III. Responses to Comments

III. Responses to Comments A. Introduction

CEQA Guidelines Section 15088(a) states that “The lead agency shall evaluate comments on environmental issues received from persons who reviewed the Draft EIR and shall prepare a written response. The lead agency shall respond to comments that were received during the notice comment period and any extensions and may respond to late comments.” In accordance with these requirements, this section of the Final EIR provides responses to each of the written comments received regarding the Draft EIR.

Section III.B, Matrix of Comments Received in Response to the Draft EIR, includes a table that provides a summary of the environmental issues raised by each commenter in response to the Draft EIR. In addition, Section III.C, Topical Responses, includes topical responses that address commonly raised topics during the public comment period. Finally, Section III.D, Response to Comments, provides a responses to each of the written comments raised regarding the Draft EIR. Copies of the original comment letters are provided in Appendix FEIR-A of this Final EIR.

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Page III-1 WORKING DRAFT – Not for Public Review III. Responses to Comments B. Matrix of Comments Received in Response to the Draft EIR

Table III-1 Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND OISE LTERNATIVES ONSTRUCTION ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OLICE OLICE ROJECT ROJECT IRE RAFFIC ETTER AND C W A G A L N AND F W CEQA C L P H P T A H COMMENTER G

STATE AGENCIES 1 Scott Morgan, Director State Clearinghouse and Planning Unit Governor’s Office of Planning and Research X State of California 1400 Tenth St. P.O. Box 3044 Sacramento, CA 95812-3044

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G

LOCAL AGENCIES 2 Nick Saponara Development Review Manager, Countywide Planning LACMTA Development Review X X Mail Stop: 99-23-4 One Gateway Plaza Los Angeles, CA 90012-2952

ORGANIZATIONS AND HOME OWNERSHIP ASSOCIATIONS 3 Scott R. Lord Archer School for Girls Board of Trustees X 1801 Century Park East, Ste. 2600 Los Angeles, CA 90067-2328 4 Barbara Natterson-Horowitz, M.D. Co-Chair X Archer Board of Trustees [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 5 Elizabeth English Head of School The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 6 Karen Pavliscak The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049 7 Archer School AIDS Ambassadors The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 8 Archer School Best Buddies The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 9 Archer School Black Student Union The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 10 Archer School Classics Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 11 Archer School Debate Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 12 Archer School Diversity Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 13 Archer School Future Culinary Artists of America Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 14 Archer School Gay/Straight Alliance The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 15 Archer School Peer Academic Work Support The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 16 Archer School Photography Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 17 Archer School Robotics Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 18 Archer School Scratch Club The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 19 Archer School Seussical Cast The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 20 Archer School Student Store The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 21 Archer School Swim Team The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 22 Archer School Varsity Basketball Team The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 23 Archer School Varsity Soccer Team The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 24 Archer School Varsity Softball Team The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918 25 Archer School Varsity Volleyball Team The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049-2918

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 26 Barbara Dohrmann President Bel Air Skycrest Property X X X X Owners’ Assn. P.O. Box 260503 Encino, CA 91436 27 Sandra Genis Planning Resources 1586 Myrtlewood Costa Mesa, CA 92626 X X X X X X X X X X X X X

on behalf of Brentwood Community Council 28 Cori Solomon President Brentwood Glen Association X X [email protected] [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 29 John Given Boardmember Brentwood Hills Homeowners X X X X X X X Assn. P.O. Box 49495 Los Angeles, CA 90049 30 Donald G. Keller Vice President Brentwood Homeowners Assn. X P.O. Box 49427 Los Angeles, CA 90049 31 Rodney Liber Brentwood Homeowners Assn. X rliber@brentwoodhomeowners. org 32 Brentwood Homeowners Assn. Lisa Robinson Administrative Director X Irobinson@ brentwoodhomeowners.org

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 33 Raymond Klein Secretary, Board of Directors Brentwood Homeowners Assn. X X X X X X X P.O. Box 49427 Los Angeles, CA 90049 34 Rodney Liber Brentwood Homeowners Assn. X P.O. Box 49625 Los Angeles, CA 90049-0625 35 Rodney Liber Brentwood Homeowners Assn. X P.O. Box 49625 Los Angeles, CA 90049-0625 36 Peter Smailes Headmaster Curtis School X 15871 Mulholland Dr. Los Angeles, CA 90049

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 37 John Amato Vice President Harvard-Westlake School X 700 N. Faring Rd. Los Angeles, CA 90077 38 Chris Joffe Joffe Emergency Services X 1454 Cloverfield Blvd. Santa Monica, CA 90404 39 Raymond R. Michaud, Jr. Headmaster The John Thomas Dye School X 11414 Chalon Road Los Angeles CA 90049 40 Laurie Wolke Head of School Laurence School X 13639 Victory Blvd. Valley Glen, CA 91401

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 41 Barbara E. Wagner Head of School Marlborough School X 250 South Rossmore Ave. Los Angeles, CA 90004 42 Jacqueline Landry Head of School Marymount High School X 10643 Sunset Blvd. Los Angeles, CA 90077 43 Dalal Hassouna-Antabli Head of School New Horizon School Westside X 1819 Sawtelle Blvd. Los Angeles, CA 90025 44 James Alan Atman, Ph.D. Headmaster Oakwood School X 11600 Magnolia Blvd. North Hollywood, CA 91601- 3015

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 45 Barbara Kohn President Pacific Palisades Community X X Council P.O. Box 1131 Pacific Palisades, CA 90272 46 Frances Tibbits Pacific Palisades Residents Assn., Inc. X X X P.O. Box 617 Pacific Palisades, CA 90272 47 Residential Neighbors of Archer X X X X X X X X X [email protected] 48 Margarita Pagliai Head of School Seven Arrows Elementary School X 15240 La Cruz Dr. Pacific Palisades, California 90272

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 49 Deborah David Head of School St. James’ Episcopal School X 625 S. St. Andrews Place Los Angeles, CA 90005 50 Stu Work Head of School St. Matthew’s Parish School X 1031 Bienveneda Ave. Pacific Palisades, CA 90272 51 Beverly Grossman Palmer Strumwasser & Woocher LLP X X X X X X X X X X 10940 Wilshire Blvd., Ste. 2000 Los Angeles, CA 90024 52 Stacia Thompson Upper Riviera Homeowners Assn. X X X 1515 Umeo Rd. Pacific Palisades, CA 90272

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 53 Nora Malone Head of School Village School X 780 Swarthmore Ave. Pacific Palisades, CA 90272- 4355 54 H. John Walter III Head of School The Wesley School X 4832 Tujunga Ave. North Hollywood, CA 91601 55 Scott Moran Head of School Westland School X 16200 Mulholland Dr. Los Angeles, CA 90049 56 Bradley Zacuto Head of School Westside Neighborhood School X 5401 Beethoven St. Los Angeles, CA 90066

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 57 Landis Green Head of School Wildwood School X 11811 Olympic Blvd. Los Angeles, CA 90064 58 Tom Gilder Head of School Windward School X 11350 Palms Blvd. Los Angeles, CA 90066

INDIVIDUALS 59 Leslie Aghili X 60 Karen and Dale Alberstone X [email protected] 61 Pamela Alexander 11901 Sunset Blvd. X X X X X Los Angeles, CA 90049 62 Jamee Alperovich 877 S. Tremaine Ave. X Los Angeles, CA 90005

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 63 Lynn K. Altman 382 N. Saltair Ave. X X X X X X Los Angeles, CA 90049 64 Phillipa Altmann 2118 Pelham Ave. X Los Angeles, CA 90025 65 Erika Amaya 7418 Gaynor Ave. X Van Nuys, CA 91406 66 Vanessa Anderson X 67 Lisa Angel X [email protected] 68 Laura Applegate 153 N. Saltair Ave. X X X X X Los Angeles, CA 90049 69 Joseph and Ellen Aragon 429 N. Oakhurst Dr. X Beverly Hills, CA 90210

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 70 Bonnie Arnold P.O. Box 49851 X Los Angeles, CA 90049 71 Paul Arrow 230 N. Bundy Dr. X X Los Angeles, CA 90049 72 Linda Arzt X [email protected] 73 Chad Attie X 74 Katie Baral X [email protected] 75 Julie Bardin 16668 Calle Jermaine X Pacific Palisades, CA 90272 76 Jennifer Barnhill 3616 Cardiff Ave. Apt. 107 X Los Angeles, CA 90034 77 Marissa Bass 8217 Beverly Blvd., Ste. 7 X Los Angeles, CA 90048

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 78 Richard L. Benfield 735 Alma Real Dr. X Pacific Palisades, CA 90272 79 Kristen Benjamin X 80 Sharma Bennett 125 N. Barrington Ave., No. 205 X X X X Los Angeles, CA 90049 81 Marc Berger 233 S. Barrington Ave., Apt. 303 X Los Angeles, CA 90049 82 Tracy Berglass X X [email protected] 83 Bruce Berman 750 Malcolm Ave. X Los Angeles, CA 90024 84 Marcia R. Berman 11922 Iredell St. X Studio City, CA 91604

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 85 Phyllis Bernard 1433 Georgina Ave. X X X Santa Monica, CA 90402 86 Russell L. Berney, Esq. Berney Law Corp. 11693 San Vicente Blvd., Ste. X 320 Los Angeles, CA 90049 87 Shane Berning 2211 Overland Ave. X Los Angeles, CA 90064 88 Robert D. Beyer X 89 Natalie Blake and Steven Schwartz X 2810 Mandeville Canyon Rd. Los Angeles, CA 90049 90 Terry Blecher 1516 Oak St. X Santa Monica, CA 90405

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 91 Tracy Blum 2573 Greenvalley Rd. X Los Angeles, CA 90046 92 Matthew Bombeck X [email protected] 93 Stephen D. and Barbara Bomes 12548 Promontory Rd. X Los Angeles, CA 90049 94 Ginger Bower X [email protected] 95 Susan H. Brin 8336 W. Fourth St. X Los Angeles, CA 90048 96 Michael Brodsky 11980 San Vicente Blvd., Ste. X 612 Los Angeles, CA 90049 97 Noelle Brooks 1116 S. Highland Ave. X Los Angeles, CA 90019

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 98 Lindsay Browder X 99 Rachel Brown 3122 Grand View Blvd. X Los Angeles, CA 90066 100 Barbara Bruser Co-Chair, Archer Board of X Trustees [email protected] 101 Tanya and Alex Bryzgalova X [email protected] 102 April M. Bujent 1601 Marine St. X Santa Monica, CA 90405 103 Suzanne Bunzel 485 N. Bowling Green Way X X X Los Angeles, CA 90049 104 Tami Burks 5520 Eileen Ave. X Los Angeles, CA 90043

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 105 Nina Bush 4131 Madison Ave. X Culver City, CA 90232 106 Andrew Callender X 107 Danny Cannon 466 Homewood Rd. X Brentwood, CA 90049 108 Nicole Cannon 466 Homewood Rd. X Los Angeles, CA 90049 109 Mark Caplow E. M. Caplow and Assoc. X X 9533 Pico Blvd. Los Angeles, CA 90035 110 April Carletto 4953 Cahuenga Blvd., #B X North Hollywood, CA 91601- 4745

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 111 Gena Carpenter 2028 Avenida Vista del Monte, X No. 1 Simi Valley, CA 93063 112 Mike Carter X 113 Sal Casola 321 N. Saltair Ave. X X X Los Angeles, CA 90049 114 Sal Casola 321 N. Saltair Ave. X Los Angeles, CA 90049 115 Andrea Cayton 2379 Earls Ct. X Los Angeles, CA 90077 116 Lisa and Daniel Cerone 4907 Densmore Ave. X Encino, CA 91436 117 Amanda Brown 243 S. Mapleton Dr. X Los Angeles, CA 90024

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 118 Justin Chang Trustee, Archer School for Girls X 243 S. Mapleton Dr. Los Angeles, CA 90024 119 Antonia Chan-Goldsobel X X X [email protected] 120 Amy Jones Chapman 621 N. Saltair Ave. X X Los Angeles, CA 90049 121 Catie R. Chase 376 Calle Mazatlan X Newbury Park, CA 91320 122 Maria Chavez 475 S. New Hampshire, No. 103 X Los Angeles, CA 90020 123 John Chen X 124 Anthony Chicco 5225 Blakeslee Ave., Apt. 419 X North Hollywood, CA 91601

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 125 Kyong Suk Chon X [email protected] 126 Bruce Chorpita 13764 Raywood Dr. X Los Angeles, CA 90049 127 Patrick Cole 11718 Chaparal St. X Los Angeles, CA 90049 128 Danielle Collins 11747 W. Sunset Blvd., No. 224 X X X Los Angeles, CA 90049 129 H. Jean Cornyn 110 Old Course Dr. X Newport Beach, CA 92660 130 Keisha Courtney 1630 N. Edgemont St., #D7 X Los Angeles, CA 90027

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 131 Robb Cox Retail Real Estate Leasing 11661 San Vicente Blvd., Ste. X X 820 Los Angeles, CA 90049 132 Dorothy F. Crawley 11901 W. Sunset Blvd., Unit 201 X X X Los Angeles, CA 90049 133 Dorothy Crawley X X [email protected] 134 Adele Cygelman and Bob Moore 9750 Yoakum Dr. X Beverly Hills, CA 90210 135 Stefanie Daehler 11706 Mayfield Ave., Apt. 9 X Los Angeles, CA 90049 136 Theresa M. Dahlin X

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 137 Shannon E. Daley Brian Varnum X 602 12th St. Santa Monica, CA 90402 138 Ellen Danna 13129 Sherry Ln. X Los Angeles, CA 90049 139 Mirella Dapretto, Ph.D. Professor Ahmanson-Lovelace Brain Mapping Center, Rm. 215 X UCLA Dept. of Psychiatry and Biobehavioral Sciences 660 Charles E. Young Dr. S. Los Angeles, CA 90095-7085 140 Stephanie Darrow 425 N. Croft Ave. X Los Angeles, CA 90048 141 Raphael Darvish, M.D., M.B.A. 11907 Chaparal St. X X Los Angeles, CA 90049

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 142 Allison Davis X [email protected] 143 Geena Davis Founder and Chair Institute on Gender in Media X 4712 Admiralty Way, Ste. 455 Marina Del Rey, CA 90292 144 Jane P. Davis 4323 Campbell Dr. X Los Angeles, CA 90066 145 Marsha and James de Vera 9864 Wilshire Blvd. X Beverly Hills, CA 90210 146 Olivia K. DeCarlo 3376 Rowena Ave., No. 205 X Los Angeles, CA 90022 147 Carla Delgado 4867 W. 21st St. X Los Angeles, CA 90016

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 148 Barbara Deming 320 N. Saltair Ave. X X X Los Angeles, CA 90049 149 Rosy DePaul X [email protected] 150 Steven DePaul and Beth Rendeiro X [email protected] 151 Jennifer Dohr [email protected] X 152 James Donnel 1722 Palisades Dr. X Pacific Palisades, CA 90272 153 Samantha Coyne Donnel X 154 Suzie Doran 10960 Wilshire Blvd., Ste. 700 X Los Angeles, CA 90024

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 155 Amy Duarte 14350 Addison St., No. 202 X Sherman Oaks, CA 91423 156 David Reddy and Betty Duffy Principals/Design R&D Architects X 12811 Venice Blvd. Venice, CA 90066 157 Caitlin S. Duffy 3596 S. Centinela Ave., Apt. 212 X Los Angeles, CA 90066 158 Iyad Duwaji X [email protected] 159 Barbara (Bunni) Dybnis 356 N. Skyewiay Rd. X X X X Los Angeles, CA 90049 160 Debora Edmunds 2576 Cordelia Rd. X X Los Angeles, CA 90049

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 161 Noa Ehrlich 226 Oceano Dr. X Los Angeles, CA 90049 162 Brett Elkins 11592 W. Sunset Blvd. X Los Angeles, CA 90049 163 Katrina Eroen 1606 Viewmont Dr. X Los Angeles, CA 90069 164 Sylvie Escande 11730 W. Sunset Blvd. X Los Angeles, CA 90049 165 Marni Eshel X [email protected] 166 Geoffrey Evans X [email protected] 167 Tatiana Evans 19440 Coslin Ave. X Carson, CA 90746 168 Reed Farley X

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 169 Stephanie Ferri X 170 Lauren (Hochberg) Finkelstein X [email protected] 171 Eileen Finney X 172 Lane Fischman X 173 Lauren Fite X [email protected] 174 Margaret Michaels Fleming X X X X [email protected] 175 Blair Frank X [email protected] 176 Julie and Steven Frank X [email protected] 177 Tena Frank X [email protected] 178 Amanda Freiler 5461 Yarmouth Ave., #35 X Encino, CA 91316

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 179 Beth C. Friedman Board of Trustees The Archer School for Girls X 248 South Mapleton Dr. Los Angeles, CA 90024 180 Dodi Fromson X X X [email protected] 181 Miho Fukuma 2114 Butler Ave. X Los Angeles, CA 90025 182 Catherine G. Fuller 762 Grenment Ave. X Los Angeles, CA 90024 183 Jennifer Galloway and Dan Ediger X 7928 Kenyon Ave. Los Angeles, CA 90045 184 Tracy Ganzer 5230 Whitaker Ave. X Encino, CA 91436

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 185 Tom and Patti Garrick 2617 Marlu Dr. X Los Angeles, CA 90046 186 Rita Gattegno-Harkins X X X X X X X X [email protected] 187 Clari Gazcon 423 S. Bedford Dr. X Beverly Hills, CA 90012 188 Talia Geffen 1940 Malcolm Ave., Apt. 208 X Los Angeles, CA 90025 189 Lisa M. Gellman 24921 Kit Carson Rd. X Hidden Hills, CA 91302 190 Lisa Gellman 24921 Kit Carson Rd. X Hidden Hills, CA 91302 191 Ann Gentry 700 Halliday Ave. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 192 Frank Gerechter 3646 Mandeville Canyon Rd. X X X Los Angeles, CA 90049 193 Christine Germano 728 23rd St. X Santa Monica, CA 90402 194 Ann and Jim Gianopulos 410 N. Carmelina Ave. X Los Angeles, CA 90049 X Mimi Gianopulos 195 4604 Los Feliz BIvd., No. 209 X Los Angeles, CA 90027 196 Cushman Gillen X 197 Ingrid B. Girod 560 Warner Ave. X Los Angeles, CA 90024 198 Beth Gold X 199 Aya Kimura Goldberg 242 S. Westgate Ave. X Los Angeles, CA 90049

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 200 Earl Goldberg 242 S. Westgate Ave. X Los Angeles, CA 90049 201 Earl Goldberg 242 S. Westgate Ave. X Los Angeles, CA 90049 202 Earl and Aya Goldberg 242 S. Westgate Ave. X Los Angeles, CA 90049 203 Mark Gordon X [email protected] 204 Marsi Gore 3314 Van Allen Pl. X Topanga, CA 90290 205 Pei-Ying Gosselin 646 S. Barrington Ave., #114 X Los Angeles, CA 90049 206 Demetress Graham demetress.graham@tetratech. X com

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 207 Caroline Grainge X [email protected] 208 Lucian Grainge Chairman and CEO Universal Music Group X 2220 Colorado Ave. Santa Monica, CA 90404 209 Robert A. Greenfield 455 N. Barrington Ave. X X X X X Los Angeles, CA 90049 210 Roberta (Bobbie) Greenfield 455 N. Barrington Ave. X X X X X Los Angeles, CA 90049 211 Charles S. Grobe 172 S. Woodburn Dr. X X X X Los Angeles, CA 90049 212 Sheryl Levine Guterman 960 S. CarmeIina Ave. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 213 Lauren Haas 1109 Tower Rd. X Beverly Hills, CA 90210 214 Alexia Haidos Smart Exposure X 2441 34th St., Apt. D Santa Monica, CA 90405 215 Shawn Cailey Hall X [email protected] 216 Jill Hall X [email protected] 217 Michael O. Hall, Ph.D. 1268 S. Beverly Glen Blvd. X Los Angeles, CA 90024 218 Cynthia Hallinan 2430 30th St. X Santa Monica, CA 90405 219 David Hallinan 2430 30th St. X Santa Monica, CA 90405

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 220 Oona Hanson 3735 Laurel Canyon Blvd. X Studio City, CA 91604 221 Nicole P. Hart 7275 Franklin Ave., Apt. 213 X Los Angeles CA 90046 222 Mary Haughie X 223 Paul and Tess Hechmer 7800 Henefer Ave. X Los Angeles, CA 90045 224 Barbara Hechtman 119 S. Westgate Ave. X X Los Angeles, CA 90049-4222 225 Catherine H. Helm 227 S. Windsor BIvd. X Los Angeles, CA 90004 226 Paul Herman X [email protected] 227 Lili Hermeline X

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 228 Jose A. Hernandez Assistant Systems Administrator Technology Department X The Archer School for Girls 11725 Sunset Blvd. Los Angeles, CA 90049 229 Kerry Hernandez 28913 Grayfox St. X Malibu, CA 90265-4254 230 Michael Heslov 1101 Montana Ave., Ste. A X Santa Monica, CA 90403 231 Nicole Hillebrandt 11747 W. Sunset BIvd., No. 126 X X X Los Angeles, CA 90049 232 Korinne Mitchell Hinderliter X [email protected] 233 Saryl S. Hirsch-Samuelson 10401 Wyton Dr. X Los Angeles, CA 90024

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 234 Christy Hobart 1101 Yale St. X Santa Monica, CA 90403 235 David Hoberman 1727 Mandeville Canyon Rd. X Los Angeles, CA 90046 236 Harry Hochman Pachulski Stang Ziehl & Jones LLP X 10100 Santa Monica Blvd., 13th Fl. Los Angeles, CA 90067-4003 237 Astrid Holczer 10968 Wilkins Ave., No. 201 X Los Angeles, CA 90024 238 Ann Hollister 216 S. Westgate Ave. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 239 Debby Hopper 2826 Roscomare Rd. X Los Angeles, CA 90077-1627 240 Jána Howard 12813 La Maida St. X Valley Village, CA 91607-3314 241 Arianna Huffington Huffington Post Media Group X 770 , Fifth Fl. New York, NY 10003 242 Laila Hussain X [email protected] 243 Illegible-01 16927 Livorno Dr. X Pacific Palisades, CA 90272 244 Illegible-02 101 N. Plymouth Blvd. X Los Angeles, CA 90004-3831

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 245 Illegible-03 [Patricia ___] 78 Fremont Pl. X Los Angeles, CA 90005-3858 246 Illegible-04 [Jacqueline B___] 1465 N. Bundy Dr. X Los Angeles, CA 90049 247 Illegible-05 6912 W. 85th Pl. X Los Angeles, CA 90045-2605 248 Illegible-06 [___ Seaman] 320 N. Carmelina Ave. X Los Angeles, CA 90049 249 Illegible-07 [Roxane Coh___] X X Daniel P. In X 250 251 Mark Itzigsohn 1638 Greenfield Ave. X Los Angeles, CA 90025

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 252 Rob Jacobs 700 Halliday Ave. X Los Angeles, CA 90049 253 Larry Jacobsen 1800 Mandeville Canyon Rd. X Los Angeles, CA 90049 254 Pam Jacobson 1800 Mandeville Canyon Rd. X Los Angeles, CA 90049-2223 255 Jerilyn Joel X [email protected] 256 Jennifer Justman 9621 Cedarbrook Dr., X Beverly Hills, CA 90210 257 Lisa G. Kaminir 7477 Palo Vista Dr. X Los Angeles, CA 90046 258 Atsuko Kanai 235 S. San Pedro #151 X Los Angeles, CA 90012

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 259 Colleen Kaner 12020 Saltair Pl. X Los Angeles, CA 90049 260 Colleen and Mark Kaner 12020 Saltair Pl. X Los Angeles, CA 90049 261 Melanie Kaplan 1520 Old Oak Rd. X X X X X X Los Angeles, CA 90049 262 Paula Kaplan 2740 Deep Canyon X Beverly Hills, CA 90210 263 Sharona and Foo Katan 224 N. Barrington Ave. X X X X Los Angeles, CA 90049

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 264 Bernard J. Katz, M.D. Geoffrey Evans UCLA-Santa Monica Bay Physicians X 2001 Santa Monica Blvd., Ste. 1080 Santa Monica, CA 90404 265 Eric Kaufman 235 Bronwood Ave. X X Los Angeles, CA 90049 266 Barry and Lisa Kay 9113 David Ave. X Los Angeles, CA 90034 267 Lily Kaye 149 South Barrington Ave., No. X 687 Los Angeles, CA 90049 268 Arezu Kaywanfar 701 Teakwood Rd. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 269 Heather S. Keddie 11973 Montana Ave. X Los Angeles, CA 90049 270 Mary Beth Kelso 12234 Everglade St. X Los Angeles, CA 90066 271 Kathleen Kennedy President X Lucasfilm 272 Phil Keoghan NOW X 151 Pier Ave., No. 184 Santa Monica, CA 90405 273 Nicola Kerner 249 N. Tigertail Rd. X Los Angeles, CA 90049 274 Sandra and Brian Kiley 4222 Bellingham Ave. X Studio City, CA 91604

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 275 Ebony O. King 329 S. Cloverdale Ave., #1 X Los Angeles, CA 90036 276 Wendy Kirshner X [email protected] 277 Amanda Kleiman 118 Grant St. X Denver, CO 80203 278 Eunkyung Koh X [email protected] 279 Stacey Kohl 422 21st Pl. X Santa Monica, CA 90402 280 Mayumi Koyabu 10840 Vicenza Way X Los Angeles, CA 90077 281 John T. Kretchmer 13452 Valley Vista Blvd. X Sherman Oaks, CA 91423

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 282 Craig Krull Craig Krull Gallery Bergamot Station X 2525 Michigan Ave., Bldg. B3 Santa Monica, CA 90404 283 Shari Young Kuchenbecker, Ph.D. Stephen L. Kuchenbecker, M.D. X X X 157 N. Saltair Ave. Los Angeles, CA 90049 284 Stephen L. Kuchenbecker, M.D. Shari Young Kuchenbecker, Ph.D. X X X 157 N. Saltair Ave. Los Angeles, CA 90049 285 Mati Laan 1205 Pacific St. X Santa Monica, CA 90405 286 Patty Lancaster 806 Wellesley Ave. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 287 Quinci Land 15926 Index St. X Granada Hills, CA 91344 288 Dr. John and Debbi Landsberger 10970 Bellagio Rd. X Los Angeles, CA 90077 289 David A. Lapin Lapin & Davis, LLP X 9201 W. Olympic Blvd., Ste. 200 Beverly Hills, CA 90212 290 Fran Lasker 11918 Chaparal St. X Los Angeles, CA 90049 291 Anthony Leach X [email protected] 292 Amanda Leach-Rouvi 4910 Valjean Ave. X Encino, CA 91436

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 293 Deborah Lehman, MD Clinical Director, Pediatric Infectious Diseases X Cedars-Sinai Medical Center 8700 Beverly Blvd. Los Angeles, CA 90048 294 Mara Lenkov 4924 Agnes Ave. X Valley Village, CA 91607 295 Laurie Lerner 3626 Mandeville Canyon Rd. X X X X Los Angeles, CA 90049-1024 296 Rhonda Leshman 4900 Overland Ave., #235 X Culver City, CA 90230 297 James Levesque President Healthcare Development X 1112 Montana Ave., Ste. 545 Santa Monica, CA 90403

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 298 James S. Levine 472 N. Barrington Ave. X X X Los Angeles, CA 90049 299 Mary Ann Lewis 221 S. Burlingame Ave. X X X Los Angeles, CA 90049 300 Miranda Lievsay X [email protected] 301 Lauren G. Linde 10431 Dunleer Dr. X Los Angeles, CA 90064 302 Susanna Linsley 12506 Pacific Ave., #10 X Los Angeles, CA 90066 303 Anita and Bill Lischak 517 Ninth St. X Santa Monica, CA 90402 304 Andrea Locke 8306 Wilshire Blvd., #506 X Beverly Hills, CA 90211

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 305 Alexandra Lodge 530 Moreno Ave. X Los Angeles, CA 90049 306 Jacob London X 307 Marcos López 2531 S. Westgate Ave. X Los Angeles, CA 90064 308 Nicola Lubitsch 11901 Sunset Blvd., No. 109 X X X X X X Los Angeles, CA 90049 309 Mitchell and Roxanne Lucas 410 S. Barrington Ave. X X X Los Angeles, CA 90049 310 Esther Lumer 849 Leonard Rd. X X X Los Angeles, CA 90049 311 Janet Lyon 1114 Princeton St., Apt. 4 X Santa Monica, CA 90403

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 312 Patrick and Mia Lyons 1740 Stearns Dr. X Los Angeles, CA 90035 313 Susan Macdonald X [email protected] 314 Marci Pool David Madden X X X X X 254 N. Barrington Ave. Los Angeles, CA 90049 315 Brooke and Jonathan Maile 468 22nd St. X Santa Monica, CA 90402 316 Monna and Simon Mainwaring 2515 Patricia Ave. X Los Angeles, CA 90064 317 Sloane K. and Robert Malecki X [email protected] 318 Rachel Mandelbaum 10840 Lindbrook Dr., No. 4 X Los Angeles, CA 90024

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 319 Katarzyna Marciniak 400 S. Cloverdale Ave. X Los Angeles, CA 90036 320 Maddie Marcus 132 N. Hayworth Ave., No. 5 X Los Angeles, CA 90048 321 Laura and Kevin Marks X [email protected] 322 Laura Marks 567 Almoloya Dr. X Pacific Palisades, CA 90272 323 Jane Marlis 409 N. Bundy Dr. X X X Los Angeles, CA 90049 324 Bob Marshall X X X X X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 325 Frank Marshall President The Kennedy/Marshall Company X 619 Arizona Ave. Santa Monica, CA 90401 326 Mrs. Nancy Martin X [email protected] 327 Sarah E. Martin X 328 Kelly Rapf Martino 11773 Sunset Blvd. X X X X X X X X Los Angeles, CA 90049 329 Amelia R. Mathis X 330 Shawn F. and Sepideh Rabi Matian X X X X X X X [email protected] 331 Malia McClurg X 332 Bowen H. McCoy 11755 Chaparal St. X X X X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 333 Christina McIntosh The Archer School for Girls X 11725 Sunset Blvd. Los Angeles, CA 90049 334 Ann and Don McLennan X [email protected] 335 Steven McMillion 2044 W. 64th St. X Los Angeles, CA 90047 336 Tanya R. McMillion 2044 W. 64th St. X Los Angeles, CA 90047 337 Sara E. Melzer 920 Amherst Ave. X X X Los Angeles, CA 90049 338 Tim Miklaucic Cordoba Music Group X 1455 19th St. Santa Monica, CA 90404

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 339 Arleen Milian 1008 N. Heliotrope Dr. X Los Angeles, CA 90029 340 Dominique Miller 350 Albany St., Apt. 10A X New York, NY 10280 341 Donna Mills 2346 Mandeville Canyon Rd X Los Angeles, CA 90049 342 Kathy and Dale Mitchell X [email protected] 343 Halima Mohammed 502 12th St. X Santa Monica, CA 90402 344 Suleman Mohammed 502 12th St. X Santa Monica, CA 90402

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 345 Catrice Monson Vice President, Labor Relations CBS X 4024 Radford Ave. Studio City, CA 91604 346 Enrique Montoya 6800 Corbin Ave., No. 208 X Reseda, CA 91335 347 Katherine (Kemmy) Moran katherine.moran@pepperdine. X edu 348 Kari Morioka 1725 Butler Ave., #104 X Los Angeles, CA 90025 349 Alexandra Moritz X [email protected] 350 Chris Mosier 4320 Corinth Ave. X Culver City, CA 90230

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 351 Sara Mottahedan 189 Granville Ave. X Los Angeles, CA 90049 352 Jenn Babin Moynihan 12412 Pacific Ave., #7 X Los Angeles, CA 90066 353 Eurydice Mundy and James Mundy III X 10400 S. 3rd Ave. Inglewood, CA 90303 354 Esmeralda Muñoz 16643 Citronia St. X Northridge, CA 91343 355 Cara Natterson 341 S. Westgate Ave. X Los Angeles, CA 90049 356 Lisa Nesbitt 441 N. Cliffwood Ave. X X X X X X X Los Angeles, CA 90049

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 357 Travis Nesbitt 2137 Benecia Ave. X Los Angeles, CA 90025 358 Bethany Neubauer X 359 Lynn and Larry Neuberg 2161 Queensborough Ln. X Los Angeles, CA 90077 360 Dana Newman and Miles Feldman X [email protected] 361 Sofi Newmyer X [email protected] 362 Dorothy Nichols 3120 Coolidge Ave. X Los Angeles, CA 90066 363 Terry Nikkhoo 130 N. Westgate Ave. X X X X X X X X X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 364 Jennifer Northrup 2160 S. Beverly Glen Blvd. X Los Angeles, CA 90025 365 John Ohanesian X [email protected] 366 Jay T. Ornellas 967 Casiano Rd. X X X Los Angeles, CA 90049 367 Nancy Ortenberg 848 S. Sycamore Ave. X Los Angeles, CA 90036 368 Laura Owens 13055 Evanston St. X Los Angeles, CA 90049 369 Felicia Paik 136 Esparta Way X Santa Monica, CA 90402 370 Rose D. Paik X

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 371 Mitch Paradise 11848 Dorothy St., No. 8 X X X Los Angeles, CA 90049 372 Sherrie Pastron 551 Amalfi Dr. X Pacific Palisades, CA 90272 373 Nilusha Patel 1451 26th St. X Santa Monica, CA 90045 374 Jenny Petersson X [email protected] 375 Jeanne Phares 11515 W. Pico Blvd. X Los Angeles, CA 90064 376 Thomas and Mary Pilla 207 N. Saltair Ave. X X X X Los Angeles, CA 90049 377 Vivian A. Pine 3440 Mandeville Canyon Rd. X X X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 378 Loretta Pinkett 5811 Bowcroft, No. 4 X Los Angeles, CA 90016 379 Lucy Pinkwater 343 N. Citrus Ave. X Los Angeles, CA 90036 380 Catherine Polisoto X X X X X [email protected] 381 Stefan and Karen Pollack 10520 Seabury Ln. X Los Angeles, CA 90077 382 Tracy Poverstein X 383 Liza Price 242 Bronwood Ave. X Los Angeles, CA 90049 384 Lee Ramer X X [email protected] 385 Evelyn Ramirez-Schultz 5865 W. 78th St. Los Angeles, CA 90045

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 386 Jennifer Ranlo 4210 Woodcliff Rd. X Sherman Oaks, CA 91403 387 Irving Reifman Attorney at Law X X X 18181 Wilshire Blvd., Ste. 1350 Los Angeles, CA 90026 388 Mia Rille 218 25th St. X Santa Monica, CA 90402 389 Norman Rille 218 25th St. X Santa Monica, CA 90402 390 Marcia Roberts X [email protected] 391 Mel Roberts X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 392 Amy Salko Robertson and John Robertson X 1700 Ocean Park Blvd. Santa Monica, CA 90405 393 Luke Robertson 11747 W. Sunset, Apt. 103 X Los Angeles, CA 90049 394 Alain and Sandra Rogier 539 Hanley Pl. X X X Los Angeles, CA 90049 395 Gilly Rojany 226 N. Saltair Ave. X X X X Los Angeles, CA 90049 396 Maria Rojas 7933 Alverstone Ave., No. 7 X Los Angeles, CA 90045 397 Jose Ernesto Rojas-Torres X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 398 Hillary Rollins 1219 Ashland Ave. X Santa Monica, CA 90405 399 Eden Romick X X X [email protected] 400 Steven Romick 355 N. Saltair Ave. X X Los Angeles, CA 90049 401 Rena Ronson 9336 Civic Center Dr. X Beverly Hills, CA 90210 402 David L. Rosenbaum, M.D. 215 N. Saltair Ave. X X X Los Angeles, CA 90049 403 Sandra L. Rosenbaum 215 N. Saltair Ave. X X X X X Los Angeles, CA 90049 404 Brad Rosenberg 15461 Milldale Dr. X Los Angeles, CA 90077

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 405 Nancy Rosenberg 15461 Milldale Dr. X Los Angeles, CA 90077 406 Fariba Rouzroch 1781 Kelton Ave. X Los Angeles, CA 90024 407 Elisa Rubin X [email protected] 408 Timothy Rule 214 N. Bowling Green Way X Los Angeles, CA 90049 409 Robin Russell 217 Westgate Ave. X X X X Los Angeles, CA 90049 410 David Russo and Ann Hallin X [email protected] 411 James Russo 2220 Overland Ave. X Los Angeles, CA 90064

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 412 Karen Richards Sachs 819 N. Roxbury Dr. X Beverly Hills, CA 90210 413 Meredith Salenger X X X X [email protected] 414 Mikael and Nancy Salomon 1665 Summitridge Dr. X Beverly Hills, CA 90210 415 Peter Samuelson Co-Founder Starlight Children’s Foundation X 9412 Kirkside Rd. Los Angeles CA 90035 416 Rebecca Samuelson Dykstra 0243 X 330 De Neve Dr. Los Angeles, CA 90024 417 Kristin and Michael Sant 831 Marco Pl. X Venice, CA 90291

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 418 Annie Santana-Grush 100 Driftwood St. X Marina del Rey, CA 90292 419 Philicia Saunders P.O. Box 83688 X Los Angeles, CA 90083 420 Tamar Saunders X 421 Andrew Schmoller 360 N. Saltair Ave. X X X Los Angeles, CA 90049 422 Brittany Schoof 7545 Hampton Ave. #214 X West Hollywood, CA 90046 423 Joan Schrier 13307 Westcove Dr. X X Los Angeles, CA 90049 424 Joel Schrier X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 425 Barbara Seinfeld Realtor Keller Williams Realty X X X X X X X X 2701 Ocean Park Blvd., Ste. 140 Santa Monica, CA 90405 426 Crystal Sengstaken 1259 N. June St. X Los Angeles, CA 90038 427 Ana Serrano X [email protected] 428 Maria Servello Executive Assistant to the Head of School X The Archer School For Girls 11725 W. Sunset Blvd. Los Angeles, CA 90049 429 Jasmine Shackelford 550 W. Regent St. #205 X Inglewood, CA 90301

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 430 Shireen Shafai 240 E. 79th Street., Apt 28 X New York, NY 10075 431 Nahal Shakib 1490 Capri Dr. X Pacific Palisades, CA 90272 432 Laurie Shearing 905 Centinela Ave. X Santa Monica, CA 90403 433 Lisa Sherman Sherman Law Corp. X 1990 S. Bundy Dr., Ste. 390 Los Angeles, CA 90025 434 Andrea Shintani 1343 Warner Ave. X Los Angeles, CA 90024 435 Hanna Shohfi X 436 Betty Sigoloff X X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 437 Emily Silver X 438 Orly Simpson 435 Westbourne Dr. X Los Angeles, CA 90048 439 Lisa Small X [email protected] 440 Amy Jo Smith President The Digital Entertainment Group X X 10635 Santa Monica Blvd., Ste. 160 Los Angeles, CA 90025 441 Dennis Smith X X [email protected] 442 Kim Smith X 443 Scott C. Smith 3544 Griffith Park Blvd. X Los Angeles, CA 90027 444 Susan Smith X

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 445 Robert Smyth 1019 26th St. X Santa Monica, CA 90403 446 Negar Soufer X [email protected] 447 Jeffrey and Christina Spitz 15210 Friends St. X X X Pacific Palisades, CA 90272 448 Arthur & Maryam St. Antoine 10787 Wilshire Blvd., #1003 X Los Angeles, CA 90024 449 Cari Stahler

[email protected] 450 Ira Stein X X [email protected] 451 Emily Stern 13503 Bayliss Rd. X Los Angeles, CA 90049 452 Violetta Sternberg, Ph.D X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 453 Carly Steward 1070 Bella Vista Ave. X Pasadena, CA 91107 454 Thomas Stockfisch and Linlin Zhang X [email protected] 455 Mindy Stone X 456 Ron Stone 1926 Parnell Ave. X Los Angeles, CA 90025 457 Lisa Stothard-Bernhardt 1905 Benedict Canyon Dr. X Beverly Hills, CA 90210 458 Lindsey and David Strasberg X [email protected] 459 Merle Strauss X X X X [email protected] 460 Katy Strouk 1225 Beverly Estates Ter. X Beverly Hills, CA 90210-2118

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 461 Dan Sturman 591 N. Beachwood Dr. X Los Angeles, CA 90004 462 Lindsay Sturman X [email protected] 463 Susan Sullivan 1700 Greenleaf Canyon Rd. X Topanga, CA 90290 464 Jay Sures 485 Halvern Dr. X X X Los Angeles, CA 90049 465 Janis Susskind 282 N. Saltair Ave. X X X X Los Angeles, CA 90049 466 Hannah Sussman X [email protected] 467 Catherine Sustana 13764 Raywood Dr. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 468 Robin Swartz X [email protected] 469 Maryam Talaie, D.D.S. 11830 Mayfield Ave., No. 102 X Los Angeles, CA 90049 470 Kristin Taylor 1164 N. Mentor Ave. X Pasadena, CA 91104 471 Courtney Teller 2131 Century Park Ln., No. 216 X Los Angeles, CA 90067 472 Ivan and Jana Tether 11901 W. Sunset Blvd., No. 209 X X X X X X Los Angeles, CA 90049 473 Chelsea Thomas X 474 Jackie Thompson 3256 Mandeville Canyon Rd. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 475 Jackie Thompson 3256 Mandeville Canyon Rd. X Los Angeles, CA 90049 476 Vince Thompson 3256 Mandeville Canyon Rd. X Los Angeles, CA 90049 477 Wendy Thornton 111 Marquez Pl., #304 X Pacific Palisades, CA 90272 478 Olivia Tiffany 2044 Glencoe Ave. X Venice, CA 90291 479 Suzanne Todd X [email protected] 480 Miranda Tollman X [email protected] 481 Noelle Tongue 5503 Village Green X Los Angeles, CA 90016

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 482 Elizabeth Topkis X [email protected] 483 Kim and Kevin Traenkle 1107 Chautauqua Blvd. X Pacific Palisades, CA 90272 484 Richard and Hazel Trevor 11901 Sunset Blvd. X X X Los Angeles, CA 90049 485 Leonard Turner X [email protected] 486 Kamil Turowski 400 S. Cloverdale Ave. X Los Angeles, CA 90036 487 Efren Tuxpan X [email protected] 488 Susan Van Horn 11730 Mayfield Ave. #201 X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 489 Carol Velasquez 11701 Texas Ave #213 X Los Angeles, CA 90025 490 Isaac Velasquez 2911 Redondo Blvd., No. 3 X Los Angeles, CA 90016 491 Helen Vera X [email protected] 492 Maria Vera 3176 Stoner Ave. X Los Angeles, CA 90066 493 Carol Vernon X [email protected] 494 Nancy Vescovo 250 Amalfi Dr. X Santa Monica, CA 90402 495 Bruce Wagner 11919 Currituck Dr. X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

Q

IGHT L

, ATER ATER ARKING

W

/P OILS AZARDOUS

REENHOUSE REENHOUSE IEWS S

H

V

ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 496 Clint Walker 11940 Chaparal St. X Los Angeles, CA 90049 497 Christine Walsh X X X X 498 Gretchen R. Warner X 499 Thelma and Eric Waxman 11840 Chaparal St. X X X X X X X X X X Los Angeles, CA 90049 500 Kate Webster 11676 Chenault St., No. 9 X Los Angeles, CA 90049 501 Jill Weinstein 11919 Currituck Dr. X Los Angeles, CA 90049 502 Fredda Weiss Box 49655 X X X 200 S. Barrington Ave. Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

Q

IGHT L

, ATER ATER ARKING

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REENHOUSE REENHOUSE IEWS S

H

V

ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 503 John Weissenbach 12824 Evanston St. X X X Los Angeles, CA 90049 504 Candace and Barry Weisz X X [email protected] 505 Angela Weltman, Ph.D. 14376 Millbrook Dr. X Sherman Oaks, CA 91423 506 John Whitesell 11706 Chaparal St. X X X X Los Angeles, CA 90049 507 Leigh Williams 11728 Chaparal St. X Los Angeles, CA 90049 508 Sharifah Z. Williams 1016 N. Heliotrope Dr., Apt. 9 X Los Angeles, CA 90029 509 Aundrea Williford 7207 Washington Ave. X Whittier, CA 90602

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

Q

IGHT L

, ATER ATER ARKING

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/P OILS AZARDOUS

REENHOUSE REENHOUSE IEWS S

H

V

ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 510 Brian Wogensen 3382 Halderman St. X Los Angeles, CA 90066 511 Damon Wolf 2227 Montana Ave. X Santa Monica, CA 90405 512 Wilma Wong X [email protected] 513 Catherine Wood 526 Moreno Ave. X Los Angeles, CA 90049 514 Jennifer and Graham Woolf 129 N. Anita Ave. X Los Angeles, CA 90049 515 David and Zofia Wright 11845 Chaparal St. X X X X X X X X X Los Angeles, CA 90049 516 Gretchen Wu 439 N. Van Ness Ave., Apt. 8 X Los Angeles, CA 90004

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

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, ATER ATER ARKING

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/P OILS AZARDOUS

REENHOUSE REENHOUSE IEWS S

H

V

ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 517 Steve Wyler 11817 Chaparal St. X Los Angeles, CA 90049 518 Valerie N. Yoshimura, Ph.D. 11353 Ovada Pl., Apt. 8 X Los Angeles, CA 90049 519 Mark Zakarin 12921 Evanston St. X X Los Angeles, CA 90049 520 Peter Zeegen, M.D. 229 Oceano Dr. X X Los Angeles, CA 90049 521 Jennifer K. Zeller 753 Chapala Dr. X Pacific Palisades, CA 90272 522 Paul Zimmelman X [email protected]

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

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REENHOUSE REENHOUSE IEWS S

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ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G

FORM LETTERS 523 Archer School Support Form X Letter

LATE LETTERS 524 Larry Watts Chairman Brentwood Community Council X X 149 S. Barrington Ave., Box 194 Los Angeles, CA 90049 525 Brentwood Homeowners Assn. Rodney Liber Vice President X rliber@brentwoodhomeowners. org 526 Wendy-Sue Rosen President Brentwood Residents Coalition X P.O. Box 491103 Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

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REENHOUSE REENHOUSE IEWS S

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ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 527 Charles Bernstein 20575 Cheney Dr. X X X X Topanga, CA 90290 528 Sarah Boyd X [email protected] 529 Dehua Chen 234 S. Westgate Ave. X Los Angeles, CA 90049-4206 530 Dehua Chen 234 S. Westgate Ave. X Los Angeles, CA 90049 531 Bob Cortes X [email protected] 532 Harvey Flax 2175½ Mandeville Canyon Rd. X X Los Angeles, CA 90049-1824 533 Paul Herman 600 Hanley Way X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

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REENHOUSE REENHOUSE IEWS S

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ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 534 Bernadette Huang 249 S. Westgate Ave. X Los Angeles, CA 90049 535 Joyce Madeline Hyman and Peter Abrahams X 847 Iliff St. Pacific Palisades, CA 90272 536 Pamela and Bob Krupka 1870 Mango Way X X X X Los Angeles, CA 90049 537 Bret Lewis 3955 Mandeville Canyon Rd. X Los Angeles, CA 90049 538 Ken Marks X X [email protected] 539 Greta McAnany 11630 Chenault St. X X X X X X X Los Angeles, CA 90049-4569

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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ASSES LARE ATERIALS G M UALITY /G

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REENHOUSE REENHOUSE IEWS S

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ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 540 Mark Mosch 221 N. Saltair X Los Angeles, CA 90049 541 Rockwell A. Schnabel 162 S. Burlingame Ave. X Los Angeles, CA 90049 542 Joy Stanley Joy Stanley Law Corp. Water Garden X 2425 Olympic Blvd., Ste. 4000-W Santa Monica, CA 90404 543 Cynthia Truhan 125 N. Barrington Ave., #206 X X X X Los Angeles, CA 90049 544 Robert Turbin 426 N. Barrington Ave. X X X X X X X Los Angeles, CA 90049

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Table III-1 (Continued) Matrix of Comments Received in Response to the Draft EIR

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REENHOUSE REENHOUSE IEWS S

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ESOURCES /G , THER ESCRIPTION . R CCESS

O D /O UPPLY ROTECTION /A N S P SE ROTECTION

HADING U UALITY P S Q ATER ATER ASTEWATER ENERAL EOLOGY AND ESTHETICS IR ULTURAL AZARDS AND YDROLOGY AND OISE LTERNATIVES ONSTRUCTION ROJECT ROJECT OLICE AND IRE RAFFIC ETTER A A C G N L W AND H CEQA C L P F W H P T A COMMENTER G 545 Bob Waldorf 212 S. Woodburn Dr. X X Los Angeles, CA 90049-3029 546 Toby Waldorf 212 S. Woodburn Dr. X X Los Angeles, CA 90049 547 Robert H. Wintroub, M.D. X X Lillian Wintroub 548 Eric Edmunds President X X X Brentwood Hills Homeowners Assn.

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Topical responses have been prepared to address commonly raised topics as reflected in the comments made regarding the Draft EIR. These topical responses include the following:

Topical Response 1: Refinements to Proposed Operations

Topical Response 2: Removal of Athletic Field Lighting and Refinements to Lighting

Topical Response 3: Overview of Reduced Parking Spaces, Parking Demand and Supply, and Parking Enforcement

Topical Response 4: Additional Measures to Reduce Noise

Topical Response 5: Additional Mitigation Measures to Eliminate Significant Traffic Impacts

Topical Response 6: Overview of Construction Traffic and Parking

Topical Response 7: Potential Traffic Impacts Associated with Proposed Campus Operations

Topical Response 8: Summary of Impacts from Parking Structure

Topical Response 9: Emergency Vehicle Access

Topical Response 10: Traffic Congestion along

Topical Response 11: Overview of Construction Refinements

Topical Response 12: Site Plan Consistency with the Residential Scale and Character of the Neighborhood

Topical Response 13: Use of Existing Residential Properties

Topical Response 14: Residential Neighbors’ Proposed Alternative

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Topical Response 15: Alternative Locations

Topical Response 16: Environmental Review and Conditional Use Permit Processes

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1. Refinements to Proposed Operations

In response to comments, the proposed campus operations set forth in the Draft EIR have been revised. The Project proposes to address the instructional needs of existing and future programs provided by Archer. A new CUP and other concurrent entitlement requests, if approved by the decision-makers, would subject the School to a new set of conditions of approval, including conditions regarding the compatibility of the School’s operations and its facilities with the surrounding neighborhood.

As provided in the general corrections subsection of Section II, Corrections and Additions to the Draft EIR, of this Final EIR, the additional restrictions on School hours and operations are as follows:

 General Hours of Operation shall include Instruction, Extracurricular Activities, and Customary School Activities.

– Instruction is defined as all teaching and learning at Archer. Instruction includes physical education classes. Instruction shall be permitted at varying times based on the Instruction location.

o Instruction shall be permitted in all School Buildings, Courtyards, and the Aquatics Center Monday through Friday from 7:00 A.M. to 6:00 P.M., and Saturday from 9:00 A.M. to 6:00 P.M. Instruction and Extracurricular Activities on Saturday in School Buildings, Courtyards, and the Aquatics Center shall be limited to no more than 30 percent of enrolled students. For reference, the Draft EIR proposed to permit Instruction in School Buildings, Courtyards, and the Aquatics Center beginning at 7:00 A.M. on Saturday, with no limit on the number of participating students.

o Instruction shall be permitted on the athletic field Monday through Friday from 7:40 A.M. to 6:00 P.M., and Saturday from 10:00 A.M. to 6:00 P.M. Instruction on the athletic field on Saturday shall be limited to 4 hours per day and 10 days per year and shall be limited to no more than 30 percent of enrolled students. For reference, the Draft EIR proposed to permit Instruction on the athletic field beginning at 7:00 A.M. Monday through

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Saturday. The Draft EIR also proposed to permit Instruction on the athletic field with no limits on the number of hours per day, days per year, or participating students.

– Extracurricular Activities are defined as student activities with faculty and/or parent volunteer oversight, which do not involve guests. Extracurricular Activities include, but are not limited to, athletic team practices, rehearsals, and student organizations. Extracurricular Activities shall be permitted at varying times based on the Activity location.

o Extracurricular Activities in all School Buildings and Courtyards shall be permitted Monday through Friday from 7:00 A.M. to 10:00 P.M. and Saturday from 9:00 A.M. to 6:00 P.M. Instruction and Extracurricular Activities in School Buildings and Courtyards on Saturday shall be limited to no more than 30 percent of enrolled students. For reference, the Draft EIR proposed to permit Extracurricular Activities in all School Buildings and Courtyards on Saturday beginning at 7:00 A.M., with no limit on the number of participating students.

o Extracurricular Activities on the athletic field shall be permitted Monday through Friday from 7:40 A.M. to 6:00 P.M. and Saturday from 10:00 A.M. to 6:00 P.M. Extracurricular Activities on the athletic field on Saturday shall be limited to 4 hours per day and 10 days per year and shall be limited to no more than 30 percent of enrolled students. For reference, the Draft EIR proposed to permit Extracurricular Activities on the athletic field Monday through Friday beginning at 7:00 A.M. The Draft EIR also proposed to permit Extracurricular Activities on the athletic field on an unlimited number of Saturdays, with no limit on the number of participating students.

o Extracurricular Activities in the Aquatics Center shall be permitted Monday through Friday from 7:00 A.M. to 8:00 P.M. and Saturday from 9:00 A.M. to 6:00 P.M. Instruction and Extracurricular Activities in the Aquatics Center on Saturday shall be limited to 30 percent of enrolled students. For reference, the Draft EIR proposed to limit Extracurricular Activities in the Aquatics Center to 4 hours on Saturdays, with no limit on the number of participating students.

– Customary School Activities include trustee meetings, parent/teacher conferences, and other school activities related to teaching, learning, and school operations that involve no more than 50 guests on campus. Customary School Activities shall be permitted in all School Buildings and Courtyards Monday through Friday from 7:00 A.M. to 10:00 P.M. and Saturday from 9:00 A.M. to 6:00 P.M. For reference, the Draft EIR proposed to permit Customary School Activities in all School Buildings and Courtyards on Saturday beginning at 7:00 A.M.

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 Interscholastic Athletic Competitions are defined as student activities generally involving visiting athletic competitors/teams and guests. Interscholastic Athletic Competitions shall be permitted at varying times based on the Competition location.

– Interscholastic Athletic Competitions in the Multipurpose Facility shall be permitted Monday through Friday from 7:00 A.M. to 10:00 P.M. and Saturday from 9:00 A.M. to 6:00 P.M. For reference, the Draft EIR proposed to permit Interscholastic Athletic Competitions in the Multipurpose Facility on Saturday beginning at 7:00 A.M.

– Interscholastic Athletic Competitions on the athletic field shall be permitted Monday through Friday from 7:40 A.M. to 6:00 P.M. and Saturday from 10:00 A.M. to 6:00 P.M. Interscholastic Athletic Competitions on the athletic field on Saturday shall be limited to 4 hours per day and 10 days per year. For reference, the Draft EIR proposed to permit Interscholastic Athletic Competitions on the athletic field Monday through Friday from 7:00 A.M. to 8:00 P.M. and Saturday beginning at 7:00 A.M. on an unlimited number of Saturdays.

– Interscholastic Athletic Competitions in the Aquatics Center shall be permitted Monday through Friday from 7:00 A.M. to 6:00 P.M. and Saturday from 9:00 A.M. to 6:00 P.M. For reference, the Draft EIR proposed to permit Interscholastic Athletic Competitions in the Aquatics Center Monday through Friday until 8:00 P.M. and Saturday beginning at 7:00 A.M.

– While anticipated that most Interscholastic Athletic Competitions would be concluded within the permitted times, Interscholastic Athletics Competitions hours shall provide flexibility for overtime.

 Saturday use of the athletic field for Instruction, Extracurricular Activities, and Interscholastic Athletic Competitions shall be permitted for 4 hours between 10:00 A.M. to 6:00 P.M. for 10 days per year. Instruction and Extracurricular Activities shall be limited to no more than 30 percent of enrolled students. While anticipated that most Interscholastic Athletic Competitions will be concluded within the permitted times, flexibility for overtime shall be provided for the Interscholastic Athletic Competitions.

 School Functions are defined as planned functions that involve students and/or guests on campus. In response to comments on the Draft EIR, the maximum number of School Functions is reduced from 98 to 86 per year. The categories of School Functions are modified to eliminate Interscholastic Athletic Tournaments.

– Categories of School Functions shall include Academic and Leadership Functions; Admissions Functions; Alumnae Functions; Dances and Socials;

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Graduation; Music Functions; Parents and Family Functions; Performances; Student Enrichment Functions; and Visual Arts Functions. The specific School Functions may vary each Academic Year depending on Archer’s instructional needs.

– School Functions in all School Buildings and Courtyards shall be permitted Monday through Friday from 10:00 A.M. to 10:00 P.M., on Saturdays from 9:00 A.M. to 10:00 P.M., and Sunday from 12:00 P.M. to 7:00 P.M. Eight School Functions shall be permitted to conclude by 11:00 P.M. on Fridays and Saturdays. No more than 5 School Functions shall be permitted on Sunday. Upper School Graduation shall be permitted on the athletic field from 10:00 A.M. to 4:00 P.M. on one Saturday per year.

– Of the 86 proposed School Functions, Archer would be limited to 27 School Functions with up to 100 guests, 22 School Functions with up to 200 guests, 26 School Functions with up to 300 guests, 7 School Functions with up to 500 guests, 3 School Functions with up to 650 guests, and 1 School Function (Graduation) with up to 800 Guests.

– Appendix FEIR-B of this Final EIR includes additional limitations for the proposed School Functions. For informational purposes only, Appendix FEIR-B includes illustrative examples of the proposed School Functions. The School Functions listed are illustrative of the types of School Functions that could occur; the specific School Functions may vary each Academic Year to address the instructional needs of existing and future programs provided by Archer.

 Administration, maintenance personnel, and security personnel may be present on the campus at any time.

 Outdoor facilities maintenance, including grounds maintenance or any mechanized maintenance activities, shall be permitted Monday through Friday from 8:00 A.M. to 6:00 P.M. and Saturday from 8:00 A.M. to 6:00 P.M. Outdoor facilities maintenance shall be permitted outside of these times in emergency repair situations.

As part of the Project, summer academic and camp programs may occur for up to six weeks when the academic year is not in session between the hours of 8:00 A.M. and 5:00 P.M. Monday through Friday. Schools in Los Angeles routinely offer summer academic and camp programs for purposes of academic remediation, enrichment, or acceleration, and athletic skill development. With appropriate facilities, Archer’s summer program also would be able to offer traditional camp programs, which include sports (e.g., volleyball, basketball, soccer, and softball), swimming, games, arts, crafts, nature, and cooking. Archer’s program would serve up to 350 students primarily in the School Buildings and Courtyards and the Aquatics Center. The athletic field may be used between

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Page III-97 WORKING DRAFT – Not for Public Review III.C Topical Responses the hours of 10:00 A.M. and 4:00 P.M. The number of students on the athletic field is anticipated to be similar to a typical fitness class during the academic year. All participants in the summer programs would arrive and depart on buses. There would be no parent drop offs or pick-ups allowed at Archer or in the surrounding neighborhood.

The Draft EIR proposed community use of the facilities a maximum of 24 days per year. In response to comments on the Draft EIR, the Project has been refined to remove the proposed community use of the facilities.

The Draft EIR proposed rental, lease, and use of the facilities for non-School Use (e.g., club athletics, weddings, private parties) a maximum of 24 days per year. In response to comments, the Project has been refined to remove the proposed rental, lease, and use of the facilities for non-School Uses.

As set forth in the Draft EIR, filming on the campus for commercial purposes would continue to be prohibited except when the School is not in session and provided the filming revenue is placed in the School’s scholarship fund. Filming would be permitted for no more than 24 days per year. In addition, as set forth in Project Design Feature A-15, provided in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, trucks and equipment would be required to use the School’s underground parking structure. Parking on neighborhood streets would be strictly prohibited. No outdoor lighting or amplified noise would be allowed on the athletic field, North Garden, Arts Plaza, or in the Court of Leaders. Filming would only be permitted when the School is not in session (i.e. during the summer, non-school days, and after school on weekdays). Hours would be further restricted, with filming beginning no earlier than 9:00 A.M. and concluding no later than 6:00 P.M., and no filming on Sunday.

Upon agreement with the production companies, when filming occurs on campus the School would require that students enrolled in the Advanced Film class be given the opportunity to visit the set, interact with the crew, and participate in a real-world, hands-on filming experience.

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III. Responses to Comments C. Topical Responses

2. Removal of Athletic Field Lighting and Refinements to Lighting

As described in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, in response to comments on the Draft EIR, the athletic field lighting has been removed from the Project. In addition, as further described in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, the Performing Arts Center would be relocated to the Chaparal Parcel and reduced in size, and the Aquatics Center and Visual Arts Center would be relocated to the Barrington Parcel. The pool would also be fully enclosed within the proposed Aquatics Center. These Project refinements would result in changes in the locations of lighting within the School. As provided in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, a supplemental lighting analysis was prepared to evaluate the proposed refinements to the Project. This supplemental lighting analysis is included as Appendix D-2 to this Final EIR.

As discussed on pages IV.A-68 through IV.A-74 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, the Draft EIR included an analysis of the Project with both the athletic field lighting on and off. Therefore, the Draft EIR included an analysis of the Project without the athletic field lighting. With the removal of the athletic field lighting, light and glare impacts from the Project would remain less than significant. Specifically, with respect to illuminance, as shown in Table IV.A-4 and Table IV.A-5 on page IV.A-70 and page IV.A-71 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, Project Site lighting with the athletic field lighting off would result in illuminance values that would be well below the significance threshold of 2.0 foot-candles. As shown in Table IV.A-4 on page IV.A-70 of the Draft EIR, the highest calculated illuminance value at a Receptor Site with the athletic field lighting off was at Receptor Site F with a value of 0.65 foot-candle, and the lowest measured illuminance value was at Receptor Sites A, D, D-1, and E, with 0.00 foot-candle. As shown in Table IV.A-5 on page IV.A-71 of the Draft EIR, at the Project Site perimeter, the highest contributed illuminance value, with the athletic field lighting off, was noted east of the Visual Arts Center and north of the Performing Arts Center, with a value of 0.60 foot-candle. Therefore, with the removal of the athletic field lighting from the Project, the calculated illuminance value at each Receptor Site and the Project Site perimeter would either be less

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Page III-99 WORKING DRAFT – Not for Public Review III.C Topical Responses than or the same as the illuminance values with the athletic field lighting and the impacts would remain less than significant.

Further, with respect to contrast, as shown in Table IV.A-6 on page IV.A-72 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, the Project with the athletic field lighting off would result in low- to mid-level contrast values that would not result in glare. Further, the resulting contrast values are less than those of existing conditions. Therefore, with the removal of the athletic field lighting from the Project impacts from contrast would remain less than significant.

In addition, Alternatives 3 and 5 on pages V-58 through V-59 and V-116 through V-117, respectively, in Section V, Alternatives, of the Draft EIR included an analysis with the Performing Arts Center relocated to the Chaparal Parcel and the Aquatics Center and Visual Arts Center relocated to the Barrington Parcel. The analysis determined that the relocation of these buildings would not significantly increase nighttime lighting levels in the area or daytime glare, and impacts with regard to lighting would be less than significant.

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III. Responses to Comments C. Topical Responses

3. Overview of Reduced Parking Spaces, Parking Demand and Supply, and Parking Enforcement

Several comments on the Draft EIR address the number of proposed parking spaces.

Summary of Draft EIR Parking Analysis

As described in Section II, Project Description, of the Draft EIR, as part of the Project, parking was proposed in a new underground parking structure. The parking structure would accommodate all on-campus parking in one location and would provide approximately 212 parking spaces. The on-site parking may be expanded to accommodate a total of 282 parking spaces when necessary with use of attendant assisted parking. For the few events when on-site parking is not sufficient, parking may be provided off-site.

Refer to Section IV.K, Traffic, Access, and Parking, of the Draft EIR for the analysis of how the proposed parking structure met the parking demand for the Project. The proposed parking supply would be able to accommodate an estimated peak parking demand of 153 parking spaces for non-event school days and a peak demand of 272 spaces at 4:00 P.M. for a 300-attendee event day. This estimated peak parking demand assumed 50 percent of students using the fixed-route bus service. As analyzed in the Draft EIR, for events with up to 650 attendees, a peak parking demand of 434 spaces was estimated at 7:00 P.M. In addition to attendant assisted parking, Archer would arrange for off-site parking to accommodate an excess demand over the 282 spaces.

Refined Parking Demand Analysis

As noted above, the parking demand of 153 parking spaces for a non-event school day assumed 50 percent of students utilized the fixed-route bus service. Pursuant to Mitigation Measure K-1, Archer would be required to raise the percentage of students who

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Page III-101 WORKING DRAFT – Not for Public Review III.C Topical Responses are required to use the fixed-route bus service from 50 percent to 70 percent.1 The estimated peak parking for non-event school days assuming 70 percent of students use the fixed-route bus service is 143 parking spaces.

As described in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, in response to comments on the Draft EIR, the Project is incorporating additional operational mitigation measures to reduce significant traffic impacts (related to School Functions and Interscholastic Athletic Competitions) to less than significant. Specifically, Mitigation Measure K-2 has been refined so that on weekdays afternoon Interscholastic Athletic Competitions and School Functions with start times between 3:00 P.M. and 4:00 P.M. would be limited to a maximum of 44 inbound vehicles and evening School Functions with start times between 6:00 P.M. and 7:00 P.M. would be limited to a maximum of 126 inbound vehicles. Archer would no longer hold weekday evening Interscholastic Athletic Competitions and School Functions with start times between 5:00 P.M. and 6:00 P.M. Saturday Interscholastic Athletic Competitions and School Functions with start times between 1:00 P.M. and 2:00 P.M. would be limited to a maximum of 243 inbound vehicles. The estimated peak demand for an event day with an Interscholastic Athletic Competitions and School Functions has been refined to assume implementation of Mitigation Measure K-2 (along with Mitigation Measure K-1). On weekdays with an Interscholastic Athletic Competition or School Functions,2 the estimated peak parking demand at 4:00 P.M. is 135 parking spaces, and the estimated peak parking demand for an evening School Function is 148 parking spaces. Figure III-1 on page III-103 shows the estimated parking demand profile during the course of both a non-event school day and an event day. A peak parking demand of up to 434 spaces was estimated for events with up to 650 attendees, which are proposed to occur after 7:00 P.M. Monday through Friday or on Saturday.

Accordingly, in response to comments on the Draft EIR, the Project proposes to reduce the number of spaces in the parking structure. Similar to the Project, the reduced parking structure would accommodate all on-campus parking in one location, but would be reduced to provide approximately 185 parking spaces. The on-site parking may be expanded to accommodate a total of 251 parking spaces when necessary with use of attendant assisted parking.

1 While the existing percentage of students who use the fixed-route bus service currently exceeds the increased level set forth in Mitigation Measure K-1 (70 percent), the increased requirement of 70 percent would exceed that currently required under Archer’s existing CUP (50 percent). 2 As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, larger events that are held infrequently and are existing events, such as graduation, are not included in the event date analysis.

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   

         

                 



Figure III-1 Parking Demand with Additional Event Limitations

Source: Fehr and Peers, 2014. III.C Topical Responses

Figure II-2 in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, shows the revised conceptual design of the reduced parking structure. For the few events when on-site parking is not sufficient, parking may be provided off-site.

Parking Enforcement

As discussed in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, as part of Project Design Feature K-1, the Project shall include implementation of a comprehensive Traffic Management Program that would include, but not be limited to, a prohibition on parking on residential streets. To ensure implementation of the Traffic Management Program, the School would continue to inform parents, students, faculty, and staff in writing on an annual basis of all rules regulating School traffic and parking. The School would maintain a progressive disciplinary system of enforcement to ensure compliance with the Traffic Management Program. In addition, pursuant to Project Design Feature K-7, Archer would develop an Event Parking and Transportation Management Plan, which would include appropriate tools to manage and control traffic and parking so that impacts to the surrounding areas are minimized. For example, to enforce the prohibition on parking on residential streets, Archer could require guests walking onto the campus to have a walking permit issued by Archer. Guests would be required to check in with security upon arrival to the campus.

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III. Responses to Comments C. Topical Responses

4. Additional Measures to Reduce Noise

In response to comments on the Draft EIR, additional measures to reduce noise within the campus are proposed to be implemented as part of the Project. As set forth in Section II, Corrections and Additions, of this Final EIR, these measures include refinements to the site plan and campus operations. Also refer to Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, regarding proposed refinements to the site plan to incorporate design changes and reduce the size of the Project, and Topical Response No. 1, Refinements to Proposed Operations, regarding the additional operational restrictions proposed including additional limits on the hours of operation, reducing the number of proposed School Functions, and eliminating community use of the facilities and the rental, lease, or use of the facilities for non-School Uses.

Outdoor Athletic Activities: Athletic Field

As shown in Figure II-3 on page II-6 and described in Section II, Project Description, of the Draft EIR, the Project Site includes a multi-use athletic field and courts. The existing multi-use athletic field and courts are used for soccer, softball, volleyball, and basketball. With implementation of the Project, the existing outdoor athletic field would be improved and would include regulation-size soccer and softball fields. As proposed in the Draft EIR, these fields would be used for practice and Interscholastic Athletic Competitions hosted on weekdays until 8:00 P.M. and on Saturdays. The soccer field is proposed to be located on the northwest corner of the campus with the long axis of the field running east to west (parallel to the north property line). This proposed east-west orientation would be consistent with the orientation of the existing soccer field. The soccer field would also be used for field hockey. The existing softball field is located in the southeast corner of the existing multi-use athletic field and overlaps with the soccer field. As part of the Project described in the Draft EIR, the softball field is proposed to be located in the southwest corner of the multi-use field and would be oriented to direct softballs toward the interior of the campus away from adjacent properties. This orientation was proposed to be consistent with the National Federation of State High School Associations’ recommended orientation of east-northeast and keeps the batter, catcher, and spectators from looking into the afternoon sun.

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As discussed in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, in response to comments, the Project is proposed to be refined to shift the athletic field approximately 7 feet 6 inches to the east. Shifting the athletic field approximately 7 feet 6 inches to the east would move the athletic field as far away as possible from the neighbors to the west of the campus property boundary while still maintaining regulation-size soccer and softball fields. This expanded setback would allow for more plantings within a larger landscaped buffer along the western property boundary of the campus.

Pages IV.I-87 through IV.I-110 of Section IV, Noise, of the Draft EIR discuss Outdoor Athletic Activities. As described therein, softball activities would result in potentially significant impacts on weekdays between 3:00 P.M. and 6:00 P.M. (Lmax noise level impacts at the sensitive receptors) and between 6:00 P.M. and 8:00 P.M. (hourly Leq and Lmax noise level impacts at the sensitive receptors), and on Saturday (Lmax noise level impacts at the sensitive receptors). An analysis of the potential noise impacts of future softball events for a northwest field orientation is provided in Section V, Alternatives, of the Draft EIR. As noted in Section V, Alternatives, of the Draft EIR, a northwest field orientation would result in new hourly Leq noise impacts for softball activities on weekdays from 6:00 P.M. and 8:00 P.M. and on Saturdays. See pages V-68 through V-70, V-97 through V-99, and V-127 through V-128 of Section V, Alternatives, of the Draft EIR.

In response to comments on the Draft EIR and consistent with Alternatives 3, 4, and 5 of the Draft EIR, the Project is proposed to be refined to maintain the softball field in its existing northwest orientation and located in the southeast corner of the athletic field. This refinement would reduce the Project’s significant impact from softball activities on weekdays from 3:00 P.M. to 6:00 P.M. to less than significant with mitigation. Accordingly, the mitigation program for the Project would include the following refinement to the location of the regulation-size softball field:

Mitigation Measure I-2: The regulation-sized softball field shall be located along the southeast portion of the athletic field so that the softball field is oriented northwest for batters.

As part of the Project described in the Draft EIR, expanded use of the athletic field was proposed for activities between 6:00 P.M. and 8:00 P.M. on weekdays. As noted above, softball activities would result in potentially significant impacts on weekdays between 6:00 P.M. and 8:00 P.M. Soccer and field hockey activities also would result in a potentially significant impact on weekdays between 6:00 P.M. and 8:00 P.M. (hourly Leq and Lmax noise level impacts at the sensitive receptors). In response to comments on the Draft EIR, the Project hours and operations would be refined and use of the athletic field would

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Page III-106 WORKING DRAFT – Not for Public Review III.C Topical Responses end at 6:00 P.M. Accordingly, the mitigation program for the Project would include the following operational restriction on the weekday use of the athletic field:

Mitigation Measure I-3: Weekday use of the athletic field shall conclude by 6:00 P.M. Flexibility for overtime shall be permitted for Interscholastic Athletic Competitions.

Implementation of Mitigation Measures I-2 and I-3 would eliminate the Project’s hourly Leq and Lmax noise level impacts at the sensitive receptors due to weekday softball activities and soccer or field hockey activities during 6:00 P.M. to 8:00 P.M.

As part of the Project, use of the athletic field is proposed on Saturday for Extracurricular Activities (e.g., athletic practice) from 10:00 A.M. to 6:00 P.M. and for Interscholastic Athletic Competitions (e.g., games) from 7:00 A.M. to 6:00 P.M. As noted above, with the northwest field orientation provided for in Mitigation Measure I-2, softball activities would be reduced with the remaining potentially significant impacts occurring on Saturday (hourly Leq and Lmax noise levels). Soccer and field hockey activities also would result in a potentially significant impact on Saturday (hourly Leq and Lmax noise level impacts at the sensitive receptors). In response to comments on the Draft EIR, the Project hours and operations would be refined to reduce the hours of operation on Saturdays. Accordingly, the mitigation program for the Project would include the following operational restriction on the Saturday use of the athletic field:

Mitigation Measure I-4: Saturday use of the athletic field shall be permitted for four (4) hours between 10:00 A.M. to 6:00 P.M. for ten (10) days per year. Flexibility for overtime shall be provided for the Interscholastic Athletic Competitions.

Therefore, implementation of Mitigation Measure I-4 would reduce the potentially significant noise impacts from the Saturday use of the athletic field to occur ten days a year within a limited timeframe.

With the removal of the weekday use of the athletic field from 6:00 P.M. to 8:00 P.M. from the Project, use of the athletic field for these ten Saturdays is needed to maximize the functionality and use of the athletic field and meet the requirements associated with interscholastic athletic activities.

In addition, as discussed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, additional operational restrictions have been proposed, including restrictions on Instruction on Saturdays. As set forth therein, Instruction, Extracurricular Activities, and Interscholastic Athletic Competitions shall

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Page III-107 WORKING DRAFT – Not for Public Review III.C Topical Responses be permitted for 4 hours between 10:00 A.M. to 6:00 P.M. for ten days per year. In addition, Instruction and Extracurricular Activities (including, for example, athletic practice) on Saturdays shall be limited to not more than 30 percent of enrolled students.

Aquatics Center

As described in Section II, Project Description, of the Draft EIR, the Project would provide an Aquatics Center with an outdoor, competition pool. With development of an Aquatics Center, the School would host swim and water polo practices, games, and meets. These activities in the Aquatics Center would occur between 3:00 P.M. and 6:00 P.M. and 6:00 P.M. and 8:00 P.M. on weekdays and between 8:00 A.M. and 6:00 P.M. on Saturday. Pages IV.I-87 through IV.I-110 of Section IV, Noise, of the Draft EIR discuss Outdoor Athletic Activities. Aquatics Center activities would result in potentially significant impacts on weekdays between 6:00 P.M. and 8:00 P.M. (Lmax noise level impacts at the sensitive receptors).

In response to comments on the Draft EIR, the Project is proposed to be refined to fully enclose the pool within the Aquatics Center. An analysis of the enclosed Aquatics Center was provided on pages V-68 through V-70, V-97 through V-99, and V-127 through V-128 of Section V, Alternatives, of the Draft EIR as part of the discussion of Alternatives 3, 4, and 5, respectively. As provided therein, the enclosure of the pool at the Aquatics Center would eliminate the significant noise impacts associated with maximum noise levels during weekday Aquatics Center activities from between 6:00 P.M. to 8:00 P.M. To incorporate the enclosure of the pool at the Aquatics Center into the Project the following Mitigation Measure I-5 would be implemented:

Mitigation Measure I-5: The swimming pool at the Aquatics Center shall be fully enclosed within a structure.

With the incorporation of Mitigation Measure I-5, all noise impacts associated with the Aquatics Center would less than significant.

Additional Measures to Reduce Noise

As discussed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, additional measures to reduce campus noise have been proposed. While the Draft EIR determined these activities resulted in a less than significant noise impact, their elimination would reduce the activities occurring on campus, which would reduce the incidence of noise in the community. These additional measures are as follows:

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Reduced Hours and Operations

School Functions

Eliminate Interscholastic Athletic Tournaments

The Project in the Draft EIR proposed Interscholastic Athletic Tournaments on campus as part of the permitted School Functions. As discussed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments, Interscholastic Athletic Tournaments are no longer proposed as part of the Project. With the elimination of Interscholastic Athletic Tournaments and other refinements to the proposed School Functions, the maximum number of School Functions has been reduced from 98 to 86 per year. Elimination of Interscholastic Athletic Tournaments would further reduce the incidence of noise in the community.

Eliminate School Functions in the North Garden

The Project proposes the North Garden, which would serve as the transition between the parking level and the campus level through the provision of a safe student pick-up and drop-off that would also provide an outdoor space for small group daytime instruction. Use of the North Garden was discussed on pages IV.I-83 through IV.I-84 of Section IV.I Noise, of the Draft EIR. As stated therein, the Project did not propose to use the North Garden to conduct large gatherings or all-school assemblies; however, the analysis conservatively analyzed that up to 650 people could be within the North Garden and determined that noise impacts associated with such use would be less than significant. To clarify the limited use of the North Garden, School Functions in the North Garden are no longer proposed as part of the Project. To further ensure that the North Garden would not be used for School Functions, large gatherings, or all-school assemblies, hardscape and landscape features have been added to the design of the North Garden. For instance, paved surfaces would be limited to pathways and landscaping features would include raised planters, terraces, flower beds, and large-specimen trees. Elimination of School Functions in the North Garden would further reduce the incidence of noise in the community.

Eliminate School Functions on the Athletic Field

As discussed in Section II, Project Description, of the Draft EIR, the Project proposed School Functions on the athletic field Monday through Saturday, 7:00 A.M. to 10:00 P.M., and Sunday, 12:00 P.M. to 7:00 P.M., with 8 School Functions per year permitted to conclude by 11:00 P.M. on Friday and Saturday. In response to comments, School Functions on the athletic field are no longer proposed, with the exception of Upper School Graduation, which shall be permitted from 10:00 A.M. to 4:00 P.M. on one Saturday per

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Page III-109 WORKING DRAFT – Not for Public Review III.C Topical Responses year. Elimination of most School Functions on the athletic field would further reduce the incidence of noise in the community.

Elimination of Community Use and Rental of School Facilities

The Project in the Draft EIR proposed community use of the facilities a maximum of 24 days per year as well as the rental, lease, and use of the facilities for non-School Use (e.g., club athletics, weddings, private parties) a maximum of 24 days per year. As discussed in Topical Response No. 1, Refinements to Proposed Operations, community use of the school facilities or the rental, lease, and use of the facilities for non-School Uses is no longer proposed as part of the Project. Elimination of community use and the rental, lease, and use of the facilities for non-School Uses would further reduce the incidence of noise in the community.

Public Address System

As discussed on pages IV.I-85 and IV.I-86 of Section IV.I, Noise, of the Draft EIR, the Project proposed use of non-permanent audio systems for public address and amplified music in conjunction with Instruction, Interscholastic Athletic Competitions, and School Functions. With the implementation of Project Design Feature I-5, which provided that the portable public address system would be calibrated for use at each proposed location, impacts due to use of the public address system would be less than significant. Although impacts would be less than significant, in response to comments on the Draft EIR use of a new non-permanent audio system for these uses has been removed from the Project. Rather, use of a non-permanent audio system solely for use during Graduation as permitted under the existing CUP would continue. Elimination of the portable public address system except for use during Graduation would further reduce the incidence of noise in the community.

Mandatory Use of Underground Pedestrian Pathway

As described on pages IV.I-84 and IV.I-85 of Section IV.I, Noise, of the Draft EIR, pedestrians currently use pedestrian pathways and access routes prior to and after Interscholastic Athletic Competitions or School Functions. As part of the Project, new pedestrian pathways and access routes would be provided to access the Multipurpose Facility, the Visual Arts Center, the Aquatics Center, the Performing Arts Center, and the underground parking structure. Pedestrians may talk in these areas prior to and after Interscholastic Athletic Competitions or School Functions. An analysis of potential noise impacts due to talking on the pedestrian pathways and access routes was performed for the Project and demonstrated that the noise associated with people talking would be less than significant. (See Tables 45 through 55 in the Noise Study of the Draft EIR.) While the Draft EIR determined that there would be less than significant impacts associated with use

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Page III-110 WORKING DRAFT – Not for Public Review III.C Topical Responses of the outdoor pedestrian pathways and access routes, in response to comments, mandatory use of the underground pedestrian pathway, which extends from the underground parking structure to the Multipurpose Facility and the Performing Arts Center, after 8:00 P.M. has been proposed as part of the Project pursuant to Project Design Feature I-8 as set forth in Section II, Corrections and Additions to the Draft EIR, of this Final EIR. Mandatory use of the underground pedestrian pathway would further reduce the incidence of noise in the community.

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III. Responses to Comments C. Topical Responses

5. Additional Mitigation Measures to Eliminate Significant Traffic Impacts

Several comments on the Draft EIR raise concerns regarding the Project-related traffic impacts during Project operations. This topical response provides a general summary of the operational traffic impacts and mitigation measures described in the Draft EIR, followed by a discussion of additional mitigation measures proposed subsequent to the circulation of the Draft EIR which would further mitigate Project traffic impacts. The additional mitigation measures and associated analysis summarized below are based on the Additional Traffic Mitigation Measures Memorandum prepared by Fehr & Peers, dated September 17, 2014, and included as Appendix FEIR-C of this Final EIR.

Summary of Draft EIR Analysis

As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, the Project was projected to have significant traffic impacts at up to three intersections on non- event days and up to six intersections associated with potential weekday afternoon events, up to three intersections associated with weekday evening events, and up to three intersections associated with Saturday events. The following mitigation measures were proposed in the Draft EIR to reduce the severity of these impacts:

Mitigation Measure K-1: The Project Applicant shall raise the percentage of students who are required to utilize the fixed-route bus service from 50 percent to 70 percent. Mitigation Measure K-2: The Project Applicant shall limit the number of trips generated by guests arriving at or departing from weekday afternoon and Saturday afternoon School Functions and Interscholastic Athletic Competitions as follows:

 3:00 P.M.–4:00 P.M. Arrival—Limit the number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 3:30 P.M. or 4:00 P.M., Monday through Friday, to no more than 72.

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 5:00 P.M.–6:00 P.M. Departure—Limit the number of vehicles generated by guests departing from the Archer campus after attending School Functions and Interscholastic Athletic Competitions ending at 5:00 P.M. or 5:30 P.M., Monday through Friday, to no more than 72.

 Saturday 1:00 P.M.–2:00 P.M.—Limit the number of number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 1:30 P.M. or 2:00 P.M. on Saturday to no more than 244. Mitigation Measure K-3: Saltair Avenue & Sunset Boulevard—The Project Applicant shall coordinate with LADOT to fund and implement the modification to the northbound approach of Saltair Avenue, which shall consist of acquiring a strip of private property right-of-way along the east side of Saltair Avenue south of Sunset Boulevard, widening the Saltair Avenue southern leg, and restriping the existing shared left/through/right-turn lane to provide a shared left/through lane and right-turn lane. This mitigation measure would require removal of the existing University Synagogue fence on the east side of Saltair Avenue’s southern leg, subject to the owner’s approval.

As described in the Draft EIR, with implementation of the above mitigation measures, all Project traffic impacts on non-event days would be reduced to below a level of significance. These mitigation measures would also reduce the Project traffic impacts during the weekday 3:00–4:00 P.M. and Saturday 1:00–2:00 P.M. hours associated with events to below a level of significance. The Draft EIR determined that significant impacts would still remain, however, during the 5:00–6:00 P.M. and 6:00–7:00 P.M. hours associated with events.

Additional Mitigation Measures

In response to the comments received on the Draft EIR, the following additional operational mitigation measures are proposed to fully eliminate significant traffic impacts associated with an event day for Interscholastic Athletic Competitions and School Functions.3 These additional operational mitigation measures are included as part of Mitigation Measure K-2 as follows:

3 As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, larger events that are held infrequently and are existing events, such as graduation, are not included in the event date analysis.

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Mitigation Measure K-2: The Project Applicant shall limit the number of trips generated by guests arriving at or departing from weekday afternoon and Saturday afternoon School Functions and Interscholastic Athletic Competitions as follows:

 3:00 P.M.–4:00 P.M. Arrival—Limit the number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 3:30 P.M. or 4:00 P.M., Monday through Friday, to no more than 72 44.

 5:00 P.M.–6:00 P.M. Departure—Limit the number of vehicles generated by guests departing from the Archer campus after attending School Functions and Interscholastic Athletic Competitions ending at 5:00 P.M. or 5:30 P.M., Monday through Friday, to no more than 72 44.

 5:00 P.M.–6:00 P.M. Arrival—Prohibit guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 5:30 P.M. or 6:00 P.M.

 6:00 P.M.–7:00 P.M. Arrival—Limit the number of vehicles generated by guests arriving at the Archer campus to attend School Functions beginning between 6:00 P.M. or 7:00 P.M., Monday through Friday, to no more than 126.

 Saturday 1:00 P.M.–2:00 P.M.—Limit the number of number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 1:30 P.M. or 2:00 P.M. on Saturday to no more than 244 243. These limits shall be enforced via measures to be included in the Event Parking and Transportation Management Plan to be developed in accordance with Project Design Feature K-7, such as a parking reservation system to manage attendance.

With the additional limitations placed on events, Table 7 of the Traffic Study, which presents the Project trip-generation estimates has been revised and is provided as Table III-2 on page III-115. In addition, revised Tables 5A, 5B, 5D, 5E, 6A, 6B, 6D, and 6E of the Traffic Study, provided as Table III-3 through Table III-10 on pages III-117 through III-126, respectively, present the intersection level of service analysis with these additional event limits. As indicated therein, with implementation of the revised Mitigation Measure K-2, all Project traffic impacts both on non-event days and associated with Interscholastic Athletic Competitions and School Functions would be reduced to below a level of significance.

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Table III-2 Revised Table 7—Project Mitigation—Trip-Generation Estimates With 70 Percent Busing and Additional Limits On Events

After School Vehicle P.M. Peak-Hour Evening Hour Saturday Peak-Hour Trips—With Vehicle Trips—With Vehicle Trips—With Saturday Peak-Hour Vehicle Trips—With A.M. Peak-Hour Additional Limits On Additional Limit On Additional Limits On Vehicle Trips— Additional Limits On Vehicle Trips Event Arrivalsa Events Departuresb Event Arrivalsc 300-Attendee Event Event Arrivalsd

Event Attendee Data— (7 A.M.– 8 A.M.) (3 P.M.–4 P.M.) (5 P.M.– 6 P.M.) (6 P.M.– 7 P.M.) (1 P.M.– 2 P.M.) (1 P.M.– 2 P.M.) No. of No. of Hours of Operation and Scenario Employees Students Number of Attendees Legend In Out Total In Out Total In Out Total In Out Total In Out Total In Out Total

Existing Non-Event School Day 95 430 7 A.M.–8 A.M.: 0 Bus 8 8 16 8 8 16 8 8 16 0 0 0 0 0 0 0 0 0 3 P.M.–4 P.M.: 0 Student Carpool (Parent Driver) 14 14 28 7 7 14 7 7 14 0 0 0 0 0 0 0 0 0 5 P.M.–6 P.M.: 0 Student Carpool (Student Driver) 7 0 7 0 3 3 0 4 4 0 0 0 0 0 0 0 0 0 6 P.M.–7 P.M.: 0 Faculty/Staff 71 0 71 0 29 29 0 27 27 0 0 0 0 0 0 0 0 0 Visitor 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total 100 22 122 15 47 62 15 46 61 0 0 0 0 0 0 0 0 0 Existing Interscholastic Athletic 7 A.M.–8 A.M.: 0 Bus 8 8 16 9 8 17 8 9 17 0 0 0 0 0 0 0 0 0 Competition or School Function 3 P.M.–4 P.M.: 74 Student Carpool (Parent Driver) 14 14 28 7 7 14 7 7 14 0 0 0 0 0 0 0 0 0 Day 5 P.M.–6 P.M.: 74 Student Carpool (Student Driver) 7 0 7 0 3 3 0 4 4 0 0 0 0 0 0 0 0 0 6 P.M.–7 P.M.: 150 Faculty/Staff 71 0 71 0 29 29 0 27 27 0 0 0 0 0 0 0 0 0 1 P.M.–2 P.M. Sat.: 150 Visitor 0 0 0 32 0 32 0 32 32 85 0 85 64 0 64 64 0 64 Total 100 22 122 48 47 95 15 79 94 85 0 85 64 0 64 64 0 64 Proposed Non-Event School 132 518 7 A.M.–8 A.M.: 0 Bus 8 8 16 8 8 16 8 8 16 0 0 0 0 0 0 0 0 0 Day 3 P.M.–4 P.M.: 0 Student Carpool (Parent Driver) 34 34 68 17 17 34 17 17 34 0 0 0 0 0 0 0 0 0 5 P.M.–6 P.M.: 0 Student Carpool (Student Driver) 16 0 16 0 8 8 0 8 8 0 0 0 0 0 0 0 0 0 6 P.M.–7 P.M.: 0 Faculty/Staff 70 0 70 0 40 40 0 38 38 0 0 0 0 0 0 0 0 0 Visitor 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Total 128 42 170 25 73 98 25 71 96 0 0 0 0 0 0 0 0 0 Existing Use Credit (100) (22) (122) (15) (47) (62) (15) (46) (61) (0) (0) (0) (0) (0) (0) (0) (0) (0) Net Site Trips 282048102636102535 0 0 0 00 0 0 0 0 Proposed Interscholastic 7 A.M.–8 A.M.: 0 Bus 8 8 16 10 8 18 8 10 18 0 0 0 0 0 0 0 0 0 Athletic Competition School 3 P.M.–4 P.M.: 84 Student Carpool (Parent Driver) 34 34 68 17 17 34 17 17 34 0 0 0 0 0 0 0 0 0 Function Day 5 P.M.–6 P.M.: 0 Student Carpool (Student Driver) 16 0 16 0 8 8 0 8 8 0 0 0 0 0 0 0 0 0 e 6 P.M.–7 P.M.: 222 Faculty/Staff 70 0 70 0 40 40 0 38 38 0 0 0 0 0 0 0 0 0 e 1 P.M.–2 P.M. Sat.: 300 or 572 Visitor 0 0 0 42 0 42 0 42 42 126 0 126 128 0 128 243 0 243 Total 128 42 170 69 73 142 25 115 140 126 0 126 128 0 128 243 0 243 Existing Use Credit (100) (22) (122) (48) (47) (95) (15) (79) (94) (85) (0) (85) (64) (0) (64) (64) (0) (64) Net Site Trips 282048212647103646 41 0 41 640641790179 Net New Projected Non-Event School Day Trips 28 20 48 10 26 36 10 25 35 0 0 0 0 0 0 0 0 0 Net New Projected Interscholastic Athletic Competition or School Function Day Trips 28 20 48 21 26 47 10 36 46 41 0 41 64 0 64 179 0 179

Existing Non-Event School Day Daily Trip Generation 316 Existing Interscholastic Athletic Competition or School Function Day Daily Trip 582 Generation Future Non-Event School Day Daily Trip Generation 480 Future Interscholastic Athletic Competition or School Function Day Daily Trip 864 Generation Net New Non-Event School Day Daily Trip Generation 164 Net New Interscholastic Athletic Competition or School Function Day Daily Trip 282 Generation

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Table III-2 (Continued) Revised Table 7—Project Mitigation—Trip-Generation Estimates With 70 Percent Busing and Additional Limits On Events

After School Vehicle P.M. Peak-Hour Evening Hour Saturday Peak-Hour Trips—With Vehicle Trips—With Vehicle Trips—With Saturday Peak-Hour Vehicle Trips—With A.M. Peak-Hour Additional Limits On Additional Limit On Additional Limits On Vehicle Trips— Additional Limits On Vehicle Trips Event Arrivalsa Events Departuresb Event Arrivalsc 300-Attendee Event Event Arrivalsd

Event Attendee Data— (7 A.M.– 8 A.M.) (3 P.M.–4 P.M.) (5 P.M.– 6 P.M.) (6 P.M.– 7 P.M.) (1 P.M.– 2 P.M.) (1 P.M.– 2 P.M.) No. of No. of Hours of Operation and Scenario Employees Students Number of Attendees Legend In Out Total In Out Total In Out Total In Out Total In Out Total In Out Total a With the number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 3:30 P.M. or 4:00 P.M., Monday through Friday, limited to no more than 44. b With the number of vehicles generated by guests departing from the Archer campus after attending School Functions and Interscholastic Athletic Competitions ending at 5:00 P.M. or 5:30 P.M., Monday through Friday, limited to no more than 44. c With the number of number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions arriving between 6:00 P.M. and 7:00 P.M., Monday through Friday, limited to no more than 126. d With the number of number of vehicles generated by guests arriving at the Archer campus to attend School Functions and Interscholastic Athletic Competitions beginning at 1:30 P.M. or 2:00 P.M. on Saturday limited to no more than 243. e Larger events that are held infrequently and are existing events, such as graduation, are not included in the event analysis. Source: Fehr & Peers, 2014.

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Table III-3 Revised Table 5A—Baseline Plus Project Conditions—Non-Event School Day—Intersection LOS and Significant Impact Analysis

Baseline + Project with Mitigation: 70 Percent Baseline + Project with Mitigations: 70 Percent Baseline + Project (50 Percent Busing) Busing Busing With Additional Limits on Events Baseline Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact

1 Cliffwood Ave. Sunset Blvd. 7–8 A.M. 0.488 A 0.493 A 0.005 No 0.491 A 0.003 No 3–4 P.M. 0.442 A 0.444 A 0.002 No 0.443 A 0.001 No 5–6 P.M. 0.337 A 0.340 A 0.003 No 0.339 A 0.002 No 2 Kenter Ave. Sunset Blvd. 7–8 A.M. 0.665 B 0.675 B 0.010 No 0.669 B 0.004 No 3–4 P.M. 0.683 B 0.689 B 0.006 No 0.686 B 0.003 No 5–6 P.M. 0.493 A 0.496 A 0.003 No 0.495 A 0.002 No 3 Bundy Dr. Sunset Blvd. 7–8 A.M. 0.516 A 0.523 A 0.007 No 0.520 A 0.004 No 3–4 P.M. 1.054 F 1.064 F 0.010 Yes 1.060 F 0.006 No 5–6 P.M. 1.220 F 1.231 F 0.011 Yes 1.226 F 0.006 No 4 Saltair Ave. Sunset Blvd. 7–8 A.M. 0.601 B 0.607 B 0.006 No 0.604 B 0.003 No 3–4 P.M. 0.958 E 0.967 E 0.009 No 0.963 E 0.005 No 5–6 P.M. 1.108 F 1.119 F 0.011 Yes 1.114 F 0.006 No 5 Barrington Ave. Sunset Blvd. 7–8 A.M. 0.858 D 0.877 D 0.019 No 0.867 D 0.009 No 3–4 P.M. 1.302 F 1.310 F 0.008 No 1.307 F 0.005 No 5–6 P.M. 1.323 F 1.334 F 0.011 Yes 1.328 F 0.005 No 6 Barrington Pl. Sunset Blvd. 7–8 A.M. 0.718 C 0.725 C 0.007 No 0.721 C 0.003 No 3–4 P.M. 0.854 D 0.860 D 0.006 No 0.857 D 0.003 No 5–6 P.M. 0.884 D 0.887 D 0.003 No 0.885 D 0.001 No 7 Church Ln. I-405 SB Ramps 7–8 A.M. 0.614 B 0.617 B 0.003 No 0.616 B 0.002 No 3–4 P.M. 0.707 C 0.709 C 0.002 No 0.708 C 0.001 No 5–6 P.M. 0.795 C 0.797 C 0.002 No 0.796 C 0.001 No 8 Church Ln. Sunset Blvd. 7–8 A.M. 0.816 D 0.822 D 0.006 No 0.819 D 0.003 No 3–4 P.M. 0.725 C 0.727 C 0.002 No 0.725 C 0.000 No 5–6 P.M. 0.821 D 0.822 D 0.001 No 0.821 D 0.000 No 9 I-405 NB Ramps Sunset Blvd. 7–8 A.M. 0.649 B 0.652 B 0.003 No 0.650 B 0.001 No 3–4 P.M. 0.430 A 0.432 A 0.002 No 0.431 A 0.001 No 5–6 P.M. 0.461 A 0.463 A 0.002 No 0.462 A 0.001 No 10 Veteran Ave. Sunset Blvd. 7–8 A.M. 0.645 B 0.647 B 0.002 No 0.646 B 0.001 No 3–4 P.M. 0.756 C 0.758 C 0.002 No 0.758 C 0.002 No 5–6 P.M. 0.965 E 0.967 E 0.002 No 0.967 E 0.002 No 11 Bundy Dr. (W) San Vicente Blvd. 7–8 A.M. 0.494 A 0.498 A 0.004 No 0.496 A 0.002 No 3–4 P.M. 0.575 A 0.578 A 0.003 No 0.577 A 0.002 No 5–6 P.M. 0.605 B 0.608 B 0.003 No 0.607 B 0.002 No 12 San Vicente Blvd. Montana Ave. 7–8 A.M. 0.718 C 0.719 C 0.001 No 0.718 C 0.000 No 3–4 P.M. 0.933 E 0.934 E 0.001 No 0.933 E 0.000 No 5–6 P.M. 0.906 E 0.906 E 0.000 No 0.906 E 0.000 No

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Table III-3 (Continued) Revised Table 5A—Baseline Plus Project Conditions—Non-Event School Day—Intersection LOS and Significant Impact Analysis

Baseline + Project with Mitigation: 70 Percent Baseline + Project with Mitigations: 70 Percent Baseline + Project (50 Percent Busing) Busing Busing With Additional Limits on Events Baseline Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact

13 Barrington Ave. Montana Ave. 7–8 A.M. 0.452 A 0.465 A 0.013 No 0.459 A 0.007 No 3–4 P.M. 0.711 C 0.715 C 0.004 No 0.713 C 0.002 No 5–6 P.M. 1.018 F 1.026 F 0.008 No 1.021 F 0.003 No 14 Barrington Ave. San Vicente Blvd. 7–8 A.M. 0.595 A 0.609 B 0.014 No 0.602 B 0.007 No 3–4 P.M. 0.630 B 0.637 B 0.007 No 0.634 B 0.004 No 5–6 P.M. 0.384 A 0.390 A 0.006 No 0.387 A 0.003 No 15 Barrington Ave. Wilshire Blvd. 7–8 A.M. 0.537 A 0.540 A 0.003 No 0.539 A 0.002 No 3–4 P.M. 1.163 F 1.166 F 0.003 No 1.166 F 0.003 No 5–6 P.M. 1.319 F 1.321 F 0.002 No 1.321 F 0.002 No 16 San Vicente Blvd./ Wilshire Blvd. 7–8 A.M. 0.661 B 0.663 B 0.002 No 0.663 B 0.002 No Federal Ave. 3–4 P.M. 1.031 F 1.034 F 0.003 No 1.033 F 0.002 No 5–6 P.M. 1.225 F 1.226 F 0.001 No 1.226 F 0.001 No 17 Bundy Dr. (E) San Vicente Blvd. 7–8 A.M. 0.450 A 0.452 A 0.002 No 0.452 A 0.002 No 3–4 P.M. 0.544 A 0.544 A 0.000 No 0.544 A 0.000 No 5–6 P.M. 0.469 A 0.470 A 0.001 No 0.469 A 0.000 No

Source: Fehr & Peers, 2014.

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Table III-4 Revised Table 5B—Baseline Plus Project Conditions—Event Day—Event Attendees Arriving Between 3:00–4:00 P.M. and Departing Between 5:00–6:00 P.M.—Intersection LOS and Significant Impact Analysis

Baseline + Project (50 Percent Busing) Baseline + Project with Mitigation: 70 Percent Baseline + Project with Mitigations: 70 Percent 300-Attendee Event Busing With 300-Attendee Event Busing With Additional Limits on Events Baseline Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 3–4 P.M. 0.442 A 0.451 A 0.009 No 0.451 A 0.009 No 5–6 P.M. 0.337 A 0.347 A 0.010 No 0.345 A 0.008 No 2 Kenter Ave. Sunset Blvd. 3–4 P.M. 0.683 B 0.696 B 0.013 No 0.693 B 0.010 No 5–6 P.M. 0.493 A 0.511 A 0.018 No 0.508 A 0.015 No 3 Bundy Dr. Sunset Blvd. 3–4 P.M. 1.054 F 1.071 F 0.017 Yes 1.068 F 0.014 Yes 1.061 F 0.007 No 5–6 P.M. 1.220 F 1.261 F 0.041 Yes 1.255 F 0.035 Yes 1.229 F 0.009 No 4 Saltair Ave. Sunset Blvd. 3–4 P.M. 0.958 E 0.967 E 0.009 No 0.963 E 0.005 No 5–6 P.M. 1.108 F 1.149 F 0.041 Yes 1.144 F 0.036 Yes 1.116 F 0.008 No 5 Barrington Ave. Sunset Blvd. 3–4 P.M. 1.302 F 1.346 F 0.044 Yes 1.338 F 0.036 Yes 1.307 F 0.005 No 5–6 P.M. 1.323 F 1.359 F 0.036 Yes 1.351 F 0.028 Yes 1.330 F 0.007 No 6 Barrington Pl. Sunset Blvd. 3–4 P.M. 0.854 D 0.867 D 0.013 No 0.865 D 0.011 No 5–6 P.M. 0.884 D 0.888 D 0.004 No 0.886 D 0.002 No 7 Church Ln. I-405 SB Ramps 3–4 P.M. 0.707 C 0.713 C 0.006 No 0.713 C 0.006 No 5–6 P.M. 0.795 C 0.797 C 0.002 No 0.797 C 0.002 No 8 Church Ln. Sunset Blvd. 3–4 P.M. 0.725 C 0.741 C 0.016 No 0.739 C 0.014 No 5–6 P.M. 0.821 D 0.823 D 0.002 No 0.822 D 0.001 No 9 I-405 NB Ramps Sunset Blvd. 3–4 P.M. 0.430 A 0.432 A 0.002 No 0.431 A 0.001 No 5–6 P.M. 0.461 A 0.469 A 0.008 No 0.467 A 0.006 No 10 Veteran Ave. Sunset Blvd. 3–4 P.M. 0.756 C 0.760 C 0.004 No 0.760 C 0.004 No 5–6 P.M. 0.965 E 0.974 E 0.009 No 0.972 E 0.007 No 11 Bundy Dr. (W) San Vicente Blvd. 3–4 P.M. 0.575 A 0.584 A 0.009 No 0.582 A 0.007 No 5–6 P.M. 0.605 B 0.613 B 0.008 No 0.612 B 0.007 No 12 San Vicente Blvd. Montana Ave. 3–4 P.M. 0.933 E 0.936 E 0.003 No 0.936 E 0.003 No 5–6 P.M. 0.906 E 0.907 E 0.001 No 0.906 E 0.000 No 13 Barrington Ave. Montana Ave. 3–4 P.M. 0.711 C 0.740 C 0.029 No 0.738 C 0.027 No 5–6 P.M. 1.018 F 1.028 F 0.010 Yes 1.023 F 0.005 No 14 Barrington Ave. San Vicente Blvd. 3–4 P.M. 0.630 B 0.655 B 0.025 No 0.652 B 0.022 No 5–6 P.M. 0.384 A 0.403 A 0.019 No 0.400 A 0.016 No 15 Barrington Ave. Wilshire Blvd. 3–4 P.M. 1.163 F 1.172 F 0.009 No 1.172 F 0.009 No 5–6 P.M. 1.319 F 1.331 F 0.012 Yes 1.330 F 0.011 Yes 1.321 F 0.002 No 16 San Vicente Blvd./ Wilshire Blvd. 3–4 P.M. 1.031 F 1.034 F 0.003 No 1.033 F 0.002 No Federal Ave. 5–6 P.M. 1.225 F 1.229 F 0.004 No 1.229 F 0.004 No 17 Bundy Dr. (E) San Vicente Blvd. 3–4 P.M. 0.544 A 0.548 A 0.004 No 0.548 A 0.004 No 5–6 P.M. 0.469 A 0.470 A 0.001 No 0.470 A 0.001 No

Source: Fehr & Peers, 2014.

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Table III-5 Revised Table 5D—Baseline Plus Project Conditions—Event Day—Event Attendees Arriving Between 6:00–7:00 P.M. on a Weekday and 1:00–2:00 P.M. on a Saturday—Intersection LOS and Significant Impact Analysis

Baseline + Project (50 Percent Busing) Baseline + Project with Mitigation: 70 Percent Baseline + Project with Mitigations: 70 Percent 300-Attendee Event Busing With 300-Attendee Event Busing With Additional Limits on Events Baseline Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 6–7 P.M. 0.341 A 0.342 A 0.001 No 0.342 A 0.001 No 1–2 Sat. 0.355 A 0.356 A 0.001 No 0.356 A 0.001 No 2 Kenter Ave. Sunset Blvd. 6–7 P.M. 0.482 A 0.489 A 0.007 No 0.489 A 0.007 No 1–2 Sat. 0.590 A 0.595 A 0.005 No 0.595 A 0.005 No 3 Bundy Dr. Sunset Blvd. 6–7 P.M. 0.812 D 0.819 D 0.007 No 0.819 D 0.007 No 1–2 Sat. 0.363 A 0.372 A 0.009 No 0.372 A 0.009 No 4 Saltair Ave. Sunset Blvd. 6–7 P.M. 0.952 E 0.952 E 0.000 No 0.952 E 0.000 No 1–2 Sat. 0.286 A 0.286 A 0.000 No 0.286 A 0.000 No 5 Barrington Ave. Sunset Blvd. 6–7 P.M. 1.020 F 1.056 F 0.036 Yes 1.056 F 0.036 Yes 1.028 F 0.008 No 1–2 Sat. 0.502 A 0.516 A 0.014 No 0.516 A 0.014 No 6 Barrington Pl. Sunset Blvd. 6–7 P.M. 0.972 E 0.972 E 0.000 No 0.972 E 0.000 No 1–2 Sat. 0.506 A 0.506 A 0.000 No 0.506 A 0.000 No 7 Church Ln. I-405 SB Ramps 6–7 P.M. 0.565 A 0.569 A 0.004 No 0.569 A 0.004 No 1–2 Sat. 0.469 A 0.472 A 0.003 No 0.472 A 0.003 No 8 Church Ln. Sunset Blvd. 6–7 P.M. 0.569 A 0.575 A 0.006 No 0.575 A 0.006 No 1–2 Sat. 0.447 A 0.455 A 0.008 No 0.455 A 0.008 No 9 I-405 NB Ramps Sunset Blvd. 6–7 P.M. 0.266 A 0.264 A -0.002 No 0.264 A –0.002 No 1–2 Sat. 0.301 A 0.301 A 0.000 No 0.301 A 0.000 No 10 Veteran Ave. Sunset Blvd. 6–7 P.M. 0.668 B 0.670 B 0.002 No 0.670 B 0.002 No 1–2 Sat. 0.478 A 0.479 A 0.001 No 0.479 A 0.001 No 11 Bundy Dr. (W) San Vicente Blvd. 6–7 P.M. 0.534 A 0.537 A 0.003 No 0.537 A 0.003 No 1–2 Sat. 0.454 A 0.456 A 0.002 No 0.456 A 0.002 No 12 San Vicente Blvd. Montana Ave. 6–7 P.M. 0.883 D 0.885 D 0.002 No 0.885 D 0.002 No 1–2 Sat. 0.859 D 0.861 D 0.002 No 0.861 D 0.002 No 13 Barrington Ave. Montana Ave. 6–7 P.M. 0.677 B 0.695 B 0.018 No 0.695 B 0.018 No 1–2 Sat. 0.673 B 0.686 B 0.013 No 0.686 B 0.013 No 14 Barrington Ave. San Vicente Blvd. 6–7 P.M. 0.568 A 0.581 A 0.013 No 0.581 A 0.013 No 1–2 Sat. 0.631 B 0.640 B 0.009 No 0.640 B 0.009 No 15 Barrington Ave. Wilshire Blvd. 6–7 P.M. 1.192 F 1.195 F 0.003 No 1.195 F 0.003 No 1–2 Sat. 0.517 A 0.517 A 0.000 No 0.517 A 0.000 No 16 San Vicente Blvd./ Wilshire Blvd. 6–7 P.M. 1.283 F 1.284 F 0.001 No 1.284 F 0.001 No Federal Ave. 1–2 Sat. 0.653 B 0.653 B 0.000 No 0.653 B 0.000 No 17 Bundy Dr. (E) San Vicente Blvd. 6–7 P.M. 0.489 A 0.492 A 0.003 No 0.492 A 0.003 No 1–2 Sat. 0.426 A 0.428 A 0.002 No 0.428 A 0.002 No

Source: Fehr & Peers, 2014.

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Table III-6 Revised Table 5E—Baseline Plus Project Conditions—Event Day—Event Attendees Arriving Between 6:00–7:00 P.M. on a Weekday and 1:00–2:00 P.M. on a Saturday—Intersection LOS and Significant Impact Analysis

Baseline + Project (50 Percent Busing) Baseline + Project with Mitigation: 70 Percent Baseline + Project with Mitigations: 70 Percent 650-Attendee Event Busing With 650-Attendee Event Busing With Additional Limits on Events Baseline Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 6–7 P.M. 0.341 A 0.345 A 0.004 No 0.345 A 0.004 No 1–2 Sat. 0.355 A 0.359 A 0.004 No 0.359 A 0.004 No 2 Kenter Ave. Sunset Blvd. 6–7 P.M. 0.482 A 0.505 A 0.023 No 0.505 A 0.023 No 1–2 Sat. 0.590 A 0.607 B 0.017 No 0.607 B 0.017 No 3 Bundy Dr. Sunset Blvd. 6–7 P.M. 0.812 D 0.832 D 0.020 No 0.832 D 0.020 No 1–2 Sat. 0.363 A 0.394 A 0.031 No 0.394 A 0.031 No 4 Saltair Ave. Sunset Blvd. 6–7 P.M. 0.952 E 0.952 E 0.000 No 0.952 E 0.000 No 1–2 Sat. 0.286 A 0.286 A 0.000 No 0.286 A 0.000 No 5 Barrington Ave. Sunset Blvd. 6–7 P.M. 1.020 F 1.068 F 0.048 Yes 1.068 F 0.048 Yes 1.028 F 0.008 No 1–2 Sat. 0.502 A 0.553 A 0.051 No 0.553 A 0.051 No 6 Barrington Pl. Sunset Blvd. 6–7 P.M. 0.972 E 0.972 E 0.000 No 0.972 E 0.000 No 1–2 Sat. 0.506 A 0.506 A 0.000 No 0.506 A 0.000 No 7 Church Ln. I-405 SB Ramps 6–7 P.M. 0.565 A 0.576 A 0.011 No 0.576 A 0.011 No 1–2 Sat. 0.469 A 0.478 A 0.009 No 0.478 A 0.009 No 8 Church Ln. Sunset Blvd. 6–7 P.M. 0.569 A 0.588 A 0.019 No 0.588 A 0.019 No 1–2 Sat. 0.447 A 0.533 A 0.086 No 0.533 A 0.086 No 9 I-405 NB Ramps Sunset Blvd. 6–7 P.M. 0.266 A 0.259 A -0.007 No 0.259 A -0.007 No 1–2 Sat. 0.301 A 0.301 A 0.000 No 0.301 A 0.000 No 10 Veteran Ave. Sunset Blvd. 6–7 P.M. 0.668 B 0.673 B 0.005 No 0.673 B 0.005 No 1–2 Sat. 0.478 A 0.481 A 0.003 No 0.481 A 0.003 No 11 Bundy Dr. (W) San Vicente Blvd. 6–7 P.M. 0.534 A 0.546 A 0.012 No 0.546 A 0.012 No 1–2 Sat. 0.454 A 0.463 A 0.009 No 0.463 A 0.009 No 12 San Vicente Blvd. Montana Ave. 6–7 P.M. 0.883 D 0.889 D 0.006 No 0.889 D 0.006 No 1–2 Sat. 0.859 D 0.864 D 0.005 No 0.864 D 0.005 No 13 Barrington Ave. Montana Ave. 6–7 P.M. 0.677 B 0.737 C 0.060 Yes 0.737 C 0.060 Yes 0.685 B 0.008 No 1–2 Sat. 0.673 B 0.718 C 0.045 Yes 0.718 C 0.045 Yes 0.711 C 0.038 No 14 Barrington Ave. San Vicente Blvd. 6–7 P.M. 0.568 A 0.611 B 0.043 No 0.611 B 0.043 No 1–2 Sat. 0.631 B 0.636 B 0.005 No 0.636 B 0.005 No 15 Barrington Ave. Wilshire Blvd. 6–7 P.M. 1.192 F 1.203 F 0.011 Yes 1.203 F 0.011 Yes 1.193 F 0.001 No 1–2 Sat. 0.517 A 0.520 A 0.003 No 0.520 A 0.003 No 16 San Vicente Blvd./ Wilshire Blvd. 6–7 P.M. 1.283 F 1.285 F 0.002 No 1.285 F 0.002 No Federal Ave. 1–2 Sat. 0.653 B 0.653 B 0.000 No 0.653 B 0.000 No 17 Bundy Dr. (E) San Vicente Blvd. 6–7 P.M. 0.489 A 0.499 A 0.010 No 0.499 A 0.010 No 1–2 Sat. 0.426 A 0.433 A 0.007 No 0.433 A 0.007 No

Source: Fehr & Peers, 2014.

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Table III-7 Revised Table 6A—Cumulative Base Plus Project Conditions—Non-Event School Day—Intersection LOS and Significant Impact Analysis

Cumulative + Project with Mitigations: Cumulative + Project with Mitigation: 70 Percent Busing With Additional Limits Cumulative Cumulative + Project (50 Percent Busing) 70 Percent Busing on Events Base 2020 Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact

1 Cliffwood Ave. Sunset Blvd. 7–8 A.M. 0.535 A 0.539 A 0.004 No 0.538 A 0.003 No 3–4 P.M. 0.485 A 0.486 A 0.001 No 0.485 A 0.000 No 5–6 P.M. 0.370 A 0.373 A 0.003 No 0.372 A 0.002 No 2 Kenter Ave. Sunset Blvd. 7–8 A.M. 0.746 C 0.756 C 0.010 No 0.750 C 0.004 No 3–4 P.M. 0.781 C 0.788 C 0.007 No 0.785 C 0.004 No 5–6 P.M. 0.571 A 0.577 A 0.006 No 0.575 A 0.004 No 3 Bundy Dr. Sunset Blvd. 7–8 A.M. 0.581 A 0.588 A 0.007 No 0.585 A 0.004 No 3–4 P.M. 1.167 F 1.177 F 0.010 Yes 1.172 F 0.005 No 5–6 P.M. 1.344 F 1.355 F 0.011 Yes 1.350 F 0.006 No 4 Saltair Ave. Sunset Blvd. 7–8 A.M. 0.665 B 0.671 B 0.006 No 0.667 B 0.002 No 3–4 P.M. 1.058 F 1.067 F 0.009 No 1.063 F 0.005 No 5–6 P.M. 1.215 F 1.225 F 0.010 Yes 1.221 F 0.006 No 5 Barrington Ave. Sunset Blvd. 7–8 A.M. 0.961 E 0.981 E 0.020 Yes 0.970 E 0.009 No 3–4 P.M. 1.449 F 1.456 F 0.007 No 1.453 F 0.004 No 5–6 P.M. 1.474 F 1.481 F 0.007 No 1.479 F 0.005 No 6 Barrington Pl. Sunset Blvd. 7–8 A.M. 0.815 D 0.821 D 0.006 No 0.818 D 0.003 No 3–4 P.M. 0.966 E 0.973 E 0.007 No 0.970 E 0.004 No 5–6 P.M. 0.997 E 1.000 E 0.003 No 0.999 E 0.002 No 7 Church Ln. I-405 SB Ramps 7–8 A.M. 0.675 B 0.678 B 0.003 No 0.677 B 0.002 No 3–4 P.M. 0.793 C 0.794 C 0.001 No 0.793 C 0.000 No 5–6 P.M. 0.883 D 0.885 D 0.002 No 0.884 D 0.001 No 8 Church Ln. Sunset Blvd. 7–8 A.M. 0.927 E 0.933 E 0.006 No 0.930 E 0.003 No 3–4 P.M. 0.785 C 0.788 C 0.003 No 0.787 C 0.002 No 5–6 P.M. 0.861 D 0.863 D 0.002 No 0.862 D 0.001 No 9 I-405 NB Ramps Sunset Blvd. 7–8 A.M. 0.857 D 0.860 D 0.003 No 0.858 D 0.001 No 3–4 P.M. 0.544 A 0.547 A 0.003 No 0.545 A 0.001 No 5–6 P.M. 0.554 A 0.557 A 0.003 No 0.555 A 0.001 No 10 Veteran Ave. Sunset Blvd. 7–8 A.M. 0.726 C 0.729 C 0.003 No 0.727 C 0.001 No 3–4 P.M. 0.798 C 0.800 C 0.002 No 0.800 C 0.002 No 5–6 P.M. 1.022 F 1.024 F 0.002 No 1.024 F 0.002 No 11 Bundy Dr. (W) San Vicente Blvd. 7–8 A.M. 0.573 A 0.578 A 0.005 No 0.575 A 0.002 No 3–4 P.M. 0.678 B 0.681 B 0.003 No 0.680 B 0.002 No 5–6 P.M. 0.709 C 0.711 C 0.002 No 0.711 C 0.002 No 12 San Vicente Blvd. Montana Ave. 7–8 A.M. 0.786 C 0.787 C 0.001 No 0.786 C 0.000 No 3–4 P.M. 1.022 F 1.023 F 0.001 No 1.022 F 0.000 No 5–6 P.M. 0.993 E 0.994 E 0.001 No 0.994 E 0.001 No

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Table III-7 (Continued) Revised Table 6A—Cumulative Base Plus Project Conditions—Non-Event School Day—Intersection LOS and Significant Impact Analysis

Cumulative + Project with Mitigations: Cumulative + Project with Mitigation: 70 Percent Busing With Additional Limits Cumulative Cumulative + Project (50 Percent Busing) 70 Percent Busing on Events Base 2020 Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact

13 Barrington Ave. Montana Ave. 7–8 A.M. 0.481 A 0.494 A 0.013 No 0.487 A 0.006 No 3–4 P.M. 0.788 C 0.793 C 0.005 No 0.790 C 0.002 No 5–6 P.M. 1.121 F 1.130 F 0.009 No 1.125 F 0.004 No 14 Barrington Ave. San Vicente Blvd. 7–8 A.M. 0.671 B 0.685 B 0.014 No 0.677 B 0.006 No 3–4 P.M. 0.725 C 0.732 C 0.007 No 0.728 C 0.003 No 5–6 P.M. 0.453 A 0.460 A 0.007 No 0.456 A 0.003 No 15 Barrington Ave. Wilshire Blvd. 7–8 A.M. 0.759 C 0.763 C 0.004 No 0.761 C 0.002 No 3–4 P.M. 1.587 F 1.589 F 0.002 No 1.589 F 0.002 No 5–6 P.M. 1.724 F 1.726 F 0.002 No 1.726 F 0.002 No 16 San Vicente Blvd./ Wilshire Blvd. 7–8 A.M. 0.744 C 0.744 C 0.000 No 0.744 C 0.000 No Federal Ave. 3–4 P.M. 1.160 F 1.163 F 0.003 No 1.162 F 0.002 No 5–6 P.M. 1.308 F 1.309 F 0.001 No 1.308 F 0.000 No 17 Bundy Dr. (E) San Vicente Blvd. 7–8 A.M. 0.529 A 0.531 A 0.002 No 0.529 A 0.000 No 3–4 P.M. 0.692 B 0.693 B 0.001 No 0.692 B 0.000 No 5–6 P.M. 0.612 B 0.613 B 0.001 No 0.612 B 0.000 No

Source: Fehr & Peers, 2014.

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Table III-8 Revised Table 6B—Cumulative Base Plus Project Conditions—Event Day—Event Attendees Arriving Between 3:00–4:00 P.M. and Departing Between 5:00–6:00 P.M.—Intersection LOS and Significant Impact Analysis

Cumulative + Project With Mitigations: Cumulative + Project (50 Percent Busing) Cumulative + Project With Mitigation: 70 Percent Busing With Additional Limits Cumulative 300-Attendee Event 70 Percent Busing With 300-Attendee Event on Events Base 2020 Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 3–4 P.M. 0.485 A 0.494 A 0.009 No 0.493 A 0.008 No 5–6 P.M. 0.370 A 0.380 A 0.010 No 0.378 A 0.008 No 2 Kenter Ave. Sunset Blvd. 3–4 P.M. 0.781 C 0.795 C 0.014 No 0.792 C 0.011 No 5–6 P.M. 0.571 A 0.592 A 0.021 No 0.589 A 0.018 No 3 Bundy Dr. Sunset Blvd. 3–4 P.M. 1.167 F 1.183 F 0.016 Yes 1.180 F 0.013 Yes 1.173 F 0.006 No 5–6 P.M. 1.344 F 1.385 F 0.041 Yes 1.378 F 0.034 Yes 1.353 F 0.008 No 4 Saltair Ave. Sunset Blvd. 3–4 P.M. 1.058 F 1.067 F 0.009 No 1.063 F 0.005 No 5–6 P.M. 1.215 F 1.255 F 0.040 Yes 1.251 F 0.036 Yes 1.224 F 0.009 No 5 Barrington Ave. Sunset Blvd. 3–4 P.M. 1.449 F 1.491 F 0.042 Yes 1.484 F 0.035 Yes 1.453 F 0.004 No 5–6 P.M. 1.474 F 1.504 F 0.030 Yes 1.501 F 0.027 Yes 1.480 F 0.006 No 6 Barrington Pl. Sunset Blvd. 3–4 P.M. 0.966 E 0.982 E 0.016 Yes 0.980 E 0.014 Yes 0.970 E 0.004 No 5–6 P.M. 0.997 E 1.001 F 0.004 No 1.000 E 0.003 No 7 Church Ln. I-405 SB Ramps 3–4 P.M. 0.793 C 0.799 C 0.006 No 0.798 C 0.005 No 5–6 P.M. 0.883 D 0.885 D 0.002 No 0.884 D 0.001 No 8 Church Ln. Sunset Blvd. 3–4 P.M. 0.785 C 0.801 D 0.016 No 0.800 C 0.015 No 5–6 P.M. 0.861 D 0.864 D 0.003 No 0.863 D 0.002 No 9 I-405 NB Ramps Sunset Blvd. 3–4 P.M. 0.544 A 0.550 A 0.006 No 0.549 A 0.005 No 5–6 P.M. 0.554 A 0.562 A 0.008 No 0.561 A 0.007 No 10 Veteran Ave. Sunset Blvd. 3–4 P.M. 0.798 C 0.802 D 0.004 No 0.802 D 0.004 No 5–6 P.M. 1.022 F 1.031 F 0.009 No 1.029 F 0.007 No 11 Bundy Dr. (W) San Vicente Blvd. 3–4 P.M. 0.678 B 0.687 B 0.009 No 0.685 B 0.007 No 5–6 P.M. 0.709 C 0.717 C 0.008 No 0.715 C 0.006 No 12 San Vicente Blvd. Montana Ave. 3–4 P.M. 1.022 F 1.025 F 0.003 No 1.025 F 0.003 No 5–6 P.M. 0.993 E 0.997 E 0.004 No 0.996 E 0.003 No 13 Barrington Ave. Montana Ave. 3–4 P.M. 0.788 C 0.817 D 0.029 Yes 0.815 D 0.027 Yes 0.793 C 0.005 No 5–6 P.M. 1.121 F 1.131 F 0.010 Yes 1.126 F 0.005 No 14 Barrington Ave. San Vicente Blvd. 3–4 P.M. 0.725 C 0.749 C 0.024 No 0.747 C 0.022 No 5–6 P.M. 0.453 A 0.472 A 0.019 No 0.469 A 0.016 No 15 Barrington Ave. Wilshire Blvd. 3–4 P.M. 1.587 F 1.596 F 0.009 No 1.596 F 0.009 No 5–6 P.M. 1.724 F 1.736 F 0.012 Yes 1.735 F 0.011 Yes 1.726 F 0.002 No 16 San Vicente Blvd./ Wilshire Blvd. 3–4 P.M. 1.160 F 1.163 F 0.003 No 1.162 F 0.002 No Federal Ave. 5–6 P.M. 1.308 F 1.313 F 0.005 No 1.313 F 0.005 No 17 Bundy Dr. (E) San Vicente Blvd. 3–4 P.M. 0.692 B 0.697 B 0.005 No 0.696 B 0.004 No 5–6 P.M. 0.612 B 0.613 B 0.001 No 0.612 B 0.000 No

Source: Fehr & Peers, 2014.

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Table III-9 Revised Table 6D—Cumulative Base Plus Project Conditions—Event Day—Event Attendees Arriving Between 6:00–7:00 P.M. on a Weekday and 1:00–2:00 P.M. on a Saturday—Intersection LOS and Significant Impact Analysis

Cumulative + Project with Mitigations: Cumulative + Project (50 Percent Busing) Cumulative + Project with Mitigation: 70 Percent Busing With Additional Limits Cumulative 300-Attendee Event 70 Percent Busing With 300-Attendee Event on Events Base 2020 Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 6–7 P.M. 0.374 A 0.375 A 0.001 No 0.375 A 0.001 No 1–2 Sat. 0.393 A 0.394 A 0.001 No 0.394 A 0.001 No 2 Kenter Ave. Sunset Blvd. 6–7 P.M. 0.552 A 0.559 A 0.007 No 0.559 A 0.007 No 1–2 Sat. 0.703 C 0.707 C 0.004 No 0.707 C 0.004 No 3 Bundy Dr. Sunset Blvd. 6–7 P.M. 0.903 E 0.909 E 0.006 No 0.909 E 0.006 No 1–2 Sat. 0.407 A 0.416 A 0.009 No 0.416 A 0.009 No 4 Saltair Ave. Sunset Blvd. 6–7 P.M. 1.047 F 1.047 F 0.000 No 1.047 F 0.000 No 1–2 Sat. 0.323 A 0.323 A 0.000 No 0.323 A 0.000 No 5 Barrington Ave. Sunset Blvd. 6–7 P.M. 1.160 F 1.188 F 0.028 Yes 1.188 F 0.028 Yes 1.168 F 0.008 No 1–2 Sat. 0.564 A 0.578 A 0.014 No 0.578 A 0.014 No 6 Barrington Pl. Sunset Blvd. 6–7 P.M. 1.074 F 1.074 F 0.000 No 1.074 F 0.000 No 1–2 Sat. 0.567 A 0.567 A 0.000 No 0.567 A 0.000 No 7 Church Ln. I-405 SB Ramps 6–7 P.M. 0.640 B 0.643 B 0.003 No 0.643 B 0.003 No 1–2 Sat. 0.516 A 0.518 A 0.002 No 0.518 A 0.002 No 8 Church Ln. Sunset Blvd. 6–7 P.M. 0.651 B 0.656 B 0.005 No 0.656 B 0.005 No 1–2 Sat. 0.498 A 0.506 A 0.008 No 0.506 A 0.008 No 9 I-405 NB Ramps Sunset Blvd. 6–7 P.M. 0.313 A 0.315 A 0.002 No 0.315 A 0.002 No 1–2 Sat. 0.312 A 0.314 A 0.002 No 0.314 A 0.002 No 10 Veteran Ave. Sunset Blvd. 6–7 P.M. 0.719 C 0.719 C 0.000 No 0.719 C 0.000 No 1–2 Sat. 0.529 A 0.530 A 0.001 No 0.530 A 0.001 No 11 Bundy Dr. (W) San Vicente Blvd. 6–7 P.M. 0.632 B 0.635 B 0.003 No 0.635 B 0.003 No 1–2 Sat. 0.561 A 0.564 A 0.003 No 0.564 A 0.003 No 12 San Vicente Blvd. Montana Ave. 6–7 P.M. 0.969 E 0.971 E 0.002 No 0.971 E 0.002 No 1–2 Sat. 0.951 E 0.952 E 0.001 No 0.952 E 0.001 No 13 Barrington Ave. Montana Ave. 6–7 P.M. 0.747 C 0.765 C 0.018 No 0.765 C 0.018 No 1–2 Sat. 0.758 C 0.772 C 0.014 No 0.772 C 0.014 No 14 Barrington Ave. San Vicente Blvd. 6–7 P.M. 0.653 B 0.665 B 0.012 No 0.665 B 0.012 No 1–2 Sat. 0.751 C 0.760 C 0.009 No 0.760 C 0.009 No 15 Barrington Ave. Wilshire Blvd. 6–7 P.M. 1.580 F 1.583 F 0.003 No 1.583 F 0.003 No 1–2 Sat. 0.735 C 0.738 C 0.003 No 0.738 C 0.003 No 16 San Vicente Blvd./ Wilshire Blvd. 6–7 P.M. 1.361 F 1.361 F 0.000 No 1.361 F 0.000 No Federal Ave. 1–2 Sat. 0.739 C 0.739 C 0.000 No 0.739 C 0.000 No 17 Bundy Dr. (E) San Vicente Blvd. 6–7 P.M. 0.633 B 0.636 B 0.003 No 0.636 B 0.003 No 1–2 Sat. 0.639 B 0.641 B 0.002 No 0.641 B 0.002 No

Source: Fehr & Peers, 2014.

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Table III-10 Revised Table 6E—Cumulative Base Plus Project Conditions—Event Day—Event Attendees Arriving Between 6:00–7:00 P.M. on a Weekday and 1:00–2:00 P.M. on a Saturday—Intersection LOS and Significant Impact Analysis

Cumulative + Project with Mitigations: Cumulative + Project (50 Percent Busing) Cumulative + Project with Mitigation: 70 Percent Busing With Additional Limits Cumulative 650-Attendee Event 70 Percent Busing With 650-Attendee Event on Events Base 2020 Project Project Project Analyzed Increase Significant Increase Significant Increase Significant ID N/S Street Name E/W Street Name Periods V/C LOS V/C LOS in V/C Impact V/C LOS in V/C Impact V/C LOS in V/C Impact 1 Cliffwood Ave. Sunset Blvd. 6–7 P.M. 0.374 A 0.378 A 0.004 No 0.378 A 0.004 No 1–2 Sat. 0.393 A 0.397 A 0.004 No 0.397 A 0.004 No 2 Kenter Ave. Sunset Blvd. 6–7 P.M. 0.552 A 0.574 A 0.022 No 0.574 A 0.022 No 1–2 Sat. 0.703 C 0.715 C 0.012 No 0.715 C 0.012 No 3 Bundy Dr. Sunset Blvd. 6–7 P.M. 0.903 E 0.923 E 0.020 Yes 0.923 E 0.020 Yes 0.905 E 0.002 No 1–2 Sat. 0.407 A 0.439 A 0.032 No 0.439 A 0.032 No 4 Saltair Ave. Sunset Blvd. 6–7 P.M. 1.047 F 1.047 F 0.000 No 1.047 F 0.000 No 1–2 Sat. 0.323 A 0.323 A 0.000 No 0.323 A 0.000 No 5 Barrington Ave. Sunset Blvd. 6–7 P.M. 1.160 F 1.200 F 0.040 Yes 1.200 F 0.040 Yes 1.168 F 0.008 No 1–2 Sat. 0.564 A 0.614 B 0.050 No 0.614 B 0.050 No 6 Barrington Pl. Sunset Blvd. 6–7 P.M. 1.074 F 1.074 F 0.000 No 1.074 F 0.000 No 1–2 Sat. 0.567 A 0.567 A 0.000 No 0.567 A 0.000 No 7 Church Ln. I-405 SB Ramps 6–7 P.M. 0.640 B 0.651 B 0.011 No 0.651 B 0.011 No 1–2 Sat. 0.516 A 0.524 A 0.008 No 0.524 A 0.008 No 8 Church Ln. Sunset Blvd. 6–7 P.M. 0.651 B 0.669 B 0.018 No 0.669 B 0.018 No 1–2 Sat. 0.498 A 0.523 A 0.025 No 0.523 A 0.025 No 9 I-405 NB Ramps Sunset Blvd. 6–7 P.M. 0.313 A 0.321 A 0.008 No 0.321 A 0.008 No 1–2 Sat. 0.312 A 0.318 A 0.006 No 0.318 A 0.006 No 10 Veteran Ave. Sunset Blvd. 6–7 P.M. 0.719 C 0.719 C 0.000 No 0.719 C 0.000 No 1–2 Sat. 0.529 A 0.532 A 0.003 No 0.532 A 0.003 No 11 Bundy Dr. (W) San Vicente Blvd. 6–7 P.M. 0.632 B 0.644 B 0.012 No 0.644 B 0.012 No 1–2 Sat. 0.561 A 0.570 A 0.009 No 0.570 A 0.009 No 12 San Vicente Blvd. Montana Ave. 6–7 P.M. 0.969 E 0.975 E 0.006 No 0.975 E 0.006 No 1–2 Sat. 0.951 E 0.955 E 0.004 No 0.955 E 0.004 No 13 Barrington Ave. Montana Ave. 6–7 P.M. 0.747 C 0.807 D 0.060 Yes 0.807 D 0.060 Yes 0.755 C 0.008 No 1–2 Sat. 0.758 C 0.803 D 0.045 Yes 0.803 D 0.045 Yes 0.796 C 0.038 No 14 Barrington Ave. San Vicente Blvd. 6–7 P.M. 0.653 B 0.695 B 0.042 No 0.695 B 0.042 No 1–2 Sat. 0.751 C 0.783 C 0.032 No 0.783 C 0.032 No 15 Barrington Ave. Wilshire Blvd. 6–7 P.M. 1.580 F 1.588 F 0.008 No 1.588 F 0.008 No 1–2 Sat. 0.735 C 0.745 C 0.010 No 0.745 C 0.010 No 16 San Vicente Blvd./ Wilshire Blvd. 6–7 P.M. 1.361 F 1.364 F 0.003 No 1.364 F 0.003 No Federal Ave. 1–2 Sat. 0.739 C 0.739 C 0.000 No 0.739 C 0.000 No 17 Bundy Dr. (E) San Vicente Blvd. 6–7 P.M. 0.633 B 0.642 B 0.009 No 0.642 B 0.009 No 1–2 Sat. 0.639 B 0.647 B 0.008 No 0.647 B 0.008 No

Source: Fehr & Peers, 2014.

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It should be noted that, with the additional event restrictions in Mitigation Measure K-2, the physical mitigation measure proposed in the Draft EIR at the intersection of Saltair Avenue & Sunset Boulevard would no longer be required, since the event restrictions themselves would be sufficient to mitigate the significant Project impact at Saltair Avenue & Sunset Boulevard along with the other impacted intersections. Therefore, Mitigation Measure K-3 in the Draft EIR is hereby deleted:

Mitigation Measure K-3: Saltair Avenue & Sunset Boulevard—The Project Applicant shall coordinate with LADOT to fund and implement the modification to the northbound approach of Saltair Avenue, which shall consist of acquiring a strip of private property right-of-way along the east side of Saltair Avenue south of Sunset Boulevard, widening the Saltair Avenue southern leg, and restriping the existing shared left/through/right-turn lane to provide a shared left/through lane and right-turn lane. This mitigation measure would require removal of the existing University Synagogue fence on the east side of Saltair Avenue’s southern leg, subject to the owner’s approval.

As detailed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, additional restrictions on School operations are proposed, including additional limitations on the hours of operation; reducing the number of proposed School Functions from 98 to 86 School Functions, including eliminating Interscholastic Athletic Competitions and two School Functions with up to 650 guests; and eliminating community use of the facilities and the rental, lease, or use of the facilities for non-School Uses.

Enforcement of Revised Mitigation Measure K-2

As part of the Final EIR, Project Design Feature K-7 is also being refined as follows:

Project Design Feature K-7: Archer The Applicant shall develop an Event Parking and Transportation Management Plan that shall be employed for the all Interscholastic Athletic Competitions and/or School Functions that infrequently require more than 212 parking spaces. The Event Parking and Transportation Management Plan shall include appropriate tools to manage and control traffic and parking for large the events so that impacts to the surrounding areas are minimized and so that the limits in Mitigation Measure K-2 are enforced. Potential measures could include a parking reservation system to manage attendance, attendant-assisted parking, off-site parking, temporary increases in traffic management and parking personnel as needed, and other measures. This Plan shall be submitted to the Department of Transportation for review and approval 60 days prior City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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to issuance of a certificate of occupancy for the Multipurpose Facility the first Interscholastic Athletic Competition or School Function that occurs on the proposed athletic field, Court of Leaders, Multipurpose Facility, Aquatics Center, Performing Arts Center, or Visual Arts Center.

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III. Responses to Comments C. Topical Responses

6. Overview of Construction Traffic and Parking

Several comments on the Draft EIR raise concerns regarding potential traffic and parking impacts associated with Project construction. These comments include the duration of Project construction, potential construction impacts on emergency access, potential construction impacts on traffic congestion and travel time, potential impacts of trucks on Chaparal Street, potential construction truck impacts on street pavement, construction parking impacts, and the cumulative effect of construction projects. This topical response provides a general summary of the construction traffic impacts described in the Draft EIR, followed by a discussion of various areas of concern raised in the comments regarding traffic and parking impacts associated with construction.

Summary of Draft EIR Analysis

As evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, after implementation of the mitigation proposed in the Draft EIR, Project construction would result in an increase in volume to capacity ratios that would result in impacts at up to the following seven intersections depending on the construction phase and haul route:

5. Barrington Avenue & Sunset Boulevard (A.M. and afternoon peak hours)

6. Barrington Place & Sunset Boulevard (afternoon peak hour and from 6:00 P.M. to 7:00 P.M.)

8. Church Lane & Sunset Boulevard (A.M. peak hour)

12. & (under Haul Route Option D— Bundy–San Vicente–Wilshire only)

14. Barrington Avenue & San Vicente Boulevard (under Haul Route Option C— Barrington–Wilshire only)

15. Barrington Avenue & (under Haul Route Option C— Barrington–Wilshire only)

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16. San Vicente Boulevard/Federal Avenue & Wilshire Boulevard

The Project would not result in any significant impacts along the analyzed neighborhood street segments during Project construction under the Baseline with Project Conditions or Future (Horizon Year 2020) with Project Conditions scenarios. To be conservative, and to reflect potential conditions at the time the Project would potentially be under construction, the Draft EIR also included a modified analysis of street segments. The modified analysis reduced the daily traffic volume on each street segment by 50 percent to reflect a conservative evaluation of traffic impacts once construction of the I-405 Sepulveda Pass Improvement Project is complete (since the City of Los Angeles’ criteria for determining significance of impacts on neighborhood streets is based on the project percent of traffic, the lower the background traffic volume, the greater the potential for finding a significant impact). Under the Modified Analysis Baseline with Project Conditions and Modified Analysis Future (Horizon Year 2020) with Project Conditions scenarios, it is possible that construction traffic would result in a temporary significant impact at Chaparal Street between Barrington Avenue and Westgate Avenue during portions of Phase 2 construction. These potential impacts would be considered significant and unavoidable on a Project and cumulative basis.

As stated above, the Draft EIR determined that up to seven intersections could be impacted by Project construction at various periods and depending on the haul route used (but not all seven intersections would be impacted at the same time). The greatest number of intersections would be impacted during the Phase 1 excavation and haul period (which is anticipated to occur over the summer months when Archer and other schools are not in session) and during the completion of the Multipurpose Facility (“Remainder of Phase 1D” period), with up to five intersections impacted during these two phases. Significant impacts during the remaining construction phases (representing the majority of the construction period) would be limited to one or two intersections per phase (see Table IV.K-30 in the Draft EIR) and on Chaparal Street during portions of Phase 2. Finally, it should be noted that the level of activity on the construction site would vary throughout the construction periods. To be conservative, the analysis in the Draft EIR was conducted for the worst- case days within each construction phase. The construction traffic activity is based on the Round Trips Per Vehicle Classification (RTVC) prepared by Paul W. Speer, Inc., which includes the round trips per vehicle classification for each week of Project construction. The RTVC is included as Appendix C.2 of the Draft EIR. It is anticipated that the impacts would be lower throughout much of each phase than the worst-case identified in the Draft EIR.

To reduce the potential construction impacts of the Project, Mitigation Measures K-4 through K-14 were included in the Draft EIR. These mitigation measure include development and implementation of a worksite traffic control plan (Mitigation Measure K-4),

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Page III-130 WORKING DRAFT – Not for Public Review III.C Topical Responses a construction Traffic Management Plan (Mitigation Measure K-5), a construction Parking Management Plan (Mitigation Measure K-6), and a construction Pedestrian Routing Plan (Mitigation Measures K-7). In addition, as described on page IV.K-82 of Section IV.K, Traffic, Access, and Parking, of the Draft EIR, most, if not all, of the haul and equipment/material delivery trips on weekdays would be scheduled during the first eight hours of the permitted construction work period (7:00 A.M. to 3:00 P.M.) Monday through Friday and during the permitted construction work period (8:00 A.M. to 6:00 P.M.) on Saturdays, to minimize impacts during the critical weekday P.M. commute peak period.

Response to Comments Regarding Construction Traffic Impacts

Duration of Project Construction

Several comments on the Draft EIR raise concerns regarding the duration of Project- related traffic impacts during construction. As described in Section II, Project Description, of the Draft EIR, construction of the Project would be implemented in phases over six years commencing with the North Wing Renovation and followed by Phase 1 and Phase 2, each designed and timed to facilitate continued School operations on site and minimize disruptions to neighbors. Construction of Phase 1 would include the underground parking structure, athletic field, and the Multipurpose Facility. Construction of Phase 2 would begin with the Aquatics Center followed by the Visual Arts Center and the Performing Arts Center, or begin with construction of the Performing Arts Center followed by the Aquatics Center and the Visual Arts Center. Concurrent construction of the Phase 2 buildings may also occur. Overlap of completion of the North Wing Renovation and Phase 1 excavation and haul activities may also occur.

The development sequence and timeline described above was used as the basis for the construction period analyses provided in the Draft EIR. As described in detail in Topical Response No. 11, Overview of Construction Refinements, in response to comments on the Draft EIR, the construction period has been reduced from six years to five years.

Potential Construction Impacts on Emergency Access

Several comments on the Draft EIR also raise concerns regarding emergency vehicle access to the surrounding neighborhood due to Project construction. Refer to Section IV.J.1, Public Services—Fire Protection, and Section IV.J.2, Public Services— Police Protection, of the Draft EIR, and Topical Response No. 9, Emergency Vehicle Access, regarding emergency vehicle access.

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Potential Construction Impacts on Traffic Congestion and Travel Time

The transportation analysis in Section IV.K, Traffic, Access, and Parking, of the Draft EIR was prepared in compliance with CEQA, the CEQA Guidelines, the City of Los Angeles 2006 CEQA Thresholds Guide, and the LADOT Traffic Study Guidelines. The LADOT Traffic Study Guidelines require the use of intersection volume-to-capacity (V/C) ratio to determine intersection level of service (LOS). In accordance with LADOT Traffic Study Guidelines, analyses were not conducted to quantify potential Project impacts on travel times and delay along the Sunset Boulevard corridor. It is indisputable that traffic congestion along Sunset Boulevard, particularly the segment between Bundy Drive and the I-405 Freeway, has substantially worsened over the past four years due to the construction of the I-405/Sepulveda Pass Improvement Project, which involved major improvements to the Sunset Boulevard Bridge and I-405 Freeway On/Off Ramps. As described in Topical Response No. 10, Traffic Congestion Along Sunset Boulevard, traffic in the area of the Project is improving as construction on the I-405 Sepulveda Pass Improvement Project has neared completion, with the opening of the HOV lane on the northbound I-405 and substantial completion of the I-405/Sunset Boulevard interchange modifications. The surrounding streets saw an increase in cut-through traffic as motorists attempted to avoid the increased congestion along Sunset Boulevard during the construction of the I-405 Sepulveda Pass Improvement Project. With improvement in conditions along Sunset Boulevard, cut-through traffic is expected to reduce. This recent improvement in conditions on Sunset Boulevard is expected to continue with the completion of the I-405 Sepulveda Pass Improvement Project.

Project construction would minimize the impact of construction trips on traffic conditions. Specifically, as described in Section II, Project Description, of the Draft EIR, most, if not all, of the haul and equipment/material delivery trips would be scheduled during the first eight hours of the permitted construction work period (7:00 A.M. to 3:00 P.M.) on weekdays and during the permitted construction work period (8:00 A.M. to 6:00 P.M.) on Saturdays. This is intended to minimize the potential impact of truck travel during the afternoon peak traffic hours. Furthermore, pursuant to Mitigation Measure K-5, a construction Traffic Management Plan would be prepared and implemented during construction which, among other items, would include the following measures: scheduling deliveries and pick-ups of construction materials during non-peak travel periods, to the extent feasible; coordinating deliveries and pick-ups to reduce the potential of trucks waiting to load or unload for protracted periods of time; minimizing obstruction of through traffic lanes on surrounding public streets; scheduling vehicle movements to ensure that there are no vehicles waiting off-site (with the exception that one to two trucks may stage on Sunset Boulevard in front of Archer) or impeding public traffic flow on the surrounding streets; and providing an off-site staging area during peak haul traffic where trucks would be radioed into the Project Site to avoiding queuing along adjacent streets.

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Potential Impacts of Trucks on Chaparal Street

With regard to truck traffic along Chaparal Street, as described in Section II, Project Description, of the Draft EIR, during the North Wing Renovation and Phase 1 construction, the primary access to the Project Site would be via Sunset Boulevard. The Draft EIR evaluated the potential for up to five percent of trucks to use Chaparal Street during the North Wing Renovation and Phase 1(a) (the Phase 1 excavation and haul), and up to 20 percent during Phases 1(b), 1(c), and 1(d). The use of Chaparal Street during the North Wing Renovation and Phase 1 is required because there may be occasional periods (such as transport of temporary classroom modulars at the beginning and end of the North Wing Renovation or movement of a larger piece of construction equipment onto the site) when it is not possible to use the Sunset Boulevard driveways due to physical limitations on the driveways as they pass by the Main Building. The Draft EIR determined that such impacts would be less than significant.

As discussed above, under the Modified Analysis Baseline with Project Conditions and Modified Analysis Future (Horizon Year 2020) with Project Conditions scenarios, the Draft EIR determined that it is possible that construction traffic would result in a temporary significant impact at Chaparal Street between Barrington Avenue and Westgate Avenue during portions of Phase 2 construction. This would be associated with construction of the Aquatics Center/Visual Arts Center. As discussed above, measures would be implemented to minimize the impacts of construction trucks to the maximum extent feasible.

Construction Worker Parking Impacts

Comments have also been raised concerning the potential for construction workers to park on neighborhood streets. As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, as set forth in Mitigation Measure K-6, construction worker parking would be provided on- and off-site depending on the phase of construction and the availability of on-site parking but no construction worker parking would be permitted within 500 feet of the nearest point of the Project Site except in designated areas. Off-street construction worker parking facilities could include existing parking facilities along Constitution Avenue, San Vicente Boulevard or Wilshire Boulevard, and/or other existing facilities with available excess parking capacity. When construction worker parking is off-site, a temporary shuttle may be operated for construction workers to and from the designated off-site parking location. The alternate parking location(s) for construction workers and the method of transportation to and from the Project Site (if beyond walking distance) would be identified for approval by the City 30 days before commencement of construction. In addition, the Project Applicant would provide all construction contractors with written information on where their workers and their subcontractors are permitted to park, and provide clear consequences to violators for failure to follow these regulations. This information would clearly state that no parking is permitted on residential streets in the City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-133 WORKING DRAFT – Not for Public Review III.C Topical Responses neighborhoods. To make this prohibition clearer, the fourth bullet in Mitigation Measure K-6 is refined as follows:

 Provide all construction contractors with written information on where their workers and their subcontractors are permitted to park, and provide clear consequences to violators for failure to follow these regulations. This information would clearly state that no parking is permitted on residential streets in the neighborhoods north and south of Sunset Boulevard.

In regards to traffic impacts associated with construction workers parking at off-site locations, the potential locations of the off-site parking is not currently known and would depend on market conditions and availability of parking supply at the time of construction. Quantitative analysis of such impacts would be therefore speculative. Mitigation Measure K-6 provides that alternate parking location(s) for construction workers would be identified for approval by the City 30 days before commencement of construction activities when parking cannot be accommodated on-site.

School Parking During Construction

Regarding School parking during construction, as described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, School parking would be provided on- and off-site depending on the phase of construction and the availability of on-site parking. Archer would arrange parking for some or all of the employees, students, and guests in available nearby parking facilities. Options for off-site parking facilities could include the surface parking lot south of Sunset Boulevard at Barrington Village or private parking lots along San Vicente Boulevard and Wilshire Boulevard. During construction when School parking is off-site, Archer may provide a shuttle to facilitate access to and from the designated parking location. The off-site parking location(s) for employees, students, and guests and the method of transportation to and from the Project Site (if beyond walking distance) would be identified for approval by the City 30 days before commencement of construction. The first bullet in Mitigation Measure K-6 is refined as follows:

 During the construction of the proposed parking garage, parking for the School would be arranged in nearby available off-site parking facilities. The alternate parking location(s) and the method of transportation to and from the Project Site (if beyond walking distance) would be identified for approval by LADOT 30 days before commencement of construction.

Upon completion of the underground parking structure, employees, students, and guests would be able to park on-site.

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Cumulative Effect of Construction Projects

Certain comments on the Draft EIR further state that the cumulative effect of construction projects including the I-405/Sepulveda Pass Improvement project, the California Incline reconstruction project, and the Wilshire Bus Rapid Transit (BRT) should be considered.

As discussed in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, the I-405/Sepulveda Pass Improvement project is currently anticipated to be completed by the end of 2014. Construction on the I-405 Freeway is expected to be completed by end of this year (2014), prior to the anticipated beginning of Project construction. To be conservative, an analysis of the Project’s potential impacts during construction of the North Wing Renovation was conducted assuming that the I-405 has not been completed. Regarding the I-405/Sepulveda Pass Improvement project, as described above and detailed in Topical Response No. 10, Traffic Congestion Along Sunset Boulevard, traffic in the area of the Project Site is improving as construction on the I-405/Sepulveda Pass project has neared completion, with the opening of the HOV lane on the northbound I-405 freeway and substantial completion of the I-405/Sunset Boulevard interchange modifications.

As set forth on page 37 of Appendix P.1, Transportation Analysis Report, of the Draft EIR, the Draft EIR considered the changes resulting from the Wilshire Bus Rapid Transit Project including modification to lane configurations at intersections along Wilshire Boulevard and traffic shifts from Wilshire Boulevard to adjacent parallel facilities, such as Sunset Boulevard and San Vicente Boulevard, based on analyses from the Wilshire Bus Rapid Transit Project EIR. Regarding the pending California Incline reconstruction, since the California Incline primarily carries traffic destined to the downtown Santa Monica area, the primary effect of its temporary closure would be to divert traffic to Chautauqua/Channel and to Moomat Ahiko Way in Santa Monica, not to Sunset Boulevard in Brentwood. The Coastal Interceptor Relief Sewer Phase 2 construction project involving lane closures on portions of Pacific Coast Highway south of Entrada Drive is currently underway and is expected to be completed by Spring 2015, which is anticipated to be prior to the beginning of substantial Project construction.4

4 City of Los Angeles Department of Public Works. Construction Projects, http://eng.lacity.org/projects/ prop_o/index_prop_o.htm, accessed October 27, 2014.

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III. Responses to Comments C. Topical Responses

7. Potential Traffic Impacts Associated with Proposed Campus Operations

Several comments on the Draft EIR raise concerns regarding potential traffic impacts associated with proposed campus operations. This topical response addresses comments regarding significant operational traffic impacts; community use and the rental, lease, or use of the facilities for non-School uses; potential project impacts on travel times and delays along Sunset Boulevard; potential use of neighborhood streets by Project- generated traffic; Project access driveways; emergency vehicle access and response; potential impacts associated with filming; and summer academic and camp programs.

Significant Operational Traffic Impacts

Comments on the Draft EIR raised concerns regarding the significant and unavoidable operational traffic impacts. As described in detail in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, in response to comments on the Draft EIR, the Project is incorporating additional operational mitigation measures to reduce significant traffic impacts (related to School Functions and Interscholastic Athletic Competitions) to less than significant. Specifically, Mitigation Measure K-2 has been refined so that on weekdays, afternoon Interscholastic Athletic Competitions and School Functions with start times between 3:00 P.M. and 4:00 P.M. would be limited to a maximum of 44 inbound vehicles, and evening School Functions with start times between 6:00 P.M. and 7:00 P.M. would be limited to a maximum of 126 inbound vehicles. Archer would no longer hold weekday evening Interscholastic Athletic Competitions and School Functions with start times between 5:00 P.M. and 6:00 P.M. Saturday Interscholastic Athletic Competitions and School Functions with start times between 1:00 P.M. and 2:00 P.M. would be limited to a maximum of 243 inbound vehicles.

With the additional mitigation measures described in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, it is estimated that arriving and departing Archer event-generated traffic would contribute a relatively small portion of traffic at the intersection of Barrington Avenue and Sunset Boulevard. As shown

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Page III-136 WORKING DRAFT – Not for Public Review III.C Topical Responses in Table III-11 on page III-138, 26 vehicles arriving for an afternoon Archer event are estimated at the intersection during the 3:00–4:00 P.M. hour, representing less than 1 percent of the total vehicles at the intersection during that hour; 26 vehicles departing from an afternoon Archer event are estimated at the intersection during the 5:00–6:00 P.M. hour, representing less than 1 percent of the total vehicles at the intersection; and 76 vehicles arriving for an evening Archer event are estimated at the intersection during the 6:00–7:00 P.M. hour, representing 2 percent of the total vehicles at the intersection.

Community Use and the Rental, Lease, or Use of the Facilities for Non-School Uses

As detailed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, additional restrictions on School operations are proposed, including eliminating community use of the facilities and the rental, lease, or use of the facilities for non-School uses, thereby reducing traffic along the surrounding streets.

Potential Project Impacts on Travel Times and Delays along Sunset Boulevard

The transportation analysis in Section IV.K, Traffic, Access, and Parking, of the Draft EIR was prepared in compliance with CEQA, the CEQA Guidelines, the City of Los Angeles 2006 CEQA Thresholds Guide, and the LADOT Traffic Study Guidelines. The LADOT Traffic Study Guidelines require the use of intersection volume-to-capacity (V/C) ratio to determine intersection level of service (LOS). As discussed above and in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, with implementation of the mitigation measures presented in the Draft EIR and Final EIR, all Project operational traffic impacts would be reduced to below significance. In accordance with LADOT Traffic Study Guidelines, analyses were not conducted to quantify potential Project impacts on travel times and delay along the Sunset Boulevard corridor.

It is indisputable that traffic congestion along Sunset Boulevard, particularly the segment between Bundy Drive and the I-405 Freeway, substantially worsened due to the construction of the I-405/Sepulveda Pass Improvement Project, which involved major improvements to the Sunset Boulevard Bridge and I-405 Freeway On/Off Ramps. As described in Topical Response No. 10, Traffic Congestion Along Sunset Boulevard, traffic in the area of the Project is improving as construction on the I-405 Sepulveda Pass Improvement Project has neared completion, with the opening of the HOV lane on the northbound I-405 and substantial completion of the I-405/Sunset Boulevard interchange modifications. In addition, the surrounding neighborhood streets saw an increase in cut-through traffic as motorists attempted to avoid the increased congestion along Sunset Boulevard during the construction of the I-405 Sepulveda Pass Improvement Project. As described this Topical Response and in Topical Response No. 10, Traffic Congestion

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Table III-11 Archer Interscholastic Athletic Competition and School Function Trips at Barrington Avenue & Sunset Boulevard Intersection (Year 2020)

70 Percent Busing 3:00–4:00 P.M. and Event Limits Archer Interscholastic Athletic Competition/School Function Trip Generation 44 trips Number of vehicles at Barrington Ave & Sunset Blvd intersection (Year 2020) 4,739 trips Number of vehicles headed westbound on Sunset Blvd at Barrington Ave & 2,224 trips Sunset Blvd intersection (Westbound Approach) (Year 2020) Number of vehicles headed northbound Barrington to westbound Sunset at 222 trips Barrington Ave & Sunset Blvd intersection (Northbound Left Turn) (Year 2020) Number of vehicles arriving at an Archer Interscholastic Athletic Competition/ NBL WBT Totala School Function (based on the event limits), traveling through Barrington Ave & Sunset Blvd. (Year 2020) 13 13 26

70 Percent Busing 5:00–6:00 P.M. Departure and Event Limits Archer Interscholastic Athletic Competition/School Function Trip Generation 44 trips Number of vehicles at Barrington Ave & Sunset Blvd intersection (Year 2020) 4,117 trips Number of vehicles headed eastbound on Sunset Blvd at Barrington Ave & 1,394 trips Sunset Blvd intersection (Eastbound Approach) (Year 2020) Number of vehicles departing from an Archer Interscholastic Athletic EBR EBT Totala Competition/School Function (based on the event limits), traveling through Barrington Ave & Sunset Blvd. (Year 2020) 13 13 26

70 Percent Busing 6:00–7:00 P.M. Arrival and Event Limits Archer School Function Trip Generation 126 trips Number of vehicles at Barrington Ave & Sunset Blvd intersection (Year 2020) 3,042 trips Number of vehicles headed westbound on Sunset Blvd at Barrington Ave & 1,465 trips Sunset Blvd intersection (Westbound Approach) (Year 2020) Number of vehicles headed northbound Barrington to westbound Sunset at 112 trips Barrington Ave & Sunset Blvd intersection (Northbound Left Turn) (Year 2020) Total number of vehicles arriving at an Archer School Function (based on event NBL WBT Totala limits), traveling through Barrington Ave & Sunset Blvd. (Year 2020) 38 38 76

NBL = Northbound Left, WBT = Westbound Through, EBR = Eastbound Right, EBT = Eastbound Through a Vehicles at intersection represents 60 percent of the peak-hour traffic arriving/departing the Archer School for Girls campus. Source: Fehr and Peers, 2014.

Along Sunset Boulevard, cut-through traffic has reduced and is expected to further decline with the completion of the I-405 Sepulveda Pass Improvement Project.

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Potential Use of Neighborhood Streets by Project-Generated Traffic

As evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, during operation, the Project would not result in a significant impact at any of the nearby neighborhood street segments, including the analyzed segments of Chaparal Street, Westgate Avenue, Barrington Avenue (north of Sunset Boulevard), Kearsarge Street, Saltair Avenue, Granville Avenue, Bundy Drive, and Kenter Avenue. As part of the Project, primary access to the Project Site would be unchanged and would continue to be from Sunset Boulevard. Accordingly, few project-generated trips are expected to use these neighborhood streets, and application of the City of Los Angeles significance criteria for determination of significance of project impacts on neighborhood streets found that Project impacts would not be significant.

Certain comments expressed concern regarding the potential for vehicles exiting Archer that wish to travel east on Sunset Boulevard to instead make a right-hand turn, travel west on Sunset Boulevard to Westgate Avenue, turn right onto Westgate Avenue, turn right again onto Chaparal Street and again onto Barrington Avenue, and then turn left onto Sunset Boulevard in order to avoid making the left-hand turn from the Archer driveway onto eastbound Sunset Boulevard. With the implementation of the mitigation measures identified in the 1997 Archer School For Girls Certified EIR, Archer made certain street improvements, including installing a two-way left turn lane in the center of Sunset Boulevard along the Project frontage to aid Project access along the Sunset Boulevard driveways. Field observations at the Project Site indicate that exiting vehicles are able to make the left-hand turn from the Archer driveway onto Sunset Boulevard, oftentimes utilizing this center left-turn lane. These turns are usually made while westbound flows on Sunset Boulevard are stopped by the traffic signal at the Sunset Boulevard and Barrington Avenue intersection.

License plate matching surveys were conducted on May 22, 2014. These surveys consisted of recording the license plates of vehicles observed to turn right from the Archer driveway onto westbound Sunset Boulevard and of vehicles observed to turn right from westbound Sunset Boulevard to northbound Westgate Avenue during the hours of 3:00 P.M. to 6:00 P.M., and then determining whether any of the license plates matched (thus indicating a vehicle potentially going around the block). During the observation period on May 22, 2014, no vehicles were observed to make this movement out of a total of 51 vehicles observed to make a right-turn exit from Archer. Only eight vehicles were observed to turn right from westbound Sunset Boulevard onto Westgate Avenue during the 3-hour observation period, of which none matched a vehicle observed to exit from Archer. Since no vehicles exiting Archer were observed to turn right onto Westgate Avenue, it can be presumed that essentially all of the vehicles that turned right on exit were destined to the west. In other words, essentially all of the vehicles wishing to travel east on

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Sunset during the 3-hour observation period did so by turning left onto Sunset, not by traveling around the block. Although the Draft EIR determined that Project operational impacts on neighborhood streets would be less than significant, pursuant to Project Design Feature K-5, the Project Applicant shall coordinate with the City of Los Angeles and neighborhood residents to provide up to $15,000 toward the development and implementation of a traffic calming plan for Chaparal Street between Saltair Avenue and Barrington Avenue to minimize cut-through traffic on this street.

Project Access Driveways

Certain comments expressed concerns regarding potential Project impacts at Archer access driveways. As described in Section II, Project Description, of the Draft EIR, as part of the Project, primary access to the Project Site would be unchanged and would continue to be from Sunset Boulevard. Upon entering the School from the eastern driveway along Sunset Boulevard, vehicles would have the option to drop off at the Main Building front steps or access the new underground parking structure and arrival plaza by proceeding down an east driveway ramp. Vehicles would continue to exit the School from the west driveway to Sunset Boulevard, and the Project would include vehicular circulation and queuing improvements. In particular, Archer proposes to widen the existing circular driveway on both the east and west sides to improve site access and allow for dedicated right- and left turn lanes at the exit. On the east side, a portion of the driveway to the south of the Main Building would be widened by approximately 11 feet 9 inches to provide two inbound lanes from Sunset Boulevard and to allow for easier maneuvering at the entrance to the parking ramp. On the west side, the width of the driveway to the south of the Main Building would be increased by approximately 5 feet 4 inches to allow for separate right- and left-turn lanes at the exit to Sunset Boulevard.

The Archer campus is currently used for typical school uses and events. Field observations at the Project Site indicate that entering vehicles are able to make the right-hand turn into the Archer driveway from westbound Sunset Boulevard. In addition, entering vehicles are able to make the left-hand turn into the Archer driveway from eastbound Sunset Boulevard and exiting vehicles are generally able to make the left-hand turn from the Archer driveway onto Sunset Boulevard, oftentimes using the center left-turn lane that is present on Sunset Boulevard in front of the Project Site. These turns are usually made while westbound flows on Sunset Boulevard are stopped by the traffic signal at the Sunset Boulevard and Barrington Avenue intersection. As described above, on the date of the license plate matching survey, no vehicles exiting the Archer campus turned right to use Westgate Avenue or Saltair Avenue to Chaparal Street to Barrington Avenue in order to gain access to eastbound Sunset Boulevard, but rather make the left-hand turn from the driveway onto eastbound Sunset Boulevard. In addition, traffic counts conducted at the School driveways confirm that vehicles are able to make both left turns into the

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Page III-140 WORKING DRAFT – Not for Public Review III.C Topical Responses entrance driveway from Sunset Boulevard and left turns out from the exit driveway onto Sunset Boulevard. It is anticipated that the driveways would continue to operate in a similar manner to existing conditions. As such, no issues are anticipated in regards to Project access.

Also, as previously described, traffic in the area of the Project is improving as construction on the I-405/Sepulveda Improvement Pass Project has neared completion, with the opening of the HOV lane on the northbound I-405 freeway and substantial completion of the I-405/Sunset Boulevard interchange modifications, and is expected to continue to improve with completion of the I-405/Sepulveda Pass Improvement Project later this year. This improvement will further facilitate turns into and out of the Archer driveways on Sunset Boulevard.

Emergency Vehicle Access and Response

Several comments on the Draft EIR raise concerns regarding emergency vehicle access to the surrounding neighborhood due to traffic conditions in the Project Site area. Refer to Section IV.J.1, Public Services—Fire Protection, and Section IV.J.2, Public Services—Police Protection, of the Draft EIR, and Topical Response No. 9, Emergency Vehicle Access, regarding emergency vehicle access.

Filming

Certain comments express concern regarding the potential impacts associated with filming. The Project proposes that filming on campus for commercial purposes would continue to be prohibited except when the School is not in session and provided the filming revenue is placed in the School’s scholarship fund. As described in Topical Response No. 1, Refinements to Proposed Operations, filming would be permitted for no more than 24 days per year. In addition, as set forth in Project Design Feature A-15 included in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, during filming, trucks and equipment would be required to use the School’s underground parking structure accessed from Sunset Boulevard. Parking on neighborhood streets would be strictly prohibited. Hours would be further restricted, with filming beginning no earlier than 9:00 A.M. and concluding no later than 6:00 P.M., and no filming on Sunday. The Project would restrict the number of vehicles allowed to travel for filming during the peak hours. The number of vehicles allowed to arrive and depart the campus would be less than the number of vehicles estimated for School operations as set forth in Table III-2 on page III-115 in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts. As described above, with implementation of the mitigation measures presented in the Draft EIR and Final EIR, all Project operational traffic impacts would be reduced to below significance. Accordingly, filming would have less than significant traffic impacts. City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Summer Academic and Camp Programs

Certain comments further express concern regarding the potential impacts associated with summer academic and camp programs. As part of the Project, summer academic and camp programs are proposed to occur for up to six weeks when the academic year is not in session between the hours of 8:00 A.M. and 5:00 P.M. Monday through Friday. The number of students, faculty, and staff attending summer academic and camp programs would be less than number of students, faculty, and staff that attend Archer when the academic year is in session. As described in Topical Response No. 1, Refinements to Proposed Operations, all participants in the summer programs would arrive and depart on buses. There would be no parent drop-offs or pick-ups allowed at Archer or in the surrounding neighborhood. Trip generation associated with this use would be less than the typical school day during the academic year and traffic volumes are generally lower in the summer months compared to months when schools are in session. As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, impacts associated with a non-event day are less than significant. Accordingly, traffic impacts of the summer academic and camp programs would be less than significant.

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8. Summary of Impacts from Parking Structure

Several comments on the Draft EIR raise concerns regarding the potential air quality and noise impacts to adjacent residential and on-site sensitive uses (e.g., Archer’s students) associated with naturally ventilating the proposed underground parking structure. This topical response provides an analysis of the potential air quality and noise impacts associated with operation of the underground parking structure.

As described in Section II, Project Description, of the Draft EIR, parking is currently provided within two surface parking areas connected by a driveway directly behind the Main Building. These surface parking areas are located to the rear and west of the Main Building. The west surface parking area is located adjacent to multi-family residential uses to the south. With the Project proposed in the Draft EIR, parking is proposed in a new, approximately 96,000-square-foot underground parking structure to accommodate approximately 212 cars within the western portion of the campus. The parking structure would be open to natural light and outside air along more than 40 percent of its perimeter, which would allow the parking structure to be naturally ventilated and reduce the need for energy-consuming (and noise-producing) mechanical ventilation equipment. As detailed in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, in response to comments on the Draft EIR, refinements to the site plan presented in the Draft EIR have been incorporated into the Project, including reducing the size of the underground parking structure to 85,500 square feet. The capacity of the underground parking structure would be reduced from 212 spaces to 185 spaces. With the reduction in size, the parking structure would be located approximately 62 feet from the western property boundary, which represents an increased set back of approximately 35 feet when compared with the Project described in the Draft EIR, wherein the setback was approximately 27 feet from the western property boundary. In addition, the row of parking spaces along the southern edge of the parking structure previously proposed to remain uncovered would be eliminated and replaced with an expanded landscape buffer. While the southern side of the parking structure would remain open, this design refinement would increase the planting area between the southern edge of the underground parking structure and the southern property line from 7 feet 10 inches to 22 feet to accommodate an expanded landscape buffer that would visually shield parked cars from view. The

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Page III-143 WORKING DRAFT – Not for Public Review III.C Topical Responses underground parking structure is proposed to be naturally ventilated along the north, south, and east. The parking structure would be completely closed along the western side. The underground parking structure could be open up to approximately 68 percent along the north side, up to approximately 100 percent along the south side, and up to approximately 42 percent along the east side. Openings on the north would consist of stair shafts and ventilation/light wells that open downward into the garage from the playing field level. These are located parallel to the north side of the soccer field and are fully screened from public view by the 8-foot-high masonry wall running the length of Archer’s site along Chaparal Street. Openings along the south and east sides occur where the south and east garage walls are left open to face into below-grade landscaped areas.

Analysis of Air Quality Impacts

The underground parking structure would be primarily used by automobiles; accordingly, the primary pollutant of concern is Carbon Monoxide (CO). However, the analysis of air quality impacts evaluates all pollutants with significance thresholds included in SCAQMD’s Localized Significance Thresholds (LST) guidelines including CO, NOX, PM10, and PM2.5. The analysis was performed using the methodology delineated in SCAQMD’s LST guidelines. Hourly emission rates were calculated based on the California Air Resources Board’s (CARB’s) EMFAC 2011 emission factors multiplied by the number of vehicles entering and exiting the underground parking structure multiplied by the distance traveled and amount of idling time. These emission rates were then input into SCAQMD’s recommended refined dispersion model (AERMOD). All arriving and departing vehicles were conservatively assumed to travel at an average speed of 10 miles per hour within the parking structure, to idle for five minutes, and travel approximately 900 feet, both entering and exiting the parking structure. To ensure that the air quality analysis was conservative, the number of vehicles entering and exiting the underground parking structure was based on two peak parking demand scenarios prior to implementation of mitigation measures. One scenario assumed enrollment of 518 students plus an event day consisting of a 300-person event starting at 4:00 P.M. (arrival between 3:00 P.M. and 4:00 P.M. and departure between 5:00 P.M. and 6:00 P.M.) and a 650-person event starting at 7:00 P.M. (arrival between 6:00 P.M. and 7:00 P.M. and departure between 9:00 P.M. and 10:00 P.M.) resulting in a parking demand of 1,776 parking spaces throughout the day. The second scenario assumed enrollment of 518 students plus an event day consisting of a 300-person event beginning at 4:00 P.M. (arrival between 3:00 P.M. and 4:00 P.M. and departure between 5:00 P.M. and 6:00 P.M.) and a 300-person event starting at 6:00 P.M. (arrival between 5:00 P.M. and 6:00 P.M. and departure between 7:00 P.M. and 8:00 P.M.) resulting in a peak parking demand of 1,206 spaces throughout the day. As noted above, neither scenario assumed implementation of mitigation measures. These assumptions, including the assumed peak parking demand, are higher than proposed as part of the Project. Refer to Section in Section IV.K, Traffic, Access, and Parking, of the Draft EIR and

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Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, for a description of the additional mitigation measures proposed to reduce significant traffic impacts to less than significant. Also refer to Topical Response No. 3, Overview of Reduced Parking Spaces, Parking Demand and Supply, and Parking Enforcement, for a discussion of the Project’s parking demand.

These assumptions and methodology were then carried across four different underground parking structure scenarios, which address concerns over how the pollutant emissions would ventilate from the underground parking structure. The modeling was consistent with federal modeling guidance.5 The first scenario analyzed emissions from the parking structure assuming that pollutant emissions would be evenly distributed throughout the parking structure and released as a single area source representing the footprint of the structure. Since the parking structure is open on three sides (up to approximately 68 percent along the north side, up to approximately 100 percent along the south side, and up to approximately 42 percent along the east side), the analysis also evaluated three additional scenarios to address the public concern as to whether the specific opening configuration could potentially increase pollutant concentrations at sensitive receptors near these openings. Each of the three scenarios assumed that all of the emissions from the parking structure would be released from one of the three sides (north, south, or east). From an emissions standpoint, these three scenarios are the equivalent of having all of the vehicles idling and traveling along one side of the parking structure and as close as possible to potential impacted sensitive receptors. As this would not be the case, these scenarios conservatively overestimate potential impacts The supporting calculations, model output files, scalar concentration isopleths for maximum impacts, and summary of impacts for this analysis are provided in Appendix F-2 of this Final EIR.

In response to comments, the potential air quality impacts were evaluated for both adjacent residential and on-site sensitive uses. Table III-12 on page III-146 presents a summary of potential impacts to on-site sensitive uses based on the ventilation scenario resulting in the maximum air quality impact. As shown in Table III-12, the maximum on-site air quality impacts would occur under the north ventilation scenario. All other scenarios analyzed for on-site impacts would be less than this scenario; the results are provided in Appendix F-2 of this Final EIR. As shown in Table III-12, potential localized air quality impacts associated with use of the underground parking structure would be below any of the applicable SCAQMD localized significance thresholds for on-site sensitive uses.

5 Emissions and Dispersion Modeling System (EDMS) User’s Manual, January 2007, www.faa.gov/about/ office_org/headquarters_offices/apl/research/models/edms_model/media/EDMS%205.0.2%20User%20 Manual.pdf

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Table III-12 Project Estimate of Localized Operational Impacts at On-Site Receptors (µg/m3)

Maximum Impact from Maximum Project Configuration Background Project + SCAQMD Emissions with Pollutant Background Significance Averaging Impact Maximum Concentrationa Concentration Thresholdb Exceed Pollutant Time (µg/m3) Impact (µg/m3) (µg/m3) (µg/m3) Threshold? 1-hour 8.7 North Vents 121 130 188 No (NAAQS-98th percentile, averaged NO2 over 3 years) 1-hour 8.7 North Vents 164 173 339 No

Annual 0.2 North Vents 37 37 57 No

1-hour 1,733 North Vents 3,450 5,183 23,000 No CO 8-Hour 649 North Vents 2,556 3,204 10,000 No

24-Hour 2.0 North Vents N/A N/A 10.4 No

PM10 Annual 0.2 North Vents N/A N/A 2.5 No

24-Hour 1.7 North Vents N/A N/A 10.4 No

PM2.5 Annual 0.2 North Vents N/A N/A 2.5 No

a Background pollutant concentrations based on monitoring results from the SCAQMD West Los Angeles station for the years 2009–2012. b SCAQMD Air Quality CEQA Significance Thresholds, www.aqmd.gov/docs/default-source/ceqa/handbook/ scaqmd-air-quality-significance-thresholds.pdf?sfvrsn=2, accessed June 2014. The SCAQMD localized 3 threshold for NOX was supplemented to account for the recently adopted 1-hour NO2 NAAQS of 188 µg/m . Source: Matrix Environmental, 2014.

Table III-13 on page III-147 presents a summary of potential impacts to off-site sensitive uses (e.g., adjacent residences) based on the ventilation scenario resulting in the maximum air quality impact. As shown in Table III-13, the maximum off-site air quality impacts for short-term pollutant concentrations (1-hour, 8-hour, and 24-hour) would occur under the area source scenario (i.e., assuming that pollutant emissions would be evenly distributed throughout the parking structure and released as a single area source representing the footprint of the structure) in which the location of the maximum impacts would be south of the underground parking structure. The maximum annual concentration would occur under the north ventilation scenario in which the location of the maximum

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Table III-13 Project Estimate of Localized Operational Impacts at Off-Site Receptors (Residential Uses) (µg/m3)

Maximum Impact from Maximum Project Configuration Background Project + SCAQMD Emissions with Pollutant Background Significance Averaging Impact Maximum Concentrationa Concentration Thresholdb Exceed Pollutant Time (µg/m3) Impact (µg/m3) (µg/m3) (µg/m3) Threshold? 1-hour 1.8 Area 121 123 188 No (NAAQS-98th percentile, averaged NO2 over 3 years) 1-hour 1.8 Area 164 123 339 No

Annual <0.1 North Vents 37 37 57 No

1-hour 354 Area 3,450 3,804 23,000 No CO 8-Hour 125 Area 2,556 2,680 10,000 No

24-Hour 0.4 Area N/A N/A 10.4 No

PM10 Annual <0.1 North Vents N/A N/A 2.5 No

24-Hour 0.2 Area N/A N/A 10.4 No

PM2.5 Annual <0.1 North Vents N/A N/A 2.5 No

a Background pollutant concentrations based on monitoring results from the SCAQMD West Los Angeles station for the years 2009–2012. b SCAQMD Air Quality CEQA Significance Thresholds, www.aqmd.gov/docs/default-source/ceqa/handbook/ scaqmd-air-quality-significance-thresholds.pdf?sfvrsn=2, accessed June 2014. The SCAQMD localized 3 threshold for NOX was supplemented to account for the recently adopted 1-hour NO2 NAAQS of 188 µg/m . Source: Matrix Environmental, 2014. impacts would be north of the underground parking structure. All other scenarios analyzed for off-site impacts would be less than these two ventilation scenarios. The results are provided in Appendix F-2 of this Final EIR. Potential localized air quality impacts associated with use of the underground parking structure would be below any of the applicable SCAQMD localized significance thresholds for off-site sensitive uses.

Consistent with the analysis provided in the Draft EIR, potential localized operational air quality impacts would be less than significant.

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Analysis of Noise Impacts

As discussed on pages IV.I-77, IV.I-79, and IV.I-81 in Section IV.I, Noise, of the Draft EIR, noise associated with parking facilities include car movements, activation of car alarms, sounding of car horns, slamming of car doors, and tire squeals. Automobile movements, which would comprise the most continuous noise source, would generate a noise level of approximately 65 dBA (Lmax) at a distance of 25 feet. Occasional events such as activation of car alarms and sounding of car horns would generate maximum noise levels as high as 75 dBA (Lmax) at a distance of 25 feet. The parking surface of the parking structure would be textured to reduce tire squeal and associated noise with implementation of the Project Design Feature I-2.

Parking is currently provided within two surface parking areas connected by a driveway directly behind the Main Building. With the Project, parking is proposed in a new underground parking structure within the western portion of the campus. Typically, noise associated with below-grade parking garages (e.g., car movements, horns, and alarms) is contained within the structure, and, thus, noise levels from below grade parking structures are effectively shielded. As discussed above, as part of the Project’s objectives to create a sustainable design, the proposed underground parking structure would include ventilation openings along the south, north, and east sides of the parking structure. Therefore, the Draft EIR analyzed the potential noise impacts associated with the proposed underground parking structure.

The Project proposed in the Draft EIR included a row of parking spaces that would remain uncovered along the southern boundary of the athletic field. However, as detailed in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, in response to comments on the Draft EIR, refinements to the site plan presented in the Draft EIR are proposed, including reducing the size of the underground parking structure. The southern row of parking spaces previously proposed to remain uncovered would be replaced with up to 10 feet of additional landscaping, which would increase the distance between the vehicles and the nearest receptor LR10. In addition, the parking structure would include barrier walls and sound-absorbing acoustic liners along the northern ventilation openings.

Additional noise analysis was conducted to evaluate the parking structure noise, as part of the refined Project, to the nearest off-site sensitive receptors. The analysis was calculated using a 3-dimensional computer noise prediction model that takes into account noise shielding provided by structures (buildings and/or walls), terrain (land topography); and sound attenuation provided by atmospheric absorption. Table III-14 on page III-149 presents an analysis of the parking facilities noise levels at the nearest receptors to the parking structure, under the existing condition and under the refined Project as detailed in

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Table III-14 Parking Operation Noise Levels

Estimated Maximum Noise Levels from Parking Operation, Lmax (dBA) Existing Final EIR Change in Noise Significant Receptora Floor Surface Parking Refined Project Levels, dBA Impact? LR02 1 49 48 -1 No 2 58 56 -2 LR03 1 45 44 -1 No 2 53 45 -8 LR10 1 75 61 -14 2 74 70 -4 No 3 72 69 -3 4 70 68 -2

a Represent off-site sensitive receptors closest to the proposed parking structure. LR02—11840 Chaparal St., nearest receptor to the west. LR03—11827 Chaparal St., nearest receptor to the north. LR10—11747 Sunset Blvd., nearest receptor to the south. Source: AES, August 2014.

Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood. As indicated in Table III-14, the parking structure would reduce the existing parking-related noise at receptors LR02, LR03, and LR10. In addition, the parking structure would also reduce the existing parking-related noise at all off-site sensitive receptors, as the parking related noise would be lower due to distance attenuation and noise reduction provided by existing and future buildings. As such, noise impacts associated with the operation of the parking structure would be less than significant.

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9. Emergency Vehicle Access

Several comments on the Draft EIR stated concerns regarding emergency vehicle access to the surrounding neighborhood due to traffic conditions in the Project Site area. Potential impacts to emergency vehicle access that could be caused during construction and operation of the Project are analyzed in Section IV.J.1, Public Services—Fire Protection and Section IV.J.2, Public Services—Police Protection, of the Draft EIR. In addition, Section IV.K, Traffic, Access, and Parking, of the Draft EIR provides an analysis of potential traffic impacts during construction and operation of the Project, including potential traffic impacts along certain neighborhood streets. This topical response summarizes potential impacts to emergency vehicle access during construction and operation of the Project, as discussed throughout the Draft EIR, and provides additional information regarding the proposed refinements to the Project, which would serve to address concerns regarding emergency vehicle access.

As discussed in the Draft EIR, in order to adequately identify and assess the full range of the Project’s potential impacts on fire protection and police protection services, early consultation with the Los Angeles Fire Department (LAFD) and the Los Angeles Police Department (LAPD) was conducted in accordance with Section 15083 of the State CEQA Guidelines, as provided in Appendix O, Correspondence from Public Service Providers, of the Draft EIR. As further provided in Appendix O of the Draft EIR, Archer also met with LAFD Inspector Terrance O’Connell regarding the specific requirements for the Project, which have been incorporated and would be verified during the building permit process for the Project.

Construction Impacts

As evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, construction traffic would result in less-than-significant traffic impacts at the analyzed street segments during the North Wing Renovation and all of Phase 1 construction. Construction traffic would result in a temporary significant impact at Chaparal Street between Barrington Avenue and Westgate Avenue during portions of Phase 2 construction. Accordingly, as analyzed in Section IV.J, Public Services, of the Draft EIR, construction-related traffic on

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Page III-150 WORKING DRAFT – Not for Public Review III.C Topical Responses adjacent streets could temporarily interfere with local and on-site emergency response. However, as set forth in Mitigation Measure K-4 through Mitigation Measure K-7 included in the Draft EIR, during construction of the Project, a Worksite Traffic Control Plan, Traffic Management Plan, Parking Plan, and Pedestrian Routing Plan would be implemented to ensure that adequate and safe access remains available within and surrounding the Project Site during construction activities. As part of these plans, provisions for temporary traffic control would be provided during all construction activities adjacent to public rights-of-way to improve traffic flow on public roadways (e.g., flag persons for truck ingress/egress, etc.). Further, Archer would coordinate with City and emergency service providers to ensure that adequate emergency access is maintained to the Project Site and neighboring businesses and residences at all times and streets remain clear and unobstructed during construction of the Project. With implementation of temporary traffic controls during construction activities adjacent to public rights-of-way, emergency vehicle access to the Project Site and surrounding uses would be maintained. Furthermore, the additional traffic generated by the Project would not significantly impact emergency vehicle response times to the Project Site and surrounding uses, including along City-designated disaster routes (the closest of which are San Vicente Boulevard and the I-405 Freeway), since the drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic. Therefore, Project-related traffic is not anticipated to impair LAFD from responding to emergencies at the Project Site or the surrounding area. Additionally, due to the proximity of Fire Station No. 19, located 0.6 mile from the Project Site, emergency response times to the Project Site are not expected to substantially increase.

As described in Topical Response No. 11, Overview of Construction Refinements, in response to comments on the Draft EIR, refinements to the Project are proposed, including reducing the construction period from six years to five years. With this modification, the duration of any potential construction-related impacts to emergency vehicle access in the vicinity of the Project Site would be reduced.

Operational Impacts

As evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, after implementation of mitigation, all Project traffic impacts on non-event days would be reduced to below a level of significance. The mitigation measures provided in Section IV.K, Traffic, Access, and Parking, of the Draft EIR would also reduce the Project traffic impacts during the weekday 3:00–4:00 P.M. and Saturday 1:00–2:00 P.M. hours associated with events to below a level of significance. The Draft EIR determined that significant impacts would still remain, however, during the 5:00–6:00 P.M. and 6:00–7:00 P.M. hours associated with events. In addition, during operation, the Project would not result in a significant impact at any of the nearby neighborhood street segments.

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As described in detail in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, in response to comments on the Draft EIR, additional operational mitigation measures are proposed to be implemented to reduce significant operational traffic impacts related to School Functions and Interscholastic Athletic Competitions to below a level of significance. With implementation of the additional mitigation measures listed in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, and Section II, Corrections and Additions, of this Final EIR, all potential traffic impacts would be reduced to below a level of significance. Therefore, it is not expected that the Project would consistently increase interference with existing emergency response capacity to the Project area. In addition, as detailed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, the Project proposes additional restrictions on School operations including additional limitations on the hours of operation; reducing the number of proposed School Functions from 98 to 86, including eliminating Interscholastic Athletic Competitions and two School Functions with up to 650 guests; and eliminating community use of the facilities and the rental, lease, or use of the facilities for non-School Uses;6 thereby further reducing traffic associated with School operations along the surrounding streets, including the analyzed neighborhood street segments.

Notwithstanding, the Project would not change the existing configuration of the surrounding streets nor install barriers that would impede emergency vehicle access within and in the vicinity of the Project Site. As such, emergency access to the Project Site and surrounding uses would be maintained at all times. In addition, the increase in traffic generated by the Project would not significantly impact emergency vehicle response times to the Project Site and surrounding uses, including along City-designated disaster routes (the closest of which are San Vicente Boulevard and the I-405 Freeway),7 since the drivers of emergency vehicles normally have a variety of options for avoiding traffic, such as using sirens to clear a path of travel or driving in the lanes of opposing traffic. Therefore, Project- related traffic would not impair emergency providers from responding to emergencies at the Project Site or the surrounding area.

6 As described on page II-37 in Section II, Project Description, of the Draft EIR, the Project included the rental, lease, and use of the facilities for non-School Use, including club athletics, weddings, and private parties, a maximum of 24 days per year. As set forth in Topical Response No. 1, Modifications to Proposed Operations, in response to comments on the Draft EIR, additional restrictions on School operations are proposed including eliminating rental, lease, and use of the facilities for non-School Use activities including club athletics, weddings, and private parties. As described on page II-37 in Section II, Project Description, of the Draft EIR, the Project also included filming on campus when the School is not in session and provided the filming revenue is placed in the School’s scholarship fund. This activity would continue to be proposed. Refer to Topical Response No. 1, Modifications to Proposed Operations, which details additional restrictions on School operations, including filming. 7 City of Los Angeles. General Plan Safety Element, Exhibit H. November 1996.

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It is further noted that in accordance with Project Design Feature K-1, Archer shall continue to implement a comprehensive Traffic Management Program that would include, but not be limited to, maintenance of an average vehicle ridership of three persons per vehicle; a maximum of 15-student driven carpools consisting of three students in each vehicle with additional carpools permitted consisting of four or more students in each vehicle; restricting students from driving to School alone; and requiring that students who do not ride the bus be dropped off either in a parent-driven carpool or student-driven carpool. In addition, as set forth in Project Design Feature K-5, Archer shall coordinate with the City and neighborhood residents to provide up to $15,000 for the development and towards implementation of a traffic calming plan on Chaparal Street between Saltair Avenue and Barrington Avenue to minimize cut-through traffic on this street. Furthermore, Project Design Feature K-6 would require that at least 20 percent of employees arrive outside of the morning peak hour when the student population reaches 470. Archer shall increase this requirement proportionally as the student population approaches 518 students, at which time Archer shall require at least 40 percent of its employees to arrive outside the morning peak hour. Additionally, as provided in Project Design Feature K-7, Archer shall develop an Event Parking and Transportation Management Plan to manage and control traffic and parking during events so that impacts to the surrounding areas are minimized. In accordance with Mitigation Measures K-1 and K-2, Archer shall also raise the percentage of students who are required to utilize the fixed-route bus service from 50 percent to 70 percent and, as discussed above, Archer shall also limit the number of trips generated by guests arriving at or departing from weekday afternoon and Saturday afternoon School Functions and Interscholastic Athletic Competitions. With the implementation of these project design features and mitigation measures, potential impacts to emergency access during operation of the Project would be further reduced.

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10. Traffic Congestion along Sunset Boulevard

Several comments on the Draft EIR state that traffic is severely congested along Sunset Boulevard in the vicinity of the Project Site, and that the Project could potentially make these conditions worse. These comments include concerns regarding traffic congestion along Sunset Boulevard; delays and lengthy travel times during the afternoon peak period on Sunset Boulevard; congestion at the intersection of Sunset Boulevard and Barrington Avenue; and cut through traffic on adjacent neighborhood streets due to traffic congestion along Sunset Boulevard.

I-405 Sepulveda Pass Improvement Project Construction

Traffic on Sunset Boulevard, particularly the eastbound segment between Bundy Drive and the I-405 Freeway, experiences congestion between 3:00 P.M. and 6:00 P.M. Construction of the I-405 Sepulveda Pass Improvement Project has temporarily increased congestion and has resulted in suppressed traffic volumes. The I-405/Sepulveda Pass Improvement Project involves major modifications to the I-405 corridor, including adding a northbound carpool lane between the I-10 and US-101 Freeways, tearing down and replacing the Sunset Boulevard bridge over the I-405, reconstructing ramps at the I-405/ Sunset Boulevard interchange, reconstructing the I-405/Wilshire Boulevard interchange to include braided on- and off-ramps, and modifying . During the construction period, traffic flow has been constrained due to a variety and constantly- changing series of activities, including: ramp and street closures, reductions in lanes on surface arterials including Sunset Boulevard, and reductions in the number of travel lanes in both the northbound and southbound directions on the I-405 Freeway between the I-10 Freeway and the US-101 Freeway. During the span of the construction period, several regional and sub-regional thoroughfares including I-10 Freeway, Wilshire Boulevard, , Olympic Boulevard, , Sepulveda Boulevard, Barrington Avenue, and Bundy Drive have experienced increased congestion that has resulted in suppressed volumes. Sunset Boulevard has been one of the desired east-west thoroughfares for motorists traveling between the San Fernando Valley and the Westside attempting to avoid severe traffic congestion along the I-10 Freeway, the I-405 Freeway, and the interchange between these two freeways.

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I-405 Sepulveda Pass Improvement Project Effects on Traffic

As a result, Sunset Boulevard has become more congested over the past four years, reflected by increased stop-and-go traffic, slower travel speeds, and longer travel times. This is evidenced by a reduction in vehicle throughput (volumes) on Sunset Boulevard.

Traffic counts were obtained for the intersection of Sunset Boulevard and Barrington Avenue for three separate years: 2006, 2011, and 2014. Since traffic in the eastbound direction is more congested between 3:00 P.M. and 6:00 P.M., this topical response focuses on throughput for eastbound approach (traffic moving east on Sunset Boulevard towards Barrington Avenue) and departure (traffic moving east on Sunset past Barrington Avenue) traffic. As shown in Figure III-2 on page III-156, eastbound throughput for both approach and departure traffic dropped substantially in Year 2011 from Year 2006 levels due to congestion resulting from the I-405/Sepulveda Pass Improvement Project. As an example, the eastbound approach volume on Sunset Boulevard at Barrington Avenue dropped from 1,362 vehicles in 2006 (before the I-405/Sepulveda Pass Improvement Project) to 862 vehicles in 2011 in the 3:00 P.M. to 4:00 P.M. hour. The eastbound approach volume on Sunset Boulevard at Barrington Avenue dropped from 1,181 vehicles in 2006 to 488 vehicles in 2011 in the 5:00 P.M. to 6:00 P.M. hour. These reductions were not due to decreased demand, but because vehicles were gridlocked and, therefore, volumes were suppressed.

Construction of the I-405 Sepulveda Pass Improvement Project has temporarily increased congestion along certain residential streets, which has resulted in increased traffic volumes on some streets due to motorists avoiding Sunset Boulevard. This cut-through traffic includes use of Saltair Avenue to Chaparal Street to North Barrington Avenue and back to Sunset Boulevard. Figure III-3 on page III-157 shows a comparative chart of 24-hour traffic counts obtained from years 2009 and 2011 for Barrington Avenue between Chaparal Street and Sunset Boulevard. As shown in the exhibit, traffic on Barrington Avenue is significantly higher between the hours of 3:00 P.M. and 7:00 P.M. in 2011 compared to year 2009. This increase in traffic could be attributed to cut-through traffic from motorists attempting to avoid congestion on Sunset Boulevard, made worse in Year 2011 due to the construction of the I-405/Sepulveda Pass Improvement Project.

Improved Conditions with Completion of I-405 Sepulveda Pass Improvement Project

The I-405 Sepulveda Pass Improvement Project is currently anticipated to be completed by the end of 2014. With the I-405 Freeway construction activity nearing completion, the level of congestion is already moderating somewhat and is expected to improve further when the construction is complete. The recent opening of the new northbound carpool lane in May of 2014, completion of much of the construction (although City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-155 WORKING DRAFT – Not for Public Review FIGURE III-1 INTERSECTION VOLUME COMPARISON SUNSET BOULEVARD AT BARRINGTON AVENUE

Eastbound Approach Volume Eastbound Departure Volume Time Period 2006 2011 2014 Time Period 2006 2011 2014 3:00 - 4:00 PM 1362 862 1041 3:00 - 4:00 PM 1723 1316 1505 5:00 - 6:00 PM 1181 488 1029 5:00 - 6:00 PM 1501 984 1330

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Figure III-2 Barrington Avenue and Sunset Boulevard Eastbound Approach and Departure Peak Hour Volumes

Source: Fehr and Peers, 2014.     

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 12:00AM AM 1:00 AM 2:00 AM 3:00 AM 4:00 AM 5:00 AM 6:00 AM 7:00 AM 8:00 AM 9:00 10:00AM 11:00AM 12:00PM PM 1:00 PM 2:00 PM 3:00 PM 4:00 PM 5:00 PM 6:00 PM 7:00 PM 8:00 PM 9:00 10:00PM 11:00PM 12:00AM

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Figure III-3 24-Hour Traffic Volumes along Barrington Avenue

Source: Fehr and Peers, 2014. III.C Topical Responses not yet all) at the I-405/Sunset Boulevard interchange, and restoration of travel lanes available during the morning and evening peak period along most of the construction segment of I-405 Freeway has already resulted in a better flow of traffic along Sunset Boulevard and other major east-west thoroughfares such as Wilshire Boulevard, Santa Monica Boulevard, Olympic Boulevard, and the I-405 Freeway itself.

This is demonstrated in Figure III-2 on page III-156, which shows that eastbound vehicle throughput on Sunset Boulevard at Barrington Avenue has increased in the Fall of 2014 over Year 2011 levels, indicating improved traffic flow for vehicles traveling on Sunset Boulevard. The eastbound approach volume on Sunset Boulevard at Barrington Avenue increased from 862 vehicles in 2011 (in the midst of the I-405/Sepulveda Pass Improvement Project construction) to 1,041 vehicles in 2014 in the 3:00 P.M. to 4:00 P.M. hour, and from 488 vehicles in 2011 to 1,029 vehicles in 2014 in the 5:00 P.M. to 6:00 P.M. hour. While not fully back to pre-I-405 construction volume levels, this indicates that traffic movement on Sunset Boulevard is improving as I-405 construction activities are nearing completion.

In addition, travel speed data was obtained from INRIX (a mobile-GPS data provider for passenger and commercial vehicles) for vehicles traveling on the I-405 Freeway. Figure III-4 on page III-159 shows a comparison of travel speeds on the northbound I-405 from 2:00 P.M. to 8:00 P.M. observed on a typical weekday in the Fall of 2013 and in the Fall of 2014. The 2014 travel speed data was obtained after the northbound carpool lane on the I-405 Freeway was opened and construction at the I-405/Sunset Boulevard interchange was substantially complete. As shown in Figure III-4, northbound travel speeds on the I-405 freeway observed in the Fall of 2014 show considerable improvement over conditions in the Fall of 2013 during the afternoon peak period of traffic activity. Generally speaking, speeds are higher in the fall of 2014 than in the fall of 2013 across the day. Although speeds during the most congested hours in the middle of afternoon peak period are still slow (e.g., below 30 miles per hour [mph] on average between over a three hour period), the duration of the period of slow speeds has decreased substantially since, in 2013, average speeds were below 30 mph over a five-hour period. This result is expected since capacity increases on a freeway such as the new northbound carpool lane often offer benefit to the motoring public not because they eliminate congestion during the worst hours but because they shorten the duration of the peak period and enable more vehicles to move at higher speeds overall.

With the completion of the I-405/Sepulveda Pass Improvement Project and associated improvement of vehicle flow on Sunset Boulevard, it is expected that the number of vehicles on neighborhood streets would reduce as drivers return to their original routes on Sunset Boulevard and other east/west thoroughfares such as Wilshire Boulevard, Santa Monica Boulevard, Pico Boulevard, and Olympic Boulevard. Machine counts were

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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                                

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Figure III-4 I-405 Northbound Speed at Sunset Boulevard

Source: Fehr and Peers, 2014. III.C Topical Responses obtained in October 2014 for Barrington Avenue between Sunset Boulevard and Chaparal Street and for Chaparal Street between Barrington Avenue and Westgate Avenue. Figure III-5 and Figure III-6 on pages III-161 and III-162 illustrate the 2014 counts contrasted to counts conducted in 2011 in the midst of the I-405 Sepulveda Pass Improvement Project construction. Volumes on Barrington Avenue have declined substantially in the afternoon peak period, both in terms of magnitude and the length of the peak. Volumes of over 500 vehicles per hour (vph) were counted for two hours (3:00 P.M. to 5:00 P.M.) in 2011, with over 400 vph for another two hours (5:00 P.M. to 7:00 P.M.). In contrast, volumes exceeded 400 vph in two hours (3:00 P.M. to 5:00 P.M.) in 2014 and never exceeded 500 vph. Chaparal Street also featured a substantial reduction in travel. In 2011, volumes exceeded 200 vph for four hours in the afternoon (3:00 P.M. to 7:00 P.M.), whereas in 2014 volumes never exceeded 200 vph in any hour. Across the entire day, the counted volumes on Chaparal Street decreased from 1,424 in 2011 to 1,012 in 2014, a decline of almost 30 percent.

Closer inspection of the daily count volumes indicates that approximately 425 fewer vehicles were counted traveling eastbound on Chaparal Street and then southbound on Barrington Avenue during the five-hour period from 2:00 P.M. to 7:00 P.M. This, in combination with the increased throughput observed on Sunset Boulevard discussed previously, suggests that motorists using Chaparal Street to Barrington Avenue to avoid congestion on Sunset Boulevard during the I-405 Sepulveda Pass construction have moved back to Sunset Boulevard.

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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 12:00 AM AM 1:00 AM 2:00 AM 3:00 AM 4:00 AM 5:00 AM 6:00 AM 7:00 AM 8:00 AM 9:00 10:00 AM 11:00 AM 12:00 PM PM 1:00 PM 2:00 PM 3:00 PM 4:00 PM 5:00 PM 6:00 PM 7:00 PM 8:00 PM 9:00 10:00 PM 11:00 PM 12:00 AM

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Figure III-5 Comparison of 2011 and 2014 Traffic Volumes along Barrington Avenue between Sunset Boulevard and Chaparal Street

Source: Fehr and Peers, 2014.     

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 12:00 AM AM 1:00 AM 2:00 AM 3:00 AM 4:00 AM 5:00 AM 6:00 AM 7:00 AM 8:00 AM 9:00 10:00 AM 11:00 AM 12:00 PM PM 1:00 PM 2:00 PM 3:00 PM 4:00 PM 5:00 PM 6:00 PM 7:00 PM 8:00 PM 9:00 10:00 PM 11:00 PM 12:00 AM

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Figure III-6 Comparison of 2011 and 2014 Traffic Volumes along Chaparal Street between Westgate Avenue and Barrington Avenue

Source: Fehr and Peers, 2014.

III. Responses to Comments C. Topical Responses

11. Overview of Construction Refinements

Several comments on the Draft EIR raise concerns regarding Project-related impacts during construction. Most of these comments are related to the duration of construction and the potential air quality, noise, and traffic impacts associated with construction. In response to these comments, this topical response provides a general summary of the construction assumptions and the potential Project-related construction impacts associated with air quality, noise, and traffic set forth in the Draft EIR. This topical response also provides an overview of the proposal to reduce the construction schedule from a six-year timeframe to a five-year timeframe and the associated environmental implications of the reduced construction schedule. As set forth below, since the Draft EIR was based on conservative construction assumptions and the analyses accounted for concurrent construction activities, the reduced construction schedule would not result in an increase in impacts beyond those set forth in the Draft EIR.

As described in Section II, Project Description, of the Draft EIR, construction of the Project would be implemented in phases over six years commencing with the North Wing Renovation and followed by Phase 1 and Phase 2, each designed and timed to facilitate continued School operations on site and minimize disruptions to neighbors. Construction of Phase 1 would include the underground parking structure, athletic field, and the Multipurpose Facility. Construction of Phase 2 would begin with the Aquatics Center followed by the Visual Arts Center and the Performing Arts Center, or begin with construction of the Performing Arts Center followed by the Aquatics Center and the Visual Arts Center. The Draft EIR also stated that concurrent construction activities may occur, including overlap of the Phase 2 buildings and overlap of completion of the North Wing Renovation and excavation and haul activities associated with Phase 1.

The six-year development sequence and timeline described above was used as the basis for the construction period analyses provided in the Draft EIR. In addition, the Draft EIR also provided an analysis of potential construction impacts under an accelerated construction schedule during which Project construction activities could be concurrent and completed within a shorter time period. The specific assumptions used to evaluate

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-163 WORKING DRAFT – Not for Public Review III.C Topical Responses construction impacts for the six-year schedule and for an accelerated schedule are presented in detail in Appendix C of the Draft EIR.

As indicated above, in response to comments on the Draft EIR, the Applicant is proposing to reduce the construction period from six years to five years.8 The timeframe was reduced by working with the contractor to expedite the sequencing of construction activities and provide for more overlap of construction activities, particularly during Phase 2. It is noted that the reduced construction period from six years to five years (and the associated construction assumptions) is the currently proposed construction schedule and should be differentiated from the accelerated construction schedule evaluated in the Draft EIR. Provided below is an overview of the construction-related impact analyses evaluated in the Draft EIR as well as analyses of the construction-related air quality, noise, and traffic impacts under the reduced schedule. The analysis demonstrates how the reduced construction schedule would not result in an increase in significant impacts beyond those set forth in the Draft EIR.

Construction-Related Air Quality Impacts

Summary of Draft EIR Analysis

In accordance with the methodologies set forth by the South Coast Air Quality Management District (SCAQMD), construction impacts associated with the Project were evaluated based on peak daily construction activities. As set forth in Table IV-B-4 on page IV.B-35 of Section IV.B, Air Quality, of the Draft EIR, construction-related daily maximum regional construction emissions would not exceed the SCAQMD daily significance thresholds for VOC, CO, SOX, PM10, and PM2.5. However, based on the peak daily construction activities, maximum regional emissions would exceed the SCAQMD daily significance thresholds for NOX during periods of heavy construction equipment use. Thus, the Project would implement a number of mitigation measures that would reduce construction emissions for all pollutants. Refer to Mitigation Measures B-1 through B-9 of Section IV.B, Air Quality, of the Draft EIR. However, as shown in Table IV-B-13 on page IV.B-61 of Section IV.B, Air Quality, even with implementation of the proposed mitigation measures, regional construction emissions resulting from the Project would result in a significant and unavoidable short-term impact with regard to NOX. Regarding construction-related localized emissions, as shown in Table IV-B-14 on page IV.B-62 of Section IV.B, Air Quality, of the Draft EIR, with incorporation of mitigation measures, maximum localized construction emissions for off-site sensitive receptors would not exceed

8 Although not currently proposed, the accelerated construction schedule provisions set forth in the Draft EIR remains an option as part of the refined Project.

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-164 WORKING DRAFT – Not for Public Review III.C Topical Responses the localized screening thresholds for CO, NOX, PM10, and PM2.5. Therefore, Project-level localized construction emissions would result in a less than significant impact with incorporation of mitigation measures.

Toxic air contaminant (TAC) emissions during construction were also evaluated in Section IV.B, Air Quality of the Draft EIR and were determined to be less than significant. As set forth therein, the Project would yield a maximum incremental increase in off-site individual cancer risk of 9.1 in a million over the duration of construction and an excess cancer burden of 0.2, where the maximum impact occurs at residential uses directly northeast of the Project Site.9 The resulting chronic hazard index would be approximately 0.01 and is less than the SCAQMD significance threshold of 1.0.10 As the Project would not emit carcinogenic or toxic air contaminants that individually or collectively exceed the maximum individual cancer risk of ten in one million or result in an excess cancer burden of 0.5 or more, Project-related toxic emission impacts from construction activities would be less than significant and no mitigation would be required.

With compliance with SCAQMD rules and regulations, the Project would not be anticipated to generate a substantial amount of objectionable odor emissions during construction. As such, Project-level odor impacts would be less than significant.

Mitigation Measures and Supplemental Analysis Added in Final EIR

Based on review of public comments, additional mitigation measures were evaluated to determine if construction emissions of NOX from the Project could be feasibly reduced to less than significant levels. As provided in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, Mitigation Measure B-4 has been revised to require off-road diesel- powered equipment to meet Tier 3 standards during construction of the Project and to require front end loaders to be used for Phase 1—Excavation and Grading to meet California Air Resources Board Tier 4 Interim Standards (Title 13, CCR, Section 2423, Table 1b). Accordingly, Table IV.B-13, Project with Mitigation—Estimate of Regional Construction Emissions, and Table IV.B-14, Project with Mitigation—Estimate of Localized Construction Emissions, included in Section IV.B, Air Quality, of the Draft EIR were revised to account for the enhanced mitigation. Refer to Section II, Corrections and Additions to the Draft EIR, of this Final EIR, for the revised Table IV.B-13 and Table IV.B-14. As shown

9 Cancer burden is the estimated increase in the occurrence of cancer cases in a population as a result of exposure to TAC emissions. Cancer burden is calculated by multiplying the total population (in the zone of impact) greater than 1 in a million. 10 Please note that diesel particulate matter does not have an acute exposure endpoint and, therefore, the SCAQMD acute index threshold of 1.0 is not applicable.

City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-165 WORKING DRAFT – Not for Public Review III.C Topical Responses therein, the additional mitigation would reduce maximum regional construction NOX impacts to 95 pounds per day, which would be less than the SCAQMD’s 100 pound per day regional NOX significance threshold. It is noted that requiring the use of Tier 3 on-site construction equipment is also considered feasible and would serve to reduce overall exhaust emissions (e.g., diesel particulate matter (DPM), NOX, VOC, PM10 and PM2.5) from construction activities over the duration of construction. With implementation of this additional mitigation, both regional and localized construction impacts would be less than significant.

In response to comments on the Draft EIR, the health risk assessment included in the Draft EIR was also updated to evaluate each month of construction activity based on the peak daily construction activity for that month. While this additional analysis is not necessary for purposes of evaluating Project impacts, it is provided in this Final EIR for informational purposes. The updated analysis also incorporates Mitigation Measure B-4, as revised in this Final EIR. Mitigation Measure B-7, which minimizes exhaust emissions by requiring trucks and vehicles in loading and unloading queues to have their engines turned off after five minutes when not in use was also incorporated into the updated health risk assessment. The updated health risk assessment demonstrates that health risks from the Project would be 5.0 in a million for off-site receptors, which is below the applicable significance threshold described above. Refer to Appendix F-2 of this Final EIR for the updated health risk assessment.

Reduced Construction Schedule

As with the proposed six-year schedule, under a five-year construction schedule, the maximum daily impacts would occur during the mass excavation and export phase. The construction intensity (e.g., use of on-site equipment and export of material on a peak day) and the amount of mass excavation would not increase since both the reduced construction schedule and six-year schedule would be constrained to the period when school is not in session during the Summer. As the reduced construction schedule would not increase the use of on-site equipment or number of trips on a daily basis during this phase of construction, regional and localized impacts would similarly not increase. As a result, the maximum daily construction impacts presented in Section IV.B, Air Quality, of the Draft EIR, would also represent peak construction impacts under the reduced construction schedule. As noted above, these impacts would be less than significant with the additional mitigation measures included in this Final EIR. Refer to Section II, Corrections and Additions to the Draft EIR, of this Final EIR for the revised mitigation and updated Table IV.B-13, Project with Mitigation—Estimate of Regional Construction Emissions, and Table IV.B-14, Project with Mitigation—Estimate of Localized Construction Emissions.

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The six-year schedule assumed that Phase 2 construction would be constructed with the Aquatics Center and Visual Arts Center built sequentially with the Performing Arts Center. Thus, construction impacts under the reduced construction schedule could also be greater during other phases of construction due to the condensed timeframe for construction and associated increased intensity of construction activities. However, the Draft EIR also evaluated concurrent construction of the Aquatics Center/Visual Arts Center and Performing Arts Center, which would achieve the time constraint of the reduced construction schedule. These overlapping emissions were presented in Table IV.B-13, Project with Mitigation—Estimate of Regional Construction Emissions and Table IV.B-14, Project with Mitigation—Estimate of Localized Construction Emissions, of the Draft EIR. Refer to Section II, Corrections and Additions to the Draft EIR, of this Final EIR for the updated Table IV.B-13, Project with Mitigation—Estimate of Regional Construction Emissions, and Table IV.B-14, Project with Mitigation—Estimate of Localized Construction Emissions. As shown in these tables, maximum daily regional and localized impacts would be less than significant and less than the worst-case day (mass excavation and export phase) discussed above.

The health risk assessment presented in Section IV.B, Air Quality, of the Draft EIR accounted for concurrent construction activities, including concurrent construction of the Aquatics Center/Visual Arts Center and Performing Arts Center. In addition, the analysis in the Draft EIR used conservative emission factors. The updated health risk assessment included as Appendix F-2 of this Final EIR also used these conservative assumptions. Both analyses demonstrate that health risk impacts during construction would be less than significant. As the concurrent construction activities and daily construction equipment mix assumptions under the reduced schedule were accounted for in the health risk assessment, construction-related health risk impacts under the reduced construction schedule would continue to be less than significant.

Similar to the six-year construction schedule, the Applicant’s mandatory compliance with applicable SCAQMD rules and regulations (e.g., SCAQMD Rule 113) under the reduced construction schedule would result in no construction activities or materials that are proposed which would create objectionable odors.

Construction-Related Noise Impacts

Summary of Draft EIR Analysis

As analyzed in Section IV.I, Noise, of the Draft EIR, noise impacts from construction activities occurring within the Project Site would be a function of the noise generated by construction equipment, the location of the equipment, the timing and duration of the noise-generating construction activities, and the relative distance to noise-sensitive

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Page III-167 WORKING DRAFT – Not for Public Review III.C Topical Responses receptors. The analysis of construction noise impacts from on-site construction activities conservatively assumed worst-case conditions wherein the maximum amount of construction equipment was assumed to operate closest to each of the off-site receptors. As detailed in Section IV.I, Noise, of the Draft EIR, during each of the construction phases evaluated, sensitive receptors would experience construction noise levels in exceedance of the significance thresholds. Construction-related noise due to truck queuing would also exceed the significance thresholds at noise-sensitive uses. Noise levels from use of the Temporary Classroom Village would not exceed ambient noise levels at any of the noise- sensitive uses. The Project would implement a project design feature and a mitigation measure that would reduce construction noise. See page IV.I-31 of Section IV.I, Noise, of the Draft EIR for a discussion of Project Design Feature I-1 and pages IV.I-114 through IV.I-115 of Section IV.I, Noise, of the Draft EIR for a discussion of Mitigation Measure I-1. However, with the implementation of Mitigation Measure I-1 construction noise impacts related to on-site construction activities would continue to be significant and unavoidable.

In addition to on-site construction noise, construction vehicles (e.g., delivery trucks, cement mixer trucks, haul trucks, and construction worker vehicles) would generate noise along the proposed access routes to the Project Site. As analyzed in Section IV.I, Noise, of the Draft EIR, during weekday and weekend construction hours, noise levels due to construction traffic would exceed significance thresholds at certain representative receptors. Noise levels from construction workers departing between 6:00 P.M. to 7:00 P.M. would not exceed the significance threshold at any of the off-site sensitive receptors.

An evaluation of noise from all the Project’s construction noise sources (i.e., composite noise level) was conducted on pages IV.I-58 and IV.I-60 in Section IV.I, Noise, of the Draft EIR to conservatively ascertain the potential maximum Project-related noise level increase that may occur at the noise-sensitive receptor locations included in this analysis. Based on the estimated composite noise levels, noise levels may increase at off-site noise-sensitive receptors by up to 3 dBA. These composite noise levels would increase the worst-case impacts, but would not result in additional off-site noise-sensitive receptors being impacted by the Project’s construction.

As discussed on pages IV.I-60 through IV.I-70 in Section IV.I, Noise, of the Draft EIR, the Project would generate ground-borne on-site construction vibration during site demolition, excavation, and grading activities where heavy construction equipment, such as bulldozers and hoe rams, would be used. Construction vehicles would also generate ground-borne vibration as they travel along the haul route. The estimated vibration velocity levels from on-site construction activities and by haul trucks along the haul route would be below the significance threshold for building damage. Therefore, vibration impacts associated with potential building damage during on- and off-site construction activities

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Reduced Construction Schedule

The on-site construction noise impacts under the five-year construction schedule would be similar to the Project’s on-site construction noise impacts summarized above and evaluated in detail in Section IV.I, Noise of the Draft EIR. Specifically, the number and types of on-site construction equipment under the reduced construction schedule would be similar to the on-site construction equipment evaluated in the Draft EIR. In addition, the construction hours under the reduced construction schedule would not extend beyond the timeframes evaluated in the Draft EIR. Furthermore, as discussed above, the analysis of on-site construction noise conservatively assumed worst-case conditions wherein the maximum amount of construction equipment was assumed to operate closest to each of the off-site receptors. Therefore, the noise impacts from the reduced construction schedule during the peak construction period would be similar to the levels in the Draft EIR. Nevertheless, consistent with the conclusions reached in the Draft EIR, even with implementation of mitigation measures, noise impacts from on-site construction activities would be temporary and would remain significant and unavoidable.

The internal construction access, number of construction trucks and hours of construction activities evaluated under the reduced construction schedule would be similar to that set forth in the Draft EIR. Thus, the noise impacts from truck queuing under the reduced construction schedule are anticipated to be similar to the Project’s queuing impacts and would result in significant noise impacts.

Under the five year construction schedule the Temporary Classroom Village would be constructed on the athletic field in the same location identified in the Draft EIR. Thus, the estimated noise levels associated with use of the Temporary Classroom Village shown in Table IV.I-21 on page IV.I-57 of the Draft EIR would not change. Such impacts would continue to be less than significant.

The construction haul routes, number of construction-related trips (vendor/haul/ concrete trucks and worker vehicles), and construction hours under the reduced construction schedule would be similar to the Project. Therefore, the off-site construction noise levels under the reduced construction schedule would be similar to as the noise levels provided in Section IV.I, Noise, of the Draft EIR. As summarized above and set forth in the Draft EIR, during weekday and weekend construction hours, noise levels due to construction traffic would exceed significance thresholds at certain representative receptors. The less than significant impact associated with noise levels from construction workers departing between 6:00 P.M. to 7:00 P.M. would remain.

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As discussed above, the peak construction equipment mix, internal construction access, and hours of construction activities evaluated under the reduced construction schedule would be similar to that set forth in the Draft EIR. Thus, the composite noise level impacts under the reduced construction schedule would be similar to the composite noise level impacts analyzed in Section IV.I Noise of the Draft EIR. As discussed therein, the composite construction noise levels, which include on-site construction equipment, truck queuing, off-site construction vehicles, and students in the Temporary Classroom Village, may increase the noise levels at off-site noise-sensitive receptors by up to 3 dBA. These composite noise levels would increase the worst-case impacts, but would not result in additional off-site noise-sensitive receptors being impacted by the Project’s construction.

With regard to construction vibration, as discussed above, the peak construction equipment mix and hours of construction under the reduced schedule would be similar to that set forth in the Draft EIR. Therefore, the on-site and off-site vibration impacts under the reduced construction schedule are expected to be similar to the Project’s vibration impacts, which are provided in Table IV.I-27 through Table IV.I-29 on pages IV.I-68 through IV.I-70 of the Draft EIR. As indicated therein, vibration impacts with respect to potential building damage from on- and off-site construction activities would be less than significant. However, vibration impacts with respect to human annoyance from on- and off-site construction activities would be significant (similar to the Project).

Construction-Related Traffic, Access, and Parking Impacts

Summary of Draft EIR Analysis

As discussed in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, while the impact on the transportation system from construction activities would be temporary in nature, Project construction would result in a reduction in street and intersection operating capacity to adjacent uses near the Project Site. To reduce potential traffic impacts related to construction traffic, Archer would implement Mitigation Measure K-4, a Worksite Traffic Control Plan, and Mitigation Measure K-5, a Traffic Management Plan, which would help to minimize the amount and effect of peak-hour construction traffic. However, temporary traffic impacts at the study intersections and street segments identified would remain and such impacts would be considered significant and unavoidable.

Construction of the Project would primarily be contained within the boundaries of the Project Site and would not affect the adjacent street system beyond the traffic impacts discussed above. However, Project development along Barrington Avenue may result in temporary sidewalk closures to accommodate truck traffic or construction within the Barrington Parcel. Such temporary impacts would be considered significant. However,

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An adequate number of parking spaces for students, employees, and guests of Archer, and construction workers would be available at all times during construction either on the Project Site or in nearby off-site locations with shuttles provided to and from the Project Site. Therefore, Project construction would not result in a significant impact with regard to the availability of parking spaces.

Project construction would not necessitate the relocation or removal of transit stops located near the Project Site or generate a substantial number of transit trips. As such, Project development would not result in significant impacts on transit access.

Reduced Construction Schedule

Under the reduced construction schedule, the maximum construction trips generated during all analyzed time periods, the haul routes and the staging areas would be similar to the maximum trips, haul routes and staging areas evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR. While the maximum construction trips may occur on more days than expected under the six-year schedule, the maximum construction traffic impacts on a given day would be similar to that set forth in the Draft EIR. Thus, as set forth in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, even with implementation of Mitigation Measure K-4, a Worksite Traffic Control Plan, and Mitigation Measure K-5, a Traffic Management Plan, construction-related intersection impacts at the study intersections and street segments identified would continue to be significant and unavoidable.

With regard to access, as with the Project as evaluated in the Draft EIR, construction of the Project under the reduced construction schedule would primarily be contained within the boundaries of the Project Site and would not affect the adjacent street system beyond the traffic impacts discussed above. Also similar to the Project as evaluated in the Draft EIR, under the reduced construction schedule, Project development along Barrington Avenue may result in temporary sidewalk closures to accommodate truck traffic or construction within the Barrington Parcel. However, with implementation of the Mitigation Measures K-4 through K-12 of Section IV.K, Traffic, Access, and Parking, such temporary adverse impacts to access and circulation would be reduced to a less-than-significant level. Similar to the assumptions evaluated in the Draft EIR for the six-year construction schedule, under the reduced construction schedule, parking for Archer staff, faculty, and students, as well as construction workers, would be provided off-site during the majority of the reduced construction schedule. The potential locations of the off-site parking are not currently known and would depend on market conditions and availability of parking supply

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Page III-171 WORKING DRAFT – Not for Public Review III.C Topical Responses at the time of construction. Options for off-site parking facilities could include the surface parking lot south of Sunset Boulevard at Barrington Village or private parking lots along San Vicente Boulevard and Wilshire Boulevard. During construction when School parking is off-site, Archer may provide a shuttle to facilitate access to and from the designated parking location. Upon completion of the underground parking structure, employees, students, and guests would be able to park on-site. As an adequate number of parking spaces for students, employees, and guests of Archer, and construction workers would be available at all times during construction either on the Project Site or in nearby off-site locations with shuttles provided to and from the Project Site under the reduced construction schedule, impacts associated with parking during construction would be less than significant. Under the reduced construction schedule, Project construction would not necessitate the relocation or removal of transit stops located near the Project Site, or generate a substantial number of transit trips. As such, as concluded in the Draft EIR, development of the Project under the reduced construction schedule would not result in significant impacts on transit access.

Also refer to Topical Response No. 6, Overview of Construction Traffic and Parking, above for additional information regarding traffic and parking during construction.

Conclusion

Based on the above, under the reduced construction schedule there are no new significant environmental impacts to air quality, noise, and traffic or increases in the severity of any of the significant environmental impacts identified in the Draft EIR. Rather, with the reduced construction schedule, while days with maximum construction impacts may occur more often than under the six-year schedule, the entire duration of potential construction impacts to air quality, noise, and traffic would occur for a shorter period.

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III. Responses to Comments C. Topical Responses

12. Site Plan Consistency with the Residential Scale and Character of the Neighborhood

Certain comments on the Draft EIR stated concerns that the Project would not be consistent with the scale and character of the neighborhood. As described in detail in Section II, Project Description, Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, and Section IV.H, Land Use, of the Draft EIR, the Project has been designed to respond to the residential scale and character of the surrounding area. In addition, as described in detail below, in response to comments on the Draft EIR, refinements have been made to the site plan for additional consistency with the residential scale and character of the neighborhood. These refinements include reducing the square footage and massing, width, and length of some of the proposed buildings, and creating expanded landscape buffers.

Overview of Site Plan

As described in Section II, Project Description, of the Draft EIR, the Project consists of improvements to the existing Archer campus. The Project Site comprises approximately 7.31 acres. The existing Archer campus is approximately 6.2 acres and includes the Main Building, outdoor athletic field, surface parking, and associated landscaped plazas, courtyards, and pedestrian paths. The remainder of the Project Site is comprises two adjacent properties currently owned by Archer that comprise approximately 1.1 acres: 11728 Chaparal Street (referred to as the Chaparal Parcel) and 141 North Barrington Avenue (referred to as the Barrington Parcel). Refer to Topical Response No. 13, Use of Existing Residential Properties, for additional discussion on the use of residential properties for school uses.

The Project proposes to replace the existing North Wing of the Main Building with a new North Wing that would provide upgraded classrooms and improved lighting, air conditioning, and information technologies (North Wing Renovation). The Project, as described in the Draft EIR, also proposed the development of new athletic, performing arts,

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The existing outdoor athletic field would be improved and would include regulation- size soccer and softball fields. Parking is proposed in a new underground parking structure within the western portion of the campus. The Project also includes associated landscaped plazas, courtyards, and pedestrian paths.

The Project as described in the Draft EIR incorporated project design features and mitigation measures to ensure that the Project would be consistent with the residential scale and character of the surrounding area. As described in Sections IV.A, Aesthetics/ Visual Quality, Views, Light/Glare, and Shading, and IV.H, Land Use, of the Draft EIR, the Project has been designed to create a visually unified campus with new buildings designed to complement the historic Main Building and respond to the residential scale of the surrounding area. Specifically, the new school buildings would be proportioned to modulate height and maintain the residential street character when viewed from Chaparal Street and Barrington Avenue. The Project has also been designed to limit views of the new facilities from Sunset Boulevard, minimize building footprints, and maximize green space within the campus. Additionally, the buildings have been designed to shield neighbors from internal campus activities and noise.

Project Refinements in Response to Comments

In response to comments, refinements to the site plan are proposed including reducing the square footage and massing, width, and length of some of the proposed buildings, reducing the number of parking spaces, and creating expanded landscape buffers.

As summarized in Table II-2 of Section II, Project Description, of the Draft EIR, the Project proposed 75,930 square feet of net new floor area. In response to comments on the Draft EIR, the square footage of several buildings has been reduced. Specifically, the North Wing Renovation is proposed to be reduced from 39,071 square feet to 30,400 square feet. The Multipurpose Facility is proposed to be reduced from 41,400 square feet to 39,330 square feet. The Performing Arts Center is proposed to be reduced from 22,600 square feet to 19,025 square feet with a reduction in seating from 650 seats to 395 seats. As described in Topical Response No. 4, Additional Measures to Reduce Noise, in response to comments to reduce noise from the use of the pool, the

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Project would fully enclose the pool within the proposed Aquatics Center. Enclosing the pool within the Aquatics Center would increase the square footage of the Aquatics Center from 2,300 square feet to 9,675 square feet. Overall, when accounting for the uses proposed to be removed, which total approximately 36,841 square feet, the Project’s net new floor area would be reduced from 75,930 square feet to 68,989 square feet. The reduction in square footage would reduce the massing, width, and length of the Multipurpose Facility and the Performing Arts Center.

Regarding the Barrington and Chaparal Parcels, in response to comments, the Performing Arts Center would be relocated to the Chaparal Parcel and the Aquatics Center and Visual Arts Center would be relocated to the Barrington Parcel. As illustrated in Figure II-X in Section II, Corrections and Additions, of this Final EIR, the Visual Arts Center would be developed along the western portion of the Barrington Parcel, just east of the North Wing, and the Aquatics Center would be developed along the eastern portion of the Barrington Parcel. Relocating the Performing Arts Center, Aquatics Center, and Visual Arts Center in this way allows the Project to better modulate the scale and character of the surrounding residential neighborhood. For example, relocating the Performing Arts Center to the Chaparal Parcel allows the Performing Arts Center to be placed partially below grade, better screen the building with landscaping, and satisfy setback requirements. Due to the elevations on the Project Site, the Performing Arts Center thus appears to have a reduced height when viewed from public right of ways if it is located on the Chaparal Parcel than it would if it was located on the Barrington Parcel. Moving the lower Aquatics Center and Visual Arts Center to the Barrington Parcel reduces the Project’s height and massing along Barrington Avenue and reduces visual impacts to adjacent uses to the south of the Barrington Parcel.

As described on page II-28 and Figure II-8 on page II-29 of Section II, Project Description, of the Draft EIR, new landscaping and landscaped gardens, courtyards, plazas, and walkways would be located throughout the Project Site. In response to comments, additional landscaping from that described in the Draft EIR would be provided as described in greater detail below.

As discussed in Topical Response No. 2, Removal of Athletic Field Lighting and Refinements to Lighting, in response to comments on the Draft EIR, the athletic field lighting has been removed from the Project.

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Site Plan Consistency with the Residential Scale and Character of the Neighborhood

Description of Surrounding Neighborhood

As described in Section II, Project Description, of the Draft EIR, the Project Site is generally bounded by Chaparal Street to the north, Sunset Boulevard to the south, Barrington Avenue and residential uses to the east, and residential uses to the west. As described in Section III, Environmental Setting, of the Draft EIR, the Project Site is located within an urban area that is developed with residential, educational, and commercial uses. Single family-residential uses are located to the north, single- and multi-family residential uses and commercial uses are located to the south, and single- and multi-family residential uses are located to the east and west. Additional information regarding the character of specific streets surrounding the Project Site is provided below.

Sunset Boulevard

As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, Sunset Boulevard is a Class II major highway and runs along the southern boundary of the Project Site. In the vicinity of the Project Site, Sunset Boulevard provides two through lanes in each direction. Along the southern boundary of the Project Site, Sunset Boulevard includes a mature network of pedestrian facilities including sidewalks, crosswalks, and pedestrian safety features such as crosswalk lights and controls. Adjacent to the Project Site, approximately 5 feet of sidewalk is provided on the northern side of Sunset Boulevard.

The main entrance to the Archer campus is located on Sunset Boulevard. As shown in Figure IV.A-1 on page IV.A-10 of the Draft EIR, existing views of the Project Site along Sunset Boulevard are dominated by the historic Main Building and the various shrubs and trees surrounding the perimeter of the campus.

On the south side of Sunset Boulevard, directly across from Archer’s front lawn, are several three and four-story multi-family buildings built between 1965 and 1996. These are flat-roofed multi-unit buildings of varying architectural style, ranging from classically themed stucco structures with projecting balconies and painted metal railings to more contemporary buildings surfaced with brick veneer and smooth plaster finishes.

On the north side of Sunset Boulevard to the west of the Project Site are three multi- family buildings built between 1951 and 1977 that range in size from two or four stories. The two easternmost buildings are predominantly flat-roofed structures finished with colored plaster and/or brick veneer. The westernmost building is a two-story plaster structure with a gabled tile roof.

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On the north side of Sunset Boulevard to the east of the Project Site is a multi-family building built in 1953 consisting of two stories of apartments over a carport. This building is a plaster structure with gabled roof forms covered with asphalt shingles.

Chaparal Street

Chaparal Street between Westgate Avenue and Barrington Avenue is approximately 22 feet in width with 19-foot-wide pedestrian rights-of-way on both sides of the street. It is lined by a variety of large one- and two-story single family residences along its north side. Along its south side is a continuous landscaped pedestrian right-of-way, as illustrated in Figure IV.A-2 included in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR.

The residences along the north side of Chaparal Street vary in architectural style and scale from contemporary wood-clad, single-story, flat-roofed structures to two-story, classically-themed buildings with plaster finishes and sloping tile roofs. The residences sited directly across from the Project Site are located behind walls and gates and are mostly screened from public view behind mature landscaping, as shown in Figure IV.A-5 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. The south side of Chaparal Street includes a 19-foot-wide pedestrian right-of-way along the existing campus, which comprises approximately 600 feet of the block’s approximately 1,000-foot length. The pedestrian right-of-way consists of a decomposed granite foot path with grass on either side adjacent to a continuous ivy covered wall approximately 8 feet in height. A row of Canary Island Pine trees, varying from 25 to 35 feet in height and 9 to 12 feet in width, runs the length of the foot path. See Figure IV.A-2 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR.

According to survey data collected by Hennon Survey & Mapping Inc. for the ALTA/ ACSM Land Title Survey of 11725 Sunset Boulevard for The Archer School for Girls (dated September 12, 2012), residences located along Chaparal Street across the street from or next to the Project Site range in height from approximately 16.1 feet (11731 Chaparal Street) to approximately 33.9 feet (11840 Chaparal Street).

As shown in Figure IV.A-2 on page IV.A-11 of the Draft EIR, existing views of the campus along Chaparal Street consist primarily of the continuous vine-covered solid cinderblock wall and wrought iron gate, and the adjacent pedestrian walkway lined by a row of Canary Island pine trees. Also visible are a few on-site trees, several power poles, overhead power/telephone lines and some pole-mounted light fixtures that can be seen over the top of the wall. As illustrated in Figure IV.A-3 on page IV.A-12, views of the residence on the Chaparal Parcel are available along Chaparal Street. City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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Barrington Avenue

As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, Barrington Avenue is a local street north of Sunset Boulevard bordering the eastern edge of the Project Site. Barrington Avenue provides one through lane in each direction. Barrington Avenue is approximately 40 feet in width with continuous curbs on both sides and a 4-foot wide sidewalk along the west. Barrington Avenue runs uphill in a northerly direction from Sunset Boulevard and curves to the east for half of the block before resuming its northerly direction near Chaparal Street.

At the northwest corner of the intersection of Sunset Boulevard and Barrington Avenue is 11707 Sunset Boulevard (the Sunset Villa Apartments), which is approximately 32.7 feet in height. The building is a simple plaster building with gabled roof forms covered with asphalt shingles. It includes two floors of multi-family residences over street-level car ports that open directly onto Barrington Avenue. An additional multi-family building located at 125 Barrington Avenue is situated immediately north of the Sunset Villa Apartments on Barrington Avenue and is four stories (43.3 feet) in height when including the street-level parking garage. The building is a flat-roofed structure with open balconies facing the street and provides a variety of white plaster site walls and landscaped planting areas adjacent to its pedestrian and vehicular entryways at the sidewalk level, as illustrated in Figure IV.A-4 and IV.A-15 included in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. The balance of the west side of the block comprises two single- family residential buildings. The first building, located at 141 Barrington Avenue, is the single-story, ranch-style structure owned by Archer sited on an uphill lot (Barrington Parcel) with a curving asphalt driveway, as shown in Figure IV.A-3 in Section IV.A, Aesthetics/ Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. The second single-family building located on the west side of Barrington Avenue, with a street address of 11706 Chaparal Street, is a larger, two-story structure (31.7 feet in height) fronting Chaparal Street, mostly screened from view along Barrington Avenue behind densely planted mature landscaping.

Three parcels border the Barrington Parcel to the north: the Chaparal Parcel, which is owned by Archer and part of the Project Site; 11718 Chaparal Street, which contains a residential structure approximately 30.2 feet in height; and 11706 Chaparal Street, described above. The rear yards of 11718 Chaparal Street and 11706 Chaparal Street are truncated by a retaining wall and property fencing located between 8 and 13 feet from the northern Barrington Parcel property line, increasing the actual distance between development on the Barrington Parcel and adjacent residential uses.

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The east side of Barrington Avenue consists of a variety of two-story single-family residences that include contemporary wood-clad structures, as well as classically themed buildings with plaster finishes and sloping tile roofs. Several of these residences are located behind site walls and gates and screened from public view behind trees and/or tall hedges.

Western Chaparal Street/Westgate Avenue

Single- and multi-family residential uses are located to the west of the Project Site. Four single-family residences are located adjacent to the western edge of the existing athletic field: 11840 Chaparal Street, 11844 Chaparal Street, 134 N. Westgate Avenue, and 130 N. Westgate Avenue. These residences range in height from approximately 18.1 feet (134 N. Westgate Avenue) to 33.9 feet (11840 Chaparal Street). Several of these residences are located behind walls or gates and are screened from public view behind trees and/or landscaping.

Site Plan Features Intended to Address Community Consistency

Floor Area

The total floor area on the Project Site as a whole is considerably below the maximum density that is permitted on the Project Site. The existing campus and two adjacent properties contain approximately 90,948 square feet of enclosed floor area. The Project, as refined in response to comments, would result in the addition of 68,989 square feet of net new floor area. Upon full build-out of the Project, the School would comprise approximately 159,937 square feet. At build out, the Project’s floor area would comprise approximately 22 percent of the total allowable floor area.

Open Space

The Project’s landscaped open space would further the objective of preserving open space to balance development. The Project has been intentionally designed to minimize building footprints and increase green space within the campus. At buildout, approximately 72 percent of Archer’s campus (approximately 222,698 square feet) would be open space. To increase green space, the lower level of the Multipurpose Facility would be located below grade. In addition, portions of the Performing Arts Center would be below grade. Parking would be provided in the underground parking structure. By placing these portions of the Project underground, the Project would maintain additional ground level outdoor space. This open space would include the athletic field, new landscaping and landscaped gardens, courtyards, plazas, and pedestrian paths.

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The Project has also been designed to maintain the residential character and open space along Chaparal Street. The Project Site has approximately 710 feet of frontage along Chaparal Street. The Project, as refined in response to comments, would maintain approximately 457 feet, or 64 percent, of the frontage along Chaparal Street as open space (i.e., no buildings would be located along 64 percent of the street frontage).

Front Yards

The Project would have 25-foot front yards along Chaparal Street and Barrington Avenue, in compliance with residential front yard requirements.

The Project is seeking a Zoning Administrator’s Adjustment pursuant to LAMC Section 12.28 to permit fences/gates/walls up to 8 feet in height within the required front yards along Chaparal Street and Barrington Avenue in lieu of the 3.5 feet otherwise permitted in the front yard. These fences would be installed in furtherance of Project Design Feature J.2-4, which states that the Project shall include the installation of new security fences and an emergency alert system. The wall along Chaparal Street would be an extension of the existing wall, and the fence along Barrington Avenue would be a landscaped architectural wall. The fences and walls would be landscaped and provide a buffer for the benefit of nearby properties, further protecting compatibility with the scale and character of the surrounding residential neighborhood. The fences and walls would enhance safety and security for the School without negatively affecting views or the surrounding residential character.

Side Yards

The Project would substantially comply with side yard requirements. As described on page IV.H-51 of Section IV.H, Land Use, of the Draft EIR, pursuant to the LAMC, the required combined width of the two side yards along Chaparal Street would be 50 feet. Pursuant to the LAMC, the required combined width of the two side yards along Barrington Avenue is 40 feet. It is important to note that pursuant to the LAMC, if the lots were being developed with a single-family residence the required side yard would only be 5 feet. The School proposes to satisfy the 50-foot requirement along Chaparal Street with a 35-foot side yard along the western side yard and a 15-foot side yard along the eastern side yard. On the Barrington Parcel, along the south, the Aquatics Center and Visual Arts Center are proposed to be set back approximately 20 feet from the property line. As noted above, in response to comments on the Draft EIR, the pool has been fully enclosed within the Aquatics Center to reduce noise from the pool. Due to the enclosure of the Aquatics Center, there would be no side yard along the northern property line at the Barrington Parcel. As such, the School is requesting relief from LAMC Section 12.21.C.3.b to allow

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Page III-180 WORKING DRAFT – Not for Public Review III.C Topical Responses this along the north side yards. As described above, three parcels border the Barrington Parcel to the north: the Chaparal Parcel, which is owned by Archer and part of the Project Site; 11718 Chaparal Street; and 11706 Chaparal Street. The rear yards of 11718 Chaparal Street and 11706 Chaparal Street are truncated by a retaining wall and property fencing located between 8 and 13 feet from the northern Barrington Parcel property line, increasing the actual distance between development on the Barrington Parcel and adjacent residential uses. Finally, the Project would comply with side yard requirements with respect to the boundary between the Barrington Parcel and 11706 Chaparal Street, as the Project would not result in development within 20 feet of the 11706 Chaparal Street property line. The Aquatics Center would be located 24 feet 3 inches from the 11706 Chaparal Street property line.

Views of the Campus

As described in detail in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, the Project would create a visually unified campus with new buildings designed to respond to the residential scale and character of the surrounding area. The new School buildings would be proportioned to modulate the height and maintain the residential street scale and character when viewed from Chaparal Street and Barrington Avenue. In addition, the Project would continue the existing building material and color palette to further integrate the new buildings within the campus and neighboring uses. The Project would also preserve the historic Main Building and would not remove existing features or elements that contribute positively to the visual character of the surrounding area. Therefore, impacts related to aesthetics/visual quality would be less than significant. Moreover, as described in detail in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, while portions of Project development would be visible from off-site locations, view changes would typically occur at limited vantage points, as opposed to along extensive roadway segments or from entire large geographic areas. Further, the Project would not affect views from a designated scenic highway, corridor, or parkway.

Residential properties that currently have views into the interior of Archer’s campus may continue to have views of campus. Views of the campus from private residences would be maintained and potentially enhanced with a continuation in the openness provided by the athletic field, the removal of the existing west surface parking lot, and the implementation of additional landscaping. In response to comments, the planting area between the southern edge of the underground parking structure and the property line would be increased from 7 feet 10 inches to 22 feet to accommodate an expanded landscape buffer that would enhance the views from neighboring multi-family residential buildings to the south and eliminate views of parked cars. Similarly, it is expected that

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Page III-181 WORKING DRAFT – Not for Public Review III.C Topical Responses private views from the residences to the north of the Barrington Parcel would be limited given the lower elevation within the Barrington Parcel and the dense, mature landscaping between the residences and the Barrington Parcel. Furthermore, while views of the campus from adjacent residences to the west and north would be altered with the introduction of new school-related buildings and athletic facilities, new school buildings would feature architectural treatments to integrate the new buildings into the existing campus and be compatible with the existing Main Building. In addition, existing, mature vegetation along the western boundary of the campus would continue to buffer the residences from campus activities and obscure views of the adjacent athletic field and related amenities from lower levels. Proposed additional landscaping along the western property boundary and along Chaparal Street would further buffer the proposed uses from the surrounding residential streets. As such, on an overall basis, the Project would not obstruct an existing valued view, and view impacts would be less than significant.

The Project has been designed to limit views of the new facilities from Sunset Boulevard. Specifically, as the Project does not propose development within the southern portion of the Project Site, along Sunset Boulevard, north-facing views of the Project Site from Sunset Boulevard would be largely preserved. In particular, the new North Wing, the Multipurpose Facility, the Performing Arts Center, the Visual Arts Center, and the Aquatics Center would not be visible from Sunset Boulevard as they would be obscured by the existing Main Building. In addition, the proposed improvements to the existing circular driveway, which would improve site access and allow for dedicated right- and left-turn lanes at the existing exit to Sunset Boulevard, would not affect existing views of the historic Main Building or along Sunset Boulevard. Furthermore, while the two new wall signs proposed to be mounted to concrete walls on either side of the east entry driveway along Sunset Boulevard and the relocated guard booth would result in a change in the views of this entry driveway compared to existing conditions, the proposed wall signs and guard booth would not dominate the viewshed and, as evaluated in Section IV.D, Cultural Resources, of the Draft EIR, would be compatible in size, scale, and materials with the historic architecture of the Main Building.

Southerly views of the Project along Chaparal Street are depicted in Figure IV.A-18 through Figure IV.A-22 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. As shown therein, while portions of the Project would be visible along breaks in landscaping, the Project would not dominate views along Chaparal Street. In addition, the Project would include architectural features to maintain the residential scale and character along Chaparal Street, including designing buildings with roof heights consistent with those of adjacent neighbors, providing setbacks of the upper portion of each building to further relieve the impression of height near the street edge, and using materials consistent with other neighboring structures and the historic Main Building. City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

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While the Barrington Parcel is largely hidden from public view by an apartment building on the south and a densely landscaped residential property on the north, as illustrated in Figure IV.A-15 and IV.A-16 included in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, the facilities proposed within the Barrington Parcel would be visible to pedestrians and motorists as illustrated in Figure IV.A-15 through Figure IV.A-17 in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. However, as described in greater detail below, the Project would implement architectural features to maintain the residential scale and character along Barrington Street.

Also refer to Section II, Corrections and Additions to the Draft EIR, of this Final EIR for the revised renderings included in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR.

Scale and Design Details Along Residential Streets

Chaparal Street

The Project has been designed to maintain the residential character along Chaparal Street. The proposed School buildings meet residential front yard setback requirements along Chaparal Street. The buildings would have a stepped profile and would be located behind 8-foot walls covered in vines and continuous landscaping to effectively reduce the massing of the buildings along Chaparal Street with only portions of the buildings being visible along breaks in the landscaping.

As noted above, the existing tree-lined right-of-way along the south side of Chaparal Street would be enhanced by adding trees to both sides of the existing site wall and extending the right-of-way an additional 110 feet eastward along the north side of the proposed Performing Arts Center. The additional landscaping along Chaparal Street would effectively screen the massing of the Multipurpose Facility and the Performing Arts Center with only portions of the buildings being visible along breaks in the landscaping. Therefore, the Multipurpose Facility and the Performing Arts Center would not represent a substantial contrast compared to the existing visual character along Chaparal Street particularly given the presence of large one- and two-story single family residences along Chaparal Street, many of which are also located behind fences, gates, hedges, or tall landscaping and are only visible through breaks in landscaping. Additionally, no new driveways would be added along Chaparal Street for access to the Project Site and, consistent with existing conditions, a single access gate along Chaparal Street would be maintained and would be used for emergency vehicle access and limited service and delivery vehicle access.

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The following provides additional detail on how the design strategies described above have been applied specifically to the Multipurpose Facility and the Performing Arts Center.

Multipurpose Facility

As discussed above, the Project, as set forth in the Draft EIR, proposed a 41,400-square-foot Multipurpose Facility. In response to comments on the Draft EIR, the Multipurpose Facility is proposed to be reduced to 39,330 square feet. As described on page II-22 of the Draft EIR, the Multipurpose Facility would comprise two general levels. To maximize open space and minimize the size of the building, the lower level would be located below grade and partially open to the sunken North Garden to the west. Approximately 19,950 square feet, or about half, of the floor area of the Multipurpose Facility would be above grade. As described above, the Multipurpose Facility would be set back 25 feet from the property line at Chaparal Street, in compliance with residential requirements. The Multipurpose Facility would be located over 400 feet from the nearest single-family residence to the west and over 145 feet from the nearest single-family residence to the east. Residences to the north, directly across Chaparal Street from proposed buildings, are set back approximately 55 feet from the north edge of the street (approximately 95 feet from the northern edge of campus, and 120 feet from proposed campus buildings) and behind a row of mature landscaping over 40 feet in height.

At its highest point, the Multipurpose Facility would be 36 feet tall. As described on page IV.H-22 of the Draft EIR, the Project is requesting a modification of the height regulations pursuant to LAMC Section 12.24F for the height of the Multipurpose Facility, which would have a roof slope of less than 25 percent and would be taller than the required maximum height of 30 feet. Notwithstanding, due to changes in elevation, the height of the Multipurpose Facility would measure and would visually appear as approximately 28 feet in height from public ways along Chaparal Street. This height is generally consistent with the heights of adjacent residences along Chaparal Street, which, as described above, range in height from approximately 16.1 feet up to approximately 33.9 feet. Therefore, the Multipurpose Facility would be consistent with the scale and character envisioned for the surrounding residential neighborhood.

To further reduce the impression of height along Chaparal Street, the upper seven feet of the Multipurpose Facility has been set back an additional six feet nine inches from the property line, creating a stepped profile along the full length of the north side of the building. Thus, at a distance of 25 feet from the property line along Chaparal Street, the height of the Multipurpose Facility would be approximately 21 feet. At a distance of 31 feet nine inches from the property line along Chaparal Street, the height of the upper portion of

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Page III-184 WORKING DRAFT – Not for Public Review III.C Topical Responses the “top step” of the Multipurpose Facility would increase to approximately 28 feet from its adjacent grade. This design feature limits the height of the north wall of the Multipurpose Facility along Chaparal Street.

The Multipurpose Facility has been designed with simple lines to present a profile that complements the clean linear character of the existing site wall and right-of-way. Smooth, lightly colored plaster walls would be consistent with Archer’s historic Main Building and adjacent residences and would help unify the building with its neighborhood context. Along the Chaparal Street elevation, architectural relief would modulate the exterior wall surface to avoid a monolithic appearance.

To reduce noise to adjacent residential properties, the main entry to the Multipurpose Facility would be located on the south side of the building, opposite Chaparal Street, facing the Court of Leaders. Entries also are provided below grade from the North Garden on the west side of the building to allow users to enter from the underground parking structure. As described in Section II, Project Description, of the Draft EIR, the North Garden would provide a safe, protected, transitional space for students and guests to move to and from the campus and the parking structure; deliver a primary source of natural ventilation to the adjacent parking structure minimizing the need for energy-consuming and audible mechanical equipment; and provide daylight to the lower-level gymnasium in the Multipurpose Facility. Further, as described in Section IV.I, Noise, of the Draft EIR, the design of the North Garden below the campus grade would effectively control sounds within this space. Specifically, the surrounding buildings, underground parking structure, and the walls surrounding the North Garden would serve as barriers that would deflect sounds before reaching nearby sensitive receptors. In addition, as described in further detail below, to reduce noise from internal campus activities, there would be no operable windows along the west, north, or east elevations of the Multipurpose Facility.

Performing Arts Center

As discussed above, the Performing Arts Center, as described in the Draft EIR, included a 22,600-square-foot facility consisting of two stories over a basement level providing maximum seating capacity for 650 spectators and sited on the Barrington Parcel. In response to comments on the Draft EIR and to provide further consistency with the scale and character of the neighborhood, the Performing Arts Center would instead be located on the Chaparal Parcel. In addition, in response to comments, the seating capacity of the Performing Arts Center would be reduced from 650 seats to 395 seats. With these proposed refinements, the area of the Performing Arts Center would be reduced to 19,025 square feet, a reduction of 3,575 square feet. This reduction would provide for reduced massing, width, and length of the Performing Arts Center.

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With the relocation of the Performing Arts Center to the Chaparal Parcel, the Performing Arts Center would be sited on the east side of the Multipurpose Facility. Like the Multipurpose Facility, the Performing Arts Center would be set back 25 feet from the property line along Chaparal Street, in compliance with residential setback requirements. The Performing Arts Center would be screened by the double row of trees and 8-foot-high site wall proposed as part of the Project. The main entry to the Performing Arts Center would open to a small plaza on the south facing the campus interior. The east and west sides of the building would have no operable windows, and doors on these sides would be for emergency egress only. The east side of the Performing Arts Center would be set back 15 feet from the eastern property line and screened from the adjacent residential property by a 200-foot-long landscaped buffer. The Performing Arts Center would be 36 feet high, which is consistent with the residential height limit in the LAMC.

To integrate the Performing Arts Center within the Chaparal Parcel and the scale and character of the neighborhood, the design reduces the footprint of the Performing Arts Center by placing over 30 percent of its square footage below grade. To further reduce the massing along Chaparal Street, the upper 10 feet of the Performing Arts Center would be set back an additional 26 feet from the north property line, placing the high point of the roof 51 feet back from the property boundary along Chaparal Street. This design feature would reduce the height of the northern-most elevation of the Performing Arts Center to approximately 18 feet, which is lower than many of the adjacent residences located along Chaparal Street. The Chaparal Parcel is 110 feet wide. With the Code-required 5-foot side yards, a residential structure on the Chaparal Parcel could be as wide as 100 feet. The proposed width of the Performing Arts Building is 85 feet.

The materials and architectural treatments of the Performing Arts Center would be consistent with those of Archer’s Main Building and adjacent residences. These include simple building lines, a sloping tiled roof and smooth, light colored plaster walls with painted trim elements of wood and/or metal. Architectural relief would be applied to exterior wall surfaces to provide visual interest and avoid a monolithic appearance.

Barrington Avenue

As described in Section II, Project Description, of the Draft EIR, the Project proposed to replace the existing residential structure on the Barrington Parcel with a Performing Arts Center. In response to comments on the Draft EIR, the Visual Arts Center and the Aquatics Center would be developed on this parcel instead of the Performing Arts Center. The Visual Arts Center would be located along the western portion of the Barrington Parcel, and the Aquatics Center would be developed along the eastern portion

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Page III-186 WORKING DRAFT – Not for Public Review III.C Topical Responses of the Barrington Parcel. The new school buildings would include modulated heights and would maintain the residential street character when viewed from Barrington Avenue.

As noted above, in response to comments on the Draft EIR, the pool would be fully enclosed within the Aquatics Center. The Aquatics Center has been placed to maximize its distance from neighboring residences. The Aquatics Center would be 27 feet high, and the Visual Arts Center, which is located to the interior campus side of the Aquatics Center, would be 30 feet high. These heights are consistent with (and lower than) the heights of adjacent residences along Chaparal Street and Barrington Avenue, which range in height from approximately 30.2 feet (11718 Chaparal Street) to 43.3 feet (125 Barrington Avenue) and are consistent with the residential height limit in the LAMC of 36 feet.

The Project would implement architectural features to maintain the residential scale and character along Barrington Street. These features would include lowering the finished grade of the Barrington Parcel; maximizing the set back of the upper portions of the buildings; replacing the southernmost curb cut and the existing asphalt driveway with a landscaped berm lined with evergreen shade trees; providing long sloping roofs and simple massing to bridge the scale differences between the four-story building on the south and the two-story residence to the north; and using architectural materials that are consistent with the adjacent buildings, including smooth plaster walls with painted metal and wood trim. The Aquatics Center has been designed to step up gradually from the street, with the lowest portions of the building closest to the street. Thus, at a distance of 25 feet from the property line, the Aquatic Center’s roof would be 14 feet high. At 51 feet from the property line, the gabled roof over the pool and deck would be 27 feet high at its ridge. This gabled roof extends 110 feet further westward until it meets the side of the Visual Arts Center with a high point of 30 feet. This design keeps the lower portions of the building’s massing in the foreground and maintains a scale that is compatible with the adjacent single-family residence to the north.

In addition, an architectural site wall and entry gate comprised of smooth white plaster and painted metal panels would provide security for the Aquatics Center fronting the Barrington Parcel and reinforce the edge of the Barrington Avenue, as illustrated in Figure IV.A-15 and IV.A.16 included in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR. Further, a 20-foot wide landscaped side yard with a continuous row of evergreen shade trees would be provided along the north side of the apartment building to the south providing privacy and a visual amenity for existing balconies.

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Landscaping

The Project proposes enhanced landscaping buffers to provide privacy to nearby properties. As described above, along Chaparal Street is a solid cinderblock wall and wrought iron gate covered in vines and a row of existing pine trees. In response to comments, the Project proposes additional trees along Chaparal Street and a second row of trees on the south side of the wall to create a double row of landscaping along Chaparal Street.

In response to comments, the Project has been refined to shift the athletic field approximately 7 feet 6 inches to the east. Shifting the athletic field would move the athletic field as far away as possible from the neighbors to the west of the campus property boundary while still maintaining regulation size soccer and softball fields. This expanded setback would allow for an enhanced landscape buffer along the western property boundary of the campus. In response to comments, the planting area between the southern edge of the underground parking structure and the southern property line would be increased from 7 feet 10 inches to 22 feet to accommodate an expanded landscape buffer that would enhance the views from neighboring apartments to the south and eliminate views of parked cars. In addition, in response to comments, the Project would more than double the width of the landscaped planting strip along the southern boundary of the Barrington Parcel and add a row of evergreen trees to further enhance this landscape buffer.

As set forth in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, the Project proposes to plant 102 new trees. With the enhanced landscaping proposed in response to comments, the Project would now plant approximately 156 new trees on the Project Site and an additional, approximately 10 new trees along the Chaparal Street right-of-way.

In summary, by maintaining a consistent street scale, intensifying perimeter landscaping, and providing architectural features compatible with existing area buildings, the character of the existing neighborhood would be substantially maintained.

Project Design Features to Ensure Site Plan Consistency With the Scale and Character of the Neighborhood

As described above, the Project has been designed to shield neighbors from internal campus activities and noise. In particular, as provided in Project Design Feature I-6, the Project would be designed such that there are no operable windows that open on the sides of buildings directly adjacent to Chaparal Street and Barrington Avenue. Specifically, on

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Page III-188 WORKING DRAFT – Not for Public Review III.C Topical Responses the Barrington Parcel, non-operable windows shall be installed along the residential property boundary with 11718 Chaparal Street, 11706 Chaparal Street, and 125 North Barrington Avenue. On the Chaparal Parcel, non-operable windows shall be installed along the residential property boundary with 11718 Chaparal Street. Additionally, the Project would replace existing surface parking lots with facilities scaled to the residential character of the surrounding neighborhood and would accommodate nearly all on-campus parking within a new underground parking structure to maximize open space and reduce vehicular noise to adjacent neighbors. Further, with construction of the Multipurpose Facility, the two existing outdoor sports courts would be moved indoors.

The Project includes a number of design features and refinements to ensure that light and glare from the Project is consistent with the community. Project Design Feature A-8 includes a lighting plan that will adopt lighting guidelines to ensure that the Project would generate light intensity levels of less than 2.0 foot-candles at the property line of the nearest off-site residence or other light-sensitive use, avoid creating new high contrast conditions that also exhibits high context and coverage, and minimize skyglow. With respect to glare, Project Design Feature A-11 provides for the use of transparent vision glass with limited reflectivity in all exterior windows and building surfaces. Additionally, as discussed in Topical Response No. 2, Removal of Athletic Field Lighting and Refinements to Lighting, in response to comments on the Draft EIR, athletic field lighting is no longer proposed as part of the Project.

The Project also includes project design features to enhance landscaping on and around campus. Project Design Feature A-12 provides for the preparation of a street tree plan to be reviewed and approved by the City’s Department of Public Works, Street Tree Division, and requires all plantings in the public right-of-way to be installed in accordance with the approved street tree plan. Project Design Feature A-13 provides that all landscaped areas will be maintained in accordance with a landscape plan, including an automatic irrigation plan, prepared by a licensed landscape architect to the satisfaction of the City of Los Angeles Department of Planning. As discussed above, landscape buffers along the north, west, and southern perimeters of campus would be preserved and/or enhanced. Additionally, pursuant to Project Design Feature A-5, all trees to be removed as part of the Project that are 8 inches in diameter at breast height and above would be replaced on a one-to-one basis with 24-inch box trees or larger.

Finally, Project Design Feature A-14 will ensure that, where practicable, new on-site utilities will be installed underground, and existing on-site electrical poles along the southern boundary of the west surface parking lot will be removed and the electrical lines would be reinstalled underground as part of the Project, subject to approval of the utility company.

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III. Responses to Comments C. Topical Responses

13. Use of Existing Residential Properties

As described in Section II, Project Description, of the Draft EIR, the Project Site includes two properties adjacent to the existing Archer campus currently owned by Archer. These adjacent properties include two residential parcels located at 11728 Chaparal Street (the Chaparal Parcel) and 141 North Barrington Avenue (the Barrington Parcel). A Project objective is to use Archer-owned properties to create an all-pedestrian campus with facilities that are compatible with the character of the surrounding neighborhood. The Project seeks a new Vesting Conditional Use Permit (CUP) pursuant to LAMC Section 12.24.T for Private Schools, which would include the Chaparal Parcel and Barrington Parcel for school use.

The use of residential properties for school use does not require a zone change. The Project does not propose to change either the Barrington Parcel’s or the Chaparal Parcel’s zoning designation from single family residential to institutional or multi-family residential. Accordingly, the current residential zoning on the Barrington and Chaparal Parcels would remain intact. Therefore, if Archer’s CUP for any reason no longer applied to these parcels, the use of the parcels would be consistent with the underlying single- family residential zoning.

As described on page IV.H-6 of Section IV.H, Land Use, of the Draft EIR, in accordance with the Los Angeles Municipal Code, educational uses are permitted in the RE and R3 zones with a CUP. The General Plan Framework Element and the Brentwood- Pacific Palisades Community Plan also call for providing adequate facilities for schools to serve the needs of the existing and future populations in locations complementary to existing land uses and community character. See, e.g., General Plan Framework Element Objective 5.4 (“Encourage the development of community facilities and improvements that are based on need within the centers and reinforce or define those centers and the neighborhoods they serve.”); Brentwood-Pacific Palisades Community Plan Goal 6 (“Appropriate locations and adequate facilities for schools to serve the needs of existing and future populations”). Further, as set forth in Table 3-1 in the General Plan Framework, typical development characteristics of the Single-Family Residential category, which includes uses designated for Very Low II Residential, includes the development of

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Page III-190 WORKING DRAFT – Not for Public Review III.C Topical Responses single-family dwelling units, as well as supporting uses such as parks, schools, and community centers. Similarly, the Multi-Family Residential category, which includes uses designated for Medium Residential, includes the development of multi-family dwelling units and supporting uses, such as parks, schools, and community centers. As the Project involves the development of additional school-related facilities within an existing school, the Project would be consistent with the Single-Family and Multi-Family Residential categories, which include the development of schools. Overall, the Project would be consistent with the General Plan Framework’s guidelines for Single-Family and Multi-Family development.

Archer currently operates under CUP No. 98-0158, which was approved through the required public process and contains conditions of approval governing campus operations and physical improvements. A new CUP, if approved by the decision-makers, would subject the School to a new set of conditions of approval, including conditions regarding the compatibility of the School’s operations and its facilities with the surrounding neighborhood.

In addition, the Project also proposes project design features and mitigation measures to ensure that the School would remain compatible with the residences. Selected project design features and other measures to ensure the School’s compatibility with the neighborhood are described below.

In accordance with Project Design Feature K-1 included in Section IV.K, Traffic, Access, and Parking, of this Draft EIR, Archer would continue to implement its comprehensive Traffic Management Program that would encourage the reduction of vehicle trips. Primary access to the Project Site—including all student drop-off and pick-up—would be unchanged and would continue to be from Sunset Boulevard. Service and delivery vehicles would continue to access the Archer campus primarily from Sunset Boulevard. Barrington Avenue and Chaparal Street would be used for limited service, delivery, and emergency vehicle access.

As described in detail in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, the School’s new buildings are designed to complement the historic Main Building and respond to and respect the residential scale and character of the surrounding area as well as the residential street scale and character when viewed from Chaparal Street and Barrington Avenue. Specifically, the physical design of the school facilities on the Barrington and Chaparal Parcels incorporates protections for compatibility with the surrounding residential character. As described in Section IV.H, Land Use, of the Draft EIR, the Project has been designed to create a visually unified campus with new buildings designed to complement the historic Main Building and respond to the residential scale and character of the surrounding area. The new School buildings would be proportioned to be generally consistent with the height

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Page III-191 WORKING DRAFT – Not for Public Review III.C Topical Responses of surrounding uses and maintain the residential street scale and character when viewed from Chaparal Street and Barrington Avenue. The Project has also been designed to limit views of the new facilities from Sunset Boulevard. Refer to Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, for a discussion of the Project’s consistency with the surrounding residential neighborhood.

In response to comments, refinements to the Project are proposed, including a reduction in the size of certain proposed buildings. Regarding the Barrington and Chaparal Parcels, the Performing Arts Center would be relocated to the Chaparal Parcel and would be reduced in size from 22,600 square feet to 19,025 square feet. The maximum seating would also be reduced from 650 seats to 395 seats. The reduction in square footage and seats would result in reduced massing, width, and length of the building. Moreover, the adjusted gabled roof form and tiered massing along Chaparal Street are intended to reflect residential design standards. Further, the Project proposes a double row of landscaping along Chaparal Street. While the Performing Arts Center would be visible from off-site locations, view changes would occur at limited vantage points. For example, the Performing Arts Center would be mainly visible through the landscaping.

The Project has been further refined to relocate the Aquatics Center and Visual Arts Center to the Barrington Parcel. The Visual Arts Center would not be visible from Barrington Avenue or Chaparal Street. To reduce noise impacts from the use of the pool, the Project would fully enclose the pool within the proposed Aquatics Center. The Aquatics Center would be compatible in height and massing with the existing single-family residences to the north and the existing multi-family use to the south. Traveling north along Barrington Avenue towards Chaparal Street, the Project would visually fill in the existing landscaped setback area fronting the Barrington Parcel with views of the new landscaping, trees, and associated wall, gate, and landscape improvements.

The Performing Arts Center, Visual Arts Center, and Aquatics Center would meet residential height and front yard setback requirements for both the Barrington and Chaparal Parcels. The Performing Arts Center would reach a maximum height of 36 feet. The Visual Arts Center would reach a maximum height of 30 feet. The Aquatics Center would reach a maximum height of 27 feet. The Project would have 25-foot front yards along Chaparal Street and Barrington Avenue, in compliance with residential front yard requirements.

The Project is seeking a Zoning Administrator’s Adjustment pursuant to LAMC Section 12.28 to permit fences/gates/walls up to 8 feet in height within the required front yards along Chaparal Street and Barrington Avenue in lieu of the 3.5 feet otherwise permitted in the front yard. These fences would be installed in furtherance of Project

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Design Feature J.2-4, which states that the Project shall include the installation of new security fences and an emergency alert system.

The Project would also substantially comply with side yard requirements, and would request relief from LAMC Section 12.21.C.3.b to allow a reduced setback along the north side yards of the Barrington Parcel. As described on page IV.H-51 of Section IV.H, Land Use, of the Draft EIR, LAMC Section 12.21.C.3.b provides that for schools in R zones, “the combined widths of the two side yards on an interior lot shall be not less than 40 percent of the width of the lot, but need not exceed 50 feet, and on either an interior lot or a corner lot the side yard adjoining another lot in an ‘RA’ or ‘R’ zone shall be not less than ten feet in width.” Pursuant to the LAMC, the required combined width of the two side yards along Chaparal Street would be 50 feet. It is important to note that pursuant to LAMC Section 12.07.01.C.2 if the lots were being developed with a single-family residence the required side yard would only be 5 feet. It is because the development is a school that the increased side yard is required.

The School proposes to satisfy the 50-foot requirement along Chaparal Street with a 35-foot side yard along the western side yard and a 15-foot side yard along the eastern side yard. Pursuant to the same section of the LAMC, the required combined width of the two side yards along Barrington Avenue is 40 feet. Along the south, the Aquatics Center and Visual Arts Center are proposed to be set back approximately 20 feet from the property line, and additional landscaping along the southern property line has been integrated into the refined Project design.

As noted above, in response to comments on the Draft EIR, the Aquatics Center has been fully enclosed to reduce noise impacts from the Project. Due to the enclosure of the Aquatics Center, there would be no side yard along the northern property line at the Barrington Parcel. As such, the School is requesting relief from LAMC Section 12.21.C.3.b to allow this setback along the north side yards. Three parcels border the Barrington Parcel to the north: the Chaparal Parcel, which is owned by Archer and part of the Project Site; 11718 Chaparal Street; and 11706 Chaparal Street. The rear yards of 11718 Chaparal Street and 11706 Chaparal Street are truncated by a retaining wall and property fencing located between 8 and 13 feet from the northern Barrington Parcel property line, increasing the actual distance between development on the Barrington Parcel and adjacent residential uses. Finally, the Project would comply with side yard requirements with respect to the boundary between the Barrington Parcel and 11706 Chaparal Street, as the Project would not result in development within 20 feet of the 11706 Chaparal Street property line. The Aquatics Center would be located 24 feet 3 inches from the 11706 Chaparal Street property line.

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The Project has been designed to shield neighbors from internal campus activities and noise. In particular, as provided in Project Design Feature I-6, the Project would be designed such that there are no operable windows that open on the sides of buildings directly adjacent to Chaparal Street and Barrington Avenue. On the Barrington Parcel, non-operable windows shall be installed along the residential property boundary with 11718 Chaparal Street, 11706 Chaparal Street, and 125 North Barrington Avenue. On the Chaparal Parcel, non-operable windows shall be installed along the residential property boundary with 11718 Chaparal Street. Additionally, the Project would replace existing surface parking lots with facilities scaled to the residential character of the surrounding neighborhood and would accommodate nearly all on-campus parking within a new underground parking structure to maximize open space and reduce vehicular noise to adjacent neighbors. The Project proposes fences, walls, and significant new landscape buffers to provide privacy and reduce noise to nearby properties. The buildings on the Barrington and Chaparal Parcels would also act as buffers to shield neighboring uses from internal campus activities and noise. Therefore, the Project would strive to enhance the Project Site while respecting the scale and character of the surrounding residential area.

In addition, the total floor area on the Project Site as a whole is considerably below the maximum density that is permitted on the Project Site. As described on page IV.H-50 of Section IV.H, Land Use, of the Draft EIR, LAMC Section 12.21.1.A.1 permits a maximum FAR of 3:1 in the R3-1 zone. For the RE11-1 zone, LAMC Section 12.07.01.C.5 permits a maximum residential floor area of 35 percent for lots 15,000 square feet or greater. In the RE11-1 zone, an additional 20 percent of the maximum residential floor area is allowed if certain design principles are met. Because Section 12.07.C.5 applies only to residential floor area, and Archer is not proposing any residential uses, the maximum residential floor area limits set forth in Section 12.07.C.5 are inapplicable to the Project. Therefore, the total maximum floor area for the entire Project Site, including the RE11 zones, is governed by the 3:1 floor area ratio set forth in LAMC Section 12.21.1.A.1. The existing campus and two adjacent properties contain approximately 90,948 square feet of enclosed floor area. The Project, as refined in response to comments, would result in the addition of 68,989 square feet of net new floor area. Upon full build-out of the Project, the School would only comprise approximately 159,937 square feet. Thus, at build out, the Project’s floor area would comprise approximately 22 percent of the total allowable floor area.

Based on the above, the use of the Barrington and Chaparal Parcels for school purposes is consistent with the LAMC, General Plan, and Brentwood-Pacific Palisades Community Plan, and would be compatible with the surrounding residential neighborhood.

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III. Responses to Comments C. Topical Responses

14. Residential Neighbors’ Proposed Alternative

Several comments on the Draft EIR indicate support for the “Residential Neighbors of Archer Alternative” (the Residential Neighbors Alternative). As set forth in the comment letters (see e.g., Comment Letter No. 499), the Residential Neighbors Alternative is similar to Alternative 4, Option B (Alternative 4B) analyzed in Section V.D, Alternatives, of the Draft EIR, with the following modifications:

 Increase the current size of the school by adding two new buildings, not four, including only one gym built underground and a 300-seat Performing Arts Center;

 Renovate the North Wing;

 Eliminate the Aquatics Center and Visual Arts Center;

 Expand and renovate the campus within the current footprint of the school, thus preserving the two residences and creating a needed buffer between the neighbors and the institutional use of the school;

 Continue to use the two residences adjacent to the school as residences;

 Add more landscaping on the northern and western property lines to provide an attractive buffer between the school and residences;

 Increase the setback of the building placed adjacent to Chaparal Street;

 Maintain the number of special events at the current level permitted in the Conditional Use Permit, which as set forth in the Draft EIR’s analysis of Alternative 2, reduces impacts to traffic to a level less than significant after mitigation;

 Maintain the current condition of no lights on the athletic field;

 Maintain the current northwest orientation of the softball field;

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 Maintain the current condition of no amplified or loud music outside;

 Follow the guidelines of the current Conditional Use Permit regarding hours of operation for school instruction and functions;

 No outside use of the facilities for rental or lease, as required by the current Conditional Use Permit, which would eliminate and/or reduce noise, aesthetic and traffic impacts;

 Improve the school’s facilities with only one phase of construction; and

 Eliminate the outdoor North Garden.

As described below, implementation of the Residential Neighbors Alternative would preclude the attainment of many basic Project objectives. Nonetheless, in response to comments, the Project has been refined to incorporate several of the proposed modifications in the Residential Neighbors Alternative.

Overview of Alternative 4B

As described on pages V-79 to V-83 in Section V, Alternatives, of the Draft EIR, Alternative 4B would develop certain reduced components proposed by the Project within the existing Archer campus boundary. Specifically, Alternative 4B would involve removal of the existing North Wing and development of a new North Wing within generally the same footprint as the existing North Wing. Parking would be provided in a new underground parking structure with ingress and egress along Sunset Boulevard. New athletic field would be provided above the new underground parking structure. Under Alternative 4B, the softball field would be oriented northwest, rather than northeast as proposed by the Project. In addition, under Alternative 4B, the two adjacent properties currently owned by Archer would continue to be used for residential uses. Due to the reduced Project Site area, the North Garden proposed under the Project would not be provided. In addition, the Multipurpose Facility would be reduced to one below-grade gymnasium with substantially reduced support facilities. Due to the reduction in area and support facilities within the gymnasium, many athletic activities would not be able to be held on-campus, but would continue to occur off-site. In addition, the Aquatics Center proposed as part of the Project would not be developed under Alternative 4B. Alternative 4B would include a reduced Performing Arts Center of approximately 18,150 square feet with reduced support facilities above the below grade gymnasium. Alternative 4B would also construct a Visual Arts Center and Arts Plaza of the same size as that proposed for the Project immediately east of the Performing Arts Center. Upon full buildout, Alternative 4B would comprise approximately 150,850 square feet in comparison to the Project proposed in the Draft EIR, which at full buildout would comprise approximately 166,878 square feet. In addition,

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Page III-196 WORKING DRAFT – Not for Public Review III.C Topical Responses because Alternative 4B would not develop the Chaparal Parcel nor the Barrington Parcel and certain components proposed by the Project would be reduced, the total amount of soil required to be exported would be reduced. In sum, Alternative 4B represents a reduced scope of development compared to the Project. Although Alternative 4B would reduce some of the Project’s environmental impacts, it would fail to meet many of the Project’s basic objectives. Please refer to pages V-105 to V-109 of the Draft EIR for a description of Alternative 4B’s relationship to project objectives.

Analysis of Residential Neighbors Alternative

Provided below is a discussion of each of the modifications set forth in the Residential Neighbors Alternative, as well as the proposed refinements to the Project to incorporate several of the modifications in the Residential Neighbors of Archer Alternative.

Increase the Current Size of the School by Adding Two New Buildings, Not Four, Including Only One Gym Built Underground and a 300-seat Performing Arts Center

A site plan that includes several smaller buildings better suits the residential character of the surrounding neighborhood. The Residential Neighbors Alternative would fail to meet the site design objective to create an all-pedestrian campus with facilities that are compatible with the character of the surrounding neighborhood, because it would require an increase in the bulk and scale of the buildings and would prevent the feeling of a campus-like setting. As described in Sections IV.A, Aesthetics/Visual Quality, Views, Light/ Glare, and Shading, and IV.H, Land Use, of the Draft EIR and Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, the Project has been designed to create a visually unified campus with new buildings designed to complement the historic Main Building and respond to the residential scale and character of the surrounding community. By separating uses into multiple buildings, the Project uses smaller building masses more compatible in scale with surrounding residential uses. In comparison, consolidating the gymnasium and performing and visual arts programs into a single structure that does not exceed the 36-foot height limit would increase the length of the proposed Multipurpose Facility by almost 30 percent, which would increase the building’s frontage along Chaparal Street and reduce the open space on either side of the building. In addition, the Multipurpose Facility would need to be shifted west to accommodate this length, bringing the building closer to the residences along the west property line and minimizing the open space around the athletic field.

Alternative 4B as incorporated as part of the Residential Neighbors Alternative would provide for 59,902 net new square feet of development for a total of 150,850 square feet at full buildout. As described in Topical Response No. 12, Site Plan Consistency

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Page III-197 WORKING DRAFT – Not for Public Review III.C Topical Responses with the Residential Scale and Character of the Neighborhood, in response to comments, the Project proposes refinements to the site plan, including reducing the square footage and massing, width, and length of some of the proposed buildings. Overall, the Project’s net new floor area would be reduced from 75,930 square feet to 68,989 square feet. Thus, upon full buildout of the Project, the School would comprise approximately 159,937 square feet.

As described on pages V-105 through V-109 in Section V, Alternatives, of the Draft EIR, providing reduced gymnasium space would not meet the objective to provide a new Multipurpose Facility with separate gymnasium space for the Middle School and Upper School. The reduced gymnasium would not meet the Project’s objective to provide basketball and volleyball courts for the Middle School and Upper School that comply with California Interscholastic Federation regulations. Because it would include limited gymnasium space, the Residential Neighbors Alternative would not meet the Project’s objective to have Middle School and Upper School basketball or volleyball teams practicing simultaneously within separate gymnasiums on the Archer campus during after school hours, and the limited space would make it difficult to schedule Archer’s Middle School and Upper School basketball and volleyball teams competing on the Archer campus. In addition, the reduced gymnasium would reduce or eliminate some ancillary uses compared to the Multipurpose Facility proposed under the Project and, therefore, would not meet the objective to provide support facilities for Middle School and Upper School basketball, volleyball, soccer, softball, and field hockey programs, including locker rooms, training rooms, coaching and staff offices, and facilities for spectators.

Moreover, providing separate gymnasium space for the Middle School and Upper School supports Archer’s busing program. As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, Archer’s Transportation Management Program requires that 70 percent of the students use the fixed-route bus service. Providing separate gymnasiums for the Middle School and Upper School will allow students to take the bus home after practice and games in compliance with Archer’s Transportation Management Program.

In response to comments on the Draft EIR, the Multipurpose Facility, which includes gymnasium space for Archer’s Upper School and Middle School, will be reduced from 41,400 square feet to 39,330 square feet. With the Middle School gymnasium located below grade, the Multipurpose Facility has been designed to be consistent with adjacent residential development with 19,950 square feet of floor area of the Multipurpose Facility located above grade.

With respect to the Performing Arts Center, the Residential Neighbors Alternative does not meet the Project objective to provide new facilities on the Archer campus that can

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Page III-198 WORKING DRAFT – Not for Public Review III.C Topical Responses accommodate the entire Middle School and Upper School separately and simultaneously. Currently, the Archer campus does not have an assembly space indoors where the entire school can meet together. Accordingly, the Project proposed the Multipurpose Facility and the Performing Arts Center, which can accommodate the entire Middle School and Upper School separately and simultaneously. Nonetheless, in response to comments on the Draft EIR, the Project has been refined to reduce the size of the Performing Arts Center from 22,600 square feet to 19,025 square feet and has reduced the number of proposed seats from 650 to 395. This change would still enable Archer to meet the Project objective to accommodate the entire Middle School and Upper School separately, while responding to concerns of the community.

Renovate the North Wing

The Residential Neighbors Alternative and the Project both propose to renovate the existing North Wing of the Main Building. Specifically, the Project proposes a renovated North Wing to provide upgraded classrooms and improved lighting, air conditioning, and information technologies (North Wing Renovation). In response to comments on the Draft EIR, the North Wing Renovation is proposed to be reduced from 39,071 square feet to 30,400 square feet with a height of 41 feet 4 inches.

Eliminate the Aquatics Center and Visual Arts Center

The Residential Neighbors Alternative’s elimination of the Visual Arts Center would fail to meet the visual arts objectives to: (i) create dedicated, visible, and modern facilities for the visual arts program on the Archer campus; and (ii) provide a Visual Arts Center to allow for studio and gallery space on the Archer campus, including drawing, painting, ceramics, and photography studios and gallery space to exhibit student work. In response to comments on the Draft EIR, the Visual Arts Center would be relocated to the western portion of the Barrington Parcel, just east of the North Wing and to the interior campus side of the Aquatics Center. As described in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, the Visual Arts Center would be 30 feet high, which is consistent with the heights of adjacent residences along Chaparal Street and Barrington Avenue and is consistent with the residential height limit in the LAMC. The Visual Arts Center has thus been designed to be consistent with the scale and character of the community.

The Residential Neighbors Alternative’s elimination of the Aquatics Center would fail to meet the Project’s objectives to provide an Aquatics Center to accommodate support facilities for the swimming and water polo programs, including coaching and staff offices, changing and restrooms, and equipment storage space. In response to comments to reduce noise from the use of the Aquatics Center, the Project would fully enclose the pool

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Page III-199 WORKING DRAFT – Not for Public Review III.C Topical Responses within the proposed Aquatics Center. The enclosure of the pool at the Aquatics Center would eliminate the significant noise impacts associated with Aquatics Center activities.

Expand and Renovate the Campus Within the Current Footprint of the School, Thus Preserving the Two Residences and Creating a Needed Buffer Between the Neighbors and the Institutional Use of the School

With the eliminated use of the Chaparal Parcel and Barrington Parcel, the Residential Neighbors Alternative would fail to meet the site design and community objective to allow expanded use of the Project Site for the School to ensure the continued preservation of the historic Main Building and would also not meet the Project objective to use Archer-owned properties to create an all-pedestrian campus with facilities that are compatible with the character of the surrounding neighborhood. As described in Section II, Project Description, of the Draft EIR, Archer owns the adjacent Chaparal Parcel located at 11728 Chaparal Street and the adjacent Barrington Parcel located at 141 North Barrington Avenue. A Project objective is to use these Archer-owned properties to create an all- pedestrian campus with facilities that are compatible with the character of the surrounding neighborhood. The Project seeks a new Vesting Conditional Use Permit (CUP) pursuant to LAMC Section 12.24.T for Private Schools, which would include the Chaparal Parcel and Barrington Parcel for school use.

As described on page IV.H-6 in Section IV.H, Land Use, of the Draft EIR, in accordance with the Los Angeles Municipal Code, educational uses are permitted in the RE and R3 zones with a CUP. As described in Topical Response No. 13, Use of Existing Residential Properties, private schools use this LAMC provision to provide private schools in residential neighborhoods close to the families and children they serve. In the process, many of these schools have incorporated residential properties for school use.

A new CUP and other concurrent entitlement requests, if approved by the decision- makers, would subject the School to a new set of conditions of approval, including conditions regarding compatibility of the School’s operations and its facilities with the surrounding neighborhood. With respect to buffers between the neighbors and the School, the Project would substantially comply with residential set back requirements. The Project would have 25-foot front yards along Chaparal Street and Barrington Avenue, in compliance with residential front yard requirements. The Project would also substantially comply with side yard requirements. As described on page IV.H-51 in Section IV.H, Land Use, of the Draft EIR, pursuant to the LAMC, the required combined width of the two side yards along Chaparal Street would be 50 feet. Pursuant to the LAMC, the required combined width of the two side yards along Barrington Avenue is 40 feet. It is important to note that pursuant to the LAMC, if the lots were being developed with a single-family residence, the required side yard would only be 5 feet.

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The School proposes to satisfy the 50-foot requirement along Chaparal Street with a 35-foot side yard along the western side yard and a 15-foot side yard along the eastern side yard. On the Barrington Parcel, along the south, the Aquatics Center and Visual Arts Center are proposed to be set back approximately 20 feet from the property line. Due to the enclosure of the pool within the Aquatics Center, which has been proposed to reduce noise, there would be no side yard along the northern property line at the Barrington Parcel. As such, the School is requesting relief from LAMC Section 12.21.C.3.b. As described in further detail in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, three parcels border the Barrington Parcel to the north: the Chaparal Parcel, which is owned by Archer and part of the Project Site; 11718 Chaparal Street; and 11706 Chaparal Street. The rear yards of 11718 Chaparal Street and 11706 Chaparal Street are truncated by a retaining wall and property fencing located between 8 and 13 feet from the northern Barrington Parcel property line, increasing the actual distance between development on the Barrington Parcel and adjacent residential uses. Finally, the Project would comply with side yard requirements with respect to the boundary between the Barrington Parcel and 11706 Chaparal Street, as the Project would not result in development within 20 feet of the 11706 Chaparal Street property line. The Aquatics Center would be located 24 feet 3 inches from the 11706 Chaparal Street property line.

In addition, in response to comments, the Project shifted the athletic field approximately 7 feet 6 inches to the east. Shifting the athletic field would move the athletic field as far away as possible from the neighbors to the west of the campus property boundary while still maintaining regulation size soccer and softball fields. This expanded setback would allow for an enhanced landscape buffer along the western property boundary of the campus. Also, in response to comments, the planting area between the southern edge of the underground parking structure and the southern property line would be increased from 7 feet 10 inches to 22 feet to accommodate an expanded landscape buffer that would enhance the views from neighboring apartments to the south and eliminate views of parked cars. Further, in response to comments, the Project would provide additional trees along Chaparal Street and a second row of trees on the south side of the wall to create a double row of landscaping along Chaparal Street.

Continue to Use the Two Residences Adjacent to the School as Residences

For the same reasons as described in the immediately preceding section, continued use of the Chaparal Parcel and the Barrington Parcel as residences would fail to meet the site design and community objective to allow expanded use of the Project Site for the School to ensure the continued preservation of the historic Main Building and would also not meet the Project’s objective to use Archer-owned properties to create an all-pedestrian

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Add More Landscaping on the Northern and Western Property Lines to Provide an Attractive Buffer Between the School and Residences

In response to comments on the Draft EIR, the Project proposes enhanced landscaping buffers around the Project Site. As described in more detail in Section IV.A, Aesthetics/Visual Quality, Views, Light/Glare, and Shading, of the Draft EIR, along Chaparal Street is a solid cinderblock wall and wrought iron gate covered in vines. Also along Chaparal Street is a row of existing pine trees. In response to comments, the Project would provide additional trees along Chaparal Street and a second row of trees on the south side of the wall to create a double row of landscaping along Chaparal Street.

In addition, as discussed above, the Project would be further refined to shift the athletic field approximately 7 feet 6 inches to the east, which would allow for an enhanced landscape buffer along the western property boundary of the campus. Also in response to comments, the planting area between the southern edge of the underground parking structure and the southern property line would be increased from 7 feet 10 inches to 22 feet to accommodate an expanded landscape buffer.

Increase the Setback of the Building Placed Adjacent to Chaparal Street

The Residential Neighbors Alternative proposes increasing the setback of the building placed adjacent to Chaparal Street. As described above and in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, the Project would have 25-foot front yards along Chaparal Street and Barrington Avenue, in compliance with residential front yard requirements. Because the Project already complies with residential setback requirements along Chaparal Street, no additional increase in setback is required.

The Project has been designed to maintain the residential character along Chaparal Street. The buildings would have a stepped profile and would be located behind 8-foot walls covered in vines and continuous landscaping. Thus, the Project would not dominate views along Chaparal Street. Further, as described in greater detail in Topical Response No. 12, Site Plan Consistency with the Residential Scale and Character of the Neighborhood, the existing tree-lined right-of-way along the south side of Chaparal Street would be enhanced by adding trees to both sides of the existing site wall and extending the right-of-way an additional 110 feet eastward along the north side of the proposed Performing Arts Center. The wall would be an extension of the existing fence and would be landscaped and provide a buffer for the benefit of nearby properties. The wall would

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Page III-202 WORKING DRAFT – Not for Public Review III.C Topical Responses enhance safety and security for the School without negatively affecting views or the surrounding residential character. Moreover, the additional landscaping along Chaparal Street would effectively screen the massing of the Multipurpose Facility and the Performing Arts Center, with only portions of the buildings being visible along breaks in the landscaping. Therefore, the Multipurpose Facility and the Performing Arts Center would not represent a substantial contrast compared to the existing visual character along Chaparal Street, particularly given the presence of large one- and two-story single-family residences along Chaparal Street, which are also visible through breaks in landscaping. Additionally, no new driveways would be added along Chaparal Street for access to the Project Site and, consistent with existing conditions, a single access gate along Chaparal Street would be maintained and would be used for emergency vehicle access and limited service and delivery vehicle access.

The Multipurpose Facility would be set back 25 feet from the property line at Chaparal Street, in compliance with residential requirements. The Multipurpose Facility would be located over 400 feet from the nearest single-family residence to the west and over 145 feet from the nearest single-family residence to the east. To further reduce the impression of height along Chaparal Street, the upper seven feet of the Multipurpose Facility is proposed to be set back an additional 6 feet 9 inches from the property line creating a stepped profile along the full length of the north side of the building. To reduce noise, the main entry to the Multipurpose Facility would be located on the south, opposite Chaparal Street, facing the Court of Leaders. In addition, to reduce noise from internal campus activities, there would be no operable windows along the west, north, or east elevations of the Multipurpose Facility.

The Performing Arts Center would be set back 25 feet from the property line along Chaparal Street, in compliance with residential setback requirements. The Performing Arts Center would be screened by the double row of trees and 8-foot-high site wall proposed as part of the Project. The main entry to the Performing Arts Center would open to a small plaza on the south facing the campus interior. The east and west sides of the building would have no operable windows, and doors on these sides would be for emergency egress only. The east side of the Performing Arts Center would be set back 15 feet from the eastern property line and screened from the adjacent residential property by a 200-foot- long landscaped buffer. To integrate the Performing Arts Center within the Chaparal Parcel and the scale and character of the neighborhood, over 30 percent of the Performing Arts Center’s square footage will be located below grade. To further reduce the massing along Chaparal Street, the upper 10 feet of the Performing Arts Center would be set back an additional 26 feet from the property line, placing the high point of the roof 51 feet back from the property boundary along Chaparal Street. This design feature would reduce the height of the northern-most elevation of the Performing Arts Center to approximately 18 feet, which is lower than many of the adjacent residences located along Chaparal Street.

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Maintain the Number of Special Events at the Current Level Permitted in the Conditional Use Permit, which as Set Forth in the Draft EIR’s Analysis of Alternative 2, Reduces Impacts to Traffic to a Level Less Than Significant After Mitigation

The Residential Neighbors Alternative proposal to maintain the number of Special Events at the current level permitted in the existing CUP would fail to meet the site design and community objective to enhance campus facilities and revise operating conditions to make the appropriate use of new on-site facilities consistent with other public and independent schools throughout Los Angeles. Nonetheless, as described in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, Project operations have been refined to reduce the number of proposed School Functions from 98 to 86, including eliminating the proposed Interscholastic Athletic Tournaments and two School Functions with up to 650 guests. In addition, as evaluated in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, and as discussed in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, with implementation of the mitigation measures presented in the Draft EIR and Final EIR, all Project traffic impacts would be reduced to below significance.

Maintain the Current Condition of No Lights on the Athletic Field

As discussed in Topical Response No. 2, Removal of Athletic Field Lighting and Refinements to Lighting, in response to comments on the Draft EIR, the athletic field lighting has been removed from the Project.

Maintain the Current Northwest Orientation of the Softball Field

As described in Topical Response No. 4, Additional Measures to Reduce Noise, in response to comments, the Project proposes maintaining the current northwest orientation of the softball field, consistent with the Residential Neighbors Alternative.

Maintain the Current Condition of No Amplified or Loud Music Outside

As described in Topical Response No. 4, Additional Measures to Reduce Noise, although impacts from the public address system were determined by the Draft EIR to be less than significant, in response to comments, the use of a new non-permanent audio system has been removed from the Project. Rather, consistent with existing conditions, Archer would continue to use a non-permanent audio system solely for use during Graduation as permitted under Archer’s existing CUP. Elimination of the portable public address system except for use during Graduation would further reduce the incidence of noise in the community and would be consistent with the Residential Neighbors Alternative.

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Follow the Guidelines of the Current Conditional Use Permit Regarding Hours of Operation for School Instruction and Functions

The Residential Neighbors Alternative proposal to maintain the current Conditional Use Permit guidelines regarding hours of operation for school instruction and functions would fail to meet the site design and community objective to enhance campus facilities and revise operating conditions to make the appropriate use of new on-site facilities consistent with other public and independent schools throughout Los Angeles. Nonetheless, as discussed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, additional limitations on the hours of operation have been proposed. The hours of operation on weekday mornings are proposed to be consistent with the existing CUP. School uses on Saturday shall not begin earlier than 9:00 A.M., and use of the athletic field on Saturday shall not begin earlier than 10:00 A.M. Use of the athletic field on Saturday shall be permitted for not more than 4 hours on 10 days per year. School Functions shall not be permitted on the athletic field, with the exception of Upper School Graduation. Appendix FEIR-B of this Final EIR includes additional limitations for the proposed School Functions and includes a table with limitations on hours and days and illustrative examples.

Moreover, as discussed in Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, in response to comments on the Draft EIR, the Project is incorporating additional operational mitigation measures to reduce significant traffic impacts related to School Functions and Interscholastic Athletic Competitions to less than significant. With incorporation of these measures, the use of the Project Site would be more restrictive than under the existing CUP regarding Interscholastic Athletic Competitions and School Functions at P.M. peak hours.

No Outside Use of the Facilities for Rental or Lease, as Required by the Current Conditional Use Permit, which would Eliminate and/or Reduce Noise, Aesthetic and Traffic Impacts

The Project in the Draft EIR proposed rental, lease, and use of the facilities for non- School Use a maximum of 24 days per year. As discussed in Topical Response No. 1, Refinements to Proposed Operations, in response to comments on the Draft EIR, proposed operations have been refined to eliminate the rental, lease, or use of the facilities for non- School Uses.

Improve the School’s Facilities with Only One Phase of Construction

The Residential Neighbors Alternative proposes improving the school’s facilities within one phase of construction. This restriction would fail to meet the site design and community objective to phase construction to provide Archer the flexibility to continue City of Los Angeles Archer Forward: Campus Preservation and Improvement Plan SCH. No. 2012011001 November 2014

Page III-205 WORKING DRAFT – Not for Public Review III.C Topical Responses operating the School on campus during construction, minimize disruption of classes, and coordinate fundraising with construction expenses. However, as detailed in Topical Response No. 11, Overview of Construction Refinements, in response to comments, the Project’s construction period has been reduced from six years to five years.

As described in Section II, Project Description, of the Draft EIR, the Project would be developed as the North Wing Renovation, Phase 1, and Phase 2, each designed and timed to facilitate continued School operations on-site and minimize disruptions to neighbors. Further, project design features have been proposed to reduce impacts to neighbors from construction activities. For example, pursuant to Project Design Feature A-7, during construction, all lighting shall be shielded and/or aimed so that no direct beam illumination would fall outside of the Project Site boundary. Pursuant to Project Design Feature I-1, pile drivers and vibratory rollers shall not be used in the construction of the Project. Further, as described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, the Project would include a Construction Traffic Management Plan, a Construction Period Pedestrian Routing Plan, and a Construction Worker Parking Plan, which would be implemented during construction to manage construction traffic and ensure that adequate and safe access and parking remains available during construction activities. Additionally, as detailed in Section II, Corrections and Additions to the Draft EIR, of this Final EIR, the Project proposes enhanced mitigation measures during construction of the Project to reduce the Project’s air quality impacts.

Eliminate Outdoor North Garden

Eliminating the outdoor North Garden would not meet the Project’s objective to provide a North Garden. Without the North Garden, the Residential Neighbors Alternative would not provide a safe, protected, transitional space for students and guests to move to and from the campus and the parking structure, deliver a primary source of natural ventilation to the adjacent parking structure minimizing the need for energy-consuming and audible mechanical equipment, and provide daylight to the lower-level of the Multipurpose Facility. The Residential Neighbors alternative would, thus, not meet the objective to enhance campus facilities to the same extent as the Project.

Use of the North Garden was discussed on pages IV.I-83 through IV.I-84 in Section IV.I, Noise, of the Draft EIR. As stated therein, the Project did not propose to use the North Garden to conduct large gatherings or all-school assemblies; however, the analysis conservatively analyzed that up to 650 people could be within the North Garden and determined that noise impacts associated with such use would be less than significant. To clarify the limited use of the North Garden, the Project proposes to prohibit School Functions in the North Garden. To further ensure that the North Garden would not be used for School Functions, large gatherings, or all-school assemblies, hardscape and landscape

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Page III-206 WORKING DRAFT – Not for Public Review III.C Topical Responses features have been added to the design of the North Garden to limit the availability of open space potential for such gatherings and assemblies. For instance, paved surfaces would be limited to pathways, and landscaping features will include raised planters, terraces, flower beds, and large-specimen trees. Elimination of School Functions in the North Garden would further reduce the incidence of noise in the community.

In sum, the modifications proposed by the Residential Neighbors of Archer would preclude the attainment of many basic Project objectives. Nonetheless, in response to comments on the Draft EIR, the Project has been refined to incorporate several of the proposed modifications in the Residential Neighbors Alternative.

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III. Responses to Comments C. Topical Responses

15. Alternative Locations

Several commenters have addressed whether an alternative location may be appropriate for the Project. As described on page V-3 in Section V, Alternatives, of the Draft EIR, an alternate site alternative was considered and rejected as infeasible because it would not meet many of the basic Project objectives. Therefore, an alternate site alternative was eliminated from detailed analysis in the Draft EIR in accordance with Section 15126.6(f) of the State CEQA Guidelines.

California Public Resources Code Sections 21001(g), 21002.1(a), and 21061 require that an EIR identify alternatives to the project. CEQA Guidelines Section 15126.6(a) expands on the statute by stating that an EIR must include a reasonable range of alternatives to the project or to the location of the project and that EIR need not consider every conceivable alternative to a project. Further, per Cal. Native Plant Society v. City of Santa Cruz, 177 Cal. App. 4th 957, 993 (2009), there is no requirement that off-site alternatives be explored in every case.

Under CEQA, an EIR need not extensively consider an alternative that is infeasible. Stated differently, in accordance with CEQA Guidelines Section 15126(f)(2)(B), alternatives presented in an EIR must be able to “feasibly attain most of the basic objectives of the project.” In accordance with case law, including City of Long Beach v. Los Angeles Unified School Dist., 176 Cal. App. 4th 889, 921 (2009), an agency may properly determine that no feasible locations exist either because basic project objectives cannot be achieved at another site or because there are no sites meeting the criteria for feasible alternate sites. In addition, in accordance with CEQA Guidelines Section 15126(f)(1), a lead agency may consider whether an alternate site is owned by the project proponent when determining whether an alternate site is feasible and may also consider whether the project proponent could reasonably acquire, control, or otherwise obtain access to an alternate site if one is not owned by the proponent.

As described above, the Draft EIR considered an alternate site alternative and rejected it as infeasible, in compliance with the CEQA Guidelines. As explained on page V-3 in Section V, Alternatives, of the Draft EIR, an alternate site would not meet many

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Page III-208 WORKING DRAFT – Not for Public Review III.C Topical Responses of the basic Project objectives. Specifically, the objectives of the Project are closely tied to the concept of improving existing operations on the Project Site by creating a cohesive and integrated campus environment, with new, state-of-the-art and technologically advanced facilities. Development of the Project on an alternate site would provide no potential to achieve the basic Project objectives related to: modernizing and reconfiguring classroom spaces within the existing campus; creating dedicated and modern facilities for the athletic, visual arts, and performing arts programs on the campus; and upgrading the existing outdoor athletic field to comply with California Interscholastic Federation regulations. Moreover, development of the Project on an alternate site would not meet the Project objective to allow expanded use of the Project Site to ensure the continued preservation of the historic Main Building. In addition, Archer already owns the Project Site and does not own or control another property of a comparable size in the Project area of the Los Angeles region. Further, it is not expected that Archer can reasonably acquire, control, or have access to an alternate site within Los Angeles that would provide for the uses and square footages contemplated for the Project. Therefore, the Draft EIR concluded that locating the Project on an alternate site would be infeasible.

In addition, in accordance with CEQA Guidelines Section 15126.6(f)(2)(A), an EIR is not required to analyze alternate sites that would not eliminate or substantially reduce significant adverse effects. As described in Topical Response No. 13, Use of Existing Residential Properties, the Los Angeles Municipal Code and the General Plan Framework Element provide for adequate facilities for schools in residential neighborhoods to serve the needs of the existing and future populations in locations complementary to existing land uses and community character. Given the urbanized, residential environment surrounding the general Project area, it is anticipated that development on an alternate site would likely produce the significant construction-related regional air quality, noise and vibration (human annoyance), and construction traffic impacts as the Project, although in a different location. Similarly, while development on an alternate site would likely avoid the Project’s significant and unavoidable operational noise and traffic impacts in the vicinity of the Project Site, it would likely result in significant noise and traffic impacts at another site. Refer to Topical Response No. 5, Additional Mitigation Measures to Eliminate Significant Traffic Impacts, detailing that with implementation of the operational mitigation measures presented in the Draft EIR and Final EIR, all Project operational traffic impacts would be reduced to below a level of significance. Also refer to Topical Response No. 4, Additional Measures to Reduce Noise, for details regarding additional measures to reduce noise associated with campus operations.

For these reasons, the Draft EIR properly eliminated an alternate site alternative from further detailed analysis. This is consistent with case law including Jones v. Regents of Univ. of Cal., 183 Cal. App. 4th 818, 828 (2010), which holds that the EIR for a development plan for a special research campus did not have to consider the alternative of

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Page III-209 WORKING DRAFT – Not for Public Review III.C Topical Responses developing the planned facilities at an off-site location where an off-site location would prevent realization of the project’s primary objective of creating a more campus-like setting at the existing site and fostering a collaborative work environment. As set forth above, the objectives of the Project are closely tied to the concept of improving existing operations on the Project Site by creating a cohesive and integrated campus environment, with new, state-of-the-art and technologically advanced facilities.

In addition, certain comments suggest that Archer should divide into two campuses on separate sites. Splitting the School onto two separate sites would also fail to meet Project objectives. Specifically, two separate sites would fail to meet the Project’s academic objective to “allocate space for ample collaboration and multiple instruction modalities….” Splitting the School onto two sites would fail to meet the site design and community objectives set forth on pages II-14 through II-16 in Section II, Project Description, of the Draft EIR, including the objectives to: (1) “use Archer-owned properties to create an all-pedestrian campus with facilities that are compatible with the character of the surrounding neighborhood”; and (2) “maximize student safety by relocating all parking on site, creating an all-pedestrian campus…” In addition, splitting the School into two separate locations would disrupt the School’s busing program. As described in Section IV.K, Traffic, Access, and Parking, of the Draft EIR, Archer’s Traffic Management Program requires that 70 percent of the student utilize the fixed-route bus service. Busing students between two locations would add traffic to the area. In addition, splitting the School onto two sites may not reduce environmental impacts due to construction and operation on two sites instead of one.

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III. Responses to Comments C. Topical Responses

16. Environmental Review and Conditional Use Permit Processes

This topical response provides an overview of Archer’s existing Conditional Use Permit (CUP) and the environmental review processes for School facilities.

Existing CUP and Previous Environmental Review Process

In accordance with Section 12.24 of the Los Angeles Municipal Code (LAMC), a CUP allows a municipality to consider uses that may be essential or beneficial to a particular community, but which are not allowed as a matter of right within a specific zone. A CUP is a discretionary approval issued after an environmental review process and a public process. The decision-maker may approve the conditional use in whole or in part, with or without conditions, or deny the application. As described on page IV.H-6 of Section IV.H, Land Use, of the Draft EIR, in accordance with the LAMC, the City of Los Angeles permits educational uses in the RE and R3 zones with the approval of a CUP.

An EIR was prepared that addressed operation of the School under its existing CUP. Specifically, the City of Los Angeles circulated a Notice of Preparation (NOP) for public comment between July 26, 1996, and August 26, 1996. The Draft EIR was circulated for public review for a 45-day public comment period starting on July 3, 1997, and was extended to 87 days, ending September 29, 1997. On June 4, 1998, the City of Los Angeles issued the Final EIR. A public hearing before the Zoning Administrator was conducted on July 9, 1998. On August 21, 1998, the Zoning Administrator certified the EIR (EIR No. 96-0147-CUZ-ZV-YV) and approved the CUP and other concurrent entitlements (ZA 98-0158 (CUZ)(ZV)). The decision of the Zoning Administrator was appealed to the Board of Zoning Appeals, which conducted a public hearing on October 27, 1998. On November 5, 1998, the Board of Zoning Appeals denied the appeal and sustained the decision of the Zoning Administrator. The decision of the Board of Zoning Appeals was appealed to the City Council. On December 8, 1998, the Planning and Land Use Management Committee of the City Council conducted a public hearing. On December 29, 1998, the City Council certified the EIR and approved the CUP and other concurrent entitlements for The Archer School for Girls to operate at the existing campus.

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The existing CUP approved in 1998 includes conditions related to construction and operation of the existing campus. Since the City approved the CUP in 1998, Archer has received four Plan Approvals demonstrating they have been in substantial compliance with the conditions set forth in the existing CUP, as well as receiving approval to modify, delete, or add conditions pursuant to each Plan Approval. These Plan Approvals occurred in January 2001 (ZA 98-0158 (CUZ)(PA1)), October 2004 (ZA 98-0158 (CUZ)(PA2)), November 2007 (ZA 98-0158 (CUZ)(PA3)), and most recently in July 2013 (ZA 98-0158 (CUZ)(PA4)). For each Plan Approval, the Zoning Administrator conducted a public hearing at which members of the public were invited to present oral and written testimony.

Environmental Review and Public Review Process for Project

The Applicant is proposing a new CUP for the Project Site that includes the construction of new facilities and refinements to related school operations. Thus, in accordance with CEQA, a new environmental review process is underway for the Project. The City of Los Angeles prepared an Initial Study and circulated a Notice of Preparation for public comment to the State Clearinghouse, Office of Planning and Research, responsible agencies, and other interested parties for a 30-day review period, beginning January 3, 2012. In addition, a public scoping meeting was conducted on January 18, 2012. In accordance with CEQA, the Draft EIR was initially circulated for a 46-day public comment period beginning February 27, 2014, and ending April 14, 2014. In response to public comments, the comment period was extended an additional 15 days through April 29, 2014, to provide more time for responsible and trustee agencies, as well as the public, to comment on the Draft EIR. This Final EIR is intended to be a companion to the Draft EIR. This Final EIR includes a revised summary; corrections and additions to the Draft EIR; a list of persons, organizations, and agencies commenting on the Draft EIR; responses to comments; and a Mitigation Monitoring and Reporting Program. Although not required by CEQA, this Final EIR will be made available to the public on the Los Angeles Department of City Planning’s website.

Subsequent to completion of the Final EIR, the City of Los Angeles Hearing Officer, on behalf of the City Planning Commission, will conduct a public hearing on the Project at which members of the public will have an opportunity to present oral and written testimony. The Hearing Officer will then make a recommendation to the City Planning Commission. The City Planning Commission, as the initial decision-maker, will conduct a meeting at which members of the public will have an opportunity to present oral and written testimony. The City Planning Commission must find the Project conforms to the purpose and intent of the findings required for a conditional use under the LAMC and, as previously stated above, may approve the conditional use in whole or in part, with or without conditions, or deny the application. The decision of the City Planning Commission is appealable to the City Council. If the decision of the City Planning Commission is appealed, the Planning

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Page III-212 WORKING DRAFT – Not for Public Review III.C Topical Responses and Land Use Management Committee will conduct a public hearing at which members of the public will again have the opportunity to present oral and written testimony. The Project would then be considered by the City Council.

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