EIR.

1. Project Location

The 61.5-acre project site is located at 26900 South Western Avenue in the City of Los Angeles. The project site is located in what is generally referred to as the San Pedro area of the City, approximately two miles northwest of the Port of Los Angeles (see Figure 1). The project

1 Public Resources Code § 21000, et seq.

2 Calif. Admin. Code § 15000, et seq.

3 Christopher A. Joseph & Assoc., Initial Study for Ponte Vista at San Pedro, submitted to the City of Los Angeles Department of City Planning, July 11, 2005, pp. 38.

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Purpose & Scope of the Analysis site is the location of the former U.S. Navy San Pedro Housing complex and is bordered by Western Avenue (State Route 213) to the west, Fitness Drive and multiple-family residential developments to the south, the U.S. Navy’s Defense Fuel Support Point (DFSP) to the north, and the approved site of a new campus for Mary Star of the Sea High School to the east. Western Avenue, which borders the Project site on the west, is also the City boundary.

Figure II-1 Project Location and Regional Vicinity Map

The Project site is currently improved with 245 duplex units, a community center, and a retail convenience facility that were constructed in approximately 1962 by the U.S. Navy for the purpose of housing personnel stationed at the Long Beach Naval Shipyard. These units and facilities were built by the United States government without compliance with building codes enforced by the City, and are required to be demolished pursuant to the sale contract between the

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Purpose & Scope of the Analysis

U.S. Navy and the developer. In addition, the dwelling units, facilities, infrastructure, streets and landscaping at the site were abandoned after the site was closed in the late 1990s and are in a state of disrepair. As part of the Project, all existing improvements would be removed from the site.

2. Project Characteristics

The Project proposes the development of a residential community comprised of 2,300 for-sale townhome and condominium units. A total of 575 (or 25%) of the units would be restricted to seniors only (aged 55 and above). The senior housing units would be located within a separate sector of the site at its northwesterly corner. The project also includes approximately 10,000 square feet of convenience retail space. The retail component of the project would serve the convenience needs of residents and would be accessible from within the site only.

When completed, the Project would be approximately 40% landscaped common areas and parks (excluding roads). As illustrated conceptually in Figure 2, the residential component of the project would incorporate large internal open space and recreational areas including an approximately 2.5-acre central park (with community clubhouse and pool), an approximately 2- acre waterscape concourse, and an approximately 0.5-acre park/recreation area within the senior community segment of the Project. Additional social and recreational amenities (e.g. community rooms, swimming pools and work-out rooms) would be distributed throughout the site. The residential component of the Project and its related facilities and amenities would be for the private use of Project residents and their guests.

As a public benefit, the Project would also include an approximately 6-acre public park accessible to the general public potentially featuring two little league baseball fields. As an additional public benefit, the Project includes the construction of a new road providing access from Western Avenue to the new Mary Star of the Sea High School. This road will also provide a minimum of 55 parking spaces to serve the adjacent potential little league baseball fields. The Site Plan for the Project is illustrated in Figure II-2.

The Project’s residential units would include for-sale townhomes and condominiums ranging from 700 to 3,000 square feet in Mediterranean, Tuscan, and contemporary-style buildings built over subterranean parking garages. Residential buildings along Western Avenue would be four stories in height (approximately 50 feet) and would be buffered and set back from the street by trees, landscaping and water features. Residential buildings throughout the rest of

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Purpose & Scope of the Analysis

Figure II-2 Proposed Site Plan

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Purpose & Scope of the Analysis

the Project would vary in height, with buildings averaging four stories, but not exceeding six stories (approximately 70 feet). The Project would be abundantly landscaped and would feature such pedestrian amenities as walking paths, benches, fountains, water features, distinctive light poles and street signage, all of which would be incorporated in the master landscape and streetscape plan. All vehicular access would be from Western Avenue.

A Specific Plan is proposed to provide zoning, architectural, landscape and streetscape standards to guide the Project's development. At approximately 37 units per acre, the Project’s density would fall between the City of Los Angeles’ Medium Residential general plan category (corresponding to “R3,” which permits approximately 54 units per acre), and the City’s Low- Medium designation (corresponding to “RD1.5,” which permits approximately 29 units per acre). A General Plan amendment and vesting tentative tract map are also proposed.

Construction of the proposed Project is estimated to begin in 2007 and would continue over a six-year period, with completion in 2012. Although the removal of all existing structures and improvements and grading of the entire site would be completed at the outset, the Project is projected to be constructed in approximate phases during this six-year timeframe as described in Table II-1.

Table II-1 Proposed Development Phasing Ponte Vista at San Pedro Construction Activity Year Demolition of Existing Structures 2007 Complete Site Grading 2007 Construction of Little League Diamonds 2007 Construction of 500 Condominum/Townhome Units 2008 Construction of 500 Condominum/Townhome Units 2009 Construction of 500 Condominum/Townhome Units 2010 Construction of 500 Condominum/Townhome Units 2011 Construction of 300 Condominum/Townhome Units 2012 Construction of Retail Component 2012 Landscaping and Park Amenities (Incremental) 2007-2012 Source: Bisno Development Co.

3. Project Objectives

The Applicant’s objectives for the proposed Ponte Vista at San Pedro project are:

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Purpose & Scope of the Analysis

To remove the abandoned improvements currently present on the site in accordance with the contractual conditions of sale required by the U.S. Navy.

To provide a project that will utilize scarce unutilized land to meet the demand for additional housing; one of the City of Los Angeles and the surrounding region’s most pressing needs.

To provide new housing that will meaningfully contribute to relieving the 2010 housing shortage for the Wilmington-Harbor City and San Pedro Community Plan areas projected by the City’s General Plan Framework and Southern California Association of Governments, without requiring the demolition of existing rent-controlled housing stock.

To provide different types of housing products to meet the housing needs of a broad spectrum of persons who desire to live in the San Pedro community, including:

o senior housing,

o entry level housing,

o work-force housing,

o family housing, and

o move-up housing.

To provide a high-quality residential project with substantial common amenities, landscaping, and open space for the enjoyment of residents.

To provide a project that will significantly invigorate the local economy, employment, and business opportunities through project construction, and through the expenditures of its future residents.

To provide a residential project that will make it feasible to set aside a portion of the Project site to be devoted to community serving uses.

To mitigate potential significant environmental impacts to the extent feasible.

To develop a project that fiscally benefits the City of Los Angeles.

To provide a project which ensures high quality development and maintenance through the creation and adoption of a specific plan that will set land use, architectural, landscaping, streetscaping, and lighting standards.

To provide a project that will be financially feasible to develop and market, and that will provide a return commensurate with the risk of investment.

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Purpose & Scope of the Analysis

C. CEQA ISSUES RELATED TO SCHOOL IMPACTS

The focus of environmental analysis prepared under CEQA is a project's potential to cause effects on the physical environment.4 Accordingly, In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant effect on the environment if it were to result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives of the school district.

D. ORGANIZATION OF THE REPORT

The remaining Chapters of this Report are each organized to follow the standard analytic sequence typically found in EIRs. These Chapters are:

School Impacts. This Chapter describes pre-Project school facility and student enrollment trends and projections in the vicinity of the Project. It then evaluates the Project in the context of existing school facility policies for the Los Angeles Unified School District in which the Project site is located.

Project Alternatives. This Chapter presents a general assessment of the schools impacts of the various alternatives to the proposed Project which are evaluated in the Project’s EIR. It provides a general comparison between the impacts of these alternatives and the proposed Project, in terms of school impacts.

4 "Environment" means the physical conditions which exist within the area which will be affected by a proposed project, including land , air water, minerals, flora, fauna, noise, and objects of historic or aesthetic significance. (Pub. Res. Code § 21060.5).

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III. SCHOOL IMPACTS

A. INTRODUCTION

This Chapter discusses the schools context and applicable facilities and enrollment growth policies applicable to the Los Angeles Unified School District. It then evaluates the Project’s housing impacts against the applicable CEQA threshold, individually and together with related projects in the Wilmington-Harbor City Community Plan area.

B. ENVIRONMENTAL SETTING: EXISTING AND FUTURE CONDITIONS WITHOUT THE PROJECT

1. Overview of the Los Angeles Unified School District

The Project is located within the boundaries of Los Angeles Unified School District (LAUSD), which is the second largest public school district in the nation in terms of enrollment. It is located in Los Angeles County, California and serves the City of Los Angeles, all or portions of 24 other cities in the County and numerous unincorporated areas of the County which surround the City of Los Angeles. This is an area of about 710 square miles with an estimated population of about 4.8 million as of 2005. Approximately two-thirds (66%) of the District's land area, and 87 percent of the population residing in its boundaries, are within the City of Los Angeles.5

The LAUSD provides kindergarten through high school (K-12) education, as well as adult and special education programs, to approximately 877,000 total students in 858 schools, 194 program “centers,” and 79 independent K12 charter schools and centers. It employs about 78,000 personnel, about half (48%) of whom are classroom teachers. The LAUSD's Fiscal Year (FY) 1995-96 total budget was $13.2 billion.6

As of fall 2005, the LAUSD's K-12 enrollment total was 727,117 students. About four in 10 (43%) were enrolled in elementary schools (grades K-6), almost one in five (19%) were enrolled in middle schools (grades 7-8), nearly one-quarter (23%) were enrolled in high schools

5 LAUSD, “Fingertip Facts 2005-06” (available at: http://notebook.lausd.net/portal/page?_pageid=33,196322&_dad=ptl&_schema=PTL_EP) .

6 Id.

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(grades 9-12), and the remainder (15%) were enrolled in magnet schools, primary centers, special education schools and other special District programs.7

2. Public Schools in the Project Vicinity

a. Public K-12 Schools

The Project site is served by the following LAUSD public schools:

Taper Elementary School, located at 1824 Taper Avenue, San Pedro, CA 90731

Dodson Middle School, located at 28014 S. Montereina Drive, Rancho Palos Verdes, CA 90275

Narbonne High School, located at 24300 S. Western Avenue, Harbor City, CA 90710

The locations of these schools are shown in Figure III-1. As indicated in Table III-1, Taper Elementary, and Dodson Middle, and Narbonne High Schools are currently operating under capacity by 383, 578 and 53 students, respectively. The Project site is vacant and therefore does not currently contribute to enrollment at these schools.

Table III-1 LAUSD School Capacities and Enrollment (-)Under/ 2004-2005 2004-2005 (+)Over School Enrollment1 Capacity Capacity Taper Elementary 306 689 -383 Dodson Middle 1,712 2,290 -578 Narbonne High 3,517 3,570 -53 1 Eligible enrollment Source: LAUSD, written correspondence from Glenn Striegler, Environmental Assessment Coordinator, Office of Environmental Health and Safety, October 4, 2005. Confirmed by Mary Prichard, Senior Boundary Coordinator, Master Planning and Demographics, LAUSD, March 7, 2006 (via email); HR&A, Inc.

7 Id.

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Table III-1 School Locations Map

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School Impacts

b. Charter Schools

Charter schools represent the opportunity to examine practices and develop structures that can help solve the many challenges facing LAUSD schools and the greater educational community. Charter schools originated from the Charter School Act of 1992. The subsequent AB 544 legislation established further guidelines and requirements for charter schools. The legislation is also intended to shift toward a performance-based system and provide competition within the public school system. A charter school is granted by the LAUSD Board of Education and approved by the State for a period of up to five years. LAUSD maintains two types of charter schools: conversion charters are existing District schools that later become charters; start- ups are charter schools that are newly created by any member of the public (e.g., educators, parents, foundations, and others). Charter schools are open to any student who wishes to attend, from any area of the City. Although certain attendance preferences may be given, enrollment is conducted by lottery.8

The Port of Los Angeles (POLA) High School of International Business and Maritime Studies, which commenced operations in September 2005, is located at 250 W. Fifth Street in San Pedro, approximately 4.5 miles from the Project site. POLA High School is a public comprehensive charter high school that serves grades 9-12. The school is an innovative model that combines a college preparatory standards-based core academic curriculum with optional specializations in international business, trade, transportation, labor, and maritime and global studies. By serving approximately 250 9th grade students the first school year (2005-2006), 500 9-10th grade students the second year, 750 9-11th grade students the third year, and 1,000 9-12th grade students in the following years, POLA High School is intended to help alleviate the overcrowding issues of local LAUSD high schools, specifically in the communities of Harbor City, Wilmington, and San Pedro. The school is governed by the Board of Directors for POLA High School 501(c)(3) Foundation.9

c. Magnet Schools

8 Los Angeles Unified School District, Charter Schools, website: http://notebook.lausd.net/portal/page?_pageid=33,205129&_dad=ptl&_schema=PTL_EP, February 27, 2006.

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programs occupy entire school sites, while other magnet centers are located on regular school campuses with access to activities and experiences shared with the host school. Applications for magnet programs usually are mailed to the homes of enrolled LAUSD students in December. Typically, students applying to gifted and talented programs are required to demonstrate advanced academic achievement and/or test scores.10

Currently, there are 162 magnet programs located within the LAUSD. Two of the schools that serve the Project site—Dodson Middle School and Narbonne High School—have magnet programs on their campuses (Dodson Gifted and Narbonne Math Science). Additional LAUSD magnet schools and programs in the area that are expected to be available to Project residents include:

• South Shores Performing Arts, 2060 W. 35th Street, San Pedro (Grades 1-5)

• Harbor Math Science Gifted, 1214 Park Western Place, San Pedro (Grades 1-5)

• San Pedro Marine/Math Science Tech, 1001 W. 15th Street, San Pedro (Grades 9-12)

• Lomita Math Science, 2211 West 247th Street, Lomita, Grades 1-5

• Glenn Hammond Curtiss Math/Science Technology, 1254 E. Helmick Street, Carson (Grades 6-8)

d. Open Enrollment

The open enrollment policy is a State-mandated policy that enables students anywhere in the LAUSD to apply to any regular, grade-appropriate LAUSD school with designated “open enrollment” seats. The number of open enrollment seats is determined annually. Each individual school is assessed based on the principal’s knowledge of new housing and other demographic trends in the attendance area. Open enrollment seats are granted through an application process that is completed before the school year begins. Students living in a particular school’s attendance area are not displaced by a student requesting an open enrollment transfer to that school.

e. Proposed New Public Schools

The LAUSD is currently engaged in the planning and construction of 185 new schools by 2012 to accommodate its student population growth forecast within and surrounding the City of

9 Port of Los Angeles High School, website: http://polahs.net/, February 27, 2006. 10 Los Angeles Unified School District, website: http://notebook.lausd.net, February 27, 2006.

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Los Angeles. LAUSD estimates that new schools and site expansions will require the acquisition of over 450 acres of land, some of which has already been acquired. Funding has been identified from various sources including State Proposition 1A bonds, local Proposition BB Bonds, and developer fees.11 In November 2005, a $4 billion facilities bond measure was passed (Measure Y). Measure Y earmarks $1.6 billion to build approximately 25 new elementary schools throughout the District, and devotes $1.5 billion for repairs and renovations to existing school facilities. With Measure Y, the total estimated cost of this Master Plan program is approximately $19 billion. In addition to acquiring new land, LAUSD has also adopted resolutions calling for the multiple use of facilities already owned by public agencies (such as the City of Los Angeles and the Community College District) for the joint siting of new school facilities “whenever and wherever possible and feasible.” LAUSD’s policy is that joint school siting at property already owned by public agencies will “promote fiscal responsibility and minimize neighborhood disruption when new facilities are constructed.”

In the project area, LAUSD has also announced a project know as new South Region High School (#14). The planned South Region High School #14 has a projected capacity of 2,025 students and would serve the area in which the Project is located.12 The planned South Region High School #14 would commence operations in 2011.13 On December 13, 2005, the LAUSD Board of Education adopted a resolution approving the Project site as the preferred site for the planned South Region High School #14, although LAUSD has subsequently stated that only 24 acres will be required for the school. The approval of the resolution authorizes LAUSD staff to study the Project site as the potential site for South Region High School #14, for planning and feasibility purposes, including the preparation on an environmental impact report by LAUSD. However, it does not approve or authorize the development of South Region High School #14 at the Project site or any other site. After such studies are completed, the LAUSD Board of Education may decide to proceed or not proceed with development of South Region High School #14.

LAUSD has issued a Notice of Preparation (NOP) dated June 23, 2006, indicating that it

11 Los Angeles Unified School District, Facilities Services Division: New Construction, website: http://www.laschools.org/employee/nf/, February 2, 2006.

12 LAUSD, written correspondence from Glenn Striegler, Environmental Assessment Coordinator, Office of Environmental Health and Safety, October 4, 2005.

13 LAUSD, Facilities Services Division, website: http://www.laschools.org/project-status/one- project?project_id=2378411, February 20, 2006.

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is currently preparing its own EIR for the South Region High School #14 project at the Project si te. Pursuant to Section 15126.6(a) of the CEQA Guidelines, the EIR to be prepared by LAUSD f or the South Region High School #14 project will consider alternatives to the South Region High School #14 project and to the location of such project, for example, alternatives to siting a 2,025 student high school at the Project site, locating South Region High School #14 at other sites, and the construction of smaller campuses at multiple locations.

As discussed above, at the present time, no project to develop South Region High School #14 at the Project site has been approved by the LAUSD Board of Education, and LAUSD has not acquired the Project site from its present owner. Until such time as all planning, feasibility, and environmental review requirements are completed by LAUSD, the Project site remains a “preferred site” for study purposes only. After such studies are completed the LAUSD Board of Education may decide to proceed with development of South Region High School #14 and acquire the property through purchase or the exercise of eminent domain powers, or pursue one or more alternatives to siting a 2,025 student high school at the Project site.

Councilwoman Janice Hahn, who represents the Council District in which the preferred site for South Region High School #14 is located, has announced that she is opposed to the development of a 2,025 student high school at the Project site, and has called for LAUSD to study the feasibility of serving the student enrollment growth related to the South Region High School #14 project through smaller new academy-sized schools located at Harbor City Community College (which would be a joint use opportunity) and Fort MacArthur, a site in San Pedro which LAUSD already owns).

Development of South Region High School #14 at the Project site would fundamentally conflict with the Project to such an extent that both projects could not be concurrently developed there. The applicant’s Project entails all of the Project site’s approximately 61.5 acres. LAUSD’s potential project requires 24 acres (almost 40 percent of the Project site). Accordingly, if LAUSD were to determine to proceed with its project and were to acquire 24 acres of the Project site, the applicant’s Project would not proceed as presently proposed. Therefore, this Draft EIR evaluates the potential environmental impacts of the applicant’s Project for the Project site assuming that South Region High School #14 is not constructed on the Project site, and is not a related project in relation to the applicant’s Project. As discussed earlier, LAUSD is preparing its own EIR for the South Region High School Project #14, which will address both the project and the cumulative impacts of its project, as well as mitigation measures and potential alternatives.

e. School Facilities Fee Plan

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Under applicable state law,14 the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities. The Leroy F. Greene School Facilities Act of 1998 (SB 50) sets a maximum level of fees a developer may be required to pay to mitigate a project’s impacts on school facilities. The maximum fees authorized under SB 50 apply to zone changes, general plan amendments, zoning permits and subdivisions. The provisions of SB 50 are deemed to provide full and complete mitigation of school facilities impacts, notwithstanding any contrary provisions in CEQA or other State or local laws.15

LAUSD has completed the studies required to support levying the fees authorized by Section 17620 of the California Education Code and SB 50.16 “Level 2” residential fees17 have been imposed at a rate of $3.60 per square foot of new residential construction. Fees of $0.34 per square foot of commercial construction, and $0.09 per square foot of parking structure construction within the boundaries of the LAUSD, also apply. By District policy, the commercial fee, rather than the residential fee, is imposed on privately developed senior housing with 150 or more units. 18 Payment of these fees would be mandatory for the Project Applicant, and would fully mitigate any impact upon school services generated by the Project.

14 California Education Code Section 17620(a)(1)

15 Calif. Government Code § 65996.

16 David Taussig & Associates, Inc., School Facilities Needs Analysis for Consideration of Alternative School Facilities Fees, prepared for LAUSD, Sept. 9, 2005. A separate study supporting imposition of the fee on non-residential development was prepared in 2002 and is scheduled for an update during 2006, per personal communication with LAUSD staff. See, David Taussig & Associates, Inc., Commercial/Industrial Development School Fee Justification Study, prepared for LAUSD, Sept. 2002.

17 Id., § 65995.5-7.

18 LAUSD, “Developer Fee Policy,” Board of Education Report No. 431-04/05, June 14, 2005, Section 6.2(2).

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3. Private Schools in the Project Vicinity

There are also a number of private schools in the Project area that would serve as convenient alternatives to LAUSD schools, should Project residents elect this option. These schools are listed in Table III-2. In addition to existing private schools, there are two planned private schools immediately adjacent to the Project site, Mary Star of the Sea High School and Rolling Hills Preparatory School, which are anticipated to be in operation upon buildout of the Project and therefore could also serve Project residents.

Table III-2 Private Schools in the Project Area Approx. Driving Grade Number of Students/ Distance from School Address Level Students Teacher Project Site (mi) Mary Star of the Sea High School 2300 Taper Avenue (planned)San Pedro, CA 12-Sep 600 N.A 0.2 North Rolling Hills Prepatory School (planned)San Pedro, CA Pre-K-12 900 N/A 0.6 1226 W. Santa Cruz St. Holy Trinity SchoolSan Pedro, CA K-8 580 36 2.3 717 S. Cabrillo Ave. Mary Star of the Sea Elementary SchoolSan Pedro, CA K-8 300 21 3.2 th Mary Star of the Sea High School 810 W. 8 St. (existing)San Pedro, CA 12-Sep 470 16 3.4 28850 S. Western Ave. Christ Lutheran SchoolRancho Palos Verdes, CA Pre-K-8 300 15 1 31100 Hawthorne Blvd. Peninsula Montessori SchoolRancho Palos Verdes, CA Pre-K-5 350 15 9.1 5446 Crest Rd. St. John Fisher SchoolRancho Palos Verdes, CA K-8 203 18 5.6 25200 Western Ave. Pines Christian SchoolHarbor City, CA K-5 140 14 1.8 1122 E. Robidoux St. Holy Family SchoolWilmington, CA Pre-K-8 200 20 4.7 1530 N. Wilmington Blvd. Pacific Harbor Christian SchoolWilmington, CA Pre-K-12 420 21 3.3 706 Bay View Ave. Saints Peter and Paul SchoolWilmington, CA K-8 220 24 3.1 24910 S. Avalon Blvd. Wilmington Christian School Wilmington, CA K-7 124 25 4.2 Sources: New York Times, Real Estate, Community Data, website: http://www.nytimes.com/pages/realestate/communities/index.html, February 27, 2006; City of Los Angeles Planning Department, C.P.C. 2000-4712 (Planned Mary Star of the Sea High School); Rolling Hills Prepatory School Annual Report, Feb. 27, 2006 (available at: http://www.rollinghillsprep.com/main/content/whatsbeenhappening/ annual_report2005.pdf) (Rolling Hills Preparatory School).

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C. PROJECT IMPACTS

1. Threshold of Significance

2. Impact Analysis

Implementation of the proposed Project would involve the development of 2,300 townhome and condominium units and 10,000 square feet of retail space that would serve Project residents. 575 of the residential units would be restricted to occupancy by seniors only (aged 55 and above), and thus would not be expected to generate school-aged children. The increase in the number of permanent residents on the Project site resulting from the Project and the potential need to enroll any school-aged children into LAUSD schools would increase the demand for school services. As shown in Table III-3, based on LAUSD student generation rates, a stabilized community of 1,725 townhome units, 575 senior units (aged 55 and above only) and 10,000 square feet of retail development would result in 199 additional LAUSD students, including 99 elementary students, 50 middle school students, and 50 high school students.

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Table III-3 Estimated Student Generation by the Proposed Project Student Generation Students 2 Land Use # or s.f. Rate Generated 1 Condominiums/Townhomes (units ) 1,725 Elementary 0.0573 99 Middle School 0.0289 50 High School 0.0289 50 Subtotal 199 Retail (000's of sq. ft.) 10 Elementary 0.0157 0 Middle School 0.0070 0 High School 0.0067 0 Subtotal 0 Total 199 1 Includes Project's family units only, not seniors units, per LAUSD School Facilities Needs Analysis , Attachment 1 (Student Generation Rates Report), p. 2. 2 LAUSD, School Facilities Needs Analysis , September 2005, Table 2, p. 9 (single- family attached); and LAUSD, Commercial/Industrial Development School Fee Justification Study , September 2002, Table 13, p. 19 (retail). Sources: LAUSD: HR&A, Inc.

It is also possible that some of the future residents of the Project already reside within the service boundaries of the LAUSD, with their school-aged children currently enrolled in the LAUSD schools near the Project site. However, to provide for a conservative scenario, it is assumed that all of the students produced from the Project would not be currently enrolled in the LAUSD schools near the Project site, and would be enrolled upon relocation to the Project area.

As shown in Table III-4, with the addition of Project-generated students to existing school enrollments, Taper Elementary School would operate under capacity by 284 students, Dodson Middle School would operate under capacity by 528 students, and Narbonne High School would operate under capacity by 3 students. Therefore, Project-generated students could be accommodated by Project area schools without any substantial adverse physical impacts associated with the provision of new or physically altered school facilities, or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts. The Project’s environmental impacts related to schools would therefore be less than significant.

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Table III-4 Project Impacts on LAUSD Schools Existing Resulting (-)Under/ Project (+)Over Students (-)Under/ (+)Over 1 School Capacity Generated2 Capacity Taper Elementary -383 99 -284 Dodson Middle -578 50 -528 Narbonne High -53 50 -3 1 From Table III-1. 2 From Table III-3. Source: HR&A, Inc.

In addition, the Project would be required to pay school facilities fees pursuant to SB 50, which would be used to construct facilities which, according to LAUSD, are necessary to serve overall student enrollment growth district-wide associated with new development. Based on 2,587,500 square feet of family residential floor area, 862,500 square feet of seniors residential and 10,000 square feet of convenience retail floor area, and the LAUSD fee rates per land use noted above, the Project’s total school facilities fee would be $9,611,650.

D. CUMULATIVE IMPACTS

LAUSD’s facility planning assumptions are based on overall demographic trends, and although not specifically based upon new development projects, are intended to address changes in student enrollment arising from area population trends from various sources, including new development.

Development of the related projects in conjunction with the proposed Project would increase the number of school-aged children who potentially would attend LAUSD schools in the Project Area. As discussed above, Project-generated students would attend the following LAUSD schools: Taper Elementary School, Dodson Middle School, and Narbonne High School. (Because the outcome of the approval and siting of South Region High School #14 is unknown at this time, this Draft EIR presents a conservative approach in which South Region High School #14 would not serve high school students generated by the Project or the related projects.) Of the 174 related projects listed in the Project’s Draft EIR, four related projects (projects 14, 18, 20, and 21) are located within the jurisdictional boundary of Taper Elementary School, ten related projects (projects 1, 4, 7, 8, 10, 14, 18, 20, 21, and 30) are located within the jurisdictional boundary of Dodson Middle School, and 58 related projects are located within the

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jurisdictional boundary of Narbonne High School (projects 3, 9, 11, 16, 20, 32-42, 46-48, 134- 168, and 171-174).19

Table III-5 depicts the number of elementary, middle, and high school students who would be generated by the proposed Project in conjunction with related projects, excepting related projects 16, 20, 32, 138, 140, 145, 146, 149, 154, and 167. Related projects 16 and 20 are the Rolling Hills Preparatory School and the Mary Star of the Sea High School projects (respectively), which are described throughout this Draft EIR. Rolling Hills Preparatory School and Mary Star of the Sea High School would be private schools that would serve the surrounding community, and their development would not be expected to generate school-aged children who would attend LAUSD schools. Related project 32 proposes the development of a 100-student preschool. It is unlikely that operation of the preschool would increase the population of school- aged children in the Project Area; rather, it would be anticipated to serve school-aged children who already live in the community and are therefore already accounted for in the LAUSD’s needs projections for the area. Related projects 138, 140, 145, 146, 149, 154, and 167 consist of senior housing and assisted living uses, which, like the senior component of the proposed Project, would not be expected to generate school-aged children who would attend LAUSD Schools.

19 Sources: Jurisdictional boundaries for Taper Elementary, Dodson Middle, and Narbonne High Schools, provided by LAUSD (see Appendix [ ] [Letters from Public Service and Utility Agencies] to this Draft EIR), and LAUSD School Finder, website: http://search.lausd.k12.ca.us/cgi-bin/fccgi.exe?w3exec=schfinder0, March 8, 2006.

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Table III-5 Cumulative Impacts to LAUSD Elementary and Middle Schools

Related Elementary School Middle School Students High School Students Project No. Location Land Use Size Students Generated1,2,3,4,5 Generated1,2,3,4,5 Generated1,2,3,4,5 1 Mixed Use – 734 Wilmington Blvd. Food/Retail 7,180 SF - 0 - 3 Walgreens Drugstore 24930 Western Ave. Commercial 13,904 SF - -0 4 Terragona Plaza Addition to Ralphs 15,000 SF 0 1000 Western Ave. Addition to Ralphs 8,960 SF-- 0 7 900 Anaheim St. Restaurant 6,600 SF - 0 - 8 6 Fueling Gas Station station 0 311 Gaffey St.Mini Mart 1,390 SF - 0 - 9 Normandie Ave./Torrance Blvd. Single Family 63 DU - - 8 10 Existing Restaurant 3,000SF 0 303 Gaffey St.Additions 1,816 SF - 0 - 11 1437 Lomita Ave. Condominium 160 DU - - 5 14 28000 Western Ave. Condominium 140 DU 8 4 - 18 Target Co. 1701 N. Gaffey St. Supermarket 126,000 SF 2 1- 21 JCC Homes 1427 N. Gaffey St Single Family 135 DU 30 14 - 30 Goldenrose St south of Miraflores Ave Single Family 27 DU - 3 - 33 1400 W. 260th St Condominium 12 DU - - 0 34 1408 W. Anaheim St Townhome 7 DU - - 0 35 26404 S. Vermont Ave Condominium 21 DU - - 1 36 1549 W. 207th St Condominium 4 DU - - 0 37 1610 W 207th St Condominium 5 DU - - 0 38 1614 W 207th St Condominium 4 DU - - 0 39 1445 W. 225th St Condominium 14 DU - - 0 40 1640 W. 227th St Condominium 4 DU - - 0 41 1636 W. 227th St Condominium 4 DU - - 0 42 1401 W.. Lomita Blvd Condominium 62 DU - - 2 46 1514 W. 207th St Condominium 4 DU - - 0 47 1610 W. 251st St Condominium 4DU - - 0 48 24000 S. Western Ave Library4 14,650 SF - - 0 134 Mr. Don Barteld 25610 Narbonne Ave Office Expansion 810 SF - -0 135 Mr. Tom Frederikson 2215-2219 W 241st St Condominium 9 DU - - 0 136 Mr. Jeh Meher 26327 Western Ave Health Gym 13,533 SF - -0 137 SUBTEC (Cheryl Vargo) Single Family 7 DU 1 2040 & 2046 Lomita Blvd Commercial 10,140 SF --0 139 Tom Yuge 26001 Eshelman Ave and 26004 Avocado Single Family 6 DU - -1 141 Ricardo Velasquez Commercial 1830 Pacific Expansion Coast Highway 1,192 SF - - 0 142 SUBTEC (Cheryl Vargo) 1748-1751 W. 257th St Condominium 6 DU - -0 143 Faizel Tar 2020 Lomita Blvd #6 Auto Rental & Sales 1,014 SF - - 0 144 George Mcguire Office 11,000 SF 0 SE corner of Western Ave and 262nd St Commercial 17,300 SF --0 147 Charles Couey 2247-2261 West 241st St Condominium 16 DU - - 0 148 Greg Warren 25209 Narbonne Ave Medical Office5 1,650 SF - - 0 150 Charles Couey 2247-2261 West 241st St Condominium 3 DU - -0 151 Donna George 2100 Lomita Blvd Beauty Salon 888 SF - - 0 152 Lanco Engineering 1837 and 1839 257th St Condominium 3 DU - -0 153 Obradovich Corporation 24633 Pennsylvania Ave Condominium 5 DU - - 0 155 Jason Fromm 2212 Lomita Blvd Office 7,548 SF - -0 156 Charles Couey 2067-2077 240th St Single Family 5 DU - - 1 157 Dan Schultz (Milestone Management) SW corner of Narbonne and Pharmacy w/ drive PCH through 13,013 SF - -0 158 Mehrzad Givechi 25114-8 Narbonne Ave Condominium 40 DU - - 1 159 Family ADHC – Lomita Medical Office 2280 Lomita Blvd Expansion5 2,915 SF - -0 160 Mary Elizabeth Lewis 2049 Pacific Coast Hwy Tutoring Center4 1,000 SF - - 0

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Table III-5 (continued) Related Elementary School Middle School Students High School Students Project No. Location Land Use Size Students Generated1,2,3,4,5 Generated1,2,3,4,5 Generated1,2,3,4,5

161 Julie Olson

24831 Narbonne Ave Suite 103 Coffee House 2,048 SF - -0 162 Dennis Pauslan 24831 Narbonne Ave Warehouse6 1,900 SF - - 0 163 Y&S Auto Body 24720 Crenshaw Blvd Office 9,228 SF - -0 164 Bijan Haleeli 2244 Pacific Coast Hwy Retail 18,285 SF - - 0 165 Stacey Witner 24429 Narbonne Ave Retail 900 SF - - 0 166 Mark Consalvo 25834 Narbonne Ave Restaurant 6,726 SF - - 0 168 21000 Normandie Ave Condominium 112 DU - - 3 171 1010-1022 W. 223rd St Condominium 16 DU - - 0 172 1154 W. 223rd Street Single Family 5 SF - - 1 173 22800 Normandie Ave Condominium 79 DU - - 2 174 SE corner of Normandie/223rd Condominium 58 DU - - 2 Related Project Subtotal 40 22 28 Plus Project 99 50 50 Cumulative Total 139 72 78 1 Per multi-family residential and retail Student Generation Rates in Table III-3. 2 LAUSD student generation rates for single family attached uses are 0.0572 elementary, 0.0289 middle, 0.0289 high school students per dwelling unit. 3 Student generation rates for library and tutoring center uses are not available. As such, the highest available high school student generation rate for a nonresidential use (i.e., office use rate) was employed. 4 LAUSD student generation rates for hospital uses were employed for medical office uses (0.0186 elementary, 0.0086 middle, and 0.0083 high school students per 1,000 square feet). 5 Student generation rates for industrial/warehouse/manufacturing (0.0180 elementary, 0.0083 middle, and 0.0080 high school students per 1,000 square feet). Source: LAUSD School Facilities Needs Analysis, 2005 and Commercial/Industrial Development School Fee Justification Study, 2002, op. cit .; Christopher A. Joseph & Associates.

As shown in Table III-5, development of the related projects plus the Project would result in the generation of 139 students at Taper Elementary School, 72 students at Dodson Middle School, and 78 students at Narbonne High School. As shown previously in Table III-4, capacity currently exists to serve the approximately 50 high school students generated by the Project at Narbonne High School, with a residual remaining capacity for three students. When related projects are added to the Project’s high school student demand, the capacity of Narbonne High School would be exceeded by 25 students (i.e., three surplus seats plus demand for 28 more from related projects, per Table III-5).

Thus, the Project and related projects may together result in the need for the construction of new facilities at Narbonne High School to serve a projected unmet demand of 25 students in excess of current capacity. Narbonne High is comprised of approximately 40 acres of property, and it is likely that, if necessary, facilities to serve an additional 25 students could be added without resulting in significant adverse environmental impacts. However, planning to serve projected student demand at Narbonne is within the authority of LAUSD, as discussed further below. The applicants of the related projects would be required to pay school facilities fees to the LAUSD, and payment of these fees would fully mitigate any impact that the related projects would have on LAUSD schools, including high schools, in accordance with SB 50.

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As discussed above, cumulative analysis pursuant to CEQA indicates that cumulative public school demand will not exceed current capacity at public schools except at Narbonne High School (where demand will exceed capacity by approximately 25 students).

As discussed earlier, LAUSD has announced a new project, known as South Region High School #14, a general high school proposed to serve 2,025 students, and has designated the Project site as the preferred site for South Region High School #14. This designation authorizes LAUSD staff to study the Project site as the potential site for South Region High School #14 for planning and feasibility purposes only, including the preparation of an EIR by LAUSD which will study potential alternatives and alternative sites. At the present time, development of South Region High School #14 at the Project site is not approved or authorized, and South Region High School #14 may or may not be developed at the Project site or at any other site.

In connection with the South Region High School #14 project, LAUSD is preparing its own enrollment projections. As shown below in Table III-6, by 2010, LAUSD anticipates that Taper Elementary and Dodson Middle Schools will operate under capacity by 419 and 270 students, respectively, while Narbonne High School will operate over capacity by 821 students.

Table III-6 LAUSD 5-Year Projected School Capacities and Enrollment (-)Under/ 2010 (+)Over School Enrollment1 2010 Capacity1 Capacity Taper Elementary 239 658 -419 Dodson Middle 1,648 1,918 -270 Narbonne High 3,967 3,146 +821

1 Project buildout is expected to occur in 2012. Future enrollment and capacity projections beyond 2010 have not been made available by LAUSD at this time. Thus, this analysis assumes 2010 projections for future baseline conditions.

Source: LAUSD, written correspondence from Glenn Striegler, Environmental Assessment Coordinator, Office of Environmental Health and Safety, October 4, 2005. Confirmed by Mary Prichard, Senior Boundary Coordinator, Master Planning and Demographics, LAUSD, March 7, 2006 (via email); HR&A, Inc.

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The data which form the basis for this projection has not been disclosed by LAUSD, and is not publicly available. To obtain the basis for LAUSD’s enrollment projections, Smart Choice for San Pedro Schools, an unincorporated association of which the Project applicant is a member, submitted a Public Records Act request requesting information concerning LAUSD’s demand projection methodology for Narbonne High School, Wilmington Banning High School, and San Pedro High School. The Public Records Act request is included as Appendix IV.I-3 to the Draft EIR. LAUSD’s response to the Public Records Act request, also included in Appendix IV.I-3 to the Draft EIR, does not provide demographic data that support the future enrollment projections for area high schools LAUSD has announced in connection with the South Region High School #14 project. Nor has LAUSD published or made available any other demographic data to support its future enrollment projections as part of the South Region High School #14 project.

Furthermore, it is noted that according to LAUSD’s own projections, LAUSD enrollment, which peaked at 746,831 in 2002-03 and totaled 727,117 in 2005-06, is expected to decline by 14,629 in 2006-07 to 712,488. The anticipated 2006-07 decline is comprised of two components: a decrease of 20,386 in regular LAUSD schools, partially offset by an increase of 5,757 in fiscally independent charter schools. Further declines are expected through 2009-10, the latest school year for which LAUSD has released projected enrollments, with a total expected 2009-10 enrollment of 677,310 (an approximate five percent decrease from 2006-07). The reasons for LAUSD’s continuing enrollment decline are complex, but LAUSD has stated that the most important factor is believed to be the high cost of housing in southern California, which may be causing families to relocate to more affordable areas.20

In summary, the basis for LAUSD’s future enrollment projections in connection with the South Region High School #14 project is not available, and resolving the discrepancy between cumulative enrollment projections that result from CEQA related projects analysis, and LAUSD’s own projections (whose basis is not known) is beyond the scope of this EIR. As discussed above, LAUSD’s enrollment projection for Narbonne High would also seem to be inconsistent with district-wide projections indicating that total LAUSD enrollment is expect to decline through 2010.

Ultimately, decisions concerning planning for future public school facilities fall within the discretion of LAUSD under the State Education Code, applicable LAUSD policies, and other applicable laws and regulations. Within this framework, LAUSD is charged with determining

20 LAUSD, Superintendent’s 2006-07 Preliminary Budget, March 30, 2006, p. I-11 and VI- 22. Available online: http://notebook.lausd.net/pls/ptl/docs/PAGE/CA_LAUSD/FLDR_ORGANIZATIONS/FLDR_ OFFICE_OF_CFO/CFO_HOME/2006-07%20PRELIMINARY%20BUDGET%203-30-2006%202.PDF.

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School Impacts whether, when, and where new facilities should be built. LAUSD is preparing its own EIR for the South Region High School #14 project, which should address the basis (need) for the project, potential environmental impacts, mitigation measures, and alternatives.

E. MITIGATION MEASURES

Because the Project would have a less-than-significant impact on schools, mitigation measures are not required pursuant to CEQA Guidelines Section 15126.4. Furthermore, as discussed in the “Environmental Setting” discussion, the Project Applicant would be required to pay school fees in compliance with SB 50, notwithstanding the less-than-significant impact on school facilities. As previously discussed, this fee provides full and complete mitigation of any potential school impacts.

F. LEVEL OF SIGNIFICANCE AFTER MITIGATION

Project specific impacts to schools would be less than significant.

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V. IMPACTS OF PROJECT ALTERNATIVES

A. INTRODUCTION

This section summarizes the student generation and capacity implications of five possible alternatives that are presented in the Environmental Impact Report on the Project. Each Project alternative is described briefly, and its housing and population impacts are then presented in quantitative and qualitative terms. These impacts are also compared to those of the proposed Project.

B. IMPACTS OF THE SIX PROJECT ALTERNATIVES

Table IV-1 compares the land use characteristics and scale of the alternatives, and their associated LAUSD student generation, each of which is discussed below in more detail.

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Table IV-1 Characteristics of the Project Altermatives AlternativeResidential (# units) Retail Biomed. Research Students Generated Seniors Families Total (000's s.f.)(000's s.f.) Elementary Middle High Total A. No Project - 429 429 - - 95 44 51 191 B. Increased Senior Housing 1,150 1,150 2,300 10 - 66 34 34 133 C. Reduced Density 425 1,275 1,700 7 - 73 37 37 147 D. Mixed Commercial & Residential - 560 560 500 - 40 20 20 79 E. Mixed Biomedical & Residential - 1,050 1,050 - 400 69 34 34 137 F. Alternative Site 575 1,725 2,300 10 - 99 50 50 199

Project 575 1,725 2,300 10 - 99 50 50 199 1 LAUSD multi-family residential and retail student generation rates per Table III-3. 2 LAUSD student generation rates for single family attached uses are 0.0572 elementary, 0.0289 middle, 0.0289 high school students per dwelling unit. 2 LAUSD student generation rates for Research & Development uses are 0.0213 elementary, 0.0096 middle, 0.0091 high school students per 1,000 s.f. Source: LAUSD; Christopher A. Joseph & Assoc.; HR&A, Inc.

1. Alternative A: No Project

Under Alternative A, the Project would not be developed on the site. However, the site would not remain in its current condition. Under the conditions of the ownership transfer from the U.S. Department of Defense to the Applicant, all existing improvements on the site must be removed. Accordingly, the existing vacant former Navy housing complex and associated roadways and other infrastructure would be demolished and all debris removed from the site under this alternative. Under current City Community Plan land use designations in the Wilmington- Harbor City Community Plan, the Project site is designated for Low Density Residential (4 to 9 dwelling units per acre) land uses. The Planning and Zoning Code, or Chapter 1 of the Los Angeles Municipal Code (LAMC), zones the Project site R1-1XL (One- Family Zone, Extra Limited Height District No. 1). Single-family dwellings, among other specified land uses, are permitted within the R1 zone. The Extra Limited Height District No. 1 limits the height of buildings to two stories or 30 feet.

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alternative would not result in a significant impact on schools. Payment of school fees would still be required, but they would also be substantially less than for the proposed Project.

2. Alternative B: Increased Senior Housing

Alternative B would retain the Project’s proposed land uses and development density but would alter the mix of market and senior-targeted housing to be developed on the Project site. Alternative B would develop a total of 2,300 condominium and townhome residential units, with 50 percent (1,150 units) constructed as senior (age 55 or older) housing and 50 percent (1,150 units) constructed as market-rate housing. This contrasts to the Project’s proposed mix of 75 per-cent (1,725 units) market-rate housing and 25 percent (575 units) senior housing. As with the Project, approximately 10,000 square feet of retail space would be integrated into the residential complex. The site plan for development under this alternative would be substantially similar to that of the Project, with some comparatively minor differences in the internal configuration of development in order to accommodate the larger senior housing element.

3. Alternative C: Reduced Density

Alternative C would retain the Project’s proposed land uses and mix of market and senior-targeted housing, but would reduce the total number of housing units to be developed on the Project site. Alternative C would develop a total of 1,700 condominium and townhome resident- tail units, with 25 percent (425 units) being constructed as senior (age 55 or older) housing and 75 percent (1,275 units) constructed as market-rate housing. The 1,700 units to be developed under Alternative C correspond to a 26 percent reduction in the Project’s proposed density. Consistent with this density reduction, the amount of retail space to be integrated within the residential development on the site would be reduced by the same 26 percent, or approximately 7,400 square feet. The site plan for development under this alternative would be substantially similar to that of the Project, with some comparatively minor differences in the internal configuration of development due to the fewer number of units to be developed.

This alternative represents a 26 percent reduction in units. Accordingly, it would generate 147 LAUSD students, or 52 fewer than the proposed Project. Like the proposed

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Project Alternatives

Project, this impact would not be significant. This alternative would also generate a lower school fee, because of the smaller number of family residential units.

4. Alternative D: Mixed Commercial and Residential Alternative

Under Alternative D, the site would be developed with a mixture of retail commercial and multi-family residential uses. An approximately 500,000 square-foot community shopping center would be developed on the northerly 40 acres of the site. This retail complex would be anchored by one or more “big box” type stores designed to serve the larger San Pedro/Eastern Palos Verdes Peninsula market. Smaller-scale retail store space would also be developed adjacent to the anchor retailers. This additional retail space could include one or more restaurants. The southerly 21.5 acres of the site would be developed with a separate residential complex consisting of 560 market-rate condominium and townhome units (a density that is consistent with RD-1.5 zoning in the City of Los Angeles). Unlike the Project, the retail and residential components of Alternative D would not be integrated, but would instead be separated by landscaping and fencing. No senior housing would be included in Alternative D. The site plan for development under this alternative would be significantly different from that of the Project.

5. Alternative E: Mixed Biomedical and Residential

This alternative would develop the site in the spirit of the recommendations contained in July 1999 City of Los Angeles Proposed Reuse Plan for Surplus Navy Property in the San Pedro area (Base Reuse Plan). The Base Reuse Plan evaluated a series of redevelopment proposals for the Project site (as well as other former Navy facility sites in the area) and selected a proposal from the Harbor-UCLA Research and Education Institute (REI) as the best option for the property among those proposals received. For a variety of reasons, the recommendations of the Base Reuse Plan for the Project site were never implemented. At the time decisions were being made by the Navy regarding the site’s disposition, the parties involved in the REI proposal decided to suspend pursuit of their proposed site redevelopment. Subsequent to this, the Navy sold the property to the Project applicant. Alternative E would develop the site in the same general spirit as the “winning” REI proposal selected in the Base Reuse Plan.

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Project Alternatives

Specifically, Alternative E would develop a 400,000 square-foot biomedical research facility on 24 acres of the northern portion of the site. A separate residential development consisting of 1,050 condominium and townhome units (corresponding to the allowable density under RD-1.5 zoning) would be developed on the southerly 37.5 acres of the site. No senior housing or retail space would be included under this alternative. The primary differences between the REI proposal selected in the Base Reuse Plan and Alternative E are that there would be no direct linkage between the biomedical research facility and the housing to be developed on the Project site, and that none of the existing former Navy housing structures on the site would be retained. Under the conditions of property transfer from the Navy to the Project Applicant, all existing structures on the site had to be removed. Thus, the reuse element of the REI proposal is no longer feasible. In addition, the number of housing units to be located on the site would be larger under Alternative E than in the REI proposal. The site plan for development under this alternative would be significantly different from that of the Project.

6. Alternative F: Alternative Site

This alternative would seek to develop a different site with the same land uses and densities as the Project. The Project is being proposed to meet the existing and projected demand for increased housing opportunities in the Wilmington-San Pedro area of Los Angeles. Individual alternative sites to the project site could be found and developed in order to meet expected demands for growth, or this amount of demand could instead be met by developing many smaller parcels of land that are spread out over the area. However, there are very few developable properties in the entire San Pedro/Los Angeles Harbor vicinity that are of a size similar to that of the Project site. Although it is conceivable that a large number of smaller land parcels could be developed in place of the Project to offer the same number of housing units, it is unlikely. Given both the existing identified housing deficit in the Wilmington-San Pedro area and the amount of population growth expected both regionally and statewide, a need may exist to develop all available parcels suitable for housing, including the Project site and all other “alternative” sites. Thus, eventually, these other sites may not be truly “alternative” sites at all.

Nonetheless, a survey was undertaken of potential alternative sites large enough to accommodate the level of development associated with the Project and are currently underutilized or vacant, though not necessarily for sale. One potential alternative site was

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Project Alternatives identified in the Wilmington portion of the City of Los Angeles and two potential alternative sites were located in the City of Long Beach. For school impact evaluation purposes, only the Wilmington site is relevant, because the others are located in other school districts.

Inasmuch as this alternative has the same number and distribution of units among families and seniors, its student generation profile would be the same as for the proposed Project, and would likewise not result in a significant impact.

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APPENDIX A Hamilton, Rabinovitz & Alschuler, Inc. Summary of Qualifications

Ponte Vista at San Pedro School Impacts Technical Report Draft EIR September 2006

HAMILTON, RABINOVITZ & ALSCHULER, INC. Policy, Financial & Management Consultants

SERVICES TO THE PUBLIC AND PRIVATE DEVELOPMENT COMMUNITY

Hamilton, Rabinovitz & Alschuler, Inc. (HR&A) is a full service policy, financial and ma nagement consulting firm. Founded in 1976, the firm has a distinguished track record of providi ng realistic answers to complex housing, real estate, economic development, public finance and s trategic planning problems. HR&A clients include Fortune 500 corporations, all levels of gover nment, the nation’s leading foundations and not-for- profit agencies. The firm has extensive experience working for the legal community in such role s as court-appointed special master, consent decree monitor, technical advisor and expert witness.

HR&A practice lines include real estate analysis and advisory services, local and regional economic analysis, economic development program formulation and analysis, fiscal impact anal ysis, land use policy analysis, development impact fees, housing policy research and analysis, po pulation forecasting and demographic analysis, and transportation system and other capital facilit ies analysis and financing.

Among the qualities for which HR&A is widely known and respected are the impeccable quality of its analysis, ability to invent new analytic methods and approaches to suit the needs of a particular client, independent professional judgment honed through extensive exposure to the ri gors of the public review process and the scrutiny of the judicial system, the ability to translate c omplex technical analysis for a variety of non-technical audiences, and the extensive involvemen t of its Partners in every project it accepts.

HR&A’s domestic and international consulting is provided by a staff of 25 people locate d in offices in Los Angeles, Carmel, CA, Portland, OR and New York. Staff members include p ublic finance professionals, planners, economists, architects, lawyers and experienced project ma nagers. Virtually every member of the firm has substantial public or private sector experience in financial and policy analysis, real estate development and planning.

HR&A provides the following analytic services to the real estate development communit y:

2800 28TH STREET, SUITE 325, SANTA MONICA, CALIFORNIA 90405 $ TEL: 310.581.0900 $ FAX: 310.581.0910

LOS ANGELES NO. CALIFORNIA PORTLAND, OR NEW YORK Services to the Public & Private Development Community

Strategic Positioning and Project Management. HR&A has been retained by developers and public agencies to perform a variety of management assignments ranging from project conceptualization to management of the technical team responsible for project development. In addition to a thorough understanding of the development business, our clients particularly value our ability to think strategically about their projects. This has propelled the firm into the forefront of reuse planning for closed military bases and development of downtown and urban waterfront revitalization strategies. HR&A has been awarded multiple assignments to manage the interdisciplinary teams of architects, urban designers, engineers and others to develop market-sensitive urban development and redevelopment strategies such projects require.

Financial Feasibility Analysis. HR&A has frequently been retained to provide specialized analytic services in all areas of real estate feasibility analysis. This includes pro forma development and review, cash flow modeling, investment return analysis, deal structuring, and the identification of equity, debt and subsidy resources. We have led and/or been key participants in negotiating many different kinds of real estate transactions on behalf of private and public clients, including experience with public ground lease deals.

Economic and Fiscal Impact Analysis. HR&A regularly prepares analyses of the impacts development projects and planning proposals may have on the revenues and expenditures of local public agencies, and/or the regional economies in which they are situated. HR&A has analyzed the impacts of high-rise office buildings, shopping centers, hospital campuses, regional performing arts centers, museums, convention centers, major airports, large single-family subdivisions and condominium developments, and mixed- use developments.

Developer Negotiations. All of HR&A's principles and senior staff are very experienced negotiators, and the firm has particular expertise in negotiating real estate transactions, often in the context of public-private development projects. These services have been performed on behalf of both private and public real estate clients, owing to our keen understanding of each party’s interests and needs. HR&A has been involved in all aspects of the formal real estate negotiations process, from structuring the process through direct participation on behalf of clients and/or acting as technical advisor during the negotiation process. HR&A has participated in drafting Exclusive Negotiating Agreements, Memoranda of Understanding, Owner-Participation Agreements and Development Agreements, particularly with respect to financial terms and conditions.

Other Socio-Economic Impacts Analyses. HR&A has a long history of experience in all aspects of population, housing, employment forecasting and analysis and public school impacts analysis. This includes special expertise in dealing with regional planning policies promoting "jobs-housing balance." The firm’s population and public school enrollment forecasting has been relied on by several school districts in making long-term

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facilities decisions, and was cited in a State Appellate court case which determined that the Santa Barbara campus of the University of California was exempt from school impact fees.

Developer Fees and Exactions. In the early 1980s HR&A was retained by several jurisdictions to design exaction systems in which the firm followed the basic principles of nexus and "fair share" later codified in the Nollan and Dolan decisions by the U.S. Supreme Court, the Ehrlich decision by the California Supreme Court and California Government Code Section 66000, et seq. More recently HR&A has been retained by a number of developers and developer/owner organizations to evaluate, critique and participate in seeking changes to adopted and proposed developer fee programs. The firm’s technical rigor and thoughtfulness about these issues is respected by all sides in the continuing debate about this method of infrastructure financing. A related area of expertise is in the analysis of project impacts on school facilities, a topic of significant interest for many developers and school districts.

Private commercial development-related clients have included 20th Century Fox, Universal Studios, The Walt Disney Company, Olympia & York, Maguire Thomas Partners, JMB Realty Corporation, Gerald Hines Interests, Trammell Crow Company, General Growth Properties, Westfield Corporation, The Maserich Company, Tishman Speyer Properties, Reliance Development Group, Millennium Partners and the Trump Organization. Residential development clients include Centex Homes, K. Hovnanian Companies of California, Castle & Cook, Newhall Land & Farming Co., Olympia & York, Starrett Housing Corp., and William Lyon Homes, Landmark Land Co. and Casden Properties, Inc

Public clients have included a variety of cities, counties, redevelopment agencies, school districts, universities and colleges, special authorities and transportation agencies. HR&A has also represented large foundations with land holdings that need to be converted to cash to further their charitable purposes.

The firm also has a long history of consulting for all of the players in the housing development business, including private housing developers, HUD, private housing lenders, public lenders, national intermediaries (e.g., NEF, CEF, LISC, Enterprise Foundation) and community-based, non-profit developers around the nation.

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REPRESENTATIVE LIST OF CLIENTS Real Estate Advisory Services

Financial Institutions & Investment Santa Monica Beach Development Companies Corporation American Council on Life Insurance Starrett Housing Corporation Citibank Private Banking Group Sunset Development Corporation Citicorp Real Estate, Inc. Tishman Speyer Properties Community Preservation Corporation Trammell Crow Company First Union National Bank Trammell Crow Residential Fleet Financial Group TransAction Companies, Ltd. Goldman Sachs Twentieth Century Fox Hartland Asset Management Universal Studios, Inc. Lehman Bros. The Walt Disney Company Shorebank Corporation Westfield Corporation, Inc. William Lyon Homes Real Estate Development Organizations and World Financial Properties Private Companies ARC Development Public Development Agencies ARCORP Properties Alliance for Downtown New York Bermant Development Company Battery Park City Authority Boeing Realty Corporation Brooklyn Bridge Park Development Casden Properties, Inc. Brooklyn Navy Yard Development Castle & Cook Development Company Corporation Centex Homes Catskill Watershed Corporation Continental Development Corporation Catholic Charities of Brooklyn Daniel Island Development Company Cincinnati Business Committee Disney Development Corporation Columbus Downtown Redevelopment Edward J. Minskoff Equities Corporation Gaylord Entertainment Downtown Brooklyn Local General Growth Properties Development Corporation Gibson Speno LLC Economic Development Growth Home Depot Company Enterprises, Oneida Co., NY JMB Urban Realty Corporation Empire State Development Corporation K. Hovnanian Companies of California Inland Valley Development Agency Landmark Land Company Memphis Riverfront Development Corp. Madison Square Garden National Capital Revitalization Corp. Maefield Development Corporation New York City Economic Development Maserich Company Corporation Maguire Thomas Partners New York State Urban Development Millennium Partners Corporation Newhall Land & Farming Company Penmar Development Corporation New York Times Company Port Authority of New York and Olympia & York (USA) New Jersey The Related Companies Queens West Development Corporation Reliance Development Group

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Cultural, Recreational & Special Events Williamsburg Affordable Housing Clients Westside Urban Forum American Museum of Natural History Brooklyn Academy of Music Governmental Agencies Corporation Boulder Urban Renewal Authority Brooklyn Museum of Art City of Berkeley Rent Stabilization City of New Haven Arts & Entertain- Board ment Facilities Committee City of Beverly Hills Lincoln Center for the Performing Arts City of Chester (PA) Madison Square Garden City of Columbus New Jersey Performing Arts Center City of Culver City (CA) NYC2008 City of Detroit Public Space for Public Life City of Houston Randall’s Island Sports Foundation City of Huntington Beach (CA) The Trust for Public Land City of Indianapolis City of Los Angeles Other Quasi-Public and Non- City of New York Profit Organizations and Foundations City of Olathe (KS) Apartment Association of Greater City of Phoenix Los Angeles City of San Luis Obispo (CA) The Bowery Mission City of Santa Monica Common Ground Community City of West Hollywood (CA) Cornell University City of Yonkers Corporation for Supportive Housing Community Redevelopment Agency of Community Services Society of the City of Los Angeles New York Compton Unified School District (CA) The Enterprise Foundation County of Santa Barbara Ford Foundation District of Columbia Gay Men’s Health Crisis New Jersey Department of Commerce Griffiss Local Development Corporation and Economic Development Harry Frank Guggenheim Foundation Redevelopment Authority of the Kaiser Permanente City of Philadelphia Local Initiatives Support Corporation San Diego Association of Governments Los Angeles Collaborative for Santa Ana Unified School District (CA) Community Development Santa Monica-Malibu Unified Metropolitan Boston Housing School District Partnership Southern California Association of Metropolitan Jewish Geriatric Center Governments National Equity Fund Yonkers Office of Downtown & Neighborhood Progress, Inc. Waterfront Development New York Blood Center Newark Alliance Transportation Agencies Saint John’s Hospital and Health Center City of Chicago Department of Airports Saint Vincent’s Hospital Connecticut Dept. of Transportation San Gabriel Valley Council of Governments Spanish-American Merchant’s Assoc. University of California, Los Angeles University of California, Santa Barbara Upper Manhattan Empowerment Zone Development Corp.

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Services to the Public & Private Development Community

Delaware Dept. of Transportation Los Angeles County Metropolitan Transportation Authority Los Angeles World Airports Massachusetts Bay Transportation Authority New Jersey Transportation Corp. New York Metropolitan Transportation Authority San Diego County Regional Airport Authority U.S. Dept. of Transportation

Housing Agencies Chicago Housing Authority Community Redevelopment Agency of the City of Los Angeles Cuyahoga Metropolitan Housing Authority (IN) Detroit Housing Commission Housing Authority of Baltimore City Housing Authority of the City of Houston Housing Authority of the County of Los Angeles Housing Authority of the City of Santa Monica Housing Bureau, City of Long Beach Indianapolis Housing Authority Los Angeles Housing Department New York City Housing Authority New York City Housing Development Corporation New York State Housing Finance Agency Omaha Housing Authority (NE) Philadelphia Housing Authority Redevelopment Authority of the City of Philadelphia St. Louis Housing Authority (MO) United States Department of Hous- ing and Urban Development

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