Mandarin and English Dual-Language Immersion Elementary School Project EIR Los Angeles Unified School District March 26, 2015
Volume I
Draft Environmental Impact Report Mandarin and English Dual-Language Immersion Elementary School Project
Volume I
Prepared for:
Los Angeles Unified School District Office of Environmental Health and Safety 333 South Beaudry Avenue, 28th Floor Los Angeles, California 90017 Contact: Mr. Edward Paek, CEQA Project Manager
Prepared by:
Sapphos Environmental, Inc. 430 North Halstead Street Pasadena, California 91107 Contact: Ms. Laura Male
March 26, 2015 Table of Contents
Executive Summary
Chapter 1.0 Introduction 1.1 Purpose of the Environmental Impact Report ...... 1-1 1.2 Scope of the EIR ...... 1-2 1.3 EIR Organization ...... 1-4 1.4 Availability of the Draft EIR ...... 1-5 1.5 Public Meetings and Hearings ...... 1-6 1.6 Agency Comments ...... 1-6
Chapter 2.0 Project Description and Environmental Setting 2.1 Project Background and Objectives ...... 2-1 2.1.1 Project Background ...... 2-1 2.1.2 Project Objectives ...... 2-3 2.2 Project Description ...... 2-4 2.2.1 Project Components ...... 2-4 2.2.2 Project Location and Site Characteristics ...... 2-6 2.2.3 Construction Schedule ...... 2-10 2.3 Project Design Features ...... 2-10 2.4 Required Permits and Approvals ...... 2-17 2.4.1 Lead Agency Approval ...... 2-17 2.4.2 Required Permits and Approvals ...... 2-18 2.4.3 Reviewing Agencies ...... 2-18 2.5 Cumulative Scenario ...... 2-20
Chapter 3.0 Environmental Analysis 3.1 Environmental Issues Addressed ...... 3-1 3.2 Organization of Environmental Analysis ...... 3-2 3.3 Terminology Used in this Analysis ...... 3-3
Subchapter 3A Aesthetics 3A.1 Regulatory Framework ...... 3A-1 3A.2 Existing Conditions ...... 3A-3 3A.3 Thresholds of Significance ...... 3A-6 3A.4 Impact Analysis ...... 3A-6 3A.5 Cumulative Impacts ...... 3A-8 3A.6 Mitigation Measures ...... 3A-8 3A.7 Level of Significance after Mitigation ...... 3A-8
Subchapter 3B Agriculture and Forestry Resources 3B.1 Regulatory Framework ...... 3B-2 3B.2 Existing Conditions ...... 3B-3 3B.3 Thresholds of Significance ...... 3B-5 3B.4 Impact Analysis ...... 3B-6 3B.5 Cumulative Impacts ...... 3B-8 3B.6 Mitigation Measures ...... 3B-8 3B.7 Level of Significance after Mitigation ...... 3B-8
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Subchapter 3C Air Quality 3C.1 Regulatory Framework ...... 3C-2 3C.2 Existing Conditions ...... 3C-6 3C.3 Thresholds of Significance ...... 3C-16 3C.4 Impact Analysis ...... 3C-18 3C.5 Cumulative Impacts ...... 3C-22 3C.6 Mitigation Measures ...... 3C-22 3C.7 Level of Significance after Mitigation ...... 3C-22
Subchapter 3D Biological Resources 3D.1 Regulatory Framework ...... 3D-2 3D.2 Existing Conditions ...... 3D-5 3D.3 Thresholds of Significance ...... 3D-14 3D.4 Impact Analysis ...... 3D-15 3D.5 Cumulative Impacts ...... 3D-17 3D.6 Mitigation Measures ...... 3D-17 3D.7 Level of Significance after Mitigation ...... 3D-18
Subchapter 3E Cultural Resources 3E.1 Regulatory Framework ...... 3E-3 3E.2 Existing Conditions ...... 3E-9 3E.3 Thresholds of Significance ...... 3E-18 3E.4 Impact Analysis ...... 3E-19 3E.5 Cumulative Impacts ...... 3E-21 3E.6 Mitigation Measures ...... 3E-22 3E.7 Level of Significance after Mitigation ...... 3E-22
Subchapter 3F Geology and Soils 3F.1 Regulatory Framework ...... 3F-3 3F.2 Existing Conditions ...... 3F-6 3F.3 Thresholds of Significance ...... 3F-9 3F.4 Impact Analysis ...... 3F-10 3F.5 Cumulative Impacts ...... 3F-13 3F.6 Mitigation Measures ...... 3F-14 3F.7 Level of Significance after Mitigation ...... 3F-14
Subchapter 3G Greenhouse Gas Emissions 3G.1 Regulatory Framework ...... 3G-4 3G.2 Existing Conditions ...... 3G-7 3G.3 Thresholds of Significance ...... 3G-8 3G.4 Impact Analysis ...... 3G-8 3G.5 Cumulative Impacts ...... 3G-9 3G.6 Mitigation Measures ...... 3G-10 3G.7 Level of Significance after Mitigation ...... 3G-10
Subchapter 3H Hazards and Hazardous Materials 3H.1 Regulatory Framework ...... 3H-2 3H.2 Existing Conditions ...... 3H-6 3H.3 Thresholds of Significance ...... 3H-12
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3H.4 Impact Analysis ...... 3H-13 3H.5 Cumulative Impacts ...... 3H-17 3H.6 Mitigation Measures ...... 3H-17 3H.7 Level of Significance after Mitigation ...... 3H-17
Subchapter 3I Hydrology and Water Quality 3I.1 Regulatory Framework ...... 3I-3 3I.2 Existing Conditions ...... 3I-7 3I.3 Thresholds of Significance ...... 3I-9 3I.4 Impact Analysis ...... 3I-10 3I.5 Cumulative Impacts ...... 3I-15 3I.6 Mitigation Measures ...... 3I-15 3I.7 Level of Significance after Mitigation ...... 3I-15
Subchapter 3J Land Use and Planning 3J.1 Regulatory Framework ...... 3J-1 3J.2 Existing Conditions ...... 3J-8 3J.3 Thresholds of Significance ...... 3J-9 3J.4 Impact Analysis ...... 3J-9 3J.5 Cumulative Impacts ...... 3J-10 3J.6 Mitigation Measures ...... 3J-10 3J.7 Level of Significance after Mitigation ...... 3J-10
Subchapter 3K Mineral Resources 3K.1 Regulatory Framework ...... 3K-1 3K.2 Existing Conditions ...... 3K-2 3K.3 Thresholds of Significance ...... 3K-3 3K.4 Impact Analysis ...... 3K-3 3K.5 Cumulative Impacts ...... 3K-4 3K.6 Mitigation Measures ...... 3K-4 3K.7 Level of Significance after Mitigation ...... 3K-4
Subchapter 3L Noise 3L.1 Regulatory Framework ...... 3L-6 3L.2 Existing Conditions ...... 3L-10 3L.3 Thresholds of Significance ...... 3L-14 3L.4 Impact Analysis ...... 3L-16 3L.5 Cumulative Impacts ...... 3L-19 3L.6 Mitigation Measures ...... 3L-19 3L.7 Level of Significance after Mitigation ...... 3L-20
Subchapter 3M Pedestrian Safety 3M.1 Regulatory Framework ...... 3M-1 3M.2 Existing Conditions ...... 3M-2 3M.3 Thresholds of Significance ...... 3M-5 3M.4 Impact Analysis ...... 3M-5 3M.5 Cumulative Impacts ...... 3M-8 3M.6 Mitigation Measures ...... 3M-8 3M.7 Level of Significance after Mitigation ...... 3M-9
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Subchapter 3N Population and Housing 3N.1 Regulatory Framework ...... 3N-1 3N.2 Existing Conditions ...... 3N-2 3N.3 Thresholds of Significance ...... 3N-5 3N.4 Impact Analysis ...... 3N-5 3N.5 Cumulative Impacts ...... 3N-7 3N.6 Mitigation Measures ...... 3N-7 3N.7 Level of Significance after Mitigation ...... 3N-7
Subchapter 3O Public Services 3O.1 Regulatory Framework ...... 3O-1 3O.2 Existing Conditions ...... 3O-3 3O.3 Thresholds of Significance ...... 3O-9 3O.4 Impact Analysis ...... 3O-10 3O.5 Cumulative Impacts ...... 3O-12 3O.6 Mitigation Measures ...... 3O-12 3O.7 Level of Significance after Mitigation ...... 3O-12
Subchapter 3P Recreation 3P.1 Regulatory Framework ...... 3P-1 3P.2 Existing Conditions ...... 3P-2 3P.3 Thresholds of Significance ...... 3P-5 3P.4 Impact Analysis ...... 3P-5 3P.5 Cumulative Impacts ...... 3P-7 3P.6 Mitigation Measures ...... 3P-7 3P.7 Level of Significance after Mitigation ...... 3P-7
Subchapter 3Q Transportation/Traffic 3Q.1 Regulatory Framework ...... 3Q-2 3Q.2 Existing Conditions ...... 3Q-6 3Q.3 Thresholds of Significance ...... 3Q-13 3Q.4 Impact Analysis ...... 3Q-14 3Q.5 Cumulative Impacts ...... 3Q-16 3Q.6 Mitigation Measures ...... 3Q-19 3Q.7 Level of Significance after Mitigation ...... 3Q-19
Subchapter 3R Utilities and Service Systems 3R.1 Regulatory Framework ...... 3R-3 3R.2 Existing Conditions ...... 3R-6 3R.3 Thresholds of Significance ...... 3R-7 3R.4 Impact Analysis ...... 3R-8 3R.5 Cumulative Impacts ...... 3R-12 3R.6 Mitigation Measures ...... 3R-12 3R.7 Level of Significance after Mitigation ...... 3R-12
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Chapter 4.0 Alternatives 4.1 Introduction and Overview ...... 4-1 4.2 Alternatives to the Proposed Project ...... 4-2 4.2.1 No Project Alternative ...... 4-4 4.2.2 Alternative Location at Marina Del Rey Middle School ...... 4-7 4.2.3 Reduced Project Alternative ...... 4-12 4.2.4 Redistricting Alternative ...... 4-15 4.3 Alternatives Eliminated from Further Consideration ...... 4-17 4.4 Environmentally Superior Alternative ...... 4-21
Chapter 5.0 Other CEQA Considerations 5.1 Environmental Effects Found Not to Be Significant ...... 5-1 5.2 Significant Irreversible Environmental Changes ...... 5-1 5.3 Growth-Inducing Impacts ...... 5-3 5.4 Significant and Unavoidable Environmental Impacts ...... 5-4
Chapter 6.0 Acronyms and Abbreviations ...... 6-1
Chapter 7.0 References ...... 7-1
Chapter 8.0 Report Preparation
8.1 Report Preparers ...... 8-1 8.2 Organizations and Persons Consulted ...... 8-2
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List of Tables
TABLE PAGE
ES-1 Summary of Environmental Impacts ...... ES-6 ES-2 Summary of Mitigation Measures ...... ES-8 2.3-1 Project Design Features ...... 2-10 2.5-1 List of Related Projects: LADOT Record of Proposed Projects ...... 2-21 3.1-1 Summary of Environmental Impacts ...... 3-1 3C.1-1 Ambient Air Quality Standards for Criteria Pollutants ...... 3C-3 3C.2-1 Average Temperatures in the Vicinity of the Proposed Project Site ...... 3C-8 3C.2-2 Project Area Air Pollutant Summary, 2010–2014 ...... 3C-10 3C.3-1 SCAQMD Air Quality Significance Thresholds ...... 3C-16 3C.4-1 Localized (On-Site) Construction Impacts ...... 3C-19 3C.4-2 Operational Emissions ...... 3C-19 3D.2-1 Federally and State-Listed Species with the Potential to Occur on the Proposed Project Site ...... 3D-6 3D.2-2 Sensitive Animal Species with the Potential to Occur on the Proposed Project Site ...... 3D-8 3D.2-3 Locally Important Plant Species with the Potential to Occur on the Proposed Project Site ...... 3D-12 3F.2-1 Active Fault Zones in LAUSD South Zone...... 3F-7 3G-1 Greenhouse Gases and Their Relative Warming Potential Compared to CO2 .... 3G-3 3G.1-1 California Business-as-Usual GHG Emissions and Targets ...... 3G-5 3H.2-1 Properties within One-Quarter Mile with the Potential to Handle Hazardous Materials ...... 3H-10 3J.1-1 Civic Center Organizations and Uses ...... 3E-5 3L-1 Change in Apparent Loudness ...... 3L-3 3L-2 Human Reaction to Typical Vibration Levels ...... 3L-5 3L.1-1 City of Los Angeles Ambient Noise Criteria ...... 3L-8 3L.1-2 Acceptable Operational Noise Levels Established by LAUSD ...... 3L-9 3L.1-3 Project Design Feature Compliance Thresholds ...... 3L-9 3L.2-1 Typical Noise Levels for Los Angeles County ...... 3L-11 3L.2-2 Measured Total Ambient Noise Levels on andaround the Proposed Project Site ...... 3L-12 3L.2-3 Measured Baseline Ambient Noise Levels on and around the Proposed Project Site ...... 3L-13 3L.2-4 Airports in the Vicinity of the Proposed Project ...... 3L-14 3L.2-5 Typical Outdoor Construction Noise Levels ...... 3L-17 3M.2-1 Existing Peak Hour Level of Service Summary ...... 3M-3 3M.2-2 Major Arterial Roadways and Freeways in the Project Vicinity ...... 3M-5 3M.4-1 Future Peak-Hour Level of Service Summary (with Project) ...... 3M-6 3N.2-1 SCAG 2020 Population and Households Projections for LAUSD Local District D ...... 3N-3 3N.2-2 Palms – Mar Vista – Del Rey Community Plan Area Population, 2000–2009 ...... 3N-3 3N.2-3 Palms – Mar Vista – Del Rey Community Plan Area Households, 2000–2009 ...... 3N-4 3O.2-1 Existing Fire Stations Serving the Proposed Project Site ...... 3O-4
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3O.2-2 K–12 Public School Enrollment ...... 3O-6 3O.2-3 Existing Parks in the Proposed Project Vicinity ...... 3O-7 3O.2-4 Existing Libraries in the Project Vicinity ...... 3O-9 3Q-1 Volume/Capacity and Corresponding Level of Service ...... 3Q-2 3Q.2-1 Study Area Roadway Descriptions ...... 3Q-8 3Q.2-2 Existing Peak-Hour Level of Service Summary ...... 3Q-11 3Q.2-3 Proposed Project Trip Generation ...... 3Q-12 3Q.2-4 Transit Service Summary...... 3Q-12 3Q.3-1 LADOT Intersection Significance Threshold ...... 3Q-13 3Q.5-1 Projected Impact Summary for Future Baseline Conditions ...... 3Q-17 3Q.5-2 Change in V/C for Future Conditions ...... 3Q-18 4.2-1 Summary of Ability of Proposed Project and Alternatives to Attain Project Objectives ...... 4-3 4.3-1 Alternative Sites Considered but Determined to Be Infeasible ...... 4-18 4.4-1 Summary of Impacts ...... 4-22 4.4-2 Comparison of Alternatives to the Proposed Project ...... 4-23 8.1 List of Preparers and Reviewers ...... 8-1
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List of Figures
FIGURE FOLLOWS PAGE
2.1-1 Regional Site Map ...... 2-1 2.2.1-1 Local Vicinity Map ...... 2-4 2.2.1-2 Site Plan ...... 2-4 2.2.2-1 Regional Vicinity Map ...... 2-6 2.2.2-2 USGS 7.5-Minute Quadrangle Topographic Map ...... 2-6 2.2.2-3 Aerial Photograph ...... 2-6 2.2.2-4 City of Los Angeles General Plan Land Use Designation ...... 2-7 2.2.2-5 Zoning Designation Map ...... 2-8 2.2.2-6 Palms-Mar Vista - Del Rey Community Plan Area ...... 2-8 2.5-1 Map of Related Projects ...... 2-20 3A.2-1 Unique Urban & Historic Features ...... 3A-4 3A.2-2 State, County, & City Designated Scenic Highways...... 3A-4 3A.2-3 Key Observation Points ...... 3A-5 3A.2-4 Key Observation Point Map ...... 3A-5 3F.2-1 Active Alquist-Priolo Fault Zones in Proposed Project Vicinity ...... 3F-6 3I.2-1 Storm Drains in the Vicinity of the Proposed Project ...... 3I-8 3L.2-1 Sensitive Receptors in the Vicinity of the Proposed Project ...... 3L-14 3L.2-2 Airports in the Vicinity of the Proposed Project ...... 3L-14 3L.6-1 Sound Barrier ...... 3L-19 3M.2-1 Pedestrian Safety Existing Conditions ...... 3M-4 3M.2-2 Pedestrian Routes for Beethoven Elementary School ...... 3M-4 3M.2-3 Pedestrian Routes for Mark Twain Middle School ...... 3M-4 3O.2-1 Public Facilities in Vicinity of Proposed Project Site ...... 3O-3 3P.2-1 Parks and Recreation ...... 3P-4 3Q.2-1 Traffic Study Area Map ...... 3Q-8
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List of Appendices
Volume II
A Notice of Preparation B Comments on Notice of Preparation C CalEEMod Model for LAUSD Mandarin and English Dual-Language Immersion School D Historic Resources Assessment E Geotechnical Evaluation
Volume III
F Phase I Environmental Site Assessment
Volume IV
G Phase I Environmental Site Assessment Addendum
Volume V
H Traffic Impact Study I Impact Analysis for Alternative Location Project Alternative at Marina Del Rey Middle School J Draft EIR Distribution List
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ix Draft EIR EXECUTIVE SUMMARY
Los Angeles Unified School District (LAUSD) is proposing to relocate the existing Mandarin and English Dual-Language Immersion Elementary School Program that has, since 2010, been located at Broadway Elementary School to a portion of the Mark Twain Middle School campus to serve students within the Mandarin and English Dual-Language Program (Program) in kindergarten through fifth grade and provide approximately 336 new seats in addition to the approximately 231 seats in existing classrooms to support the Program’s total projected enrollment of 567 on a consolidated site. Dual-language programs (also known as two-way immersion programs) allow English learners and English proficient students to receive instruction in English and a target language in the same classroom to develop academic proficiency in both languages beginning in kindergarten for a minimum of 6 years. LAUSD currently offers students at selected schools the option of participating in a Spanish/English, Korean/English, or Mandarin/English dual-language program.1 The Program was initiated at Broadway Elementary School, and is part of the world language instructional pathways initiative in the Venice High School complex that includes Venice High School and its elementary and middle feeder schools. Currently, the Program has 365 students enrolled in kindergarten through fourth grade; however, the program is designed to expand through fifth grade. The total projected enrollment is 567 students. Broadway Elementary School also operates a Spanish and English dual-language immersion program and a traditional instructional program. The proposed Mandarin and English Dual-Language Immersion Elementary School Project (proposed project) would involve the construction of new buildings and new facilities and improvements to eight existing portable classrooms at Mark Twain Middle School, in the community of Mar Vista, within the City of Los Angeles in the County of Los Angeles, California. The proposed project is intended to relieve school overcrowding at Broadway Elementary School and allow for consolidation of the Mandarin and English Dual-Language Program at Mark Twain Middle School and enable the expansion of the existing traditional instructional program and Spanish and English Immersion Program at Broadway Elementary School. Implementation of the proposed project is intended to fulfill eight objectives:
1. Provide educational facilities dedicated to the Program for kindergarten through fifth grade;
2. Consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitate a learning environment that is conducive to an immersion Program;
1 Los Angeles Unified School District Website. Accessed March 2015. http://notebook.lausd.net/portal/page?_pageid=33,230293&_dad=ptl
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-1 Draft EIR Executive Summary
3. Build and maintain a school that reflects the wise and efficient use of limited District Bond Funds and General Funds;
4. Build and maintain a school that reflects the wise and efficient use of limited land and public resources;
5. Maintain the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program;
6. Enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School;
7. Comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school; and
8. Provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program, allowing acceptance of up to 4 classes of kindergarten students every year.
This Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines. It provides an overview of the proposed project and considered alternatives, identifies the potentially significant environmental impacts from the proposed project and the alternatives, and identifies mitigation measures designed to reduce potentially significant impacts to below the level of significance. Purpose of the EIR
The primary purpose of CEQA is to inform the public and decision makers as to the potential impacts of a project and to allow an opportunity for public input to ensure informed decision making. CEQA requires all state and local government agencies to consider the environmental effects of projects over which they have discretionary authority. CEQA also requires each public agency to mitigate or avoid the significant environmental impacts resulting from proposed projects, when feasible, and to identify a range of feasible alternatives to the proposed project that could reduce or avoid those environmental effects.
Under CEQA, a project EIR analyzes the impacts of an individual activity or specific project and focuses primarily on changes in the physical environment that would result from the activity or project. The EIR must include the contents required by CEQA and examine all phases of the project, including planning, construction, operation, and any reasonably foreseeable future phases. Project Location and Setting
The proposed project site is located in the City of Los Angeles, within the community of Mar Vista. The proposed project site is located on the northeastern portion (approximately 4.2 acres) of the existing 21.3-acre Mark Twain Middle School campus (2224 Walgrove Avenue, Los Angeles, California 90066 in the City of Los Angeles, within the County of Los Angeles). The proposed project site is located approximately 0.2 mile northwest of State Route 187, 0.6 mile northeast of
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-2 Draft EIR Executive Summary
State Route 1, 1.1 miles north of State Route 90 (Marina Freeway), 1.6 miles southwest of Interstate 405, and 1.8 miles south of Interstate 10.
The proposed project site is currently occupied by eight existing portable classrooms (0.2 acre), a 0.1-acre asphalt walkway north of the classrooms, 0.1 acre of sidewalk along Victoria Avenue, 1.9 acres of asphalt with painted parking stalls and a painted track, and 1.9 acres of an athletic field for a total of approximately 4.2 acres on the existing Mark Twain Middle School campus, which encompasses a total of 21.3 acres. There are 10 structures located within the proposed project site that would remain on-site (including the eight portable classrooms). Only one tree, an ornamental Chinese elm tree (Ulmus parvifolia), is situated within the proposed project site, at the northwestern end of the athletic field, adjacent to Victoria Avenue. A segment of east-trending Victoria Avenue would be widened to incorporate a 12-foot-wide drop-off area as part of the proposed project.
The proposed project site lies within an urbanized area and is characterized by a mixture of asphalt and turf athletic facilities and portable classrooms.2 Specifically, land uses north of the proposed project site, across Victoria Avenue, include single-family and multi-family residences; land uses east of the site consist of Beethoven Elementary School and, across Beethoven Street, single-family residences and multi-family residences; land uses south of the site, across the remaining Mark Twain Middle School Campus and Lucille Avenue, consists of single-family residences; and land uses west of the site, across Walgrove Avenue, consist of single-family residences.
The proposed project site is located within the Palms – Mar Vista – Del Rey Community Plan Area, which is one of 35 community planning areas that makes up the Land Use Element for the City of Los Angeles General Plan.3,4 The current land use designation of the approximately 4.2 acres is Public Facilities. The California Legislature granted school districts the power to exempt their school construction projects from applicable general plans and zoning requirements, provided the school district complies with the terms of Government Code Section 53094. On October 11, 2005, the LAUSD Board of Education (Board) adopted a resolution on the basis of Government Code Section 53094 exempting zoning designation for the proposed project.5 It is anticipated that the Board would adopt a new resolution under Section 53094 prior to certification of this project’s Final EIR to ensure that the exemption would extend to the proposed project. As such, the proposed project would be consistent with all general plan and zoning designations.
2 Sapphos Environmental, Inc. 2 October 2014. Site visit. 3 City of Los Angeles City Planning Department. June 27, 2007. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available online at: http://cityplanning.lacity.org/ Palms – Mar Vista – Del Rey Community Plan available online at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 4 City of Los Angeles Department of City Planning. Accessed December 2014. Website. “Zimas Zone Information and Map Access System.” Available at: http://zimas.lacity.org/ 5 Los Angeles Unified School District Board of Education. 11 October 2005. “Resolution by the Los Angeles Unified School District Rendering Specified City and County Zoning Ordinances Inapplicable to the District’s Acquisition and Use of Property for Designated Schools Pursuant to Government Code Section 53094 and Making Findings of Fact Related Thereto.” Reference Board of Education Report No. 69-05/06.
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Project Description
The proposed project would consist of new buildings that would be one to two stories in height of approximately 30 feet to the top of the highest roof and approximately 35 feet to the top of the mechanical screens on the two-story classroom buildings. This building would encompass approximately 33,000 square feet in area. The proposed project would also include the widening of the eastbound side of Victoria Avenue to accommodate a student drop-off area; and modification to the eight existing portable classrooms (approximately 7,680 square feet), which lie within an approximately 4.2-acre portion (proposed project site) of the 21.3-acre Mark Twain Middle School campus adjacent to Beethoven Elementary School, located south of Victoria Avenue. The proposed project would also include construction of designated elementary and kindergarten play areas (approximately 1.7 acres); designated student drop-off and parking areas (approximately 70 parking stalls, including replacement parking of existing parking areas serving Mark Twain Middle School); construction of a new multi-purpose room (MPR); new food services and lunch shelter facilities; and furnishing and equipping with grade appropriate desks, chairs, and equipment. No existing buildings would be demolished as a result of the proposed project.
Student drop-off and pick-up, as well as loading and unloading for passenger cars and buses, for the existing Mark Twain Middle School campus would remain along Walgrove Avenue, Lucille Avenue, and the western portion of Victoria Avenue. An additional right-turn lane would be constructed on Walgrove Avenue to reduce traffic impacts from buses and commuters turning onto Victoria Avenue in order to ensure that this access is appropriate for the anticipated increase in use.
Approximately 70 parking spaces would be provided for faculty and staff of the elementary school, including replacement parking for existing Mark Twain Middle School parking spaces that would be removed; these spaces would be accessed from Victoria Avenue. During school operating hours, the parking lot would be available for faculty and staff use; visitors would be required to park off-site. The parking area may be available for after-school, district-sponsored events, and community events.
The proposed project design would conform to the requirements of the Americans with Disabilities Act (ADA), Division of the State Architect (DSA), CEQA, and any other required improvements or mitigations to ensure compliance with local, state, and/or federal facilities requirements. The proposed project would implement all Collaborative for High Performance Schools (CA-CHPS 2009) Criteria, LAUSD design standards, and best management practices into the development of the proposed project.6,7 Implementation of these measures address project-related concerns (from both construction and operation of the proposed project) and would significantly reduce the impact of the proposed project on the environment and surrounding community.
6 Collaborative for High Performance Schools. 2009. California Criteria for High Performance Schools Best Practices Manual. Volume III. 2009 Edition. Available at: http://www.chps.net/manual/index.htm 7 Los Angeles Unified School District. 28 October 2003. Los Angeles City Board of Education Resolution, Sustainability and the Design and Construction of High Performance Schools. Los Angeles, CA. Available at: http://www.laschools.org/documents/download/sustainability%2Fhealthy_schools%2FBoard_Resolution_on_C HPS.pdf
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Areas of Known Controversy
Nine areas of controversy are known to LAUSD as a result of scoping and community outreach efforts:
Potential for traffic increase as a result of more students at Mark Twain Middle School (addressed in Section 3Q, Transportation and Traffic)
Pedestrian and bicyclist safety on narrow streets with increased traffic (addressed in Section 3Q)
Reduction of playground or open space from development of parking for the proposed project (addressed in Section 3P, Recreation)
Impacts on availability of public sports fields in the community due to removal of one half of the playable field space on the east side of Mark Twain Middle School (addressed in Section 3P)
The use of the Mark Twain Middle School campus as a site for the Mandarin Immersion Program instead of Broadway Elementary School (addressed in Section 4.0, Alternatives Analysis)
Perceived incompatibility of elementary school on a middle school campus (addressed in Section 2.0, Project Description)
Potential impacts on ambient noise levels from expanded school programs during the weekdays and weekends (addressed in Section 3L, Noise)
Opposition to construction and operation of new buildings rather than accommodating the Program in existing school facilities (addressed in Section 4.0)
Preference for funds allocated to the proposed project be redirected to improvements of existing neighborhood schools (addressed in Sections 2.0 and 4.0) Issues to Be Resolved
The analysis undertaken in support of this EIR determined that the proposed project would result in no impact or less than significant impacts for 14 environmental issue areas: Aesthetics, Agriculture and Forestry Resources, Air Quality, Biological Resources, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Population and Housing, Public Services, Recreation, and Utilities and Service Systems. Four environmental issues were identified with the potential for significant impacts, thus requiring the consideration of mitigation measures and alternatives: Cultural Resources, Noise, Pedestrian Safety, and Transportation and Traffic.
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Proposed Project Impacts
This EIR addresses those environmental impact categories identified by LAUSD as having potentially significant impacts in Section 3.0, Environmental Analysis. Input provided by interested parties, including community residents and public agencies, during the public review period for the NOP were also taken into account. Environmental factors are listed by the level of significance of their impacts in Table ES-1, Summary of Environmental Impacts.
Table ES-1: Summary of Environmental Impacts No Impact Less than Significant Impact Potentially Significant Impact Agriculture and Forestry Resources Aesthetics Cultural Resources Hazards and Hazardous Materials Air Quality Noise Land Use and Planning Biological Resources Pedestrian Safety Mineral Resources Geology and Soils Transportation and Traffic Population and Housing Greenhouse Gas Emissions Hydrology and Water Quality Public Services Recreation Utilities and Service Systems
Unavoidable Adverse Impacts
Based on the analysis contained within this EIR, it has been determined that implementation of the proposed project would result in significant and unavoidable impacts to transportation and traffic, based on traffic volumes and calculated levels of service and volume-to-capacity ratios at six intersections, as a result of additional trips associated with operation of the proposed project at the existing Mark Twain Middle School, during AM and PM peak hours.
Project design features and mitigation measures have been recommended that would reduce impacts related to cultural resources, noise, and pedestrian safety to a less than significant level based on each set of significance criteria.
There were no anticipated significant impacts that require the evaluation of mitigation measures related to aesthetics, agriculture and forestry resources, air quality biological resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, public services, recreation, or utilities and service systems.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-6 Draft EIR Executive Summary
Cumulative Impacts
A list of 18 related present and reasonably foreseeable future projects within the vicinity of the proposed project was developed based upon information supplied by the City of Los Angeles Department of Transportation to evaluate cumulative impacts. The proposed project would result in cumulatively considerable impacts with respect to transportation and traffic. Cumulative impacts are discussed in detail within each issue area section for he proposed project. Growth-Inducing Impacts
The proposed project would not induce more growth. Rather, development of the proposed project would accommodate the population growth that has already occurred within the surrounding area, which is anticipated to continue in the near future. Mitigation Measures
Table ES-2, Summary of Mitigation Measures, provides a summary of the mitigation measures presented in this EIR.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-7 Draft EIR Executive Summary
Table ES-2: Summary of Mitigation Measures Impact Significance Mitigation Measure(s) Level of Significance after Mitigation Cultural Resources Impact 3B-c: Destroy a unique paleontological resource or site or Potentially significant MM Cultural-1: Paleontological Resources Sensitivity Training will be provided for all project personnel prior to the start of ground-disturbing Less than significant unique geologic feature activities. Should a potentially unique paleontological resource be encountered, a qualified paleontologist, as defined by the Society of Vertebrate Paleontology’s Impact Mitigation Guidelines, shall be contacted to assess the find. All significant specimens collected shall be appropriately prepared, identified, and catalogued prior to their placement in a permanent accredited repository. At the conclusion of ground- disturbing activities, a mitigation report will be prepared documenting the results of the paleontological resources monitoring. Impact 3B-d: Disturb any human remains, including those interred Potentially significant MM Cultural-2: In the event of unanticipated discovery of human remains, the Los Angeles County Coroner shall be notified within 24 hours Less than significant outside of formal cemeteries of the discovery of human remains and there shall be no further excavation or disturbance of the site or any of that area reasonably suspected to overlie adjacent human remains until the Coroner has determined that no investigation of the cause of death is required. Additionally, if the remains are of Native American origin, interested Native American groups or individuals will be contacted to make recommendations to LAUSD for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods. Noise Impact 3F-a: Exposure of persons to or generation of noise levels in Potentially significant MM Noise 1: LAUSD shall incorporate a sound barrier between the proposed project site and adjacent sensitive receptors to reduce noise Less than significant excess of standards established in the local general plan or noise levels to meet jurisdictional standards or result in an increase in 3dB or less over ambient noise levels established in the existing conditions. ordinance, or applicable standards of other agencies. MM Noise 2: LAUSD shall consult and coordinate with the site administrator or school principal prior to construction to schedule high noise or vibration producing activities to minimize disruption. This may include doing such noise or vibration producing activities after school hours or in coordination with the school schedule to minimize the exposure of students to noise or vibration impacts while in classrooms. Coordination shall continue on an as needed basis throughout the construction phase of the project to reduce school and other sensitive receptor disruptions.
MM Noise 3: LAUSD shall require its construction contractor to provide advance notice of the start of construction to all noise sensitive receptors, including residences and schools adjacent to the proposed project site. The announcement shall state specifically where and when construction activities will occur, and shall provide contact information for filing noise complaints with the contractor and the District. In the event of noise complaints, LAUSD shall monitor noise from the construction activity to ensure that construction noise does not exceed limits specified in the noise ordinance.
MM Noise 4: LAUSD shall require the construction contractor to locate, store, and maintain portable equipment as far as possible from the adjacent residents and other sensitive receptors.
MM Noise 5: LAUSD shall require compliance with the applicable noise ordinances of the affected city and county jurisdiction in the construction contracts. Impact 3F-b: Exposure of persons to or generation of excessive ground Potentially significant See MM Noise 2 above, which will be implemented, along with MM Noise 6 and 7, to reduce this impact to below the level of significance. Less than significant borne vibration or ground borne noise levels. MM Noise 6: If feasible, impact tools (e.g., jack hammers, pavement breakers, and rock drills) used for construction activities shall be hydraulically or electrically powered wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools. Where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used. External jackets on the tools themselves shall be used. Quieter procedures, such as use of drills rather than impact tools, shall be used.
MM Noise 7: The construction contractor shall select non-impact demolition and/or construction methods, such as removal for off-site demolition or hydraulic jack splitting, and use pavement breakers and vibratory rollers and packers near sensitive receptors.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-8 Draft EIR Executive Summary
Table ES-2: Summary of Mitigation Measures Impact Significance Mitigation Measure(s) Level of Significance after Mitigation Impact 3F-d: A substantial temporary or periodic increase in ambient Potentially significant See MM Noise 1, 2, 3, 4, and 5 above, which will be implemented to reduce this impact from the construction phase of the proposed project Less than significant noise levels in the project vicinity above levels existing without the to below the level of significance. project. Pedestrian Safety PS-1: Vehicle Access: Substantially increase vehicular and/or Potentially significant MM Trans/Traffic 1: Restriping of the westbound approach at the intersection of Walgrove Avenue and Rose Avenue to provide a Less than significant pedestrian safety hazards due to a design feature or incompatible uses. left/through lane and right-turn lane, including prohibition of on-street parking within vicinity of approach.
MM Trans/Traffic 2: Restriping of the northbound and southbound approach at the intersection of Beethoven Street and Venice Boulevard to provide a left-turn lane and shared-through/right lane, including prohibition of on-street parking within vicinity of approach.
MM Trans/Traffic 3: Install a new traffic signal at the intersection of Walgrove Avenue and Washington Boulevard with protected permissive, or a left turn signal with five lights (red, yellow, green, yellow arrow, green arrow) that allows left turns to be made as protected movements (opposite movement receives a red indication) with the green arrow indication, and then through gaps in traffic as permitted movements during the “green ball” indication portion of the cycle, at the eastbound approach.
MM Trans/Traffic 4: Restriping of the northbound approach at the intersection of Beethoven Street and Washington Boulevard to provide a left-turn lane and right/through lane, including prohibition of on-street parking within vicinity of approach. Transportation and Traffic Impact 3Q-a: Conflict with an applicable plan, ordinance or policy Potentially significant See MM Trans/Traffic 1, 2, 3, and 4, which will be implemented to reduce this impact. Significant and unavoidable establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? Impact 3Q-b: Conflict with an applicable congestion management Potentially significant See MM Trans/Traffic 1, 2, 3, and 4, which will be implemented to reduce this impact. Significant and unavoidable program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-9 Draft EIR Executive Summary
Alternatives to the Proposed Project
As a result of the project formulation process, LAUSD evaluated a reasonable range of alternatives to the proposed project to assess their ability to meet most of the objectives of the project and reduce significant effects of the proposed project. Alternative projects recommended by the scoping process were evaluated as related to the project objectives and their ability to reduce significant impacts as described in Section 4.0, Alternatives Analysis, of this EIR. Six alternatives have been considered, including two not carried forward for detailed evaluation. Four project alternatives have been evaluated in this EIR with the detail required by CEQA, including the No Project Alternative required pursuant to CEQA.
No Project
The No Project Alternative would result in the continuation of existing conditions at the proposed project site. The Program would remain on a split campus between Broadway Elementary School and Mark Twain Middle School and/or the District would have to restrict the Program’s enrollment. The existing capacity and facilities at both campuses would remain the same. The proposed project site would remain as asphalt and turf athletic facilities and eight portable classrooms, as described in Chapter 2.0, Project Description and Environmental Setting. Unlike the proposed project (which would result in no impacts to 5 environmental issue areas, less than significant impacts to 9 issue areas, and potentially significant impacts to 4 issue areas), this alternative would result in no significant impacts for 17 environmental issue areas, less than significant impacts for 1 issue area (public services – schools), and potentially significant impacts for 0 issue areas. Compared to the proposed project, the No Project Alternative is environmentally superior in all of the environmental issue areas assessed in this EIR. Under this alternative, the site would remain unchanged, at least in the near future. As a result, this alternative would not induce the impacts associated with the proposed project. The No Project Alternative, however, would meet only three of the eight project objectives:
Maintaining the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators, engaged in the Program;
Complying with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school; and
Providing sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to 4 classes of kindergarten students every year.
Under the No Project Alternative, five of the eight objectives of the project would not be met:
This alternative would not provide educational facilities dedicated to the Program for kindergarten through fifth grade;
It would not consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program;
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-10 Draft EIR Executive Summary
It would not result in the building and maintaining of a school that reflects the wise and efficient use of limited District Bond Funds and General Funds;
It would not result in the building of a school that reflects the wise and efficient use of limited land and public resources; and
It would not enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School.
Alternative Location at Marina Del Rey Middle School Alternative
Marina Del Rey Middle School has been considered a feasible alternative site, due to its location within the Venice High School complex of schools and potential for development. Under this alternative, the Program would move to the Marina Del Rey Middle School campus and utilize 23 new classrooms that would be constructed on land currently occupied by outdoor recreation facilities. As the Marina Del Rey Middle School campus does not have any available classrooms that could be modified to support the Program, this alternative would require constructing 23 new classrooms instead of the 15 classrooms proposed for the proposed project and constructing all of the same support and core facilities as proposed for the proposed project. Under this alternative, more and larger buildings (an approximately 25 percent increase in building footprint) would be required for operation of the Program than for the proposed project. No existing buildings would be demolished as a result of this alternative. Only five of the eight objectives would be met under this alternative:
Provide educational facilities dedicated to the Program for kindergarten through fifth grade;
Consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program;
Maintain the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program;
Comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school; and
Provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year.
This alternative would not meet the proposed project’s objectives of building and maintaining a school that reflects the wise and efficient use of limited District Bond Funds and General Funds, building and maintaining a school that reflects the wise and efficient use of limited land and public resources; or enabling the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School, which exists at Mark Twain Middle School and Venice High School. It would be more expensive than the proposed project because 23 new classrooms would be constructed instead of Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-11 Draft EIR Executive Summary constructing only 15 classrooms and modernizing 8 classrooms to support the entire student population for the Program. The net loss of recreational facilities is greater with this project because there are 0.8 acres less of existing recreational facilities at Marina Del Rey Middle School than those available at Mark Twain Middle School campus, and the Marina Del Rey Middle School requires a larger footprint, due to the increased number of classrooms, thus exacerbating and increasing the net loss of open space and recreational facilities. Similar to the proposed project, this alternative would result in no significant impacts for 6 issue areas (agriculture and forestry resources, biological resources, hazards and hazardous materials, land use and planning, mineral resources, population and housing), less than significant impacts for 8 issue areas (aesthetics, air quality, geology and soils, greenhouse gas emissions, hydrology and water quality, public services, recreation, and utilities and service systems), and potentially significant impacts for 4 issue areas (cultural resources, noise, pedestrian safety, and transportation and traffic), 3 of which would be reduced to below the level of significance with the incorporation of mitigation measures (Appendix I, Impact Analysis for Alternative Location Project Alternative at Marina Del Rey Middle School). Implementation of this alternative would not create new impacts that are not associated with the proposed project. As with the proposed project, this alternative would result in significant and unavoidable impacts to traffic related to reduction in level of service and compromised volume/capacity ratio for six intersections.
Reduced Project Alternative
This alternative would involve providing 50 percent less classroom space at Mark Twain Middle School for the Program by reducing the enrollment of the Program to accept only two classes in kindergarten every school year, as opposed to the four classes of kindergarteners included in the proposed project. This alternative would require constructing five new classrooms, modernizing eight existing classrooms in portables, and constructing all of the same support and core facilities as proposed in the Project. The total projected enrollment for the Program would be reduced by 50 percent from 567 to 283. Under the Reduced Project Alternative, the same amount of construction- related activities would occur as those activities required for the proposed project, for an approximately 33 percent reduction in the footprint of new buildings. Only five of the eight objectives of the project would be met under this alternative because this alternative:
Would not consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program;
Would not enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School; and
Would not provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year.
This alternative would not provide a full 50/50 model of Mandarin dual-language instruction that requires collaboration among instructors within and across grade levels; where older students and younger students benefit from mentoring; resources are shared for K–5 and 6–8 programs, such as books, recorded material, tutoring, and after school programs; and the world language instructional Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-12 Draft EIR Executive Summary pathways initiative is aligned in the Venice High School complex. The proposed project accommodates a four-class unit model, with 4 classes per grade for grades K–3 (total 16 classes) and 3 classes per grade for grades 4–5 (total 6 classes), to create the critical mass needed to make the Program work, as the Program thins out in the fourth and fifth grades. An additional set-aside classroom for alternative use is customary to an elementary school, such as for a parent center or break out instruction, for a total of 23 classrooms needed to support the Program. As with the proposed project, this alternative would result in no significant impacts for 5 issue areas (agriculture and forestry resources, hazards and hazardous materials, land use and planning, mineral resources, population and housing), less than significant impacts for 9 issue areas (aesthetics, air quality, biological resources, geology and soils, greenhouse gas emissions, hydrology and water quality, public services, recreation, and utilities and service systems), and potentially significant impacts for 4 issue areas (cultural resources, noise, pedestrian safety, and transportation and traffic), 3 of which would be reduced to below the level of significance with the incorporation of mitigation measures. Implementation of this alternative would not create new impacts that are not associated with the proposed project. As with the proposed project, this alternative would result in significant and unavoidable impacts to traffic related to reduction in level of service and compromised volume/capacity ratio for six intersections.
Redistricting Alternative
This alternative would involve redrawing the LAUSD boundaries so that resident students in traditional instructional programs at LAUSD elementary schools would be relocated from their neighborhood school and redistricted to other campuses. After redistricting, the Program would return to a consolidated campus at Broadway Elementary School. Currently, there is intermittent classroom capacity sprinkled in various campuses in the general area where the Program operates. This alternative proposes that by redistricting students to fill capacity across various campuses, the Program will be able to be consolidated and allowed to operate on a single site. The eight portables at Mark Twain Middle School would be vacated and the proposed project site would remain as athletic facilities, parking, and portable classrooms. Under the Redistricting Alternative, no construction-related activities would occur. This alternative would make space for the Program at Broadway Elementary School, but it would require resident students to be displaced from their nearest geographic school. This alternative would meet only six of the eight objectives for the project because the Redistricting Alternative:
Would not result in the building and maintaining of a school that reflects the wise and efficient use of limited District Bond Funds and General Funds, and
Would be inconsistent with LAUSD’s commitment to provide every student with the opportunity to attend their neighborhood school.
Unlike the proposed project, this alternative would result in no significant impacts for 12 issue areas (aesthetics, agriculture and forestry resources, biological resources cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, recreation, and utilities and service systems), less than significant impacts for 5 issue areas (air quality, greenhouse gas emissions, noise, pedestrian safety, and public services), and potentially significant impacts for 1 issue area (transportation and traffic), which would not be reduced to below the level of significance with the incorporation of mitigation
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-13 Draft EIR Executive Summary measures. Implementation of this alternative would create new regional impacts to transportation and traffic as a result of increased commute distance from current resident students who are not associated with the proposed project. As with the proposed project, this alternative would result in significant and unavoidable impacts to traffic related to reduction in level of service and compromised volume/capacity ratio for six intersections, and the level of impact would potentially be substantially more adverse.
The Redistricting Alternative would be the environmentally superior alternative, although it would not reduce impacts to transportation and traffic to below the level of significance, because it would not require the construction of new facilities and therefore result in the fewest environmental impacts of the action alternatives considered. The Redistricting Alternative is considered environmentally superior to all other alternatives for a number of reasons, including:
The Redistricting Alternative would not entail construction of new structures and classrooms, therefore reducing impacts associated with construction emissions, noise, and traffic.
The Redistricting Alternative would fulfill the greatest decrease in disturbances to the physical environment. There are no excavation or physical disturbances anticipated; therefore, this alternative has no environmental impacts associated with grading, excavation, or earth-moving activities.
The Redistricting Alternative would meet most of the project objectives and result in the least amount of environmental impacts compared to the proposed project, Reduced Project, and Marina Del Rey alternatives.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page ES-14 Draft EIR CHAPTER 1.0 INTRODUCTION
1.1 PURPOSE OF THE ENVIRONMENTAL IMPACT REPORT
LAUSD is proposing to relocate the existing Mandarin and English Dual-Language Immersion Elementary School Program at Broadway Elementary School to a portion of the Mark Twain Middle School campus, known as the Mandarin and English Dual-Language Immersion Elementary School Project (proposed project). The approximately 4.2-acre site consists of eight existing portable classrooms (0.2 acre) and the 0.1-acre asphalt walkway to the north of the classrooms, 0.1 acre of sidewalk along Victoria Avenue, 1.9 acres of asphalt with painted parking stalls and a painted track, and 1.9 acres of an athletic field on the northeastern portion of the existing 21.3-acre Mark Twain Middle School campus adjacent to Victoria Avenue, known as the proposed project site. The proposed project site is located in the Mar Vista community within the City of Los Angeles.
All projects within the State of California are required to undergo an environmental review to determine the environmental impacts associated with implementation of the project in accordance with CEQA.1
CEQA was enacted in 1970 by the California legislature to disclose to decision makers and the public the significant environmental effects of proposed activities and ways to avoid or reduce the environmental effects by requiring implementation of feasible alternatives or mitigation measures. CEQA applies to all California governmental agencies at all levels, including local agencies, regional agencies, state agencies, boards, commissions, and special districts (such as LAUSD). LAUSD is the lead agency for the proposed project and, as such, is required to conduct an environmental review to analyze the potential environmental effects associated with the proposed project.
As allowed by the State CEQA Guidelines, LAUSD determined to proceed directly to preparation of an EIR, based on their experience with other comparable projects in the District and the results of the preliminary traffic analysis that identified congestion in the surrounding intersections during the AM and PM peak hours. The existing level of traffic congestion suggests that the anticipated contribution by the project would have the potential to result in significant impacts. Based on these findings and input gathered during the scoping period, this EIR has been prepared and is now being circulated to the public and affected agencies for review and comment.
One of the primary objectives of CEQA is to enhance public participation in the planning process.2 Community members are encouraged to participate in the environmental review process, request
1 California Environmental Quality Act, Public Resources Code Section 21000 et al. 2 California Environmental Quality Act, Public Resources Code Section 21000 et al. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-1 Draft EIR Chapter 1.0 Introduction to be notified of meetings and release of documents, monitor newspapers for formal announcements, and submit substantive comments at every possible opportunity afforded by the lead agency. The environmental review process provides ample opportunity for the public to participate through scoping, public review of CEQA documents, and public hearings. 1.2 SCOPE OF THE EIR
The EIR addresses and incorporates information obtained through a robust public outreach effort. Seven community meetings have been held with parents, teachers, and community stakeholders to present, provide updates, and answer questions about the proposal to relocate the Mandarin Immersion Program, which are summarized below:
Wednesday, May 29, 2013: A community meeting was held at Marina Del Rey Middle School to provide an update and answer questions about the proposal to relocate the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Marina Del Rey Middle School campus for the 2014–2015 school year.
Wednesday, June 5, 2013: A community meeting was held at Broadway Elementary School to provide an update and answer questions about the proposal to relocate the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Marina Del Rey Middle School campus for the 2014–2015 school year.
Wednesday, October 30, 2013: A community meeting was held at Broadway Elementary School to provide an update on the relocation of the Mandarin Immersion Program, currently located at Broadway Elementary School.
Thursday, March 6, 2014: A community meeting was held at Mark Twain Middle School that included a presentation of the long-term instructional and facilities vision in the Venice High School Complex. Specifically, the presentation was about potential changes which could directly impact: Broadway Elementary School, Mark Twain Middle School, and Westminster Elementary School.
Friday, March 7, 2014: A community meeting was held at Broadway Elementary School that included a presentation of the long-term instructional and facilities vision in the Venice High School Complex. Specifically, the presentation was about potential changes that could directly impact Broadway Elementary School, Mark Twain Middle School, and Westminster Elementary School.
Monday, November 12, 2014: A community meeting was held at Broadway Elementary School to provide an update regarding the proposed relocation of the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Mark Twain Middle School campus.
Wednesday, November 14, 2014: A community meeting was held at Mark Twain Middle School to provide an update regarding the proposed relocation of the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Mark Twain Middle School campus.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-2 Draft EIR Chapter 1.0 Introduction
Thursday, February 26, 2015: A community meeting was held at Mark Twain Middle School to present the latest conceptual designs and provide an update regarding the proposed relocation of the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Mark Twain Middle School campus.
Thursday, March 5, 2015: A community meeting was held at Mark Twain Middle School to present the latest conceptual designs and provide an update regarding the proposed relocation of the Mandarin Immersion Program, currently located at Broadway Elementary School, to the Mark Twain Middle School campus.
In accordance with CEQA, an NOP was prepared and distributed on October 14, 2014, to responsible agencies, affected agencies, and other interested parties.3
The NOP was posted in the Los Angeles County Clerk’s office for 30 days beginning on October 14, 2014. The NOP was also submitted to the California Office of Planning and Research, State Clearinghouse on October 14, 2014 (SCH# 2014101034) to officially solicit participation from state agencies and other interested parties in determining the scope of the EIR.
In addition, the NOP was mailed to adjacent residents and property owners within 500 feet of the proposed project site in both Spanish and English. LAUSD agreed to accept comments on the NOP for an additional 2 weeks after the 30-day review period per the request of the Mar Vista Neighborhood Council.
Information provided during the 30-day public review period regarding the contents of the NOP and the scope of the EIR was considered, where applicable, in the preparation of this EIR.
The EIR was prepared based on research, records review, site investigation, quantitative modeling, and qualitative assessments, input from the public, responsible agencies, affected agencies, and other interested parties through the EIR scoping process. The content of the EIR was established based on public and agency input. This EIR analyzes the eighteen (18) environmental issues listed below.
Aesthetics Land Use and Planning Agriculture and Forestry Resources Mineral Resources Air Quality Noise Biological Resources Population and Housing Cultural Resources Public Services Geology and Soils Recreation Greenhouse Gas Emissions Pedestrian Safety Hazards and Hazardous Materials Transportation/Traffic Hydrology and Water Utilities and Service Systems
3 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15063. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-3 Draft EIR Chapter 1.0 Introduction
1.3 EIR ORGANIZATION
The EIR is organized into the following chapters so the reader can easily obtain information about the proposed project and its specific issues:
“Executive Summary” presents a summary of the proposed project; considered alternatives; potential impacts; and mitigation measures, and describes the analysis and conclusions pertaining to potential growth inducement and cumulative impacts.
Chapter 1, “Introduction,” describes the purpose and use of the EIR, provides a brief overview of the proposed project, and outlines the organization of the EIR.
Chapter 2, “Project Description and Environmental Setting,” describes the project location; project details; baseline environmental setting and existing physical conditions; and the LAUSD overall objectives for the proposed project.
Chapter 3, “Environmental Analysis,” describes the existing conditions, or setting, before project implementation; methods and assumptions used in the impact analysis; thresholds of significance; impacts that would result from the proposed project; and applicable mitigation measures that would eliminate or reduce significant impacts for each environmental issue.
Chapter 4, “Alternatives Analysis,” evaluates the environmental effects of project alternatives, including the No Project Alternative and Environmentally Superior Project Alternative and compares these impacts with those associated with the proposed project.
Chapter 5, “Other CEQA Considerations,” includes a discussion of issues required by CEQA that are not covered in other chapters. This includes unavoidable adverse impacts, impacts found not to be significant, irreversible environmental changes, and growth-inducing impacts.
Chapter 6, “Acronyms and Abbreviations,” presents a list of the acronyms and abbreviations used in this document.
Chapter 7, “References,” identifies the documents and individuals consulted in preparing the EIR.
Chapter 8, “Report Preparation,” lists the individuals involved in preparing the EIR and organizations and persons consulted.
Appendices present data supporting the analysis or contents of the EIR. The appendices include the following:
Appendix A: Notice of Preparation
Appendix B: Comments on Notice of Preparation
Appendix C: CalEEMod Model for LAUSD Mandarin and English Dual-Language Immersion School
Appendix D: Historic Resources Assessment
Appendix E: Geotechnical Evaluation
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-4 Draft EIR Chapter 1.0 Introduction
Appendix F: Phase I Environmental Site Assessment
Appendix G: Phase I Environmental Site Assessment Addendum
Appendix H: Traffic Study
Appendix I: Impact Analysis for Marina Del Rey Project Alternative at Marina Del Rey Middle School
Appendix J: Distribution List 1.4 AVAILABILITY OF THE DRAFT EIR
The Draft EIR for the proposed project will be distributed directly to numerous agencies, organizations, interested groups and persons for comment during the Draft EIR comment period. The Draft EIR is also available for review at the following locations:
LAUSD Office of Environmental Health and Safety 333 South Beaudry Avenue, 28th Floor Los Angeles, California 90017
LAUSD Educational Services Center - West 11380 W. Graham Place Los Angeles, California 90064
Mark Twain Middle School 2224 Walgrove Avenue Los Angeles, California 90066
Broadway Elementary School 1015 Lincoln Boulevard Venice, California 90291
Beethoven Elementary School 3711 Beethoven Street Los Angeles, California 90066
Venice-Abbott Kinney Memorial Branch Library 501 S. Venice Boulevard Venice, California 90291
Mar Vista Branch Library 12006 Venice Boulevard Los Angeles, California 90066
Lloyd Taber-Marina del Rey Library 4533 Admiralty Way Marina del Rey, California 90292
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-5 Draft EIR Chapter 1.0 Introduction
In addition, the Draft EIR is available online at the LAUSD OEHS website: http://achieve.lausd.net/oehs. 1.5 PUBLIC MEETINGS AND HEARINGS
During the 30-day NOP comment period, LAUSD received 27 public comments and 4 agency comments. Agency comments were received from the City of Los Angeles Bureau of Contract Administration, the City of Los Angeles Department of Transportation, Mar Vista Community Council, and the South Coast Air Quality Management District. Nine areas of controversy are known to LAUSD as a result of scoping and community outreach efforts, in regard to Noise, Pedestrian Safety, Recreation, and Transportation and Traffic. LAUSD will receive public input on the proposed project’s Draft EIR during the 45-day public review period and at a public meeting to be held on April 22, 2015, from 6:00 p.m. to 8:00 p.m. at the Mark Twain Middle School Auditorium located at 2224 Walgrove Avenue, Los Angeles, California. Comments from the community and interested parties regarding this proposed project also are encouraged at all public hearings before the Facilities Committee and the Board. 1.6 AGENCY COMMENTS
If this document includes information necessary for an agency to meet any statutory responsibilities related to the proposed project, LAUSD needs to know the views of that agency regarding the scope and content of the environmental information included in this EIR. The agency will need to use the environmental documents prepared by LAUSD when considering any permits or other approvals necessary to implement the project. The environmental topics studied by LAUSD are provided in Chapters 3 and 5 of this EIR. If the topics of concern to the agency have already been identified for analysis, the agency need not provide a response to this notice.
The project description, location, and the environmental issues to be addressed in this EIR are contained in the attached materials. Due to the time limits mandated by state law (CEQA Guidelines Section 15205(d)), comments must be sent to LAUSD at the earliest possible date but not later than Monday, May 11, 2015 by 5:00 p.m., which is 45 days after publication of this notice. Please send responses to:
Los Angeles Unified School District Office of Environmental Health and Safety 333 South Beaudry Avenue, 28th Floor Los Angeles, CA 90017-5157 Attention: Edward Paek, AICP
Comments may be sent via fax to: (213) 241-6816, or via e-mail to:
Please include “Mandarin Immersion Project” in the subject line. Agency responses should include the name of a contact person within the commenting agency.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 1-6 Draft EIR
CHAPTER 2.0 PROJECT DESCRIPTION AND ENVIRONMENTAL SETTING
2.1 PROJECT BACKGROUND AND OBJECTIVES
2.1.1 PROJECT BACKGROUND
Dual-language programs (also known as two-way immersion programs) allow English learners and English proficient students to receive instruction in English and a target language in the same classroom to develop academic proficiency in both languages beginning in kindergarten for a minimum of 6 years. LAUSD currently offers students at selected schools the option of participating in a Spanish/English, Korean/English, or Mandarin/English dual-language program.1 The Mandarin and English Dual-Language Immersion Program (“Program”) was initiated in 2010 at Broadway Elementary School (Figure 2.1-1, Regional Site Map), and is part of the world language instructional pathways initiative in the Venice High School complex that includes Venice High School and its elementary and middle feeder schools. Currently, the Program has 365 students enrolled in kindergarten through fourth grade; however, the program is designed to expand through fifth grade. The total projected enrollment is 567 students. Broadway Elementary School also operates a Spanish and English dual-language immersion program and a traditional instructional program.
Enrollment at Broadway Elementary School is projected to continually grow as new cohorts of kindergarten classes are enrolled annually in the existing programs. Beginning in the 2015–2016 school year, the Broadway Elementary School campus will be unable to operate all three of its current educational programs due to limited classroom space and site constraints that do not allow for the addition of permanent classroom capacity. Additionally, there is not an existing LAUSD facility within the Venice High School complex with enough available space to provide the entire K–5 Program on a single campus. As a result, and in an effort to support the growth of all traditional instructional and dual-language immersion programs, beginning in the 2015–2016 school year, the Program will be operated on multiple campuses with its kindergarten through second-grade students housed at Broadway Elementary School and third- through fifth-grade students housed in existing available classroom space at Mark Twain Middle School. The long-term operation of the Program on split campuses significantly limits the Program’s ability to successfully deliver the educational program as designed and requires additional administrative support, further burdening LAUSD’s already limited General Fund resources.
In order to provide educational facilities that allow for the Program to grow and operate efficiently on a single consolidated site, the LAUSD Board of Education defined the Mandarin and English
1 Los Angeles Unified School District Website. Accessed March 2015. http://notebook.lausd.net/portal/page?_pageid=33,230293&_dad=ptl Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-1 Draft EIR LEGEND K-12 Schools Culver City Unified School District (CCUSD) Overland Ave Mark Twain Middle School Elementary Los Angeles Unified School Broadway Elementary School School District (LAUSD) Santa Monica-Malibu Marina Del Rey Middle School Unified School District (SMMUSD)
McKinley Elementary Clover Ave Webster School Elementary Palms Middle School Elementary Edison Language Richland Ave School School Academy Elementary Elementary School School
Palms Middle School Charnock Road Grant John Adams Mar Vista Elementary Middle Elementary School School Elementary School School
La Ballona Will Rogers Elementary Elementary School John Muir School Walgrove Ave Elementary Elementary School School
Beethoven Mark Twain Elementary Middle School School Grand View Blvd Broadway Elementary Elementary School School Venice Stoner Ave High Elementary School School Westminster Ave Elementary Braddock Drive School Coeur d'Alene Elementary Ave Elementary School School Short Ave Elementary School Marina Del Rey Middle School
Playa Del Rey Elementary School
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FIGURE 2.1-1 Regional Site Map Chapter 2. Project Description and Environmental Setting
Dual-Language Immersion Elementary School Project (proposed project) in April 2014.2 The proposed project would provide educational facilities for kindergarten through fifth-grade students on approximately 4.2 acres of the Mark Twain Middle School campus and includes the construction of new buildings, site improvements, and modifications to eight existing portable classrooms. Once completed, the new and upgraded facilities would allow the Program to operate on a single contiguous campus.
Developing the proposed project on a portion of the Mark Twain Middle School campus supports the alignment of the world language instructional pathways initiative that begins in kindergarten and continues through high school, in the Venice High School complex. Mark Twain Middle School already has a substantial commitment to language learning, housing the World Languages Magnet and a middle school program for Spanish Immersion. Moving the Mandarin Immersion Program to Mark Twain Middle School, as opposed to other locations that were evaluated, would facilitate continuity and optimal K–8 instruction in the dual-language program. The elementary and middle school administrators, faculty and staff, and parent communities will work collaboratively to support all students in the program. Furthermore, adding to Mark Twain’s portfolio of language classes will strengthen all programs on campus, as teachers of different languages can exchange strategies for innovative instruction, and students will share the value of language learning. Mark Twain Middle School is an ideal location for the Program for various reasons including, but not limited to:
Its designation as the middle school in the world language instructional pathway in the Venice High School complex
Its established commitment to language learning, housing the World Languages Magnet and a middle school Spanish Immersion program
The potential for the Program to grow into the middle school grade levels, further adding to Mark Twain Middle School’s portfolio of language classes
The availability of eight classrooms that will already be utilized by the Program beginning in the 2015–2016 school year
The site area is large enough to develop the new facilities without compromising Mark Twain Middle School students’ ability to meet state and local educational requirements
Its close proximity to Broadway Elementary School where the Program was initiated
In addition to the significance of the Mark Twain Middle School campus for fostering K–8 instructional continuity, it is critical that all K–5 Mandarin Immersion classes are located on a single campus. There are multiple benefits and objectives to having the program on a consolidated single campus, including but not limited to four key areas:
2 Board of Education of the City of Los Angeles. April 2, 2014. Board of Education Regular Meeting: Order of Business. Available at: http://www.laschoolboard.org/sites/default/files/04-08-14RegBdOB_1.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-2 Draft EIR Chapter 2. Project Description and Environmental Setting
Supporting collaboration between teachers in designing curriculum and assessments;
Facilitating teacher collaboration in instructional planning within and across grade levels to ensure that instruction is coherent within the Program;
Creating an immersive language community that allows students to use the language outside the classroom and practice their language skills by teaching younger students on the playground and at lunch; and
Providing shared resources for K–8, such as Mandarin books and multimedia for the students and a collection of resources for teachers.
In the past 5 years, teacher collaboration and developing growth together have proven to be a tremendous asset to Broadway’s Mandarin Immersion program, resulting in rigorous instruction and strong student learning. This is also true for tutoring and afterschool programs in Mandarin; the paucity of such programs for Mandarin means that organizing them is a challenge and it is far easier to manage in a single location.
Locating an elementary school on or adjacent to a middle school is not uncommon in LAUSD. There are 45 campuses within LAUSD that have elementary schools and middle schools on shared campuses,3 and 14 middle school campuses adjacent to elementary school campuses, including Mark Twain Middle School, which is adjacent to Beethoven Elementary School.
2.1.2 PROJECT OBJECTIVES
LAUSD has established eight objectives for the proposed project:
1. Provide educational facilities dedicated to the Program for kindergarten through fifth grade;
2. Consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitate a learning environment that is conducive to an immersion program;
3. Build and maintain a school that reflects the wise and efficient use of limited District Bond Funds and General Funds;
4. Build and maintain a school that reflects the wise and efficient use of limited land and public resources;
5. Maintain the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program;
3 California Department of Education, Educational Demographics Unit. Report Generated 24 March 2014. DataQuest. “Enrollment by Grade for 2013-14: Los Angeles Unified Report.” Available at: http://dq.cde.ca.gov/dataquest/Enrollment/GradeEnr.aspx?cChoice=DistEnrGr2&cYear=2013- 14&cSelect=1964733-- Los%20Angeles%20Unified&TheCounty=&cLevel=District&cTopic=Enrollment&myTimeFrame=S&cType= ALL&cGender=B Main website: http://dq.cde.ca.gov/dataquest/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-3 Draft EIR Chapter 2. Project Description and Environmental Setting
6. Enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School;
7. Comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school; and
8. Provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program, allowing acceptance of up to four classes of kindergarten students every year. 2.2 PROJECT DESCRIPTION
2.2.1 PROJECT COMPONENTS
The proposed project includes the construction and operation of an elementary school to serve kindergarten through fifth-grade students in the Program. Approximately 33,000 square feet of new building space is proposed to be constructed on 4.2 acres of land located on the Mark Twain Middle School campus. The Project would provide approximately 336 new seats in addition to the approximately 231 seats in existing classrooms to support the Program’s total projected enrollment of 567 on a consolidated site. The Project would also provide the administrative, support, and core facilities and site improvements necessary to operate the elementary school. Current plans are to operate the Program on a traditional single-track, two-semester, 180-day calendar. School instructional hours would be from approximately 8:00 a.m. to 3:00 p.m., with staff and students of the proposed elementary school arriving on campus between approximately 7:00 a.m. and 8:00 a.m. and leaving between approximately 3:00 p.m. and 6:00 p.m. The Program would have a dedicated staff, separate from that supporting the Mark Twain Middle School, with approximately 70 full-time and part-time faculty and staff. Proposed Facilities
The proposed project consists of new buildings that would be one to two stories in height (approximately 30 feet to the top of the highest roof and approximately 35 feet to the top of the mechanical screens on the two-story classroom buildings) and improvements to eight existing portable classrooms within an approximately 4.2-acre portion of the 21.3-acre Mark Twain Middle School campus, adjacent to Beethoven Elementary School (Figure 2.2.1-1, Local Vicinity Map). The proposed project includes, but is not limited to (Figure 2.2.1-2, Site Plan):
Construction of new classroom buildings consisting of approximately 15 classrooms with the capacity to serve approximately 336 students and include administrative and support spaces (approximately 33,000 square feet);
Modifications to the eight existing portable classrooms with capacity to serve approximately 231 students (approximately 7,680 square feet);
Construction of new designated elementary and kindergarten play areas, totaling approximately 1.7 acres;
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-4 Draft EIR LEGEND Beethoven Elementary School Early Education Center
Beethoven Elementary School Walgrove Avenue Elementary School Mark Twain Middle School Walgrove Avenue Venice High School
Elementary School M a p le A v e
Beethoven Elementary School
Mark Twain Middle School Beethoven Elementary School Early Education Center
Venice High School
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FIGURE 2.2.1-1 Local Vicinity Map VICTORIA AVENUE
60’
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FIGURE 2.2.1-2 Site Plan Chapter 2. Project Description and Environmental Setting
Construction of new designated student drop-off and parking areas (approximately 70 parking stalls, including replacement of existing parking areas serving Mark Twain Middle School);
Construction of a new multi-purpose room (MPR);
Construction of new food services and lunch shelter facilities; and
Furnishing and equipping with grade appropriate desks, chairs and equipment.
The proposed project design would conform to the requirements of the Americans with Disabilities Act (ADA), Division of the State Architect (DSA), CEQA, and any other required improvements or mitigations to ensure compliance with local, state, and/or federal facilities requirements. No existing buildings would be demolished as a result of the proposed project. As required by LAUSD’s tree replacement policy, any tree removal would be mitigated by the planting of landscaping trees at a minimum 1:1 ratio that are a 24” box or larger, a species that will be the appropriate size at maturity for the space planted, and a species that is included in the LAUSD Approved Plant List. The Mark Twain Middle School campus would continue to provide over 5 acres of outdoor recreational facilities for the students, and the athletic field would continue to be available during off-school hours for permitted use by public organizations. Off-Site Improvements
The following street and sidewalk improvements would be made off-site as part of the proposed project in accordance with City of Los Angeles Bureau of Engineering recommendations:
Widening of Victoria Avenue by 12 feet across the frontage of the property in the proposed area of development to provide a 22-foot eastbound half roadway and a 10-foot-wide sidewalk (widening in other segments of the block is hampered by existing buildings and underground private utilities adjacent to the fence line as well as code required area for playground facilities).
Widening of Walgrove Avenue by 5.5 feet to provide a 22-foot half northbound roadway and a 10-foot wide sidewalk.
Construction of a standard ADA access ramp at each street corner with a 25-foot radius curb return.
Construction of ADA facilities (ramps and sidewalks) as necessary.
Any cracked, broken, or off-grade curb, gutter, sidewalk, and pavement identified along Victoria Avenue, Beethoven Street, Lucille Avenue, and Walgrove Avenue would be repaired or replaced.
Construction of driveways no wider than 30 feet.
Construction of curb outlets or connections to catch basins located at Beethoven Street, Victoria Avenue, Walgrove Avenue, and Lucille Avenue to capture any discharge of roof or site storm water drainage associated with the Project, in accordance with Low Impact Development (LID) requirements, to be demonstrated to the City Engineer. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-5 Draft EIR Chapter 2. Project Description and Environmental Setting
Construction of extensions of existing sewer mains on Victoria Avenue to connect to existing sewer facilities on Beethoven Street and Walgrove Avenue. LAUSD would obtain a Sewer Capacity Report from the Bureau of Engineering sewer counter and obtain a sewer permit to connect to the existing sewer facilities.
An additional right-turn lane would also be constructed on Walgrove Avenue to reduce traffic impacts from buses commuters turning onto Victoria Avenue in order to ensure that this access is appropriate for the anticipated increase in use. Project Schedule
Q2 2015: Anticipated Community Meeting to present Draft EIR
Q3 2015: Anticipated Board Action/EIR and Project Approval
Q1 2016: Anticipated Construction Start
Q3 2017: Anticipated Construction Completion
2017–2018 School Year: All students in the Program would attend school in the facilities at the Mark Twain Middle School campus and the Program would no longer be split on separate campuses. Instruction would commence for Grades K–5 of the Program in the consolidated new elementary school facilities located on the Mark Twain Middle School campus. Access and Parking
Main access to the proposed project site would be available at a new student drop-off area and parking areas along Victoria Avenue near Maplewood Avenue. The new student drop-off area would not conflict with existing school pick-up/drop-off locations, which are located on Walgrove Avenue to the south of Victoria Avenue for Mark Twain Middle School and on Beethoven Street to the south of Victoria Avenue for the Beethoven Elementary School. As previously mentioned, Victoria Avenue would be widened by 12 feet on the east-bound side of the project site towards the south, creating a designated student drop-off area. Additionally, Walgrove Avenue would be widened by 5.5 feet to increase the width of the drop-off area for Mark Twain Middle School and improve traffic flow during drop-off times. The bell schedule for the proposed school would provide for offset start and end times, for spacing of at least 15-20 minutes from the schedules of the two adjacent schools.
2.2.2 PROJECT LOCATION AND SITE CHARACTERISTICS Location
The proposed project site is located in the City of Los Angeles, within the neighborhood of Mar Vista (Figure 2.2.2-1, Regional Vicinity Map). The proposed project site is located on the northeastern portion (approximately 4.2 acres) of the existing 21.3-acre Mark Twain Middle School campus, approximately 0.2 mile northwest of State Route 187 (Venice Boulevard), 0.6 mile northeast of State Route 1 (Lincoln Boulevard), 1.1 mile north of State Route 90 (Marina Freeway), 1.6 miles southwest of Interstate 405 (San Diego Freeway), and 1.8 miles south of Interstate 10 (Santa Monica Freeway) (see Figure 2.1-1). Venice Boulevard and Lincoln Boulevard have been
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-6 Draft EIR Vaall Veerrddee «¬14 LEGEND Santa Clarita ^_ Project Location 5 ¨¦§ County Boundaries City of Los Angeles Ventura County
118 Simi Valley «¬ ¨¦§210
170 «¬ «¬2 «¬101 210 Thousand Oaks «¬134 ¨¦§
405 ¨¦§ 101 «¬ 10 Los Angeles ¨¦§ County ¨¦§10 «¬60 ^_ ¨¦§110 ¨¦§710 ¨¦§605
¨¦§105 «¬57 «¬91
5 405 Orange ¨¦§ ¨¦§ County
P Mapped acific Oc Area ean
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FIGURE 2.2.2-1 Regional Vicinity Map Chapter 2. Project Description and Environmental Setting designated by the City as scenic highways.4 Mark Twain Middle School is located at 2224 Walgrove Avenue, Los Angeles, California 90066 in the City of Los Angeles (see Figure 2.2.1-1). Mark Twain Middle School opened on July 1, 1980,5 but the proposed project site has been occupied as a school since 1949 or 1950, and was previously used for agricultural purposes between approximately 1928 and 1947.6 The proposed project site is located on the U.S. Geological Survey (USGS) 7.5-minute Series Beverly Hills, California, topographic quadrangle (Figure 2.2.2-2, USGS 7.5-Minute Quadrangle Topographic Map). The elevation of the proposed project site ranges from approximately 37 to 41 feet above mean sea level (MSL). Mark Twain Middle School is situated at longitude –118.4º, latitude 34.0º in a primarily residential neighborhood, bordered by Beethoven Elementary School to the east, Lucille Avenue to the south, Walgrove Avenue to the west, and Victoria Avenue to the north (Figure 2.2.2-3, Aerial Photograph). The largest major streets are Venice Boulevard to the south by two blocks and Lincoln Boulevard to the west by approximately seven blocks. Walgrove Avenue is a commonly used thoroughfare and constitutes the majority of traffic adjacent Mark Twain Middle School. Existing Land Uses
The proposed project site is currently occupied by eight existing portable classrooms (0.2 acre) and the 0.1-acre asphalt walkway to the north of the classrooms, 0.1 acre of sidewalk along Victoria Avenue, 1.9 acres of asphalt with painted parking stalls and a painted track, and 1.9 acres of an athletic field, for a total of approximately 4.2 acres on the existing Mark Twain Middle School campus (21.3 acres). There are 10 structures located within the proposed project site that would remain on-site (including the eight portable classrooms). One tree, an ornamental Chinese elm tree (Ulmus parvifolia), is situated within the proposed project site, at the northwestern end of the athletic field, adjacent to Victoria Avenue. Surrounding Land Uses
The project area is suburban and characterized by a mixture of single-family residences and educational facilities. The proposed project site within the Mark Twain Middle School campus is surrounded by Mark Twain Middle School classrooms and the Student Garden to the southwest; the gymnasium building to the south; and athletic facilities to the southeast, consisting of handball courts, four-square courts, basketball courts, and tennis courts painted on asphalt and a multi-use athletic field. The playground at Beethoven Elementary School is adjacent to the northeastern boundary of the project site, including vegetative screening along the chain link fence separating the two schools, painted four-square and handball courts on an asphalt surface, a track, and a small vegetable garden at the northwestern corner of the campus along Victoria Avenue. Single-family residences are situated on Victoria Avenue, across the street to the north of the proposed project site. The nearest public airport is the Santa Monica Municipal Airport, located approximately 0.8 mile northwest of the proposed project site. The planning boundary/airport influence area for Santa
4 City of Los Angeles Department of City Planning, Citywide Transportation Section and Graphic Services Section. June 1998. “Map E: Transportation Element of the General Plan – Scenic Highways in the City of Los Angeles.” Available at: http://cityplanning.lacity.org/ 5 California Department of Education. Accessed 30 October 2014. California School Directory – School: Mark Twain Middle. Available online at: http://www.cde.ca.gov/re/sd/details.asp?cds=19647336058135&public=Y 6 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-7 Draft EIR LEGEND Mark Twain Middle School USGS 7.5-Minute Quadrangle
BEVERLY HILLS VENICE
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FIGURE 2.2.2-2 USGS 7.5-Minute Quadrangle Topographic Map LEGEND Proposed New Frontage and Drop Off for Mandarin Immersion Elementary School G r e Proposed Mandarin Immersion e n vd w Elementary School Bl o s o alm d Proposed Restriped Parking for P A v e Mark Twain Middle School Student Garden M a p Beethoven Elementary School le w Early Education Center o o d A v Beethoven Elementary School e Mark Twain Middle School
R o s l e P w co o ar o M d A ve v A e ria cto Vi Proposed New Frontage A s h and Drop Off for Mandarin w o Immersion Elementary School o d A v R e e d w o o Proposed Restriped Parking for d A Mark Twain Middle School v e
W Student a lg ve Garden r A o a v ri e to B ic e A V e v ve t e A h G e o n v r u e Existing Portable e cC n e M n S Classrooms w t o o d A v ve e A ve ille A uc R ale L o d s rn e e w F o o d
ve M A A v ia a e or p ict le V w o o d A A v s e 187 h UV w o o d R A e v d e w o o d A v e e Av le cil Lu
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FIGURE 2.2.2-3 Aerial Photograph Chapter 2. Project Description and Environmental Setting
Monica Municipal Airport does not extend farther south than Dewey Street (approximately 0.7 mile northwest of the proposed project site). Los Angeles International Airport (LAX) is located approximately 3.6 miles southeast of the proposed project site; the northernmost planning boundary/airport influence area for LAX is located approximately 2.9 miles southeast of the proposed project site at Manchester Boulevard in Westchester, California. There are 32 K–12 schools within 2 miles of Mark Twain Middle School (see Figure 2.1-1), including Beethoven Elementary School, which is adjacent to the eastern boundary of the proposed project site and the Mark Twain Middle School campus; Venice High School, which is located approximately 0.2 mile southeast of the proposed project site; Walgrove Avenue Elementary School, which is located approximately 0.4 mile northwest of the proposed project site; and Broadway Elementary School, which is located approximately 0.9 mile west of the proposed project site and approximately 0.7 mile west of the western edge of the Mark Twain Middle School campus. There are three waterways within a 2-mile radius of Mark Twain Middle School: Ballona Creek (approximately 1.9 miles southeast of the proposed project site), Centinela Creek Channel (approximately 2.0 miles southeast of the proposed project site), and Grand Canal (approximately 1.5 miles southwest of the proposed project site). General Plan Designation and Zoning
The City of Los Angeles General Plan land use designation for the existing 21.3-acre Mark Twain Middle School campus is “Public Facilities” (Figure 2.2.2-4, City of Los Angeles General Plan Land Use Designation). The proposed Mark Twain Middle School campus is zoned [Q]PF-1XL, Qualified Public Facilities in Height District I, Extra Limited.7 The City of Los Angeles Municipal Code – Zoning Plan has designated the proposed project site as PF: Public Facilities, a zone for the use and development of publicly owned land, including fire and police stations, public libraries not located inside public parks, post office and related facilities, public health facilities such as clinics and hospitals, public elementary and secondary schools, public parking facilities under freeway rights- of-way, and farming and nurseries under power transmission rights-of-way (Figure 2.2.2-5, Zoning Designation Map).8,9 The City of Los Angeles has designated the properties surrounding the project site as R1 (One-Family Zone/Low Residential Land Use) to the northwest, west, south and east of the project site and RD (Restricted Density Multiple Dwelling Zone/Los Medium Residential Land Use) to the north in the City’s Zoning Plan and General Plan. The proposed project site is located on Assessor’s Parcel Number (APN) 4245-015-900.
7 City of Los Angeles Department of City Planning. Accessed 15 October 2014. ZIMAS. Available at: http://zimas.lacity.org/ 8 City of Los Angeles Department of City Planning. City of Los Angeles Zone Information and Map Access System (ZIMAS). Available at: http://zimas.lacity.org/ Main website: http://cityplanning.lacity.org/ 9 American Legal Publishing Corporation. 2013. Los Angeles Municipal Code, Chapter I (Planning and Zoning Code), Article 2, Section 12.04.09. Available at: http://www.amlegal.com/nxt/gateway.dll/California/lapz/municipalcodechapteriplanningandzoningco/chapterig eneralprovisionsandzoning/article2specificplanning- zoningcomprehen/sec1219m2lightindustrialzone?f=templates$fn=default.htm$3.0$vid=amlegal:lapz_ca$anc =JD_12.19.%20PDF%20available%20online%20at:%20https://law.resource.org/pub/us/code/city/ca/LosAngele s/Municipal/chapter01.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-8 Draft EIR LEGEND Beethoven Elementary School Residential Open Space Early Education Center High Medium Residential Public Facilities Beethoven Elementary School Medium Residential Mark Twain Middle School Low Medium I Residential Land Use Designation Low Medium II Residential Commercial Low Medium Residential Community Commercial Low Residential General Commercial Neighborhood Commercial Neighborhood Office Commercial
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FIGURE 2.2.2-4 City of Los Angeles General Plan Land Use Designation LEGEND Beethoven Elementary School R2 - Two-Family Zone Early Education Center RD - Restricted Density Multiple Dwelling Zone R3 - Multiple Dwelling Zone Beethoven Elementary School R4 - Multiple Dwelling Zone Mark Twain Middle School C1 - Limited Commercial Zone C2 - Commercial Zone Zoning Designation OS - Open Space Zone P - Automobile Parking Zone R1 - One-Family Zone PF - Public Facilities
[Q ] R R D R 1 D 2 -1 - 2 1 - D X 1 VL L -1 R1 D VL -1 R1 D -1 VL R1 -1 R1 XL F-1 D D ]P L 1 VL Q 1V 1- -1 [ 1- R R1 R
D VL -1 R1 D LD VL 1V -1 1- R1 R D VL -1 R1
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FIGURE 2.2.2-5 Zoning Designation Map Chapter 2. Project Description and Environmental Setting
Mark Twain Middle School is located at the western edge of the Palms – Mar Vista – Del Rey Community Plan Area (CPA),10 adjacent to the Venice CPA,11 which are 2 of 35 CPAs that comprise the land use element for the City of Los Angeles General Plan (Figure 2.2.2-6, Palms – Mar Vista – Del Rey Community Plan Area). The proposed project site is located within the Mar Vista Neighborhood Council’s jurisdictional area.12 Coastal Transportation Corridor Specific Plan
The proposed project site is located within the Coastal Transportation Corridor Specific Plan Area (Ordinance No. 168,999, effective September 22, 1993).13 For properties within this Specific Plan Area, no building, grading, or foundation permit for a project shall be issued until the City of Los Angeles Department of Transportation (LADOT) and the City Engineer have certified completion of mitigation measures required by Section 5, Transportation Mitigation Standards and Procedures, of the Specific Plan. It is anticipated that the LAUSD Board of Education will adopt a resolution under Government Code Section 53094 to exempt the proposed project from local zoning and land use regulations, including this Specific Plan.14 Regardless of this exemption, this EIR proposes feasible measures to mitigate potentially significant impacts where such measures appear available.
The Coastal Transportation Corridor Specific Plan is intended to accomplish the following two objectives relevant to the proposed project:
1) Avoid Peak Hour Level of Service (LOS) on streets and interchanges from reaching LOS F or, if presently at LOS F, preclude further deterioration in the Level of Service
2) Promote the development of coordinated and comprehensive transportation plans and programs with other jurisdictions and public agencies
The Los Angeles International Airport Corridor Area consists of an area generally bounded by Manchester Avenue to the north, Imperial Highway to the south, City of Los Angeles boundary line to the east and Vista Del Mar to the west. LAX is located approximately 2.9 miles south of the proposed project site.
10 City of Los Angeles City Planning Department. June 27, 2007. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available online at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 11 City of Los Angeles City Planning Department. September 29, 2000. Venice Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available at: http://cityplanning.lacity.org/. Venice Community Plan available online at: http://cityplanning.lacity.org/complan/pdf/vencptxt.pdf 12 Mar Vista Community Council. Website: http://www.marvista.org/ 13 City of Los Angeles. 22 September 1993. Coastal Transportation Corridor Specific Plan. Available at: http://cityplanning.lacity.org/complan/specplan/sparea/coastaltranspage.htm 14 Los Angeles Unified School District Board of Education. 11 October 2005. “Resolution by the Los Angeles Unified School District Rendering Specified City and County Zoning Ordinances Inapplicable to the District’s Acquisition and Use of Property for Designated Schools Pursuant to Government Code Section 53094 and Making Findings of Fact Related Thereto.” Reference Board of Education Report No. 69-05/06. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-9 Draft EIR G:\1498\1498-019\Documents\Draft EIR
LEGEND Residential Single Family Industrial Residential Open Space Multiple Family Commercial Public Facilities
Venice Community Plan Area
Palms - Mar Vista - Del Rey Community Plan Area
SOURCE: City of Los Angeles Department of Planning
FIGURE 2.2.2-6 Palms-Mar Vista - Del Rey Community Plan Area Chapter 2. Project Description and Environmental Setting
2.2.3 CONSTRUCTION SCHEDULE
The Design Bid Contract for the proposed project was established as a Board Action in January 2015.
Construction of the proposed project is anticipated to begin in the first quarter of 2016 and be completed in the third quarter of 2017. The entire construction process is expected to take approximately 22 months to complete. School occupancy at the new building and facilities is scheduled for the third quarter of 2017.
The construction site and staging areas would be clearly marked and barriers would be installed to prevent disturbance. In general, construction would commence with excavation, grading, and compaction of the site followed by any necessary trenching (e.g., utility hookups to buildings). The foundation, buildings, and utilities would then be constructed. The area surrounding the new buildings would be covered with concrete and asphalt and new curb-cuts, driveways, and the drop-off area would be added. New sidewalks would be constructed along the perimeter of the proposed project site, and then landscaping, site fencing, and any finishing work would be completed. 2.3 PROJECT DESIGN FEATURES
The proposed project would include implementation of the project design features listed in Table 2.3-1, Project Design Features.
Table 2.3-1: Project Design Features Trigger for Implementation PDF # Topic Compliance Phase Standard Conditions and Project Design Feature Biological Resources BIO-1 Bird nesting If tree or building Prior to the start The removal of the Chinese Elm tree and/or the sites removal or of construction disturbance of nearby trees or suitable nesting disturbance is shrubbery would be avoided and minimized to the required during the greatest extent possible through project design. nesting season (March 1 through If removal or disturbance of trees cannot be avoided, August 31) LAUSD shall:
Retain a qualified biologist to conduct an intensive nest search in all trees and buildings slated for removal before construction begins. If nests with young are found, the LAUSD shall not remove the trees until the young have fledged or the nest has been abandoned; or,
Delay tree or building removal until between September 1 and February 28 to ensure reproductive success for native species using the site for nesting.
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Table 2.3-1: Project Design Features Trigger for Implementation PDF # Topic Compliance Phase Standard Conditions and Project Design Feature Cultural Resources CUL-1 Native Throughout LAUSD shall continue consultation with Native American entirety of American groups or individuals through all aspects of Consultation proposed project this project. A response from the Native American Heritage Commission (NAHC) indicated no Native American cultural resources are known within the proposed project area. Any additional action, such as Native American monitoring, shall be done at the discretion of LAUSD. Pedestrian Safety PS-1 Student Drop- Prior to the The proposed student drop-off zone on Victoria Off Zone issuance of an Avenue shall include signs at the start and end of the Signage occupancy area clearly designating it as a student drop-off zone. permit Signs shall be posted on Victoria Avenue 100 feet prior to both the start and end of the proposed student drop-off zone. PS-2 Speed Limit Prior to the There shall be school zone signs and speed limit issuance of an postings of 25 mph installed along Victoria Avenue as occupancy a traffic control and pedestrian safety element. permit PS-3 Crosswalks Prior to the There shall be two crosswalks striped to allow for safe issuance of an pedestrian crossings at the setback of the proposed occupancy project site. The crosswalks shall be aligned in permit concert with existing stop signs at Maplewood Avenue. Transportation and Traffic T-1 Dedications Design Standard Prior to the LAUSD shall provide a 12-foot dedication for a half Requirements from issuance of an right-of-way of 32 feet across the frontage of the the City of Los occupancy property in the proposed area of development on the Angeles Bureau of permit eastbound side of Victoria Avenue to meet the City’s Engineering Collector Street Design Standard of a 64-foot right-of- way and a 32-foot wide half right-of-way. T-2 Dedications Design Standard Prior to the LAUSD shall provide a 5.5-foot dedication on Requirements from issuance of an Walgrove Avenue to meet the City’s Collector Street the City of Los occupancy Design Standard of a 32-foot wide half right-of-way. Angeles Bureau of permit Engineering T-3 Dedications Design Standard Prior to the LAUSD shall provide a 10-foot by 10-foot corner cut Requirements from issuance of an or a 15-foot radius dedication at the corner of each the City of Los occupancy intersection. Angeles Bureau of permit Engineering
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Collaborative for High Performance Schools Criteria
LAUSD is the first school district in the United States to adopt and implement the Collaborative for High Performance Schools (CHPS) Criteria.15 The LAUSD Board of Education adopted a Resolution on High Performance School Facilities requiring Phase II and future phase schools to be certified according to CHPS.16 These measures are considered beneficial to improving environmental quality. LAUSD has incorporated these into the project design and operation of the Program projects as part of standard LAUSD practices. The CHPS criteria are assumed to be part of the District’s projects as they may apply to specific projects and are not included as mitigation measures.
The proposed project, which is registered under CA-CHPS 2009 criteria, would include a minimum of 32 CHPS criteria points, which is the minimum required to be considered as a certified CHPS school.17 CHPS recommends flexible standards to promote energy efficiency, water efficiency, site planning, materials, and indoor environmental quality. Certain CHPS points are mandatory and are identified below as part of certain LAUSD Design Standards. LAUSD Design Standards Best Management Practices
In addition to the CHPS criteria, LAUSD applies best management practices (BMPs) in accordance with the 2014 School Design Guide for LAUSD, which are established and refined as part of LAUSD’s current building efforts.18 The mandatory CHPS criteria and standard LAUSD BMPs measures are presented below as they may be applied to this specific proposed project.
Noise/Acoustics. In accordance with CHPS Criteria EQ3.0: Minimum Acoustical Performance, unoccupied classrooms must have a maximum background noise level of no more than 45 dBA Leq. Background noise levels of 45 dBA are not sufficient for classrooms with young children, students with limited English proficiency, and those with hearing impairments or language disorders. Districts and designers are strongly encouraged to move beyond these prerequisites and achieve background noise levels of 35 dBA for all classrooms. An analysis of the acoustical environment of the proposed project site (such as traffic) and characterization of planned building components (such as heating, ventilation, and air conditioning) was conducted to achieve a classroom acoustical performance with 45 A-weighted decibels (dBA) at the equivalent sound level 19 (Leq) for an interior background noise level (unoccupied with HVAC ) or better. Where excessive
15 Los Angeles Unified School District. Accessed 23 March 2015. Key OEHS Programs. Available at: http://achieve.lausd.net/Page/3495 16 Los Angeles Unified School District. 28 October 2003. Los Angeles City Board of Education Resolution, Sustainability and the Design and Construction of High Performance Schools. Los Angeles, CA. Available at: http://www.laschools.org/documents/download/sustainability%2Fhealthy_schools%2FBoard_Resolution_on_ CHPS.pdf 17 Collaborative for High Performance Schools. 2009. California Criteria for High Performance Schools Best Practices Manual. Volume III. 2009 Edition. Available at: http://www.chps.net/manual/index.htm 18 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/new-site/asset-management/school- design-guide 19 The unit of measurement of environmental noise is the decibel (dB). To better approximate the range of sensitivity of the human ear to sounds of different frequencies, the A-weighted decibel scale was devised. Because the human ear is less sensitive to low-frequency sounds, the A-scale de-emphasizes these frequencies by incorporating frequency weighting of the sound signal. When the A-scale is used, the decibel Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-12 Draft EIR Chapter 2. Project Description and Environmental Setting noise from operation of the new school site could disturb adjacent residential uses, the proposed project might incorporate buffers, such as masonry walls, between playgrounds and adjacent residential uses.
Hazards. In accordance with CHPS Criteria SS1.0: Code Compliance, locally or privately funded new schools, new buildings at existing schools, or major modernizations shall undertake an environmental evaluation that assesses possible environmental hazards from existing or formal hazardous waste sites; existing hazardous material pipelines (other than natural gas supplied to school); freeways and other busy traffic corridors, large agricultural operations, or rail yards within ¼ mile; and other operations that might reasonably be anticipated to emit hazardous air emissions, or to handle hazardous, or extremely hazardous materials, substances or waste. A Phase I Environmental Site Assessment and a supplemental soil survey have been completed by Parsons for the project site that conclude that the proposed project would not result in these environmental hazards and, furthermore, the proposed development area is not adversely impacted by chemicals of potential concern.20,21 Additionally, a Seismic Hazard Evaluation has been completed for the proposed project to satisfy certain state requirements.22,23,24
Light and Glare. In accordance with CHPS Criteria SS5.1: Light Pollution Reduction, interior lighting shall be designed so that the angle of maximum candela from each interior luminaire as located in the building shall not exit out through the windows or maintain all non-emergency lighting on a programmable timer that turns lighting off during non-operable hours.25 Additionally, exterior lighting shall only be provided when it is clearly required for safety and comfort and designed not to exceed 80% of the lighting power allowed by the California energy efficiency standards in effect at the time of submission of the project to the Division of the State Architect. For a new building on an existing campus, additions, and major modernizations, the exterior requirement applies to the entire school site, not just the lighting around the new building or the building(s) being modernized. In accordance with the 2014 School Design Guide, all luminaries or lighting sources in connection with school construction projects shall be installed in such a manner as to minimize glare for pedestrians and drivers and to minimize light spilling onto adjacent properties.
levels are shown as dBA. Leq is defined as the equivalent continuous sound pressure level, which represents the average of a 24-hour noise history at a location. 20 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 21 Parsons. August 21, 2014. Phase I Environmental Site Assessment Addendum: Future Mandarin Dual-Language Immersion School Site at the Mark Twain Middle School, 2224 Walgrove Avenue, Los Angeles, California 90066. 22 California Code of Regulations, Title 24. 23 State Mining and Geology Board. 13 March 1997. Guidelines for Evaluating and Mitigating Seismic Hazards in California. Special Publication 117. Available at: http://gmw.consrv.ca.gov/shmp/webdocs/sp117.pdf 24 California Geological Survey. October 2007. Note 48: Checklist for the Review of Geological/Seismic Reports for California Public Schools, Hospitals, and Essential Services Buildings. Available at: http://www.consrv.ca.gov/CGS/information/publications/cgs_notes/note_48/note_48.pdf 25 Collaborative for High Performance Schools. 2009. California Criteria for High Performance Schools Best Practices Manual. Volume III. 2009 Edition. Available at: http://www.chps.net/manual/index.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-13 Draft EIR Chapter 2. Project Description and Environmental Setting
Water Supply. LAUSD shall require its construction contractor to coordinate with the City of Los Angeles Department of Water and Power (LADWP) or other appropriate jurisdiction and department prior to the relocation or upgrade of any water facilities to reduce the potential for disruptions in service. With respect to outdoor systems, in accordance with CHPS Criteria WE1.0: Create Water Use Budget, CHPS requires the landscape and ornamental water-use budget to conform to the California Model Water Efficient Landscape Ordinance.
Fire Protection. In accordance with the 2014 School Design Guide, LAUSD shall reduce impacts to fire protection services in connection with new construction projects by requiring local fire jurisdictions to review and approve site plans.
Energy Efficiency. Under CHPS Criteria EE1.0: Minimum Energy Performance, new school designs must exceed the California energy efficiency standards (Title 24 – 2008, Part 6) by 15 percent or energy-efficient lighting with occupancy controls and/or economizers on the package equipment must be included in the design.26,27 In addition, new buildings must meet 2013 Title 24 standards, which became effective on July 1, 2014.28
Waste Reduction and Efficient Material Use. Under CHPS Criteria ME1.0: Storage and Collection of Recyclables, the proposed project must meet local ordinance requirements for recycling space and provide an easily accessible area serving the entire school that is dedicated to the separation, collection, and storage of materials for recycling including, at a minimum, paper, cardboard, glass, plastics, metals, and landscaping waste.
Indoor Air Quality. Under CHPS Criteria EQ2.0A: Minimum HVAC and Construction IEQ Requirements, the proposed project must meet the performance requirements of ASHRAE Standard 62.1-2007, which requires the design of building ventilation systems to ensure that the continuous delivery of outside air is no less than the governing design standard (Title 8, Sec. 5142), and occur at all times rooms are occupied. Ventilation rates shall be no less than required by California Title 24, Part 6, §121 or the outdoor ventilation rate calculated according to the outdoor air ventilation rate procedure in § 6.2 ASHRAE 62.1-2007. The design must ensure that the supply operates in continuous mode and is not readily defeated (i.e., blocked registers or windows) during occupancy periods.
Thermal Comfort. Under CHPS Criteria EQ2.0B: ASHRAE 55 Thermal Comfort Code Compliance and Moisture Control, the proposed project must comply, at minimum with the American Society of Heating, Refrigeration, and Air-Conditioning Engineers (ASHRAE) Standard 55-2004 for thermal comfort standards, including humidity control within established ranges per climate zone. Indoor design temperature and humidity conditions for general comfort applications shall be determined in accordance with appropriate American National Standards Institute (ANSI) or ASHRAE standards.29
26 Collaborative for High Performance Schools. 2009. California Criteria for High Performance Schools Best Practices Manual. Volume III. 2009 Edition. Available at: http://www.chps.net/manual/index.htm 27 California Energy Commission. Accessed 17 March 2015. 2008 Building Energy Efficiency Standards. Available at: http://www.energy.ca.gov/2008publications/CEC-400-2008-001/CEC-400-2008-001-CMF.PDF 28 California Energy Commission. May 2012. 2013 Building Energy Efficiency Standards. Available at: http://www.energy.ca.gov/2012publications/CEC-400-2012-004/CEC-400-2012-004-CMF-REV2.pdf 29 Note: ASHRAE Standard 55-2013 -- Thermal Environmental Conditions for Human Occupancy (ANSI Approved) is the most up-to-date version of ASHRAE 55. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-14 Draft EIR Chapter 2. Project Description and Environmental Setting
LAUSD Construction BMPs
Water Quality and Hydrology
LAUSD shall obtain a National Pollution Discharge Elimination System (NPDES) permit from the Regional Water Quality Control Board (RWQCB) with requirements for discharge, BMPs, and Stormwater Pollution Prevention Plan (SWPPP). LAUSD’s construction contractor shall properly discharge any water accumulation within the excavation pit in accordance with BMPs and a dewatering plan that must be developed and approved prior to construction as part of the NPDES General Construction Stormwater Permit. LAUSD’s construction contractor shall prevent sediment flows from entering storm drainage systems by constructing temporary filter inlets around existing storm drain inlets prior to the stabilization of the construction site area. The sediment trapped in these impounding areas shall be removed after each storm. LAUSD’s construction contractor shall collect and discharge surface runoff into the storm water collection system. The design of the storm drain system (i.e., drain inlets and conveyances) must be adequate to prevent localized flooding due to foliage and debris entrapment from increased storm runoff and prevent contamination of any nearby water basins.
To accommodate the additional storm water runoff and annual water yield resulting from the construction, storm drain improvements shall provide capacity to carry 25-year peak runoff rates. As required, an NPDES storm water permit application shall be submitted and the effluent quality criteria shall be specified in the permit, as determined by the Los Angeles RWQCB based on receiving water guidelines and waste load allocations. Monitoring of the outflow from the collection system may be required in the permit to ensure that the requirements and water quality criteria specified by the permit are achieved. The construction contractor shall use reclaimed water during the construction process, specifically for dust control, soil compaction, and concrete mixing, to the extent feasible.
Construction Traffic
LAUSD shall require its contractors to submit a construction worksite traffic control plan to the LADOT for review prior to construction. The plan will show the location of any haul routes, hours of operation, protective devices, warning signs, and access to abutting properties. LAUSD shall encourage its contractor to limit construction-related trucks to off-peak commute periods. As required by the State of California Department of Transportation (Caltrans), applicable transportation related safety measures shall be implemented during construction.
Construction Air Emissions
LAUSD shall comply with all applicable South Coast Air Quality Management District (SCAQMD) rules and regulations in carrying out its Program.
To reduce the potential for significant hazardous emissions during a removal action, LAUSD or its construction contractor shall:
Maintain slow speeds with all vehicles
Load impacted soil directly into transportation trucks to minimize soil handling
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Water/mist soil as it is being excavated and loaded onto the transportation trucks
Water/mist and/or apply surfactants to soil placed in transportation trucks prior to exiting the site
During dumping, minimize soil drop height into transportation trucks or stockpiles
During transport, cover or enclose trucks transporting soils, increase freeboard requirements, and repair trucks exhibiting spillage due to leaks
Cover the bottom of the excavated area with polyethylene sheeting when work is not being performed
Place stockpiled soil on polyethylene sheeting and cover with similar material
Place stockpiled soil in areas shielded from prevailing winds
Construction Noise
The LAUSD shall require the construction contractor to keep properly functioning mufflers on all internal combustion and vehicle engines used in construction. The LAUSD shall require its construction contractor to provide advance notice of the start of construction to all noise sensitive receptors, businesses, and residences adjacent to the project area. The announcement shall state specifically where and when construction activities will occur, and provide contact information for filing noise complaints. During construction activities, LAUSD’s construction contractor shall serve as the contact person in the event that noise levels become disruptive to local residents. During construction activities, the construction contractor shall locate portable equipment and shall store and maintain equipment as far as possible from the adjacent residents.
The LAUSD shall require the construction contractor to comply with all applicable noise ordinances of the affected jurisdiction (e.g., City of Los Angeles). In the event of complaints by nearby residents or receptors, the LAUSD shall monitor noise from the construction activity to ensure that construction noise does not exceed limits specified in the noise ordinance. LAUSD shall include the applicable city or county ordinance in all construction contracts. LAUSD shall require its contractors to build a masonry wall or other noise reducing measures along the property line adjacent to residential uses when necessary to reduce noise levels on adjacent sensitive receptors. If project construction noise levels are expected to exceed noise thresholds of significance, the LAUSD may require the construction contractor to install effective noise attenuation measures that may be identified as part of the environmental review of each individual project.
Hazardous Materials
For state-funded classroom construction projects, LAUSD shall assess and remediate hazardous materials under DTSC supervision. For classroom construction projects that do not receive DTSC oversight, LAUSD will assess and remediate hazardous material under supervision of the LAUSD OEHS.30 A Phase I Environmental Site Assessment and a supplemental soil survey have been
30 Education Code §17071.13, 17072.13, 17210, 17210.1, 17213.1-3 and 17268. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-16 Draft EIR Chapter 2. Project Description and Environmental Setting conducted for the Mark Twain Middle School campus, on which the proposed project site is situated, in order to establish the existing conditions of hazards and hazardous materials, and provide a basis for potential impacts resulting from hazards or hazardous materials.31,32 The supplemental soil survey that has been completed for the proposed project site concludes that the proposed development area is not adversely impacted by chemicals of potential concern.
Sewer Services
LAUSD or its construction contractor shall coordinate with the City of Los Angeles Department of Public Works, Bureau of Sanitation, and Bureau of Engineering or other appropriate jurisdictions and departments prior to the relocation or upgrade of any sewer facilities to reduce the potential for disruptions in service.
Waste Management
To ensure optimal diversion of solid resources generated by a project, the LAUSD shall require its contractors to prepare and implement, including reporting and documentation, a Waste Management Plan (Process) for reusing, recycling, salvage or disposal of non-hazardous waste materials generated during demolition and/or new construction (Construction & Demolition [C&D] Waste), to foster material recovery and reuse and to minimize disposal in landfills. In accordance with the CHPS Criteria ME2.0: Minimum Construction Site Waste Management, all new construction work and major modernizations are required to recycle, compost, and/or salvage at least 50% (by weight) of the non-hazardous construction and demolition debris. In accordance with the 2014 School Design Guide, LAUSD shall establish a minimum non-hazardous construction and demolition debris recycling requirement of 75 percent of waste, as defined in Specification 01340, Construction & Demolition Waste Management. LAUSD has established procedures for C&D Waste management that must be complied with in meeting this requirement. The procedures establish a standard format for preparing the plan and monthly progress reporting.33 2.4 REQUIRED PERMITS AND APPROVALS
As required by the State CEQA Guidelines,34 this section provides, to the extent the information is known to LAUSD, a list of the agencies that are expected to use the EIR in their decision-making and a list of permits and other approvals required to implement the project.
2.4.1 LEAD AGENCY APPROVAL
The Final EIR must be certified by the LAUSD Board of Education as to its adequacy in complying with the requirements of CEQA before action can be taken on the proposed project. The Board of Education shall consider the information contained in the EIR in making a decision to approve or deny the proposed project. The analysis in the EIR is intended to provide environmental review for
31 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 32 Parsons. August 21, 2014. Phase I Environmental Site Assessment Addendum: Future Mandarin Dual-Language Immersion School Site at the Mark Twain Middle School, 2224 Walgrove Avenue, Los Angeles, California 90066. 33 California Integrated Waste Management Act of 1989 and CCR Title 14, §18700. 34 California Code of Regulations. Title 14, Division 6, Chapter 3, Section 15124(d). Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-17 Draft EIR Chapter 2. Project Description and Environmental Setting the whole of the proposed project, including the planning of the proposed project, site acquisition, demolition (if necessary), site clearance, excavation and grading of the site, construction of school buildings and appurtenant facilities, and ongoing operation of the school and associated school programs in accordance with CEQA requirements. This EIR is intended to provide environmental review for the proposed project in accordance with the requirements of CEQA.
2.4.2 REQUIRED PERMITS AND APPROVALS
A public agency, other than the Lead Agency, that has discretionary approval power over a project is known as a Responsible Agency, as defined by State CEQA Guidelines.35 The Responsible Agencies and their corresponding approvals for this project include the following: State of California
Department of Education
. School Facilities Planning Division (approval of final plan and final site)
Department of General Services
. Division of State Architect (approval of construction drawings)
Department of Toxic Substances Control (Determination of “No Further Action”) City of Los Angeles
Department of Public Works Bureau of Engineering (approval of b-permit plans and work)
Fire Department (approval of site plan for emergency access) Regional Agencies
Los Angeles Regional Water Quality Control Board (NPDES permit, issuance of waste discharge requirement [WDR] permit, construction storm water run-off permits, 401 waiver of water quality certification)
2.4.3 REVIEWING AGENCIES
Reviewing Agencies include those agencies that do not have discretionary powers, but that may review the EIR for adequacy and accuracy. Potential Reviewing Agencies include the following: Federal
U.S. Army Corps of Engineers
U.S. Fish and Wildlife Service
35 California Code of Regulations. Title 14, Division 6, Chapter 3, Sections 15000–15387. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-18 Draft EIR Chapter 2. Project Description and Environmental Setting
State of California
Environmental Protection Agency
. Department of Toxic Substances Control
Office of Historic Preservation
Department of Transportation
Natural Resources Agency
. Department of Conservation
. Department of Fish and Wildlife
. Department of Parks and Recreation
. Native American Heritage Commission
California Highway Patrol City of Los Angeles
Department of City Planning
Department of Transportation
Police Department
Bureau of Sanitation
Waste Water Engineering Services Division
Department of Water and Power
Department of Recreation and Parks
Department of Environmental Affairs Regional Agencies
Los Angeles County Metropolitan Transportation Authority
Los Angeles Regional Water Quality Control Board
South Coast Air Quality Management District
Southern California Association of Governments
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2.5 CUMULATIVE SCENARIO
Cumulative impacts refer to the combined effect of proposed project impacts with the impacts of other past, present, and reasonably foreseeable future projects. CEQA requires that cumulative impacts be analyzed in an EIR.36 As set forth in the State CEQA Guidelines, the discussion of cumulative impacts must reflect the severity of the impacts, as well as the likelihood of their occurrence; however, the discussion need not be as detailed as the discussion of environmental impacts attributable to the project alone.37 As stated in CEQA, a project may have a significant effect on the environment if the possible effects of a project are individually limited but cumulatively considerable.38
According to the State CEQA Guidelines:
Cumulative impacts refer to two or more individual effects which, when considered together, are considerable and which compound or increase other environmental impacts.
The individual effects may be changes resulting from a single project or a number of separate projects.
The cumulative impact from several projects is the change in the environment, which results from the incremental impact of the proposed project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.39
In addition, as stated in the State CEQA Guidelines, it should be noted that:
The mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.40
Cumulative impact discussions for each issue area are provided in the technical analyses contained within Chapter 3, Environmental Analysis.
As previously stated, and as set forth in the State CEQA Guidelines, related projects consist of closely related past, present, and reasonably foreseeable probable future projects that would likely result in similar impacts and are located in the same geographic area.41 The LADOT identified 18 potential projects within the cumulative impact area of the proposed project. These related projects are located within a 2-mile radius from the proposed project site and are listed in Table 2.5-1, List of Related Projects: LADOT Project Record, along with their location and a brief description (Figure 2.5-1, Map of Related Projects).
36 California Code of Regulations. Title 14, Division 6, Chapter 3, Sections 15000–15387. 37 California Code of Regulations. Title 14, Division 6, Chapter 3, Section 15130(b). 38 Public Resources Code. Title 14, Section 21083(b). 39 California Code of Regulations. Title 14, Division 6, Chapter 3, Section 15355. 40 California Code of Regulations. Title 14, Division 6, Chapter 3, Section 15064(h)(4). 41 California Code of Regulations. Title 14, Division 6, Chapter 3, Section 15355. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-20 Draft EIR LEGEND !( LADOT Related Projects ^]! Project Site Project Site 2-Mile Radius
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FIGURE 2.5-1 Map of Related Projects Chapter 2. Project Description and Environmental Setting
It is noted that cumulative impacts analyzed in this EIR would likely represent a “worst-case” scenario for the following reasons:
Not all the related projects will be approved and/or built. Further, it is also likely that several of the related projects will not be constructed at the same time as the proposed project or opened until after the proposed project has been built and occupied.
Impact projections for related projects would likely be, or have been, subject to unspecified mitigation measures, which would reduce potential impacts.
Many related projects are expressed in terms of gross square footage or are conceptual plans such as master plans that assume complete development; in reality, such projects may be smaller because of the demolition or removal of existing land uses resulting from the development of the related projects.
Table 2.5-1: List of Related Projects: LADOT Record of Proposed Projects Code Year of Distance First Traffic from Mark Study Twain Submittal Middle Project Name Location Description Date School Proposed House Of Pies, sit-down 1020 West Venice high-turnover restaurant, 3895 sf, 0.7 mile A House Of Pies Restaurant Boulevard, Venice, expected to generate 33 net A.M. 2013 south- CA 90291 trips, 33 net P.M. trips (396 net daily southwest trips) 2,195 sf Starbucks coffee shop 12404 West Venice Change of Use from Retail to without drive through, expected to B Boulevard, Los 2014 0.7 mile east Restaurant generate 119 net A.M. trips, 45 net Angeles, CA 90066 P.M. trips (899 net daily trips) 67-DU condo and 7,525 sf 4091 South Redwood commercial office building providing Condominium & Commercial 0.8 mile C Avenue, Los 111 parking spaces, expected to 2014 Office Building south Angeles, CA 90066 generate 25 net A.M. trips, 51 net P.M. trips (391 net daily trips) Mixed-use (apartments/retail), 280 1400 South Lincoln apartment units, 197,000 sf gross 0.9 mile D Lincoln Center Project Boulevard, Playa Del retail area, expected to generate 196 2000 west- Rey, CA 90291 net A.M. trips, 460 net P.M. trips southwest (10,593 net daily trips) New 4-story, 67-unit apartment and 4140 South Glencoe 3,211 sf office building over 2-level New apartment and office 0.9 mile E Avenue, Marina del parking garage, expected to 2012 building VTT-72107 south Rey, CA 90292 generate 39 net A.M. trips, 56 net P.M. trips (481 net daily trips)
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Table 2.5-1: List of Related Projects: LADOT Record of Proposed Projects Code Year of Distance First Traffic from Mark Study Twain Submittal Middle Project Name Location Description Date School New 4-story, 51-unit residential 4090 Del Rey apartment building over 3-level 0.9 mile F Apartments (51 Units) Avenue, Marina del parking garage, expected to 2013 south Rey, CA 90292 generate 26 net A.M. trips, 36 net P.M. trips (339 net daily trips) New 136-condiminium, 20,000 4210 South Del Rey square-foot office space mixed use, 1.0 mile G Mixed-Use Condominiums/Office Avenue, Marina del expected to generate 57 net A.M. 2015 south Rey, CA 90292 trips, 66 net P.M. trips (559 net daily trips) 158 unit condominium and 3,178 sf 4363 Lincoln gross retail area, expected to 1.2 miles H MDR Tower Boulevard, Marina 2006 generate 73 net A.M. trips, 127 net south del Rey, CA 90292 P.M. trips (1,062 net daily trips) Southeast Corner of 92 dual-unit residential and 15,000 sf West Washington Washington/Inglewood of commercial development, Boulevard and 1.4 miles I Multifamily Residential and expected to generate 61 net A.M. 2015 Inglewood Boulevard, east Commercial trips, 113 net P.M. trips (1,253 net Los Angeles, CA daily trips) 90066 Increase in enrollment at Private 12095-12101 West Summit View School Expansion School (Grades 2-12) by 200 Washington 1.4 miles J (Enrollment Increase from 400 to students, expected to generate 162 2015 Boulevard, Los east 600) net A.M. trips, 34 net P.M. trips (496 Angeles, CA 90066 net daily trips) 2919 Lincoln Boulevard/802 10 dual-unit apartment, expected to 1.5 miles K Apartment Ashland Avenue, generate 5 net A.M. trips, 6 net P.M. 2015 west Santa Monica, CA trips (67 net daily trips) 90405 New 92-guest room hotel, 3,000 sf 1027 South Abbot retail, & 2,072 sf restaurant use, Mixed-Use, Hotel, Retail & 1.6 miles L Kinney Boulevard, expected to generate 25 net A.M. 2012 Restaurant Uses southwest Venice, CA 90291 trips, 42 net P.M. trips (654 net daily trips) New 14,900 square-foot shopping 4114 Sepulveda Culver Crossroads Shopping center, expected to generate 14 net 1.7 miles M Boulevard, Culver 2015 Center A.M. trips, 55 net P.M. trips (636 net northeast City, CA 90230 daily trips) New Five 2-Unit Residential project 4044-4068 Globe with 10 dual units, expected to 1.7 miles N Globe Housing Project Avenue, Culver City, 2015 generate 5 net A.M. trips, 6 net P.M. east CA 90230 trips (67 net daily trips)
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-22 Draft EIR Chapter 2. Project Description and Environmental Setting
Table 2.5-1: List of Related Projects: LADOT Record of Proposed Projects Code Year of Distance First Traffic from Mark Study Twain Submittal Middle Project Name Location Description Date School 2200 Virginia New 8,630 sf library, not expected to 1.9 miles O Pico Neighborhood Library Avenue, Santa 2015 generate vehicular traffic northwest Monica, CA 90404 New 21 dual-unit condominiums, 2002 21st Street, expected to generate 9 net A.M. 1.9 miles P Virginia Townhomes Santa Monica, CA 2015 trips, 11 net P.M. trips (122 net daily northwest 90404 trips) 3115 South 28,000 sf specialty retail center and Sepulveda 138-du condominium, expected to 2.0 miles Q Mixed Use 2008 Boulevard, Los generate 73 net A.M. trips, 111 net northeast Angeles, CA 90034 P.M. trips (772 net daily trips) 32 dual-unit condominiums, 1112 Pico Boulevard, expected to generate 14 net A.M. 2.0 miles R Condominium Santa Monica, CA 2015 trips, 17 net P.M. trips (186 net daily northwest 90405 trips) SOURCE: Pedro B. Ayala, Transportation Engineering Associate II. Los Angeles Department of Transportation (LADOT), West LA/Coastal Development Review. Related Projects Request by Ms. Laura Male on October 30, 2014 for current and upcoming projects within a two-mile radius of Mark Twain Middle School (2224 Walgrove Avenue, Los Angeles, CA 90066). KOA Corporation. 23 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Table 7: Area/Cumulative Projects Trip Generation Summary. Monterey Park, California.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 2-23 Draft EIR CHAPTER 3.0 ENVIRONMENTAL ANALYSIS
3.1 ENVIRONMENTAL ISSUES ADDRESSED
The 18 environmental issue areas (17 recommended pursuant to Appendix G of the State CEQA Guidelines and pedestrian safety, an additional issue area required by the LAUSD) that were evaluated resulted in three distinct significance determination (Table 3.1-1, Summary of Environmental Impacts): (1) no Impact for five environmental issues; (2) less than significant impact for nine environmental issues; and (3) potentially significant impacts warranting the consideration of mitigation measures and alternatives for four environmental issue areas.
Table 3.1-1: Summary of Environmental Impacts No Impact Less than Significant Impact Potentially Significant Impact Agriculture and Forestry Resources Aesthetics Cultural Resources Hazards and Hazardous Materials Air Quality Noise Land Use and Planning Biological Resources Pedestrian Safety Mineral Resources Geology and Soils Transportation and Traffic Population and Housing Greenhouse Gas Emissions Hydrology and Water Quality Public Services Recreation Utilities and Service Systems
The environmental issues and their corresponding subchapter numbers discussed in this EIR include:
3A – Aesthetics
3B – Agriculture and Forestry Resources
3C – Air Quality
3D – Biological Resources
3E – Cultural Resources
3F – Geology and Soils
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3-1 Draft EIR Chapter 3.0 Environmental Analysis
3G – Greenhouse Gas Emissions
3H – Hazards and Hazardous Materials
3I – Hydrology and Water Quality
3J – Land Use and Planning
3K – Mineral Resources
3L – Noise
3M – Pedestrian Safety
3N – Population and Housing
3O – Public Services
3P – Recreation
3Q – Transportation/Traffic
3R – Utilities and Service Systems
These subchapters provide a detailed discussion of the environmental setting, applicable project design features, impacts associated with the proposed project, cumulative impacts, and mitigation measures designed to reduce significant impacts. 3.2 ORGANIZATION OF ENVIRONMENTAL ANALYSIS
To assist the reader in comparing information about the various environmental issues, each subchapter contains the following information.
Introduction
Regulatory Framework
Existing Conditions
Thresholds of Significance
Impact Analysis
Cumulative Impacts
Mitigation Measures
Level of Significance after Mitigation
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3-2 Draft EIR Chapter 3.0 Environmental Analysis
3.3 TERMINOLOGY USED IN THIS ANALYSIS
For each impact identified in this EIR, a statement of the level of significance of the impact is provided. Impacts are categorized as follows:1,2
A designation of no impact is given when no adverse changes in the environment are expected.
A less than significant impact would cause no substantial adverse change in the environment.
A less than significant impact with mitigation incorporated would have a substantial adverse effect on the environment but could be reduced to a less than significant level with incorporation of mitigation measure(s).
A significant and unavoidable impact would cause a substantial adverse effect on the environment, and no feasible mitigation measures would be available to reduce the impact to a less than significant level.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15064.7. 2 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15382. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3-3 Draft EIR SUBCHAPTER 3A Aesthetics
This analysis is undertaken to determine if the proposed project may have a significant impact to aesthetics, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to aesthetics at the proposed project site was evaluated with regard to the California Department of Transportation’s (Caltrans’) Scenic Highway System2 designations, previously published information regarding the visual character of the proposed project site, including light and glare; site reconnaissance; and a review of Google Earth street view photography.
3A.1 REGULATORY FRAMEWORK Federal
There are no applicable federal plans or policies related to aesthetics. State
California Streets and Highways Code, Sections 260 through 263
The California Scenic Highway Program preserves and protects scenic highway corridors from changes that would diminish their aesthetic value. Caltrans designates scenic highway corridors and establishes those highways that are eligible for the program. The program was adopted in 1963 with the enactment of the State Scenic Highways Law. The street and highway code includes a list of those highways that are either eligible for designation or are designated.3
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 California Department of Transportation. Accessed 17 October 2014. The California Scenic Highway Program: Eligible (E) and Officially Designated (OD) Routes. Available at: http://www.dot.ca.gov/hq/LandArch/scenic/cahisys.htm 3 California Department of Transportation. Accessed 17 October 2014. Scenic Highway Program: Eligible (E) and Officially Designated (OD) Routes. Available online at: http://www.dot.ca.gov/hq/LandArch/scenic/cahisys.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-1 Draft EIR Subchapter 3A. Aesthetics
Local
School Design Guide: Los Angeles Unified School District
The 2014 School Design Guide for LAUSD establishes the following standards relevant to aesthetics:4
Trees
. Implement LAUSD tree removal and replacement policy when it is required that a tree be removed, including replacement in accordance with the following guidelines:
o Newly planted trees should be a 24” box or larger at planting.
o Tree species must be of appropriate size at maturity for the space planted.
o The selection must be made from the LAUSD Approved Plant List.
o Trees will be provided and planted by each area’s gardening crews.
. Provide for fast-growing shade trees on the perimeter of Elementary School Playgrounds, surrounding Outdoor Assembly Areas, in Outdoor Eating Areas, in Kindergarten Play Areas, and in selected areas for outdoor instruction and small group gatherings.
. Provide trees to shade buildings, where other conditions permit, on the south (tall deciduous trees), east (deciduous trees), and west exposures (evergreen trees).
. Provide at least one mulberry tree on each Elementary School Campus, in the Kindergarten or Primary Grade Play Areas.
. Provide trees to shade parking and other large paved areas to reduce the heat-island effect.
Gates and Fencing
. Provide full perimeter fence or wall enclosure for school campus; buildings may be used in lieu of a fence when located within 5’-0” of the sidewalk.
. Perimeter and parking area walls and fences should be 8’-0” in height.
Site Lighting
. Provide exterior lighting to enhance site security, including area lighting, walkway lights, and building perimeter illumination.
4 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/documents/download/asset_management/school_design_guide/School_Design_Guide _Jan_2014.pdf?version_id=310708755 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-2 Draft EIR Subchapter 3A. Aesthetics
. Eliminate direct-beam projection off-site or glare off buildings into adjoining residential areas or other occupancies.
. Campus and parking areas and building perimeters must be lighted to provide for the safety of people and the security of property. Provide adequate light, properly distributed to reveal such hazards as curbs and steps, and to illuminate dark and potentially dangerous areas. Solid state lighting is the preferred light source.
. Provide safety and security lighting on exterior walls of buildings, building entrances, parking lots, covered walks, and where needed to meet specific project requirements.
. Lighting fixtures must be installed in such a manner as to minimize glare for pedestrians and drivers, and to avoid light spilling onto adjacent properties.
Signage
. Provide metal letter signs at the main entry of school to identify the name of the school and street address. Signs shall be visible by both pedestrian and vehicular traffic.
3A.2 EXISTING CONDITIONS Scenic Vistas
The City of Los Angeles has not designated any scenic vistas in the City of Los Angeles, although Section 15 of the Conservation Element identifies three categories of scenic resources within the City of Los Angeles that are relevant to the consideration of the proposed project:5
Scenic Features:
. Views of the ocean
. Striking or unusual natural terrain
. Unique urban or historic features
The proposed project site is located approximately 2.0 miles away from the ocean and has a relatively flat terrain, with a topographic range of less than 5 feet from approximately 37 feet above MSL to approximately 41 feet above MSL. The proposed project site is not visible from the nearest beach, Venice Beach, due to distance and buildings ranging from 10 feet to 50 feet tall between the school and the beach.
There is no striking or unusual natural terrain visible from the school, nor is the school visible from any striking or unusual natural terrain.
5 City of Los Angeles Department of City Planning. September 2001. City of Los Angeles Conservation Element. Available at: http://cityplanning.lacity.org/cwd/gnlpln/consvelt.pdf Section 15: Land Form and Scenic Vistas. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-3 Draft EIR Subchapter 3A. Aesthetics
Unique urban or historic features within the Palms – Mar Vista – Del Rey CPA include (Figure 3A.2-1, Unique Urban & Historic Features):
The Venice Japanese Community Center on Braddock Drive. Located approximately 1.7 mile east of the proposed project site, the proposed project site is shielded from view by buildings and ornamental street trees.
The Gregory Ain housing tract, also known as Mar Vista Houses located on Meier, Moor, and Beethoven Street, south of Marco Place, a small-scale low-cost housing development that was built in 1946–1948 by the famous architect Gregory Ain. Located approximately 0.1 mile north of the proposed project site, the proposed project site is shielded from view by residential buildings and ornamental street trees.
The Moreton Bay Fig tree at 11000 National Boulevard at Military Avenue, which was planted in 1875, described as “the greatest of Australian avenue trees.” Located approximately 2.1 miles northeast of the proposed project site, the proposed project site is shielded from view by buildings and ornamental street trees.
The Ivy Substation, a cultural landmark located at 9015 Venice Boulevard that was completed in July 1907 to provide power for the expanding system of the Los Angeles Pacific Railway. Located approximately 3.4 miles east of the proposed project site, the proposed project site is shielded from view by buildings and ornamental street trees. State Scenic Highways
There are no officially designated or eligible state scenic highways on or adjacent to the proposed project site. According to the California Scenic Highway Program, the nearest officially designated scenic highway is 55.1 miles of State Route 2 (Angeles Crest Highway),6 located approximately 21.6 miles to the northeast of the proposed project site (Figure 3A.2-2, State, County, & City Designated Scenic Highways). The nearest state designated historic parkway is 6 miles of Interstate Route 110 (Arroyo Seco Historic Parkway),7 located approximately 13.6 miles east-northeast of the proposed project site. The nearest eligible state scenic highway is State Route 1 (Lincoln Boulevard), which is located approximately 0.6 mile southwest of the proposed project site within Mark Twain Middle School (located 0.5 mile northwest of State Route 1) at the nearest point (intersection of Venice Boulevard and Lincoln Boulevard).8 State Route 27 (Topanga Canyon Boulevard) is the next nearest eligible state scenic highway, located approximately 8.1 mile northwest of the proposed project site. The proposed project site cannot be viewed from any of these highways, due to distance, intervening topography, and the built environment.
6 California Department of Transportation. Accessed 22 October 2014. Officially Designated State Scenic Highways. Available at: http://www.dot.ca.gov/hq/LandArch/scenic/schwy.htm 7 Caltrans Roadside Resource Assets and Scenic Highway Coordinator. Accessed 22 October 2014. Route 110 – Historic Parkway. Available at: http://www.dot.ca.gov/hq/LandArch/scenic_highways/route110.htm 8 California Department of Transportation. Accessed 22 October 2014. Eligible (E) and Officially Designated (OD) Routes. Available at: http://www.dot.ca.gov/hq/LandArch/scenic/cahisys.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-4 Draft EIR LEGEND !( 1875 Moreton Bay Fig Tree !( 1907 Culver City Ivy Substation 1946-1948 Gregory Ain Mar Vista Historic Housing Tract (Historic Preservation Zone)
Venice Japanese Community Center Proposed Mandarin Immersion Elementary School
!( Culver City Moreton Bay Ivy Substation Fig Tree !(
Gregory Ain Mar Vista Historic Housing Tract
Proposed Mandarin Immersion Elementary School
Venice Japanese Community Center
SOURCE: SEI, ESRI, City of Los Angeles
0 0.25 0.5 1 Miles o 1:35,000 Q:\1498\MarkTwain_MS\ArcProjects\HistoricFeatures.mxd
FIGURE 3A.2-1 Unique Urban & Historic Features Q:\1498\MarkTwain_MS\ArcProjects\ScenicHighways.mxd
0 2.5 5 10 Miles o 1:450,000 SOURCE: SEI, ESRI, Caltrans, City of Los Angeles ÄÃ126
[^210
ÄÃ118 ÄÃ2
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ÄÃ1 LEGEND !( Project Site City of Los Angeles Designated Scenic Highway Officially Designated State Scenic Highway Officially Designated County Scenic Highways Eligible State Scenic Highways Historic Parkway
FIGURE 3A.2-2 State, County, & City Designated Scenic Highways Subchapter 3A. Aesthetics
Visual Character and Quality
The proposed project site is located approximately 10 miles west of the downtown Los Angeles skyline and associated clusters of high-rise development. Consistent with the provisions of the surrounding zoning classifications (R1-1 and [Q]RD2-1XL, RD2-1, M2-2, and M1-1), the area surrounding the proposed project site is predominantly developed with low-density single family residences located immediately to the northwest, west, south, and east; and low medium density multiple family residences located to the northeast. The adjacent residential buildings to the northwest are approximately 12 to 20 feet tall, the residences to the northeast of the proposed project site are approximately 12 to 24 feet tall, and the residences to the southeast of Mark Twain Middle School range from 12 to 24 feet tall.
The existing buildings on the northeastern and eastern portions of the adjacent Beethoven Elementary School campus, which is located northeast of the proposed project site, are approximately 12 to 20 feet tall. The Beethoven Elementary School campus is separated from the adjacent Mark Twain Middle School campus by a chain-link fence and a row of ornamental Chinese Elm trees and one fruit tree along Victoria Avenue. The school campus is organized with an L-shape of buildings along Lucille Avenue and Beethoven Avenue, and playground and athletic facilities facing Victoria Avenue and the athletic track on the Mark Twain Middle School campus, with a small garden at the northwestern corner of the elementary school campus. Where the line of buildings does not create a natural barrier, the rest of the Beethoven Elementary School campus is enclosed by 8-foot-high chain-link fencing.
The existing visual character of the proposed project site is characteristic of a public middle school. The portion of the school campus that is proposed for development consists of eight existing portable classrooms (0.2 acre) that would be modernized and the 0.1-acre asphalt walkway to the north of the classrooms, 0.1 acre of sidewalk along Victoria Avenue, 1.9 acres of asphalt with painted parking stalls and a painted track, and 1.9 acres of an athletic field, for a total of approximately 4.2 acres on the existing Mark Twain Middle School campus (21.3 acres). Approximately 2.3 acres of the 4.2-acre proposed project site are paved, and the remaining 1.9 acres are a multi-use turf athletic field with four baseball backstops and one ornamental Chinese elm tree (see Figure 2.2.2-3, Aerial Photograph, Figure 3A.2-3, Key Observation Points, and Figure 3A.2-4, Key Observation Point Map). A portion of the asphalt area is used for six tennis courts, and 1.0 acre contains a painted track. The Mark Twain Middle School campus consists of 34 buildings (26 permanent buildings and 8 portable buildings) including 19 primary classroom buildings, an administrative building, a gymnasium, a multi-purpose building, and an industrial arts building. The portable buildings are located at the southeastern perimeter of the staff parking lot and along the southern perimeter of the garden. The majority of the existing buildings on the Mark Twain Middle School campus are single story and approximately 10 to 15 feet tall. The tallest buildings on the campus are the administrative building and the physical education building, which are approximately 35 feet tall.
Where the existing buildings do not create a natural barrier, the rest of the Mark Twain Middle School campus is enclosed by 8-foot-high chain-link fencing. The northern border of the proposed project site along Victoria Avenue is separated from the 3-foot-wide sidewalk by a chain-link fence. The topography is graded and relatively flat, with a general slope down to the southwest.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-5 Draft EIR G:\1498\1498-019\Documents\Draft EIR
KOP 1 Rosewood Ave and Venice Blvd - North-Northwest
KOP 2 Greenwood Ave and Venice Blvd - North-Northwest
FIGURE 3A.2-3 Key Observation Points KOP 3 Victoria Ave and Ashwood Ave - East-Northeast (GoogleEarth)
KOP 4 Victoria Ave and Maplewood Ave - South-Southeast
FIGURE 3A.2-3 Key Observation Points KOP 5 Victoria Ave and Alleyway - East (GoogleEarth)
KOP 6 Victoria Ave and Rosewood Ave - South-Southeast
FIGURE 3A.2-3 Key Observation Points KOP 7 Victoria Ave and Greenwood Ave - West-Southwest (GoogleEarth)
FIGURE 3A.2-3 Key Observation Points LEGEND !( Key Observation Point (KOP) # Direction of Photograph
G r e Student Garden e n vd w Bl o Proposed New Frontage s o alm d and Drop Off for Mandarin P A v e Immersion Elementary School Proposed Restriped Parking for M Mark Twain Middle School a p le w Proposed Mandarin Immersion o o Elementary School d A v e Mark Twain Middle School
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SOURCE: SEI, ESRI
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FIGURE 3A.2-4 Key Observation Point Map Subchapter 3A. Aesthetics
The existing streetscape at Victoria Avenue contains a 3-foot-wide sidewalk and a designated crosswalk at Maplewood Avenue, with public signage indicating No Stopping zones, stop signs, and street signs. There are no street trees, street lighting, street furniture, or other streetscape elements. Light and Glare
There are no sources of light within the proposed project site. There are no street lights on Victoria Avenue. The nearest existing sources of light are the existing buildings on the Mark Twain Middle School campus, adjacent motor vehicles on Victoria Avenue, and nearby residences located on the northern side of Victoria Avenue, approximately 40 feet to the northwest of the proposed project site. The security lighting on the campus is mounted on the buildings at approximately 16 feet high to illuminate all exterior doors and is shielded on top to orient the light downward and horizontally.
There are no sources of glare within the proposed project site. There are minimal levels of glare generate from window and reflective surface on the buildings within the Mark Twain Middle School, adjacent Beethoven Elementary, and single- and multi-family residences.
3A.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of four questions when addressing the potential for significant impacts to aesthetics. Would the proposed project: a. Have a substantial adverse effect on a scenic vista? b. Substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway? c. Substantially degrade the existing visual character or quality of the site and its surroundings? d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
3A.4 IMPACT ANALYSIS
Impact 3A-a: Would the proposed project have a substantial adverse effect on a scenic vista?
No Impact
The proposed project would not result in impacts to aesthetics in relation to scenic vistas. The City of Los Angeles has not designated any scenic vistas within the proposed project area or any area that would be affected by the development of the proposed project area.9 The proposed project site does not change the viewshed from Venice Beach, is not visible from any unique natural area, and does not change the viewshed of any historic building or unique urban structure. Existing
9 City of Los Angeles Department of City Planning. September 2001. City of Los Angeles Conservation Element. Available at: http://cityplanning.lacity.org/cwd/gnlpln/consvelt.pdf Section 15: Land Form and Scenic Vistas. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-6 Draft EIR Subchapter 3A. Aesthetics buildings, trees, and infrastructure shield the proposed project site from view from these unique features. Therefore, there would be no impacts to aesthetics related to scenic vistas.
Impact 3A-b: Would the proposed project substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway?
No Impact
The proposed project would not result in impacts to aesthetics in relation to substantial damage of scenic resources within a state scenic highway as there are no officially designated or eligible state scenic highways on or adjacent to the proposed project site (see Figure 3A.2-2). The proposed project site cannot be viewed from the nearest designated and proposed state scenic highways that are located 0.6 mile or more away, due to distance, intervening topography, and the built environment. Therefore, the proposed project would not substantially damage scenic resources within a state scenic highway, and no further study of this issue is required.
Impact 3A-c: Would the proposed project substantially degrade the existing visual character or quality of the site and its surroundings?
No Impact
The proposed project would not substantially degrade the existing visual character or quality of the site and its surroundings.
The proposed project would be designed to meet the requirements and standards of LAUSD’s 2014 School Design Guide, including the planting of shade trees, replacement of trees removed at the project site, and the installation of signage at the main school entry that blends with the visual character of the existing campus.10 The proposed project would consist of building materials comparable to the existing wood frame, masonry, and concrete buildings with brick and painted finishes on the campus. The size and massing of the new building, which would be no taller than the existing 35-foot-high administrative building and physical education building, would be consistent with the existing buildings on the campus. No existing buildings on the campus would be demolished or removed as a result of the project. Therefore, the proposed project would not substantially degrade the existing visual character or quality of the site and its surroundings, and no further study of this issue is required.
10 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/documents/download/asset_management/school_design_guide/School_Design_Guide _Jan_2014.pdf?version_id=310708755 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-7 Draft EIR Subchapter 3A. Aesthetics
Impact 3A-d: Would the proposed project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than Significant Impact
The proposed project would result in a less than significant light or glare impact on day or nighttime views in the area. The proposed project would involve security lighting around the exterior walls and at the entrance of the new building, area lighting, and along walkways, with a focus on providing adequate light to reveal curbs and steps and illuminate dark and potentially dangerous areas. In accordance with the 2014 School Design Guide Standards, all luminaries or lighting sources in connection with construction would be installed in such a manner as to minimize glare for pedestrians and drivers and to minimize light spilling onto adjacent properties; the same type of elevated security lighting installed at the existing campus buildings. There are no existing street lights on Victoria Avenue. Although not required, lighting systems for the proposed project would be designed to minimize glare and “light trespass.”11 Therefore, the proposed project would result in a less than significant impact in regard to creating a new source of substantial light or glare that would adversely affect day or nighttime views in the area. No further study of this issue is required.
3A.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to aesthetics. Therefore, there would be no cumulative impacts.
3A.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development, design, and construction standards that would meet LAUSD Design Standards. Therefore, impacts related to aesthetics would be less than significant, and no mitigation measures are required.
3A.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3A-a, 3A-b, and 3A-c: No impact.
Impact 3A-d: Less than significant impact.
11 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. June 27, 2007 Land use map available online at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available online at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Chapter V. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3A-8 Draft EIR SUBCHAPTER 3B Agriculture and Forestry Resources
This analysis is undertaken to determine if the proposed project may have a significant impact to agriculture and forestry resources which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to agriculture and forestry resources at the proposed project site were evaluated with regard to the California Department of Conservation (CDC) Farmland Mapping and Monitoring Program (FMMP),2,3 and the California Land Conservation Act of 1965 (the Williamson Act).4
Definitions
Agricultural Land: State CEQA Statutes (§21060.1(a)) Public Resources Code 21000-21177) define agricultural land to mean “prime farmland, farmland of statewide importance, or unique farmland, as defined by the United States Department of Agriculture (USDA) land inventory and monitoring criteria, as modified for California,” and is herein collectively referred to as “Farmland.”
Forest Land: Public Resources Code Section 12220(g) defines Forest Land as “land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.”5
Timberland: Public Resources Code Section 4526 defines Timberland as “land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees.”6
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 California Department of Conservation, Division of Land Resource Protection, Farmland Mapping and Monitoring Program. 2004. Important Farmland in California, 2002. Sacramento, CA. 3 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf. Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf 4 State of California Department of Conservation. Accessed 15 October 2014. Governing Statutes: California Land Conservation Act. Available at: http://www.conservation.ca.gov/dlrp/lca/lrcc/Pages/governing_statutes.aspx 5 State of California. Accessed 15 October 2014. Public Resources Code Section 12220. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=prc&group=12001-13000&file=12220 6 State of California. Accessed 15 October 2014. Public Resources Code Section 4521-4529.5. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=prc&group=04001-05000&file=4521-4529.5
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Timberland Production Zone: California Government Code Section 51104(g) defines a Timberland Production Zone (TMZ) as “an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses, as defined in subdivision (h). With respect to general plans of cities and counties, ‘timberland preserve zone’ means ‘timberland production zone.’”7
3B.1 REGULATORY FRAMEWORK
Federal
There are no applicable federal plans or policies related to agriculture and forestry resources.
State
Farmland Mapping and Monitoring Program (FMMP)
The FMMP was established in 1982 to assess the location, quality, and quantity of agricultural lands in the State of California and conversion of these lands over time.8 The goal of the FMMP is to provide consistent and impartial data to decision makers for use in planning for the future of California’s agricultural land resources. The CDC applies the Natural Resources Conservation Service (NRCS) soil classifications to identify agricultural lands, and these agricultural designations are used in planning for the present and future of California’s agricultural land resources. The CDC has a minimum mapping unit of 10 acres, with parcels smaller than 10 acres being absorbed into the surrounding classifications. There are five CDC mapping categories that are relevant to the evaluation of agriculture:9
Prime Farmland. Farmland that has the best combination of physical and chemical features able to sustain long-term agricultural production. This land has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
Farmland of Statewide Importance. Farmland similar to Prime Farmland but with minor shortcomings, such as greater slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date.
7 State of California. Accessed 15 October 2014. Government Code Section 51100-51104. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=gov&group=51001-52000&file=51100-51104 8 State of California Department of Conservation. Accessed 15 October 2014. Farmland Mapping and Monitoring Program. Available at: http://www.conservation.ca.gov/DLRP/FMMP/Pages/Index.aspx 9 California Department of Conservation Division of Land Resource Protection. 2004. A Guide to the Farmland Mapping and Monitoring Program. Available at: http://www.conservation.ca.gov/dlrp/fmmp/Documents/fmmp_guide_2004.pdf
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Unique Farmland. Farmland of lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated, but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Land must have been cropped at some time during the four years prior to the mapping date.
Farmland of Local Importance. Land of importance to the local agricultural economy as determined by each county’s board of supervisors and a local advisory committee.
Urban and Built-Up Land. Land occupied by structures with a building density of at least one unit to 1.5 acres, or approximately six structures to a 10-acre parcel. This land is used for residential, industrial, commercial, institutional, public administrative purposes, railroad and other transportation yards, cemeteries, airports, golf courses, sanitary landfills, sewage treatment, water control structures, and other developed purposes.
California Land Conservation Act (Williamson Act)
The California Land Conservation Act of 1965, commonly referred to as the Williamson Act, is the State’s primary program for the conservation of private land in agricultural and open space. The Williamson Act (California Government Code Section 51200–51297.4) enables local governments to enter into contracts with private landowners in order to restrict specific parcels of land to agricultural or related open space use in return for reduced property tax assessments.10
Local
There are no applicable local plans or policies related to agriculture and forestry resources.
3B.2 EXISTING CONDITIONS
Mark Twain Middle School is located at the western edge of the Palms – Mar Vista – Del Rey Community Plan Area, adjacent to the Venice Community Plan Area in the City. The land use designation for the project site is “Public Facilities,” and the adjacent land use designations are Public Facilities, Low Density Residential, Low Medium Density Multiple Family Residential, Medium Density Multiple Family Residential, General, and High Medium Multiple Family Residential (see Figure 2.2.2-5, Palms – Mar Vista – Del Rey Community Plan Area). The Palms – Mar Vista – Del Rey Community Plan and the Venice Community Plan do not designate any of the parcels within these two Community Plan Areas for agricultural resources or forestry resources. Furthermore, the City ZIMAS indicates that the proposed project site is zoned for public facilities (PF) and not for agriculture, forestry, or timberland production.
10 State of California Department of Conservation. Accessed 15 October 2014. Governing Statutes: California Land Conservation Act. Available at: http://www.conservation.ca.gov/dlrp/lca/lrcc/Pages/governing_statutes.aspx
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Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
The most recent mapping (2010) of the City for Farmland undertaken by the CDC FMMP was reviewed for the proposed project site. Prime Farmland in the City is limited to the San Fernando Valley; the nearest Prime Farmland to the proposed project site is located approximately 14 miles to the northwest.11 The CDC FMMP has identified the area that includes the proposed project site as Urban and Built-Up Land at the statewide scale, and this area has not been surveyed at the County scale.12 The CDC FMMP does not designate any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance east of the Interstate 405 Freeway or south of the San Gabriel Mountains in Los Angeles County at the statewide scale, and the area east of the I-405 and south of the San Gabriel Mountains has not been recently surveyed at the County scale. The nearest designated Prime Farmland is located approximately 11.4 miles north of the proposed project site within the Sepulveda Dam Recreation Area, northwest of the intersection of I-405 and State Route 101; the nearest designated Unique Farmland is located approximately 11.6 miles north of the proposed project site within the Sepulveda Dam Recreation Area, directly south of the nearest Prime Farmland; and the nearest designated Farmland of Statewide Importance is located approximately 14.3 miles northwest of the proposed project site at Pierce College.13 Based on the review of the land use designations and applicable Important Farmland map for the proposed project site, there is no Prime Farmland, Unique Farmland, or Farmland of Statewide Importance located in or immediately adjacent to the proposed project site.
Williamson Act Preserves
According to the Los Angeles County Williamson Act Fiscal Year 2012/2013 map by the California Department of Conservation Division of Land Resource Protection, the proposed project site and surrounding communities are not enrolled in a Williamson Act contract.14
Farmlands
There are no existing farmlands and lands designated for agricultural uses in the vicinity of the proposed project site. The proposed project site is located in the residential community of Mar Vista, with single-family and multiple family residences and other schools surrounding the project site according to the City of Los Angeles General Plan Land Use Map.15 The proposed project site is
11 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf. Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf 12 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf. Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf. 13 State of California, Department of Conservation. 2014. Accessed 23 December 2014. California Important Farmland Finder. Available at: http://maps.conservation.ca.gov/ciff/ciff.html 14 California Department of Conservation, Division of Land Resource Protection. 2013. Los Angeles County Williamson Act FY 2012/2013. Map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/wa/LA_12_13_WA.pdf 15 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. June 27, 2007 Land use map available
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presently zoned [Q]PF-1XL, Qualified Public Facilities in Height District I, Extra Limited (see Figure 2.2.2-5, Zoning Designation Map).16 The City has designated the proposed project site as PF: Public Facilities, a zone and land use type for the use and development of publicly owned land for public uses The City has designated the properties surrounding the project site as R1 (One-Family Zone/Low Residential Land Use) to the northwest, west, south and east of the project site and RD (Restricted Density Multiple Dwelling Zone/Los Medium Residential Land Use) to the north in the City’s Zoning Plan and General Plan. The most recent mapping (2010) of the City for Farmland undertaken by the CDC FMMP was reviewed for the proposed project site. The CDC FMMP has identified the area encompassing the proposed project site as Urban and Built-Up Land at the statewide scale and this area has not been surveyed at the County scale.17 Based on the review of the land use designations and applicable Important Farmland map for the proposed project site, there are no Farmlands located in or immediately adjacent to the proposed project site. The proposed project site was used for agriculture purposes between approximately 1928 and 1947; however, the project site has been developed as a school since 1949 or 1950 (see Appendix F, Phase I Environmental Site Assessment).18
Forestry and Timberland
As noted, the proposed project site is located in public facilities zone in a suburban area. No forestry or timberland resources are located on or in the vicinity of the proposed project site.
3B.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of five questions when addressing the potential for significant impacts to agriculture and forestry resources. Would the proposed project: a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? c. Conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production?
at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 16 City of Los Angeles Department of City Planning. Accessed 15 October 2014. ZIMAS. Website. Available at: http://zimas.lacity.org/ 17 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf. Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf 18 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Section 3.6, Historical Uses and Operations of the Property. Page 21.
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d. Result in the loss of forest land or conversion of forest land to non-forest use? e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
3B.4 IMPACT ANALYSIS
Impact 3B-a: Would the proposed project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
No Impact
The proposed project would not convert Farmland to non-agricultural uses. The proposed project site is in a suburban setting and is currently developed with grass playfields and asphalt used by the Mark Twain Middle School. The proposed project site is located within an area designated as Urban and Built-Up Land by the Farmland Mapping and Monitoring Program.19 Therefore, no impact to Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would occur. No further study of this issue is required.
Impact 3B-b: Would the proposed project conflict with existing zoning for agricultural use, or a Williamson Act contract?
No Impact
The proposed project would not conflict with agricultural zoning or a Williamson Act contract. The proposed project site is in a suburban setting and is currently developed as asphalt and turf within an existing middle school, a non-agricultural use. The proposed project site is presently zoned [Q]PF-1XL, Qualified Public Facilities in Height District I, Extra Limited.20 Furthermore, the County of Los Angeles does not offer Williamson Act contracts; thus, no Williamson Act contract exists for the school or surrounding areas.21 Therefore, no further study of this issue is required.
19 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map Available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf. Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf 20 City of Los Angeles Department of City Planning. Accessed 15 October 2014. ZIMAS. Website. Available at: http://zimas.lacity.org/ 21 State of California. 2010. California Department of Conservation, Division of Land Resources Protection, Farmland Mapping and Monitoring Program. Important Farmland in California, 2010. Statewide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/statewide/2010/fmmp2010_wallsize.pdf Countywide map available at: ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2010/los10.pdf
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Impact 3B-c: Would the proposed project conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production?
No Impact
The proposed project site is presently zoned [Q]PF-1XL, Qualified Public Facilities in Height District I, Extra Limited.22,23,24 The City has designated the properties surrounding the project site as R1 (One-Family Zone/Low Residential Land Use) to the northwest, west, south and east of the proposed project site and RD (Restricted Density Multiple Dwelling Zone/Los Medium Residential Land Use) to the north in the City’s Zoning Plan and General Plan. Thus, there is no zoned forest land, timberland, or Timberland Production within the vicinity of the proposed project site. Therefore, the proposed project would not conflict with zoning for forest land, timberland, or Timberland Production. No further study of this issue is required.
Impact 3B-d: Would the proposed project result in the loss of forest land or conversion of forest land to non-forest use?
No Impact
The proposed project would not result in the loss of forest land or conversion of forest land to non- forest use. There are no trees within the proposed project site on the Mark Twain Middle School campus; the nearest trees are located within the Student Garden adjacent to the western boundary of the project site. There is no forest land within the vicinity of the project site, which is located in a suburban area. Therefore, the proposed project would not result in the loss of forest land or the conversion of forest land to non-forest use, and no further study of this issue is required.
Impact 3B-e: Would the proposed project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact
The proposed project site is currently being used as athletic fields, a parking lot, and a painted track on the asphalt for the Mark Twain Middle School. There is no designated Farmland and no forest land (only one ornamental tree) within the proposed project site. Therefore, the proposed
22 City of Los Angeles Department of City Planning. Accessed 15 October 2014. ZIMAS. Website. Available at: http://zimas.lacity.org/ 23 City of Los Angeles Department of City Planning. City of Los Angeles Zone Information and Map Access System (ZIMAS). ZIMAS Available at: http://zimas.lacity.org/. Main website: http://cityplanning.lacity.org/ 24 American Legal Publishing Corporation. 2013. Los Angeles Municipal Code, Chapter I (Planning and Zoning Code), Article 2, Section 12.19. Available at: http://www.amlegal.com/nxt/gateway.dll/California/lapz/municipalcodechapteriplanningandzoningco/chapterig eneralprovisionsandzoning/article2specificplanning- zoningcomprehen/sec120409pfpublicfacilitieszone?f=templates$fn=default.htm$3.0$vid=amlegal:lapz_ca$an c=f
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project would not result in the conversion of Farmland to non-agricultural use or the conversion of forest land to non-forest use, and no further study of this issue is required.
3B.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts related to agriculture and forestry resources. Therefore, there would be no cumulative impacts.
3B.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development, design, and construction standards that would meet LAUSD Design Standards. Therefore, there would be no impacts related to agriculture and forestry resources, and no mitigation measures are required.
3B.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3B-a through 3B-e: No impact.
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This section evaluates the potential impacts to air quality resulting from construction and operation of the proposed project. The air quality evaluation in this EIR was prepared in accordance with the requirements of CEQA to determine if significant air quality impacts are likely to occur in conjunction with the development of the proposed project. The analysis in this section is based on the methodology and criteria provided in the South Coast Air Quality Management District’s (SCAQMD) CEQA Air Quality Handbook (Handbook).1,2 Emissions calculations for air quality modeling can be found in Appendix C, CalEEMod Model for LAUSD Mandarin and English Dual- Language Immersion School, of this EIR with updates provided on the SCAQMD website.3 Definitions
Air Basin. California is divided into 15 air basins to better manage air pollution. Air basin boundaries were determined by grouping together areas with similar geographical and meteorological features. While air pollution can move freely within an air basin, it can also sometimes be transported from one basin to another.4 The LAUSD is wholly within the South Coast Air Basin (SCAB).
Ambient Air Quality Standards (AAQS). The levels of air quality set for air pollutants that are considered to provide a reasonable margin of safety in the protection of the public health and welfare. There are both state and federally established AAQS.
Attainment/Nonattainment. These are designations for the air basins signifying whether air pollutants meet the National and California AAQS. An attainment status signifies that an air pollutant meets the AAQS within a specified air basin. A nonattainment status signifies that an air pollutant does not meet the AAQS within a specified air basin.
Criteria Air Pollutants. These are air pollutants that have established federal and state AAQS and are identified and regulated under Title I in the Federal Clean Air Act of 1970. These pollutants include ozone (O3), carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), coarse particulate matter (PM10), fine particulate matter (PM2.5), and lead (Pb).
1 South Coast Air Quality Management District. April 1993. CEQA Air Quality Handbook. Diamond Bar, CA. 2 South Coast Air Quality Management District. 2014. http://www.aqmd.gov/home/regulations/ceqa/air-quality- analysis-handbook/ceqa-air-quality-handbook-(1993) 3 South Coast Air Quality Management District. n.d. Available at: http://www.aqmd.gov/Default.htm 4 California Air Resources Board. California Air Basins. March 2014. http://www.arb.ca.gov/desig/airbasins/airbasins.htm. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-1 Draft EIR Subchapter 3C. Air Quality
Toxic air contaminants. These are other air pollutants not identified as criteria air pollutants, but may cause or contribute to an increase in mortality or in serious illness, or may pose a present or potential hazard to human health. There are currently 187 toxic air contaminants (TACs) identified and regulated under Title III of the Federal Clean Air Act Amendments of 1990.5 There are 244 TACs identified in Title 17 of the California Code of Regulations.6
3C.1 REGULATORY FRAMEWORK
The construction and operation of the proposed project have the potential to release gaseous emissions of criteria pollutants and dust into the ambient air; therefore, the LAUSD will consider the proposed project in relation to applicable federal, state, and local statutes and regulations related to air quality. Federal
Clean Air Act
The Clean Air Act (CAA) was first enacted in 1955 and has been amended numerous times in subsequent years (1963, 1965, 1967, 1970, 1977, and 1990). The CAA establishes federal air quality standards, known as NAAQS, and specifies future dates for achieving compliance. The NAAQS have been established for the following criteria pollutants: CO, O3, SO2, NO2, PM10, PM2.5, and Pb.7
The CAA Amendments of 1971 established the NAAQS, with states retaining the option to adopt more stringent standards or to include other pollution species. These standards are the levels of air quality considered to provide a margin of safety in the protection of the public health and welfare. They are designed to protect those sensitive receptors most susceptible to further respiratory distress such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed.
The CAA requires that states that do not meet the standards submit a State Implementation Plan (SIP). SIPs are designed to assist areas designated as non-attainment in establishing strategies to achieve compliance.8 The California SIP is composed of plans developed at the regional or local level. For example, the SCAB is a non-attainment area for PM10 and NOX, and the SIP addresses how these standards will be met. Each of these plans is reviewed and approved by the U.S. Environmental Protection Agency (EPA) prior to incorporation into the SIP. The federal CAA allows California to adopt more stringent vehicle emission standards than the rest of the nation due to the state’s severe O3 non-attainment status.
5 United States Environmental Protection Agency. March 2014. http://www.epa.gov/ttn/atw/pollsour.html. 6 California Air Resources Board (CARB). 1999. Final Staff Report: Update to the Toxic Air Contaminant List. 7 U.S. Environmental Protection Agency. Accessed 10 December 2014. “National Ambient Air Quality Standards.” Available at: http://www.epa.gov/air/criteria.html 8 U.S. Environmental Protection Agency. Accessed 10 December 2014. “National Ambient Air Quality Standards.” Available at: http://www.epa.gov/air/criteria.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-2 Draft EIR Subchapter 3C. Air Quality
The most recent 1990 amendments to the federal CAA identify specific emission reduction goals for areas not meeting the NAAQS. These amendments require both a demonstration of reasonable further progress toward attainment and incorporation of additional sanctions for failure to attain or to meet interim milestones. State
California Clean Air Act (California CAA)
In 1988, the state legislature passed the California CAA, which established California’s air quality goals, planning mechanisms, regulatory strategies, and standards of progress for the first time.9 The California CAA provides the state with a comprehensive framework for air quality planning regulation. The California CAA requires attainment of state ambient air quality standards by the earliest practicable date. Preparation of and adherence to attainment plans are the responsibility of the local air pollution districts or air quality management districts.
California Ambient Air Quality Standards (CAAQS)
The State of California has set ambient air quality standards for criteria pollutants. The CAAQS for these criteria pollutants are more stringent than the corresponding federal standards.10 The state has also set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. Table 3C.1-1, Ambient Air Quality Standards for Criteria Pollutants, summarizes the state and federal standards within the State of California.
Table 3C.1-1: Ambient Air Quality Standards for Criteria Pollutants Averaging California Federal Pollutant Health and Pollutant Time Standard Standard Atmospheric Effects Major Pollutant Sources
Ozone (O3) 1 hour 0.09 ppm --- High concentrations can directly Motor vehicles 8 hours 0.07 ppm 0.075 affect lungs, causing irritation. ppm Long-term exposure may cause damage to lung tissue. Carbon 1 hour 20 ppm 35 ppm Classified as a chemical Internal combustion Monoxide 8 hours 9.0 ppm 9 ppm asphyxiant, CO interferes with the engines, primarily gasoline- (CO) transfer of fresh oxygen to the powered motor vehicles blood and deprives sensitive tissues of oxygen. Nitrogen Annual 0.030 ppm 0.053 Irritating to eyes and respiratory Motor vehicles, petroleum Dioxide Arithmetic (56 µg/m3) ppm tract. Colors atmosphere reddish- refining operations, (NOx) Mean brown. industrial sources, aircraft, 1 hour 0.18 ppm --- ships, and railroads (338 µg/m3)
9 California Air Resources Board. 1988. California Clean Air Act. 10 California Air Resources Board. 21 February 2008. Ambient Air Quality Standards. Sacramento, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-3 Draft EIR Subchapter 3C. Air Quality
Table 3C.1-1: Ambient Air Quality Standards for Criteria Pollutants Averaging California Federal Pollutant Health and Pollutant Time Standard Standard Atmospheric Effects Major Pollutant Sources Sulfur Annual --- 0.030 Irritates upper respiratory tract; Fuel combustion, chemical Dioxide Arithmetic ppm injurious to lung tissue. Can yellow plants, sulfur recovery (SOx) Mean the leaves of plants, destructive to plants, and metal 1 hour 0.25 ppm 0.075 marble, iron, and steel. Limits processing ppm visibility and reduces sunlight. 24 hours 0.04 ppm 0.14 ppm Suspended Annual 20 µg/m3 --- May irritate eyes and respiratory Dust and fume-producing
Particulate Arithmetic (PM10) tract, decreases in lung capacity, industrial and agricultural Matter Mean cancer, and increased mortality. operations, combustion, 12 µg/m3 12 µg/m3 (PM10, Produces haze and limits visibility. atmospheric photochemical (PM2.5) (PM2.5) PM2.5) reactions, and natural 24 hours 50 µg/m3 150 µg/m3 activities (e.g., wind-raised dust and ocean sprays) (PM10) (PM10) --- 35 µg/m3
(PM2.5)
Lead (Pb) Monthly 1.5 µg/m3 --- Disturbs gastrointestinal system, Present source: lead Quarterly --- 1.5 µg/m3 and causes anemia, kidney smelters, battery disease, and neuromuscular and manufacturing and neurologic dysfunction (in severe recycling facilities 3–Month --- 0.15 cases). Past source: combustion of Average µg/m3 leaded gasoline Sulfates 24 hours 25 µg/m3 --- Decrease in ventilatory functions; Industrial processes (SO4) aggravation of asthmatic symptoms; aggravation of cardio- pulmonary disease; vegetation damage; degradation of visibility; property damage. KEY: Ppm = parts per million μg/m3 = micrograms per cubic meter SOURCE: California Air Resources Board. 4 June 2013. Ambient Air Quality Standards. Available at: http://www.arb.ca.gov/research/aaqs/aaqs2.pdf.
South Coast Air Quality Management District Air Quality Management Plan
The SCAQMD and Southern California Association of Governments (SCAG) are both responsible for preparing the Air Quality Management Plan (AQMP), which addresses federal and California CAA requirements.11 The AQMP details goals, policies, and programs for improving air quality and establishes thresholds for daily operation emissions. Environmental review of individual projects within the region must demonstrate whether daily construction and operation emissions thresholds
11 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-4 Draft EIR Subchapter 3C. Air Quality established by the SCAQMD would be exceeded and whether the proposed project would increase the number or severity of existing air quality violations.
Exceedances that are affected by highly irregular or infrequent events are not considered violations of a state standard and are not used as a basis for designating areas as non-attainment. Based on regional monitoring to date, the County of Los Angeles portion of the SCAB is currently designated 12 as a non-attainment area with regard to O3, PM2.5, and PM10. The SCAB is currently designated as 13 an attainment area for CO, SO2 and NO2.
To ensure continued progress toward clean air and to comply with state and federal requirements, the SCAQMD, in conjunction with the California Air Resources Board (CARB) and the Southern California Association of Governments (SCAG), prepared the 2007 AQMP. The 2007 AQMP employs up-to-date science and analytical tools and incorporates a comprehensive strategy aimed at controlling pollution from all sources, including stationary sources, on-road and off-road mobile sources, and area sources.
The 2007 AQMP updates the federal standards for O3 and PM2.5, slightly increasing the timeframe for attainment, but adopts significantly more stringent standards. This 2007 AQMP addresses several state and federal planning requirements and incorporates significant new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological episodes, and new air quality modeling tools. This 2007 AQMP is consistent with and builds upon the approaches taken in the 2003 AQMP and the 1999 amendments to the Ozone SIP for the SCAB for the attainment of the federal ozone standard.
The 2007 AQMP proposes attainment demonstration of the federal PM2.5 standards through a more focused control of SOX, directly emitted PM2.5, and NOX supplemented with VOC by 2015. The 8- hour ozone control strategy builds upon the PM2.5 strategy, augmented with additional NOX and VOC reductions to meet the standard by 2024 assuming the attainment period is extended.14
The SCAQMD also adopts rules to implement portions of the AQMP. Some of these rules may apply to construction or operation of the proposed project.
Rule 403
Rule 403 requires the implementation of numerous measures to control fugitive dust. In addition, certain stationary sources of air pollution, such as boilers and heaters, may require permits from the SCAQMD pursuant to Rules 201, 202, and 203. Emission increases related to those sources may be subject to SCAQMD Regulation XIII, which requires that best available control technology (BACT) be utilized to reduce pollutants and that any increases of criteria air pollutants be offset by achieving equivalent emission reductions at the facility or elsewhere in the SCAB. In addition, the proposed project is subject to Title V of the federal CAA, in which all equipment located at the
12 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. 13 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. 14 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-5 Draft EIR Subchapter 3C. Air Quality
Title V facility must be in compliance with all terms, requirements, and conditions specified in the Title V permit.
AB 32 California Global Warming Solutions Act of 2006
In September 2006, Governor Arnold Schwarzenegger signed the California Global Warming Solutions Act of 2006, also known as AB 32, into law. AB 32 commits the state to: achieving the following:
2000 GHG emissions levels by 2010 (a reduction of 11 percent below business as usual)
1990 levels by 2020 (25 percent below business as usual)
80 percent below 1990 levels by 2050
To achieve these goals, AB 32 mandates that the CARB establish a quantified emissions cap; institute a schedule to meet the cap; implement regulations to reduce statewide GHG emissions from stationary sources; and develop tracking, reporting, and enforcement mechanisms to ensure that reductions are achieved. Senate Bill 1368, a companion bill to AB 32, requires the California Public Utilities Commission and the CEC to establish GHG emissions performance standards for the generation of electricity. These standards will also apply to power that is generated outside of California and imported into the state. The CARB list of discrete early action measures that can be adopted and implemented before January 1, 2010 was approved on June 21, 2007. In December 2012, the CARB released a draft report with three of these proposed discrete early action measures, which are focused on major state-wide contributing sources and industries, not on individual development projects or practices. These three measures are: 1) a low-carbon fuel standard, 2) reduction of refrigerant losses from motor vehicle air conditioning system maintenance, and 3) increased methane capture from landfills.
The City of Los Angeles published Green LA: An Action Plan to Lead the Nation in Fighting Global Warming (LA Green Plan), outlining the goals and actions the city has established to reduce the generation and emission of GHGs from both public and private activities. According to the LA Green Plan, the City of Los Angeles is committed to the goal of reducing emissions of CO2 to 35 percent below 1990 levels. To achieve this, the city will:
Increase the generation of renewable energy.
Improve energy conservation and efficiency.
Change transportation and land use patterns to reduce dependence on automobiles.
The extent to which the proposed project supports the city’s goals will be discussed qualitatively.
3C.2 EXISTING CONDITIONS Ambient Air Quality
Air quality is affected by both the amount and location of pollutant emissions and by meteorological conditions that influence movement and dispersal of pollutants. Atmospheric
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-6 Draft EIR Subchapter 3C. Air Quality conditions, such as wind speed, wind direction, and air temperature gradients; along with local topography provide the link between air pollutant emissions and air quality.
Regional Characteristics
The project site is located in the SCAB.15 The SCAB incorporates approximately 12,000-square miles within four counties—including all of Orange County, most of Los Angeles and Riverside Counties, and the western portion of San Bernardino County—and some portions of what was previously known as the Southeast Desert Air Basin. The distinctive climate of the SCAB is determined by its terrain and geographical location. The SCAB is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean to the southwest and high mountains around its remaining perimeter. The general region lies in the semi-permanent high-pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds. The usually mild climatological pattern is interrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds.16
The vertical dispersion of air pollutants in the Los Angeles portions of the SCAB is hampered by the presence of persistent temperature inversions.17 High-pressure systems, such as the semi-permanent high-pressure zone, regularly occur within the SCAB. Usually the high-pressure zones are characterized by an upper layer of dry air that warms as it descends, restricting the mobility in the formation of subsidence inversions. Such inversions restrict the vertical dispersion of air pollutants released into the marine layer and, together with strong sunlight, can produce worst-case conditions for the formation of photochemical smog.
The atmospheric pollution potential of an area is largely dependent on winds, atmospheric stability, solar radiation, and terrain. The combination of low-wind speeds and low inversions produces the greatest concentration of air pollutants. On days without inversions, or on days of winds averaging over 15 miles per hour (mph), smog potential is greatly reduced.18
Air Monitoring Station
The closest climate monitoring station to the proposed project site is located at the Culver City Air Monitoring Station, approximately 1.6 miles east of the site.19 Data from this climate monitoring station were used to characterize the study area climate conditions. As summarized in Table 3C.2- 1, Average Temperatures in the Vicinity of the Proposed Project Site, the average summer (August) high temperature is 79.0 degrees Fahrenheit (ºF), and the average summer (June) low temperature
15 South Coast Air Quality Management District. 1 June 2007. 2007 Air Quality Management Plan. Page 1-3. Diamond Bar, CA. 16 South Coast Air Quality Management District. April 1993. CEQA Air Quality Handbook. Page A8-1. Diamond Bar, CA. 17 South Coast Air Quality Management District. 1 June 2007. 2007 Air Quality Management Plan. Page 1-3. Diamond Bar, CA. 18 South Coast Air Quality Management District. April 1993. CEQA Air Quality Handbook. Page A8-1. Diamond Bar, CA. 19 Western Regional Climate Center. Accessed 2 December 2014.“Comparative Data for the Western States.” Available at: http://www.wrcc.dri.edu/CLIMATEDATA.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-7 Draft EIR Subchapter 3C. Air Quality is 58.0ºF. The average winter (December) high temperature is 67.6ºF, and the average winter (January) low temperature is 45.3ºF.20
Table 3C.2-1 Average Temperatures in the Vicinity of the Proposed Project Site Month Average Maximum (°F) Average Minimum (°F) January 66.5 45.3 February 67.1 46.6 March 67.8 48.3 April 70.1 51.2 May 71.5 54.5 June 74.1 58.0 July 78.0 61.2 August 79.0 61.9 September 78.7 60.5 October 76.0 56.2 November 71.6 50.2 December 67.6 46.1 Annual 72.3 53.3 SOURCE: Western Regional Climate Center. Accessed 20 March 2008. Comparative Data for the Western States. Available at: http://www.wrcc.dri.edu/CLIMATEDATA.html
Precipitation
In contrast to a very steady pattern of temperature, rainfall is seasonally and annually highly variable. Almost all rain falls from November through April. Summer rainfall is normally restricted to widely scattered thundershowers near the coast, with slightly heavier shower activity in the east and over the mountains. According to the Western Regional Climate Center, the average annual rainfall is 13.15 inches near the proposed project site.21
Wind
The closest wind monitoring station to the proposed project site is the Santa Monica Municipal Airport Monitoring Station.22 Data from this wind station were used to characterize study area wind conditions. Wind patterns in the proposed project vicinity trend in a southwesterly direction, and average wind speeds are approximately 5 mph.23
20 Western Regional Climate Center. Accessed 2 December 2014.“Comparative Data for the Western States.” Available at: http://www.wrcc.dri.edu/CLIMATEDATA.html 21 Western Regional Climate Center. Accessed 2 December 2014.“Comparative Data for the Western States.” Available at: http://www.wrcc.dri.edu/CLIMATEDATA.html 22 South Coast Air Quality Management District. Accessed 2 December 2014.“AQMD Meteorological Data Dispersion Model Application.” Available at: http://www.aqmd.gov/smog/metdata/MeteorologicalData.html 23 South Coast Air Quality Management District. Accessed 2 December 2014. “AQMD Meteorological Data Dispersion Model Application.” Available at: http://www.aqmd.gov/smog/metdata/MeteorologicalData.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-8 Draft EIR Subchapter 3C. Air Quality
Although the SCAB has a semi-arid climate, the air near the surface is typically moist because of the presence of a shallow marine layer. Except for infrequent periods when dry, continental air is brought into the SCAB by offshore winds known as Santa Ana winds; the ocean effect is dominant. Periods of heavy fog, especially along the coastline, are frequent and low stratus clouds, often referred to as high fog, are a characteristic climatic feature. Annual average humidity is 70 percent at the coast and 57 percent in the eastern portions of the SCAB.
Criteria Air Pollutants
The air pollutants emitted into the ambient air by stationary and mobile sources are regulated by federal and state law. These regulated air pollutants are known as criteria air pollutants and are categorized as primary and secondary pollutants. Primary air pollutants are those that are emitted directly from sources. CO, ROC, NOX, SO2, and most of PM10 and PM2.5, including Pb and fugitive dust, are primary air pollutants. Of these, CO, SO2, PM10, and PM2.5 are criteria pollutants. ROC and NOX are criteria pollutant precursors and go on to form secondary criteria pollutants through chemical and photochemical reactions in the atmosphere. O3 and NO2 are the principal secondary pollutants. Presented below is a description of each of the primary and secondary criteria air pollutants and their known health effects.
The SCAQMD maintains an air quality monitoring station (Source Receptor Area No. 42– West Los Angeles) at Wilshire Boulevard and Sawtelle Boulevard in the City of Los Angeles. The monitoring station is approximately 3.5 miles north of the proposed project site. Criteria pollutants monitored at this station include O3, CO, NO2, PM10, PM2.5, and SO2. A 5-year summary (2010–2014) of data collected at this station is shown in Table 3C.2-2, Project Area Air Pollutant Summary, 2010–2014, and is compared with the corresponding state ambient air quality standards.24
24 South Coast Air Quality Management District. Current Air Quality Map, 2010–2014. Accessed 2 December 2014. Available at http://www.aqmd.gov/home/tools/air-quality Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-9 Draft EIR Subchapter 3C. Air Quality
Table 3C.2-2 Project Area Air Pollutant Summary, 2010–2014a Pollutant Standard b 2010 2011 2012 2013 2014
Ozone (O3) Highest 1-hour average, ppmc 0.09 0.10 0.10 0.077 0.089 0.116 Number of standard exceedanced 6 3 0 0 12 Violation Yes Yes No No Yes Carbon Monoxide (CO) Highest 1-hour average, ppmc 20 5.0 4.9 2.7 5.2 2.8 Number of standard exceedanced 0 0 0 0 0 Violation No No No No No
Nitrogen Dioxide (NO2) Highest 1-hour average, ppmc 0.18 0.26 0.14 0.12 0.09 0.10 Number of standard exceedanced 1 0 0 0 0 Violation Yes No No No No
Sulfur Dioxide (SO2) Highest 1-hour average, ppbc 75 26 12 5 10 15 Number of standard exceedanced 0 0 0 0 0 Violation No No No No No
Particulate Matter-10 Micron (PM10) Highest 24-hour average, g/m3 c 150 37 41 31 38 46 Number of standard exceedanced,e 0 0 0 0 0 Violation No No No No No
Particulate Matter-2.5 Micron (PM2.5) Annual Arithmetic Mean, g/m3 c 12 12.5 13 11.7 12 N/A Violation Yes Yes No Yes N/A NOTE: Italicized values indicate an excess of applicable standard. a. Data are from the SCAQMD monitoring station (No. 42 – West Los Angeles) located at Wilshire Boulevard and Sawtelle Boulevard, Los Angeles, California. b. State standard, not to be exceeded. c. ppm - parts per million; ppb – parts per billion; g/m3 - micrograms per cubic meter. d. Refers to the number of days in a year during which at least one exceedance was recorded. e. Measured every six days. SOURCE: SCAQMD, Air Quality Data Summaries, 2010–2014. Diamond Bar, CA.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-10 Draft EIR Subchapter 3C. Air Quality
Other Effects of Air Pollution
Just as humans are affected by air pollution, so are plants and animals. Animals must breathe the same air and are subject to the same types of negative health effects. Certain plants and trees may absorb air pollutants that can stunt their development or cause premature death. There are also numerous impacts to the economy, including lost workdays due to illness, a desire on the part of business to locate in areas with a healthy environment, and increased expenses from medical costs. Pollutants may also lower visibility and cause damage to property. Certain air pollutants are responsible for discoloring painted surfaces, eating away at stones used in buildings, dissolving the mortar that hold bricks together, and cracking tires and other items made from rubber.
In conformance with the requirements of the CAA Amendments, the U.S. EPA has prepared a monetary cost-benefit analysis related to implementation requirements. By the year 2010, the U.S. EPA estimates that its emissions reductions programs would cost approximately $27 billion. The programs are estimated to result in a savings benefit of $110 billion, for a net benefit of $83 billion.25 While these values are, for the nation as a whole, a net benefit ratio of about 4:1 is noted, and a similar ratio could be expected for the City of Los Angeles and its residents.
Another direct cost-benefit issue relates to federal funding. Areas that do not meet the federal air quality standards may lose eligibility for federal funding for road improvements and other projects that require federal or California Department of Transportation (Caltrans) approval.
Cleaner air also yields benefits to ecological systems. The quantified benefits of CAA Amendments programs reflected in the overall monetary benefits include increased agricultural and timber yields, reduced effects of acid rain on aquatic ecosystems, and reduced effects of nitrogen deposited to coastal estuaries. Many ecological benefits, however, remain difficult or impossible to quantify, or can only be quantified for a limited geographic area. The magnitude of quantified benefits and the wide range of unquantified benefits, nonetheless, suggest that as more is learned about ecological systems and conducted more comprehensive ecological benefits assessments, estimates of these benefits could be substantially greater. Attainment Status
26 Ozone (O3). The SCAB is in non-attainment for both the federal and state O3 standards. O3 is a secondary pollutant produced through a series of photochemical reactions involving ROC and NOX. O3 creation requires ROC and NOX to be available for approximately three hours in a stable atmosphere with strong sunlight. O3 is a regional air pollutant because it is not directly emitted by sources but is formed downwind of sources generating ROC and NOx emissions.
O3 effects include eye and respiratory irritation, reduction of resistance to lung infection, and possible aggravation of pulmonary conditions in persons with lung disease. O3 is also damaging to vegetation and untreated rubber. As shown in Table 3C.2-2, the state 1-hour O3 standard was
25 U.S. Environmental Protection Agency. 1997. Benefits and Costs of the Clean Air Act, Final Report to Congress on Benefits and Costs of the Clean Air Act, 1990 to 2010. EPA 410-R-99-001. 26 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-11 Draft EIR Subchapter 3C. Air Quality exceeded between 6 and 12 times per year at the West Los Angeles Monitoring Station from 2010 to 2014.27
Carbon Monoxide (CO). The SCAB is in attainment for both federal and state CO standards.28 CO is a non-reactive pollutant that is a product of incomplete combustion. Ambient CO concentrations usually follow the spatial and temporal distributions of vehicular traffic and are also influenced by meteorological factors such as wind speed and atmospheric mixing. Under inversion conditions, CO concentrations may be distributed more uniformly over an area out to some distance from vehicular sources. As shown in Table 3C.2-2, the 1-hour average CO standards were not exceeded at the West Los Angeles Air Monitoring Station in the five-year period from 2010 to 2014.
29 Nitrogen Dioxide (NO2). The SCAB is in attainment for the state NO2 standard. There are two oxides of nitrogen (NOX) that are important in air pollution: nitric oxide (NO) and NO2, which are both emitted from motor vehicle engines, power plants, refineries, industrial boilers, aircraft, and railroads. NO2 is primarily formed when NO reacts with atmospheric oxygen. NO2 gives the air the whiskey-brown color associated with smog. Since NOX emissions contribute to O3 generation, NOX emissions are regulated through the O3 attainment plans. As shown in Table 3C.2-2, the state 1- hour standard was exceeded only one time during 2010 at the West Los Angeles Monitoring Station in the five-year period from 2010 to 2014.
30 Sulfur Dioxide (SO2). The SCAB is in attainment for the federal and state SO2 standards. SO2 is primarily produced by the burning of high-sulfur coal in industrial operations and power plants. In some parts of the state, elevated levels can also be due to natural causes, such as wind-blown dust and sea salt spray. Suspended sulfates contribute to overall particulate concentrations in ambient air that, if high enough, are suspected to be a cause of premature death in individuals with pre- existing respiratory disease. The 1-hour SO2 standard was not exceeded at the West Los Angeles Monitoring Station, in the five-year period from 2010 to 2014.
31 Particulate Matter (PM10). The SCAB is in attainment for the federal and state PM10 standard. PM10 refers to particulate matter that is 10 microns or less in diameter. PM10 can be inhaled deep into the lungs and cause adverse health effects. PM10 in the atmosphere results from many kinds of dust- and fume-producing industrial and agricultural operations, fuel combustion, and atmospheric photochemical reactions. Some sources of particulate matter, such as construction activities, are more local in nature, while others such as vehicular traffic, have a more regional effect.
Particulate matter contributes to pollution through fugitive dust and exhaust emissions. Fugitive dust is produced from activities that disturb soil, such as grading, digging, or driving on an unpaved road. Particulate matter from exhaust gases is produced from incomplete combustion, resulting in
27 South Coast Air Quality Management District. Air Quality Data Summaries, 2010–2014. Diamond Bar, CA. 28 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. 29 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. 30 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. 31 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-12 Draft EIR Subchapter 3C. Air Quality soot formation. Both forms of particulate matter are accounted for in calculations performed in this analysis. As shown in Table 3C.2-2, the PM10 standards have not been exceeded at the West Los Angeles Air Monitoring Station in the 5-year period from 2010 to 2014.32
33 Particulate Matter (PM2.5). The SCAB is in non-attainment for the federal PM2.5 standard. It refers to particulate matter that is 2.5 microns or less. A state standard of 12 micrograms per cubic meter 3 (μg/m ) has been promulgated, but the state has not yet determined PM2.5 attainment status. PM2.5 is mostly derived from combustion sources, such as automobiles, trucks, and other vehicle exhaust, as well as from stationary combustion sources. The particles are either directly emitted or are formed in the atmosphere from the combustion of gases, such as NOX and SOX combining with ammonia. Components from material in the earth’s crust, such as dust, are also present, with the amount varying in different locations. As shown in Table 3C.2-2, the state annual arithmetic standard was exceeded in 2010, 2011, and 2013 at the West Los Angeles Air Monitoring Station.34
Reactive Organic Compounds (ROCs). There is currently no ambient air quality standard for ROC. ROCs are any reactive compounds of carbon (excluding methane), carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and other compounds. ROC is a precursor of ozone and, as such, is regulated under the SCAQMD ozone attainment plan.35 In this analysis, ROC includes volatile organic compounds (VOCs).
Lead (Pb). Lead concentrations historically exceeded the state and federal air quality standards by a wide margin but have not exceeded the standards at any regular monitoring station since 1982. Although special monitoring sites immediately downwind from lead sources recorded localized violations of the state standard in 1994, no violations were recorded at these stations in 2005. Consequently, the SCAB is designated as an attainment area for lead. Airborne ambient lead is no longer a health issue in the SCAB, and the SCAQMD does not require an emissions analysis unless the project is typically associated with lead emissions. The proposed project would not result in lead emissions, and, as such, lead emissions are not quantified in this analysis.
Sulfates (SOx). The entire state of California is designated as attainment for sulfates. Sulfates are monitored at only a few stations in the SCAB, and the last recorded exceedance was in 2001. In California, emissions of sulfur compounds primarily occur from the combustion of petroleum- derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. This sulfur is oxidized to SO2 during the combustion process and subsequently converted to sulfate compounds in the atmosphere. As SO2 is a precursor to sulfates, the SCAQMD recommends analyzing SO2 as an indicator of sulfates. As such, sulfate emissions are not quantified in this analysis.
Toxic Air Contaminants (TACs). The public’s exposure to various TACs is a significant environmental health issue in California. In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. The Health and Safety Code defines a TAC as an air pollutant that may cause or
32 South Coast Air Quality Management District. Air Quality Data Summaries, 2010–2014. Diamond Bar, CA. 33 South Coast Air Quality Management District. Air Quality Data Summaries, 2010–2014. Diamond Bar, CA. 34 South Coast Air Quality Management District. Air Quality Data Summaries, 2010–2014. Diamond Bar, CA. 35 South Coast Air Quality Management District. 7 December 2012. 2012 Air Quality Management Plan. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-13 Draft EIR Subchapter 3C. Air Quality contribute to an increase in mortality or in serious illness, or that may pose a present or potential hazard to human health.36 Any substance that is listed as a hazardous air pollutant pursuant to Subsection (b) of Section 112 of 42 USC Sec. 7412[b] is a TAC. Under state law, the California Environmental Protection Agency, acting through the California Air Resources Board (CARB), is authorized to identify a substance as a TAC if it determines the substance is an air pollutant that may cause or contribute to an increase in mortality or to an increase in serious illness, or that may pose a present or potential hazard to human health.
California regulates TACs primarily through Assembly Bill (AB) 1807 (Tanner Air Toxics Act) and AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987). The Tanner Air Toxics Act sets forth a formal procedure for the CARB to designate substances as TACs. Once a TAC is identified, the CARB adopts an airborne toxics control measure for sources that emit designated TACs. If there is a safe threshold for a substance (a point below which there is no toxic effect), the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate BACT to minimize emissions. The CARB has, to date, established formal control measures for 11 TACs, all of which are identified as having no safe threshold.
Air toxics from stationary sources are also regulated in California under the Air Toxics “Hot Spot” Information and Assessment Act of 1987. Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High-priority facilities are required to perform a health risk assessment and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings.
To date, the CARB has designated nearly 200 compounds as TACs. In addition, the CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from TACs can be attributed to a relatively few compounds, one of the most important in Southern California being particulate matter from diesel-fueled engines.
In 1998, the CARB identified particulate emissions from diesel-fueled engines as a TAC. Previously, the individual chemical compounds in the diesel exhaust were considered as TACs. Almost all diesel exhaust particle mass is in the fine particle range of 10 microns or less in diameter. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs.
In 2005, the SCAQMD conducted a study on ambient concentrations of TACs and estimated the potential health risks from air toxics. The results showed that the overall risk for excess cancer from a lifetime exposure to ambient levels of air toxics was about 812 in a million. The largest contributor to this risk was diesel exhaust, accounting for 84 percent of the air toxics risk.
36 California Department of Health Services. Health and Safety Code. Available at: http://www.oes.ca.gov/Operational/OESHome.nsf/Content/349DB91B4D35827F88256CE0006060A1?OpenDo cument Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-14 Draft EIR Subchapter 3C. Air Quality
Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. The CARB has identified the following groups as being the most likely to be affected by air pollution: children under 14 years of age, the elderly over 65 years of age, athletes, and people with cardiovascular and chronic respiratory diseases. According to the SCAQMD, sensitive receptors include residences, schools, playgrounds, child care centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, exercise places a high demand on respiratory functions, which can be impaired by air pollution. Noticeable air pollution can detract from the enjoyment of recreation. Industrial and commercial areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent, as the majority of the workers tend to stay indoors most of the time.
There are six sensitive receptor groups within 0.25 miles (1,320 feet) of the proposed project:
Mark Twain Middle School located adjacent to and west of the proposed project site
Beethoven Elementary School located adjacent to and east of the proposed project site
Single-family residences located approximately 30 feet north of the proposed project site
Single-family residences located approximately 500 feet south of the proposed project site
Single-family residences located approximately 450 feet east of the proposed project site
Single-family residences located approximately 825 feet west of the proposed project site
The above sensitive receptors represent the nearest residential and school land uses with the potential to be impacted by the proposed project. The students who would attend the proposed project facilities would also be considered a sensitive receptor population. Additional single-family residences are located in the surrounding community within 0.25 miles of the project site. Odors
The type of facilities that are considered to have objectionable odors include wastewater treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities. Schools do not fall within these types of land uses. While use of landscaping equipment to maintain school property can generate exhaust fumes, the odors would be temporary. Similarly, any construction-related odor emissions from construction equipment exhaust and application of asphalt and architectural coatings would be temporary and intermittent in nature. Short-term construction-related odors are expected to cease upon the drying or hardening of the odor-producing materials.
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3C.3 THRESHOLDS OF SIGNIFICANCE
The criteria used to determine the significance of an impact related to air quality are based on the following CEQA and SCAQMD standards.37,38 Would the proposed project: a. Conflict with or obstruct implementation of the applicable air quality plan? b. Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions that exceed quantitative thresholds for ozone precursors)? d. Expose sensitive receptors to substantial pollutant concentrations? e. Create objectionable odors affecting a substantial number of people?
CEQA allows for the significance criteria established by the applicable AQMP or air pollution control district to be used to assess the impact of a project on air quality. The SCAQMD has established the air pollution emissions criteria shown in Table 3C.3-1, SCAQMD Air Quality Significance Thresholds, for determining the significance of an impact during project construction and operation.
Table 3C.3-1: SCAQMD Air Quality Significance Thresholds Daily Thresholds Pollutant Construction Operation
NOX 100 lbs/day 55 lbs/day VOCa 75 lbs/day 55 lbs/day
PM2.5 55 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
SOX 150 lbs/day 150 lbs/day CO 550 lbs/day 550 lbs/day Lead 3 lbs/day 3 lbs/day TACs and Odor Thresholds Maximum Incremental Cancer Risk ≥ 10 in 1 million TACs (including carcinogens and non- Hazard Index ≥ 1.0 (project increment) carcinogens) Hazard Index ≥ 3.0 (facility-wide) Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402
37 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15152. 38 South Coast Air Quality Management District. April 1993. CEQA Air Quality Handbook. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-16 Draft EIR Subchapter 3C. Air Quality
Table 3C.3-1: SCAQMD Air Quality Significance Thresholds Ambient Air Quality for Criteria Pollutantsb
NO2 SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:
1-hour average 0.18 ppm (state) Annual average 0.053 ppm (federal)
PM2.5
24-hour average 10.4 g/m3 (recommended for construction)c 2.5 g/m3 (operation) Annual arithmetic mean 12 g/m3
PM10
24-hour average 10.4 g/m3 (recommended for construction)c 2.5 g/m3 (operation) Annual arithmetic mean 20 g/m3 Sulfate
24-hour average 25 g/m3 CO SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:
1-hour average 20 ppm (state) 8-hour average 9.0 ppm (state/federal) NOTE: lbs/day = pounds per day. ppm = parts per million. g/m3 = micrograms per cubic meter. ≥ = greater than or equal to. a. For purposes of this analysis, VOC is equivalent to ROC. b. Ambient air quality thresholds for criteria pollutants based on SCAQMD Rule 1303, Table A-2 unless otherwise stated. c. Ambient air quality threshold based SCAQMD Rule 403. SOURCE: South Coast Air Quality Management District. 2009. CEQA Air Quality Handbook. Diamond Bar, CA. South Coast Air Quality Management District. June 2008. Localized Significance Methodology.
Regarding local CO emissions from roadway traffic, the proposed project would result in a significant air quality impact if it would do either of the following: (1) cause or contribute to exceeding the California 1-hour CO standard of 20 ppm, or the 8-hour CO standard of 9.0 ppm, at an intersection or roadway near a sensitive receptor; or (2) create an incremental increase in CO levels equal to or greater than 1 ppm for the 1-hour standard, or 0.45 ppm for the 8-hour standard, at an intersection or roadway near a sensitive receptor.
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3C.4 IMPACT ANALYSIS
Project-related demolition, site preparation, and building erection emissions, were calculated using the CalEEMod Emissions Model.
In addition to the Handbook, the SCAQMD published the Localized Significance Threshold Methodology for CEQA Evaluations that is intended to provide guidance in evaluating localized effects from mass emissions during construction.39 The SCAQMD updated this guidance with Final 40 Methodology to Calculate Particulate Matter (PM) 2.5 and PM2.5 Significance Thresholds.
CalEEMod 2013.2.2 was also used to compile long-term project operational emissions from mobile sources. In calculating mobile-source emissions, the CalEEMod 2013.2.2 default trip length assumptions were changed to reflect a specific vehicle trip length identified by LAUSD. As documented in the Program EIR, student vehicles traveling to and from west region elementary schools travel an average of 0.35 miles per trip.41
The environmental impact analysis presented below is based on the determinations made for issues that were potentially significant (Appendix A, Notice of Preparation). The air quality impact analysis includes both construction-related impacts and operational-related impacts.
Impact 3C-a: Would the proposed project conflict with or obstruct implementation of the applicable air quality plan?
No Impact
Construction. The modeled construction emissions, based on CalEEMod.2013.2.2, for the proposed project do not exceed the significance thresholds established by the SCAQMD (Table 3C.4-1, Localized [On-Site] Construction Impacts). Therefore, the construction phase of the project would not conflict with the SCAQMD significance thresholds. As there is no violation of the regional significance threshold, there would be no violation of the California AAQS (Table 3C.1-1). Therefore, construction of the proposed project would not conflict with or obstruct the implementation of the AQMP, the applicable air quality plan; and thus would not have any impact on applicable air quality plans.
39 South Coast Air Quality Management District. June 2003. Localized Significance Threshold Methodology for CEQA Evaluations. Diamond Bar, CA. 40 South Coast Air Quality Management District. October 2006. Final-Methodology to Calculate Particulate Matter (PM) 2.5 and PM2.5 Significance Thresholds. Diamond Bar, CA. 41 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised June 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-18 Draft EIR Subchapter 3C. Air Quality
Table 3C.4-1: Localized (On-Site) Construction Emissions Estimated Emissions (lbs/day)
Phasea ROC NOX CO PM2.5 PM10 Site Preparation 2.70 30.82 18.06 1.40 1.60 Grading 2.85 29.95 19.63 2.84 4.19 Building Construction 3.70 24.63 16.72 1.56 1.63 Paving 1.64 16.46 12.06 0.94 1.02 Architectural Coating 36.67 2.19 1.87 0.17 0.17
Regional Significance Threshold 75 100 550 55 150 Significant Impact No No No No No NOTE: The table assumes the proposed project would comply with SCAQMD Rule 403 (Fugitive Dust). SOURCE: CalEEMod Simulation using CalEEMod.2013.2.2. Completed March 2015.
Operations. The modeled operational emissions, based on CalEEMod.2013.2.2, for the proposed project do not exceed the significance thresholds established by the SCAQMD (Table 3C.4-2: Operational Emissions). Therefore, the operational phase of the project would not conflict with the AQMP, and would not violate the California AAQS (Table 3C.1-1). Therefore, construction of the proposed project would not conflict with or obstruct the implementation of the AQMP, the applicable air quality plan; and thus would not have any impact on applicable air quality plans.
Table 3C.4-2: Operational Emissions Estimated Emissions (lbs/day)
Source ROC NOX CO PM2.5 PM10 Mark Twain Middle School Addition Mobile Sources 2.19 2.96 14.00 0.39 1.38 Stationary Sources <1 <1 <1 <1 <1 Total 3.07 3.05 14.08 0.40 1.39
Regional Significance Threshold 55 55 550 150 150 Significant Impact No No No No No SOURCE: CalEEMod Simulation using CalEEMod.2013.2.2. Completed March 2015.
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Impact 3C-b: Would the proposed project violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Less than Significant Impact
Construction Emissions. Construction of the proposed project has the potential to impact air quality through the use of heavy-duty construction equipment and from trips generated by construction workers commuting to and from the proposed project site. Fugitive dust emissions would result from site preparation, excavation, and other construction activities. Mobile source emissions, primarily NOX, would result from the use of construction equipment such as bulldozers, wheeled loaders, and cranes. During the finishing phase, paving operations and the application of architectural coatings, such as paints and other building materials, would release ROCs. The assessment of construction air quality impacts considers all of these potential sources. Construction emissions can substantially vary from day to day, depending on the level of activity, the specific type of operation and, for dust, the prevailing weather conditions.
It is mandatory for all construction projects in this air basin to comply with the SCAQMD Rule 403 for fugitive dust.42 Specific Rule 403 control requirements include, but are not limited to, applying water in sufficient quantities to prevent the generation of visible dust plumes, applying soil binders to uncovered areas, re-establishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the project site, and maintaining effective cover over exposed areas.43 Incorporating Rule 403 compliance into the proposed project would avoid impacts to regional PM2.5 and PM10. LAUSD shall require its construction contractor to comply with Rule 403.
Maximum localized construction emissions would not exceed the SCAQMD daily significance thresholds for ROC, NOX, CO, PM2.5, or PM10 (Table 3C.4.-1). Therefore, the construction impact would not violate any air quality standard or contribute substantially to an existing or projected air quality violation, and would thus be less than significant.
Operational Emissions. Regional air pollutant emissions associated with proposed project operations would be generated by the consumption of natural gas and by the operation of on-road vehicles. Mobile source emissions would be the largest source of pollutants resulting from proposed project operation, according to CalEEMod. The average daily trips total is based on information from the traffic study prepared for the proposed project (Appendix C) pursuant to a Memorandum of Understanding (MOU) between LAUSD and the City of Los Angeles Department of Transportation. The MOU prepared for the proposed project indicates that the proposed project would generate 510 trips during the a.m. peak hour, with 281 trips entering the site and 230 exiting. Regional operational emissions would not exceed the SCAQMD significance thresholds as a result of these trips (Table 3C.4-2). Therefore, the regional operations impact would not violate any air quality standard or contribute substantially to an existing or projected air quality violation, and would thus be less than significant.
42 South Coast Air Quality Management District. 3 June 2005. Rule 403, Fugitive Dust. Diamond Bar, CA. 43 South Coast Air Quality Management District. 3 June 2005. Rule 403, Fugitive Dust. Diamond Bar, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-20 Draft EIR Subchapter 3C. Air Quality
Impact 3C-c: Would the proposed project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?
Less than Significant Impact
Cumulative impacts to air quality could occur as a result of construction of the proposed project in combination with other cumulative projects, as well as increases in air pollution from stationary and mobile source emissions. However, cumulative thresholds for air quality are the same as those used when considering a project-specific air quality impact, because the thresholds are related to a project’s contribution to the regional air quality baseline (as determined by the SCAQMD modeling that considers general plan land use designations for the jurisdictions within its borders). If a project would result in exceedances of daily regional emission limits, then it can be considered to contribute to cumulatively considerable air quality impacts.
With respect to the proposed project, none of the criteria pollutants produced during project construction or operation would exceed regional or localized significance thresholds, as described above in Impact 3C-a and Impact 3C-b. In addition to considering the proposed project emissions discussed above, LAUSD policy is to consider the concurrent construction-period emissions from all LAUSD school projects located within a 1-mile radius of the proposed project that would be under construction simultaneously with the proposed project. Since no LAUSD school projects are proposed to be under construction simultaneously within a 1-mile radius of the proposed project, and the proposed project emissions are below all applicable SCAQMD significance criteria, the proposed project emissions are not considered to be cumulatively considerable.
Impact 3C-d: Would the proposed project expose sensitive receptors to substantial pollutant concentrations?
Less than Significant Impact
The proposed project would result in less than significant impact to air quality relating to exposing sensitive receptors to substantial pollutant concentrations. As indicated in Tables 3C.4-1 and 3C.4- 2, construction and operational emissions of the proposed project would not exceed the significance thresholds established by the SCAQMD. In addition, construction of the proposed project would be required to be in conformance with SCAQMD Rule 403 regarding the control of fugitive dust (see Section 2, Project Description, Table 2.3-1, Project Design Features). Therefore, the proposed project would result in less than significant impacts to air quality relating to exposing sensitive receptors to substantial pollutant concentrations, and the consideration of mitigation measures is not warranted.
Impact 3C-e: Would the proposed project create objectionable odors affecting a substantial number of people?
Less than Significant Impact
The proposed project has the potential to create objectionable odors during the construction of the project, including emissions from diesel burning vehicles and general odors from construction
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-21 Draft EIR Subchapter 3C. Air Quality processes. However, construction-related odor emissions would be temporary and intermittent in nature. Short-term construction-related odors are expected to cease upon the drying or hardening of the odor-producing materials. Therefore, the proposed project would result in less than significant impact to air quality relating to objectionable odors affecting a substantial number of people, and the consideration of mitigation measures is not required.
3C.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to air quality. Therefore, there would be no cumulative impacts.
3C.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development, safety, and construction standards that would meet LAUSD Design Standards. Construction of the proposed project would be required to be in conformance with SCAQMD Rule 403 regarding the control of fugitive dust (see Table 2.3-1, Project Design Features). Therefore, impacts related to air quality would be less than significant, and no mitigation measures are required.
3C.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact 3C-a: No impact.
Impacts 3C-b, 3C-c, 3C-d, and 3C-e: Less than significant impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3C-22 Draft EIR SUBCHAPTER 3D Biological Resources
This analysis is undertaken to determine if the proposed project may have a significant impact on biological resources, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to biological resources at the proposed project site was evaluated with regard to the Federal Endangered Species Act (ESA), the Migratory Bird Treaty Act (MBTA), Section 404 of the Federal Clean Water Act, the California ESA, Sections 2080 and 2081 of the State Fish and Game Code, the Native Plant Protection Act, Section 3503 and 3503.5 of the State Fish and Game Code, and Section 1600 of the State Fish and Game Code. Definitions
Special Status Species are those species that have been afforded special recognition by federal, state, and/or local resource agencies or jurisdictions, or recognized resource conservation organizations. Special status wildlife species include those that are federally or state-listed as endangered, threatened, or candidate species pursuant to the federal ESA, the California ESA, or other regulations enforced by a federal or state agency; or those species considered by the scientific community to be rare. For this purposes of this analysis, special status species include listed, sensitive, and locally important species.
Federally Listed Species are those species provided with special legal protection under the federal ESA. A federally listed endangered species is a species that is in danger of extinction throughout all or a significant portion of its range. A federally threatened species is one likely to become endangered in the absence of special protection or management efforts provided by the listing. A candidate species is one that is proposed by the federal government for listing as endangered or threatened.
State-Listed Species are those species provided special legal protection under the California ESA. A state-listed endangered species is a species that is in danger of extinction throughout all or a significant portion of its range. A state-listed threatened species is one likely to become endangered in the absence of special protection or management efforts provided by the listing. A candidate species is one that is proposed by the federal or state government for listing as endangered or threatened.
Federally Designated Sensitive Species are those species that are not listed by the federal government as endangered, threatened, or candidate species but are categorized by the federal government as a federal species of concern. Federal species of concern is a term-of-art that describes a taxon (organism or group of organisms) whose conservation status may be of concern
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-1 Draft EIR Subchapter 3D. Biological Resources to the U.S. Fish and Wildlife Service (USFWS) but does not have official status. In addition, federally designated sensitive species include those that are designated as such by the Bureau of Land Management (BLM) and U.S. Forest Service (USFS) on lands that fall under their jurisdiction.
State-designated Sensitive Species are those species that are not listed by the state government as endangered, threatened, or candidate species but are categorized by the state as a species of special concern or fully protected species. A California species of special concern is defined by the California Department of Fish and Wildlife (CDFW) as being a wildlife species that has declining population levels, a limited range, and/or continuing threats that have made it vulnerable to extinction.
Locally Important Species are those species that are not monitored by the resource agencies, but monitored by private organizations or local municipal governments. For the purposes of this EIR, locally important species include those plant species recognized by the California Native Plant Society (CNPS), a private organization dedicated to the conservation of native plants, as well as those recognized by the Audubon Society.
3D.1 REGULATORY FRAMEWORK
Biological resources in California are afforded protection under state and federal legislation depending on the rarity of a given species. Regulations pertaining to special status species are discussed in the following sections. Federal
Federal Endangered Species Act (the Federal ESA)
The federal ESA defines species as endangered and threatened and provides regulatory protection for listed species. The federal ESA provides a program for conservation and recovery of threatened and endangered species, and conservation of designated critical habitat that the USFWS has determined is required for the survival and recovery of these listed species. Section 9 of the federal ESA prohibits the take of species listed by USFWS as threatened or endangered. Take is defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in such conduct.” In recognition that take cannot always be avoided, Section 10(a) of the federal ESA includes provisions for take that is incidental to, but not the purpose of, otherwise lawful activities. Section 10(a)(1)(B) permits may be issued if take is incidental and does not jeopardize the survival and recovery of the species.
Migratory Bird Treaty Act
The MBTA makes it unlawful to pursue, capture, kill, or possess any migratory bird or part, nest, or egg of any such bird listed in wildlife protection treaties between the United States, Great Britain, Mexico, Japan, and the countries of the former Soviet Union. Similar to the federal ESA, the MBTA authorizes the Secretary of the Interior to issue permits for incidental take.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-2 Draft EIR Subchapter 3D. Biological Resources
Section 404 of the Federal Clean Water Act
Section 404 of the federal Clean Water Act, which is administered by the U.S. Army Corps of Engineers (USACOE), regulates the discharge of dredged and fill material into waters of the United States. USACOE has established a series of nationwide permits that authorize certain activities in waters of the United States, provided that a proposed activity can demonstrate compliance with standard conditions. In general, USACOE requires an individual permit for an activity that will affect an area equal to or in excess of 0.3 acre of waters of the United States. Projects that result in impacts to less than 0.3 acre of waters of the United States can normally be conducted pursuant to one of the nationwide permits, if consistent with the standard permit conditions. USACOE also has discretionary authority to require an Environmental Impact Statement for projects that result in impacts to an area between 0.1 and 0.3 acre. Use of any nationwide permit is contingent on the activities having no impacts to endangered species. State
California Endangered Species Act (the California ESA)
The California ESA prohibits the take of listed species except as otherwise provided in state law. Unlike the federal ESA, the California ESA applies the take prohibitions to species petitioned for listing (state candidates). State lead agencies are required to consult with the CDFW to ensure that any actions undertaken by that lead agency are not likely to jeopardize the continued existence of any state-listed species or result in destruction or degradation of required habitat. CDFW is authorized to enter into Memoranda of Understanding (MOUs) with individuals, public agencies, universities, zoological gardens, and scientific or educational institutions to import, export, take, or possess listed species for scientific, educational, or management purposes.
Section 2080 and 2081 of the State Fish and Game Code
Section 2080 of the State Fish and Game Code (Code) states:
No person shall import into this state [California], export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product thereof, that the commission [State Fish and Game Commission] determines to be an endangered species or threatened species, or attempt any of those acts, except as otherwise provided in this chapter, or the Native Plant Protection Act, or the California Desert Native Plants Act.
Pursuant to Section 2081 of the Code, the CDFW may authorize individuals or public agencies to import, export, take, or possess, any state-listed endangered, threatened, or candidate species. These otherwise prohibited acts may be authorized through permits or MOUs if:
The take is incidental to an otherwise lawful activity.
The impacts of the authorized take are minimized and fully mitigated.
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The permit is consistent with any regulations adopted pursuant to any recovery plan for the species.
The applicant ensures adequate funding to implement the measures required by CDFW.
CDFW shall make this determination based on available scientific information and shall include consideration of the ability of the species to survive and reproduce.
Native Plant Protection Act
The Native Plant Protection Act includes measures to preserve, protect, and enhance rare and endangered native plants. The list of native plants afforded protection pursuant to the Native Plant Protection Act includes those listed as rare and endangered under the California ESA. The Native Plant Protection Act provides limitations by stating “no person will import into this State, or take, possess, or sell within this State” any rare or endangered native plant, except in compliance with provisions of the act. Individual landowners are required to notify the CDFW at least 10 days in advance of changing land uses to allow the CDFW to salvage any rare or endangered native plant material.
Sections 3503 and 3503.5 of the State Fish and Game Code
These sections of the Code provide regulatory protection to resident and migratory birds and all birds of prey within California, including the prohibition of the taking of nests and eggs unless otherwise provided for by the Code.
Section 1600 of the State Fish and Game Code
All diversions, obstructions, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake in California are subject to the regulatory authority of the CDFW pursuant to Sections 1600 through 1603 of the Code and require preparation of a Streambed Alteration Agreement. Pursuant to the Code, a stream is defined as a body of water that flows at least periodically, or intermittently, through a bed or channel having banks and supporting fish or other aquatic life. Based on this definition, a watercourse with surface or subsurface flows that support or have supported riparian vegetation is a stream and is subject to CDFW jurisdiction. Altered or artificial waterways valuable to fish and wildlife are subject to CDFW jurisdiction. CDFW also has jurisdiction over dry washes that carry water ephemerally during storm events. Local
Los Angeles Unified School District Tree Removal and Replacement Policy
LAUSD implements the following tree removal and replacement policy when it is required that a tree be removed due to damage or other safety concerns. In such a case the tree will need to be replaced based on the following guidelines:
Newly planted trees should be a 24” box or larger at planting.
Tree species must be of appropriate size at maturity for the space planted.
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The selection must be made from the LAUSD Approved Plant List.
Trees will be provided and planted by each area’s gardening crews.
If the location of the new tree is not tied to an existing irrigation system arrangements must be made to hand water the tree until it is established, in some cases this may take up to 3 months.
If the site administrator chooses not to replace the tree, the tree well shall be paved over (asphalt or concrete, as appropriate) to mitigate any tripping hazards.
3D.2 EXISTING CONDITIONS
The proposed project would be constructed on the existing Mark Twain Middle School campus that is located in an urbanized area surrounded by city streets and single- and multi-family residences. Special-Status Species: Listed, Sensitive, and Locally Important Species
There are no native plant communities on the school campus or in the surrounding area. There are no current or historic records for sensitive plant or animal species on the proposed project site.2
Listed Species
A search of the California Native Diversity Database (CNDDB) using Rarefind 5 within 5 miles of the proposed project site was performed to develop a list of listed species and biological resources that could potentially occur in the proposed project vicinity (Table 3D.2-1, Federally and State- Listed Species with the Potential to Occur on the Proposed Project Site).3 Although no listed plant or animal species have been documented on the proposed project site, 17 listed species have been known to historically occur in the proposed project vicinity. The natural communities that provide suitable habitat for the 17 listed plant and animal species are absent from the proposed project site. Many of the species noted have since been extirpated, and the existing urbanized environmental setting is not capable of providing a suitable habitat for these species. As such, the likelihood of species dispersal from these areas to the proposed project site is extremely low. Based on a review of the CNDDB and historic records for listed plant and animal species within the vicinity of the proposed project, there is no potential for listed species recognized by the USFWS as endangered, threatened, or candidate species or by the CDFW as candidate, endangered, threatened, or rare to be present on the proposed project site.
2 California Department of Fish and Wildlife. 2014. Rarefind 5: A Database Application for the Use of the California Department of Fish and Game Natural Diversity Data Base. Sacramento, CA. 3 California Department of Fish and Game. 2014. Rarefind 5: A Database Application for the Use of the California Department of Fish and Game Natural Diversity Data Base. Sacramento, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-5 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-1: Federally and State-Listed Species with the Potential to Occur on the Proposed Project Site Species Status Habitat Requirements On-Site Potential Plants None. No coastal dunes or Coastal dunes, coastal scrub. Formerly Beach spectaclepod coastal scrub habitat occurs ST more widespread in coastal habitats in (Dithyrea maritime) within the proposed project Southern California. property. Chaparral, coastal scrub, and valley None. No chaparral, coastal Braunton’s milk-vetch and foothill grassland; found in recent scrub, or grassland habitat occurs FE (Astragalus brauntonii) burns or disturbed areas, usually within the proposed project sandstone with carbonate layers. property. None. No coastal bluff scrub, Annual herb; Coastal bluff scrub Coastal dunes milk-vetch coastal dunes, or coastal prairie FE, SE (sandy), coastal dunes, coastal prairie (Astragalus tener var. titi) habitat occurs within the (mesic), often in vernally mesic areas. proposed project property. Salt marsh bird’s-beak None. No coastal dunes, marsh, Coastal dunes, marshes and swamps (Chloropyron maritimum ssp. FE, SE or swamp habitat occurs within (coastal salt). maritimum) the proposed project property. San Fernando Valley spineflower None. No coastal scrub or Coastal scrub in sandy soil, valley and (Chorizanthe parryi var. FC, SE grassland habitat occurs within foothill grassland. Fernandina) the proposed project property. Ventura Marsh milk-vetch Low. No coastal salt marsh (Astragalus pycnostachyus var. FE, SE Coastal salt marsh. habitat occurs within the lanosissimus) proposed project property. Invertebrates Low. No coastal dune habitat El Segundo blue butterfly Restricted to remnant coastal dune FE occurs within the proposed (Euphilotes battoides allyni) habitat in Southern California. project property. None. No freshwater vernal pool Riverside fairy shrimp FE Freshwater, vernal pool complexes. habitat occurs within the (Streptocephalus woottoni) proposed project property. Birds Riparian scrub, riparian woodland; nests in steep sand, dirt, or gravel banks, in Low. No riparian scrub or riparian Bank swallow burrows dug near the top of the bank, ST woodland habitat occurs within (Riparia riparia) along the edge of inland water, along the proposed project property. coast, in gravel pits, or road embankments. Belding’s savannah sparrow Inhabits coastal salt marshes, from Low. No coastal salt marsh (Passerculus sandwichensis SE Santa Barbara south through San Diego habitat occurs within the beldingi) County. proposed project property. Inhabits freshwater marshes, wet California black rail Low. No freshwater marsh habitat meadows and shallow margins of (Laterallus jamaicensis ST occurs within the proposed saltwater marshes bordering larger coturniculus) project property. bays. Nests along the coast from San Low. No coastal nesting habitat California least tern FE, SE Francisco Bay south to northern Baja occurs within the proposed (Sternula antillarum browni) California. project property. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-6 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-1: Federally and State-Listed Species with the Potential to Occur on the Proposed Project Site Species Status Habitat Requirements On-Site Potential Coastal bluff scrub, coastal scrub; dry coastal slopes, washes, and mesas; Low. No coastal scrub or coastal Coastal California gnatcatcher cone-shaped nests built in shrubs; FT bluff scrub habitat occurs within (Polioptila californica californica) areas of low plant growth (about 1 the proposed project property. meter high); strongly associated with sage scrub. Riparian forest, riparian scrub, riparian woodland; forages exclusively in Low. No riparian habitat occurs Least Bell’s vireo riparian habitats primarily on insects; FE, SE within the proposed project (Vireo bellii pusillus) dense riparian understory shrubbery property. required for nesting; nests usually 1 meter off ground. Riparian, cropland/hedgerow, desert, Low. No riparian, cropland, grassland/herbaceous, savanna, mixed Swainson’s hawk desert, grassland, or woodland FT woodland; may be found in grasslands (Buteo swainsoni) habitat occurs within the and other open habitats in winter and proposed project property. migration. Low. No sandy beach, salt pond Western snowy plover Sandy beaches, salt pond levees, and levee, or alkali lake habitat occurs FT (Charadrius alexandrinus nivosus) shores of large alkali lakes. within the proposed project property. Mammals Occurs on fine-grain, sandy or gravelly substrates in the immediate vicinity of Pacific pocket mouse None. No coastal dune or coastal the Pacific Ocean. Occurs on coastal (Perognathus longimembris FE sage scrub habitat occurs within strand, coastal dunes, river alluvium, pacificus) the proposed project property. and coastal sage scrub habitats on marine terraces. KEY: FE = Listed as endangered under the federal Endangered Species Act. FT = Listed as threatened under the federal Endangered Species Act. FC = Listed as a candidate species under the federal Endangered Species Act. SE = Listed as endangered by the State of California. ST = Listed as threatened by the State of California.
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Sensitive Species
A query of the CNDDB identified 20 sensitive wildlife species recognized by the USFWS as Federal Species of Concern, by the CDFW as California Special Concern Species, or species that are tracked by the CNDDB, that are known from the region (Table 3D.2-2, Sensitive Animal Species with the Potential to Occur on the Proposed Project Site).4 These species include 10 California Special Animals, 9 California Species of Concern, and 1 Fully Protected Species. The natural communities that provide suitable habitat for the 20 sensitive wildlife species are absent from the proposed project site. The proposed project is located in an urban setting that lacks the native plant communities needed to support the subject species. Of the sensitive species that were identified as having the potential to occur within 5 miles of the proposed project (Table 3D.2-2), none of the species were determined to have the potential to occur within the proposed project area due to lack of suitable habitat.
Table 3D.2-2: Sensitive Animal Species with the Potential to Occur on the Proposed Project Site Species Status Habitat On-Site Potential Invertebrates None. No coastal sand dune Belkin’s dune tabanid fly Inhabits coastal sand dunes of CSA habitat occurs within the proposed (Brennania belkini) Southern California. project property. None. No coastal dune or coastal Busck’s gallmoth CSA Coastal dunes, coastal scrub. scrub habitat occurs within the (Carolella busckana) proposed project property.
Dorothy’s El Segundo Dune None. No coastal dune habitat Coastal dune habitats in Los Angeles weevil CSA occurs within the proposed project County. (Trigonoscuta dorothea dorothea) property.
None. Not enough information on Generally unknown. This species has this species to adequately been described from only four Gertsch's socalchemmis spider determine habitat suitability. CSA specimens collected from the lower to (Socalchemmis gertschi) Nearest record of this species is mid elevations of the Santa Monica approximately 4 miles away from Mountains. the proposed project property. Fore dunes, sand hummocks, None. No fore dune or sand Globose dune beetle CSA occasionally back dunes along hummock habitat occurs within (Coelus globosus) immediate coast. the proposed project property. None. No dune habitat occurs Henne's eucosman moth Endemic to the El Segundo Dunes CSA within the proposed project (Eucosma hennei) (type locality), Los Angeles County. property. None. No dune habitat occurs Lange's El Segundo Dune weevil CSA El Segundo Dunes. within the proposed project (Onychobaris langei) property.
4 California Department of Fish and Wildlife. 2014. Rarefind 5: A Database Application for the Use of the California Department of Fish and Game Natural Diversity Data Base. Sacramento, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-8 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-2: Sensitive Animal Species with the Potential to Occur on the Proposed Project Site Species Status Habitat On-Site Potential Mimic tryonia (=California None. No benthic freshwater Benthic; freshwater; found in brackish brackishwater snail) CSA habitat occurs within the proposed salt marshes. (Tryonia imitator) project property. Low. Eucalyptus trees present within the vicinity of the proposed Grassland/herbaceous, Old field, project property may provide Sand/dune, Shrubland/chaparral, suitable tree-roosting habitat. No Monarch butterfly CSA Suburban/orchard, Woodland– Eucalyptus trees are present (Danaus plexippus) Hardwood, Woodland–Mixed, coastal within the proposed project site. California conifer or Eucalyptus groves. Nearest record of monarch butterfly to the proposed project is approximately 0.75 mile away. None. No sand dune habitat Sandy beach tiger beetle Sand/dune; found in moist sand near CSA occurs within the proposed project (Cicindela hirticollis gravida) ocean. property. Herbaceous wetland; sand/dune; in None. No herbaceous wetland or Wandering (=saltmarsh) skipper CSA salt marshes, near beaches, near sand dune habitat occurs within (Panoquina errans) mouths of rivers. the proposed project property. Reptiles Aquatic, artificial flowing waters, marsh and swamp, south coast flowing waters, south coast standing waters, None. No aquatic habitat occurs Western pond turtle wetland; habitat includes permanent CSC within the proposed project (Emys marmorata) and intermittent waters of rivers, property. creeks, small lakes and ponds, including human-made stock ponds and sewage-treatment ponds. Birds Found in open grasslands, agricultural and range lands, and desert habitats and often are associated with None. No grassland or open Burrowing owl CSC burrowing animals, specifically the space habitat occurs within the (Athene cunicularia) California ground squirrel; can also proposed project property. inhabit grass, forbs, and shrub stages of pinyon and ponderosa pine habitats. California brown pelican Low. No suitable habitat occurs Colonial nester on coastal islands just (Pelecanus occidentalis CFP within the proposed project outside the surf line. californicus) property.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-9 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-2: Sensitive Animal Species with the Potential to Occur on the Proposed Project Site Species Status Habitat On-Site Potential Mammals Low. No suitable roosting trees occur within the proposed project property. The high level of urban Forages over a wide range of habitats, development within the vicinity but prefers open habitats with access Hoary bat and the lack of nearby foraging CSA to trees for roosting, and water. (Lasiurus cinereus) locations is not suitable for hoary Primarily roosts in trees and foliage. bat presence. The nearest record Ranges throughout most of California. of hoary bat is from 1939 and approximately 2.5 miles away from the proposed project. Low. No chaparral, coastal scrub Chaparral, coastal scrub, desert wash, or other suitable habitat occur Great Basin grassland, Great Basin within the proposed project scrub, Mojavean desert scrub, riparian property. The high level of urban woodland, Sonoran desert scrub, development within the vicinity Pallid bat CSC upper montane coniferous forest, and the lack of nearby foraging (Antrozous pallidus) valley and foothill grassland; roosts in locations is not suitable for pallid rock crevices, caves, mineshafts, bat presence. The nearest record under bridges, in buildings, and within of pallid bat is from 1939 and hollow trees. approximately 2.5 miles away from the proposed project. Low. No forested habitat occurs within the proposed project property. No suitable roosting Primarily forested areas adjacent to trees occur within the proposed lakes, ponds, or streams, including project property. The high level of areas that have been altered by urban development within the Silver-haired bat CSA humans. Summer roosts and nursery vicinity and the lack of nearby (Lasionycteris noctivagans) sites are in tree foliage, cavities, or foraging locations is not suitable under loose bark, sometimes in for silver-haired bat presence. The buildings. nearest record of silver-haired bat is from 1985 and approximately 2.5 miles away from the proposed project. Montane riparian, annual grassland, wet meadow; occupies underground burrows and surface runways through grass. The south coast marsh vole None. No riparian, grassland, or South coast marsh vole CSC occurs in a narrow band of wetland meadow habitat occurs within the (Microtus californicus stephensi) communities and associated proposed project property. grasslands in the immediate coastal zone from southern Ventura County to northern Orange County.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-10 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-2: Sensitive Animal Species with the Potential to Occur on the Proposed Project Site Species Status Habitat On-Site Potential Southern California saltmarsh Herbaceous wetland; fallen log/debris; None. No herbaceous wetland shrew CSC coastal marshes; nests above high tide habitat occurs within the proposed (Sorex ornatus salicornicus) line project property. Found in the southwestern United States, generally away from human Low. No chaparral, woodland, development; this species can utilize a forest, agricultural, or desert Western mastiff bat variety of habitat types including habitat occurs within the proposed CSC (Eumops perotis californicus) chaparral, oak woodland, pine forests, project Property. No rock crevices agricultural areas and desert washes; or cliffs for roosting exist on the roosts primarily in vertical rock crevices proposed project property. on cliffs; KEY: CSC = California Species of Special Concern. CSA = California Special Animal. CFP=California Fully Protected Species. NOTE: CSA is a general term that refers to all of the taxa the CNDDB is interested in tracking, regardless of their legal or protection status. The CDFW considers the taxa on this list to be those of greatest conservation need. For those species with statuses identified by the USFWS and/or CDFW, the status is noted. Those species included on the list due to identification by other governmental agencies and/or non-governmental conservation organizations are listed as CSA.
Locally Important Species
As a result of a query of the CNDDB and the CNPS Electronic Inventory,5 10 locally important species were identified as potentially occurring in the proposed project vicinity (Table 3D.2-3, Locally Important Plant Species with the Potential to Occur on the Proposed Project Site). A review of the habitat requirements of the 10 identified locally important species resulted in no potential for these species to occur. The natural communities that provide suitable habitat for the 10 locally important species are absent from the proposed project site (Table 3D.2-3).6,7 There are no state-designated plant species of special concern whose range includes the proposed project site.
5 CNPS, Rare Plant Program. 2014. Inventory of Rare and Endangered Plants (online edition, v8-02). California Native Plant Society, Sacramento, CA. Available at: http://www.rareplants.cnps.org 6 California Department of Fish and Game. 2014. Rarefind 5: A Database Application for the Use of the California Department of Fish and Game Natural Diversity Data Base. Sacramento, CA. 7 CNPS, Rare Plant Program. 2014. Inventory of Rare and Endangered Plants (online edition, v8-02). California Native Plant Society, Sacramento, CA. Available at: http://www.rareplants.cnps.org Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-11 Draft EIR Subchapter 3D. Biological Resources
Table 3D.2-3: Locally Important Plant Species with the Potential to Occur on the Proposed Project Site Species Status Habitat On-Site Potential None. No coastal bluff scrub, Ballona cinquefoil Coastal bluff scrub, coastal dunes, coastal dune, or coastal scrub 1A (Potentilla multijuga) coastal scrub. habitat occurs within the proposed project property. None. No coastal scrub or coastal Brand's star phacelia 1B.1 Coastal scrub and coastal dunes. dune habitat occurs within the (Phacelia stellaris) proposed project property. None. No coastal dune habitat Coastal goosefoot 1B.2 Coastal dunes. occurs within the proposed project (Chenopodium littoreum) property. None. No alkali playa, marsh, Annual herb; Alkali playa, marsh and swamp, saltmarsh, grassland, Coulter's goldfields 1B.1 swamp, salt marsh, valley and foothill vernal pool, or wetland habitat (Lasthenia glabrata ssp. coulteri) grassland, vernal pool, wetland. occurs within the proposed project property. None. No marsh and swamp Mud nama 2B.2 Marshes and swamps. habitat occurs within the proposed (Nama stenocarpum) project property. Closed-cone coniferous forest, None. No forest, chaparral, or Nuttall's scrub oak 1B.1 chaparral, coastal scrub; found in coastal scrub habitat occurs within (Quercus dumosa) sandy clay loam soils. the proposed project property. Orcutt's pincushion None. No coastal bluff scrub or (Chaenactis glabriuscula var. 1B.1 Coastal bluff scrub and coastal dunes. coastal dune habitat occurs within orcuttiana) the proposed project property. None. No alkali playa, chenopod Annual herb; Alkali playa, chenopod Parish's brittlescale scrub, meadow, vernal pool, or 1B.1 scrub, meadow and seep, vernal pool, (Atriplex parishii) wetland habitat occurs within the wetland. proposed project property. Chaparral, coastal scrub, lower None. No chaparral, coastal Salt Spring checkerbloom montane coniferous forest, mojavean scrub, forest, desert scrub, or 2B.2 (Sidalcea neomexicana) desert scrub, playas; alkaline, mesic playa habitat occurs within the soils. proposed project property. None. No marsh, swamp, salt Southern tarplant Annual herb; Marsh and swamp, salt marsh, grassland, wetland, or (Centromadia parryi ssp. 1B.1 marsh, valley and foothill grassland, vernal pool habitat occurs within australis) wetland, vernal pools. the proposed project property. KEY: CNPS Rare Plant Rank: 1A = Plants presumed extirpated in California and either rare or extinct elsewhere 1B = Plants considered rare, threatened, or endangered in California and elsewhere 2B = Plants rare, threatened, or endangered in California, but more common elsewhere Threat ranks: 0.1: Seriously threatened in California 0.2: Moderately threatened in California 0.3: Not very threatened in California
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Riparian Habitat or Other State-Designated Sensitive Plant Communities
The Beverly Hills and Venice USGS 7.5-minute topographic quadrangles were reviewed for potential riparian habitats and sensitive natural communities by conducting a CNDDB search.8 As a result of literature and database review, it was found that there are no riparian habitats or other state-designated sensitive plant communities present on the proposed project site. The nearest riparian habitat was determined to be approximately 4.9 miles northwest of the proposed project site. Additionally, no state-designated sensitive plant communities were determined to be present at or within the vicinity of the proposed project site. The nearest state designated sensitive plant community was determine to be approximately 2 miles southwest of the proposed project site. The proposed project site exists within the existing Mark Twain Middle School and is completely developed with buildings, hardscape, and ornamental landscape.
Federally Protected Wetlands
Current National Wetlands Inventory9 maps for the Beverly Hills and Venice USGS 7.5-minute topographic quadrangles were reviewed for potential wetlands subject to protection under Section 404 of the Clean Water Act. No wetlands, historic or current, subject to protection under Section 404 of the Clean Water Act were identified within or immediately adjacent to the proposed project site based on the desktop analysis. The closest wetland identified is located approximately 1.5 miles southwest of the proposed project site.
Wildlife Movement Corridors and Nursery Sites
A desktop analysis, including aerial photograph review, was conducted to determine the proposed project site’s potential as a wildlife movement corridor or wildlife site. The proposed project site exists within the existing Mark Twain Middle School and is completely developed with buildings, hardscape, and ornamental landscape. There is no undeveloped open space surrounding the proposed project site that would serve as an important wildlife corridor. The predominant wildlife species found at the proposed project site would be those well adapted to living in an urban environment. Birds may occasionally fly through the proposed project site. The nearest natural open space habitat is located over 1.5 miles away from the proposed project site. As previously discussed, the proposed project site does not contain suitable habitat for any listed, sensitive, or locally important species. There is a single mature Chinese elm (Ulmus parvifolia) tree present within the proposed project site. Common, native bird species could potentially nest in this tree. Thus, although the proposed project site would not be considered a preferred wildlife nursery site, very minimal habitat is available for nesting birds, which are protected under the MBTA and the State Game and Fish Code. Local Plans and Ordinances
As a result of a review of aerial imagery, it was determined that a mature single Chinese elm tree is present at the proposed project site. This tree is not protected under the City of Los Angeles
8 California Department of Fish and Wildlife. 2014. Rarefind 5: A Database Application for the Use of the California Department of Fish and Game Natural Diversity Data Base. Sacramento, CA. 9 U.S. Fish and Wildlife Service. 24 October 2014. National Wetlands Inventory Map. Arlington, VA. Available at: http://www.fws.gov/wetlands/Wetlands-Mapper.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-13 Draft EIR Subchapter 3D. Biological Resources
Protected Tree Ordinance No. 177404. No additional mature trees are present at the proposed project site. The proposed project is consistent with the policies of the City of Los Angeles General Plan. The proposed project would not conflict with any local plans or ordinances, even if it were not exempt from such plans and ordinances, which it is, as previously noted. Habitat Conservation Plans and Natural Community Conservation Plans
As a result of a review of the City of Los Angeles General Plan as well as a review of all currently proposed and adopted Habitat Conservation Plans (HCPs) and Natural Community Conservation Plans (NCCPs) established by CDFW and the USFWS, and other approved local, regional, and state HCPs, it was determined there are no adopted or proposed HCPs or NCCP within or adjacent to the proposed project site.10,11 The nearest HCP and NCCP is the Palos Verdes Peninsula HCP/NCCP, which is approximately 13 miles south of the proposed project site. The proposed project site is not designated or proposed for designation as a conservation plan area.
3D.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of six questions when addressing the potential for significant impacts to biological resources. Would the proposed project: a. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? b. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? c. Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state Habitat Conservation Plan?
10 California Department of Fish and Game. Natural Community Conservation Plans. 6 January 2009. Available at: http://www.dfg.ca.gov/habcon/nccp/images/region.gif 11 U.S. Fish and Wildlife Service. Habitat Conservation Plans. 6 January 2009. Available at: http://www.fws.gov/carlsbad/HCPs/hcp_map%20area%20plans%200507.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-14 Draft EIR Subchapter 3D. Biological Resources
3D.4 IMPACT ANALYSIS
Impact 3D-a: Would the proposed project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
No Impact
The proposed project would not have an effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. This analysis is based on the habitat requirements and historical occurrences of the special-status species with the potential to occur at the proposed project site. The proposed project site is entirely developed and is located in an urban setting that does not contain habitat suitable to support any candidate, sensitive, or special status species as listed in local or regional plans, policies, or regulations, or by the CDFW or USFWS. Due to the lack of habitats suitable to support the subject species, they have been determined to be absent from the proposed project site. Therefore, no impact would occur.
Impact 3D-b: Would the proposed project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
No Impact
The proposed project would not have an effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the CDFW or USFWS. The proposed project site is currently developed and located in an urban environment and does not contain riparian habitat, or other natural habitat as designated by the CDFW and USFWS. In addition, a search for blue-line drainages on the National Wetlands Inventory Map12 determined that no blue-line drainages or wetlands are present within the proposed project site that would support sensitive natural communities. Therefore, no impact to riparian or other natural habitat would occur.
Impact 3D-c: Would the proposed project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
No Impact
The proposed project would not have an effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. The proposed project site is currently developed and located in an urban setting and does not contain any wetlands as
12 U.S. Fish and Wildlife Service, Division of Habitat and Resource Conservation. Accessed October 2014. “Wetlands Geodatabase.” Available at: http://wetlandsfws.er.usgs.gov/NWI/index.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-15 Draft EIR Subchapter 3D. Biological Resources defined by Section 404 of the Clean Water Act or the National Wetlands Inventory Map.13 Therefore, no impact would occur.
Impact 3D-d: Would the proposed project Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less than Significant Impact
Implementation of the proposed project would not interfere with the movement of any native resident or migratory fish or wildlife species or established native resident or migratory wildlife corridors. The proposed project site is located in an urban environment and occupied by an existing school. The proposed project site does not contain any watercourse or greenbelt for wildlife movement as it is immediately adjacent to residential and commercial development, which do not provide appropriate habitat that would support the movement of any native resident or migratory fish or wildlife species. The proposed project would have no impact on native resident or migratory wildlife corridors.
The proposed project site contains a single ornamental tree (Chinese elm). There are several additional ornamental trees adjacent to but not within the proposed project site. This tree, as well as the surrounding trees, has the potential to be used as nesting locations by native birds protected by the MBTA. The proposed project shall comply with Project Design Feature BIO-1 (see Section 2, Project Description). Project Design Feature BIO-1 states the following:
The removal of the Chinese elm tree and/or the disturbance of nearby trees or suitable nesting shrubbery would be avoided and minimized to the greatest extent possible through project design. If removal or disturbance of trees cannot be avoided, LAUSD shall retain a qualified biologist to conduct an intensive nest search in all trees and buildings slated for removal before construction begins. If nests with young are found, the LAUSD shall not remove the trees until the young have fledged or the nest has been abandoned; or, delay tree or building removal until between September 1 to February 28 to ensure reproductive success for native species using the site for nesting.
In addition, as required by LAUSD’s tree replacement policy, the removal of the Chinese elm (should it be necessary) would be mitigated by the planting of landscaping trees at a minimum 1:1 ratio that are a 24” box or larger, a species that will be the appropriate size at maturity for the space planted, and a species that is included in the LAUSD Approved Plant List. The replacement of the tree will mitigate for any nesting bird habitat loss resulting from the removal of the Chinese elm tree. As the proposed project shall comply with LAUSD’s tree replacement policy and Project Design Feature BIO-1, impacts to native wildlife nursery sites would be less than significant.
13 U.S. Fish and Wildlife Service, Division of Habitat and Resource Conservation. Accessed October 2014. “Wetlands Geodatabase.” Available at: http://wetlandsfws.er.usgs.gov/NWI/index.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-16 Draft EIR Subchapter 3D. Biological Resources
Impact 3D-e: Would the proposed project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
No Impact
The proposed project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. As noted, the proposed project is exempt from such local policies and ordinances. The desktop analysis and review of aerial photographs did not identify any native trees or vegetation within the vicinity of the proposed project site. The Mark Twain Middle School campus contains a few non-native ornamental or landscape trees. The proposed project site contains a single ornamental tree (Chinese elm) that has the potential to be removed during project construction. As required by LAUSD’s tree replacement policy, the removal of the Chinese elm would be mitigated by the planting of landscaping trees at a minimum 1:1 ratio that are a 24” box or larger, a species that will be the appropriate size at maturity for the space planted, and a species that is included in the LAUSD Approved Plant List. As such, no impact would occur.
Impact 3D-f: Would the proposed project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state Habitat Conservation Plan?
No Impact
The proposed project site is not located within an adopted HCP, NCCP, or similar plan.14,15 The proposed project site is not located within or proximate to any land trust, or conservation plan.16 As such, no impact would occur.
3D.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts related to biological resources. Therefore, there would be no cumulative impacts.
3D.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code, and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development, design, and construction standards that would meet LAUSD Design Standards. Therefore, impacts related to biological resources would be less than significant, and no mitigation measures are required.
14 California Department of Fish and Game. NCCP Plan Summaries. 20 October 2014. Available at: https://www.wildlife.ca.gov/Conservation/Planning/NCCP/Plans 15 U.S. Fish and Wildlife Service. Habitat Conservation Plans. 20 October 2014. Available at: http://www.fws.gov/carlsbad/HCPs/hcp_map%20area%20plans%200507.pdf 16 Los Angeles County Department of Regional Planning. January 2014. Los Angeles County General Plan Public Review Draft: Chapter 9: Conservation and Natural Resources Element. Available at: http://planning.lacounty.gov/assets/upl/project/gp_2035_Chapter9_2014.pdf Page 146. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3D-17 Draft EIR Subchapter 3D. Biological Resources
3D.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3D-a, 3D-b, 3D-c, 3D-e, and 3D-f: No impact.
Impact 3D-d: Less than significant impact.
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This analysis is undertaken to determine if the proposed project may have a significant impact to cultural resources, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The Cultural Resources Analysis was conducted in accordance with the LAUSD California Environmental Quality Act Specification Manual.2 The following analysis has been based on the results of the Historic Resources Assessment Memorandum for the Record prepared by Sapphos Environmental, Inc. for the proposed project (attached to this EIR as Appendix D, Historic Resources Assessment) and records searches at the South Central Coastal Information Center (SCCIC) at California State University, Fullerton, regarding previously recorded cultural resources and investigations conducted within the proposed project; the Natural History Museum of Los Angeles County for the presence of paleontological resources; and the Native American Heritage Commission (NAHC) for the presence of Native American sacred lands within the proposed project area. Definitions
Alluvium is an unconsolidated accumulation of stream‐deposited sediments, including sands, silts, clays or gravels.
Archaeological site is defined by the National Register of Historic Places (NRHP) as the place or places where the remnants of a past culture survive in a physical context that allows for the interpretation of these remains. Archaeological remains usually take the form of artifacts (e.g., fragments of tools, vestiges of utilitarian, or non-utilitarian objects), features (e.g., remnants of walls, cooking hearths, or midden deposits), and ecological evidence (e.g., pollen remaining from plants that were in the area when the activities occurred). These can include prehistoric (pre- European contact), historic (post-contact), or a combination thereof.
B.P. stands for “before present,” which is defined as before 1950 and is used by archaeologists in conjunction with the commonly used term, AD.
Formation is defined as a laterally continuous rock unit with a distinctive set of characteristics that make it possible to recognize and map from one outcrop or well to another. It is the basic rock unit of stratigraphy.
Holocene is defined as an interval of time relating to, or denoting the present epoch, which is the second epoch in the Quaternary period, including the time period from approximately 11,000 years ago to the present.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-1 Draft EIR Subchapter 3E. Cultural Resources
Historic period is defined as the period that begins with the arrival of the first nonnative population and thus varies by area. In 1769, Gaspar de Portolá became the first European to attempt to colonize the Los Angeles basin, initiating the historic period in the study area.
Historical resource is defined by CEQA as any object, building, structure, site (including archaeological sites), area, place, record, or manuscript that is listed in, or is eligible for listing in, the California Register of Historical Resources (CRHR); officially designated or recognized as historically significant by a local government pursuant to a local initiative or resolution; or identified as significant in a historic resource survey conducted in accordance with the requirements of the CRHR statute (Public Resources Code Section 5024.1(g)). Properties listed in, or determined eligible for listing in, the NRHP are automatically listed in the CRHR and are therefore historical resources under CEQA.
Isolate is defined as an isolated artifact or small group of artifacts appearing to reflect a single event, loci, or activity. It may lack identifiable context but has the potential to add important information about a region, culture, or person. Isolates are not considered under CEQA to be significant and, thus, do not require avoidance or mitigation under CEQA. All isolates located during the field effort, however, are recorded, and the data are transmitted to the appropriate California Historical Resources Information System (CHRIS) Information Center.
Native American sacred site is defined as an area that has been, and often continues to be, of religious significance to Native American peoples, such as an area where religious ceremonies are practiced or an area that is central to their origins as a people. They also include areas where Native Americans gather plants for food, medicinal, or economic purposes.
Outcrop is defined as a rock formation that is visible on earth’s surface.
Paleocene is defined as an interval of time, relating to, or denoting the earliest epoch of the Tertiary period, between the Cretaceous period and the Eocene epoch.
Pleistocene is defined as an interval of time, relating to or denoting the first epoch of the Quaternary period, between the Pliocene and Holocene epochs, from approximately 2.6 million years ago to 11,000 years ago.
Plutonic igneous rocks are igneous rocks that have crystallized beneath the earth’s surface.
Prehistoric period is defined as the era prior to AD 1769. The later part of the prehistoric period (post–AD 1542) is also characterized as the protohistoric period in some areas, which marks a transitional period during which native populations began to be influenced by European presence resulting in gradual changes to their lifeways.
Quaternary is defined as the most recent Period in geological time; includes the Pleistocene and Holocene Epochs.
Unique geologic feature is defined as an important and irreplaceable geological formation. Such features may have scientific and/or cultural values.
Unique paleontological resource is defined as a fossil that meets one or more of the following criteria:
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It provides information on the evolutionary relationships and developmental trends among organisms, living or extinct.
It provides data useful in determining the age(s) of the rock unit or sedimentary stratum, including data important in determining the depositional history of the region and the timing of geologic events therein.
It provides data regarding the development of biological communities or interaction between plant and animal communities.
It demonstrates unusual or spectacular circumstances in the history of life.
The fossils are in short supply and/or in danger of being depleted or destroyed by the elements, vandalism, or commercial exploitation, and are not found in other geographic locations.
3E.1 REGULATORY FRAMEWORK Federal
National Historic Preservation Act3
Enacted in 1966, the National Historic Preservation Act (NHPA) declared a national policy of historic preservation and instituted a multifaceted program, administered by the Secretary of the Interior, to encourage the achievement of preservation goals at the federal, state, and local levels. The NHPA authorized the expansion and maintenance of the NRHP, established the position of State Historic Preservation Officer (SHPO) and provided for the designation of State Review Boards, set up a mechanism to certify local governments to carry out the purposes of the NHRA, assisted Native American tribes to preserve their cultural heritage, and created the Advisory Council on Historic Preservation (ACHP). Section 106 of the NHPA states that federal agencies with direct or indirect jurisdiction over federally funded, assisted, or licensed undertakings must take into account the effect of the undertaking on any historic property that is included in, or eligible for inclusion in, the NRHP, and that the ACHP must be afforded an opportunity to comment, through a process outlined in the ACHP regulations in 36 Code of Federal Regulations (CFR) Part 800, on such undertakings.
National Register of Historic Places
The NRHP was established by the NHPA of 1966 as “an authoritative guide to be used by Federal, State, and local governments, private groups and citizens to identify the Nation’s cultural resources and to indicate what properties should be considered for protection from destruction or impairment.”4 The NRHP recognizes properties that are significant at the national, state, and local levels. To be eligible for listing in the NRHP, a resource must be significant in American or regional/local history, architecture, archaeology, engineering, or culture. Districts, sites, buildings, structures, and objects of potential significance must also possess integrity of location, design,
3 United States Code, Title 16, Section 470: “National Historic Preservation Act.” 4 Code of Federal Regulations, Title 36, Part 60.2: “Effects of Listing under Federal Law.” Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-3 Draft EIR Subchapter 3E. Cultural Resources setting, materials, workmanship, feeling, and association. A property is eligible for the NRHP if it is significant under one or more of four established criteria:5
(A) It is associated with events that have made a significant contribution to the broad patterns of our history;
(B) It is associated with the lives of persons who are significant in our past;
(C) It embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components may lack individual distinction; and/or
(D) It has yielded, or may be likely to yield, information important in prehistory or history.
Ordinarily cemeteries, birthplaces, or graves of historical figures, properties owned by religious institutions or used for religious purposes, structures that have been moved from their original locations, reconstructed historic buildings, and properties that are primarily commemorative in nature are not considered eligible for the NRHP unless they satisfy certain conditions. In general, a resource must be 50 years of age to be considered for the NRHP, unless it satisfies a standard of exceptional importance.
Secretary of the Interior’s Standards for the Treatment of Historic Properties
Evolving from the Secretary of the Interior’s Standards for Historic Preservation Projects with Guidelines for Applying the Standards, which were developed in 1976, the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings were published in 1995 and codified as 36 CFR 67. Neither technical nor prescriptive, these standards are “intended to promote responsible preservation practices that help protect our Nation’s irreplaceable cultural resources.”6 “Preservation” acknowledges a resource as a document of its history over time and emphasizes stabilization, maintenance, and repair of existing historic fabric. “Rehabilitation,” while also incorporating the retention of features that convey historic character, also accommodates alterations and additions to facilitate continuing or new uses. “Restoration” involves the retention and replacement of features from a specific period of significance. “Reconstruction,” the least used treatment, provides a basis for recreating a missing resource. These standards have been adopted, or are used informally, by many agencies at all levels of government to review projects that affect historical resources.
Native American Graves Protection and Repatriation Act of 1990
The Native American Graves Protection and Repatriation Act (NAGPRA) of 1990 sets provisions for the intentional removal and inadvertent discovery of human remains and other cultural items from
5 Code of Federal Regulations, Title 36, Part 60.4: “Criteria for Evaluation.” 6 Weeks, Kay D. and Anne E. Grimmer. 1995. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstruction Historic Buildings. Washington, DC: U.S. Department of the Interior, National Park Service. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-4 Draft EIR Subchapter 3E. Cultural Resources federal and tribal lands. It clarifies the ownership of human remains and sets forth a process for repatriation of human remains and associated funerary objects and sacred religious objects to the Native American groups claiming to be lineal descendants or culturally affiliated with the remains or objects. It requires any federally funded institution housing Native American remains or artifacts to compile an inventory of all cultural items within the museum or with its agency, and to provide a summary to any Native American tribe claiming affiliation. State
California Environmental Quality Act7
Pursuant to CEQA, an historical resource is a resource listed in, or eligible for listing in, the CRHR. In addition, resources included in a local register of historical resources or identified as significant in a local survey conducted in accordance with state guidelines are also considered historical resources under CEQA, unless a preponderance of evidence demonstrates otherwise. According to CEQA, the fact that a resource is not listed in or determined eligible for listing in the CRHR or is not included in a local register or survey shall not preclude a lead agency, as defined by CEQA, from determining that the resource may be an historical resource as defined in California Public Resources Code (PRC) Section 5024.1.8 Pursuant to CEQA, a project with an effect that may cause a substantial adverse change in the significance of an historical resource may have a significant effect on the environment.9
CEQA also applies to effects on archaeological sites. Archaeological sites may be eligible for the CRHR, and thus would qualify as historical resources under CEQA. If an archaeological site does not satisfy the criteria as an historical resource, but does meet the definition of a “unique archaeological resource,” it is also subject to CEQA. A unique archaeological resource is defined as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:10
(1) It contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information.
(2) It has a special and particular quality such as being the oldest of its type or the best available example of its type.
(3) It is directly associated with a scientifically recognized important prehistoric or historic event or person.
California Register of Historical Resources
Created in 1992 and implemented in 1998, the CRHR is “an authoritative guide in California to be used by state and local agencies, private groups, and citizens to identify the state’s historical
7 California Public Resources Code, Division Thirteen, Statutes 21083.2 and 21084.1. 8 California Code of Regulations, Title 14, Chapter 3, CEQA Guidelines, Section 15064.5(a). 9 California Code of Regulations, Title 14, Chapter 3, CEQA Guidelines, Section 15064.5(b). 10 California Public Resources Code, Section 21083.2(g). Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-5 Draft EIR Subchapter 3E. Cultural Resources resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change.”11 Certain properties, including those listed in or formally determined eligible for listing in the NRHP and California Historical Landmarks (CHL) numbered 770 and higher, are automatically included in the CRHR. Other properties recognized under the California Points of Historical Interest program, identified as significant in historical resources surveys, or designated by local landmarks programs may be nominated for inclusion in the CRHR. A resource, either an individual property or a contributor to a historic district, may be listed in the CRHR if the State Historical Resources Commission determines that it meets one or more of the following criteria, which are modeled on NRHP criteria:12
(1) It is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;
(2) It is associated with the lives of persons important in our past;
(3) It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; and/or
(4) It has yielded, or may be likely to yield, information important in history or prehistory.
Resources nominated to the CRHR must retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance.13 It is possible that a resource whose integrity does not satisfy NRHP criteria may still be eligible for listing in the CRHR. Similarly, resources that have achieved significance within the last 50 years may be eligible for inclusion in the CRHR provided that enough time has lapsed to obtain a scholarly perspective on the events or individuals associated with the resource.14
California Historical Landmarks15
CHLs are buildings, structures, sites, or places that have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value and that have been determined to have statewide historical significance by meeting at least one of the criteria listed below. The resource also must be approved for designation by the County Board of Supervisors or be recommended by the State Historical Resources Commission; and be officially designated by the Director of California State Parks. The specific standards now in use were first applied in the designation of CHL 770. CHLs 770 and above are automatically listed in the CRHR.
11 California Public Resources Code, Section 5024.1(a). 12 California Public Resources Code, Section 5024.1(c). 13 Office of Historic Preservation. n.d. “Technical Assistance Bulletin 6: California Register and National Register, A Comparison (for purposes of determining eligibility for the California Register).” Available at: www.ohp.parks.ca.gov 14 Office of Historic Preservation. n.d. “Technical Assistance Bulletin 6: California Register and National Register, A Comparison (for purposes of determining eligibility for the California Register).” Available at: www.ohp.parks.ca.gov 15 Office of Historic Preservation, Department of Parks and Recreation, State of California. n.d. “California Historical Landmarks Registration Programs.” Available at: www.ohp.parks.ca.gov Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-6 Draft EIR Subchapter 3E. Cultural Resources
To be eligible for designation as a “landmark,” a resource must meet at least one of the following criteria:
The first, last, only, or most significant of its type in the state or within a large geographic region (Northern, Central, or Southern California)
Associated with an individual or group having a profound influence on the history of California
A prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in a region of a pioneer architect, designer, or master builder
California Points of Historical Interest16
California Points of Historical Interest (CPHI) are sites, buildings, features, or events that are of local (city or county) significance and have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value. Points of Historical Interest designated after December 1997 and recommended by the State Historical Resources Commission are also listed in the CRHR. No historic resource may be designated as both a landmark and a “point.” If a point is later granted status as a landmark, the point designation will be retired. In practice, the point designation program is most often used in localities that do not have a locally enacted cultural heritage or preservation ordinance.
To be eligible for designation as a point of historical interest, a resource must meet at least one of the following criteria:
The first, last, only, or most significant of its type within the local geographic region (city or county)
Associated with an individual or group having a profound influence on the history of the local area
A prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in the local region of a pioneer architect, designer, or master builder
State Historical Building Code17
Created in 1975, the State Historical Building Code (SHBC) provides regulations and standards for the preservation, restoration, rehabilitation, or relocation of historic buildings, structures, and properties that have been determined by an appropriate local or state governmental jurisdiction to be significant in the history, architecture, or culture of an area. Rather than being prescriptive, the SHBC constitutes a set of performance criteria. The SHBC is designed to help facilitate restoration
16 Office of Historic Preservation, Department of Parks and Recreation, State of California. n.d. “California Points of Historical Interest Registration Programs.” Available at: www.ohp.parks.ca.gov 17 California State Historical Building Safety Board, Division of the State Architect. 2 June 2006. “California’s State Historical Building Code and State Historical Building Safety Board.” Sacramento, CA. Available at: http://www.dsa.dgs.ca.gov/StateHistoricalBuildingSafetyBoard/default.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-7 Draft EIR Subchapter 3E. Cultural Resources or change of occupancy in such a way as to preserve original or restored elements and features of a resource; to encourage energy conservation and a cost-effective approach to preservation; and to provide for reasonable safety from earthquake, fire, or other hazards for occupants and users of such “buildings, structures and properties.” The SHBC also serves as a guide for providing reasonable availability, access, and usability by the physically disabled.
Native American Heritage Commission
Section 5097.91 of the PRC established the NAHC, whose duties include the inventory of places of religious or social significance to Native Americans and the identification of known graves and cemeteries of Native Americans on private lands. Section 5097.98 of the PRC specifies a protocol to be followed when the NAHC receives notification of a discovery of Native American human remains from a county coroner.
Government Code Sections 6254(r) and 6254.10
These sections of the California Public Records Act were enacted to protect archaeological sites from unauthorized excavation, looting, or vandalism. Section 6254(r) explicitly authorizes public agencies to withhold information from the public relating to “Native American graves, cemeteries, and sacred places maintained by the Native American Heritage Commission.” Section 6254.10 specifically exempts from disclosure requests for “records that relate to archaeological site information and reports, maintained by, or in the possession of the Department of Parks and Recreation, the State Historical Resources Commission, the State Lands Commission, the NAHC, another state agency, or a local agency, including the records that the agency obtains through a consultation process between a Native American tribe and a state or local agency.”
Health and Safety Code Sections 7050 and 7052
Health and Safety Code Section 7050.5 declares that, in the event of the discovery of human remains outside of a dedicated cemetery, all ground-disturbing activities must cease and the county coroner must be notified. Section 7052 establishes a felony penalty for mutilating, disinterring, or otherwise disturbing human remains, except by relatives.
Penal Code Section 622.5
Penal Code Section 622.5 provides misdemeanor penalties for injuring or destroying objects of historic or archaeological interest located on public or private lands, but specifically excludes the landowner.
Public Resources Code Section 5097.5
PRC Section 5097.5 defines as a misdemeanor the unauthorized disturbance or removal of archaeological, historic, or paleontological resources located on public lands. Local
LAUSD Cultural Resources Policy
As stated in the LAUSD Program EIR, LAUSD is committed to the “protection and preservation of cultural resources, where feasible.” Appendix E2 of the Program EIR describes the procedures for Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-8 Draft EIR Subchapter 3E. Cultural Resources the identification of historical resources pursuant to CEQA. The LAUSD project design criteria include:18
LAUSD shall identify and evaluate proposed school sites for potential historical resources. Record searches shall be undertaken to determine if any previously evaluated potential historical resources are present. Archaeological records searches for potential school sites shall determine whether probability for encountering archaeological resources is low, moderate or high. Regardless of the outcome of records searches, reviewers shall prepare reconnaissance surveys of potential school sites. If the records searches and reconnaissance surveys indicate that potential historical resources may be present, reviewers should prepare an Intensive Survey. If the master reviewer accepts the Intensive Survey confirming potential historical resources are present on the proposed school site, LAUSD shall treat such properties as historical resources under CEQA ... If the records searches and reconnaissance surveys indicate a low probability of encountering archaeological resources on a proposed school site and archaeological resources are discovered during ground disturbing activity, then the contractor shall suspend work in the vicinity of the discovery and immediately notify the LAUSD.
LAUSD Historic Context Statement, 1870 to 1969
The 2014 LAUSD Historic Context Statement was prepared to assist LAUSD in creating a framework for context-driven evaluations of educational facilities in Los Angeles. The Historic Context Statement identifies and describes four major themes of historical significance throughout LAUSD’s history: (1) Founding Years, 1870s through 1909; (2) Progressive Education Movement: Standardization and Expansion, 1910 to 1933; (3) Era of Reform: Great Depression, Earthquake, and Early Experiments in the Modern, Functionalist School Plant, 1933 to 1944; and (4) Educating the Baby Boom: Postwar Expansion and the Modern, Functionalist School Plant, 1945 to 1969. Eligibility standards, character-defining features, and integrity thresholds are provided for each theme.19
3E.2 EXISTING CONDITIONS
The proposed project site is located on the existing Mark Twain Middle School campus, which is in an urbanized area surrounded by City streets and single- and multi-family residences.
The existing conditions for paleontological, archaeological, historical resources, and human remains are characterized at the project level of detail. For the purposes of this section, paleontological resources include any fossilized remains, traces, or imprints of organisms, preserved in or on the earth's crust, that are of paleontological interest and that provide information about the history of life on Earth; unique archaeological resources are defined as an archaeological artifact, object, or site which contains information needed to answer important scientific research questions or has a special and particular quality such as being the oldest of its type or the best available example of its type; historical resources include any object, building, structure, site, area, place, record, or manuscript determined to be historically significant or significant in the
18 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. 19 Los Angeles Unified School District. 2014. Los Angeles Unified School District Historic Context Statement, 1870 to 1969. Prepared by Sapphos Environmental, Inc., Pasadena, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-9 Draft EIR Subchapter 3E. Cultural Resources architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California or any resources that are listed in, or determined to be eligible for listing in, the CRHR, which also includes local registries. Additionally, resources determined eligible for the NRHP are automatically eligible for listing on the CRHR. Paleontological Resources
Based on an assessment of data from the Natural History Museum of Los Angeles County,20 the proposed project site is located in an area with the potential to uncover unique paleontological resources, despite there being no known vertebrate fossil localities within the proposed project area. The surficial deposits of the proposed project site consists of younger Quaternary Alluvium (Holocene) derived from fluvial deposits of the Ballona Creek that currently flows east and south of the proposed project site. Older Quaternary Alluvium is found beneath the surficial deposits. The younger Quaternary deposits do not usually contain significant fossil vertebrates; however, older Quaternary Alluvium deposits have the potential to contain significant fossil vertebrates. The closest known fossil locality, identified as LACM 7879, was recovered from these older Quaternary deposits. It is situated approximately 3/4 mile northwest of the proposed project area, near the intersection of Rose Avenue and Penmar Avenue. This locality produced fossil specimens of horse, Equus, and ground sloth, Paramylodon, at greater than 11 feet in depth. The next closest fossil locality is located approximately 2 miles north of the proposed project area, along Michigan Avenue south of Olympic Boulevard and east of Cloverfield Boulevard. This locality produced a fossil specimen of extinct lion, Felis atrox, at a depth of only 6 feet below grade. Therefore, although the record search failed to indicate any known vertebrate fossil localities within the proposed project area, the areas underlain by older Quaternary Alluvium deposits have a potential to produce unique paleontological resources. Archaeological Resources
Prehistoric Context
Several prehistoric cultural chronologies have been proposed for the Southern California coast with two of the most frequently cited sequences developed by William Wallace21 and Claude Warren.22 The chronological sequence presented herein represents an updated synthesis of these schemes as compiled by Glassow and others23 for the Northern California Bight. This geographic area consists of the coastal area from Vandenberg Air Force Base south to Palos Verdes, as well as the Channel
20 McLeod, Samuel A., Vertebrate Paleontology Section, Natural History Museum of Los Angeles County, Los Angeles, CA. October 22, 2014. Letter to Karl Holland, Sapphos Environmental, Inc., Pasadena, CA. 21 Wallace, William J. 1955 “A Suggested Chronology for Southern California Coastal Archaeology.” Southwestern Journal of Anthropology, 11: 214–230. 22 Warren, Claude M. 1968 “Cultural Tradition and Ecological Adaptation on the Southern California Coast.” In Archaic Prehistory in the Western United States, edited by Cynthia Irwin-Williams, pp. 1–14. Eastern New Mexico University Contributions in Anthropology No. 1. Portales. 23 Glassow, Michael A., Lynn H. Gamble, Jennifer E. Perry, and Glenn S. Russell. 2007. “Prehistory of the Northern California Bight and the Adjacent Transverse Ranges.” In California Prehistory, Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 191–213. New York, NY: Altamira Press. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-10 Draft EIR Subchapter 3E. Cultural Resources
Islands and adjacent inland areas, including the Los Angeles Basin.24 The prehistoric sequence of the Los Angeles Basin can be divided into four broad temporal categories: Late Pleistocene / Early Holocene, Middle Holocene, Late Holocene, and Late Holocene. It should be noted that the prehistoric chronology for the region is being refined on a continuing basis, with new discoveries and improvements in the accuracy of dating techniques.
Terminal Pleistocene and Early Holocene: Paleo-Coastal Period (Circa 11,500 to 9000/8500 B.P.)
Relatively few sites have been identified in the Los Angeles Basin that date to the terminal Pleistocene and early Holocene. Currently, the earliest reliable date for human occupation in the area derives from the La Brea Tar Pits (CA-LAN-159), where human bone has been dated to 10,520 B.P.25 Evidence of possible early human occupation has also been found at the sand dune bluff site of Malaga Cove (CA-LAN-138), located between Redondo Beach and Palos Verdes.26 Researchers have proposed that archaeological remains recovered from the lowermost cultural stratum at the site, which include shell, animal bone, and chipped stone tools, may date as early as 10,000 B.P.27,28
Middle Holocene: Millingstone Period (Circa 9000/8500 to 3500/3000 B.P.)
The Millingstone Period or Horizon, also referred to as the “Encinitas Tradition,”29,30 is the earliest well-established cultural occupation of the coastal areas of the region. The onset of this period, which began sometime between 9000 and 8500 B.P., is marked by the expansion of populations throughout the Northern California Bight. A number of Millingstone sites have been identified in the Los Angeles Basin. Within the vicinity of the current proposed undertaking, evidence of long- term Topanga occupation has been found in the Ballona Lagoon near Marina Del Rey. Data obtained from survey and excavation projects in the Ballona Lagoon indicate that during the Topanga I phase, the bluff tops overlooking the lagoon were used as temporary campsite locales by coastal groups who exploited marine and lagoon fish and shellfish resources.31 During the Topanga II phase, use of the area intensified with small, limited-use settlements established along the edges
24 Glassow, Michael A., Lynn H. Gamble, Jennifer E. Perry, and Glenn S. Russell. 2007. “Prehistory of the Northern California Bight and the Adjacent Transverse Ranges.” In California Prehistory, Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 191–213. New York, NY: Altamira Press. 25 Berger, R., R. Protsch, R. Reynolds, C. Rozaire, and J.R. Sackett. 1971. New Radiocarbon Dates Based on Bone Collagen of California Indians, pp. 43–49. Contributions to the University of California Archaeological Survey, Los Angeles. 26 Walker, Edwin Francis. 1951. Five Prehistoric Archaeological Sites in Los Angeles County, California. Southwest Museum, F.W. Hodge Anniversary Publication Fund VI, Los Angeles. 27 Moratto, M.J. 1984. California Archaeology, pp. 132. New York, NY: Academic Press. 28 Wallace, W.J. 1986. “Archaeological Research at Malaga Cove.” In Symposium: A New Look at Some Old Sites, edited by G.S. Breschini and T. Haversat, pp. 21–27. Salinas, CA: Coyote Press. 29 Sutton, Mark Q. 2010. “The Del Rey Tradition and Its Place in the Prehistory of Southern California.” Pacific Coast Archaeological Society Quarterly, 44(2): 1–54. 30 Sutton, Mark Q., and Jill K. Gardner. 2010. “Reconceptualizing the Encinitas Tradition of Southern California.” Pacific Coast Archaeological Society Quarterly, 42(4): 1–64. 31 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 34–42. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-11 Draft EIR Subchapter 3E. Cultural Resources of the lagoon. Faunal remains from these latter sites suggest Topanga II groups practiced a more generalized subsistence strategy that emphasized the exploitation of small terrestrial mammals, in addition to fish and shellfish resources.32
Late Holocene: Intermediate Period (3500/3000 B.P. to AD 750)
The Intermediate Period, which encompasses the early portion of the “Del Rey Tradition” as defined by Sutton,33 begins around 3500 B.P. At this time, significant changes are seen throughout the coastal areas of Southern California in material culture, settlement systems, subsistence strategies, and mortuary practices. In the Ballona Lagoon near Marina Del Rey, several large residential sites (CA-LAN-63, CA-LAN-64, and CA-LAN-206A) were established within the wetlands and surrounding bluffs at the beginning of the Intermediate Period.34 These sites contained a diversity of features, including hearths, burials, and houses. Faunal remains indicate a broad- spectrum collecting strategy that included the exploitation of terrestrial mammals and birds, as well as fish and shellfish. The presence of particular species of migratory waterfowl in the faunal assemblage indicates that primary occupation of these sites may have occurred in the late fall to early spring. These data suggest that although residential mobility in the Intermediate Period was greatly reduced from previous times, a fully sedentary occupation of the Ballona Lagoon locale is still not indicated.35
Late Holocene: Late Period (AD 750 to Spanish Contact)
The Late Period dates from approximately AD 750 until Spanish contact at AD 1542. Sutton36 has divided this period, which falls within the larger Del Rey Tradition, into two phases: Angeles IV (AD 750–1200) and Angeles V (AD 1200–1550). The Angeles IV phase is characterized by the continued growth of regional populations and the development of large, sedentary villages. Recent archaeological research indicates that Late Period habitation sites within the Los Angeles Basin may have been hierarchically organized around estuarine locales with more productive locales supporting large residential populations.37 Marked changes occurred in the occupation of the Ballona Lagoon during the Late Period. Paleoenvironmental reconstructions indicate that by 1000
32 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 34–42. 33 Sutton, Mark Q. 2010. “The Del Rey Tradition and Its Place in the Prehistory of Southern California.” Pacific Coast Archaeological Society Quarterly, 44(2): 1–54. 34 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 37–38. 35 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 38. 36 Sutton, Mark Q. 2010. “The Del Rey Tradition and Its Place in the Prehistory of Southern California.” Pacific Coast Archaeological Society Quarterly, 44(2): 26. 37 Grenda, D.R., and J.A. Altschul. 2002. “Complex Cultures, Complex Arguments: Sociopolitical Organization in the Blight.” In Islanders and Mainlanders, Prehistoric Context for the Southern California Blight, edited by J.H. Altschul and D.R. Grenda, pp. 147–178. Tucson, AZ: SRI Press. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-12 Draft EIR Subchapter 3E. Cultural Resources
BP, much of the lagoon had silted in and become a sediment-choked estuary.38 At this time, most of the Intermediate Period settlements in the area were abandoned as the local population aggregated into a few large settlements along lower Centinela Creek and at the edge of the lagoon.39 Faunal remains recovered from these Late Period sites indicate a generalized subsistence strategy focused on a broad mix of terrestrial and marine resources with a shift from lagoon to sandy shoreline shellfish species as the estuary silted in.40,41
Regional Ethnography
At the time of contact, the Native Americans referred to as the Gabrielino Indians occupied lands around the proposed project area and whose territories comprised nearly the entire basin comprising the Counties of Los Angeles and Orange. They belonged to the Takic family of the Uto- Aztecan linguistic stock. Named after the Mission San Gabriel, the Gabrielino are considered to have been one of the two wealthiest and largest ethnic groups in aboriginal Southern California,42 the other being the Chumash. This was largely due to the many natural resources within the land base they controlled, primarily the rich coastal section from Topanga Canyon to Aliso Creek, and the offshore Channel Islands of San Clemente, San Nicholas, and Santa Catalina.
The Takic-speaking ancestors of the Gabrielino arrived in the Los Angeles Basin around 3500 B.P. and spread throughout the area, displacing a preexisting Hokan-speaking population.43 The first Spanish contact with the Gabrielino took place in AD 1520, when Juan Rodriguez Cabrillo arrived in Santa Catalina Island. In 1602, the Spanish returned to Santa Catalina under Sebastián Vizcaíno, and in 1769, Gaspar de Portolá made the first attempt to colonize Gabrielino territory. By 1771, the Spanish had built four missions, and the decimation of the Gabrielino had already begun.44 European diseases and conflicts among the Gabrielino population, as well as conversion to Christianity, carried a toll in their numbers, traditions, and beliefs.
38 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 39. 39 Altschul, Jeffrey H., John G. Douglass, Richard Ciolek-Torrello, Sarah Van Galder, Benjamin R. Vargas, Kathleen L. Hull, Donn R. Grenda, Jeffrey Homburg, Manual Palacios-Fest, Steven Shelley, Angela Keller, and David Maxwell. 2007. “Life at the Nexus of the Wetlands and Coastal Prairie, West Los Angeles.” Proceedings for the Society for California Archaeology, 20: 39. 40 Maxwell, D. 2003. “Vertebrate Faunal Remains.” In At the Base of the Bluff, Archaeological Inventory and Evaluation along Lower Centinela Creek, Marina del Rey, California, edited by J.H. Altschul, A.Q. Stoll, D.R. Grenda, and R. Ciolek-Torrello, pp. 145–177. Playa Vista Monograph Series, Test Excavation Report 4. Tucson, AZ: Statistical Research. 41 Becker, K.M. 2003. “Invertebrate Faunal Remains.” In At the Base of the Bluff, Archaeological Inventory and Evaluation along Lower Centinela Creek, Marina del Rey, California, edited by J.H. Altschul, A.Q. Stoll, D.R. Grenda, and R. Ciolek-Torrello, pp. 179–200. Playa Vista Monograph Series, Test Excavation Report 4. Tucson, AZ: Statistical Research. 42 Bean, L.J., and C.R. Smith. 1978. “Gabrielino.” In Handbook of North American Indians, Vol. 8, edited by R.F. Heizer, p. 538. Washington, DC: Smithsonian Institution. 43 Sutton, Mark Q. 2009. “People and Language: Defining the Takic Expansion in Southern California.” Pacific Coast Archaeological Society Quarterly, 41(2 and 3): 31–93. 44 Bean, L.J., and C.R. Smith. 1978. “Gabrielino.” In Handbook of North American Indians, Vol. 8, edited by R.F. Heizer, pp. 540–541. Washington, DC: Smithsonian Institution. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-13 Draft EIR Subchapter 3E. Cultural Resources
Historic Context
Gaspar de Portolá made the first European attempt to colonize the region surrounding the proposed project site in 1769. The area later became known as “La Bellona” and became part of Rancho La Ballona in 1839, when the area was granted by the Mexican government. A review of historic United States Geologic Survey topographic maps suggests no significant development occurred within the proposed project area prior to the construction of Mart Twain Middle School.45,46,47,48,49
Mark Twain Middle School
According to LAUSD pre-planning data and background research, the campus core of Mark Twain Middle School was built primarily in 1949, with later additions in 1951 and 1954.50,51 When the school opened in September 1949, it was called Venice Junior High School; the school asked for a name change to Mark Twain Junior High School shortly thereafter.52
Further research indicates that the campus was designed by architects Gordon G. Kaufmann and J. E. (Jesse) Stanton; E. C. Nesser served as the contractor.53 Kaufmann was a high-profile Southern California area architect who worked in several styles over his career. His early Mediterranean Revival projects include the Scripps College campus in Claremont in the late 1920s. Working in concrete, he later became known for his massive streamlined Art Deco projects, including Boulder (Hoover) Dam (1936) and the Los Angeles Times Building (1935), as well as more delicate treatments such as exhibited at the Santa Anita Park racetrack (1934) and the Hollywood Palladium (1940).54
Archaeological Resources Characterization
A record search was conducted on October 6, 2014, by staff at the SCCIC, located at California State University, Fullerton, and revealed no previously recorded archaeological resources within the proposed project footprint.55 No previous cultural resources studies were conducted within the proposed project footprint. Because the proposed project will not be extending beyond the
45 U.S. Geological Survey. 15-minute Santa Monica Quadrangle. 1902. 46 U.S. Geological Survey. 15-minute Santa Monica Quadrangle. 1921. 47 U.S. Geological Survey. 7.5-minute Sawtelle Quadrangle. 1925. 48 U.S. Geological Survey. 7.5-minute Sawtelle Quadrangle. 1934. 49 U.S. Geological Survey. 7.5-minute Beverly Hills Quadrangle. 1950. 50 Mark Twain Middle School: Campus Pre-Planning Survey. Available at: http://mo.laschools.org/planlausd/content/?crit=surveys#s2; Accessed 20 September 2014. 51 “Contracts Awarded for Two Schools Total $1,174,571, Los Angeles Times, July 21, 1950 (for construction of “administration, arts and sciences, and industrial arts buildings at Mark Twain Junior High School”). 52 “Venice Junior High Name Change Approved.” 13 January 2013. Los Angeles Times. 53 “Expansion Under Way at Mark Twain School,” Los Angeles Times, December 17, 1950. 54 Pacific Coast Architecture Database. Available at: https://digital.lib.washington.edu/; accessed October 2, 2014. 55 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 6 October 2014. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Program.” Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-14 Draft EIR Subchapter 3E. Cultural Resources boundaries of the property previous investigations and resources outside the proposed project footprint were not reviewed.
Coordination was undertaken with the NAHC for the presence of known Native American sacred sites. According to a response from the NAHC dated October 30, 2014,56 no Native American cultural resources have been recorded in the Sacred Lands File for the proposed project site. Additionally, a list of Native American individuals who may have knowledge of cultural resources was provided by the NAHC to Sapphos Environmental, Inc. Letters requesting information or comments regarding Native American cultural resources in the vicinity of the proposed project were sent to the individuals listed by the NAHC. As of November 20, 2014, Sapphos Environmental, Inc. has received one response from the contacted individuals. Sapphos Environmental, Inc. received an email response from Mr. Andrew Salas, Chairperson of the Gabrieleno Band of Mission Indians, on November 19, 2014, stating the project area is within a Sacred Area of his tribe and that the project area is known as a highly sensitive site. Additionally, Mr. Salas requested that Native American monitors from the Gabrieleno Band of Mission Indians and Tongva Ancestral Territorial Tribal Nation be present during any and all ground disturbance associated with this project. Sapphos Environmental, Inc. replied to Mr. Salas on November 20, 2014, stating his comments and concerns would be addressed and incorporated in the EIR.
Historical Resources Characterization
A record search was conducted on October 6, 2014, by staff at the SCCIC, located at California State University, Fullerton, and revealed no resources recorded on the California Office of Historic Preservation Historic Properties Directory or the Los Angeles Historic-Cultural Monuments list are present within the proposed project footprint.57
The recent 2014 LAUSD Historic Resources Inventory prepared by Sapphos Environmental, Inc. did not evaluate this campus. SurveyLA, a multi-year, citywide historic resource survey led by the City of Los Angeles Office of Historic Resources and covering all of Los Angeles, is ongoing. As of November 2014, Mark Twain Middle School has not been designated as eligible for listing. In earlier LAUSD surveys, the school was evaluated as ineligible for NRHP, CRHR, or local designation. As of 2014, previous evaluations of this school are over 5 years old; as such, the Mark Twain Middle School requires a current evaluation for its potential historical significance under CEQA.
Mark Twain Middle School
The campus site plan consists of a large main building with two wings enclosing a central grassy quadrangle and housing administrative offices, classrooms, and the school library. Separate auditorium, Industrial arts building, cafeteria, and physical education buildings are dispersed throughout the campus. Freestanding single-loaded classroom buildings are grouped toward the northwest and northeast boundaries of the campus.
56 Sanchez, Katy, Native American Heritage Commission, Sacramento, CA. 30 October 2014. Letter to Karl Holland, Sapphos Environmental, Inc., Pasadena, CA. 57 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 6 October 2014. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Program.” Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-15 Draft EIR Subchapter 3E. Cultural Resources
The campus buildings form a unified site plan with consistent architectural style throughout. All of the buildings have flat or low-pitched shed roofs and are one story or one-and-a-half stories in height. Exterior surfaces are clad in stucco over what appears to be concrete block, with variegated rose-colored brick used for planters and piers near the entrance and occasionally throughout the campus. Repeated motifs include a grid pattern, vertical projecting piers, and plain projecting window surrounds. The grid pattern is apparent in the window groupings and in a punched-out screen near the library. Vertical projecting piers are used most noticeably at the entrance to the auditorium, at both elevations of the physical education building, and at the cafeteria. The piers are typically of smooth stucco, although a few are faced with brick. The projecting window surrounds define window groupings throughout the campus.
Although Mark Twain Middle School is technically a postwar campus, when viewed through the lens of the contexts defined by the LAUSD Historic Context Statement, it appears to mark a transition between early experiments in modernism and the school types arising out of the rapid postwar expansion.58 Architecturally, some of the Art Deco elements of the campus, and for which the principal architect was known, are more typical of earlier campuses, specifically those falling under the theme of Public Schools and the LAUSD, 1876–1980, sub-theme of Post-1933 Long Beach Earthquake, 1933–1945, as defined in the Historic Context Statement for SurveyLA.59 The strong columnar elements are also suggestive of the institutional instance of a slightly later style known as New Formalism (Architecture and Engineering, 1850–1980; sub-context: L.A. Modernism, 1919–1980; theme: Post-War Modernism, 1946–1976; sub-theme: New Formalism, 1955–1976).60 Character-defining/associative features apparent at the Mark Twain Middle School campus that are atypical of a postwar school include a main administration building with “separate additional buildings for cafeterias, auditoriums, gymnasiums, and classrooms.”61 The monumentality of the tall tower at the intersection of the two wings of the main building and the muscularity of the Physical Education Building suggest an industrial sensibility such as practiced during the earlier New Deal era.
In general, although the simple, geometric volumes, flat roofs, lack of historicism, and minimal ornamentation of the campus buildings are qualities shared with Mid-Century Modernism, the campus displays a symmetry and formalism suggestive of an earlier era. Doors are often centered on walls, and windows are generally placed in balanced groups. The relationship of indoors to outdoors that is so important in Mid-Century Modern architecture is less apparent at this campus. Mature trees in the quad and between classroom buildings are planted in regularly spaced rows rather than in naturalistic groupings. Rather than orienting the classroom buildings and windows to take advantage of sun and shade, classroom buildings at Mark Twain Middle School are sited in
58 Sapphos Environmental, Inc., March 2014. Los Angeles Unified School District Historic Context Statement. Pasadena, CA. 59 Historic Context Summary Tables published by the City of Los Angeles Office of Historic Resources. Accessed 25 June 2014. Available at: http://preservation.lacity.org/news/surveyla-historic-context-summary- tablespublished 60 Historic Context Summary Tables published by the City of Los Angeles Office of Historic Resources. Accessed 25 June 2014. Available at: http://preservation.lacity.org/news/surveyla-historic-context-summary- tablespublished 61 Historic Context Summary Tables published by the City of Los Angeles Office of Historic Resources. Accessed 25 June 2014. Available at: http://preservation.lacity.org/news/surveyla-historic-context-summary- tablespublished, p. 61. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-16 Draft EIR Subchapter 3E. Cultural Resources various directions. Windows throughout the campus are relatively small, occupying 50 percent of the wall space or less.
Main Building. The main building is composed of two long double-loaded wings set at right angles to one another. Administrative offices and classrooms occupy the wing at the front of the campus on Walgrove Avenue, and the other wing is devoted to arts and sciences. A plain stucco-clad tower rises above the building at the juncture of the two wings. A flat pop-up roof extends the length of each wing, with a series of clerestory windows on the sides admitting light and air to the hallways and rooms below. The clerestories are composed of discrete groups of glass blocks, each with a central operable narrow awning-type window. At the street elevation is a series of double-hung wood sash windows inset in groups of three with simple projecting around the length of the building. At the quad side are groups of awning-type windows; at the southeast wing, a central door opening onto a patio is included in each grouping.
Classroom Buildings. The majority of the classrooms are located in small single-loaded buildings clustered in one section of the campus and positioned with ample space between. The stucco-clad buildings are connected by flat-roofed corridors supported by slender metal poles positioned below clerestory windows. The shed roofs have a shallow overhang at the back side of the classrooms, where double-hung sash windows are placed in groups of six.
Physical Education Building. The Physical Education Building is arguably the building that most reflects the sensibilities of the Art Deco style. The building displays clean, simple lines and a striking barrel-vaulted roof. At the southeast elevation toward the playground, strongly projecting piers frame a series of windows arranged in a grid pattern. At the northwest elevation toward campus, the curve of the barrel vault is emphasized by a projecting frame and a broad expanse of stucco with no windows.
Auditorium. Located at the western corner of the campus, the one-and-a-half story Auditorium displays a smooth stucco surface and a projecting canopy supported by plain rectangular stucco piers at the street-side entrance.
Landscaping. The landscaping in the interior of the campus is notable for its formality. In keeping with the symmetry of the buildings, mature trees are intentionally aligned and regularly spaced in the areas between classroom buildings and in the central quadrangle. Straight walkways line the quadrangle and provide circulation throughout the campus. Human Remains
Context
The interment of human remains among California Native Americans can be classified into three methods: inhumation (burial), cremation, and a combination of both inhumation and cremation. The preferred method varied depending on the region and cultural group, and some groups practiced both methods simultaneously depending of the situation in which the individual died. With interment came the practice of grave goods, a practice favored by most of the tribes in California. Grave goods usually consisted of beads of various materials, knifes, projectile points, and exotic trade items among other objects.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-17 Draft EIR Subchapter 3E. Cultural Resources
Historic period interment of human remains varied greatly by early migrants and ethnic groups. The internment method chosen was often a result of the circumstances and location at the time of death, religion or cultural beliefs, as well as financial status. In the late nineteenth and early twentieth centuries, cemeteries were few and often located at some distance. Burial on the homestead grounds was often a preferred alternative.
Resource Characterization
Reviews of historic maps,62,63,64,65,66 along with the results of the SCCIC records search and NAHC Sacred Lands file search, indicate that there are no known Native American or historic period cemeteries, nor known informal Native American burials, within the vicinity of the proposed project site.67,68 Letters of inquiry were sent to individuals listed by the NAHC regarding the presence of sensitive Native American resources in the project vicinity. As of November 20, 2014, Sapphos Environmental, Inc. has received one response. Sapphos Environmental, Inc. received an email response from Mr. Andrew Salas, Chairperson of the Gabrieleno Band of Mission Indians, on November 19, 2014, stating the project area is within a Sacred Area of his tribe and that the project area is known as a highly sensitive site. Additionally, Mr. Salas requested that Native American monitors from the Gabrieleno Band of Mission Indians and Tongva Ancestral Territorial Tribal Nation be present during any and all ground disturbance associated with this project. Sapphos Environmental, Inc. replied to Mr. Salas on November 20, 2014, stating his comments and concerns would be addressed and incorporated in the EIR.
3E.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of four questions when addressing the potential for significant impact to cultural resources. Would the proposed project: a. Cause a substantial adverse change in the significance of a historical resource as defined in § 15064.5? b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? c. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d. Disturb any human remains, including those interred outside of formal cemeteries?
62 U.S. Geological Survey. 15-minute Santa Monica Quadrangle. 1902. 63 U.S. Geological Survey. 15-minute Santa Monica Quadrangle. 1921. 64 U.S. Geological Survey. 7.5-minute Sawtelle Quadrangle. 1925. 65 U.S. Geological Survey. 7.5-minute Sawtelle Quadrangle. 1934. 66 U.S. Geological Survey. 7.5-minute Beverly Hills Quadrangle. 1950. 67 Sanchez, Katy, Native American Heritage Commission, Sacramento, CA. 30 October 2014. Letter to Karl Holland, Sapphos Environmental, Inc., Pasadena, CA. 68 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 6 October 2014. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Program.” Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-18 Draft EIR Subchapter 3E. Cultural Resources
With respect to paleontological resources, CEQA does not specifically establish thresholds for significant impacts; however, Appendix G of the State CEQA Guidelines indicates that a project may have a significant effect on the environment if it would directly or indirectly destroy a unique paleontological resource or unique geologic feature.
Under CEQA, a project with an effect that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment. Substantial adverse change in the significance of an historical resource is defined as physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. The significance of an historical resource would be significantly impaired when a project demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the CRHR, a local register of historic resources pursuant to Section 5020.1(k) of the Public Resources Code, or historic resources survey meeting the requirements of Section 5024.1(g) of the Public Resources Code. CEQA also explicitly states that damage to archaeological sites that meet the definition of an historical resource or unique archaeological resource must be considered. In general, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties and associated guidelines shall be considered as mitigated to below the level of significance.69
While a significance threshold for impacts to human remains is not explicitly stated in CEQA, Appendix G of the CEQA Guidelines indicates that any disturbance of human remains could potentially be considered an impact to cultural resources, particularly with respect to Native American graves and burials.
3E.4 IMPACT ANALYSIS
Impact 3E-a: Would the proposed project cause a substantial adverse change in the significance of a historical resource as defined in § 15064.5?
No Impact
The proposed project would not be expected to result in significant impacts to historical resources related to a substantial adverse change in the significance of a historical resources resource. There are no existing historic resources listed as eligible or eligible for listing on the CRHR, NRHP, or locally register within the proposed project area. Additionally, the Mark Twain Middle School campus was evaluated for the CRHR and local listing in a Historic Resources Assessment (Attachment A, Historic Resources Assessment) and determined that the campus is not associated with lives of persons significant in the past or with events that have made a significant contribution to broad patterns of history, and it is not a historical resource as defined by CEQA. Therefore, it is not eligible for CRHR or NRHP listing under Criteria A/1, B/2, or C/3. As such, the proposed project would not be expected to cause a substantial adverse change in the significance of a historical resource.
69 Weeks, Kay D., and Anne E. Grimmer. 1995. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstruction Historic Buildings. Washington, DC: U.S. Department of the Interior, National Park Service. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-19 Draft EIR Subchapter 3E. Cultural Resources
Impact 3E-b: Would the proposed project cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
No Impact
The proposed project would not be expected to result in significant impacts to cultural resources related to a substantial adverse change in the significance of a prehistoric archeological resource. According to the SCCIC, there are no known prehistoric resources within the proposed project area.70,71 An individual listed by the NAHC as someone who may have knowledge of cultural resources in the project area identified the proposed project area as an area of high sensitivity to Native American resources. However, due to the level of disturbance that has occurred within the proposed project area with historical development and construction, it is unlikely that such resources are present. Therefore, the proposed project is unlikely to cause a substantial adverse change in the significance of an archaeological resource. It is the recommendation of Sapphos Environmental, Inc. that Native American consultation continue; however, any additional action, such as Native American monitoring, shall be done under the discretion of LAUSD.
Impact 3E-c: Would the proposed project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Potentially Significant Impact
The proposed project has the potential to result in significant impacts to cultural resources related directly or indirectly to the destruction of a unique paleontological resource. The geology of the proposed project site is composed of surficial deposits of younger Quaternary Alluvium underlain by older Quaternary Alluvium. The older Quaternary Alluvium deposits have the potential to reveal important vertebrate fossils that can contribute to the life history of the area. The implementation of the proposed project is anticipated to result in excavations into these older deposits. As a result, the proposed project has the potential to result in significant impacts to cultural resources related directly or indirectly to the destruction of a unique paleontological resource, therefore requiring the consideration of mitigation measures.
There are no unique geological features currently identified within the proposed project boundary; therefore, there would be no expected impacts to cultural resources related to the destruction of a unique geologic feature.
70 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 6 October 2014. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Program.” 71 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 9 March 2015. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Program.” Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-20 Draft EIR Subchapter 3E. Cultural Resources
Impact 3E-d: Would the proposed project disturb any human remains, including those interred outside of formal cemeteries?
Potentially Significant Impact
Although the likelihood of encountering human remains is low, the proposed project has the potential to directly or indirectly disturb human remains, including those interred outside of formal cemeteries. The results of the archaeological record search and review of historic maps72,73,74 indicate that no historic period or Native American burial grounds are located within or in proximity to the proposed project site. An individual listed by the NAHC as someone who may have knowledge of cultural resources in the project area identified the proposed project area as an area of high sensitivity to Native American resources. Sensitive Native American resources may contain human remains. However, due to the level of disturbance that has occurred within the proposed project area with historical development and construction, it is unlikely that such resources are present. It is the recommendation of Sapphos Environmental, Inc. that Native American consultation continue; however, any additional action, such as Native American monitoring, shall be done under the discretion of LAUSD. The potential disruption associated with an unanticipated discovery of human remains constitutes a significant impact requiring the consideration of mitigation measures. Therefore, although the likelihood of encountering human remains is low, the proposed project has the potential to disturb human remains, including those interred outside of formal cemeteries, requiring the consideration of mitigation measures.
3E.5 CUMULATIVE IMPACTS
Cumulative impacts to cultural resources take into account the impacts of the proposed project or alternatives as well as those likely to occur as a result of other existing, proposed, and reasonably foreseeable future projects. When analyzing cumulative impacts to cultural resources, an assessment is made of the impacts on individual resources as well as the inventory of cultural resources within the cumulative impact analysis area. This study identifies the destruction of a unique paleontological resource or unique geologic feature as a potentially significant impact. Cumulative impacts to paleontological resources involve the loss of nonrenewable scientifically important fossils and associated data, and the incremental loss to science and society of these resources over time.
In consideration of the related past, present, or reasonably foreseeable probable future projects in the proposed project vicinity, the proposed project would not lead to an adverse effect or a significant impact to paleontological resources. Any paleontological resources encountered as a result of the proposed project are likely to be individual specimens contained within a confined area, based on fossil localities in the project vicinity. Therefore, any impact to paleontological resources will not result in a cumulative impact as the resource will be contained within the proposed project area. With regard to paleontological resources, implementation of the proposed project or an alternative is not expected to contribute to cumulative impacts associated with the destruction of unique paleontological resources or unique geologic features.
72 U.S. Geological Survey. 1902. 15-Minute Downey, California, Topographic Quadrangle. Reston, VA. 73 U.S. Geological Survey. 1936. 7.5-Minute Bell, California, Topographic Quadrangle. Reston, VA. 74 U.S. Geological Survey. 1947. 15-Minute Downey, California, Topographic Quadrangle. Reston, VA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-21 Draft EIR Subchapter 3E. Cultural Resources
3E.6 MITIGATION MEASURES
The impacts to cultural resources related directly or indirectly to the destruction of a unique paleontological resource from the proposed project shall be reduced to below the level of significance through the salvage and disposition of paleontological resources that result from all earthmoving activities involving disturbances of the older Quaternary Alluvium. Ground-disturbing activities, including, but not limited to, drilling, excavation, and trenching, greater than five feet of the surface have the potential to uncover significant vertebrate fossil remains. For this reason, Mitigation Measure Cultural-1 is proposed to reduce the level of impacts regarding the destruction of a unique paleontological resource to below the level of significance:
MM Cultural-1 Paleontological Resources Sensitivity Training will be provided for all project personnel prior to the start of ground-disturbing activities. Should a potentially unique paleontological resource be encountered, a qualified paleontologist, as defined by the Society of Vertebrate Paleontology’s Impact Mitigation Guidelines, shall be contacted to assess the find.75 All significant specimens collected shall be appropriately prepared, identified, and catalogued prior to their placement in a permanent accredited repository. At the conclusion of ground-disturbing activities, a mitigation report will be prepared documenting the results of the paleontological resources monitoring.
Mitigation Measure Cultural-2 is proposed to reduce the level of impacts regarding the unanticipated discovery of human remains to below the level of significance.
MM Cultural-2 In the event of unanticipated discovery of human remains, the Los Angeles County Coroner shall be notified within 24 hours of the discovery of human remains and there shall be no further excavation or disturbance of the site or any of that area reasonably suspected to overlie adjacent human remains until the Coroner has determined that no investigation of the cause of death is required. Additionally, if the remains are of Native American origin, interested Native American groups or individuals will be contacted to make recommendations to LAUSD for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code Section 5097.98.
3E.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3E-a and 3E-b: No impact.
Impact 3E-c: Less than significant impact with mitigation incorporated. Implementation of Mitigation Measure Cultural-1 would reduce impacts to cultural resources related to an adverse change in the significance of a paleontological resource to below the level of significance.
75 Society of Vertebrate Paleontology. n.d. “Conformable Impact Mitigation Guidelines.” Available at: http://vertpaleo.org/The-Society/Governance-Documents/Conformable-Impact-Mitigation-Guidelines- Committee.aspx Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3E-22 Draft EIR Subchapter 3E. Cultural Resources
Impact 3E-d: Less than significant impact with mitigation incorporated. Implementation of Mitigation Measure Cultural-2 would reduce any potential significant impacts to human remains to below the level of significance.
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This analysis is undertaken to determine if the proposed project may have a significant impact to geology and soils, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 This analysis also explores opportunities to avoid or mitigate any potential significant impacts that may be identified that relate to geology and soils.
The analysis of geology and soils consists of a summary of the regulatory framework that guides the decision-making process, a description of the existing conditions at the proposed project site, thresholds for determining if the proposed project would result in significant impacts, anticipated impacts (direct, indirect, and cumulative), mitigation measures, and level of significance after mitigation. The potential for impacts to mineral resources has been analyzed in accordance with the methodologies provided by California Division of Mines and Geology publications,2,3,4,5,6,7,8 the Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation (Appendix E to this EIR),9 the LAUSD California Environmental Quality Act Specification Manual,10 the California Building Code,11 the California Administrative Code,12 and the California Education Code.13
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 California Division of Mines and Geology. 2007. Fault-Rupture Hazard Zones in California, Alquist-Priolo Earthquake Fault Zoning Act with Index to Earthquake Fault Zones Maps. 3 California Division of Mines and Geology. 1985. Fault Evaluation Report FER-173, Northern Newport- Inglewood Fault Zone, Los Angeles County, California. Prepared by William Bryant. 4 California Division of Mines and Geology. 1998. Seismic Hazard Zone Report for the Beverly Hills 7.5-Minute Quadrangle, Los Angeles County, California. 5 California Division of Mines and Geology. 1986. State of California Special Studies Zones, Beverly Hills Quadrangle. 6 California Division of Mines and Geology. 1999. State of California Seismic Hazard Zones, Beverly Hills Quadrangle. 7 California Division of Mines and Geology. 1999. State of California Seismic Hazard Zones, Venice Quadrangle. 8 California Division of Mines and Geology. 1998. Seismic Hazard Zone Report for the Venice 7.5-Minute Quadrangle, Los Angeles County, California. 9 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 10 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. 11 California Building Standards Commission. 2013. California Building Code, California Code of Regulations, Title 24, Part 2, Volume 1. 12 California Building Standards Commission. 2013. California Administrative Code, California Code of Regulations, Title 24, Part 1. 2013. 13 California Education Code, California Department of Education. 1976. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-1 Draft EIR Subchapter 3F. Geology and Soils
Definitions
Seismic Hazard Zone Maps. Maps issued by the State Geologist under PRC Section 2696 that show zones of required investigation.
Zones of Required Investigation, referred to as Seismic Hazard Zones. Defined in CCR Section 3722, are areas shown on Seismic Hazard Zone Maps where site investigations are required to determine the need for mitigation of potential liquefaction and/or earthquake-induced landslide ground displacements.
Minimum Statewide Safety Standard. The Seismic Hazards Mapping Act and related regulations establish a statewide minimum public safety standard for mitigation of earthquake hazards. This means that the minimum level of mitigation for a project should reduce the risk of ground failure during an earthquake to a level that does not cause the collapse of buildings for human occupancy, but in most cases, not to a level of no ground failure at all. More stringent requirements are prescribed by the California Building Code (CCR Title 24) for hospitals, public schools, and essential service buildings. For such structures, the requirements of the Seismic Hazards Mapping Act are intended to complement the CCR Title 24 requirements.
Fault. A fault is a fracture along which the blocks of crust on either side have moved relative to one another parallel to the fracture. Faults are classified as active by the California Geological Survey if they show evidence of surface displacement within the last 11,000 years.14
Energy Release. The energy released by an earthquake is measured as moment magnitude (Mw). The Mw scale is logarithmic; therefore, each 1-point increase in magnitude represents a tenfold increase in amplitude of the waves and a 32-fold increase in energy. So, a magnitude-7 earthquake produces 100 times (10 × 10) the ground motion amplitude of a magnitude-5 earthquake.
Ground Motion. Motion at the ground surface during an earthquake is measured as horizontal ground acceleration in g, where g is the acceleration of gravity.
Alquist-Priolo Earthquake Fault Zone. The California Geological Survey designates zones of required investigation along known active faults. Before cities and counties can permit development within Alquist-Priolo Earthquake Fault Zones, geologic investigations are required to show that the sites are not threatened by surface rupture from future earthquakes. Building sites must be set back from identified active faults.
Liquefaction. Liquefaction is a process whereby strong earthquake shaking causes sediment layers that are saturated with groundwater to lose strength and behave as a fluid. This subsurface process can lead to near-surface or surface ground failure that can result in property damage and structural failure. If surface ground failure does occur, it is usually expressed as lateral spreading, flow failures, ground oscillation, and/or general loss of bearing strength. Sand boils (injections of fluidized sediment) can commonly accompany these different types of failure.
Earthquake-Induced Landslides. Landslides triggered by earthquakes historically have been a significant cause of earthquake damage. Areas that are most susceptible to earthquake-induced
14 California Geological Survey (CGS). 27 August 2007. Fault-Rupture Hazards in California: Special Publication 42. Available at: ftp://ftp.consrv.ca.gov/pub/dmg/pubs/sp/Sp42.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-2 Draft EIR Subchapter 3F. Geology and Soils landslides are steep slopes in poorly cemented or highly fractured rocks; areas underlain by loose, weak soils; and areas on or adjacent to existing landslide deposits.15
Collapsible Soils. Collapsible soils are low-density, silty to very fine-grained, predominantly granular soils containing minute pores and voids. When saturated, these soils undergo a rearrangement of their grains and a loss of cementation, causing substantial, rapid settlement under even relatively light loads. A rise in the groundwater table or an increase in surface water infiltration, combined with the weight of a building or structure, can cause rapid settlement and consequent cracking of foundations and walls. Collapsible soils generally result from rapid deposition close to the source of the sediment where the materials have not been sufficiently moistened to form a compact soil.
Expansive Soils. Expansive soils contain certain types of clay minerals that shrink or swell as the moisture content changes; the shrinking or swelling can shift, crack, or break structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture experience a much higher frequency of problems from expansive soils than areas with higher rainfall and more constant soil moisture.16
Subsidence. Subsidence is the sinking of the land surface. Evidence of subsidence includes ground cracking and damage to roadways, aqueducts, and structures. Subsidence caused by excessive groundwater pumping is a common occurrence in areas of California where groundwater is pumped for agricultural and municipal wells.17 Land subsidence also occurs due to oil withdrawal; the best-known example of which is in the Wilmington Oil Field in southern Los Angeles County, where land subsidence has reached nine meters (30 feet).18
Groundwater. Groundwater is water underneath the surface of the earth. Rock or soil yielding groundwater to wells or springs in economically usable amounts is termed an aquifer; the upper surface of an aquifer is termed the water table.19
3F.1 REGULATORY FRAMEWORK
The following regulatory framework identifies the federal, state, and local statutes, ordinances, or policies that govern geology and soils in relation to the proposed project.
15 California Geological Survey. 2001. Seismic Hazard Zone Report for the Oat Mountain 7.5-Minute Quadrangle, Los Angeles County, California. http://gmw.consrv.ca.gov/shmp/download/quad/OAT_MOUNTAIN/reports/oatm_eval.pdf 16 Colorado Geological Survey (COGS). 28 April 2011. Definition of Swelling Soils. http://geosurvey.state.co.us/hazards/Swelling%20Soils/Pages/Definition.aspx 17 Harden, Deborah. 2004. California Geology. Upper Saddle River, NJ: Pearson Education, Inc. 18 Poland, Joseph F. 1984. Guidebook to studies of land subsidence due to ground-water withdrawal. United Nations Educational, Scientific, and Cultural Organization (UNESCO). http://wwwrcamnl.wr.usgs.gov/rgws/Unesco/PDF-Chapters/Chapter3.pdf 19 Sharp, John M., Jr. 2007. A Glossary of Hydrogeological Terms. University of Texas, Austin. http://www.geo.utexas.edu/faculty/jmsharp/sharp-glossary.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-3 Draft EIR Subchapter 3F. Geology and Soils
Federal
Uniform Building Code
The Uniform Building Code (UBC) is published by the International Conference of Building Officials and forms the basis for California’s building code, as well as approximately 50 percent of the state building codes in the United States. It has been adopted by the California Legislature to address the specific building conditions and structural requirements for California, and to provide guidance on foundation design and structural engineering for different soil types. The UBC defines and ranks regions of the United States according to their seismic hazard potential. There are four types of regions defined by Seismic Zones 1 through 4, with Zone 1 having the least seismic potential and Zone 4 having the highest. The subject parcels in the proposed project are located within Seismic Zone 4.
Code of Federal Regulation, Title 10, Section 1022.11
Flood Insurance Rate Maps (FIRMs) are prepared by the Federal Insurance Administration of the Department of Housing and Urban Development (HUD) after a risk study for a community has been completed and the risk premium rates have been established, pursuant to 10 CFR §1022.11, 43 CFR §64.3. The maps indicate the risk premium zones applicable in the community and when those rates are effective. FIRMs are used in making flood plain determinations and determining if a proposed action is located in the base or critical action flood plain, as appropriate. State
Alquist-Priolo Earthquake Fault Zoning Act of 1972
Formerly the Special Studies Zoning Act, the Alquist-Priolo Earthquake Fault Zoning Act of 1972 regulates development and construction of buildings intended for human occupancy to avoid the hazard of surface fault rupture. In accordance with this law, the California Geological Survey maps active faults and designates Earthquake Fault Zones along mapped faults. This Act groups faults into categories of active, potentially active, and inactive. Historic and Holocene age faults are considered active, Late Quaternary and Quaternary age faults are considered potentially active, and pre-Quaternary age faults are considered inactive. These classifications are qualified by the conditions that a fault must be shown to be “sufficiently active” and “well defined” by detailed site- specific geologic explorations in order to determine whether building setbacks should be established. Any project that involves the construction of buildings or structures for human occupancy, such as an operation and maintenance (O&M) building, is subject to review under the Alquist-Priolo Earthquake Fault Zoning Act, and any structures for human occupancy must be located at least 50 feet from any active fault.
Seismic Hazards Mapping Act of 1990
In accordance with Public Resources Code, Chapter 7.8, Division 2, the California Department of Conservation, Division of Mines and Geology (now the California Geological Survey [CGS]) is directed to delineate Seismic Hazard Zones through the Seismic Hazards Zonation Program. The purpose of the Act is to reduce the threat to public health and safety and to minimize the loss of life and property by identifying and mitigating seismic hazards, such as those associated with
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-4 Draft EIR Subchapter 3F. Geology and Soils strong ground shaking, liquefaction, landslides, other ground failures, or other hazards caused by earthquakes. Cities, counties, and State agencies are directed to use seismic hazard zone maps developed by CGS in their land-use planning and permitting processes. In accordance with the Seismic Hazards Mapping Act, site-specific geotechnical investigations must be performed prior to permitting most urban development projects within seismic hazard zones.
California Administrative Code
Chapter Four, Group One of the California Administrative Code (Safety of Construction of Public Schools) provides specific requirements for the construction of school buildings in regard to geologic hazards. The provisions expect school buildings to be constructed able to resist earthquake forces generated by major earthquakes of the intensity and severity of the strongest experienced in California without catastrophic collapse. The provisions require the design and construction of school buildings be in compliance with regulations adopted by the Division of State Architect (DSA) and may require consultation and approval by the DSA.
California Building Code (CBC 2010)
The State of California provides minimum standards for building design through the California Building Code (CBC). The CBC is based on the Uniform Building Code (UBC), which is used widely throughout the United States (generally adopted on a state-by-state or district-by-district basis), and has been modified for conditions within California. In 2010, a revised version of the CBC took effect. In accordance with the CBC, a grading permit is required if more than 50 cubic yards of soil is moved during implementation of a project. Chapter 16 of the CBC contains definitions of seismic sources and the procedure used to calculate seismic forces on structures.
California Education Code
Sections §17212 and §17212.5 of the California Education Code require analysis of impacts relating to geology and soils prior to the construction of school buildings. Section §17212 states that if the prospective school site is located within the boundaries of any special studies zone or within an area designated as geologically hazardous in the safety element of the local general plan, a geological and soil engineering study completed by competent personnel is needed to provide an assessment of the nature of the site and potential for earthquake or other geologic hazard damage. Section §17212.5 states that no school building shall be constructed, reconstructed, or relocated on the trace of a geological fault along which surface rupture can reasonably be expected to occur within the life of the school building. Additionally, Section §17212.5 requires a geological and soil engineering study be prepared for the construction of any school building, or if the estimated cost exceeds $25,000 for the reconstruction, alteration or addition to any school building that alters structural elements.
California Code of Regulations, Title 5. Education, §14010
Standards for School Site Selection requires that, pursuant to Education Code §17212 and §17212.5, the site shall not contain an active earthquake fault or fault trace, and shall not be subject to moderate to high liquefaction or landslides.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-5 Draft EIR Subchapter 3F. Geology and Soils
California Code of Regulations, Title 5. Education, §14011
Procedures for Site Acquisition–State-Funded School requires that, in compliance with Education Code §17212 and §17212.5, the geological and soil engineering study shall address all of the following:
a) Nature of the site, including a discussion of liquefaction, subsidence or expansive soils, slope, stability, dam or flood inundation, and street flooding;
b) Whether the site is located within a special study zone as defined in Education Code §17212;
c) Potential for earthquake or other geological hazard damage;
d) Whether the site is situated on or near a pressure ridge, geological fault, or trace fault that may rupture during the life of the school building and the student risk factor; and
e) Economic feasibility of the construction effort to make the school building safe for occupancy.
3F.2 EXISTING CONDITIONS Earthquake Faults
The proposed project area is located within a seismically active region. Potential hazards that can result from seismic activities include surface rupture of earthquake faults, seismic ground shaking, liquefaction, and landslides. Numerous faults are located within the Los Angeles Basin. Of the four national earthquake zones, ranging from 1 to 4 with 4 posing the largest danger, the Los Angeles Basin is classified as a Seismic Zone 4.20
Although the proposed project area is not located within an Alquist-Priolo Earthquake Fault Zone (APEFZ), one APEFZ is present approximately four miles of the proposed project area (Figure 3F.2- 1, Active Alquist-Priolo Fault Zones in Proposed Project Vicinity).21,22 The Newport-Inglewood fault zone is an APEFZ that extents for approximately 45 miles from Newport mesa northwest to the Cheviot Hills northeast of the proposed project area. The Newport-Inglewood fault zone consists of a series of northwest-trending, generally right-lateral strike-slip faults. These faults and associated structural features make up the Newport-Inglewood structural zone. Maximum displacement along the Newport-Inglewood fault zone has been estimated to six miles at an average slip rate of 0.02 inches/year.23 The Newport-Inglewood fault zone is the only fault zone included in the South Area
20 California Seismic Safety Commission. 2005. Homeowner’s Guide to Earthquake Safety. Sacramento, CA. Available at: http://www.seismic.ca.gov/pub/CSSC_2005-01_HOG.pdf 21 California Division of Mines and Geology. 1986. State of California Special Studies Zones, Beverly Hills Quadrangle. 22 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 23 California Division of Mines and Geology. 1985. Fault Evaluation Report FER-173, Northern Newport- Inglewood Fault Zone, Los Angeles County, California. Prepared by William Bryant. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-6 Draft EIR LEGEND ^]! Project Site Fault Zones Hollywood Newport-Inglewood
^]!
SOURCE: SEI, ESRI
0 0.5 1 2 3 Miles o 1:120,000 Q:\1498\MarkTwain_MS\ArcProjects\FaultZone.mxd
FIGURE 3F.2-1 Active Alquist Priolo Fault Zones in Proposed Project Vicinity Subchapter 3F. Geology and Soils
(includes Mark Twain Middle School) as described in the LAUSD California Environmental Quality Act Specification Manual (Table 3F.2-1, Active Fault Zones in LAUSD South Zone).24
Table 3F.2-1 Active Fault Zones in LAUSD South Zone Length Maximum Fault Zone Fault Type (Miles) Nearby Communities Slip Rate Magnitude Newport-Inglewood Strike-slip 45 Culver City, Inglewood, Gardena, 0.02 inches/year 6.9 Compton SOURCE: LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007.
Historic activity along the Newport-Inglewood fault zone occurred on March 10, 1933.25 Although there was no surface rupture associated with the earthquake, it resulted in the deaths of 120 people and at least $50 million in property damage. The event became known as the Long Beach earthquake (6.3 magnitude) and was the second most deadly earthquake in California history next to the 1906 San Francisco earthquake. Additional significant earthquakes centered within 30 miles of the proposed project site include: the February 9, 1971, San Fernando earthquake (6.6 magnitude), the 1987 Whittier Narrows earthquake (6.0 magnitude), and the January 17, 1994, Northridge earthquake (6.7 magnitude).26
Although no potentially active or active faults are known to exist within the site, the area will be subject to ground motion from occasional earthquakes in the region.27 Where earthquakes are large enough, or shallow enough, surface rupture can occur along the fault plane where it intersects the earth's surface. Despite the presence of faults in the region, there are no fault scarps showing signs of recent activity recorded in the proposed project area.28 Seismic Ground Shaking
Seismic ground shaking is a potential seismic danger resulting from earthquakes that may occur in the region. Several factors contribute to the significance of ground shaking during an earthquake, including the proximity of the area to a fault or fault system, the depth of earthquake, the location of the epicenter, the magnitude of the earthquake, and the geologic substrate. Movement along the Newport-Inglewood fault zone or any other known or unknown fault in the Los Angeles Basin could result in ground shaking within the proposed project area. The project area would be most likely affected by seismic ground shaking along the Newport-Inglewood fault zone due to its proximity. Based on geotechnical studies, it is likely significant earthquakes will occur in the region within the life expectancy of the proposed project and the proposed project site will experience
24 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. 25 “Long Beach Earthquake.” n.d. California Institute of Technology Southern California Earthquake Data Center. Available at: http://www.data.scec.org/significant/longbeach1933.html 26 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 27 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 28 California Division of Mines and Geology. 1986. State of California Special Studies Zones, Beverly Hills Quadrangle. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-7 Draft EIR Subchapter 3F. Geology and Soils ground shaking from these events.29 Despite this, the proposed project area is not delineated by the California Division of Mines and Geology as within an APEFZ.30 Liquefaction
Liquefaction occurs when saturated, cohesionless (low relative density) materials (usually sand or silty sand) are transformed from a solid to a near liquid state due to the increase in pore water pressure that can be caused by moderate to severe seismic ground shaking. In order for liquefaction to occur, the groundwater table must be close to the surface, the soil must be loosely packed, and ground shaking needs to be powerful enough to cause the soil to liquefy. The depth to groundwater in the proposed project area ranges from approximately 20 to 30 feet, increasing in depth to the east.31 Investigations by Gorian Associates, Inc. encountered groundwater approximately 30 feet beneath the surface.32 The sediment in the proposed project area is mapped as Quaternary alluvium, which includes alluvial gravel, sand, and silt-clay, derived mostly from the Santa Monica Mountains.33 Investigations by Gorian Associates, Inc. encountered alluvium beneath thin layers of fill to a depth of 9 to 12 feet.34 Although groundwater is located relatively close to the surface at the proposed project area, the proposed project area is not located within a liquefaction zone, as delineated by the California Division of Mines and Geology. A liquefaction zone is present approximately 1000 feet to the south and west of the proposed project area.35 This zone is the only liquefaction zone included in the South Area as described in the LAUSD California Environmental Quality Act Specification Manual.36 Landslides
Landslides result from unstable slopes that loose cohesion and collapse. Contributing factors to landslides include weakened bedrock, soil erosion, heavy and consistent rainfall, ground shaking from earthquake activity, and fire, as well as by human alteration of the surrounding environment. The proposed project area is not located within an Earthquake-Induced Landslide Zone, as delineated by the California Division of Mines and Geology.37 The closest Earthquake-Induced Landslide Zone is located over 2 miles away from the proposed project area. The proposed project area is located on flat land sloping to the west at approximately 0.16 degree. No landslide hazard
29 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 30 California Division of Mines and Geology. 1986. State of California Special Studies Zones, Beverly Hills Quadrangle. 1986. 31 California Division of Mines and Geology. 1998. Seismic Hazard Zone Report for the Beverly Hills 7.5-Minute Quadrangle, Los Angeles County, California. 32 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 33 Diblee, Thomas. 1991. Geologic Map of the Beverly Hills and Van Nuys (South ½) Quadrangles, Los Angeles County, California. 34 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. 35 California Division of Mines and Geology. 1999. State of California Seismic Hazard Zones, Venice Quadrangle. 36 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. 37 California Division of Mines and Geology. 1999. State of California Seismic Hazard Zones, Venice Quadrangle. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-8 Draft EIR Subchapter 3F. Geology and Soils zones exist in the South Area as described in the LAUSD California Environmental Quality Act Specification Manual.38 Soil Erosion
Erosion of earth materials is the process of wearing away and transport of materials due to concentrated water, wind, or gravitational forces. Harder, denser, and more cemented bedrock formations (usually older) will erode much less than softer, uncemented alluvium under the same forces. Erosion by water and gravity is usually more severe on steep terrain/slopes than on relatively flat ground, and in seismically active (uplifting) areas. Quaternary alluvium has a moderate to high erosion potential where exposed on slopes; however, the proposed project area is located on relatively flat, stable ground. Additionally, much of the proposed project site is developed and underlain by compacted construction fill at the near surface.39 Quaternary alluvium is present beneath the fill material. Approximately 55 percent of the proposed project site is covered by asphalt, and the remaining 45 percent is a landscaped athletic field. These hardscaped and landscaped surfaces significantly reduce the potential of soil erosion at the proposed project site. Expansive Soil
Soils that expand and contract in volume (“shrink-swell” pattern) are considered to be expansive and may cause damage to above ground structures as a result of density changes that shift overlying materials. Fine-grain clay sediments are most likely to exhibit shrink-swell patterns in response to changing moisture levels. As described above, the sediment in the proposed project area is described as Quaternary Alluvium, which primarily contains coarse gravels, sands, and silts. Although the possibility of encountering clay sediments during the proposed project exists, the majority of the mapped sediments at the proposed project area does not exhibit shrink-swell patterns and are not considered expansive soils. Additionally, the majority of soil at the near surface of the proposed project site is construction fill designed to resist shrink-swell patterns.
3F.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of five questions when addressing the potential for significant impact to geology and soils. Would the proposed project: a. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
(i) Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
(ii) Strong seismic ground shaking?
38 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. 39 Gorian Associates, Inc. 2014. Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-9 Draft EIR Subchapter 3F. Geology and Soils
(iii) Seismic-related ground failure, including liquefaction?
(iv) Landslides? b. Result in substantial soil erosion or the loss of topsoil? c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse? d. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? e. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
3F.4 IMPACT ANALYSIS
Impact 3F-a(i): Would the proposed project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault?
No Impact
The proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault. The proposed project is not located in an Alquist-Priolo Earthquake Fault Zone. The closest Alquist-Priolo Earthquake Fault Zone to the proposed project is the Newport-Inglewood fault zone, located approximately 4 miles east of the project area. Therefore, the proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault.
Impact 3F-a(ii): Would the proposed project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Strong seismic ground shaking?
No Impact
The proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking. The proposed project is not located in an Alquist-Priolo Earthquake Fault Zone. The closest Alquist-Priolo Earthquake Fault Zone to the proposed project is the Newport-Inglewood fault zone, located approximately 4 miles east of the project area. Additionally, state law requires LAUSD to investigate and minimize the risk of loss, injury, or death involving seismically related hazards prior to construction on school property. The proposed project will be in compliance with provisions of the CBC, California Administrative Code, California Educational Code, and any other additional regional, state, and federal regulations. These provisions include strict building
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-10 Draft EIR Subchapter 3F. Geology and Soils requirements for the construction of California public schools that when applied are expected to resist earthquake forces generated by major earthquakes of the intensity and severity of the strongest experienced in California without catastrophic collapse. For each new construction project, LAUSD will conduct a Seismic Hazards Assessment prior to any construction activity.40 The Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation satisfies the requirements of a Seismic Hazards Assessment, as defined in the LAUSD California Environmental Quality Act Specification Manual. The proposed project will follow the recommendations of the geotechnical evaluation, including providing 5 feet of newly compacted soils within the footprint of proposed structures, following seismic parameters detailed by the evaluation, and anticipating groundwater when drilling extends below 29 feet. Therefore, the proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking.
Impact 3F-a(iii): Would the proposed project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Seismic- related ground failure, including liquefaction?
No Impact
The proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction. The proposed project is not located in a Liquefaction Zone, as delineated by the California Division of Mines and Geology. Therefore, the proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction.
Impact 3F-a(iv): Would the proposed project expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Landslides?
No Impact
The proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. The proposed project area is not located within an Earthquake-Induced Landslide Zone, as delineated by the California Division of Mines and Geology. The closest Earthquake-Induced Landslide Zone is located over 2 miles away from the proposed project area. The proposed project area is located on flat land sloping to the west at approximately 0.16 degree. Therefore, the proposed project would not result in impacts from exposing people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving landslides.
40 LAUSD, OEHS. California Environmental Quality Act Specification Manual. Revised January 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-11 Draft EIR Subchapter 3F. Geology and Soils
Impact 3F-b: Would the proposed project result in substantial soil erosion or the loss of topsoil?
No Impact
The proposed project would not result in substantial soil erosion and loss of topsoil. Erosion by water and gravity is usually more severe on steep terrain/slopes than on relatively flat ground, and in seismically active (uplifting) areas. Although the underlying sediment at the proposed project (Quaternary Alluvium) has a moderate to high erosion potential where exposed on slopes, the proposed project area is located on flat, stable ground. Much of the proposed project area is developed and underlain by compacted construction fill at the near surface. Approximately 55 percent of the proposed project site is covered by asphalt, and the remaining 45 percent is a landscaped athletic field. These hardscaped and landscaped surfaces significantly reduce the potential of soil erosion at the proposed project site. Additionally, state law requires LAUSD to investigate and minimize the risk of loss, injury, or death involving geologically related hazards prior to construction on school property. The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. A Stormwater Pollution Prevention Plan (SWPPP) will be prepared for the proposed project that will address and prevent erosion during construction, as described in the Los Angeles Unified School District New School Construction Program Environmental Impact Report. Therefore, the proposed project would not result in substantial soil erosion and loss of topsoil.
Impact 3F-c: Would the proposed project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
No Impact
The proposed project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. The sediment at the proposed project site (Quaternary Alluvium) has the potential to be unstable. However, state law requires LAUSD to investigate and minimize the risk of loss, injury, or death involving geologically related hazards prior to construction on school property. The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. Therefore, the proposed project would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-12 Draft EIR Subchapter 3F. Geology and Soils
Impact 3F-d: Would the proposed project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property?
Less than Significant Impact
The proposed project would result in less than significant impacts to geology and soils in relation to location on expansive soil creating substantial risks to life or property. Fine-grain clay sediments are most likely to exhibit shrink-swell patterns in response to changing moisture levels. As described above, the sediment in the proposed project area is described as Quaternary Alluvium, which primarily contains coarse gravels, sands, and silts. Although the possibility of encountering clay sediments during the proposed project exists, the majority of the mapped sediments at the proposed project area does not exhibit shrink-swell patterns and are not considered expansive soils. Additionally, state law requires LAUSD to investigate and minimize the risk of loss, injury, or death involving geologically related hazards prior to construction on school property. A preliminary evaluation of the potential for soils that have shrink-swell potential and/or corrosive soils to cause damage to the facilities was conducted under the Mandarin & English Dual-Language Immersion Elementary School Project Geotechnical Evaluation. Geotechnical recommendations for expansive soils were included as part of the evaluation. The proposed project will follow the recommendations of the geotechnical evaluation. Therefore, the proposed project would result in less than significant impacts to geology and soils in relation to location on expansive soil creating substantial risks to life or property.
Impact 3F-e: Would the proposed project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact
The proposed project would not have soils that are incapable of adequately supporting the use of septic tanks or other onsite wastewater treatment systems (OWTS) or alternative wastewater disposal systems where a public sewers system is not available for the disposal of wastewater. The proposed project is located in an urban area where sewers are available for the disposal of waste water. Additionally, the soils present at the proposed project area (Quaternary alluvium) are capable of supporting the use of septic tanks or alternative waste water disposal systems, if the use of such systems is deemed necessary for the proposed project. Therefore, the proposed project would not have soils that are incapable of adequately supporting the use of septic tanks or other OWTS or alternative wastewater disposal systems where a public sewer system is not available for the disposal of wastewater.
3F.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts in relation to geology and soils. Therefore, there would be no cumulative impacts.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-13 Draft EIR Subchapter 3F. Geology and Soils
3F.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development and construction standards that are designed to protect public safety. Therefore, impacts related to geology and soils would be less than significant, and no mitigation measures are required.
3F.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3F-a(i), 3F-a(ii), 3F-a(iii), 3F-a(iv), 3F-b, 3F-c, and 3F-e: No impact.
Impact 3F-d: Less than significant impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3F-14 Draft EIR CHAPTER 3G Greenhouse Gas Emissions
This section of the EIR evaluates the potential for implementation of the proposed project to cumulatively contribute to greenhouse gas (GHG) emission impacts in the LAUSD. Because individually no one project is large enough to singlehandedly result in a significant increase in global concentrations of GHG emissions, project-related climate change impacts are inherently cumulative. The section discusses plans and policies from several jurisdictional agencies and LAUSD standard conditions, guidelines, specifications, practices, policies, and project design features (LAUSD Standards), along with the existing GHG emissions throughout the project area, and possible environmental impacts that may occur during future related projects. Definitions
Carbon Dioxide (CO2) enters the atmosphere through the burning of fossil fuels (oil, natural gas, and coal), solid waste, trees and wood products, and respiration, and as a result of other chemical reactions (e.g., manufacture of cement). Carbon dioxide is removed from the atmosphere (sequestered) when it is absorbed by plants as part of the biological carbon cycle.
Carbon Dioxide-Equivalent (CO2e). The standard unit to measure the amount of greenhouse gases in terms of the amount of CO2 that would cause the same amount of warming. CO2e is based on the GWP ratios between the various GHGs relative to CO2.
Chlorofluorocarbons (CFCs). One of a class of fluorinated gases with a high greenhouse warming potential, CFCs are greenhouse gases covered under the 1987 Montreal Protocol and used for refrigeration, air conditioning, packaging, insulation, solvents, or aerosol propellants. Since they are not destroyed in the lower atmosphere (troposphere, stratosphere), CFCs drift into the upper atmosphere where, given suitable conditions, they break down ozone. These gases are therefore being replaced by other greenhouse gas compounds covered under the Kyoto Protocol.
Climate Change. Climate change is the variation of earth’s climate over time, whether due to natural variability or as a result of human activities. Scientists have concluded that human activities are contributing to global climate change by adding large amounts of heat-trapping gases, known as greenhouse gases, to the atmosphere. The primary source of these GHGs is fossil fuel use.
Fluorinated Gases are synthetic, strong greenhouse gases that are emitted from a variety of industrial processes. Fluorinated gases are sometimes used as substitutes for ozone-depleting substances. These gases are typically emitted in smaller quantities, but they are potent greenhouse gasses, sometimes referred to as high greenhouse warming potential gases.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-1 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
Global Warming Potential (GWP). Metric used to describe how much heat a molecule of a greenhouse gas absorbs relative to a molecule of carbon dioxide (CO2) over a given period of time (20, 100, and 500 years). CO2 has a GWP of 1.
Greenhouse Gases (GHGs). GHGs are those compounds in the earth’s atmosphere that play a critical role in determining the earth’s surface temperature. Specifically, these gases allow high- frequency solar radiation to enter the earth’s atmosphere but retain the low-frequency energy, which is radiated back from the earth to space, resulting in a warming of the atmosphere. This phenomenon is known as the greenhouse effect. Increased concentrations of GHGs in the earth’s atmosphere are thought to be linked to global climate change, such as rising surface temperatures, melting icebergs and snowpack, rising sea levels, and the increasing frequency and magnitude of severe weather.
GHGs include CO2, CH4, O3, water vapor, N2O, HFCs, PFCs, and SF6. Carbon dioxide is the most abundant GHG. Other GHGs are less abundant, but have higher global warming potential than CO2. (see Table 3G-1, Greenhouse Gases and Their Relative Warming Potential Compared to CO2). Thus, emissions of other GHGs are frequently expressed in the equivalent mass of CO2, denoted as CO2e. GHGs are the result of natural and anthropogenic activities. Forest fires, decomposition, industrial processes, landfills, and consumption of fossil fuels for power generation, transportation, heating, and cooking are the primary sources of GHG emissions. According to the California Energy Commission (CEC), emissions from fossil fuel consumption represent approximately 81 percent of all GHG emissions, and transportation creates 41 percent of all GHG emissions in the United States.1
Understanding of the fundamental processes responsible for global climate change has been improved over the past decade, and the predictive capabilities are advancing. However, there remains significant scientific uncertainties, for example, in predictions of local effects of climate change; occurrence of extreme weather events; effects of aerosols; changes in clouds; shifts in the intensity and distribution of precipitation; and changes in oceanic circulation. Due to the complexity of the earth’s climate system, the uncertainty in its description and in the prediction of changes may never be completely eliminated. Because of these uncertainties, there continues to be significant debate over the extent to which increased concentrations of GHGs have caused or will cause climate change, and over the appropriate actions to limit and/or respond to climate change.
1 California Energy Commission. December 2006. Inventory of Greenhouse Gas Emissions and Sinks, 1990 to 2004. Available at: http://www.energy.ca.gov/2006publications/CEC-600-2006-013/CEC-600-2006-013-SF.PDF Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-2 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
Table 3G-1: Greenhouse Gases and Their Relative Global Warming Potential Compared to CO2
GHG Atmospheric Lifetime (years) Global Warming Potential Relative to CO2a
Carbon Dioxide (CO2) 50 to 100 1
Methane (CH4)b 12 (±3) 21 Nitrous Oxide 120 310 Hydrofluorocarbons: HFC-23 264 11,700 HFC-32 5.6 650 HFC-125 32.6 2,800 HFC-134a 14.6 1,300 HFC-143a 48.3 3,800 HFC-152a 1.5 140 HFC-227ea 36.5 2,900 HFC-236fa 209 6,300 HFC-4310mee 17.1 1,300
Perfluoromethane: CF4 50,000 6,500
Perfluoroethane: C2F6 10,000 9,200
Perfluorobutane: C4F10 2,600 7,000 Perfluoro-2-methylpentane: 3,200 7,400 C6F14
Sulfur Hexaflouride (SF6) 3,200 23,900 SOURCE: Intergovernmental Panel on Climate Change. 2001. 2001 IPCC Third Assessment Report: Climate Change 2001. U.S. Environmental Protection Agency. 2012. Greenhouse Gas Emissions. NOTE: a. Based on 100-Year Time Horizon of the Global Warming Potential (GWP) of the air pollutant relative to CO2. b. The methane GWP includes the direct effects and those indirect effects due to the production of tropospheric ozone and stratospheric water vapor. The indirect effect due to the production of CO2 is not included.
Hydrofluorocarbons (HFCs). One of a class of fluorinated gases with a high greenhouse warming potential, HFCs contain only hydrogen, fluorine, and carbon atoms. They were introduced as alternatives to ozone-depleting substances to serve many industrial, commercial, and personal needs. HFCs are emitted as by-products of industrial processes and are also used in manufacturing. They do not significantly deplete the stratospheric ozone layer, but they are strong GHGs.2
Hydrochlorofluorocarbons (HCFCs). One of a class of fluorinated gases with a high greenhouse warming potential, HCFCs contain hydrogen, fluorine, chlorine, and carbon atoms. Although ozone-depleting substances, they are less potent at destroying stratospheric ozone than CFCs. They have been introduced as temporary replacements for CFCs and are greenhouse gases.
2 See http://www.epa.gov/climatechange/ghgemissions/gases.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-3 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
Methane (CH4) is emitted during the production and transport of coal, natural gas, and oil. Methane emissions also result from livestock and other agricultural practices and from the decay of organic waste in municipal landfills and water treatment facilities.
MTCO2e. Metric ton of CO2e.
MMTCO2e. Million metric tons of CO2e.
Nitrous oxide (N2O) is emitted during agricultural and industrial activities as well as during combustion of fossil fuels and solid waste.
Sulfur Hexafluoride (SF6). One of a class of fluorinated gases with a high greenhouse warming potential, SF6 is a colorless gas soluble in alcohol and ether; slightly soluble in water. SF6 is a strong greenhouse gas used primarily in electrical transmission and distribution systems as an insulator.
Perfluorocarbons (PFCs). One of a class of fluorinated gases with a high greenhouse warming potential, PFCs are a group of human-made chemicals composed of carbon and fluorine only. These chemicals (predominantly perfluoromethane [CF4] and perfluoroethane [C2F6]) were introduced as alternatives, along with HFCs, to the ozone-depleting substances. In addition, PFCs are emitted as by-products of industrial processes and are also used in manufacturing. PFCs do not harm the stratospheric ozone layer, but they have a high global warming potential.
South Coast Air Quality Management District (SCAQMD). Air districts have primary authority under state law for “control of air pollution from all sources, other than emissions from motor vehicles” (H&SC §40000). Greenhouse gases and other global warming pollutants such as black carbon would certainly be included in this definition. The U.S. Supreme Court held in Massachusetts v. EPA, 549 U.S. 497 (2009) that greenhouse gases were clearly within the Federal Clean Air Act’s broad definition of air pollutants. Therefore, air districts have the authority to regulate global warming pollutants primarily from non-vehicular sources, while pursuant to AB 32 CARB has authority over a wide range of sources, including vehicular sources. The SCAQMD has authority to adopt standards on which to evaluate the impacts of greenhouse gas emissions pursuant to the CEQA Guidelines.
3G.1 REGULATORY FRAMEWORK Federal
Clean Air Act and Mandatory Reporting of GHG Rule
The U.S. Environmental Protection Agency (EPA) announced on December 7, 2009, that GHG emissions threaten the public health and welfare of the American people and that GHG emission from on-road vehicles contribute to that threat. The EPA’s final findings respond to the 2007 U.S. Supreme Court decision that GHG emissions fit within the Clean Air Act definition of air pollutants. The findings do not in and of themselves impose any emission reduction requirements,
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-4 Draft EIR Subchapter 3G. Greenhouse Gas Emissions but allow the EPA to finalize the GHG standards proposed in 2009 for new light-duty vehicles as part of the joint rulemaking with the Department of Transportation.3
The EPA’s endangerment finding covers emissions of six key GHGs—CO2, CH4, N2O, hydrofluorocarbons, perfluorocarbons, and SF6—which have been the subject of scrutiny and intense analysis for decades by scientists in the United States and around the world.
In response to the endangerment finding, the EPA issued the Mandatory Reporting of GHG Rule that requires substantial emitters of GHG emissions (large stationary sources, etc.) to report GHG emissions data. Facilities that emit 25,000 MTCO2e or more per year are required to submit an annual report. State
Executive Order S-03-05
Executive Order S-3-05, which was signed by Governor Schwarzenegger on June 1, 2005, establishes statewide climate change emission reduction targets to reduce CO2e to the 2000 level (473 million metric tons) by 2010, to the 1990 level (427 million metric tons of CO2e) by 2020, and to 80 percent below the 1990 level (85 million metric tons of CO2e) by 2050 (Table 3G.1-1, California Business-as-Usual GHG Emissions and Targets).4,5 The executive order directs the California EPA Secretary to coordinate and oversee efforts from multiple agencies to reduce GHG emissions to achieve the target levels. To further ensure accomplishment of the targets, the California EPA Secretary created a Climate Action Team composed of representatives from the aforementioned agencies to implement global warming emission reduction programs and report on the progress made toward meeting the statewide GHG targets established in this executive order.
Table 3G.1-1: California Business-as-Usual Emissions and Targets
GHG Emissions (Million Metric Tons of CO2Equivalent) Emission Level 1990 2000 2010 2020 2050 Business-as-usual Emissions 427 473 532 596 762* Target Emissions — — 473 427 85 NOTE: * Business-as-usual emissions reflect the projected emissions under a scenario without GHG control measures, where California would continue to emit GHGs at the same per capita rate. The CARB has not yet projected 2050 emissions under a business-as-usual scenario. Therefore, 2050 business-as-usual emissions were calculated assuming a linear increase of emissions from 1990 to 2050.
3 U.S. Environmental Protection Agency. December 2009. EPA: Greenhouse Gases Threaten Public Health and the Environment. Science overwhelmingly shows greenhouse gas concentrations at unprecedented levels due to human activity. Available at: http://yosemite.epa.gov/opa/admpress.nsf/0/08D11A451131BCA585257685005BF252. 4 California Governor. 1 June 2005. Executive Order S-3-05. Sacramento, CA. 5 California Climate Action Team. 3 April 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. Sacramento, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-5 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
Assembly Bill 32, the Global Warming Solutions Act (2006)
Current State of California guidance and goals for reductions in GHG emissions are generally embodied in AB 32, the Global Warming Solutions Act. AB 32 was passed by the California state legislature on August 31, 2006, to place the state on a course toward reducing its contribution of GHG emissions. AB 32 follows the 2020 tier of emissions reduction targets established in Executive Order S-3-05.
AB 32 directed the California Air Resources Board (CARB) to adopt discrete early action measures to reduce GHG emissions and outline additional reduction measures to meet the 2020 target. Based on the GHG emissions inventory conducted for the Scoping Plan by CARB, GHG emissions in California by 2020 are anticipated to be approximately 596 MMTCO2e. In December 2007,
CARB approved a 2020 emissions limit of 427 MMTCO2e (471 million tons) for the state. The
2020 target requires a total emissions reduction of 169 MMTCO2e, 28.5 percent from the projected emissions of the business-as-usual scenario for the year 2020 (i.e., 28.5 percent of 596 6 MMTCO2e).
In order to effectively implement the emissions cap, AB 32 directed CARB to establish a mandatory reporting system to track and monitor GHG emissions levels for large stationary sources that generate more than 25,000 MT of CO2e per year, prepare a plan demonstrating how the 2020 deadline can be met, and develop appropriate regulations and programs to implement the plan by 2012. The Climate Action Registry Reporting Online Tool was established through the Climate Action Registry to track GHG emissions.
California Code of Regulations, Title 24, Part 6
Energy conservation standards for new residential and nonresidential buildings were adopted by the California Energy Resources Conservation and Development Commission in June 1977 and are updated tri- annually in the California Building Code. Title 24, Part 6 requires the design of building shells and building components to conserve energy. The standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods.
On May 31, 2012, the California Energy Commission adopted the 2013 Building Energy Efficiency Standards, which went into effect on January 1, 2014. Buildings that are constructed in accordance with the 2013 Building and Energy Efficiency Standards are 25 percent (residential) to 30 percent (nonresidential) more energy efficient than the 2008 standards as a result of better windows, insulation, lighting, ventilation systems, and other features that reduce energy consumption in homes and businesses. Local
High Performance School (CHPS) Requirement
In 2009, the LAUSD Board of Education adopted the California Criteria for High Performance Schools Best Practices Manual, Volume III, which requires all new schools and new occupiable
6 California Air Resources Board. October 2008 October. Climate Change Proposed Scoping Plan, a Framework for Change. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-6 Draft EIR Subchapter 3G. Greenhouse Gas Emissions and conditioned buildings on existing campuses within the District to qualify as a CHPS project.7,8 The CHPS Criteria and CHPS Verified Program, which were established to measure performance, includes eight potential Climate points recommended by LAUSD in the 2014 School Design Guide to address GHG emission reduction through climate change action, grid neutral, or zero net energy performance.9
3G.2 EXISTING CONDITIONS California per Capita Greenhouse Gas Emissions
California is the second largest emitter of GHG in the United States, only surpassed by Texas, and the tenth largest GHG emitter in the world. However, California also has over 12 million more people than the state of Texas. Because of more stringent air emission regulations, in 2001
California ranked fourth lowest in carbon emissions per capita and fifth lowest among states in CO2 emissions from fossil fuel consumption per unit of Gross State Product (total economic output of goods and services).
CARB’s latest update to the statewide GHG emissions inventory was conducted in 2014 for year
2012 emissions. In 2012, California produced 458.7 MMTCO2e GHG emissions. California’s transportation sector is the single largest generator of GHG emissions, producing 36.0 percent of the state’s total emissions. Electricity consumption is the second largest source, comprising 22.7 percent. Industrial activities are California’s third largest source of GHG emissions, comprising 17.8 percent of the state’s total emissions. Other major sources of GHG emissions include commercial and residential, recycling and waste, high global warming potential GHGs, agriculture, and forestry.10 High Performance Schools (CHPS) Requirement
The CA-CHPS Criteria is a flexible yardstick that precisely defines a high performance school in California. CA-CHPS addresses integration, indoor environmental quality, energy, water, site, materials & waste management, and operations & metrics. The LAUSD has adopted the Criteria for their new and existing schools.
7 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/documents/download/asset_management/school_design_guide/School_Design_Guide _Jan_2014.pdf?version_id=310708755 Chapter 2.4: Environment and Sustainability. 8 Collaborative for High Performance Schools. 2009. California Criteria for High Performance Schools Best Practices Manual. Volume III. 2009 Edition. Available at: http://www.chps.net/manual/index.htm 9 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/documents/download/asset_management/school_design_guide/School_Design_Guide _Jan_2014.pdf?version_id=310708755 Chapter 2.4: Environment and Sustainability. 10 See http://www.arb.ca.gov/cc/inventory/data/misc/ghg_inventory_trends_00-12_2014-05-13.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-7 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
3G.3 THRESHOLDS OF SIGNIFICANCE
According to Section 15064.4 of the State CEQA Guidelines, a lead agency should consider the following factors, among others, when assessing the significance of impacts from GHG emissions on the environment:11
(1) The extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting;
(2) Whether a project emissions exceed a threshold of significance that the lead agency determines applies to the project;
EPA Mandatory Reporting of GHG Rule that requires substantial emitters of GHG emissions (large stationary sources, etc.) to report GHG emissions data applies to
facilities that emit 25,000 MTCO2e per year.
3000 metric tons CO2e/year is the recommended threshold of significant by SCAQMD.
(3) The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
The potential for the proposed project to result in impacts related to GHG emissions was analyzed in relation to the questions outlined in Appendix G of the State CEQA Guidelines. Would the proposed project: a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? b. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
3G.4 IMPACT ANALYSIS
This chapter summarizes the CalEEMod analysis in relation to the CEQA guidelines. The analysis includes estimates to short-term and long-term impacts regarding greenhouse gas emissions related to the proposed project. Project parameters as outlined in the project description were used as inputs into the CalEEMod simulation. The construction phases were estimated based on the proposed start and end dates of the construction. Defaults were used for the cases in which the proposed project has no specific parameters. The SCAQMD recommends that construction GHG emissions be amortized over a 30-year project lifetime and included in the long-term operational GHG emissions. This analysis is based on the results of the CalEEMod Emissions modeling (Appendix E, CalEEMod Model for LAUSD Mandarin and English Dual-Language Immersion School). The GHG emissions associated with the proposed project can be separated into construction-related short-term impacts and operation-related long-term, permanent impacts. Both types of impacts may occur on a local or regional scale.
11 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15064.4. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-8 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
Impact 3G-a: Would the proposed project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact
The project site is within the jurisdiction of the SCAQMD, which is the governing authority for air quality planning in the region. The SCAQMD CEQA Guidelines are intended to meet the requirements of Assembly Bill 32 (AB 32), which are the basis for controlling and reducing GHG emissions in California. The analysis completed using the CalEEMod modeling software estimates the total GHG emissions from the project construction to be 408 metric tons per year, or 0.720 per capita (based on number of students). The total GHG emissions from the operation of the proposed project are estimated to be 342 metric tons per year or 0.603 per capita (based on number of students). The estimated GHG emissions are below the EPA standard for requiring reporting, and the estimated GHG emissions are also below the SCAQMD threshold of 3000 metric tons CO2e/year. Therefore, there would be less than significant impacts regarding greenhouse gas emissions resulting from the proposed project.
Construction. The analysis completed using the CalEEMod modeling software estimates the total GHG emissions from construction are 408 metric tons per year. The estimated GHG emissions are below the EPA standard for requiring reporting. The estimated GHG emissions during construction are also below the SCAQMD threshold of 3000 metric tons CO2e/year. Therefore, there are no violations of applicable standards and no significant impacts.
Operation. The analysis completed using the CalEEMod modeling software estimates the total GHG emissions from operations would be 342 metric tons per year. The estimated GHG emissions are below the EPA standard for requiring reporting. The estimated annual GHG emissions during operation of the Mandarin and English Dual-Language Immersion School are also below the SCAQMD threshold of 3,000 metric tons CO2e/year. Therefore, there are no violations of applicable standards and no significant impacts.
Impact 3G-b: Would the proposed project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
No Impact
As the net emissions associated with the proposed project would be well below the SCAQMD thresholds, the proposed project would not conflict with plans, policies, or regulations for reducing GHG emissions. In addition, the proposed project would be required to be construction-consistent with the LAUSD CHPS. Through compliance with the LAUSD CHPS Requirement, the proposed Mandarin and English Dual-Language Immersion School would be expected to reduce per capita GHG emissions below the already less than significant emissions estimated using the CalEEMod analysis.
3G.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to greenhouse gas emissions. Therefore, there would be no cumulative impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-9 Draft EIR Subchapter 3G. Greenhouse Gas Emissions
3G.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the Federal Clean Air Act, AB 32, the California High Performance School standards, and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development and construction standards that are designed to protect public safety. Therefore, impacts related to greenhouse gases would be less than significant, and no mitigation measures are required.
3G.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact 3G-a: Less than significant impact.
Impact 3G-b: No impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3G-10 Draft EIR SUBCHAPTER 3H Hazards and Hazardous Materials
This analysis is undertaken to determine if the proposed project may have a significant impact related to hazards and hazardous materials, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The analysis is based on findings incorporated in the technical report by Parsons, Phase I Environmental Site Assessment (ESA), Mark Twain Middle School, Los Angeles Unified School District, dated July 2014 (Appendix F to the EIR), and the Phase I ESA Addendum by Parsons, dated August 2014 (Appendix G to the EIR). This analysis was undertaken to identify opportunities to avoid, reduce, or otherwise mitigate potential significant impacts related to hazards and hazardous materials and to identify potential alternatives.
The analysis considers two types of potential risks: (1) risks that construction and operation of the proposed project could pose to the surrounding community and (2) risks to students, faculty, and other LAUSD staff at the proposed project from on-site and off-site sources of hazards and hazardous materials.
Hazardous materials can threaten human health and/or the environment through routine emissions and/or accidental releases. Hazardous materials include materials that are toxic, corrosive, flammable, reactive, irritating, and strongly sensitizing. The term “hazardous materials” as used in this section is defined to include all materials defined as hazardous under California Health & Safety Code §25501(o).2 The term includes chemicals regulated by the Department of Transportation (DOT), the U.S. Environmental Protection Agency (U.S. EPA), the Department of Toxic Substances Control (DTSC), the California Governor’s Office of Emergency Services, and other agencies as hazardous materials, wastes, or substances. Hazardous wastes require special handling and disposal because of their potential to impact public health and the environment. Some materials are designated “acutely” or “extremely” hazardous under relevant statutes and regulations.
Federal, state, and local laws regulate the use and management of hazardous materials in order to protect human health and the environment. In particular, CEQA contains special provisions
1 California Code of Regulations. Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 The term “hazardous material” is defined in the California Health and Safety Code [CHSC Section 25501(o)] as: any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. A “hazardous waste” is any hazardous material that is abandoned, discarded, or recycled (CHSC Section 25124). Because of their quantity, concentration, or physical, chemical, or infectious characteristics, hazardous wastes may either cause, or significantly contribute to an increase in mortality or an increase in serious illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed, or otherwise managed [CHSC Section 25117, and CCR, Title 22, Section 66261.2]. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-1 Draft EIR Subchapter 3H. Hazards and Hazardous Materials designed to protect students and LAUSD school employees from exposure to hazardous materials. The potential for the proposed project to result in impacts to health and the environment was evaluated in light of the Phase I ESA and Phase I ESA Addendum of the proposed project site3,4 and relevant environmental regulatory databases.5
3H.1 REGULATORY FRAMEWORK
Hazardous materials and waste can pose a significant actual or potential risk or hazard to human health and the environment when improperly treated, stored, transported, disposed of, or otherwise managed. The proposed project was evaluated in light of federal, state, and local statutes and regulations that are intended to minimize the exposure of people and property to risk or hazards resulting from the use, storage, and transportation of hazardous materials and hazardous waste. Federal, State, and local statutes related to emergency response, and proximity to potentially hazardous conditions related to site planning were also taken into consideration. Federal
Toxic Substances Control Act of 1976
The Toxic Substances Control Act (TSCA) of 1976 was enacted by Congress to give the EPA the ability to track the 75,000 industrial chemicals currently produced or imported into the United States. The EPA repeatedly screens these chemicals and can require reporting or testing of any that may pose an environmental or human health hazard. It can ban the manufacture and import of chemicals that pose an unreasonable risk. Also, the EPA has mechanisms in place to track the thousands of new chemicals that industry develops each year with either unknown or dangerous characteristics. It then can control these chemicals as necessary to protect human health and the environment. The act supplements other federal statutes, including the Clean Air Act and the Toxic Release Inventory (TRI) under the Emergency Planning and Community Right-to-Know Act (EPCRA). Legislation can be found in the United States Code (USC), Title 15, Sections 2601 et seq.
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, also known as the Superfund Act, outlines the potential liability related to the cleanup of hazardous substances, available defenses to such liability, appropriate inquiry into site status under Superfund, which is the federal government's program to clean up the nation's uncontrolled hazardous waste sites, statutory definitions of hazardous substances and petroleum products, and the petroleum product exclusion under CERCLA.6
3 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 4 Parsons. August 21, 2014. Phase I Environmental Site Assessment Addendum: Future Mandarin Dual-Language Immersion School Site at the Mark Twain Middle School, 2224 Walgrove Avenue, Los Angeles, California 90066. 5 California Environmental Protection Agency. Department of Toxic Substances Control. Envirostor Database. Available at: http://www.envirostor.dtsc.ca.gov/public/ 6 United States Code, Title 42, Chapter 103, Subchapter I: “Hazardous Substances Releases, Liability, Compensation.” Available at: http://www.law.cornell.edu/uscode/html/uscode42/usc_sup_01_42_10_103.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-2 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Superfund Amendment and Reauthorization Act, Title III
The Superfund Amendment and Reauthorization Act (SARA), Title III of 1986 is the EPCRA.7 Facilities are required to report the following items on U.S. EPA Form R, the Toxic Chemical Release Inventory Reporting Form: facility identification, off-site locations where toxic chemicals are transferred in wastes, chemical-specific information, and supplemental information.
Form R requires a facility to list the hazardous substances that are handled on-site and to account for the total aggregate releases of listed toxic chemicals for the calendar year. Releases to the environment include emissions to the air, discharges to surface water, and on-site releases to land and underground injection wells.
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) of 1976 was the first major federal act regulating the potential health and environmental problems associated with hazardous and non- hazardous solid waste.8 RCRA and the implementation regulations developed by the U.S. EPA provide the general framework for the national hazardous and non-hazardous waste management systems. This framework includes the determination of whether hazardous wastes are being generated, techniques for tracking wastes to eventual disposal, and the design and permitting of hazardous waste management facilities.
RCRA amendments enacted in 1984 and 1986 began the process of eliminating land disposal as the principal hazardous waste disposal method. Hazardous waste regulations promulgated in 1991 address site selection, design, construction, operation, monitoring, corrective action, and closure of disposal facilities. Additional regulations addressing solid waste issues are contained in 40 Code of Federal Regulations (CFR), Part 258. State
Hazardous Waste and Substances Sites (Cortese) List (Government Code Section 65962.5
The Cortese List is a planning document used by the state and local agencies and developers to comply with CEQA requirements in disclosing information about the location of hazardous materials release sites. Government Code Section 65962.5 requires the California EPA to update the Cortese List at least annually. DTSC is responsible for a portion of the information contained in the Cortese List. Other state and local government agencies are required to provide additional hazardous material release information for the Cortese List.
7 United States Code, Title 42, Chapter 116 et. seq: “Emergency Planning and Community Right-to-Know Act.” Available at: http://www.law.cornell.edu/uscode/html/uscode42/usc_sup_01_42_10_116.html 8 United States Code, Title 42, Chapter 82, Subchapter I, §§ 6901 et. seq.: “Solid Waste Disposal Act, Resource Conservation and Recovery Act of 1986.” Available at: http://www.law.cornell.edu/uscode/html/uscode42/usc_sup_01_42_10_82.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-3 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Hazardous Waste Control Law of 1972
The Hazardous Waste Control Law of 1972 is the original hazardous waste control law in California. This law initiated programs that track hazardous waste generators, their hazardous waste streams, and their hazardous waste handling practices.
Title 22 and Title 23 of the California Code of Regulations
In California, Titles 22 and 23 of the California Code of Regulations (CCR) address hazardous materials and wastes. Title 22 defines, categorizes, and lists hazardous materials and wastes. Title 23 identifies public health and safety issues related to hazardous materials and wastes, and specifies disposal options.
Hazardous Materials Release Response Plans and Inventory Law of 1986
The Hazardous Materials Release Response Plans and Inventory Law of 1986 (Business Plan Act)9 governs hazardous materials handling, reporting requirements, and local agency surveillance programs.
CEQA Statute, PRC §21151.8; 14 CCR §15186[c], [d]
CEQA contains special requirements that apply to school site acquisition and construction projects (Public Resources Code [PRC] §21151.8; 14 CCR §15186[c],[d]). These sections require school districts to carefully consider potential risks to students, faculty, and other school district employees that may be posed by on-site and off-site sources of hazardous materials. In addition, new school acquisition and construction projects that receive funds from the State of California must undergo a specific hazardous materials review process under the direction of the DTSC. Projects exempt from CEQA, and those that do not involve state funds, do not require DTSC oversight. In those cases, the LAUSD OEHS oversees the environmental review of proposed acquisition and construction projects.
CEQA Statute, PRC §21092.6; Government Code §65962.5 (Lists Relating to Hazardous Waste)
Section 65962.5 of the Government Code requires the California EPA to compile, maintain, and update specified lists of hazardous material release sites. CEQA requires each lead agency to consult the lists compiled pursuant to Government Code§65962.5 to determine whether the project and any alternatives are identified on any of the lists. For each project subject to CEQA, the district reviews the §65962.5 list and other relevant records.
CEQA Statute, PRC §21151.8 (School Sites and Hazardous Materials)
CEQA prohibits lead agencies from approving environmental documents for any project involving the purchase of a school site or the construction of a new elementary or secondary school unless the following conditions occur:
9 California Health and Safety Code, Chapter 6.8, §25500 et seq. (1985, as amended). Available at: http://www.aroundthecapitol.com/code/code.html?sec=hsc&codesection=25404-25404.9 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-4 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
The Environmental Impact Report (EIR) identifies whether the property to be purchased or to be constructed upon is a current or former hazardous waste site or a site that contains underground or aboveground pipelines carrying hazardous substances. The lead agency notifies in writing and consults with the administrative agency in which the school site is located, and with the local air pollution control district, to identify facilities within 0.25 mile of the school site that might reasonably be anticipated to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste.
If facilities within a 0.25-mile radius of the proposed site that might reasonably be anticipated to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste are identified, the school district governing board must make one of the following findings:
. The health risks from the identified facilities do not and will not constitute an actual or potential endangerment of public health to persons who attend or are employed at the school; or
. Corrective measures required under order by another agency having jurisdiction over the facilities will, before the school is occupied, result in the mitigation of all chronic or accidental air emissions to levels that do not constitute an actual or potential endangerment of public health to persons who would attend or be employed at the proposed school. If this finding is made, the Board shall make a subsequent finding, prior to occupancy at the school, that the emissions have been so mitigated.
Senate Bill (SB) No. 352 amended this section to include large freeways, busy traffic corridors, large agricultural operations, and rail yards within the list of facilities that might reasonably be anticipated to emit hazardous emissions. Under SB 352, school districts must perform a health risk assessment if a proposed school site is within 500 feet of a freeway or other busy traffic corridor, and either (1) find that air emissions from the freeway pose no significant short-term or long-term health risk to pupils, or (2) adopt a Statement of Overriding Considerations on the grounds that the district is unable to locate an alternative site that is suitable due to a severe shortage of sites that meet the requirements of Education Code §17213(a).
CEQA Guidelines, §15186 (School Facilities)
CEQA Guidelines §15186 restates the requirements of PRC §21151.8. Local
Los Angeles Unified School District Standards
OEHS has developed numerous practices, procedures, and standard conditions related to hazards and hazardous materials, including the following:
Site Hazards. Procedures are in place for OEHS to evaluate the presence of potentially toxic or hazardous conditions on or in the vicinity of a proposed or existing LAUSD facility. If necessary, a site screening is conducted to determine the proximity of the project site to any rail lines, pipelines, oil fields, methane zones, methane buffer zones, freeways, landfills, industrial facilities, and high voltage power lines. The findings are documented in Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-5 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
the OEHS Site Environmental Review and may involve preparation of supporting technical studies such as an air quality health risk assessment, pipeline safety hazard assessment, rail safety study, electromagnetic field exposure management plan, geohazard report, tank safety study, or methane assessment. OEHS is also actively involved in identifying potential environmental hazards in proximity to schools pursuant to the LAUSD’s Safe School Plans (SSPs) ram. Finally, OEHS has procedures in place to identify and evaluate existing high risk facilities and new offsite projects that may impact a school within one-quarter mile. Applicable LAUSD guidance includes:
. LAUSD-OEHS Safety Alert No. 03-02: Procedures – Responding to Toxic Air Emissions, February 2003
. LAUSD Board Resolution: Siting of New Schools Near Industrial Facilities, February 22, 2005
. LAUSD-OEHS Memorandum: Industrial Facilities in Proximity to Schools, MEM-1611, March 4, 2005
. LAUSD-OEHS User Manual Pipeline Safety Hazard Assessment, October 2008
. LAUSD-OEHS Reference Guide: Environmental Hazards in Proximity to Schools, REF- 5892.0, October 8, 2012
. LAUSD-OEHS Procedures: Review of Non-District Projects to Determine Impact on Schools, undated draft
3H.2 EXISTING CONDITIONS
A Phase I ESA investigation was prepared in July 2014 to identify potential Recognized Environmental Conditions (RECs) at 2224 Walgrove Avenue, Los Angeles CA 90066 (Appendix F).10 Routine Transport, Storage, Use, or Disposal of Hazardous Materials
The Proposed Development Area is considered the site for the purposes of this analysis (see Figure 2.2.2-3, Aerial Photograph). Off-site locations are those within the Mark Twain Middle School campus but outside of the proposed project area, and off-campus locations are those outside the entire campus. The entire Mark Twain Middle School campus, including the proposed project site, was investigated to determine potential issues for the site. No known environmental issues have been identified at the proposed project site. However, several potential, controlled, or historical RECs have been identified at off-site locations.11 These RECs consist of:
Paint storage areas
Former fuel storage bunker
10 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 11 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-6 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Boiler room
Former boiler room
Soap and cleaner storage areas
Former incinerator yard
Electric feed and transformer
Fuel storage room
Waste incinerator stack
The Mark Twain Middle School campus does not store or use any kind of herbicide or pesticide for weed or pest management, in accordance with a Submittal of Consolidated Contingency Plan for Twain Middle School.12 Cleaning materials, paints for touching up areas of the school buildings, and gasoline fuel for landscape equipment are present in de minimis (less than significant) quantities at several locations around the school property, which are stored in locked rooms and locked metal sheds. There are no chemicals associated with chemistry classes currently at the Mark Twain Middle School campus. Release of Hazardous Materials into the Environment
The purpose of the Phase I ESA investigation was to identify the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment. The proposed project site has been utilized for agricultural operation and began construction in the late 1940s. Due to the historical use of the Mark Twin Middle School campus and proposed project improvement area, the site contains a potential for lead-based paint residues and termiticides associated with former school buildings on the southwestern portion of the existing campus and buildings near the project site, a potential presence of pesticides associated with areas of the campus that were former agricultural use (1928 to 1947), and a potential presence of arsenic underneath the pavement that may have been applied as a herbicide due to former LAUSD standard practice.
Furthermore, records reviewed by Parsons at the City of Los Angeles Fire Department indicate one abandoned 5,000 gallon diesel Underground Storage Tank (UST) located outside the former boiler room that was part of the Science Building (Building 5) on the southwestern portion of the Mark Twain Middle School Campus, one boiler/process heater in a boiler room adjacent to the gymnasium (Building 1) to the south of the proposed project site, and one permitted small bypass feeder Aboveground Storage Tank (AST), as well as cleaning chemicals and gasoline stored for the school playground sweeper and lawn mowers and edgers in minimal quantities (see Appendix G).
12 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Section 4.3.9 City and County of Los Angeles Fire Department Hazardous Materials Records. Page 31. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-7 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Pursuant to the July 2014 Phase I ESA On-Site Recommendations,13 the August 2014 Phase I ESA Addendum was prepared by Parsons to document the results of surface and shallow soil sampling and analyses (see Appendix G).14 A total of 57 boring locations were sampled at preselected depths, 2 on the existing grass playfield and 55 on the asphalt-paved existing playground. The soil sampling and analyses produced the following results:
Lead. Seventy primary soil samples and six duplicated soil samples were collected for lead analysis by EPA Method 6010. The maximum detected concentration of lead in soil was 24 milligrams per kilogram (mg/kg); no soil sample exceeded the California Human Health Screening Level (CHHSL) of 80 mg/kg for lead.
Arsenic. Thirty-two primary surface soil samples and three duplicate soil samples were collected for arsenic analysis by EPA Method 6010. Two of the 32 primary soil samples collected contained detections exceeding the DTSC upper-bound background screening level of 12 mg/kg. These two samples had an arsenic concentration of 13 mg/kg and were collected at sample locations A9 and B6. As a result of the soil sampling and analysis, it was determined that the generally low arsenic concentrations that were detected, which appear to be naturally occurring, should be deemed acceptable and do not necessitate remediation or any further action.
Title 22 Metals. Nine primary soil samples were collected from three borings for Title 22 Metals analysis by EPA Method 6010 in the “incinerator yard” samples adjacent to the former incinerator yard. Low levels of barium, beryllium, chromium, cobalt, copper, mercury, nickel, vanadium, and zinc were detected; however, none of the constituents detected exceeded their respective Regional Screening Levels (RSLs) provided by the Office of Environmental Hazard Association. No other Title 22 Metals were detected in soil samples from this investigation.
OCPs. Eighteen primary soil samples and one duplicate soil sample were collected from three borings and analyzed for organochlorine pesticides (OCPs) by EPA Method 8081. The maximum results indicate that 6.0 micrograms per kilogram (μg/kg) alpha-clordane was detected (well below the screening value of 105 μg/kg), 5.9 μg/kg gamma-chlordane was detected (well below the screening value of 105 μg/kg), 95 μg/kg 4,4-DDE was detected (well below the screening value of 400 μg/kg), and 17 μg/kg 4,4 DDT was detected (well below the screening value of 400 μg/kg).
Agricultural Pesticides. Eight primary soil samples and one duplicate were collected and analyzed from four borings for agricultural pesticides by EPA Method 8081. No agricultural pesticides were detected above their respective laboratory method detection limits in any soil samples at the proposed project site, and are not considered constituents of concern.
13 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 14 Parsons. August 21, 2014. Phase I Environmental Site Assessment Addendum: Future Mandarin Dual-Language Immersion School Site at the Mark Twain Middle School, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-8 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Dioxins/Furans. Soil samples were collected at three locations in the vicinity of the former “incinerator yard” for dioxins/furans analysis using EPA Method 8290. The total dioxin/furan concentration detected was 0.16 to 1.2 picograms per gram – dry weight (pg/g-dw), well below the DTSC residential cleanup goal of 50 pg/g-dw and the residential RSL of 4.9 pg/g-dw.
PCBs. Soil samples were collected at three locations in the vicinity of the former “incinerator yard” for polychlorinated biphynels (PCBs) using EPA Method 8082. No PCBs were detected.
SVOCs. Soil samples were collected at three locations in the vicinity of the former “incinerator yard” for semivolatile organic compounds (SVOCs) using EPA Method 8270. No SVOCs were detected.
Total Recoverable Hydrocarbons. Three soil samples were collected from three borings for total recoverable petroleum hydrocarbons (TRPH); a maximum concentration of 220 mg/kg SGT-HEM was detected. Total Petroleum Hydrocarbons (TPH) in the gasoline and light hydrocarbon range (C4-C12) was not reported above the laboratory method detection limit in the three soil samples. TPH in the diesel range (C13-C22) were detected above the laboratory method detection limit in two of the three samples, at concentrations of 5.7 mg/kg and 5.1 mg/kg. TPH in the oil range 9C23-C32) was detected in the three soil samples, with concentrations ranging from 3.5 mg/kg to 51 mg/kg. TRPH and TPH results are deemed to be acceptable and do not necessitate remediation or any further action.
Based on the soil analytical data presented in the Phase I ESA Addendum, the proposed project area is not adversely impacted by chemicals of potential concern.
Due to the age of the former use on the project site, pesticides from the use of termiticides or pesticides to control pests may be present in shallow on-site soils. Other potential hazardous materials at the project site include, as determined by the Environmental Data Resources (EDR) report, radon and asbestos.15 However, the proposed project was identified as located within a U.S. EPA Radon Zone 2 area, which is characterized as having low indoor air radon levels between 2 and 4 picocuries per liter (pCi/L). U.S. EPA further characterizes Radon Zone 2 areas as a moderate potential for elevated indoor radon levels; indoor radon concentrations less than 4 pCi/L are considered safe for building occupancy.
A second purpose of the Phase I ESA investigation was to acquire information regarding safety issues that may be of specific interest to the LAUSD, including geologic hazards and the proximity of the Site to potentially hazardous activities (e.g., fuel pipelines, airports, railroads, high voltage power transmission lines, major roadways, etc.).16 The Mark Twain Middle School campus is not located within an earthquake fault zone area or fault rupture study area, within a known methane zone or oil field, is located approximately 1,000 feet northwest of the nearest high-pressure distribution gas line, is located over 1 mile southwest of the nearest natural gas transmission line, is
15 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 16 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-9 Draft EIR Subchapter 3H. Hazards and Hazardous Materials located approximately 800 feet northeast of a 10-inch oil line below Walgrove Avenue, and is adjacent to a private sewer line below Walgrove Avenue. There are no known adverse air quality health risks related to major transportation corridors, or a major stationary source of emissions, within 500 feet of the Mark Twain Middle School campus. Sources of Hazardous Emissions or Known Handling of Hazardous or Acutely Hazardous Material within One-Quarter Mile of Mark Twain Middle School
Within one-quarter mile of the proposed project site, there are several properties with the potential to handle hazardous materials (Table 3H.2-1, Properties within One-Quarter Mile with the Potential to Handle Hazardous Materials).
Table 3H.2-1 Properties within One-Quarter Mile with the Potential to Handle Hazardous Materials Approximate Distance to Potentially Hazardous Site Name Site Address Proposed Project Site Material 0.0 miles, surrounding proposed Asbestos containing material LAUSD Mark Twain 2224 Walgrove Ave project site to the west and (ACM), and inorganic solid Middle School Los Angeles, CA 90066 south sides waste Beethoven Elementary 3711 Beethoven St 0.0 miles, adjacent to northeast Lead School Los Angeles, CA 90066 side of proposed project site 13059 Venice Blvd 767 feet east-southeast of the Azteca Carpet Cleaners No information Los Angeles, CA 90066 proposed project site LAUSD Venice High 12912 Venice Blvd 0.159 miles east southeast of Lead School Los Angeles, CA 90066 the proposed project site Benzene, tetrachloroethylene, 12912 Venice Blvd 0.184 miles east of proposed Apple Shirt tricholorethylene, unspecified Los Angeles, CA 90066 project site solvent mixture Ranar Manufacturing 12820 Venice Blvd 0.215 miles east of proposed No information Company Los Angeles, CA 90066 project site 12818 Venice Blvd 0.216 miles northwest of One Happy Cleaners No information Venice, CA 90066 proposed project site 1401 Venice Blvd 0.234 miles south southwest of Gasoline and oil service Beedle 0 W Venice, CA 90066 proposed project site stations 3756 May Street 0.248 miles east northeast of Conway Auto Group No information Los Angeles, CA 90066 proposed project site SOURCE: Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066.
On-Site or Off-Site Sources of Hazardous Materials
All of the sites listed in Table 3H.2-1 have no violations found in the database or records search.17 The records search demonstrates that there is no site on or adjacent to the proposed project property that is included on a government list and that would require remediation in accordance
17 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-10 Draft EIR Subchapter 3H. Hazards and Hazardous Materials with state or government standards. A review of a list of hazardous materials sites, compiled in accordance with Government Code Section 65962.5, and as demonstrated by the Phase I ESA prepared by Parsons (Appendix F),18 shows that there are no existing hazardous materials located on-site. Despite that there are no on-site findings, potential presence of lead-based paint residues and termiticides may be present for southwest side and arsenic underneath the pavement of the project site from historic uses. Other off-site hazardous materials include an historic incinerator yard where two outdoor equipment shed currently exist and one stack in the main administration building associated with former use of the site. The former incinerator yard site is located adjacent to the western boundary of the proposed project site, between the proposed restriped parking for Mark Twain Middle School and the Student Garden (see Figure 2.2.2-3, Aerial Photograph). As noted above, the results of soil sampling and analyses conducted for the August 2014 Phase I ESA Addendum determined that the proposed project site is not adversely impacts by the presence of lead-based paint residues, termiticides, arsenic, and other chemicals of potential concern (see Appendix G). Proximity to Off-Site Hazards
The proposed project site is located on the existing Mark Twain Middle School campus, and is adjacent to Beethoven Elementary School to the east. The surrounding area consists of single-family residential homes, as well as a few multi-family homes. As seen in Figure 2.1-1, Regional Site Map, and as described in Section 2, Project Description, the proposed project is located approximately 1.86 miles south of the I-10 freeway, 1.78 miles west of the 405 freeway, and 1.17 miles north of the 90 freeway. Additionally, the nearest traffic corridor is Venice Boulevard (State Route 187), located approximately 700 feet to the south of the proposed project site. The nearest rail line is the Metro Exposition Line in Culver City, approximately 3.6 miles to the northeast of the proposed project site. The proposed project is outside of the Alquist-Priolo Earthquake Fault Zone (APEFZ), with the nearest APEFZ located approximately 4 miles away. The proposed project does not lie within a tsunami hazard flood zone19 and does not lie within a 100-year floodplain. Airport Land Use Plan or within 2 Miles of a Public Airport
According to the Airport Land Use Commission’s (ALUC) database, the nearest public is the Santa Monica Municipal Airport, located at 3223 Donald Douglas Loop South, Santa Monica, California 90405.20 Although Santa Monica Municipal Airport is located approximately 0.8 mile south of the proposed project site, the planning boundary/airport influence area does not extend further south than Dewey Street (approximately 0.7 miles northwest of the proposed project site), and therefore the Santa Monica Municipal Airport does not affect or pose a potential hazards threat to the proposed project site on the campus of Mark Twain Middle School. Additionally, Los Angeles
18 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 19 California Emergency Management Agency, California Geological Survey, and University of Southern California. Accessed 19 November 2014. “Tsunami Inundation Map for Emergency Planning.” Beverly Hills Quadrangle. Available at: http://www.conservation.ca.gov/cgs/geologic_hazards/Tsunami/Inundation_Maps/LosAngeles/Documents/Tsuna mi_Inundation_BeverlyHills_Quad_LosAngeles.pdf 20 Los Angeles Airport Land Use Commission (ALUC). Accessed 10 December 2014. “Airports – Los Angeles County.” Available at: http://planning.lacounty.gov/aluc/airports Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-11 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
International Airport (LAX), located at 1 World Way, Los Angeles, California 90045, is located approximately 3.6 miles south of the proposed project site, the northernmost planning boundary/airport influence area of which is located approximately 2.9 miles south of the proposed project site at Manchester Boulevard in Westchester, California. Vicinity of a Private Airstrip
Based on the review of the Thomas Guide, there are no private airports within 2 miles of the proposed project site.21 Emergency Response Plan
The existing Emergency Response Plan for Mark Twain Middle School includes provisions for earthquake, tsunami, fire, and other hazard response programs. Emergency contact information is included for Red Cross Disaster Services and primary LAUSD emergency contacts. Additionally, comprehensive fire and earthquake drill plans are outlined, in addition to lockdown procedures. Emergency plans are in place for the LAUSD as a whole, providing the necessary resources for any expected scenario as well as procedures to properly document and report any events. Proximity to Power Lines
According to the Phase I ESA, the proposed project is located approximately 440 feet southeast of the nearest power transmission lines along Marco Place and 660 feet southwest of power transmission lines along Beethoven Street. Wildland Fire
A review of fire severity hazard zone maps developed by the California Department of Forestry and Fire Protection (CAL FIRE)22 as well as the Safety Element23 of the Los Angeles City General Plan shows that the proposed project site is not located in a Very High Fire Hazard Safety Zone and is, therefore, not at risk for Wildland Fires. The surrounding area is primarily single-family residential that is highly urbanized. The nearest risk for wildland fires is located approximately 1.8 miles south of the proposed project site in Marina Del Rey, within a portion of the Ballona Wetlands.
3H.3 THRESHOLDS OF SIGNIFICANCE
The potential for the proposed project to result in impacts related to hazards or hazardous materials was analyzed in relation to the eight questions contained in Appendix G of the State CEQA Guidelines. Would the proposed project: a. Create a significant hazard to the public or the environment through the routine transport, storage, use, or disposal of hazardous materials?
21 Thomas Guide. 2006. Los Angeles & Orange Counties Street Guide. 22 California Department of Forestry and Fire Protection (CAL FIRE). September 2011. Very High Fire Hazard Severity Zones in LRA As Recommended by CAL FIRE. Available at: http://www.fire.ca.gov/fire_prevention/fhsz_maps/FHSZ/los_angeles/Los_Angeles.pdf 23 Department of City Planning of Los Angeles, California. Adopted November 26, 1996. Safety Element of the Los Angeles City General Plan. “Safety Element Exhibit D: Selected Wildfire Hazard Areas in the City of Los Angeles.” Available at: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf Page 53. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-12 Draft EIR Subchapter 3H. Hazards and Hazardous Materials b. Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? d. Be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment? e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f. For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g. Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? h. Expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
3H.4 IMPACT ANALYSIS
Impact 3H-a: Would the proposed project create a significant hazard to the public or the environment through the routine transport, storage, use, or disposal of hazardous materials?
No Impact
The proposed project would not result in impacts from hazards and hazardous materials with respect to creating a significant hazard to the public or the environment through the routine transport, storage, use, or disposal of hazardous materials. Current and planned operations at the proposed project site do not include the routine transport, use, or disposal of hazardous materials. As implemented at the existing Mark Twain Middle School campus, the storage of de minimis (less than significant) quantities of cleaning materials, paints for touching up areas of the school buildings, and gasoline fuel for landscape equipment would be stored in locked rooms or locked metal sheds if needed to prevent public access to potentially hazardous materials on-site. Therefore, occurrences of hazardous material release from upset and accident conditions are not to create a significant hazard to the public or the environment through the routine transport, storage, use, or disposal of hazardous materials.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-13 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Impact 3H-b: Would the proposed project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
No Impact
The proposed project would not result in impacts from hazards and hazardous materials with respect to creating a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous material. The proposed project site would be used for K–5 education, which is not expected to use hazardous materials. No hazardous materials are anticipated to be used during construction. While it is not anticipated that on-site sources of hazardous materials would pose a significant hazard for students and staff, the July 2014 Phase I ESA prepared by Parsons indicates the potential presence of arsenic from historic herbicide use below the existing asphalt pavement on the project site, as well as a low potential for the presence of lead-based paint residues and termiticides associated with former school buildings on the southwestern portion of the Mark Twain Middle School campus (Appendix F). Pursuant to the July 2014 Phase I ESA On-Site Recommendations,24 the August 2014 Phase I ESA Addendum was prepared by Parsons to document the results of surface and shallow soil sampling and analyses (see Appendix G).25 A total of 57 boring locations were sampled at preselected depths, 2 on the existing grass playfield and 55 on the asphalt-paved existing playground. Based on the soil sampling and analyses conducted at the proposed project site, lead results are below screening values; the detected arsenic concentrations appear to be naturally occurring; the concentrations of PCBs, metals, TPH, and SVOCs in the vicinity of the former “incinerator yard” are well below the residential screening values for these constituents; and concentrations of dioxins/furans collected in surface soil samples in the vicinity of a former “incinerator yard” near the proposed project site created an equivalent that is an order of magnitude below the DTSC residential clean up goal and also below the U.S. EPA RSL. Based on the soil analytical data presented in the Phase I ESA Addendum, the proposed project area is not adversely impacted by chemicals of potential concern.
The review of the environmental regulatory database did not identify hazardous material sites on the proposed property. A number of sites within the vicinity of the proposed project contain hazardous materials or waste (Table 3H.2-1).26 However, there are no violations found in the database or records search. Therefore, there is no foreseeable accident or upset conditions that could arise from existing or future hazards on or within the vicinity of the proposed project site. Therefore, there are no impacts from hazards and hazardous materials related to the creation of a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous material.
24 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. 25 Parsons. August 21, 2014. Phase I Environmental Site Assessment Addendum: Future Mandarin Dual-Language Immersion School Site at the Mark Twain Middle School, 2224 Walgrove Avenue, Los Angeles, California 90066. 26 July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-14 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
In the event that hazardous materials are found to be present, the materials would need to be removed under the oversight of the DTSC prior to the proposed project, in accordance with California Education Code Sections 17213.1, 17213.2, and 17268. The proposed project site would be cleaned up to an acceptable level in accordance with DTSC requirements to result in no further actions for proposed contractors in meeting the less than significant level determination. Therefore, the proposed project would not result in impacts from hazards and hazardous materials with respect to creating a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
Impact 3H-c. Would the proposed project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
No Impact
The proposed project is located on the site of a currently operating school. However, as demonstrated from the records search as well as an evaluation of sites within the proposed project vicinity (Table 3H.2-1), there is no foreseeable upset, release, or risk of release of hazardous materials within one-quarter mile of an existing school. Therefore, the proposed project would not result in impacts from hazards and hazardous materials with respect to the emission of hazardous emissions or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
Impact 3H-d. Would the potential project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment?
No Impact
The proposed project would not result in impacts from hazardous materials sites because the proposed project is located on a site that is not included on a list of hazardous materials sites. The review of hazardous materials sites, compiled in accordance with Government Code Section 65962.5, and as demonstrated by the Phase I ESA prepared by Parsons in July 2014 (Appendix F),27 shows that there are no existing hazardous materials located on-site. Therefore, the proposed project would not result in a significant hazard to the public or the environment due to location on a hazardous materials site.
27 Parsons. July 2014. Phase I Environmental Site Assessment, Mark Twain Middle School, Los Angeles Unified School District, 2224 Walgrove Avenue, Los Angeles, California 90066. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-15 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
Impact 3H-e. For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the proposed project result in a safety hazard for people residing or working in the project area?
No Impact
Although the proposed project site is located only 0.8 mile southwest of Santa Monica Municipal Airport, the proposed project site is not located within the Santa Monica Municipal Airport planning boundary/influence area, which does not extend further south than Dewey Street (approximately 0.7 miles northwest of the proposed project site). Additionally, the proposed project site is an existing school campus, with the same existing safety hazard level as the hazard level for the proposed project. Therefore, the Santa Monica Municipal Airport does not pose a potential hazards threat to the proposed project site on the campus of Mark Twain Middle School.
The northernmost planning boundary/airport influence area for LAX is located approximately 2.9 miles south of the proposed project site at Manchester Boulevard in Westchester, California. Therefore, the proposed project would not be expected to result in impacts to hazards and hazardous materials in regard to a potential safety hazard for people residing or working in the project area.
Impact 3H-f. For a project within the vicinity of a private airstrip, would the proposed project result in a safety hazard for people residing or working in the project area?
No Impact
There are no private airports within 2 miles of the proposed project site; therefore, there would be no impacts in regard to the potential for the proposed project to result in safety hazards for people residing or working in the project area within the vicinity of a private airstrip.
Impact 3H-g: Would the proposed project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
No Impact
The proposed project would not impair or interfere with the implementation of the existing adopted emergency response plan and emergency evacuation plans for Mark Twain Middle School. Emergency response planning and implementation for the proposed project would be managed consistent with OEHS policies and standards:
Safety and Industrial Hygiene. OEHS provides support related to occupational safety and health regulatory program compliance, loss control, accident management, workers’ compensation cost reduction, industrial hygiene, liability loss control, ergonomic support, safety and industrial hygiene training, traffic/pedestrian safety, asbestos compliance oversight, lead in drinking water compliance, chemical product evaluation, regulatory agency support and citation management, and equipment approval. OEHS staff works on District-wide design standards and policies, conducts comprehensive analyses of all major facilities projects, and approves occupancy for new construction and significant site modification projects. In addition to traditional safety and industrial hygiene program Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-16 Draft EIR Subchapter 3H. Hazards and Hazardous Materials
management, OEHS staff manages the District’s Emergency Operations Centers (EOCs), responds to District emergency response situations (e.g., hazardous materials, fires, chemical spills, sewer overflows, vandalism), provides emergency response training, coordinates the District emergency response equipment inventory, and responds to catastrophic emergencies. In cooperation with School Operations, OEHS coordinates with local, state, and federal emergency management agencies, communicates with District executive management during large-scale emergencies, and conducts post-event analyses of District response activities.
The existing provisions of the Emergency Response Plan for Mark Twain Middle School would be expanded to include the proposed project. Therefore, the proposed project would not result in significant impacts from hazards and hazardous resources related to an emergency response plan or emergency evacuation plan.
Impact 3H-h: Would the proposed project expose people or structures to a significant risk involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
No Impact
The proposed project would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires. The proposed project is located 1.8 miles from the nearest wildland fire risk area. The proposed project site is located in an urban environment served by fire hydrants and local fire stations. Therefore, the proposed project would not result in significant impacts related to wildland fires.
3H.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts related to hazards and hazardous materials. Therefore, there would be no cumulative impacts.
3H.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development, safety, and construction standards that would meet LAUSD Design Standards. Therefore, impacts related to hazards and hazardous materials would be less than significant, and no mitigation measures are required.
3H.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3H-a through 3H-g: No impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3H-17 Draft EIR SUBCHAPTER 3I Hydrology and Water Quality
This analysis is undertaken to determine if the proposed project may have a significant impact on hydrology and water quality, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to hydrology and water quality at the proposed project site was evaluated with regard to the Los Angeles RWQCB, Los Angeles Department of Water and Power Urban Water Management Plan (UWMP),2 National Flood Insurance Program Flood Insurance Rate Maps for Los Angeles County, the USGS 7.5-minute topographic quadrangles where the proposed project area is located, and a review of published and unpublished literature. Definitions
Acre-Foot: An acre-foot represents the amount of water it would take to cover an acre of land 12 inches deep. The term is commonly used in irrigation and water resource management to allocate water resources and to calculate the volume of water in reservoirs and other bodies of water.
General Construction Activity Storm Water Permit: Where the U.S. Environmental Protection Agency (EPA) is the permitting authority, or in California acting through the State Water Resources Control Board (SWRCB) and RWQCBs, construction stormwater discharges are almost all regulated under the General Construction Activity Storm Water Permit, that requires compliance with effluent limits and other permit requirements, such as the development of an SWPPP. Construction operators intending to seek coverage under General Construction Activity Storm Water Permit must submit a Notice of Intent (NOI) certifying that they have met the permit’s eligibility conditions and that they will comply with the permit’s effluent limits and other requirements.
City of Los Angeles Bureau of Sanitation: The primary responsibility of the Bureau of Sanitation is to collect, clean, and recycle solid and liquid waste generated by residential, commercial, and industrial users in the City and surrounding communities.
Los Angeles Department of Water and Power (LADWP): The LADWP is the largest municipal water and power utility provider in the nation established to provide water and electricity to provide water to 3.8 million residents and businesses in Los Angeles.
Los Angeles Regional Water Quality Control Board: The Los Angeles RWQCB is one of nine state regional boards. The Los Angeles RWQCB protects ground and surface water quality in the Los
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 LAUSD. 2007. Urban Waste Management Plan. Available at: http://www.laschools.org/employee/design/fs- studies-and- reports/download/white_paper_report_material/BMP_White_Paper_Oct__2007.pdf?version_id=9490499 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-1 Draft EIR Subchapter 3I. Hydrology and Water Quality
Angeles Region, including the coastal watersheds of Los Angeles and Ventura Counties, along with very small portions of Kern and Santa Barbara Counties. In order to carry out its mission “to preserve and enhance water quality in the Los Angeles Region for the benefit of present and future generations,” the Los Angeles RWQCB conducts a broad range of activities to protect ground and surface waters under its jurisdiction.
Mudflow: Mudflows result from the downslope movement of soil and/or rock under the influence of gravity.
Runoff: Runoff is the water flow that occurs when the soil is infiltrated to full capacity and excess water from rain, meltwater, or other sources flows over the land. This is a major component of the water cycle, and the primary agent in water erosion. In addition to causing water erosion and pollution, surface runoff in urban areas is a primary cause of urban flooding which can result in property damage, damp and mold in basements, and street flooding.
Seiche: A seiche is an oscillation of a body of water in an enclosed or semi-enclosed basin, such as a reservoir, harbor, lake, or storage tank.
State Water Resources Control Board: The federal Clean Water Act (CWA) is administered and enforced by the SWRCB, which develops regulations to implement water-quality control programs mandated at the federal and state levels. To implement these programs, California has nine RWQCBs, as noted above.
Storm Water and Stormwater: In layman’s terms, stormwater is defined as an abnormal amount of surface water due to a heavy rain or snowstorm. The term storm water is used when employed by the cited source of information. In all other instances, stormwater is used, consistent with the provision of Appendix G of the State CEQA Guidelines and as defined by the U.S. EPA. Stormwater runoff is generated when precipitation from rain and snowmelt events flows over land or impervious surfaces and does not percolate into the ground. As the runoff flows over the land or impervious surfaces (e.g., paved streets, parking lots, and building rooftops), it accumulates debris, chemicals, sediment or other pollutants that could adversely affect water quality if the runoff is discharged untreated.
Stormwater BMPs: As defined by the California Stormwater Quality Association (CASQA), Stormwater BMPs include schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent, eliminate, or reduce the pollution of the receiving waters. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
SWPPP: A plan created by developers to show their plans for sediment and erosion control. Typically these plans are part of an overall design that details procedures to be followed during various phases of construction. This is required by a federal regulation governing stormwater runoff from active construction sites that are more than one acre in area.
Total Maximum Daily Loads (TMDL): Section 303(d) of the CWA requires territories and authorized tribes to develop TMDLs that calculate the maximum amount of a pollutant that a water body can receive and still safely meet water quality standards.
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Tsunami: A tsunami is a great sea wave produced by a significant undersea disturbance.
UWMP: As defined by the SWRCB, UWMPs are prepared by California’s urban water suppliers to support their long-term resource planning and ensure adequate water supplies are available to meet existing and future water demands. Every urban water supplier that either provides over 3,000 acre-feet of water annually or serves more than 3,000 or more connections is required to assess the reliability of its water sources over a 38-year planning horizon considering normal, dry, and multiple dry years. This assessment is to be included in its UWMP, which must be prepared every five years and submitted to the California Department of Water Resources (DWR). DWR then reviews the submitted plans to make sure they have completed the requirements identified in the Urban Water Management Planning Act (Division 6 Part 2.6 of the Water Code §10610–10656).
Waters of the United States: Surface waters such as navigable waters and their tributaries, all interstate waters and their tributaries, natural lakes, all wetlands adjacent to other waters, and all impoundments of these waters.
Water Resources Plans (WRP): A WRP provides a comprehensive overview of water resources and demands in the region; an overview of the water resources portfolio, or available resources; the approach used for forecasting water demand; recommendations for demand management and strategy for meeting long-term resources needs, including a plan of action for times of declared shortages. A WRP will normally include a discussion of the environmental issues that will influence future supply and demand.
3I.1 REGULATORY FRAMEWORK
Federal, state, and local regulations regarding hydrology and surface water quality are relevant to and would be implemented by the proposed project. The CWA forms the basic national framework for management of quality and control of pollutant discharges at the federal level. At the State level, the Porter-Cologne Water Quality Control Act established the legal and regulatory framework for California’s water quality control including implementation of the provisions set forth in the CWA. At the regional level, the Water Quality Control Plan of Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles designates beneficial uses for surface waters and groundwater. At the local level, the Los Angeles County Department of Public Works’ Hydrology Manual provides guidance to have drainage facilities meet the Urban Flood level of protection. Federal
Clean Water Act, Sections 401 and 404
Section 401 of the CWA of 1972 established the basic structure for regulating discharges of pollutants into the waters of the U.S. and regulating quality standards for surface waters. Under the CWA, the U.S. EPA has implemented pollution control programs such as setting wastewater standards for industries and surface waters. The CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit is obtained. The EPA’s NPDES permit program controls discharges. Point sources are discrete conveyances such as pipes or manmade ditches. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
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Section 404 of the CWA establishes a program to regulate the discharge of dredged and fill material into waters of the United States, including wetlands. Responsibility for administering and enforcing Section 404 is shared by the USACOE and U.S. EPA. USACOE administers the day-to- day program, including individual permit decisions and jurisdictional determinations; develops policy and guidance; and enforces Section 404 provisions. Section 303 of the CWA identifies the water bodies that are not achieving water quality standards or receiving beneficial uses and for what pollutants.
Executive Order 11988, Flood Plain Management
The objective of Executive Order 11988, dated May 24, 1977, is to avoid, to the extent possible, long- and short-term adverse impacts associated with the occupancy and modification of the base floodplain (100-year floodplain) and direct and indirect support of development in the base floodplain wherever there is a practicable alternative. Under the Executive Order, USACOE must provide leadership and take action to:
Avoid development in the base floodplain unless it is the only practicable alternative
Reduce the hazard and risk associated with floods
Minimize the impact of floods to human safety, health, and welfare
Restore and preserve the natural and beneficial values of the base floodplain
Federal Anti-degradation Policy (40 Code of Federal Regulations 131.12)
The Federal Antidegradation Policy requires states to develop statewide anti-degradation policies and identify methods for implementation. State
California Water Code, Division 7, Section 13000 et seq.—Porter-Cologne Water Quality Control Act
Water quality in California is further regulated under the Porter-Cologne Water Quality Control Act. This law assigns responsibility for protection of water quality to the SWRCB, which is divided into nine RWQCBs that enforce water quality standards. The area affected by the proposed project is subject to the jurisdiction of the Los Angeles RWQCB. The SWRCB also administers the NPDES stormwater permitting program through its General Permit. A construction site subject to the General Permit must prepare and implement a SWPPP, which documents the selection and implementation of BMPs for the LAUSD construction projects.
Waters of the State are defined in Section 13050 of the Porter‐Cologne Water Quality Control Act as “any surface water or groundwater, including saline waters, within the boundaries of the state.” Water quality criteria include the identification of beneficial uses, narrative and numerical water quality standards, and implementation procedures.
Section 13260 of the California Water Code states that persons discharging or proposing to discharge waste that could affect the quality of the waters of the State, other than into a community sewer system, shall file a Report of Waste Discharge (ROWD) with the appropriate RWQCB. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-4 Draft EIR Subchapter 3I. Hydrology and Water Quality
Following the filing of a ROWD, if applicable, the RWQCB adopts Waste Discharge Requirements (WDR) specifying water quality limitations for the reported waste discharge. Pursuant to California Water Code 13267, a Monitoring and Reporting Program may be required by the RWQCB as a condition of the WDR.
The RWQCBs are authorized to issue WDRs specifying conditions for protection of water quality in Section 13263.
Urban Water Management Planning Act, Division 6 Part 2.6 of the Water Code §10610– 10656
The California Urban Water Management Planning Act of 1983 (UWMP Act) requires all publicly or privately owned entities that serve water for municipal purposes to more than 3,000 service connections or serve more than 3,000 acre-feet of water per year to prepare an updated UWMP once every 5 years—either at the beginning or midpoint of each decade—to support long-term resource planning. Regional
Water Quality Control Plan for the Los Angeles Region
The RWQCB has prepared a Water Quality Control Plan for the Los Angeles Region (Basin Plan), which includes the coastal watersheds of Los Angeles and Ventura Counties. The Water Quality Control Plan designates beneficial uses for surface waters and groundwater, sets narrative and quantitative objectives (as described below) to attain or maintain the designated beneficial uses and conform to the federal and state anti-degradation policy. The first essentially complete Basin Plan, which was established under the requirements of California's 1969 Porter-Cologne Water Quality Control Act (Section 13000 [Water Quality] et seq. of the California Water Code), was adopted in 1975 and revised in 1984. The latest version was adopted in 1994.
The Basin Plan assigned beneficial uses to surface and groundwater such as municipal water supply and water-contact recreation to all waters in the basin. It also set water-quality objectives, subject to approval by the EPA, intended to protect designated beneficial uses. These objectives apply to specific parameters (numeric objectives) and general characteristics of the water body (narrative objectives). An example of a narrative objective is the requirement that all waters must remain free of toxic substances in concentrations producing detrimental effects upon aquatic organisms. Numeric objectives specify concentrations of pollutants that are not to be exceeded in ambient waters of the basin.
The Los Angeles RWQCB regulates various activities that are relevant to the proposed project. This agency:
Prepares, monitors compliance with, and enforces Waste Discharge Requirements, including NPDES Permits
Implements and enforces local stormwater control efforts
Enforces water quality laws and regulations
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-5 Draft EIR Subchapter 3I. Hydrology and Water Quality
Authorizes Notices of Applicability pursuant to the General Construction Activity Storm Water Discharges
Stormwater discharges that are composed entirely of runoff from qualifying construction activities may be subject to regulation pursuant to the General Construction Activity Storm Water Permit issued by the SWRCB (Water Quality Order 99-08-DWQ).
Construction activities that are regulated pursuant to the General Construction Storm Water Permit include:
Any construction or demolition activity, including, but not limited to: clearing, grading, grubbing, or excavation, or any other activity that results in a land disturbance of equal to or greater than one acre.
Construction activity related to residential, commercial, or industrial development on lands currently used for agriculture including, but not limited to, the construction of buildings related to agriculture that are considered industrial pursuant to U.S. EPA regulations, such as dairy barns or food processing facilities.
Stormwater discharges from dredge spoil placement that occur outside of USACOE jurisdiction (upland sites) and that disturb one or more acres of land surface from construction activity.
Construction projects that intend to disturb one or more acres of land that are subject to the jurisdiction of the USACOE, pursuant to Section 404 of the CWA. Local
City of Los Angeles Bureau of Sanitation
The Bureau of Sanitation carries out its responsibility by the management of these primary programs related to water quality:
Wastewater Program: Safely and efficiently convey and treat 550 million gallons of wastewater per day and beneficially reuse 700 wet tons per day of biosolids.
Watershed protection program: protect the beneficial uses of receiving waters, while complying with all stormwater pollution abatement regulations.
Los Angeles Department of Water and Power
The LADWP, a municipal water and power provider, prepares a UWMP to forecast the future water demands and water supplies under average and dry year conditions, identify future water supply projects such as recycled water, provide a summary of water conservation BMPs, and provide a single and multi-dry-year management strategy. The most recent UMWP was adopted in 2010 and serves two purposes: (1) to achieve full compliance with requirements of California Urban Water Management Planning Act and (2) to serve as a master plan for water supply and resources management consistent with the City’s goals and policy objectives.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-6 Draft EIR Subchapter 3I. Hydrology and Water Quality
The LADWP’s Hydrology Manual further requires projects to have drainage facilities to meet the Urban Flood level of protection. In addition, the Water Quality Compliance Master Plan for Urban Runoff identifies and describes the various sources of pollutants, describes the BMPs that are being implemented by the City and discusses existing TMDL implementation plans and watershed management plans.
3I.2 EXISTING CONDITIONS
The project site is located within the Mar Vista neighborhood of the West Los Angeles area and lies within the Los Angeles Basin as designated by the RWQCB. The Los Angeles Basin consists of the coastal areas of Los Angeles County, south of the divide of the San Gabriel Mountains and Santa Susana Mountains, and a small part of the coastal portion of Ventura County, south of the divide of the Santa Monica Mountains. The Basin is drained by four watersheds: the Los Angeles River, the Rio Hondo River, Ballona Creek, and the San Gabriel River. The project site is entirely located within the Santa Monica Bay Watershed. The tributaries have been converted in this watershed to flood control channels lined with concrete and stone rip-rap. Surface water flows in the Santa Monica Bay through catchment basins that can be grouped into nine subwatershed areas. The project site is located within the Ballona Creek subwatershed area. There are three waterways within a 2-mile radius of Mark Twain Middle School: Ballona Creek (located approximately 1.9 miles southeast of the proposed project site), Centinela Creek Channel (located approximately 2.0 miles southeast of the proposed project site), and Grand Canal (located approximately 1.5 miles southwest of the proposed project site). Water Quality
As indicated, the proposed project is located within the Santa Monica Bay watershed area of the Los Angeles Basin. Many of the beneficial uses of the watershed may have been impaired or are threatened due to pollutant loadings originating from human activities. As the project is located within the Ballona Creek watershed, the project site is surrounded by residential uses, commercial uses, industrial uses and open spaces. The topography of the site is flat since the site is situated on primarily on a flat site changing slightly in elevation from approximately 37 feet above MSL to approximately 41 feet above MSL. Since the majority of the site is developed with buildings and pavements otherwise surround the development footprint, the site has low potential for absorbing natural soils and vegetation to pollutants in the water sources. Groundwater
The project site is located in the Santa Monica Groundwater Basin, in the northwestern portion of the coastal plain of Los Angeles County. Water in the Santa Monica Groundwater Basin is used for municipal and domestic supply, agricultural supply, and industrial service and process supply.
There are no on-site groundwater production wells. The nearest groundwater production water well is 1.4 miles northeast of the project site. The Santa Monica Groundwater Basin is composed of sand, sandy clay, clay, and gravel. Based on local topography, groundwater flows around the project site is expected to be toward the south. Existing topography also indicates that groundwater flows to the south and southwest along a natural drainage pattern.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-7 Draft EIR Subchapter 3I. Hydrology and Water Quality
Drainage Patterns and Erosion and Siltation
The proposed project site is located in a dry area and experiences minimal rainfall throughout the year. A total of 5.05 inches and a monthly average of 0.30 inch of rainfall were recorded at the Santa Monica Municipal Airport Weather Station. The proposed project area encompasses approximately 4.2 acres of the existing Mark Twain Middle School Campus, of which approximately 55 percent is paved with asphalt and the remaining 45 percent is turf. Curb cuts and existing drainage controls are in place as part of the project site. Stormwater
There are existing stormwater drainage facilities in the proposed project area. Stormwater drainage facilities and surface runoff from the campus is conveyed by a non-erosive storm drain system consisting of area drains, catch basins, gutters, roof drains, and storm drain piping. From the proposed project site, runoff would flow west-southwest along the surface topography to storm drains maintained by the Los Angeles County Flood Control District (LACFCD) through catch basins at the intersection of Victoria Avenue and Walgrove Avenue (see Figure 3I.2-1, Storm Drains in the Vicinity of the Proposed Project). These systems convey runoff from the campus to the Santa Monica Bay. Sediment is a common component of stormwater and can also be a pollutant. Sediment may include total suspended solids (TSS), and suspended sediment concentration. Nutrients, including nitrogen and phosphorous from algae and vegetation, are the major plant nutrients when fertilizing landscape areas and can be found in stormwater. Oil and grease, including hydrocarbon compounds, can be associated with construction equipment, engines, and waste oil disposal. Metals are also commonly found in stormwater and some have potential to be toxic to contaminate drinking water supplies. Adherence to DTSC rules would minimize chances for contaminating water sources. 100-Year Flood Hazard Zone / Flood Hazards to People or Structures
According to the Safety Element of the City of Los Angeles General Plan, the proposed project site is not located within a 100-year flood plain area or a 500-year flood plain area.3 The National Flood Insurance Program administered by the Federal Emergency Management Agency (FEMA) has assigned flood risk zones within Los Angeles County according to Flood Hazards. The proposed project area is not located within a 100-year flood zone. The project is within Other Areas Zone X.4,5 Other Areas Zone X is a FEMA flood zone designation for areas that are outside the 0.2 percent annual chance floodplain (500-year flood zone); these areas are classified as being a
3 City of Los Angeles Department of City Planning. 1996. Safety Element of the Los Angeles City General Plan. Adopted by the City Council November 26, 1996. Available at: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf Exhibit F: 100-Year & 500-Year Flood Plains in the City of Los Angeles 4 County of Los Angeles Department of Public Works. Accessed 26 August 2011. “Los Angeles County Flood Control District.” Available at: http://ladpw.org/wmd/dspFloodControlDist.cfm 5 Federal Emergency Management Agency. Accessed 26 August 2011. FEMA Map Service Center. Available at: http://msc.fema.gov/webapp/wcs/stores/servlet/info?storeId=10001&catalogId=10001&langId=- 1&content=floodZones&title=FEMA%20Flood%20Zone%20Designations Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-8 Draft EIR ") ") ") ") ") ") ") ") ") ") ") ") ") ")") LEGEND ") ")") ") ") ") ") Catch Basins ") ") ") ") ") ") ") Maintained by City ") ") ") ") ") Maintained by LACFCD ") ")") ") ") ")") ") Laterals ")") ") ") ") ")") ") Ma")in")tained by LACFCD ")") ") ") Drains ")
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FIGURE 3I.2-1 Storm Drains in the Vicinity of the Proposed Project Subchapter 3I. Hydrology and Water Quality moderate-to-low risk flood zone area as indicated in the County General Plan and Flood Insurance Rate Maps for the County.6,7,8 Seiche, Tsunami, or Mudflows
The proposed project area does not fall within a City of West Los Angeles inundation and tsunami hazard area.9,10 The topography of the proposed project area ranges from approximately 37 feet to 41 feet above mean sea level on generally flat terrain, with shallow downward slopes toward the coast. The low relief of the proposed project area does not contribute to the risk for earthquake- related ground failures that would result in mudflows, and there would be no direct or indirect impacts. Based on a review of USGS 7.5-minute series Venice and Beverly Hills topographic quadrangle map, in which the proposed project site is located, no areas susceptible to mudslides or landslides are shown in the proposed project vicinity.11 The proposed project site is not located near coastlines, lakes, and/or flood control basins, or adjacent to any steep-sided slopes covered with soils and/or vegetation.
3I.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of ten questions when addressing the potential for significant impacts to hydrology and water quality. Would the proposed project: a. Violate any water quality standards or waste discharge requirements? b. Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level that would not support existing land uses or planned uses for which permits have been granted)? c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on or off site?
6 Federal Emergency Management Agency. Accessed 19 November 2014. “Los Angeles County, California and Incorporated Areas Flood Insurance Rate Map.” Panel 1590F, Map Number 06037C1590F. Effective 26 September 2008. 7 County of Los Angeles Department of Regional Planning. November 1980. County of Los Angeles General Plan. Los Angeles, CA. 8 National Flood Insurance Program. 26 September 2008. Flood Insurance Rate Map Los Angeles County, California, Panel 1820 of 2350. Available at: http://www.msc.fema.gov/ 9 California Emergency Management Agency, California Geological Survey, and University of Southern California. Accessed 19 November 2014. “Tsunami Inundation Map for Emergency Planning.” Beverly Hills Quadrangle. Available at: http://www.conservation.ca.gov/cgs/geologic_hazards/Tsunami/Inundation_Maps/LosAngeles/Documents/Tsuna mi_Inundation_BeverlyHills_Quad_LosAngeles.pdf 10 City of Los Angeles Department of City Planning. 1996. Safety Element of the Los Angeles City General Plan. Adopted by the City Council November 26, 1996. Available at: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf Exhibit G: Inundation & Tsunami Hazard Areas in the City of Los Angeles. 11 U.S. Geological Survey. [1964] Photorevised 1981. 7.5-Minute Series, Venice, California, Topographic Quadrangle. Reston, VA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-9 Draft EIR Subchapter 3I. Hydrology and Water Quality d. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner that would result in flooding on site or off site? e. Create or contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff? f. Otherwise substantially degrade water quality? g. Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h. Place within a 100-year flood hazard area structures that would impede or redirect flood flows? i. Expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam? j. Inundation by seiche, tsunami, or mudflow?
3I.4 IMPACT ANALYSIS
Impact 3I-a: Would the proposed project violate any water quality standards or waste discharge requirements?
Less than Significant Impact
The impacts to hydrology and water quality related to water quality standards or waste discharge requirements from the proposed project would be less than significant. The proposed project requires renovation of existing facilities, and construction of new buildings and facilities, which would result in potential impacts to water quality. While the construction and operation of the proposed project may contribute to erosion, sediment-laden runoff, discharge of non-stormwater runoff, and shifts from current hydrology-related activities, these impacts would be less than significant. The proposed project would comply with water quality standards or waste discharge requirements by abiding by NPDES requirements and implementing BMPs, as discussed below.
The quality of storm water runoff is regulated under the NPDES permit. The NPDES storm water permit (CAS614001, Order No. 1-182) issued to the County by the Los Angeles RWQCB provides a mechanism for establishing appropriate controls and monitoring the discharge of pollutants to the storm water runoff system. The County requires all development projects within its jurisdiction on sites of 1 acre or larger to comply with the NPDES requirements for construction and operations as appropriate. The proposed project would implement BMPs to reduce or eliminate non-storm discharges to the storm water system. These requirements meet the water quality standards set forth by the responsible agencies, and address storm runoff quantity and flow rate, suspended solids (primarily from erosion), and contaminants such as phosphorus and hydrocarbons. BMPs would be incorporated in accordance with the NPDES permit issued to the LAUSD by the Los Angeles RWQCB, the County Storm Water Management, and the City General Plan. Therefore, impacts to hydrology and water quality in relation to water quality standards or waste discharge requirements would be expected to be less than significant. No further analysis is warranted.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-10 Draft EIR Subchapter 3I. Hydrology and Water Quality
Impact 3I-b: Would the proposed project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level that would not support existing land uses or planned uses for which permits have been granted)?
Less than Significant Impact
The impacts to hydrology and water quality related to groundwater supplies or groundwater recharge from the proposed project would be expected to be less than significant. The proposed project site is not located within a designated groundwater recharge basin.12 The proposed project would not include the construction of groundwater extraction wells and would not deplete groundwater supplies. Therefore, impacts to hydrology and water quality in relation to groundwater supplies or groundwater recharge would be less than significant, and no further analysis is warranted.
Impact 3I-c: Would the proposed project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation on or off site?
Less than Significant Impact
Impacts to hydrology and water quality related to the alteration of the existing on-site drainage pattern of the proposed project site or area, including the alteration of the course of a stream or river, in a manner that would result in substantial erosion or siltation either on site or off site, would be reduced to below the level of significance with the implementation of LAUSD Construction BMPs (see Section 2.3, Project Design Features). There are no streams or rivers located in the immediate vicinity of the proposed project site; the two nearest water bodies are Grand Canal, which is located approximately 1.5 miles southwest of the proposed project site in the community of Venice, and Ballona Creek, which is located approximately 1.9 miles southeast of the proposed project site. Both of these water bodies are channelized. Project construction would temporarily expose on-site soils to surface water runoff. The proposed project would involve grading activities, which would need to be documented in a conceptual grading plan, and a drainage concept study completed by the LAUSD.
Site drainage is directed to adjacent streets following the natural topography of the existing land, and sheet flow is directed to existing storm drains. The proposed project would be designed to maintain a similar pattern of drainage, thereby providing a less than significant change in the existing storm runoff. As currently conceived, site improvements from implementation of the proposed project may potentially change the amount of pervious area. During construction and normal operation, the proposed project, as currently conceived, would be required to incorporate BMPs consistent with the guidelines provided in the California Storm Water Best Management Practices Handbook for Construction Activities and in the LAUSD Storm Water Management Plan
12 County of Los Angeles Department of Public Works. January 2006. Hydrology Manual. Alhambra, CA. Available at: http://ladpw.org/wrd/publication/engineering/2006_Hydrology_Manual/2006%20Hydrology%20Manual- Divided.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-11 Draft EIR Subchapter 3I. Hydrology and Water Quality
(SWMP) for substantiated erosion or siltation. These BMPs shall be designed in coordination with the existing project area in order to prevent any substantial alteration of the existing drainage pattern of the proposed project area. Impacts to hydrology and water quality related to the alteration of existing drainage patterns of the site or area would thus be less than significant and no further analysis is warranted.
Impact 3I-d: Would the proposed project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner that would result in flooding on site or off site?
Less than Significant Impact
The proposed project would be expected to result in less than significant impacts to hydrology and water quality in relation to alteration of existing drainage patterns in a manner that would result in flooding on site or off site. There are no streams or rivers located in the immediate vicinity of the proposed project site; the two nearest water bodies are Grand Canal, which is located approximately 1.5 miles southwest of the proposed project site, and Ballona Creek, which is located approximately 1.9 miles southeast of the proposed project site. The proposed improvements would not make major alterations of the existing drainage patterns; nor would they in an increase in flooding on site or off site. The proposed project would be engineered in a manner that would avoid or reduce flooding concerns. Although the proposed project has the potential to change the amount of pervious surface, implementation of BMPs would ensure that infiltration would remain at current levels and that the overall volume of flow accumulating on or off site would not change from existing conditions. Therefore, the proposed project would be expected to result in less significant impacts to hydrology and water quality related to alteration of existing drainage patterns in a manner that would result in flooding on site or off site. No further analysis is warranted.
Impact 3I-e: Would the proposed project create or contribute runoff water that would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff?
Less than Significant Impact
The proposed project would result in less than significant impacts to hydrology and water quality related to runoff water that would exceed the capacity of existing or planned storm water drainage systems or providing substantial additional sources of polluted runoff.
The quality of storm water runoff is regulated under the NPDES storm water permit (CAS614001, Order No. 1-182), which provides a mechanism for establishing appropriate controls and monitoring the discharge of pollutants to the storm water runoff system. LAUSD requires all development projects within its jurisdiction on sites of 1 acre or larger to comply with the NPDES requirements for construction and operations as appropriate and the design and implementation of the Standard Urban Storm Water Management Plan prepared consistent with the requirements of the applicable NPDES permit. The proposed project would entail development which would require conformance to the LAUSD’s NPDES storm water permit (see Section 2.3, Project Design Features: LAUSD Construction Best Management Practices). Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-12 Draft EIR Subchapter 3I. Hydrology and Water Quality
Therefore, the proposed project would result in less than significant impacts to hydrology and water quality related to runoff water that would exceed the capacity of existing or planned storm water drainage systems or providing substantial additional sources of polluted runoff. No further analysis is warranted.
Impact 3I-f: Would the proposed project otherwise substantially degrade water quality?
Less than Significant Impact
The proposed project would not cause significant impacts to hydrology and water quality in relation to substantial degradation of water quality. The proposed project would be required to comply with the NPDES requirements, and as such there is no potential for impacts to hydrology and water quality in relation to substantial degradation of water quality for the proposed project. As previously stated, construction and operation of the proposed project would incorporate LAUSD BMPs that would further reduce the potential for the proposed project degrade water quality (see Section 2.3, Project Design Features). Therefore, these impacts would be less than significant, and no further analysis is warranted.
Impact 3I-g: Would the proposed project place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?
No Impact
The proposed project would not place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. The proposed project would involve the construction of one new building and supporting facilities for a school program and not involve the construction of new housing. Potential flooding at the proposed project site is monitored by the Los Angeles County Flood Control District, whose responsibility and authority have been transferred to the LADWP. Additionally, the entirety of the proposed project area is in Other Zone X, an area of minimal flooding risk.13,14 Other Zone X is a FEMA flood zone designation for areas that are outside the 0.2-percent annual chance floodplain (500-year flood zone); these areas are classified as being a moderate-to-low risk flood zone area as indicated in the City’s General Plan and Flood Insurance Rate Maps for the County.15 Therefore, the proposed project would not result in significant impacts to hydrology and water quality related to the placement of housing within a 100-year old flood hazard area. No further analysis is warranted.
13 Federal Emergency Management Agency. Accessed 26 August 2011. FEMA Map Service Center. Available at: http://msc.fema.gov/webapp/wcs/stores/servlet/info?storeId=10001&catalogId=10001&langId=- 1&content=floodZones&title=FEMA%20Flood%20Zone%20Designations 14 Federal Emergency Management Agency. Accessed 19 November 2014. “Los Angeles County, California and Incorporated Areas Flood Insurance Rate Map.” Panel 1590F, Map Number 06037C1590F. Effective 26 September 2008. 15 National Flood Insurance Program. 26 September 2008. Flood Insurance Rate Map Los Angeles County, California, Panel 1820 of 2350. Available at: http://www.msc.fema.gov/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-13 Draft EIR Subchapter 3I. Hydrology and Water Quality
Impact 3I-h: Would the proposed project place within a 100-year flood hazard area structures that would impede or redirect flood flows?
No Impact
The proposed project would result in no impacts to hydrology and water quality in relation to placement of structures within a 100-year flood hazard area that would impede or redirect flood flows. The proposed project would not impede or redirect flood flows because all of the proposed project area is in Other Zone X, an area of minimal flooding.16 Other Zone X is a FEMA flood zone designation for areas that are outside the 0.2-percent annual chance floodplain (500-year flood zone); these areas are classified as being a moderate-to-low risk flood zone area as indicated in the City’s General Plan and Flood Insurance Rate Maps for the County.17 Therefore, the proposed project would result in no impacts to hydrology and water quality related to placement of structures within a 100-year flood hazard area that would impede or redirect flood flows. No further analysis is warranted.
Impact 3I-i: Would the proposed project expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam?
No Impact
The proposed project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. The proposed project site is not located within the potential flood zone of any levees or dams. The proposed project would be expected to be constructed in accordance with applicable state requirements, including the 2007 California Building Code flood zone requirements. The USGS 7.5-minute series Beverly Hills and Venice topographic quadrangles indicate that Ballona Creek, located approximately 1.9 miles southeast of the proposed project site, is the nearest flood control facility.18,19 Therefore, the proposed project would not result in impacts from the exposure of people or structures to a risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. No further analysis is warranted.
Impact 3I-j: Would the proposed project experience inundation by seiche, tsunami, or mudflow?
No Impact
The proposed project would not be expected to result in impacts to hydrology and water quality in relation to inundation by seiche, tsunami, or mudflow. Although ground shaking (earthquakes) is a
16 National Flood Insurance Program. 26 September 2008. Flood Insurance Rate Map Los Angeles County, California, Panel 1820 of 2350. Available at: http://www.msc.fema.gov/ 17 National Flood Insurance Program. 26 September 2008. Flood Insurance Rate Map Los Angeles County, California Panel 1820 of 2350. Available at: http://www.msc.fema.gov/ 18 U.S. Geological Survey. [1964] Photorevised 1981. 7.5-Minute Series, Beverly Hills, California, Topographic Quadrangle. Reston, VA. 19 U.S. Geological Survey. [1964] Photorevised 1981. 7.5-Minute Series, Venice, California, Topographic Quadrangle. Reston, VA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-14 Draft EIR Subchapter 3I. Hydrology and Water Quality possibility within the area of the proposed project site, due to the sufficient elevation of the proposed project area and the distance from the ocean and other bodies of water, there would be no direct or indirect impacts related to seiches or tsunamis. A review of the Tsunami Inundation Map for Emergency Planning prepared by the California Emergency Management Agency, CGS, and University of Southern California shows the proposed project site does not lie within the tsunami inundation area.20 Also, the low relief of the proposed project area does not contribute to the risk for earthquake-related ground failures that would result in mudflows, and there would be no direct or indirect impacts. The topographic profile of the proposed project site is generally flat terrain, with shallow downward slopes toward the coast. Based on a review of USGS 7.5-minute series Venice and Beverly Hills topographic quadrangle maps, in which the proposed project site is located, no areas susceptible to mudslides or landslides are shown in the proposed project vicinity.21 The proposed project site is not located near coastlines, lakes, and/or flood control basins, or adjacent to any steep-sided slopes covered with soils and/or vegetation. Therefore, implementation of the project would not result in impacts to hydrology and water quality related to inundation by seiche, tsunami, or mudflow. No further analysis is warranted.
3I.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to hydrology and water quality and would not cause any cumulative impacts.
3I.6 MITIGATION MEASURES
The proposed project would not result in significant impacts related to hydrology and water quality. Therefore, the consideration of mitigation measures is not required.
3I.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3I-a through 3I-f: Less than significant impact.
Impacts 3I-g through 3I-j: No impact.
20 California Emergency Management Agency, California Geological Survey, and University of Southern California. Accessed 19 November 2014. “Tsunami Inundation Map for Emergency Planning.” Beverly Hills Quadrangle. Available at: http://www.conservation.ca.gov/cgs/geologic_hazards/Tsunami/Inundation_Maps/LosAngeles/Documents/Tsuna mi_Inundation_BeverlyHills_Quad_LosAngeles.pdf 21 U.S. Geological Survey. [1964] Photorevised 1981. 7.5-Minute Series, Venice, California, Topographic Quadrangle. Reston, VA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3I-15 Draft EIR SUBCHAPTER 3J Land Use and Planning
This analysis is undertaken to determine if the proposed project may have a significant impact to land use and planning, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 Land use and planning were evaluated with regard to the Federal ESA of 1973,2 the California Natural Community Conservation Planning Act of 1991,3 the California Coastal Act of 1976, the California Department of Education School Site Selection and Approval Guide,4 California Environmental Quality Act Specification Manual,5 the California Civic Center Act,6 the Southern California Area of Governments (SCAG) Regional Transportation Plan,7 the SCAG Regional Comprehensive Plan,8 and the SCAG Congestion Management Plan.9
3J.1 REGULATORY FRAMEWORK Federal
Federal Endangered Species Act of 1973
The federal ESA was established by Congress in order to “provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved [and] to provide a program for the conservation of such . . . species.” HCPs, established under Section 10(a)(1)(B) of the ESA, are planning documents that provide for partnerships with non-federal parties to conserve the ecosystems upon which listed (and candidate) species depend, ultimately contributing to their recovery. The USFWS requires HCPs as part of an application for an incidental take permit. HCPs provide for long-term conservation of habitat to support the “survival and recovery” of federally listed rare, threatened, and endangered species.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 U.S. Fish and Wildlife Service. Accessed July 2009. Federal Endangered Species Act. Available at: http://www.fws.gov/Endangered/pdfs/esaall.pdf 3 California Department of Fish and Wildlife. Accessed 4 June 2014. Natural Community Conservation Planning (NCCP). Available online at http://www.dfg.ca.gov/habcon/nccp/. 4 California Department of Education. n.d. School Site Selection and Approval Guide. Available online at: http://www.cde.ca.gov/ls/fa/sf/schoolsiteguide.asp 5 LAUSD OEHS. California Environmental Quality Act Specification Manual. Revised June 2007. 6 State of California. n.d. Civic Center Act. Available at: http://www.leginfo.ca.gov/cgi- bin/displaycode?section=edc&group=38001-39000&file=38130-38139 7 Southern California Association of Governments. 2012. Regional Transportation Plan 2012-2035. Available at: http://rtpscs.scag.ca.gov/Pages/2012-2035-RTP-SCS.aspx. 8 Southern California Association of Governments. 2008. Regional Comprehensive Plan 2008. Available at: http://www.scag.ca.gov/NewsAndMedia/Pages/RegionalComprehensivePlan.aspx. 9 California Government Code, Title 7, Division 1, Chapter 2.6, Congestion Management. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-1 Draft EIR Subchapter 3J. Land Use and Planning
State
California Department of Education (CDE) School Site Selection and Approval Guide
The Education Code Section 17251 and the California Code of Regulations (CCR) Title 5, Sections 14001–14012 outline the CDE’s authority for approving proposed school sites and constructing school buildings. CDE must approve each site in order for that site to receive state acquisition funds under the School Facilities Program administered by the State Allocation Board. According to the CDE School Site Selection and Approval Guide, some of the many factors that affect school site selection include health and safety, location, size, and cost. The School Facilities Planning Division (SFPD) has developed screening and ranking procedures applied during the site selection process. The criteria used during the LAUSD site selection are listed in detail in the Project Description in Section 2.3.3 (Site Selection).10
California Government Code Section 53094
The California legislature granted school districts the power to exempt school property from local zoning requirements, provided the school district complies with the terms of Government Code Section 53094.11 As lead agency for the proposed project, it is anticipated that LAUSD will comply with Government Code Section 53094 to render the local City of Los Angeles Zoning Ordinance inapplicable to the proposed project. Following a two-thirds vote of the Board of Education, LAUSD can exempt a school site from such local zoning requirements. Within 10 days of the action, the Board must provide the City of Los Angeles with notice of this action.
California Civic Center Act of 1970
The California Civic Center Act requires that every public school facility be considered a civic center where citizens, school-community councils, and clubs as well as senior, recreation, education, political, artistic, and other organizations may meet. Additionally, the act states the school district may grant the use of school facilities and grounds upon certain terms and conditions deemed proper by the governing board and subject to specified limitations, requirements, and restrictions set forth within the law.12
10 California Department of Education. n.d. School Site Selection and Approval Guide. Available at: http://www.cde.ca.gov/ls/fa/sf/schoolsiteguide.asp 11 Government Code Section 53094. (a) Notwithstanding any other provision of this article, this article does not require a school district to comply with the zoning ordinances of a county or city unless the zoning ordinance makes provision for the location of public schools and unless the city or county has adopted a general plan. (b) Notwithstanding subdivision (a), the governing board of a school district, that has complied with the requirements of Section 65352.2 of this code and Section 21151.2 of the Public Resources Code, by a vote of two-thirds of its members, may render a city or county zoning ordinance inapplicable to a proposed use of property by the school district. The governing board of the school district may not take this action when the proposed use of the property by the school district is for non-classroom facilities, including, but not limited to, warehouses, administrative buildings, and automotive storage and repair buildings. (c) The governing board of the school district shall, within 10 days, notify the city or county concerned of any action taken pursuant to subdivision (b). 12 State of California. n.d. Civic Center Act. Available online at: http://www.leginfo.ca.gov/cgi- bin/displaycode?section=edc&group=38001-39000&file=38130-38139 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-2 Draft EIR Subchapter 3J. Land Use and Planning
Natural Community Conservation Planning Act of 1991
The Natural Community Conservation Planning Act of 2003 (California Fish and Game Code Sections 2800–2835) established the State’s NCCP program for the protection and perpetuation of the state’s biological diversity. The California CDFW established the program in order to conserve natural communities at the ecosystem level while accommodating compatible land use. An NCCP identifies and provides for the regional or area-wide protection of plants, animals, and their habitats, while allowing compatible and appropriate economic activity.
California Coastal Act of 1976
The California Coastal Act constitutes the California Coastal Management Program for the purposes of the Federal Coastal Zone Management Act (California Coastal Act of 1976, PRC §30000 et seq.). The act established the California Coastal Commission (CCC), identified a designated California Coastal Zone, and established the CCC’s responsibility to include the preparation and ongoing oversight of a Coastal Plan for the protection and management of the Coastal Zone. Each local jurisdictional authority (city or county) with lands within the coastal zone is required to develop, and comply with, a coastal management plan. The Coastal Act requires that any person or public agency proposing development within the Coastal Zone obtain a Coastal Development Permit (CDP) from either the CCC or the city or county having the jurisdictional authority to issue a CDP. New school construction in portions of the Central and South LAUSD areas could require a CDP. Any construction within the Coastal Zone must conform to the requirements of the California Coastal Act generally, and Chapter 3, Section 6 (Development) specifically. On or near the shoreline, coastal-dependent developments have priority over those uses not dependent on a coastal location (PRC §30255). To comply with the Coastal Zone Management Act, localities develop Local Coastal Plans (LCPs).13 Regional
Southern California Association of Governments Regional Comprehensive Plan and Guide
SCAG is the federally mandated Metropolitan Planning Organization (MPO) for Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties. SCAG’s Regional Comprehensive Plan and Guide (RCPG) is a 20-year strategic plan for local and regional development.14 The RCPG focuses on transportation, housing, growth management, air quality issues, and the local economy. SCAG does not infringe on the land use planning prerogatives of local government. However, SCAG encourages and promotes the coordination and integration of local general plans, sub-regional plans, and regional plans. State law and State General Plan Guidelines direct cities and counties to refer their proposals for general plan adoptions and substantial amendments to area-wide planning agencies, such as SCAG, for review and comment. The RCPG supports and encourages local government, the sub-regional agencies, and other affected parties to work together with SCAG to foster a high degree of consistency among plans in
13 California Coastal Commission. Accessed 23 November 2014. Laws, Regulations, and Legislative Information. Available at: http://www.coastal.ca.gov/ccatc.html. 14 Southern California Association of Governments. 1996. Regional Comprehensive Plan and Guide. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-3 Draft EIR Subchapter 3J. Land Use and Planning order to achieve harmonious planning relationships at all geographic levels. The RCPG consists of three sections:
Core Chapters (Growth Management, Regional Mobility, Air Quality, Water Quality, and Hazardous Waste Management). The Core chapters correspond directly to the federal and State requirements and may also contain non-binding advisory materials and guidance.
Ancillary Chapters (Economy, Housing, Human Resources and Services, Public Finance, Open Space and Conservation, Water Resources, Energy, and Integrated Waste Management). The Ancillary chapters may reflect other regional plans but are strictly advisory and establish no new mandates or policies for the region.
Bridge Chapters (Introduction, Strategy, and Implementation). The Bridge chapters show the links between the requirements in the Core chapters and the guidance in the Ancillary chapters for other areas of concern.
In summary, the RCPG is a compilation of planning documents for the Southern California region. Some of these plans are required by federal or state law, some are prepared by operating agencies that produce them in the course of meeting their obligations, and some respond to the direction of SCAG’s Regional Council. SCAG information is useful in policy consistency analysis for regional projects in that it provides a consistent review and evaluation of planning documents and demographic data across multiple jurisdictional boundaries. In a letter dated May 21, 2003, SCAG determined that the Program is not “regionally significant” within the meaning of the SCAG Intergovernmental Review Criteria and CEQA Guidelines (§15206).15
LAUSD Regulations for Civic Center Use
As mentioned in the Program Description in Section 2.3.6 (School Operations), California Education Code 38131 (b), the Civic Center Act, permits public use of school facilities. Table 3J.1- 1, Civic Center Organizations and Uses, outlines organizations and activities that qualify and do not qualify for Civic Center permits. School facilities available for Civic Center use include gyms, playing fields, stadiums, auditoriums, multi-purpose rooms, cafeterias, and classrooms. Facilities are available within designated time frames outside school hours. Organizations wishing to use a school location for Civic Center use must go through an application/permit process with LAUSD. A variety of rules, regulations, and restrictions governing the use of school buildings for Civic Center purposes appear in detail on the permit and the application.
15 Southern California Association of Governments. 2008. Regional Comprehensive Plan 2008. Available at: http://www.scag.ca.gov/NewsAndMedia/Pages/RegionalComprehensivePlan.aspx. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-4 Draft EIR Subchapter 3J. Land Use and Planning
Table 3.J.1-1: Civic Center Organizations and Uses Qualify for Civic Center Permits Do Not Qualify for Civic Center Permits PTAs For-profit organizations Girl/Boy Scout Troops Swimming pools Senior citizens’ organizations Private school activities Youth groups Parking lots Recreational activities of clubs and associations concerned with education, recreation, arts, politics, economics, charity Religious services Meetings/discussions open to the general public concerned Political campaign headquarters with education, politics, economics, arts, charities, culture, community moral interests Jazzercise Cultural classes Aerobics Invitation only and exclusive meetings Jujitsu Tennis courts Ballroom dances sponsored by Youth Services and PTAs or Roller blading specifically authorized by the Superintendent Good news clubs Gymnastics Karate Child care and enrichment programs Wrestling Hammer throwing and discus Non-authorized ballroom dances Picnics Weight lifting SOURCE: Los Angeles Unified School District. 1999. Civic Center Procedure Manual.
Local
City of Los Angeles General Plan
As previously noted, this EIR has taken into account local land use and zoning regulations, but considers these regulations as advisory only and not binding or determinative of whether impacts would be significant because the proposed project site is exempt from them under Government Code Section 53094. The discussion of local plans and zoning codes in this section is guided by these considerations.
The proposed project site is located within the City of Los Angeles. The City’s General Plan guides land use decisions and policies to meet the existing and future needs of the community, while integrating a range of state-mandated elements including Land Use, Transportation, Noise, Safety, Housing, Open Space, and Conservation. Two major components of the Citywide General Plan are the Citywide General Plan Framework Element and the Land Use Element. The Land Use Element comprises 35 local area plans known as Community Plans that guide land use at the local level.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-5 Draft EIR Subchapter 3J. Land Use and Planning
The proposed project site is located within the boundaries of the Palms – Mar Vista – Del Rey Community Plan.16
Palms – Mar Vista – Del Rey Community Plan
Community Plans are intended to promote an arrangement of land uses, streets, and services that will encourage and contribute to the economic, social, and physical health, safety, welfare, and convenience of the people who live and work in the community. Through the Community Plan, the City of Los Angeles can inform the general public, property owners, prospective investors, and business interests of the community’s goals, policies, and development standards, thereby communicating what is expected of the City government and private sector to meet its objectives. The Community Plan ensures that sufficient land is designated which provides for the housing, commercial, employment, educational, recreational, cultural, social, and aesthetic needs of the residents of the plan area.
The Palms – Mar Vista – Del Rey Community Plan Area consists of approximately 5,257 acres located in the western portion of Los Angeles. The community plan area is bisected by a narrow strip of the City of Culver City along Washington Boulevard. The northern section proceeding in a clockwise direction is bounded by the City of Santa Monica, Pico Boulevard, southerly along the San Diego Freeway up to National Boulevard, Exposition Boulevard and Southern Pacific Railroad Company line, Robertson Boulevard up to National Boulevard, Venice Boulevard, Washington Boulevard, City of Culver City, and Walgrove Avenue. The southern section, in a clockwise direction, is bounded by Del Rey Avenue, City of Culver City, Centinela Avenue, Jefferson Boulevard, and Lincoln Boulevard. The community plan area is surrounded by the communities of Venice, West Los Angeles, West Adams – Baldwin Hills – Leimert Park, Westchester – Playa Del Rey, and the Cities of Santa Monica and Culver City.
Chapter III of the Palms – Mar Vista – Del Rey Community Plan contains the following Land Use Policy for Public and Institutional land uses:17
Public facilities such as libraries, parks, schools, fire and police stations shown on the Palms-Mar Vista-Del Rey Community Plan should be developed in accordance with user needs, site area, design and general location identified in the Service Systems Element and the Safety Element of the General Plan. Such development shall be phased and scheduled to provide an efficient and adequate balance between land use and public services.
There is a continuing need for the modernizing of public facilities to improve services and accommodate the changes in the community plan. However, the community’s amenities and environmental quality must be adequately protected. Cost and equitable distribution are major issues in the provision of public facilities. It is essential that priorities are established and new and alternate funding sources
16 City of Los Angeles Palms-Mar Vista-Del Rey Community Plan. Adopted September 1997. Available at: http://cityplanning.lacity.org/complan/westla/plmpage.htm 17 City of Los Angeles Palms-Mar Vista-Del Rey Community Plan. Adopted September 1997. Available at: http://cityplanning.lacity.org/complan/westla/plmpage.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-6 Draft EIR Subchapter 3J. Land Use and Planning
are located. Additionally, public and private development must be coordinated to avoid costly duplication so that more services can be provided at less cost.
Chapter III, Goal 5, Objective 5-1 of the Palms – Mar Vista – Del Rey Community Plan contains the following policy for schools with regard to the shared use of existing schools for the general public after hours and on weekends:
The Los Angeles Unified School District (LAUSD) administers public schools in the Palms-Mar Vista-Del Rey Community Plan area. There are 12 Elementary schools and four Junior High Schools within the community. The Plan encourages shared use of existing school facilities for the general public after hours and on weekends. School grounds should be made available to the public for after school hour recreational uses.
Chapter IV of the Palms – Mar Vista – Del Rey Community Plan contains the following policy for schools with regard to coordination opportunities for public agencies:
Consider siting new schools, when needed, on vacant parcels rather than acquiring sites with existing uses which may be displaced. Plan for a System of Neighborhood Councils
The City of Los Angeles Department of Neighborhood Empowerment, through a system of Citywide Neighborhood Councils, provides operational support to facilitate the sharing of resources among Certified Neighborhood Councils, including, but not limited to, meeting and office space, office equipment and mail and communications in order to communicate among constituents, certified neighborhood councils, City departments, and governing officials.18
Neighborhood councils are city-certified local groups made up of people who live, work, own property, or have some other connection to a neighborhood. Neighborhood council board members are elected or selected to their positions by the neighborhoods themselves. Neighborhood councils are funded by the City to engage in activities that may include but not be limited to creating events and programs that respond to the unique needs of their community or advocating on behalf of the issues they care about such as crime, roads and streets, the creation of safe spaces for children, gangs, and economic development. Neighborhood councils also receive advance notice of issues and projects that are important to them and their neighborhoods so they can understand, discuss them, and voice the opinions of the neighborhood to the City before final decisions are made. The neighborhood council representing the neighborhood of the proposed project is the Mar Vista Neighborhood Council.
City of Los Angeles Municipal Code – Zoning Plan
The City of Los Angeles Zoning Plan designates, regulates, and restricts the location and use of buildings, structures and land, for agriculture, residence, commerce, trade, industry or other purposes in order to encourage the most appropriate use of land, conserve and stabilize the value
18 City of Los Angeles Department of Neighborhood Empowerment. 30 May 2001. Plan for a Citywide System of Neighborhood Councils. Available at: http://empowerla.org/wp-content/uploads/2012/12/Plan_Amended_12- 18-131.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-7 Draft EIR Subchapter 3J. Land Use and Planning of property, provide adequate open spaces for light and air, prevent and fight fires, and promote the general welfare.19 The Public Facilities (PF) zone is for the use and development of publicly owned land, including fire and police stations, public libraries not located inside public parks, post office and related facilities, public health facilities such as clinics and hospitals, public elementary and secondary schools, public parking facilities under freeway rights-of-way, and farming and nurseries under power transmission rights-of-way, in both the City’s General Plan20 and Zoning Plan.21
3J.2 EXISTING CONDITIONS
Mark Twain Middle School is located within a predominantly residential area consisting of single- family residential homes, near other existing school facilities, and commercial uses on major arterial roads. The proposed project site is located in the northern section of the Palms – Mar Vista – Del Rey Community Plan area. The surrounding Palms – Mar Vista – Del Rey Community Plan General Plan designations are Low Residential and Low Medium Residential, and General Commercial on Venice Boulevard. The surrounding zoning is R1, RD2-1, and C2-1 on Venice Boulevard.
The proposed project site is located within the City of Los Angeles Coastal Transportation Corridor Specific Plan, which provides guidelines for commercial and industrial development within the Corridor. The Corridor Specific Plan does not provide recommendation for public facilities.22
The Coastal Zone is located approximately 0.5 mile to the west of the proposed project site within the City of Los Angeles–administered Venice Local Coastal Program Land Use Plan.23 The Coastal Zone is the area generally bounded by Marine Street on the north, the city-county boundary, Washington Boulevard and Via Marina on the south, Lincoln Boulevard and Via Dolce on the east, and the Pacific Ocean on the west. The project site is located approximately 0.5 mile to the east of the Coastal Zone. As a result, the proposed project would not be subject to the requirements of the California Coastal Act.
19 American Legal Publishing Corporation. September 2013. City of Los Angeles, California Code Resources. Planning and Zoning (Chapter 1 of the Municipal Code. Chapter 1, Article 2, Specific Planning – Zoning Comprehensive Zoning Plan.” Available online at: http://www.amlegal.com/library/ca/losangeles.shtml 20 City of Los Angeles Department of City Planning. n.d. City of Los Angeles Zone Information and Map Access System (ZIMAS). ZIMAS available online at: http://zimas.lacity.org/ Main website: http://cityplanning.lacity.org/ 21 American Legal Publishing Corporation. 2013. Los Angeles Municipal Code, Chapter I (Planning and Zoning Code), Article 2, Section 12.19. Available at: http://www.amlegal.com/nxt/gateway.dll/California/lapz/municipalcodechapteriplanningandzoningco/chapterig eneralprovisionsandzoning/article2specificplanning- zoningcomprehen/sec1219%E2%80%9Cm2%E2%80%9Dlightindustrialzone?f=templates$fn=default.htm$3. 0$vid=amlegal:lapz_ca$anc=JD_12.19. 22 City of Los Angeles Coastal Transportation Corridor Specific Plan. Adopted 22 September 1993. Available at: http://cityplanning.lacity.org/complan/specplan/sparea/coastaltranspage.htm 23 City of Los Angeles. 14 June 2001. Venice Local Coastal Program Land Use Plan. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-8 Draft EIR Subchapter 3J. Land Use and Planning
Habitat Conservation Plans and Multi-Species Habitat Conservation Areas
There are no existing or proposed HCPs or Multi-Species Habitat Conservation Areas that include the Mark Twain Middle School campus.24
3J.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of three questions when addressing the potential for significant impacts to land use and planning. Would the proposed project: a. Physically divide an established community? b Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c. Conflict with any applicable habitat conservation plan or natural community conservation plan?
3J.4 IMPACT ANALYSIS
Impact 3J-a: Would the proposed project physically divide an established community?
No Impact
The proposed project is located on the existing Mark Twain Middle School campus in the 5,257- acre Palms – Mar Vista – Del Rey Community Plan Area. The proposed new development is wholly contained within the existing Mark Twain Middle School campus and would not physically divide the Palms – Mar Vista – Del Rey Community Plan Area. Therefore, the proposed project would not result in significant impacts to land use and planning with regard to the physical division of an established community.
Impact 3J-b: Would the proposed project conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?
No Impact
The proposed project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project because it is exempt from local land use and zoning regulations. Even if it were not so exempt, the City of Los Angeles Zoning Code designates the proposed project site as PF. The proposed K–5 school facilities are a permitted use within the PF zone. The PF designation is applied to property where the ownership and use is by a government
24 California Department of Fish and Wildlife. Accessed 24 November 2014. Natural Community Conservation Planning (NCCP). Available at: http://www.dfg.ca.gov/habcon/nccp/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-9 Draft EIR Subchapter 3J. Land Use and Planning agency and includes such public facility uses as libraries, parks, schools, fire and police stations.25 The proposed project would add additional school facilities and programming to an existing school site, which is allowed and encouraged by the Palms – Mar Vista – Del Rey Community Plan. Therefore, the proposed project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project even if the proposed project were not exempt from the City's local zoning and land use plans and regulations.
Impact 3J-c: Would the proposed project conflict with any applicable habitat conservation plan or natural community conservation plan?
No Impact
The proposed project would not result in impacts to land use and planning in relation to a conflict with any applicable HCP or NCCP. The proposed project would be located on the existing Mark Twain Middle School campus. There is no intact native habitat that exists on the property or in the surrounding vicinity.26 The proposed project site is not located within an NCCP designated or proposed for designation by CDFW.27 Additionally, the proposed project site is not located within an HCP designated, or proposed for designation, by USFWS.28 Therefore, there would be no impacts to land use and planning related to a conflict with any adopted HCP or NCCP.
3J.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts related to land use and planning. Therefore, there would be no cumulative impacts.
3J.6 MITIGATION MEASURES
The proposed project would not result in significant impacts related to land use and planning. Therefore, the consideration of mitigation measures is not required.
3J.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3J-a through 3J-c: No impact.
25 City of Los Angeles Palms-Mar Vista-Del Rey Community Plan. Adopted September 1997. Available at: http://cityplanning.lacity.org/complan/westla/plmpage.htm 26 Sapphos Environmental, Inc., October 2, 2014, site visit. 27 California Department of Fish and Wildlife. Accessed 23 November 2014. Natural Community Conservation Planning (NCCP). Available at: http://www.dfg.ca.gov/habcon/nccp/ 28 California Department of Fish and Wildlife. Accessed 23 November 2014. Natural Community Conservation Planning (NCCP). Available at: http://www.dfg.ca.gov/habcon/nccp/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3J-10 Draft EIR SUBCHAPTER 3K Mineral Resources
This analysis is undertaken to determine if the proposed project may have a significant impact to mineral resources, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to mineral resources has been analyzed in accordance with the methodologies provided by California Division of Mines and Geology publications.2
3K.1 REGULATORY FRAMEWORK
Federal
There are no applicable federal regulations related to mineral resources for the proposed project.
State
Surface Mining and Reclamation Act of 1975 (SMARA)
SMARA states that all mining activities in operation as of January 1976 and those placed in operation after that date shall be required to submit a surface mining and reclamation plan, which shall provide for appropriate measures to rehabilitate the site prior to its abandonment. The California Division of Mines and Geology, Department of Conservation provides a special publication, Mines and Mineral Producers Active in California (1988–1989), that contains the names and addresses, commodities, and locations of 1,012 mines believed to have produced mineral commodities in California during 1988– 1989.3
Division of Oil, Gas, and Geothermal Resources (DOGGR)
Within the Department of Conservation, DOGGR supervises the drilling, operation, maintenance, and abandonment of oil, gas, and geothermal wells to protect the environment, public health and safety, and to encourage good conservation practices. DOGGR collects data on the location of groundwater, oil, gas, and geothermal resources, and records the location of all drilled and abandoned wells.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 California Department of Conservation. Accessed October 2014. SMARA Mineral Land Classification Map. Available at: http://www.consrv.ca.gov/cgs/minerals/mlc/pages/index.aspx 3 California Department of Conservation, Division of Mines and Geology. 1990. Mines and Mineral Producers Active in California (1988–1989). Los Angeles, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3K-1 Draft EIR Subchapter 3K. Mineral Resources
California Geologic Survey (CGS)
Based on guidelines adopted by the CGS, areas known as Mineral Resource Zones (MRZ) are classified according to the presence or absence of significant deposits, as defined below. These classifications indicate the potential for a specific area to contain significant mineral resources.
MRZ-1: Areas where available geologic information indicates there is little or no likelihood for presence of significant mineral resources.
MRZ-2: Areas underlain by mineral deposits where geologic data indicate that significant measured or indicated resources are present or where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists.
MRZ-3: Areas containing known mineral occurrences of undetermined mineral resource significance.
MRZ-4: Areas of no known mineral occurrences where geologic information does not rule out the presence or absence of significant mineral resources.
Much of the area within the MRZ sites in Los Angeles was developed with structures prior to the MRZ classification and, therefore, is unavailable for extraction.
Local
There are no applicable local regulations related to mineral resources for the proposed project.
3K.2 EXISTING CONDITIONS
Mineral Resource Zones
According to the CGS, the proposed project site is located within a designated MRZ-3 zone. MRZ-3 zones contain known mineral occurrences of undetermined mineral resource significance. The proposed project site most likely received this designation as a result of underlying sand and gravel deposits. However, the City, through the Land Use Element of the General Plan, has designated the proposed project property as Public Facility, and the surrounding properties are designated as predominantly Low Density Residential and some Low Medium Multiple Family Residential. Therefore, while underlying sand and gravel deposits could potentially be used for construction purposes, they are not available for commercial mining operations.
Regionally and Locally Important Mineral Resources
Based on a review of California Division of Mines and Geology publications, there are no known mineral resources of statewide or regional importance located within the proposed project site.4,5
4 California Department of Conservation, Division of Mines and Geology. 1966. Minerals of California Volume Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3K-2 Draft EIR Subchapter 3K. Mineral Resources
Based on a review of the Conservation Element of the City of Los Angeles General Plan, there are no known mineral resource recovery sites of local importance located within the proposed project site.6,7,8 The nearest active mine to the project site is the Atkinson Brick Company Pit, located at 1601 N Central Ave in Lynwood, California, approximately 12.5 miles to the southeast of the proposed project site.
3K.3 THRESHOLDS OF SIGNIFICANCE
Would the project: a. Result in the loss of availability of known mineral resource that would be a future value to the region and the residents of the state? b. Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use?
3K.4 IMPACT ANALYSIS
Impact 3K-a: Would the proposed project result in the loss of availability of known mineral resource that would be a future value to the region and the residents of the state?
No Impact
The proposed project would not be expected to result in impacts to mineral resources in relation to the loss of availability of a known mineral resource. Based on a review of California Division of Mines and Geology publications, there are no known mineral resources of statewide or regional importance located within the proposed project site.9,10 The proposed project site is located within a designated MRZ-3 zone, characterized as an area containing known mineral occurrences of undetermined mineral resource significance. However, structures and buildings constructed in conjunction with the proposed project would be built in the near surface environment, and subsurface resources would remain in situ.
(1866-1966). Bulletin 189. Los Angeles, CA. 5 California Department of Conservation, Division of Mines and Geology. 1990. Mines and Mineral Producers. Los Angeles, CA. 6 California Department of Conservation, Division of Mines and Geology. 1966. Minerals of California Volume (1866-1966). Bulletin 189. Los Angeles, CA. 7 California Department of Conservation, Division of Mines and Geology. 1990. Mines and Mineral Producers. Los Angeles, CA. 8 City of Los Angeles Planning Department. Adopted 26 September 2001. City of Los Angeles General Plan. Conservation Element. Available at: http://planning.lacity.org/cwd/gnlpln/ConsvElt.pdf 9 California Department of Conservation, Division of Mines and Geology. 1966. Minerals of California Volume (1866-1966). Bulletin 189. Los Angeles, CA. 10 California Department of Conservation, Division of Mines and Geology. 1990. Mines and Mineral Producers. Los Angeles, CA. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3K-3 Draft EIR Subchapter 3K. Mineral Resources
The proposed project site is not located within a designated Oil Drilling/Surface Mining Supplemental Use District, or City-designated Oil Field/Drilling Area. No mineral or oil extraction operations occur in or around the proposed project site. The potential mineral resource underlying the proposed project site consists of sand and gravel, with an undetermined significance. However, much of the project and surrounding areas have been developed with structures and are inaccessible for mining extraction. Therefore, the proposed project would not be expected to result in significant impacts to a known mineral resource.
Impact 3K-b: Would the proposed project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use?
No Impact
The proposed project would not result in significant impacts to a locally important mineral recovery site because the proposed project is exempt from such local regulatory requirements. Even if the proposed project were not so exempt, there are no mineral recovery sites delineated within the vicinity of the proposed project site in the Conservation Element of the City of Los Angeles General Plan,11 the Palms – Mar Vista – Del Rey Community Plan,12 and the Venice Community Plan. Therefore, the proposed project would not result in significant impacts to a known mineral resource with or without the proposed project's Exemption.
3K.5 CUMULATIVE IMPACT
The proposed project would not result in significant impacts to mineral resources. Therefore, there would be no cumulative impact.
3K.6 MITIGATION MEASURES
The proposed project will be in compliance with provisions of the California Building Code, California Administrative Code, California Educational Code, and any other additional regional, state, and federal regulations. All activities and development on the proposed project site would be subject to uniform site development and construction standards that are designed to protect public safety. Therefore, impacts related to mineral resources would be less than significant, and no mitigation measures are required.
3K.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3K-a and 3K-b: No impact.
11 City of Los Angeles Planning Department. Adopted 26 September 2001. City of Los Angeles General Plan. Conservation Element. Available at: http://planning.lacity.org/cwd/gnlpln/ConsvElt.pdf 12 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3K-4 Draft EIR SUBCHAPTER 3L
Noise
This analysis is undertaken to determine if the proposed project may have a significant impact on ambient noise levels, which would require the consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1
This section evaluates the potential impacts of the proposed project on noise through examination of documentation of on-site ambient noise levels and modeling of anticipated noise level based on the results of the Traffic Impact Analysis (Appendix H, Traffic Study) and other relevant data.2
Baseline conditions were established using data collected on and in the vicinity of the proposed project site. Noise levels were collected using a Larson Davis 706RC Spark that was calibrated prior to use in the field. Six monitoring locations were established, one located at the nearest sensitive receptor to the project site, three within a 500-foot radius of the proposed project location, one within the surrounding neighborhood, and one at the nearest major intersection of Venice Boulevard and Walgrove Avenue. The data collected were used to establish baseline conditions, as documented in the section. Terminology
Noise is most often defined as unwanted sound. Although sound can be easily measured, the perception of noise and the physical response to sound complicate the analysis of its impact on people. People judge the relative magnitude of sound sensation in subjective terms such as “noisiness” or “loudness.” The following are brief definitions of terminology used in this chapter:
Sound. A disturbance created by a vibrating object, which, when transmitted by pressure waves through a medium such as air, is capable of being detected by a receiving mechanism, such as the human ear or a microphone.
Noise. Sound that is loud, unpleasant, unexpected, or otherwise undesirable.
Decibel (dB). A unitless measure of sound on a logarithmic scale.
A-Weighted Decibel (dBA). An overall frequency-weighted sound level in decibels that approximates the frequency response of the human ear.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 Los Angeles Unified School District, Office of Environmental Health and Safety. California Environmental Quality Act Specification Manual. Revised June 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-1 Draft EIR Subchapter 3L. Noise
Equivalent Continuous Noise Level (Leq). The mean of the noise level, energy-averaged over the measurement period.
Day-Night Level (Ldn). The energy-average of the A-weighted sound levels occurring during a 24- hour period, with 10 dB added to sound levels from 10:00 PM to 7:00 AM.
Community Noise Equivalent Level (CNEL). The energy-average of the A-weighted sound levels occurring during a 24-hour period, with 5 dB added to the levels from 7:00 PM to 10:00 PM and 10 dB added from 10:00 PM to 7:00 AM. Characteristics of Sound
Sound is a pressure wave transmitted through the air. It is described in terms of loudness or amplitude (measured in decibels), frequency or pitch (measured in Hertz [Hz] or cycles per second), and duration (measured in seconds or minutes). The standard unit of measurement of the loudness of sound is the decibel (dB). Changes of 1 to 3 dB are detectable under quiet, controlled conditions and changes of less than 1 dBA are usually indiscernible. A 3 dB change in noise levels is considered the minimum change that is detectable with human hearing in outside environments. A change of 5 dB is readily discernible to most people in an exterior environment, and a 10 dBA change is perceived as a doubling (or halving) of the sound.
The human ear is not equally sensitive to all frequencies. Sound waves below 16 Hz are not heard at all and are “felt” more as a vibration. Similarly, though people with extremely sensitive hearing can hear sounds as high as 20,000 Hz, most people cannot hear above 15,000 Hz. In all cases, hearing acuity falls off rapidly above about 10,000 Hz and below about 200 Hz.
Noise is defined as unwanted sound and is known to have several adverse effects on people, including hearing loss, speech and sleep interference, physiological responses, and annoyance. Based on these known adverse effects, the federal government, State of California, and many local governments have established criteria to protect public health and safety and to prevent disruption of certain human activities. Measurement of Sound
Sound intensity is measured through the A-weighted measure to correct for the relative frequency response of the human ear. That is, an A-weighted noise level deemphasizes low and very high frequencies of sound similar to the human ear’s de-emphasis of these frequencies.
Unlike units of measure that are computed with arithmetic functions (such as adding or subtracting numbers), decibels are measured and processed on a logarithmic scale. The logarithmic scale reflects the subjective effects of changes in sound pressure levels; specifically, an increase of 10 dB is 10 times more intense than 1 dB, a 20 dB increase is 100 times more intense, and 30 dB is 1,000 times more intense (Table 3L-1, Change in Apparent Loudness). A sound as soft as human breathing is about 10 times greater than 0 dB. The decibel system of measuring sound gives a rough connection between the physical intensity of sound and its perceived loudness to the human ear. Ambient sounds generally range from 30 dBA (very quiet) to 100 dBA (very loud).
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-2 Draft EIR Subchapter 3L. Noise
Table 3L-1: Change in Apparent Loudness ± 3 dB Threshold of human perceptibility ± 5 dB Clearly noticeable change in noise level ± 10 dB Half or twice as loud ± 20 dB Much quieter or louder SOURCE: Bies, David A., and Colin H. Hansen. 2009. Engineering Noise Control: Theory and Practice. 4th ed. New York, NY: Spon Press.
Sound levels decrease as the distance from their source increases. Sound dissipates exponentially with distance from the noise source. This phenomenon is known as “spreading loss.” For a single point source, sound levels decrease by approximately 6 dB for each doubling of distance from the source. This drop-off rate is appropriate for noise generated by on-site operations from stationary equipment or activity at a project site. If noise is produced by a line source, such as highway traffic, the sound decreases by 3 dB for each doubling of distance in a hard site environment.3 Line source noise in a relatively flat environment with absorptive vegetation decreases by 4.5 dB for each doubling of distance.
Time variation in noise exposure is typically expressed in terms of a steady-state energy level equal to the energy content of the time varying period (called Leq) or, alternately, as a statistical description of the sound level that is exceeded over some fraction of a given observation period. For example, the L50 noise level represents the noise level that is exceeded 50 percent of the time. Half the time the noise level exceeds this level and half the time the noise level is less than this level. This level also represents the level that is exceeded 30 minutes in an hour. Similarly, the L2, L8, and L25 values represent the noise levels that are exceeded 2, 8, and 25 percent of the time or 1, 5, and 15 minutes per hour. These “L” values are typically used to demonstrate compliance for stationary noise sources with a city’s noise ordinance, as discussed below. Other values typically noted during a noise survey are the Lmin and Lmax. These values represent the minimum and maximum root-mean-square noise levels obtained over the measurement period.
Because community receptors are more sensitive to unwanted noise intrusion during the evening and at night, state law and the City require that, for planning purposes, an artificial dB increment be added to quiet time noise levels in a 24-hour noise descriptor called the CNEL or Day-Night Noise Level (Ldn). The CNEL descriptor requires that an artificial increment of 5 dBA be added to the actual noise level for the hours from 7:00 PM to 10:00 PM and 10 dBA for the hours from 10:00 PM to 7:00 AM. The Ldn descriptor uses the same methodology except that there is no
3 Surface type or ground cover is defined as the “hardness” or “softness” of the surrounding area. “Hard site environment” is areas with acoustically hard ground (e.g., pavement or water). Distance attenuation from a line source (i.e., roadway or railway) with a hard site environment is 3 dB per doubling of distance (dB/DD). “Soft site environment” is areas with acoustically soft ground (e.g., lawn or loose dirt or agricultural uses). Ground cover can affect the sound propagation rate by as much as an additional 1.5 dB/DD. (Note that this rate occurs only when both the noise source and the receiver are close to the ground and the terrain between the two is flat and soft.) As a result of this additional attenuation, the line-source sound levels decrease at a rate of 4.5 dB/DD at soft sites. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-3 Draft EIR Subchapter 3L. Noise artificial increment added to the hours between 7:00 PM and 10:00 PM. Both descriptors give roughly the same 24-hour level, with the CNEL being only slightly more restrictive (i.e., higher).4 Psychological and Physiological Effects of Noise
Physical damage to human hearing begins at prolonged exposure to noise levels higher than 85 dBA. Exposure to high noise levels affects our entire system, with prolonged noise exposure in excess of 75 dBA increasing body tensions and thereby affecting blood pressure, functions of the heart, and the nervous system. In comparison, extended periods of noise exposure above 90 dBA could result in permanent hearing damage. Vibration Fundamentals
Vibration is a trembling, quivering, or oscillating motion of the earth. Like noise, vibration is transmitted in waves, but in this case through the earth or solid objects. Unlike noise, vibration is typically of a frequency that is felt rather than heard.
Vibration can be either natural as in the form of earthquakes, volcanic eruptions, sea waves, landslides, or manmade as from explosions, the action of heavy machinery or heavy vehicles such as trains. Both natural and manmade vibration may be continuous such as from operating machinery, or transient as from an explosion.
Humans are generally more perceptive to vibration than structures, humans will normally begin to notice vibration at peak particle velocities of 0.08 inches per second and begin to be annoyed or distracted by vibrations at peak particle velocities of 0.10 inches per second (Table 3L-2, Human Reaction to Typical Vibration Levels). As with noise, vibration can be described by both its amplitude and frequency. Amplitude may be characterized in three ways, including displacement, velocity, and acceleration. Particle displacement is a measure of the distance that a vibrated particle travels from its original position and, for the purposes of soil displacement, is typically measured in inches or millimeters. Particle velocity is the rate of speed at which soil particles move in inches per second or millimeters per second. Particle acceleration is the rate of change in velocity with respect to time and is measured in inches per second or millimeters per second. Typically, particle velocity (measured in inches or millimeters per second_ and/or acceleration (measured in gravities) are used to describe vibration.
4 Ldn and CNEL values rarely differ by more than 1 dB. As a matter of practice, Ldn and CNEL values are considered equivalent and are treated as such in this assessment. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-4 Draft EIR Subchapter 3L. Noise
Table 3L-2: Human Reaction to Typical Vibration Levels Vibration Level Peak Particle Velocity (in/sec) Human Reaction Effect on Buildings Threshold of perception, possibility of Vibrations unlikely to cause damage of any type 0.006–0.019 intrusion Vibrations readily perceptible Recommended upper level of vibration to which 0.08 ruins and ancient monuments should be subjected Level at which continuous vibration Virtually no risk of “architectural” (i.e., not 0.10 begins to annoy people structural) damage to normal buildings Vibrations annoying to people in Threshold at which there is a risk to “architectural” 0.20 buildings damage to normal dwelling—houses with plastered walls and ceilings Vibrations considered unpleasant by Vibrations at a greater level than normally expected people subjected to continuous vibrations from traffic, but would cause “architectural” damage 0.4–0.6 and unacceptable to some people and possibly minor structural damage walking on bridges
Vibration also varies in frequency, and this affects perception. Typical construction vibrations fall in the 10 to 30 Hz range, usually around 15 Hz. Traffic vibrations exhibit a similar range of frequencies; however, due to their suspension systems, buses often generate frequencies around 3 Hz at high vehicle speeds. It is less common, but possible, to measure traffic frequencies above 30 Hz.
The way in which vibration is transmitted through the earth is called propagation. Propagation of ground-borne vibrations is complicated and difficult to predict because of the endless variations in the soil through which waves travel. There are three main types of vibration propagation: surface, compression, and shear waves. Surface waves, or Raleigh waves, travel along the ground’s surface. These waves carry most of their energy along an expanding circular wave front, similar to ripples produced by throwing a rock into a pool of water. P-waves, or compression waves, are body waves that carry their energy along an expanding spherical wave front. The particle motion in these waves is longitudinal (i.e., in a “push-pull” fashion).
P-waves are analogous to airborne sound waves. S-waves, or shear waves, are also body waves that carry energy along an expanding spherical wave front. However, unlike P-waves, the particle motion is transverse or “side-to-side and perpendicular to the direction of propagation.” As vibration waves propagate from a source, the energy is spread over an ever-increasing area, such that the energy level striking a given point is reduced with the distance from the energy source. This geometric spreading loss is inversely proportional to the square of the distance. Wave energy is also reduced with distance as a result of material damping in the form of internal friction, soil layering, and void spaces. The amount of attenuation provided by material damping varies with soil type and condition as well as the frequency of the wave.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-5 Draft EIR Subchapter 3L. Noise
3L.1 REGULATORY FRAMEWORK Federal
Noise Control Act of 1972
The adverse impacts of noise were officially recognized by the federal government in the Noise Control Act of 1972,5 which serves three purposes:
Promulgating noise emission standards for interstate commerce;
Assisting state and local abatement efforts; and
Promoting noise education and research.
The Office of Noise Abatement and Control (ONAC) was initially tasked with implementing the Noise Control Act. However, the ONAC has since been eliminated, leaving the development of federal noise policies and programs to other federal agencies and interagency committees. For example, the Occupational Safety and Health Administration (OSHA) agency prohibits exposure of workers to excessive sound levels. The Federal Highway Administration (FHWA) has adopted and promulgated noise abatement criteria for highway construction projects. The federal government encourages local jurisdictions to use their land use regulatory authority to site new development to minimize potential noise impacts. State
California Code of Regulations, Title 5, Section 14040(q)
Under Title 5,6 the California Department of Education (CDE) regulations require the school district to consider noise in the site selection process. As recommended by CDE guidance, if a school district is considering a potential school site near a freeway or other source of noise, it should hire an acoustical engineer to determine the level of sound that the site is exposed to and to assist in designing the school should that site be chosen.
California Code of Regulations, Title 24, Part 2
Current law states that every local agency enforcing building regulations, such as cities and counties, must adopt the provisions of the California Building Code (CBC) within 180 days of its publication. The publication date of the CBC is established by the California Building Standards Commission. The most recent building standard adopted by the legislature and used throughout the state is the 2013 version, often with local, more restrictive amendments that are based on local geographic, topographic, or climatic conditions.7 The State of California’s noise insulation standards are codified in the CBC. These noise standards are for new construction in California for the purposes of interior compatibility with exterior noise sources. The regulations specify that
5 42 U.S.C., Noise Control Act of 1972, § 4901-4918. 6 Title 5. Education, Division 1. California Department of Education, Chapter 13. School Facilities and Equipment, Subchapter 1. School Housing, Article 2. School Sites, 14010. Standards for School Site Selection. Available at: http://government.westlaw.com/linkedslice/default.asp?SP=CCR-1000 7 The 2013 CBC took effect on 1 January 2014. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-6 Draft EIR Subchapter 3L. Noise acoustical studies must be prepared when noise-sensitive structures, such as residential, schools, or hospitals, are near major transportation noises, and where such noise sources create an exterior noise level of 60 dBA CNEL or higher. Acoustical studies that accompany building plans must demonstrate that the structure has been designed to limit interior noise in habitable rooms to acceptable noise levels. For new residential buildings, schools, and hospitals, the acceptable interior noise limit for new construction is 45 dBA CNEL. Local
City of Los Angeles General Plan Noise Element
The City of Los Angeles includes noise standards and guidelines in its general plan noise element and the municipal code, as discussed below. The city’s noise element is the guiding document for the City’s noise policy. The City classifies land uses for noise compatibility as acceptable, conditionally acceptable, normally unacceptable, and unacceptable depending on the noise level and land use. Noise levels of less than 60 dBA CNEL are classified as acceptable for land uses that are sensitive to noise. Noise-sensitive land uses include residential, schools, libraries, churches, nursing homes, hospitals, and open space/recreation areas. Noise levels from 60 to 70 dBA CNEL are “conditionally acceptable” for noise-sensitive uses, meaning a detailed analysis of noise mitigation is required and noise insulation features should be included in the project design. Noise levels above 70 dBA CNEL are considered by the city to be “normally unacceptable” or “unacceptable” for noise sensitive land uses.8
Municipal Code
The City’s noise ordinance, codified in its municipal code, is designed to protect people from objectionable non-transportation noise sources such as music, machinery, pumps, and air conditioners.9 These standards do not gauge the compatibility of developments in the noise environment, but provide restrictions on the amount and duration of noise generated at a property, as measured at the property line of the noise receptor. According to the City’s noise ordinance, stationary noise sources such as radios, television sets, and similar devices (Section 112.01), and air conditioning, refrigeration, heating, pumping, and filtering equipment (Section 112.02) are prohibited from causing the ambient noise level to increase by more than 5 dB (Table 3L.1-1, City of Los Angeles Ambient Noise Criteria). Where actual ambient levels are lower than those established by the City of Los Angeles Ambient Noise Criteria, the presumed ambient noise levels are used to characterize the baseline condition.10
8 City of Los Angeles General Plan Noise Element, City of Los Angeles Department of City Planning, 1999. 9 City of Los Angeles Municipal Code, Chapter 11, Noise Regulation. 10 City of Los Angeles Municipal Code, Chapter 11, Noise Regulation. Article 1, Section 111.03, Minimum Ambient Noise Levels. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-7 Draft EIR Subchapter 3L. Noise
Table 3L.1-1: City of Los Angeles Ambient Noise Criteria Zoning Categories Time Period Exterior Noise Limits (dBA Leq) Residential: A1, A2, RA, RE, RS, RD, RW1, 10:00 PM to 7:00 AM 40 RW2, R1, R2, R3, R4, and R5 7:00 AM to 10:00 PM 50 Commercial: P, PB, CR, C1, C1.5, C2, C4, 10:00 PM to 7:00 AM 55 C5, and CM 7:00 AM to 10:00 PM 60 Industrial: M1, MR1, and MR2 10:00 PM to 7:00 AM 55 7:00 AM to 10:00 PM 60 Industrial: M2 and M3 10:00 PM to 7:00 AM 65 7:00 AM to 10:00 PM 65 NOTE: Residential: A1 and A2: Agriculture; RA and RS: Suburban; RE Residential Estate; RD: Restricted Density Multiple Dwelling; RW1 and RW2: Residential Waterways. R1: One-family; R2: Two-family; R3, R4, and R5: Multiple Dwelling. Commercial: P: Automobile Parking; PB Parking Building; CR, C1, and C1.5: Limited Commercial; C2, C4, and C5: Commercial Zone; CM: Commercial Manufacturing. Light Industrial: M1: Limited Industrial; MR1: Restricted Industrial; MR2: Restricted Light Industrial, M2: Light Industrial; M3: Heavy Industrial.
Trash collecting within 200 feet of a residential building is prohibited between the hours of 9:00 PM and 6:00 AM.11 In addition, loading/unloading of commercial vehicles is prohibited between the hours of 10:00 PM and 7:00 AM within 200 feet of a residential building.12
Construction Noise Standards
Section 41.40 and Section 112.05 of the Municipal Code govern noise limits and the hours of construction activities in the city.
Section 41.40 of the Municipal Code specifies hours allowed for construction activities for the purposes of noise control. Construction activities are constrained to the daytime hours from 7:00 AM to 9:00 PM Monday through Friday, 8:00 AM to 6:00 PM on Saturdays and national holidays, and prohibited on Sundays.
Section 112.05 of the Municipal Code also specifies the maximum noise level for construction equipment. In accordance with this section and Section 41.40, construction equipment, including augers, loaders, power shovels, cranes, derricks, motor graders, paving machines, off-highway trucks, ditchers, trenchers, compactors, scrapers, wagons, pavement breakers, compressors, and pneumatic or other powered equipment items shall not produce a maximum noise level exceeding 75 dBA at a distance of 50 feet between the hours of 7:00 AM and 9:00 PM. The City allows construction noise exceeding these noise limits if compliance is technically infeasible. However, the burden of proving that compliance is technically infeasible includes showing that noise
11 City of Los Angeles Municipal Code, Chapter 11, Noise Regulation. Article 1, Section 113.01, Rubbish and Garbage Collection and Disposal. 12 City of Los Angeles Municipal Code, Chapter 11, Noise Regulation. Article 1, Section 114.03, Vehicles-Loading and Unloading. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-8 Draft EIR Subchapter 3L. Noise limitations cannot be complied with despite the use of mufflers, shields, sound barriers, and/or other noise reduction devices or techniques during the operation of the equipment.
LAUSD Noise Standards
LAUSD has established noise standards (Table 3L.1-2, Acceptable Operational Noise Levels Established by LAUSD) to protect students and faculty/staff from noise impacts generated by traffic in terms of Leq. These standards were established based on regulations set forth by the California Department of Transportation and the City of Los Angeles. LAUSD has indicated that a 3-dBA Ldn increase would represent a permanent increase in ambient noise levels when projected ambient noise levels (ambient noise levels after implementation of the proposed project) would exceed acceptable noise levels as adopted in local agency noise ordinances or general plan goals. LAUSD has also indicated that a substantial temporary significant noise increase would result from activity that generates noise levels above 75 dBA at a sensitive receptor.
Table 3L.1-2: Acceptable Operational Noise Levels Established by LAUSD
Location L10 Noise Level Leq Noise Level Exterior 70 dBA 67 dBA Interior 55 dBA 45 dBA SOURCE: Los Angeles Unified School District, Office of Environmental Health and Safety. California Environmental Quality Act Specification Manual. Revised January 2007.
Table 3L.1-3, Project Design Feature Compliance Thresholds, lists project design features, including the applicable noise related topic and the associated trigger for compliance. All of the measures listed in the table are applicable to the proposed project.
Table 3L.1-3: Project Design Feature Compliance Thresholds PDF # Topic Trigger for Compliance AQ-1 Construction Emissions If project requires large construction equipment N-1 Noise-Sensitive Land Uses Where project-related school noise levels will exceed local noise standards, policies, or ordinances. N-2 Noise-Sensitive Land Uses If construction projects occur on an existing school campus N-3 Construction Noise If project requires exterior construction and/or heavy equipment N-4 Construction Noise If construction project requires the use of portable equipment and/or outside storage and/or maintenance of equipment N-5 Construction Noise If project requires exterior construction and/or heavy equipment N-6 Construction Noise If project requires exterior construction N-7 Construction Noise If project requires exterior construction
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-9 Draft EIR Subchapter 3L. Noise
City of Los Angeles CEQA Thresholds Guide
The Los Angeles CEQA thresholds guide provides criteria to determine noise impacts. A project would normally have a significant impact on noise levels from construction if:
Construction activities lasting more than one day would exceed existing ambient exterior noise levels by 10 dBA or more at a noise sensitive use.
Construction activities lasting more than 10 days in a 3-month period would exceed existing ambient exterior noise levels by 5 dBA or more at a noise sensitive use.
Construction activities would exceed the ambient noise level by 5 dBA at a noise sensitive use between the hours of 9:00 PM and 7:00 AM Monday through Friday, before 8:00 AM or after 6:00 PM on Saturday, or at any time on Sunday.
Other Recommendations Related to Classroom Acoustics
Los Angeles Unified School District School Design Guide
In January 2014, the LAUSD prepared the School Design Guide to establish and sustain consistent representation of requirements and standards, presenting design guidelines and criteria for the planning, design, and technical development of new schools and modernization. The School Design Guide is updated yearly and edited with the input from various departments. LAUSD states that background noise shall be defined and measures as specified in ANSI Standard 2.60. The following criteria are established in the School Design Guide:13
1. The background sound level from traffic noise or playground noise in classrooms and teaching spaces must not exceed 45 dBA, with a target of 40 dBA.
2. The background sound level from traffic noise or playground noise in a multi-purpose room must not exceed 40 dBA, with a preference of 35 dBA.
3. Classroom and teaching spaces reverberation must not surpass 0.60 seconds (RT 60).
3L.2 EXISTING CONDITIONS
Within Los Angeles County, the major noise sources are generally transportation-related (i.e., vehicles, railroads, and aircraft). In addition, stationary noise sources (air conditioning units, loading docks, mechanical equipment, rail yards, machinery, etc.) from commercial and industrial activity also contribute to the ambient noise environment (Table 3L.2-1, Typical Noise Levels for Los Angeles County).
13 Los Angeles Unified School District. “School Design Guide.” January 2014. Design Standards Department. Pages 313-316. Available at: http://www.laschools.org/documents/download/asset_management%2fschool_design_guide%2fSchool_Design _Guide_Jan_2014.pdf?version_id=310708755
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-10 Draft EIR Subchapter 3L. Noise
Table 3L.2-1: Typical Noise Levels for Los Angeles County Common Outdoor Activities Noise Level (dBA) Common Indoor Activities 110 Rock Band Jet Flyover at 1,000 feet 100 Gas Lawn Mower at 3 feet 90 Diesel Truck at 50 feet, at 50 mph Food Blender at 3 feet 80 Garbage Disposal at 3 feet Noisy Urban Area, Daytime Gas Lawn Mower at 100 feet 70 Vacuum Cleaner at 10 feet Commercial Area Normal speech at 3 feet Heavy Traffic at 300 feet 60 Large Business Office Quiet Urban Daytime 50 Dishwasher Next Room
Quiet Urban Nighttime 40 Theater, Large Conference Room (background) Quiet Suburban Nighttime 30 Library Quiet Rural Nighttime Bedroom at Night, Concert Hall (background) 20
10 Broadcast/Recording Studio
0 SOURCE: California Department of Transportation (Caltrans). September 2013. Technical Noise Supplement (“TeNS”). Prepared by California Department of Transportation, Division of Environmental Analysis.
The existing ambient noise levels at all monitoring locations currently exceed the City’s presumed daytime ambient noise standard of 50 dBA (Leq) by an average of 18.3 dBA (Leq) (Table 3L.2-2, Measured Total Ambient Noise Levels on and around the Proposed Project Site). Therefore, the measured existing ambient noise levels are appropriate for use as the baseline conditions for the purposes of determining the proposed project’s noise impacts on the surrounding community.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-11 Draft EIR Subchapter 3L. Noise
Table 3L.2-2: Measured Total Ambient Noise Levels on and around the Proposed Project Site Monitoring Period (15- Average Maximum Minimum Area Classification/Primary Noise Location minute interval) Leq (dBA) Leq (dBA) Leq (dBA) Sources A1: Victoria Ave/ Single-family residential; few cars, a Louella Ave 2:36–2:51 PM 53.6 77.0 47.9 school bus, and ambient noise from houses Single-family residential, adjacent A2: Victoria Ave/ project site boundary; School buses, 3:14–3:29 PM 60.5 80.9 52.2 Walgrove Ave medium traffic, and ambient noise from houses and school Single-family residential, adjacent A3: Lucille Ave/ project site boundary; School buses, 4:00–4:15 PM 61.6 83.4 53.3 Walgrove Ave medium traffic, and ambient noise from houses and middle school Major street, with adjacent single- family residential and Venice High A4: Venice Blvd/ School to the south; major traffic 4:20–4:35 PM 67.8 88.2 58.8 Walgrove Ave noise, with accelerating traffic primary source of noise, and ambient noise from houses Single-family residential, elementary A5: Victoria Ave/ school; school buses, light traffic, and 4:45–5:00 PM 60.3 80.5 49.3 Beethoven St ambient noise from houses and elementary school Single-family residential, adjacent project site boundary (nearest A6: Maplewood Ave/ 2:53–3:08 PM 53.0 81.6 47.8 sensitive receptor); school buses, Victoria Ave light traffic, and ambient noise from houses and middle school
The proposed project site is located in a highly residential area that is adjacent to Venice Boulevard (California State Route 187), which provides a major east-west thoroughfare for commuters in the Los Angeles area. Additionally, the proposed project site is directly bordered by Walgrove Avenue to the west and closely bordered by Beethoven St to the east. Field observations at the proposed project site revealed that the primary source of maximum ambient noise levels (as high 88.2 dBA at monitoring location A4) are school buses, Culver City Buses, Big Blue Buses, and Metro Local and Rapid Buses.
According to the Traffic Impact Study, there are four primary access routes to the proposed project site: Walgrove Avenue, Lucille Avenue, Victoria Street, and Beethoven Street.
The Traffic Impact Study concluded that the proposed project is expected to result in a peak of approximately 850 total trips per day, with the assumption that most of the trips will be completed Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-12 Draft EIR Subchapter 3L. Noise in passenger vehicles. The typical noise level for most buses traveling at a speed of 35 miles per hour (mph) (the highest speed limit on access routes to proposed project site) is 82 dBA at a distance of 50 feet.14
Because the maximum ambient noise levels recorded directly adjacent to the proposed project site were 83.4 dBA, with the source of noise being buses transporting students to and from Mark Twain Middle School, it can be assumed that the additional vehicles associated with the proposed project would be comparable to existing maximum ambient noise levels. The maximum ambient noise levels recorded in close proximity to sensitive receptors were 80.9 dBA for monitoring location A2, 83.4 dBA for monitoring location A3, and 81.6 dBA for monitoring location A6, providing an average maximum ambient noise level of 82.0 dBA. Heavy trucks (buses) associated with the proposed project would typically be at or below the ambient conditions at the nearest sensitive receptors for heavy trucks (buses), assuming heavy trucks (buses) are traveling at a speed of 35 mph.
Table 3L.2-3, Measured Baseline Ambient Noise Levels on and around the Proposed Project Site, shows the ambient noise levels, removing the peaks due to passing busses, other heavy trucks, and loud motorcycles.
Table 3L.2-3: Measured Baseline Ambient Noise Levels on and around the Proposed Project Site Average Location Leq (dBA) Area Classification A1: Victoria Ave/Louella Ave 52.7 Single-family residential A2: Victoria Ave/Walgrove Ave 60.0 Single-family residential, adjacent project site boundary A3: Lucille Ave/Walgrove Ave 60.4 Single-family residential, adjacent project site boundary Major street, with adjacent single-family residential and Venice High School to A4: Venice Blvd/Walgrove Ave 66.9 the south A5: Victoria Ave/Beethoven St 59.8 Single-family residential, elementary school Single-family residential, adjacent project site boundary (nearest sensitive A6: Maplewood Ave/Victoria Ave 52.4 receptor)
The levels determined above are to be used for baseline conditions during the non-school hours. This assumption is justified as the average Leq is increased with the presence of school buses and a higher traffic of personal vehicles. Sensitive Receptors
Certain land uses are particularly sensitive to noise and vibration. These uses include schools, residences, hospital facilities, religious facilities, and open space/recreation areas where quiet environments are necessary for the enjoyment, public health, and safety of the community. Commercial and industrial uses are not considered noise- and vibration-sensitive uses. The proposed project is a school and therefore included as a sensitive receptor. The surrounding area is
14 Cowan, James P. 1994. Handbook: Environmental Acoustics. New York, NY: John Wiley & Sons. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-13 Draft EIR Subchapter 3L. Noise composed of an additional school and residences, resulting in a large number of sensitive receptors. Figure 3L.2-1, Sensitive Receptors in the Vicinity of the Proposed Project, displays the project area and sensitive receptors located in a 500-foot buffer surrounding the project area. There are 458 sensitive receptors in the 500-foot buffer area. Existing Vibration Sources
Similar to the environmental setting for noise, the vibration environment is dominated by traffic from nearby roadways. Heavy trucks can generate ground-borne vibrations that vary depending on vehicle type, weight, and pavement conditions. Existing ground-borne vibration in the proposed project vicinity is largely related to heavy truck traffic on the surrounding roadway network. Vibration levels from adjacent roadways are not perceptible at the proposed project site. Airports in the Regional Vicinity
The proposed project is located in the community of Mar Vista. The nearest airports are shown in Table 3L.2-4 and Figure 3L.2-2, Airports in the Vicinity of the Proposed Project.
Table 3L.2-4: Airports in the Vicinity of the Proposed Project Distance to Project Airport Name (IATA) Address Site (miles) Santa Monica Airport (SMO) 3223 Donald Douglas Loop S, Santa Monica, CA 90405 0.9 Hawthorne Municipal Airport (HHR) 12101 S Crenshaw Blvd, Hawthorne, CA 90250 8.0 Los Angeles International Airport (LAX) 1 World Way, Los Angeles, CA 90045 3.5
3L.3 THRESHOLDS OF SIGNIFICANCE CEQA Guidelines
The potential for the proposed project to result in impacts related to noise was analyzed in relation to the six questions contained in Appendix G of the State CEQA Guidelines. Would the proposed project result in: a. Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. b. Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels. c. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. d. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-14 Draft EIR LEGEND !( Sensitive Receptors Student Garden Proposed New Frontage Beethoven Elementary School and Drop Off for Mandarin Early Education Center Immersion Elementary School Beethoven Elementary School Proposed Mandarin Immersion Elementary School Mark Twain Middle School Proposed Restriped Parking for 500-Foot Radius Mark Twain Middle School
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SOURCE: SEI, ESRI
0 250 500 750 1,000 Feet o 1:6,000 Q:\1498\MarkTwain_MS\ArcProjects\SensRecNoise.mxd
FIGURE 3L.2-1 Sensitive Receptors in the Vicinity of the Proposed Project LEGEND Mark Twain Middle School Airport
Santa Monica Municipal Airport
0 .8 M i le s
3 . 1
M
i l e s
7 .9 M il es
Los Angeles International Airport (LAX)
Pacif ic Oc Hawthorne ean Municipal Airport
SOURCE: SEI, ESRI, LA Co.
0 0.5 1 1.5 2 Miles o 1:84,000 Q:\1498\MarkTwain_MS\ArcProjects\Airports.mxd
FIGURE 3L.2-2 Airports in the Vicinity of the Proposed Project Subchapter 3L. Noise e. For a project located within an airport land use plan or where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels. f. For a project within the vicinity of a private airstrip, expose people residing or working in the project area to excessive noise levels. City of Los Angeles CEQA Thresholds
The City of Los Angeles CEQA thresholds state that a project would have a long-term operational noise impact if noise levels during operation “causes the ambient noise levels at the property line of affected uses to increase by three (3) dBA CNEL to or within the ‘normally unacceptable’ or ‘clearly unacceptable’ category, or any five dBA or greater increase.”15
The City of Los Angeles CEQA thresholds state that a project would have a significant construction- related noise impact if:
Construction activities lasting more than one day would exceed existing ambient exterior noise levels by 10 dBA or more at a noise sensitive use;
Construction activities lasting more than 10 days in a three month period would exceed existing ambient exterior noise levels by 5 dBA or more at a noise sensitive use; or
Construction activities would exceed the ambient noise level by 5 dBA at a noise sensitive use between the hours of 9:00 PM and 7:00 AM Monday through Friday, before 8:00 AM or after 6:00 PM on Saturday, or at any time on Sunday
Three relevant standards were considered in the evaluation of the potential for the proposed project to result in noise levels in excess of established standards: ANSI S12.60-2002 Standard, Acoustical Performance Criteria, Design Requirements and Guidelines for Schools; California Community Noise and Land Use Compatibility Guidelines. Construction Noise
The county prohibits construction noise weekdays between 7:00 PM and 7:00 AM, or at any time on Sundays or holidays. The county also sets maximum noise levels from mobile and stationary equipment.
15 City of Los Angeles CEQA Thresholds Guide. 2006. Available at: http://environmentla.org/programs/thresholdsguide.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-15 Draft EIR Subchapter 3L. Noise
3L.4 IMPACT ANALYSIS
Impact 3L-a: Would the proposed project result in exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Potentially Significant Impact
The City’s Noise Element establishes the baseline level of 60 dB as the acceptable threshold for ambient noise levels at land uses that are sensitive to noise. The proposed project is situated in an area with baseline ambient noise levels of approximately 60.0–60.4 dBA. Federal requirements indicate that an exposure of greater than 65 dBA for a school is considered generally unacceptable. The baseline conditions measured from Venice Boulevard at Walgrove Avenue demonstrate that on busy streets within the vicinity of the proposed project site, there exist conditions of 66.9 dBA average, which is greater than 65 dBA. However, Venice Boulevard is greater than 1,200 feet from the proposed project site. Therefore, the ambient noise levels of 60.0–60.4 dBA would apply for the proposed project site.
The proposed project includes construction of new school facilities as well as the renovation of existing buildings. The City of Los Angeles Municipal Code, Section 112.05, states that construction activities may not exceed 75 dBA at a distance of 50 feet between the hours of 7:00 AM and 10:00 PM in any residential zone of the City or within 500 feet thereof. This construction has the potential to create temporary noise levels at the proposed project location that would exceed the 75 dBA City threshold. Based on the noise levels found in Table IV.L-9: Typical Outdoor Construction Noise Levels, and the fact that noise attenuates from a point source at a rate of approximately 6.0 dBA per doubling of distance, the noise impacts on sensitive receptors can be determined by Equation 1 for noise attenuation over distance:
(1)
Where:
L1 = known sound level at d1
L2 = desired sound level at d2
d1 = distance of known sound level from the noise source
d2 = distance of the sensitive receptor from the noise source
The noise levels associated with activities required for the construction of the proposed project can be estimated using typical outdoor construction noise levels. These noise levels can be found in Table 3L.2-5, Typical Outdoor Construction Noise Levels.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-16 Draft EIR Subchapter 3L. Noise
Table 3L.2-5: Typical Outdoor Construction Noise Levels
Noise Level (dBA Leq) Construction Phase 50 Feet 50 Feet with Mufflers Ground Clearing 84 82 Grading 89 86 Foundations 78 77 Structural, Paving 85 83 Finishing 89 86 SOURCE: U.S. Environmental Protection Agency. 1971. Noise from Construction Equipment and Operation, Building Equipment and Home Appliances. PB 206717. Washington, DC.
As shown in Table 3L.2-5, typical outdoor construction noise levels range from 77 dBA to 86 dBA at a distance of 50 feet from the operating muffled construction equipment.16 These noise levels are greater than the City threshold of 75 dBA. Therefore, the proposed project would result in significant impacts as a result of construction exposing persons to, or generating, noise levels in excess of existing established standards, requiring the consideration of mitigation measures.
Impact 3L-b: Would the proposed project result in exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels?
Potentially Significant Impact
Vehicle-created ground-borne vibration is not perceivable at the proposed project location. However, vibration and ground-borne noise as a result of construction is possible. Therefore, the proposed project has the potential to result in significant impacts to noise related to the exposure of persons to or generation of excessive ground-borne vibration or ground-borne noise levels, requiring the consideration of mitigation measures to reduce impacts to below the level of significance.
Impact 3L-c: Would the proposed project result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?
Less than Significant Impact
After the completion of the construction of the proposed project, the existing Mark Twain Middle School is anticipated to continue operations as usual. The addition of 336 students to an existing campus is not anticipated to increase the ambient noise levels of the school once the proposed project is completed. No anticipated weekend noise generating activities are associated with the proposed project. Additionally, the increase in traffic due to the drop-off and pick-up of students
16 U.S. Environmental Protection Agency. 1971. Noise from Construction Equipment and Operation, Building Equipment and Home Appliances. PB 206717. Washington, DC.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-17 Draft EIR Subchapter 3L. Noise from the proposed project would not be anticipated to significantly increase ambient noise levels in the surrounding area. The baseline conditions were taken during the peak afternoon hours, during which traffic on Walgrove Avenue and Beethoven Street was extremely dense. Therefore, the proposed project would result in a less than significant impact to noise regarding a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the proposed project.
Impact 3L-d: Would the proposed project result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project?
Less than Significant Impact
The existing ambient noise levels at the proposed project site were determined to fall within the range of 60.0–60.4 dBA. As a result of the proposed project, Victoria Avenue will be used as the drop-off zone for the proposed project. The noise levels associated with dropping off and picking up students is expected to consist of ambient school noise combined with traffic from automobiles on Victoria Avenue. Section 2, Project Description, includes a Pedestrian Safety Project Design Feature, PS-2, which establishes a speed limit of 25 mph with appropriate signage on Victoria Avenue prior to the issuance of an occupancy permit. The noise levels from automobiles traveling at 25 mph are approximately 59 dBA, and at 30 mph, 62 dBA. These noise levels are within an acceptable range of the ambient noise levels measured in Table 3L.2-2, Measured Total Ambient Noise Levels on and around the Proposed Project Site. Therefore, the impacts related to a temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project would be less than significant.
Impact 3L-e: For a project located within an airport land use plan or where such a plan has not been adopted, within two miles of a public airport or public use airport, would the proposed project expose people residing or working in the project area to excessive noise levels?
No Impact
The proposed project is located approximately 0.9 mile from the Santa Monica Municipal Airport. However, according to the Area of Influence Map prepared by the Los Angeles County Airport Land Use Commission,17 the proposed project does not lie within the vicinity of the airport’s area of influence. The next nearest airport is LAX, located 3.5 miles to the south. The distance between the proposed project site and LAX makes any potential noise impact negligible. The proposed project is not in the flight path of the Santa Monica Municipal Airport or LAX. Therefore, the proposed project would not result in significant impact related to exposing people residing or working in the project area to excessive noise levels.
17 Los Angeles County Airport Land Use Commission. Airport Influence Area. Accessed 24 November 2014. Available at: http://planning.lacounty.gov/assets/upl/project/aluc_airport-santa-monica.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-18 Draft EIR Subchapter 3L. Noise
Impact 3L-f: For a project within the vicinity of a private airstrip, would the proposed project expose people residing or working in the project area to excessive noise levels?
No Impact
The proposed project is located approximately 0.9 mile from the Santa Monica Municipal Airport. However, according to the Area of Influence Map prepared by the Los Angeles County Airport Land Use Commission,18 the proposed project does not lie within the vicinity of the airport’s area of influence. The proposed project is not in the flight path of the Santa Monica Municipal Airport. Therefore, the proposed project would not result in significant impact related to exposing people residing or working in the project area to excessive noise levels.
3L.5 CUMULATIVE IMPACTS
After completion of construction of the proposed project, the source of noise levels in excess of LAUSD standards, as described in Impact 3L-a, would no longer exist. Noise levels for operation of the proposed project are expected to be in line with baseline ambient noise levels. Therefore, the proposed project would result in a less than significant cumulative impact related to exposing persons to or generating noise levels in excess of existing established standards.
After completion of the construction of the proposed project, the source of vibration levels that would result in excess of LAUSD standards, as described in Impact 3L-b, will no longer exist. Operations of the proposed project would not result in excessive ground-borne vibration or ground-borne noise levels. Therefore, the proposed project would result in a less than significant cumulative impact related to exposure of persons to or generation of excessive ground-borne vibration or ground-borne noise levels.
3L.6 MITIGATION MEASURES
To reduce the impacts of the proposed project related to noise to below the level of significance, the following mitigation measures are proposed:
MM Noise-1 LAUSD shall incorporate sound barriers between the proposed project site and adjacent sensitive receptors to reduce noise levels during construction to meet jurisdictional standards. A solid sound-absorbing wall shall be installed along Victoria Avenue with a minimum height of 8 feet and shall be able to reduce noise levels by a minimum of 8 dBA. Sound-absorbing blankets shall be installed surrounding the remaining sides of the proposed project area with a minimum height of 8 feet. Additionally, a sound absorbing wall shall be installed between the existing portable classrooms on the Mark Twain Middle School Campus and the construction activity for the duration of their use during the proposed project construction. Figure 3L.6-1, Sound Barrier, demonstrates the locations and type of sound barrier relative to the proposed project site and adjacent school facilities.
18 Los Angeles County Airport Land Use Commission. Airport Influence Area. Accessed 24 November 2014. Available at: http://planning.lacounty.gov/assets/upl/project/aluc_airport-santa-monica.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-19 Draft EIR LEGEND Temporary Sound Wall, Solid Sound Absorbing Material
G Temporary Sound Barrier, Cloth r e Sound Absorbing Material e n vd w Bl o Proposed Mandarin Immersion s o alm d Elementary School P A v e Beethoven Elementary School Early Education Center
M a p Beethoven Elementary School le w o o Mark Twain Middle School d A v e
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FIGURE 3L.6-1 Sound Barrier Subchapter 3L. Noise
MM Noise-2 LAUSD shall consult and coordinate with the site administrator or school principal prior to construction to schedule high noise or vibration producing activities to minimize disruption. Coordination shall continue on an as needed basis throughout the construction phase of the project to reduce school and other sensitive receptor disruptions.
MM Noise-3 LAUSD shall require its construction contractor to provide advance notice of the start of construction to all noise sensitive receptors, including residences and schools adjacent to the proposed project site. The announcement shall state specifically where and when construction activities will occur, and shall provide contact information for filing noise complaints with the contractor and the District. In the event of noise complaints, LAUSD shall monitor noise from the construction activity to ensure that construction noise does not exceed limits specified in the noise ordinance.
MM Noise-4 LAUSD shall require the construction contractor to locate, store, and maintain portable equipment as far as possible from the adjacent residents and other sensitive receptors.
MM Noise-5 LAUSD shall include the applicable noise ordinances of the affected city and county jurisdiction in the construction contracts.
MM Noise-6 If feasible, impact tools (e.g., jack hammers, pavement breakers, and rock drills) used for construction activities shall be hydraulically or electrically powered wherever possible to avoid noise associated with compressed air exhaust from pneumatically powered tools. Where use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used. External jackets on the tools themselves shall be used. Quieter procedures, such as use of drills rather than impact tools, shall be used.
MM Noise-7 The construction contractor shall select non-impact demolition and/or construction methods, such as removal for off-site demolition or hydraulic jack splitting, and use pavement breakers and vibratory rollers and packers near sensitive receptors.
3L.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3L-a and 3L-b: Less than significant impact with mitigation incorporated. Implementation of mitigation measures MM Noise-1 through Noise-7 would reduce the impacts of the proposed project related to noise to below the level of significance. The significant project impacts are related to noise created from construction activity. The proposed mitigation measures would decrease the construction-generated noise levels from approximately 85 dBA at the nearest sensitive receptor to within the thresholds established in the City of Los Angeles Municipal Code and in accordance with guidelines established by LAUSD. The implementation of a sound barrier would reduce the noise levels of construction by approximately 8 dBA, resulting in construction- generated sound levels below the 75 dBA threshold at the nearest sensitive receptor, as established by the City. In the event that construction activity does exceed these standards, MM Noise-3 provides protocol to follow regarding reporting and monitoring of such exceedances.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-20 Draft EIR Subchapter 3L. Noise
Impacts 3L-c and 3L-d: Less than significant impact.
Impacts 3L-e and 3L-f: No impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3L-21 Draft EIR SUBCHAPTER 3M Pedestrian Safety
This analysis is undertaken to determine if the proposed project may have a significant impact on pedestrian safety, which would require the consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 This section evaluates the potential impacts of the proposed project on pedestrian safety through a review and discussion of the results of the Pedestrian Safety Study conducted as part of the traffic impact analysis (Appendix H, Traffic Study).2 The analysis includes an estimate of the number of pedestrians who would be walking to and from the proposed school, an inventory of the existing pedestrian-oriented traffic controls and sidewalks within 0.25 mile of the proposed project location, a map of the recommended pedestrian routes to the proposed project site, and a review of the potential safety concerns for pedestrians.
3M.1 REGULATORY FRAMEWORK Federal
Section 1404 in SAFETEA-LU (Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users)
This federal funding program emphasizes community collaboration in the development of a project, in relation to three objectives that are relevant to the consideration of the proposed project: (1) enabling and encouraging students in kindergarten through eighth grade (K–8), including students with disabilities, to safely walk and bicycle to school; (2) making walking and bicycling to school a more appealing mode choice; and (3) facilitating the planning, design, and implementation of projects that will improve safety, environment, and overall quality of life. Consistent with other federal-aid programs, each State Department of Transportation is held responsible for developing and implementing the program. State
Streets and Highways Code Section 2331, 2333, and 2333.53
The “Safe Routes to School” program, with enactment of AB 1475 in 1999 and indefinite extension of the program through AB 57, outlines a series of measures implemented to ensure that students have access to safe routes to and from schools. The purpose of the program is to provide funding to
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H). 3 California Department of Transportation. January 2000. Assembly Bill 1475, Sections 2331, 2333, and 2333.5. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-1 Draft EIR Subchapter 3M. Pedestrian Safety improve the safety of children as they walk or bike to school. School districts are responsible for establishing and enforcing site-specific school route plans. School districts are also responsible for establishing and developing school facilities that foster a good pedestrian environment. These responsibilities include choosing school locations that balance vehicle access with pedestrian safety needs, constructing adequate pedestrian facilities along the perimeter of the school site, and working with the local public works agency to fund/install adequate crossing protection at key points. School districts are responsible for distributing walk route maps to parents and students.4 School districts are required to prepare, prior to school opening, a pedestrian safety plan for the safe arrival and departure of students in accordance with the School Area Pedestrian Safety Manual.5,6 Local
LAUSD OEHS CEQA Specification Manual, Appendix C7
The LAUSD OEHS has identified thresholds of significance to minimize potential pedestrian safety risks to students, staff, and visitors to LAUSD schools. These thresholds are defined below, as found in the LAUSD OEHS CEQA Specification Manual, Appendix C.
PS-1 Vehicle Access: Substantially increase vehicular and/or pedestrian safety hazards due to a design feature or incompatible uses.
PS-2 Pedestrian Routes to School: Create unsafe routes to schools for students walking from local neighborhoods.
PS-3 Roadways in the Project Vicinity: Be located on a site that is adjacent to or near a major arterial roadway or freeway that may pose a safety hazard.
3M.2 EXISTING CONDITIONS Vehicle Access
Primary pedestrian access to Mark Twain Middle School is on Walgrove Avenue, aligned with the passenger loading zones on Walgrove Avenue. Primary access to the adjacent Beethoven Elementary School is from Beethoven Street, which is equipped with aligned passenger loading zone. Both pick-up/drop-off locations are located to the south of Victoria Avenue. The 2015 evaluation of 25 intersections indicates that LOS ranges from A to F during the AM Peak Hour, with the worst congestion occurring at intersections with Walgrove Avenue (Table 3M.2-1, Existing Peak Hour Level of Service Summary). Similarly, the evaluation indicates that LOS ranges from A to D during the PM Peak Hour, with the worst congestion occurring at intersections with Walgrove Avenue (Table 3M.2-1). The southwest corner of the Mark Twain Middle School campus experiences the most severe congestion. For Beethoven Street, from Lucille Avenue to Victoria
4 California Department of Health Services. 2004. “Responsibilities for Walk Route Safety.” Available at: www.dhs.ca.gov/ps/cdic/epic/sr2s/documents/RouteResponsibilitiesChart.doc 5 California Department of Transportation. 1997. School Area Pedestrian Safety Manual. 6 Caltrans, Division of Local Assistance. n.d. California State-legislated Safe Routes To School (SR2S) Program. Available at: http://www.dot.ca.gov/hq/LocalPrograms/saferoutes/sr2s.htm. 7 LAUSD OEHS. California Environmental Quality Act Specification Manual, Appendix C. Revised January 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-2 Draft EIR Subchapter 3M. Pedestrian Safety
Avenue, the LOS ranges from C to A in the peak morning hours. During peak evening hours, the LOS ranges from B to A. The southeast corner of the Beethoven Elementary School campus experiences the most severe congestion.
Table 3M.2-1: Existing Peak Hour Level of Service Summary Existing Study Intersections AM Peak Hour LOS PM Peak Hour LOS 1 Lincoln Blvd & Marine Ave A B 2 23rd St & Ocean Park Blvd C B A B 3 Bundy Dr & Airport Ave B C 4 Walgrove Ave & Rose Ave F D 5 Walgrove Ave & Morningside Way A A 6 Walgrove Ave & Palms Blvd B A 7 Beethoven St & Palms Blvd A C 8 Centinela Ave & Palms Blvd E E 9 Walgrove Ave & Victoria Ave (W-leg) A A 10 Beethoven St & Victoria Ave (E-leg)* A A 11 Centinela Ave & Charnock Ave B A 12 Lincoln Blvd & Venice Blvd C D 13 Walgrove Ave & Venice Blvd C D 14 Beethoven Ave & Venice Blvd C C 15 Centinela Ave & Venice Blvd E F 16 Beethoven Ave & Zanja St* B C 17 Lincoln Blvd & Washington Blvd D C 18 Glencoe Ave & Washington Blvd C D 19 Walgrove Ave & Washington Blvd* F F 20 Beethoven Ave & Washington Blvd B C D E 21 Centinela Ave & Washington Pl C D D E 22 Centinela Ave & Washington Blvd C D A A 23 Lincoln Blvd & Bali Wy A A B D 24 Lincoln Blvd & Mindanao Wy B D A C 25 Lincoln Blvd & Fiji Wy A C NOTE: * Un-signalized intersection SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-3 Draft EIR Subchapter 3M. Pedestrian Safety
The proposed project site is located approximately 1.2 miles from the 90 freeway, 1.6 miles from the 405 freeway, and 1.8 miles from the 10 freeway. The nearest major arterial roadway is Venice Boulevard, located approximately 0.25 mile to the south of the proposed project site.
The project design features outlined in Section 2.0, Project Description, describe the existing street widths, and proposed street widening as part of the project construction, and in order to make Walgrove Avenue and Victoria Avenue compliant with the definition of a collector street.
Pedestrian Routes to School
“Safe Routes to School” maps exist for both Mark Twain Middle School and Beethoven Elementary School (Figure 3M.2-1, Pedestrian Safety Existing Conditions, Figure 3M.2-2, Pedestrian Routes for Beethoven Elementary School; and Figure 3M.2-3, Pedestrian Routes for Mark Twain Middle School). Beethoven Street provides direct access to Beethoven Elementary, and Walgrove Avenue provides direct access to Mark Twain Middle School.
No railroads, drainage canals, or other hazards to pedestrian safety are located along the pedestrian routes identified in both the Mark Twain Middle School and Beethoven Elementary School Safe Routes to School Maps. Venice Boulevard is designated as a bicycle route, and has an accommodating lane on the right side of the flow of traffic. Walgrove Avenue, Beethoven Street, and Palms Boulevard are considered to be Bike Friendly Streets according to the City of Los Angeles Department of Transportation’s (LADOT’s) Bikeways Map.8
Crosswalks and crossing guards are utilized at the corners of Walgrove Avenue/Lucille Avenue and Beethoven Street/Lucille Avenue. Traffic signals are present in the immediate vicinity of the proposed project site at the intersections of Victoria Avenue/Walgrove Avenue (south) and Victoria Avenue/Beethoven Street (south). Additional traffic signals are present at the intersections of Venice Boulevard/Walgrove Avenue, Maplewood Avenue, and Beethoven Street, as well as Palms Boulevard/Walgrove Avenue and Palms Boulevard/Beethoven Street (see Figure 3M.2-1). Roadways in the Project Vicinity
The nearest major arterial roadways or freeways to the proposed project are included in Table 3M.2-2, Major Arterial Roadways and Freeways in the Project Vicinity.
8 Los Angeles Department of Transportation. Accessed 20 November 2014. “City of Los Angeles Bikeways.” Available at: http://bicyclela.org/pdf/BikeMapWestsideCC.pdf and http://bicyclela.org/maps_main.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-4 Draft EIR LEGEND !( Crossing Guard Bus Drop Off Zone Crosswalk
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FIGURE 3M.2-1 Pedestrian Safety Existing Conditions H A WAY L N D O WEY ST WARREN AVE ER DE Y M PPLET WA A A C WAD N ON A T S ST B RE RI E P LL S EN ST T O DGRE BL WOO V D VE E A AV R E TE NS ROS M MI EI EST E W GR R COLO S ST M D AN E Y T AK WA O L S O N D A R I V LMS BLV WA A SOM E PA L IE P S W S A T V A B TC E L GRE V H E D AV V E A PENMAR NWO M E D ROSE AR A W Y PL FR D ME ST IN O A W W D RCO NCE O I A C T O AVE ER M S WAL GROV E E S O E E A K D A A ST N VI EW L AVE V C E E AY N W T DE IN SI WA AV G E IN L N D A E OR E A M S V E MA T
Y ST WAY TON MA LE CO P BE APP LEWOO MO LONI E T ORE AS H WAS A A O L AY H D V S A WOOD EN A T V ON W T E T VE CH S RED S T BOI A PRE A WO VE V S E S E A OD T E VE W LVD A B V A S E R LM T A P A V E
BEETHOVEN ES
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Legend Parents: Recommended Crossing This map shows the recommended crossings to be used from each block in your school attendance area. Stop Sign Following the arrows, select the best route from your Traffic Signal home to the school and mark it with a colored pencil or crayon. This is the route your child should take. Crossing Guard Instruct your child to use this route and to cross streets only at locations shown. You and your child should Flashing Warning Light 0350 700 become familiar with the route by walking it together. Stairs or Walkway Obey marked crosswalks, stop signs, traffic signals Feet and other traffic controls. Crossing points have been Pedestrian Bridge located at these controls wherever possible, even Pedestrian Tunnel though a longer walk may be necessary. Instruct your child to always look both ways before crossing the Parks street. If no sidewalk exists, your child should walk SOURCE: City of Los Angeles, Department of Transportation, July 2013 facing traffic.
FIGURE 3M.2-2 Pedestrian Routes for Beethoven Elementary School T S N MEI E RE E E R C T O AV OODG S MOO S W L SE E T LVD E AK WAY V O RO L S B A N AS R M R LM E IA E ST WAS PSO PA IN L S TM A T T S VE S WE A N T T EE C S H E DGR K O A LA VE VE R WO O ER A SE ST L FRANC M N P W O E TMI C WALGROVE ES O R IE ES A O M R W E AV D A S T Y VE E
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FIGURE 3M.2-3 Pedestrian Routes for Mark Twain Middle School Subchapter 3M. Pedestrian Safety
Table 3M.2-2: Major Arterial Roadways and Freeways in the Project Vicinity Distance to Proposed Project Roadway Name Type of Road (Miles) 1. Lincoln Boulevard (California State Route 1) Major Arterial 0.64 2. Venice Boulevard (California State Route 187) Major Arterial 0.25 3. Santa Monica Boulevard (California State Route 2) Major Arterial 2.67 4. Interstate 405 Freeway 1.68 5. California State Route 90 Freeway 1.20 6. Interstate 10 Freeway 1.80
The nearest major freeway is California State Route 90, located 1.20 miles to the south of the proposed project. The nearest interstate is the Interstate 405, which is located 1.68 miles to the east of the proposed project. The nearest major arterial roadway is Venice Boulevard, located 0.25 mile to the south of the proposed project.
3M.3 THRESHOLDS OF SIGNIFICANCE
LAUSD has developed a set of significance thresholds found in the LAUSD OEHS CEQA Specification Manual, Appendix C.9 These significance thresholds are intended to minimize potential pedestrian safety risks to students, faculty and staff, and visitors to LAUSD schools. The proposed project would result in a significant adverse impact relating to pedestrian safety if it would result in any of the following effects:
PS-1 Vehicle Access: Substantially increase vehicular and/or pedestrian safety hazards due to a design feature or incompatible uses.
PS-2 Pedestrian Routes to School: Create unsafe routes to schools for students walking from local neighborhoods.
PS-3 Roadways in the Project Vicinity: Be located on a site that is adjacent to or near a major arterial roadway or freeway that may pose a safety hazard.
3M.4 IMPACT ANALYSIS
The analysis of potential significant impacts to pedestrian safety associated with the proposed project is based on information contained in the Traffic Study (Appendix H).
9 LAUSD OEHS. California Environmental Quality Act Specification Manual, Appendix C. Revised January 2007. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-5 Draft EIR Subchapter 3M. Pedestrian Safety
PS-1: Vehicle Access: Substantially increase vehicular and/or pedestrian safety hazards due to a design feature or incompatible uses.
Potentially Significant Impact
According to the Traffic Study, the following intersections will experience a decrease in their Level of Service for the peak hours as a result of the proposed project: (1) Walgrove Avenue/Rose Avenue, (2) Centinela Avenue/Palms Boulevard, (3) Walgrove Avenue/Venice Boulevard, (4) Beethoven Street/Venice Boulevard, (5) Centinela Avenue/Venice Boulevard, and (6) Walgrove Avenue/Washington Boulevard (see Table 3M.4-1, Future Peak-Hour Level of Service Summary [with Project]).
Table 3M.4-1: Future Peak-Hour Level of Service Summary (with Project) With Project Study Intersections AM Peak Hour LOS PM Peak Hour LOS 1 Lincoln Blvd & Marine Ave A B 2 23rd St & Ocean Park Blvd C C A B 3 Bundy Dr & Airport Ave B D 4 Walgrove Ave & Rose Ave F E 5 Walgrove Ave & Morningside Way A B 6 Walgrove Ave & Palms Blvd B B 7 Beethoven St & Palms Blvd B C 8 Centinela Ave & Palms Blvd E E 9 Walgrove Ave & Victoria Ave (W-leg) B A 10 Beethoven St & Victoria Ave (E-leg)* A A 11 Centinela Ave & Charnock Ave C B 12 Lincoln Blvd & Venice Blvd F F 13 Walgrove Ave & Venice Blvd E D 14 Beethoven Ave & Venice Blvd D E 15 Centinela Ave & Venice Blvd F F 16 Beethoven Ave & Zanja St* C D 17 Lincoln Blvd & Washington Blvd E D 18 Glencoe Ave & Washington Blvd D E 19 Walgrove Ave & Washington Blvd* F F 20 Beethoven Ave & Washington Blvd C D E E 21 Centinela Ave & Washington Pl D E E F 22 Centinela Ave & Washington Blvd C D A A 23 Lincoln Blvd & Bali Wy A A Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-6 Draft EIR Subchapter 3M. Pedestrian Safety
Table 3M.4-1: Future Peak-Hour Level of Service Summary (with Project) With Project Study Intersections AM Peak Hour LOS PM Peak Hour LOS B E 24 Lincoln Blvd & Mindanao Wy B E A D 25 Lincoln Blvd & Fiji Wy A D NOTE: * Unsignalized intersection. SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
As stated in the existing conditions, the current schools have site access designed in concert with student drop-off areas and the dominant existing traffic flow in the area. The proposed project would include safe access ways as part of the design features, in concert with student drop-off areas.
The addition of 510 trips during the AM Peak Hour and 340 trips during the PM Peak Hour to the local traffic circulation constitutes a significant impact requiring the consideration of mitigation measures.
PS-2: Pedestrian Routes to School: Create unsafe routes to schools for students walking from local neighborhoods.
No Impact
The existing “Safe Routes to School” maps for Mark Twain Middle School and Beethoven Elementary School are adequate for the proposed project (see Figures 3M.2-2 and 3M.2-3).
The proposed project would not expose pedestrians to risk or hazard from railroads, drainage canals, or other hazards along the defined pedestrian routes. The proposed project site is accessible via Bike Friendly Routes and Bike Paths on Venice Boulevard, Walgrove Avenue, and Beethoven Street. The proposed project would not create significant impacts related to exposing pedestrian or cyclists using designated routes of travel to unusual risks or hazards.
The existing traffic and pedestrian safety measures, including cross walks, traffic signals, stop signs, and crossing guards, would all serve the proposed project. Project Design Feature PS-3 includes necessary design features for crosswalks implemented in concert with existing stop signs in the vicinity of the proposed project site.
Therefore, the proposed project would not result in significant impacts to pedestrian safety relating to pedestrian routes to school, and no further analysis is warranted.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-7 Draft EIR Subchapter 3M. Pedestrian Safety
PS-3: Roadways in the Project Vicinity: Be located on a site that is adjacent to or near a major arterial roadway or freeway that may pose a safety hazard.
No Impact
The proposed project is approximately 0.25 mile from Venice Boulevard, a major east-west arterial street. Venice High School, Mark Twain Middle School, and Beethoven Elementary School are all currently in operation within the same vicinity as the proposed project. Venice Boulevard has protected pedestrian crossings at Walgrove Avenue, Maplewood Avenue, and Beethoven Street. Additionally, Venice Boulevard is a divided street with three lanes of traffic in each direction, with light controlled left hand turn lanes. Venice Boulevard also has posted speed limits of 40 miles per hour and signs indicating Safe School Zone signs at Walgrove Avenue and Beethoven Street. It can be concluded that Venice Boulevard is fully equipped with the safety controls necessary to ensure that pedestrians walking to and from the proposed project across Venice Boulevard will be protected.
The surrounding roads in the proposed project vicinity are composed of collector streets and residential streets. There are no additional major arterial roadways within 0.5 mile of the proposed project. The nearest freeway is California State Route 90, which poses no threat to pedestrian safety within the project vicinity. Therefore, the proposed project would not result in significant impacts to pedestrian safety relating to roadways in the project vicinity, and no further analysis is warranted.
3M.5 CUMULATIVE IMPACTS
The proposed project has the potential to combine with past, present, and reasonably foreseeable future projects to result in significant cumulative impacts to pedestrian safety relating to vehicle access. Tables 2.5-1 and 2.5-2, List of Related Projects, in Section 2.5, Cumulative Scenario, list the related projects in the vicinity of the proposed project. While there are 10 development projects located within 2 miles of the proposed project site, it is assumed that all new student peak hour pedestrian or traffic resulting from these cumulative projects would only generate potential pedestrian safety impacts in the immediate area of the school. The nearest cumulative projects are located more than half a mile away (0.6 mile) on Venice Boulevard. As each of the listed related projects would only result in immediate project area specific pedestrian safety impacts, these projects would not combine to create areas of cumulative impacts related to pedestrian safety. Therefore, the proposed project would result in a less than significant cumulative impact to pedestrian safety in relation to vehicle access.
3M.6 MITIGATION MEASURES
Mitigation measures for Pedestrian Safety are included in Section 3Q, Transportation and Traffic, as Mitigation Measures Trans/Traffic 1, 2, 3, and 4.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-8 Draft EIR Subchapter 3M. Pedestrian Safety
3M.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact PS-1: Less than significant impact with mitigation incorporated. With the incorporation of Mitigation Measures Trans/Traffic 1, 2, 3, and 4, impacts to pedestrian safety in relation to vehicle access would be reduced to below the level of significance.
Impacts PS-2 and PS-3: No impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3M-9 Draft EIR SUBCHAPTER 3N Population and Housing
This analysis is undertaken to determine if the proposed project may have a significant impact on population and housing, which would require the consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to population and housing at the proposed project site was evaluated with regard to state, regional, and local data and forecasts for population and housing and the proximity of the proposed project to existing and planned utility infrastructure. SCAG’s 2013 Profile of the City of Los Angeles2 and 2012 Growth Forecasting;3 and the Housing Element4 of the City of Los Angeles General Plan were referenced in this analysis.
3N.1 REGULATORY FRAMEWORK Federal
There are no applicable federal plans or policies related to population and housing. State
California Housing Element Law
According to California Government Code §65300, each governing body of a local government in California is required to adopt a comprehensive, long-term General Plan for the physical development of the city, city and county, or county.5 The California Housing Element Law, enacted in 1969, mandates that local governments adequately plan to meet the existing and projected housing needs of all economic segments of the community as part of the Housing Element, one of the seven mandated elements of the local General Plan. The California Housing Element Law is implemented by the California Department of Housing and Community Development (HCD), which is responsible for reviewing local government housing elements for compliance with state law and providing written comments to the local government. Using the information provided by local governments in its Housing Element, the HCD determines the regional housing need for each
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 Southern California Association of Governments. May 2013. Profile of the City of Los Angeles. Available at: http://www.scag.ca.gov/Documents/LosAngeles.pdf Main website: http://www.scag.ca.gov/Pages/default.aspx 3 Southern California Association of Governments. 12 March 2012. 2012 Adopted RTP Growth Forecast. Available at: http://www.scag.ca.gov/Documents/2012AdoptedGrowthForecastPDF.pdf Main website: http://www.scag.ca.gov/DataAndTools/Pages/GrowthForecasting.aspx 4 City of Los Angeles Department of City Planning. January 2009. Housing Element of the General Plan 2006- 2014. Available at: http://cityplanning.lacity.org/HousingInitiatives/HousingElement/Final/HE_Final.pdf 5 California Department of Housing and Community Development. 2013. Housing Elements and Regional Housing Need Allocation. Available at: http://www.hcd.ca.gov/hpd/hrc/plan/he/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-1 Draft EIR Subchapter 3N. Population and Housing county and allocates funding to meet this need to the council of governments for distribution to its jurisdictions. The HCD also oversees distribution of funding related to the regional housing need by the council of governments to the local governments to ensure that funds are appropriately allocated. The requirements for the Housing Element are delineated in California State Government Code Sections 65580–65589.9.6 Local
City of Los Angeles General Plan
As previously noted, this EIR has taken into account local land use and zoning regulations in evaluating potential impacts to population and housing, but considers these regulations as advisory only and not binding or determinative of whether impacts would be significant because the proposed project site is exempt from them under Government Code Section 53094. The discussion of local plans and zoning codes in this section is guided by these considerations.
The proposed project site is located within the City of Los Angeles. The Housing Element of the City of Los Angeles General Plan has established the following relevant goals, objectives, and policies:7
Goal 2: A City in which housing helps to create safe, livable and sustainable neighborhoods
. Objective 2.3: Promote sustainable buildings, which minimize adverse effects on the environment and minimize the use of non-renewable resources.
o Policy 2.3.5: Promote outreach and education regarding sustainable buildings.
3N.2 EXISTING CONDITIONS
The LAUSD boundaries spread over 720 square miles and include the City of Los Angeles (approximately 470 square miles) as well as all or parts of 31 smaller municipalities and several unincorporated sections of Southern California.8 According to the SCAG local profile for the City of Los Angeles, K–12 public school enrollment within the City of Los Angeles has increased by 4.9 percent from 2000 to 2012.9
According to the LAUSD California Environmental Quality Act Specification Manual, the population within Local District D, which includes Mark Twain Middle School and Broadway Elementary School, and comprises the southwestern portion of the LAUSD area, from El Segundo
6 City of Los Angeles Department of City Planning. 3 December 2013. Housing Element 2013-2021. “Executive Summary and Introduction.” Available at: http://cityplanning.lacity.org/HousingInitiatives/HousingElement/Text/0ES.pdf 7 City of Los Angeles Department of City Planning. 3 December 2013. Housing Element 2013-2021. “Chapter 6: Objectives, Policies, and Programs.” Available at: http://cityplanning.lacity.org/HousingInitiatives/HousingElement/Text/Ch6.pdf 8 Los Angeles Unified School District. Accessed 21 October 2014. About the Los Angeles Unified School District. Available at: http://achieve.lausd.net/site/default.aspx?DomainID=32 9 Southern California Association of Governments. May 2013. Profile of the City of Los Angeles. Available at: http://www.scag.ca.gov/Documents/LosAngeles.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-2 Draft EIR Subchapter 3N. Population and Housing northwest to Calabasas, northeast to West Hollywood, and southeast to Inglewood. Local District D is projected by SCAG to increase in population from 2000 to 2020 by 18.0 percent, with a 21.4 percent increase in households (Table 3N.2-1, SCAG 2020 Population and Households Projections for LAUSD Local District D).10
Table 3N.2-1: SCAG 2020 Population and Households Projections for LAUSD Local District D U.S. Census 2000 Conditions SCAG 2020 Projections 2000 Population 2000 Households 2020 Population (%) 2020 Households (%) Local District D1 641,797 283,770 757,236 (18.0%) 344,383 (21.4%) LAUSD total1 4,559,659 1,472,581 5,363,000 (17.6%) 1,829,293 (24.2%) City of Los Angeles total2,3 3,694,7422 1,275,3602 3,991,7003 (8.0%) 1,455,7003 (14.1%) SOURCE: 1Los Angeles Unified School District. Office of Environmental Health and Safety. California Environmental Quality Act Specification Manual. Revised June 2007. 2 Southern California Association of Governments. May 2013. Profile of the City of Los Angeles. Available at: http://www.scag.ca.gov/Documents/LosAngeles.pdf 3 Southern California Association of Governments. 12 March 2012. Adopted 2012 RTP Growth Forecast. Available at: http://www.scag.ca.gov/Documents/2012AdoptedGrowthForecastPDF.pdf
Population
According to the City of Los Angeles Local Population and Housing Profile, the Palms – Mar Vista – Del Rey Community Plan Area (CPA), which encompasses approximately 9.0 square miles, has a population of approximately 130,50011 (Table 3N.2-2, Palms – Mar Vista – Del Rey Community Plan Area Population, 2000-2009).12
Table 3N.2-2: Palms – Mar Vista – Del Rey Community Plan Area Population, 2000–2009 Census 1990 Census 2000 2009 (Estimate) Total population 103,747 110,044 122,295 Annual growth rate N/A 0.591% 1.117% Population density (persons/square 11,508 12,207 13,566 mile) Resident population (total population in 109,578 (6.2% increase 121,708 (11.1% increase 103,220 households) from 1990) from 2000) Residents’ share of population 99.49% 99.58% 99.52%
10 Los Angeles Unified School District. Office of Environmental Health and Safety. California Environmental Quality Act Specification Manual. Revised June 2007. 11 The 2014 population estimate assumes an annual growth rate of approximately 1.117 percent. 12 City of Los Angeles Department of City Planning. Demographic Research Unit. October 2014. City of Los Angeles Local Population and Housing Profile. “Palms – Mar Vista – del Rey Community Plan Area.” Available at: http://cityplanning.lacity.org/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-3 Draft EIR Subchapter 3N. Population and Housing
According to the Health Atlas Report, a data-informed analysis of health conditions throughout the City of Los Angeles, the Palms – Mar Vista – Del Rey CPA had a population density of 13,437 people per square mile in 2010, with approximately 17 percent of the population under the age of 18 (approximately 19,000 people).13
According to the Los Angeles Times Neighborhood Mapping Project, the proposed project is located within the neighborhood of Mar Vista, which is bordered by the Interstate 405 Freeway to the northeast, National Boulevard and Airport Avenue (Santa Monica Municipal Airport) to the northwest, Walgrove Avenue to the southwest, and West Washington Boulevard to the southeast.14 The neighborhood of Mar Vista’s population is approximately 40,000 (2008 estimated population: 37,447). The existing population density in the Mar Vista neighborhood is approximately 12,259 people per square mile, about average for the City of Los Angeles but among the highest densities for Los Angeles County. The ethnicity in the neighborhood is 51.3 percent white, 29.1 percent Latino, 12.8 percent Asian, 3.5 percent black, and 3.4 percent other.
The proposed project site is composed of approximately 4.2 acres on the northeastern portion of the existing Mark Twain Middle School campus. There are no people residing on the existing Mark Twain Middle School campus. Housing
The Palms – Mar Vista – Del Rey CPA contains approximately 56,600 housing units15 (Table 3N.2- 3, Palms – Mar Vista – Del Rey Community Plan Area Households, 2000–2009).16
Table 3N.2-3: Palms – Mar Vista – Del Rey Community Plan Area Households, 2000–2009 Census 1990 Census 2000 2009 (Estimate) Total housing units 48,806 50,055 53,987 Housing vacancy rate 6.02% 2.57% 1.28% Annual housing growth rate n/a 0.253% 0.799%
According to the Health Atlas Report, the Palms – Mar Vista – Del Rey CPA had a housing density of 24.3 housing units per residential acre in 2010, with approximately 70 percent of the housing units occupied by renters (approximately 35,000 units).17 There are approximately 56,600 housing units (2009 estimated housing units: 53,987) within the Palms – Mar Vista – Del Rey CPA.
13 City of Los Angeles Department of City Planning, Raimi & Associates, County of Los Angeles Department of Public Health, et al. June 2013. Health Atlas for the City of Los Angeles. Available at: http://cityplanning.lacity.org/Cwd/Framwk/healthwellness/text/HealthAtlas.pdf 14 Los Angeles Times. Accessed 21 October 2014. Mapping L.A.: Mar Vista. Available at: http://maps.latimes.com/neighborhoods/neighborhood/mar-vista/ 15 The 2014 household estimate assumes an annual growth rate of approximately 0.799 percent. 16 City of Los Angeles Department of City Planning. Demographic Research Unit. October 2014. City of Los Angeles Local Population and Housing Profile. “Palms – Mar Vista – del Rey Community Plan Area.” Available at: http://cityplanning.lacity.org/ 17 City of Los Angeles Department of City Planning, Raimi & Associates, County of Los Angeles Department of Public Health, et al. June 2013. Health Atlas for the City of Los Angeles. Available at: http://cityplanning.lacity.org/Cwd/Framwk/healthwellness/text/HealthAtlas.pdf. Section 3: Demographics and Social Characteristics. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-4 Draft EIR Subchapter 3N. Population and Housing
According to the Los Angeles Times Neighborhood Mapping Project, the average household size within the Palms – Mar Vista – Del Rey CPA in 2000 was 2.3 people per household.18
The proposed project site, which comprises a portion of an existing school campus within a designated Public Facility zone (PF), does not contain any existing residences. There are no people currently residing in the proposed project property, which is located within the existing Mark Twain Middle School campus, and no residences, infrastructure, or businesses currently exist within the proposed project site. The nearest residence to the proposed project site is located approximately 40 feet north of the proposed project location on the project site.
3N.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of three questions when addressing the potential for significant impacts to population and housing. Would the proposed project: a. Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? b. Displace substantial amounts of existing housing, necessitating the construction of replacement housing elsewhere? c. Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
3N.4 IMPACT ANALYSIS
Impact 3N-a: Would the proposed project induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
No Impact
The proposed project would not induce population growth in the proposed project area. Implementation of the proposed project, which would accommodate up to 336 students in new buildings with a Program capacity of up to 567 students, would include students relocated from the existing Mandarin Immersion program at Broadway Elementary School, as well as new students who would enroll in the Program. Students who participate in the Mandarin Immersion program are considered to be traveling or “non-resident,” meaning that they can participate in the program even if it is not their LAUSD-designated resident school, which is based on the student’s home address. As the proposed project would not be limited to a student pool from the immediate neighborhood, it would not be growth-inducing and would not create the need for additional housing. As described in Subchapter 3Q, Transportation and Traffic, it is anticipated that the majority of students enrolled in the program will be dropped off by vehicles at the proposed student drop-off and parking areas instead of walking or riding bicycles from homes within the Mar Vista neighborhood. The proposed project would be located adjacent to a number of existing
18 Los Angeles Times. Accessed 21 October 2014. Mapping L.A.: Mar Vista. Available at: http://maps.latimes.com/neighborhoods/neighborhood/mar-vista/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-5 Draft EIR Subchapter 3N. Population and Housing roadways and would not indirectly induce population growth through the extension of roads or increasing the capacity of existing off-site infrastructure. The proposed project would involve the widening of Victoria Avenue and Walgrove Avenue to create a student drop-off area and right turn lane, respectively, in order to allow Victoria Avenue and Walgrove Avenue, which are designated as collector streets, to meet existing City of Los Angeles standards.19 The proposed project is intended to serve students who live within, and would not cause other students or their families to move to, Local District D of the LAUSD. The proposed project would thus not result in the creation of housing or infrastructure that would induce or accelerate population or household growth that would exceed SCAG Year 2020 projections for the LAUSD.20 As such, the proposed project would not stimulate population growth beyond that already projected to occur. Therefore, impacts on population growth would not occur, and no further study of this issue is required.
Impact 3N-b: Would the proposed project displace substantial amounts of existing housing, necessitating the construction of replacement housing elsewhere?
No Impact
The proposed project would not result in impacts to population and housing in relation to the displacement of substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere. The proposed project site is currently being used as athletic fields, a parking lot, and a painted track on the asphalt for the Mark Twain Middle School. There is no existing housing or housing being constructed on the paved parking lot, asphalt track, and athletic field on the northeastern portion of Mark Twain Middle School campus. The proposed project site is zoned for public facilities use, and the proposed project is an elementary school that does not involve displacement of housing or people.21 Therefore, there would be no impacts to population and housing related to the displacement of substantial amounts of existing housing, and no further study of this issue is required.
Impact 3N-c: Would the proposed project displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
No Impact
The proposed project would not result in impacts to population and housing by displacing substantial numbers of people, necessitating the construction of replacement housing elsewhere. The proposed project site is currently being used as athletic fields, a parking lot, and a painted track on the asphalt for the Mark Twain Middle School. There are no people currently residing on the paved parking lot, asphalt track, and athletic field on the northeastern portion of Mark Twain
19 City of Los Angeles Department of City Planning. Transportation Element: City of Los Angeles General Plan. Chapter VI – Street Designations and Standards. Available at: http://cityplanning.lacity.org/ 20 Los Angeles Unified School District. Office of Environmental Health and Safety. California Environmental Quality Act Specification Manual. Revised June 2007. 21 American Legal Publishing Corporation. 2013. Los Angeles Municipal Code, Chapter I (Planning and Zoning Code), Article 2: Specific Planning – Zoning Comprehensive Zoning Plan. Available at: http://www.amlegal.com/nxt/gateway.dll/California/lapz/municipalcodechapteriplanningandzoningco/chapterig eneralprovisionsandzoning/article2specificplanning- zoningcomprehen/sec120409pfpublicfacilitieszone?f=templates$fn=default.htm$3.0$vid=amlegal:lapz_ca$an c=. PDF available at: https://law.resource.org/pub/us/code/city/ca/LosAngeles/Municipal/chapter01.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-6 Draft EIR Subchapter 3N. Population and Housing
Middle School campus. The proposed project site is zoned for public facilities use and the proposed project is an elementary school that does not involve displacement of housing or people.22 Therefore, there would be no impacts to population and housing caused by a displacement of substantial numbers of people, and no further study of this issue is required.
3N.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts related to population and housing. Therefore, there would be no cumulative impacts.
3N.6 MITIGATION MEASURES
The proposed project would not result in significant impacts related to population and housing. Therefore, the consideration of mitigation measures is not required.
3N.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3N-a through 3N-c: No impact.
22 American Legal Publishing Corporation. 2013. Los Angeles Municipal Code, Chapter I (Planning and Zoning Code), Article 2: Specific Planning – Zoning Comprehensive Zoning Plan. Available at: http://www.amlegal.com/nxt/gateway.dll/California/lapz/municipalcodechapteriplanningandzoningco/chapterig eneralprovisionsandzoning/article2specificplanning- zoningcomprehen/sec120409pfpublicfacilitieszone?f=templates$fn=default.htm$3.0$vid=amlegal:lapz_ca$an c=. PDF available at: https://law.resource.org/pub/us/code/city/ca/LosAngeles/Municipal/chapter01.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3N-7 Draft EIR SUBCHAPTER 3O Public Services
This analysis is undertaken to determine if the proposed project may have a significant impact to public services, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The Los Angeles Fire Department (LAFD), Los Angeles School Police Department (LASPD), Los Angeles Department of Recreation and Parks, and the LAUSD serve the project area. The LAFD,2 LASPD,3 Los Angeles Department of Recreation and Parks,4 and LAUSD5 websites were referenced for this analysis.
3O.1 REGULATORY FRAMEWORK Federal
There are no applicable federal plans or policies related to public services. State
There are no applicable state plans or policies related to public services. Local
City of Los Angeles General Plan
Palms – Mar Vista – Del Rey Community Plan
The proposed project site is located in the Palms – Mar Vista – Del Rey CPA. Pursuant to a resolution adopted by the Board of Education for the LAUSD under Government Code Section 53094 that exempts the proposed project site from local zoning and land use regulations, LAUSD is not required to comply with the Community Plan.6 However, the Community Plan establishes similar community-focused policies that LAUSD is allowed to grant pursuant to the Civic Center Act, which permits the governing board of any school district to grant the public use of school facilities: the Palms – Mar Vista – Del Rey Community Plan encourages shared use of existing
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 LAFD. n.d. Los Angeles Fire Department. Available at: http://lafd.org/ 3 LASPD. Accessed 4 December 2014. Los Angeles School Police Department. Available at: http://www.laspd.com/about.html 4 City of Los Angeles Department of Recreation and Parks. n.d. Available at: http://www.laparks.org/index.htm 5 Los Angeles Unified School District. n.d. Available at: http://home.lausd.net/ 6 State of California. Accessed 1 December 2014. “Government Code Section 53094.” Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=gov&group=53001-54000&file=53090-53097.5 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-1 Draft EIR Subchapter 3O. Public Services school facilities for the general public after hours and on weekends.7 According to the Palms – Mar Vista – Del Rey Community Plan, school grounds should be made available to the public for after school hour recreational uses. The Palms – Mar Vista – Del Rey Community Plan establishes the following relevant goals, objectives, policies, and programs relevant to public services in the vicinity of the proposed project site:8
Goal 6: Appropriate locations and adequate school facilities to serve the needs of the existing and future population.
. Objective 6-1: To site schools in locations complementary with existing land uses and adequate buffering between residential uses and convenient to the community with access to recreational opportunities.
o Policy 6-1.3: Expansion of existing school facilities should be considered prior to acquisition of new sites.
Program: The Los Angeles Unified School District is the responsible agency for providing schools facilities.
o Policy 6-1.4: Encourage cooperation between the Los Angeles Unified School District and the Department of Recreation and Parks to provide recreation facilities for the community.
Program: The Los Angeles Unified School District and the Department of Recreation and Parks should develop a program where both schools and parks can be utilized for recreational and instructional purposes.
Goal 9: Protect the community through a comprehensive fire and life safety program.
. Objective 9-1: Ensure that fire facilities and protective services are sufficient for the existing and future population and land uses.
o Policy 9-1.1: Coordinate with the Fire Department the review of significant development projects and General Plan amendments affecting land use to determine the impact on service demands.
City of Los Angeles Municipal Code
The City of Los Angeles Municipal Code addresses public safety services in Chapter V (including Article 7, the Fire Protection and Prevention Code). The Fire Protection and Prevention Plan (Fire Code) of the City of Los Angeles provides an official guide for the construction, maintenance, and operation of fire facilities and is intended to promote fire prevention by maximizing fire safety
7 State of California Legislative Council. Accessed 31 October 2014. California Education Code Section 38130- 38139. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=edc&group=38001- 39000&file=38130-38139 8 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-2 Draft EIR Subchapter 3O. Public Services education and minimizing loss of life through fire prevention programs. Section 57.09.06 of the Municipal Code establishes the following requirements for industrial development:9
Maximum response distance to an LAFD Fire Station is 1 mile to an engine company or 1.5 miles to a truck company.
Where a response distance is greater than the requirement, all structures shall be constructed with automatic fire sprinklers, and additional fire protection shall be provided as required by the Chief.
3O.2 EXISTING CONDITIONS Fire
The LAFD provides fire protection services to the site, which is located within the City of Los Angeles in the neighborhood of Mar Vista. Fire protection services include fire prevention, fire suppression, and life safety services.10 The LAFD provides Class I fire protection, rescue, and emergency medical services for the citizens of the City of Los Angeles and City of San Fernando through the service of the following five bureaus: Administrative Services Bureau, Training and Support Bureau, Bureau of Emergency Operations, Bureau of Fire Prevention and Public Safety, and Emergency Services Bureau.11 There are 106 fire stations in the City of Los Angeles.12 LAFD operates two facilities within the Palms – Mar Vista – Del Rey CPA (Stations 62 and 43), and a fire station (Station 63) on Venice Boulevard in the Venice CPA (Figure 3O.2-1, Public Facilities in Vicinity of Proposed Project Site).13 Station 62, which serves the Mar Vista, Venice, and Del Rey communities, is the primary responder; Station 63 is the secondary responder (Table 3O.2-1, Existing Fire Stations Serving the Proposed Project Site).
9 American Legal Publishing Corporation. 30 September 2013. Los Angeles Municipal Code. Available at: http://www.amlegal.com/library/ca/losangeles.shtml Chapter V, Article 7 (Fire Code), Division 9: Access, Hydrants, and Fire-Flow Requirements. 10 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 11 City of Los Angeles. Accessed 1 December 2014. City of Los Angeles Departments and Bureaus. Available at: http://www.lacity.org/government/DepartmentsandBureaus/index.htm?laCategory=1962#Fire Main Department website: http://lafd.org/ 12 Los Angeles Fire Department. Accessed 1 December 2014. Fire Stations. Available at: http://lafd.org/find-a-fire- station 13 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-3 Draft EIR !( ")
!( %, !( !( LEGEND !( Los Angeles Fire !( ^]! Project Site ") !( Department %,Fire Stations Los Angeles Unified !( !( ") ") Other Fire Stations School District Schools Pocket Park (0-5 acres) !( Public Elementary Schools Neighborhood Park (5-15 acres) !( Public Middle Schools !( !( Community Park (15-1")00 acres) !( Public High Schools Regional Park (100+ acres) !( %, Libraries %, Recreation Center GF Hospital !( ") !( ") !( !( !( ") ") Fire Station ") #43 ") !( !( %, ")
%, Fire Station #62 ") %, !( %, ") ") Los Angeles Public Library - Mar Vista Branch %, !( !( !( ^]! !( !( !( Fire Station #63 !( !( ") !( !( !( %, Marina Del Rey Hospital ") %, GF !(
!(
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SOURCE: SEI, ESRI, LA Co. !( 0 0.5 1 !( %, Miles !( o 1:50,000 !( Q:\1498\MarkTwain_MS\ArcProjects\PublicFacilities.mxd
FIGURE 3O.2-1 Public Facilities in Vicinity of Proposed Project Site Subchapter 3O. Public Services
Table 3O.2-1: Existing Fire Stations Serving the Proposed Project Site Linear Distance to Driving Distance to Station Location Primary Service Area Site Site* 11970 Venice Blvd. Mar Vista, Venice, and Del Rey LAFD Station 62 0.96 mile east 1.8 miles (6 minutes) Los Angeles, CA 90066 communities 1930 Shell Ave Venice and Venice Beach 0.98 mile LAFD Station 63 1.4 miles (6 minutes) Venice, CA 90291 communities southwest 3690 Motor Ave Palms and South Cheviot Hills 3.1 miles (11 LAFD Station 43 2.7 miles east Los Angeles, CA 90034 communities minutes) NOTE: * Based on Google Maps directions.
The average full 911 response time to the proposed project site, based on performance from 2007 to 2012, is 7 minutes and 28 seconds.14,15 The proposed project site is not located within a wildfire hazard area.16 Police
The LASPD is the largest independent school police department in the United States, with over 350 sworn police officers, 126 non-sworn safety officers, and 34 civilian support staff.17 The LASPD provides police protection services to the proposed project site. The Campus Services Bureau serves as “First Responders” to critical incidents occurring on campus, off campus, and in the surrounding neighborhoods. Officers respond to in-progress calls for service, conduct parking/traffic enforcement and education, conduct the Ready Set Go Program, conduct the Anger Management Program for Students, provide an Anti-Bullying Awareness program, and conduct threat assessments. The LASPD headquarters is located at 125 North Beaudry Avenue, Los Angeles, California 90012.
The project area is also served by the Los Angeles Police Department’s Pacific Community Police Station, located at 12312 Culver Boulevard, Los Angeles, California 90066, approximately 2.3 miles southeast of the proposed project site address via police vehicle (distance is approximately 1.5 miles southeast) (see Figure 3O.2-1).18 The Pacific Division covers 25.7 square miles (16,473.6
14 Los Angeles Times Data Desk. Accessed 1 December 2014. Interactive Map: How Fast is LAFD Where You Live? Available at: http://graphics.latimes.com/how-fast-is-lafd/#15/34.0013/-118.4457 15 Data based on 107 responses within a grid surrounding the Mark Twain Middle School Campus, for which the average dispatch time was 1 minute and 35 seconds and average arrival time was 5 minutes and 54 seconds. 16 City of Los Angeles Department of City Planning. November 1996. Safety Element of the Los Angeles City General Plan. Available at: http://cityplanning.lacity.org/cwd/gnlpln/saftyelt.pdf Safety Element Exhibit D: Selected Wildfire Hazard Areas in the City of Los Angeles. Page 53. 17 LASPD. Accessed 4 December 2014. Los Angeles School Police Department. Available at: http://www.laspd.com/about.html 18 The Los Angeles Police Department. Accessed 17 November 2014. About Pacific. Available at: http://www.lapdonline.org/pacific_community_police_station/content_basic_view/1600 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-4 Draft EIR Subchapter 3O. Public Services acres), serving over 200,000 people in the neighborhoods of Venice Beach, Oakwood, Mar Vista, Playa del Rey, Playa Vista, Palms, and Westchester. Schools
The LAUSD administers public schools in the Palms – Mar Vista – Del Rey CPA.19 The Mark Twain Middle School campus, which currently serves grades 6–8, is one of the 1,309 schools served by the LAUSD.20 During the 2013–2014 school year, total LAUSD enrollment in grades K–12 was 653,826, including:21
312,758 in grades K–5 (elementary school grades)
142,888 in grades 6–8 (middle school grades)
198,180 in grades 9–12 (high school grades)22
In the past 18 academic years (1996–1997 to 2013–2014), the enrollment at Mark Twain Middle School has steadily declined from an enrollment of 1,393 students in 2003–2004 to a steady enrollment of approximately 700 students from the 2010–2011 to the 2013–2014 school years (Table 3O.2-2, K–12 Public School Enrollment). In contrast, the enrollment at Broadway Elementary School has consistently increased since the 2008–2009 school year, even as the overall enrollment within LAUSD has consistently declined since the 2003–2004 school year. The Mandarin Immersion Program was initiated at Broadway Elementary School in 2010 with 48 students, increasing by approximately 96 students each year, and has a current enrollment of 365 students for the 2014–2015 school year, currently accounts for approximately 70 percent the enrollment at Broadway Elementary School.23
19 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available at: http://cityplanning.lacity.org/ Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 20 California Department of Education (CDE). 30 October 2014. California Public Schools Directory. Available at: http://www.cde.ca.gov/re/sd/. 21 California Department of Education, Educational Demographics Unit. Accessed 30 October 2014. Enrollment by Grade for 2013-14: District Enrollment by Grade. Available at: http://data1.cde.ca.gov/dataquest/ 22 Note: some LAUSD schools vary in grade levels served from the grade levels in the preceding list (i.e., some school extend from grades K–8, and some charter schools provide education in both middle school and high school grades). 23 Singletary, Scott. 18 March 2015. Communication with Ms. Susan Wang, Principal at Broadway Elementary School. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-5 Draft EIR Subchapter 3O. Public Services
Table 3O.2-2: K–12 Public School Enrollment Number of Students Number of Students Number of Students Number of Enrolled at Mark Twain Enrolled at Broadway Enrolled in Mandarin Students Enrolled School Year Middle School1 Elementary School1 Immersion Program2 within LAUSD1 1996–97 980 342 0 667,305 1997–98 997 388 0 680,430 1998–99 995 437 0 695,885 1999–00 1,060 436 0 710,007 2000–01 1,217 432 0 721,346 2001–02 1,375 450 0 735,058 2002–03 1,382 372 0 746,852 2003–04 1,393 327 0 747,009 2004–05 1,284 323 0 741,367 2005–06 1,229 285 0 727,319 2006–07 1,073 314 0 707,626 2007–08 950 289 0 693,680 2008–09 811 257 0 687,534 2009–10 759 259 0 670,745 2010–11 707 277 48 667,251 2011–12 709 334 1443 662,140 2012–13 714 391 2403 655,494 2013–14 685 454 3363 653,826 SOURCE: 1 California Department of Education, Educational Demographics Unit. Accessed 30 October 2014. Enrollment by Grade for 2013-14: District Enrollment by Grade. Available at: http://data1.cde.ca.gov/dataquest/ 2 Singletary, Scott. 18 March 2015. Communication with Ms. Susan Wang, Principal at Broadway Elementary School. 3 Note: Enrollment numbers for 2011-2014 are approximate, based on an average incoming kindergarten enrollment of 96 students per year, a starting enrollment of 48 students in the 2010–2011 school year, and a 2014–2015 enrollment of 365 students, which includes some loss of enrollment at the higher grade levels.
There are 12 elementary schools and four middle (junior high) schools within the Palms – Mar Vista – Del Rey CPA, all of which are governed by the LAUSD.24 The nearest high school is Venice High School, which is located on Venice Boulevard and Walgrove Avenue within the adjacent Venice CPA (see Figure 2.2.2-6, Palms – Mar Vista – Del Rey Community Plan Area). Nearby K– 12 LAUSD schools within 1 mile of the Mark Twain Middle School campus include Broadway Elementary School, Walgrove Elementary School, Beethoven Street Elementary School, Venice
24 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-6 Draft EIR Subchapter 3O. Public Services
High School, Coeur d’Alene Avenue Elementary School, Short Avenue Elementary School, and Grand View Boulevard Elementary School (see Figure 2.1-1, Regional Site Map). Parks
According to the Health Atlas Report,25 a data-informed analysis of health conditions throughout the City of Los Angeles, the Palms – Mar Vista – Del Rey CPA had a population density of 13,437 people per square mile in 2010, with approximately 17 percent of the population under the age of 18 (approximately 19,000 people) and a 2012 park level of service of 0.3 (the lowest in City of Los Angeles). This level of service indicator includes state, county, regional, and municipal parks, but excludes restricted open spaces such as golf courses. Using a straight-line distance along the street network, the percentage of population within a half-mile walk to a park was calculated; the Palms – Mar Vista – Del Rey CPA had a low to moderate level of park access (53 percent).
The Palms – Mar Vista – Del Rey CPA has one existing community park and four existing neighborhood parks.26 The Mar Vista Park and Recreation Center (19 acres) consists of a large park area, pool, day care, and sports programs. Mar Vista Gardens (10 acres) provides a variety of sports and other activities for the public housing residents. Glen Alla Park (4.8 acres), Culver Slauson Park (2.9 acres), and Woodbine Park (1.2 acres) feature picnic and play areas (see Figure 3P.2-1, Parks and Recreation). In addition to the community parks, there are three existing large park facilities in proximity to the CPA: Venice Beach Recreation Center (Venice City Beach encompasses 138.5 acres), Rancho Park (183.5 acres), and Culver Slauson Park (Table 3O.2-3, Existing Parks in the Proposed Project Vicinity).
Table 3O.2-3: Existing Parks in the Proposed Project Vicinity Distance from Distance from Project Broadway Site at Mark Twain Elementary Park Name Acres Park Type Middle School School Culver West Park 3.1 Pocket park 0.8 mile southeast 1.6 miles east Glen Alla Park 4.8 Pocket park 1.3 miles southeast 1.9 miles southeast Marina Beach 3.0 Pocket park 1.4 miles southwest 1.0 mile south Culver Slauson Park 3.0 Pocket park 2.3 miles east 3.1 miles east Woodbine Park 1.2 Pocket park 2.8 miles northeast 3.6 miles northeast Marine Park 6.9 Neighborhood park 0.9 mile northwest 0.5 mile northwest Yvonne B. Burke Park 9.4 Neighborhood park 1.0 mile south 0.8 mile southeast Airport Park 7.2 Neighborhood park 1.0 mile north 1.4 miles northeast Burton Chace Park 7.2 Neighborhood park 1.5 miles south 1.6 miles southeast
25 City of Los Angeles Department of City Planning, Raimi & Associates, County of Los Angeles Department of Public Health, et al. June 2013. Health Atlas for the City of Los Angeles. Available at: http://cityplanning.lacity.org/Cwd/Framwk/healthwellness/text/HealthAtlas.pdf 26 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Available online at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available online at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-7 Draft EIR Subchapter 3O. Public Services
Table 3O.2-3: Existing Parks in the Proposed Project Vicinity Distance from Distance from Project Broadway Site at Mark Twain Elementary Park Name Acres Park Type Middle School School Mar Vista Gardens 7.2 Neighborhood park 1.8 miles southeast 2.8 miles east Virginia Avenue Park 5.6 Neighborhood park 1.8 miles northeast 1.6 mile north Ocean View Park 5.8 Neighborhood park 2.0 miles west 1.0 mile west Del Rey Lagoon Park 11.0 Neighborhood park 2.7 miles south 2.4 miles southeast Clover Park 18.5 Community park 1.0 mile north-northwest 1.1 mile northeast Culver City Park 38.6 Community park 3.5 miles east 4.3 miles east Community park / Mar Vista Recreation Center 19.7 1.2 miles northeast 2.2 miles northeast recreation center Penmar Recreation Center 12.7 Recreation center 0.5 mile northwest 0.5 mile north Oakwood Recreation Center 3.6 Recreation center 0.9 mile southwest 0.1 mile southwest Stoner Recreation Center 8.7 Recreation center 2.4 miles north 2.7 miles north Westchester Recreation Center 27.5 Recreation center 3.3 miles south 3.5 miles southeast Venice City Beach 138.5 Regional park 1.7 miles southwest 0.9 mile southwest Santa Monica State Beach 207.2 Regional park 1.9 miles west 1.1 miles northwest Dockweiler State Beach 316.9 Regional park 2.1 miles south-southwest 0.9 mile southwest Kenneth Hahn State Recreation 340.4 Regional park 4.1 miles east 5.1 miles east Area Will Rogers State Historic Park 187.8 Regional park 4.9 miles northwest 4.6 miles northwest Santa Monica Mountains National Recreation Area (including 153,075 Regional park 5.1 miles northwest 4.7 miles northwest Topanga State Park)
Other Public Facilities
Other public facilities include libraries and hospitals. Mark Twain Middle School has an existing student library with adjacent textbook room on the western portion of the school campus, located approximately 434 feet southwest of the proposed project site.27 The Broadway Elementary School campus also has a student library.28 The Los Angeles City Public Library also provides library services within the Palms – Mar Vista – Del Rey CPA, which is served primarily by the 5,450- square-foot Mar Vista Branch (Table 3O.2-4, Existing Public Libraries in the Project Vicinity; see Figure 3O.2-1). The majority of the local libraries are located closer to Mark Twain Middle School than Broadway Elementary School.
27 Los Angeles Unified School District. August 2011. Mark Twain Middle School: Campus Pre-Planning Survey. 28 Library Technology Guides. Accessed 4 December 2014. Broadway Elementary School. Available at: http://librarytechnology.org/diglib-fulldisplay.pl?SID=20141204412109375&code=lwc&RC=78596&Row=3 Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-8 Draft EIR Subchapter 3O. Public Services
Table 3O.2-4: Existing Public Libraries in the Project Vicinity Distance from Distance from Project Site at Mark Broadway Library Location Twain Middle School Elementary School 12006 Venice Boulevard Mar Vista Branch (City) 0.9 mile east 1.9 mile east Los Angeles, CA 90066 501 Venice Way Venice – Abbot Kinney Library (City) 1.4 mile southwest 0.6 mile southwest Los Angeles, CA 90291 6400 Playa Vista Drive Playa Vista (City) 2.4 miles southeast 2.8 miles southeast Playa Vista, CA 90094 2920 Overland Avenue Palms-Rancho Park Branch (City) 2.6 miles northeast 3.5 miles northeast Los Angeles, CA 90064 4533 Admiralty Way Lloyd Taber-Marina Del Rey (County) 1.3 mile south 1.5 mile southeast Marina del Rey, CA 90292
The nearest hospital to the proposed project site is Marina Del Rey Hospital, a 145-bed surgical hospital located at 4650 Lincoln Boulevard, approximately 1.4 miles south of the proposed project site.29
3O.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of the following question when addressing the potential for significant impact to public services: a. Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the following five public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
29 Marina Del Rey Hospital. Accessed 1 December 2014. “About Marina Del Rey Hospital.” Available at: https://www.marinahospital.com/about Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-9 Draft EIR Subchapter 3O. Public Services
3O.4 IMPACT ANALYSIS
Impact 3O-a: Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services?
No Impact
The proposed project would not result in significant impacts to public services in relation to fire protection services. The proposed project is nonresidential, involving the relocation of up to 336 students less than 1 mile from the existing program at Broadway Elementary School to new buildings at the existing Mark Twain Middle School campus, and would not be expected to result in substantial population growth. The Palms – Mar Vista – Del Rey CPA has adequate existing fire protection services, with two LAFD fire stations located within 1 mile of the proposed project site. As such, the proposed project would not directly generate any substantial new demand for fire protection services. Therefore, the proposed project would not result in significant impacts to fire protection services that would require the provision of new or altered facilities to maintain acceptable service ratios or response times.
Impact 3O-b: Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services?
No Impact
The proposed project would not result in significant impacts to public services in relation to police protection services. The proposed project is nonresidential, involving the relocation of up to 336 students less than 1 mile from the existing program at Broadway Elementary School to new buildings on the existing Mark Twain Middle School campus, and would not be expected to result in substantial population growth. As such, the proposed project would not directly generate any substantial new demand for police protection services. LASPD already provides police protection services at the Mark Twain Middle School campus. Therefore, the proposed project would not result in significant impacts to police protection services that would require the provision of new or altered facilities to maintain acceptable service ratios or response times.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-10 Draft EIR Subchapter 3O. Public Services
Impact 3O-c: Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for school services?
Less than Significant Impact
The proposed project would result in less than significant impacts to public services in relation to schools. The proposed project is nonresidential, involving the relocation of up to 336 students less than 1 mile from the existing program at Broadway Elementary School to new buildings on the existing Mark Twain Middle School campus, and would not be expected to result in substantial population growth. As such, the proposed project would not directly generate any substantial new demand for school services. Therefore, the proposed project would not result in significant impacts to school services that would require the provision of new or altered facilities to maintain acceptable service ratios or response times, other than the construction of the facilities contemplated by the proposed project that are the subject of this EIR.
Impact 3O-d: Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for park services?
No Impact
The proposed project would not result in significant impacts to public services in relation to parks. The proposed project is nonresidential, involving the relocation of up to 336 students less than 1 mile from the existing program at Broadway Elementary School to new buildings on the existing Mark Twain Middle School campus, and would not be expected to result in substantial population growth. As such, the proposed project would not directly generate any substantial new demand for parks. Therefore, the proposed project would not result in significant impacts to parks that would require the provision of new or altered facilities to maintain acceptable service ratios.
Impact 3O-e: Would the proposed project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for other public facilities?
No Impact
The proposed project would not result in significant impacts to public services in relation to other public facilities. The proposed project is nonresidential, involving the relocation of up to 336 students less than 1 mile from the existing program at Broadway Elementary School to new buildings on the existing Mark Twain Middle School campus, and would not be expected to result in substantial population growth. As such, the proposed project would not directly generate any substantial new demand for public facilities such as libraries or hospitals. The proposed project
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-11 Draft EIR Subchapter 3O. Public Services area is served by adequate library and hospital facilities. Therefore, the proposed project would not result in significant impacts to public services that would require the provision of new or altered facilities to maintain acceptable service ratios.
3O.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to public services. Therefore, there would be no cumulative impacts.
3O.6 MITIGATION MEASURES
The proposed project would not result in significant impacts to public services. Therefore, the consideration of mitigation measures is not required.
3O.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3O-a, 3O-b, 3O-d, and 3O-e: No impact.
Impact 3O-c: Less than significant impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3O-12 Draft EIR SUBCHAPTER 3P Recreation
This analysis is undertaken to determine if the proposed project may have a significant impact to recreation, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to recreation at the proposed project site was evaluated with regard to the Civic Center Act.2
3P.1 REGULATORY FRAMEWORK Federal
There are no applicable federal plans or policies related to recreation. State
California Education Code Section 38131.b
The Civic Center Act permits the governing board of any school district to grant the public use of school facilities.3 Organizations and uses qualifying for Civic Center permits include Parent- Teacher Associations (PTAs); Girl/Boy Scout Troops; senior citizens’ organizations; youth groups; recreational activities of clubs and associations concerned with education, recreation, arts, politics, economics, charity; meetings/discussions open to the general public concerned with education, politics, economics, arts, charities, culture, community moral interests; exercise classes such as jazzercise, aerobics, and jujitsu; good news clubs; and authorized ballroom dances sponsored by youth services and PTAs.4 School facilities available for Civic Center use include gyms, playing fields, stadiums, auditoriums, multipurpose rooms, cafeterias, and classrooms. These facilities are available only within designated time frames outside school hours. Organizations wishing to use a school location for a Civic Center use must apply for a permit from the LAUSD. A variety of rules, regulations, and restrictions governing the use of school buildings for civic center purposes appear in detail on the permit and the application.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 State of California Legislative Council. Accessed 31 October 2014. California Education Code Section 38130- 38139. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=edc&group=38001- 39000&file=38130-38139 3 State of California Legislative Council. Accessed 31 October 2014. California Education Code Section 38130- 38139. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=edc&group=38001- 39000&file=38130-38139 4 Los Angeles Unified School District, Facilities Services Division. Accessed March 2015. Available at: http://www.laschools.org/new-site/facility-use/civic-center-permit Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-1 Draft EIR Subchapter 3P. Recreation
Local
City of Los Angeles General Plan
Palms – Mar Vista – Del Rey Community Plan
The proposed project site is located within the Palms – Mar Vista – Del Rey CPA. Pursuant to a resolution adopted by the Board of Education for the LAUSD under Government Code Section 53094 that exempts the proposed project site from local zoning and land use regulations, LAUSD is not required to comply with the Community Plan.5 However, the Community Plan establishes similar community-focused policies that LAUSD is allowed to grant pursuant to the Civic Center Act, which permits the governing board of any school district to grant the public use of school facilities: the Palms – Mar Vista – Del Rey Community Plan encourages shared use of existing school facilities for the general public after hours and on weekends.6 According to the Palms – Mar Vista – Del Rey Community Plan, school grounds should be made available to the public for after school hour recreational uses. The Palms – Mar Vista – Del Rey Community Plan establishes the following relevant goals, objectives, policies, and programs relevant to recreation in the vicinity of the proposed project site:7
Goal 6: Appropriate locations and adequate school facilities to serve the needs of the existing and future population.
. Objective 6-1: To site schools in locations complementary with existing land uses and adequate buffering between residential uses and convenient to the community with access to recreational opportunities.
o Policy 6-1.4: Encourage cooperation between the Los Angeles Unified School District and the Department of Recreation and Parks to provide recreation facilities for the community.
Program: The Los Angeles Unified School District and the Department of Recreation and Parks should develop a program where both schools and parks can be utilized for recreational and instructional purposes.
3P.2 EXISTING CONDITIONS
The approximately 4.2-acre proposed project site is currently occupied by eight existing portable classrooms and an asphalt walkway to the north of the classrooms, the sidewalk along Victoria Avenue, a large asphalt area with painted parking stalls and a painted track used for physical
5 State of California. Accessed 1 December 2014. “Government Code Section 53094.” Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=gov&group=53001-54000&file=53090-53097.5 6 State of California Legislative Council. Accessed 31 October 2014. California Education Code Section 38130- 38139. Available at: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=edc&group=38001- 39000&file=38130-38139 7 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-2 Draft EIR Subchapter 3P. Recreation education, and an athletic recreational field on the existing Mark Twain Middle School campus (21.3 acres).
In accordance with the Civic Center Act, the existing athletic recreational field on the Mark Twain Middle School campus is used for soccer by several third-party organizations when available during non-school hours, including FC Los Angeles, which uses the field as one of the Club’s primary “home fields” for league play and most scrimmages.8,9 The athletic field is not used by the local AYSO (Region 19) soccer organization.10
The Palms – Mar Vista – Del Rey CPA has one existing community park and four existing neighborhood parks.11 The Mar Vista Park and Recreation Center (19 acres) consists of a large park area, pool, day care, and sports programs. Mar Vista Gardens (10 acres) provides a variety of sports and other activities for the public housing residents. Glen Alla Park (4.8 acres), Culver Slauson Park (2.9 acres), and Woodbine Park (1.2 acres) feature picnic and play areas. In addition to the community parks, there are three existing large park facilities in proximity to the CPA: Venice Beach Recreation Center (Venice City Beach encompasses 138.5 acres), Rancho Park (183.5 acres), and Culver Slauson Park.
There are 74 existing baseball fields (44 turf, 30 asphalt) and 11 turf soccer fields within the Palms – Mar Vista – Del Rey CPA, including 8 turf baseball fields on the Mark Twain Middle School campus (4 within the project site) and 1 turf soccer field on the Mark Twain Middle School campus (approximately half of it within the project site).
Additionally, the 3.6-acre playground at Beethoven Elementary School, which is located adjacent to the northeastern boundary of the proposed project site, is a community school park intended for public use.12 In 2012, a new full size multipurpose grass field opened on the “big yard” playground; LAUSD has been working towards a partnership with AYSO to support a local soccer program at the community school park.13 Existing Neighborhood Parks
The City of Los Angeles defines a neighborhood park as a 5- to 15-acre park serving residents within a half-mile radius of the park. The nearest neighborhood parks to the proposed project site are Marine Park (6.9 acres), located approximately 0.9 mile northwest of the Mark Twain Middle School campus; Yvonne B. Burke Park (5.6 acres), located approximately 1.0 mile south of Mark
8 Male, Laura, Sapphos Environmental, Inc. 4 December 2014. Conversation with Ms. Kay Rudolph, Mark Twain Middle School, main office. 9 FC Los Angeles. Accessed 4 December 2014. “Mark Twain Middle School.” Available at: http://www.fclosangeles.org/mar-vista.cfm 10 AYSO Region 19 Culver City, Mar Vista, Palms and Surrounding Areas. Accessed 4 December 2014. “Schedules.” Available at: http://www.ayso19.com/schedules.html 11 City of Los Angeles City Planning Department. Updated September 16, 1997. Palms – Mar Vista – Del Rey Community Plan, a part of the General Plan of the City of Los Angeles. Land use map available at: http://cityplanning.lacity.org/. Palms – Mar Vista – Del Rey Community Plan available at: http://cityplanning.lacity.org/complan/pdf/plmcptxt.pdf 12 Los Angeles Unified School District. July 2011. “Beethoven Elementary School: Pre-Planning Survey.” 13 Friends of Beethoven. Accessed 21 January 2015. Friends of Beethoven. Available at: http://www.friendsofbeethoven.org/about/
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-3 Draft EIR Subchapter 3P. Recreation
Twain Middle School; Airport Park (7.2 acres), located approximately 1.0 mile north of Mark Twain Middle School; Burton Chace Park (7.2 acres), located approximately 1.5 miles south of Mark Twain Middle School; Mar Vista Gardens (7.2 acres), located approximately 1.8 miles southeast of Mark Twain Middle School; and Virginia Avenue Park (5.6 acres), located approximately 1.8 miles northeast of Mark Twain Middle School (Figure 3P.2-1, Parks and Recreation). The proposed project area is underserved in regard to neighborhood parks. Existing Community Parks
According to the City of Los Angeles Public Recreation Plan, the service radius of a community park, a 15+ acre park, is defined as approximately 2 miles. There are two community parks located within 2 miles of Mark Twain Middle School (see Figure 3P.2-1). The nearest community park to the proposed project site is Clover Park (18.5 acres), which is located approximately 1.0 mile north-northwest of the Mark Twain Middle School campus; and Mar Vista Recreation Center (19.7 acres), which is located approximately 1.2 mile northeast of Mark Twain Middle School. The proposed project area is underserved in regard to community parks. Existing Recreation Centers
The nearest recreation centers are Penmar Recreation Center (12.7 acres), located approximately 0.5 mile northwest of Mark Twain Middle School; Mar Vista Recreation Center (19.7 acres), located approximately 1.2 mile northeast of Mark Twain Middle School; Oakwood Recreation Center (3.6 acres), located approximately 0.9 mile southwest of Mark Twain Middle School; Mar Vista Recreation Center (19.7 acres), located approximately 1.2 mile northeast of Mark Twain Middle School; and Stoner Recreation Center (8.7 acres), located approximately 2.4 miles north of Mark Twain Middle School (see Figure 3P.2-1). Existing Regional Parks
According to the Parks and Recreation Element of the County of Los Angeles General Plan, a regional park is typically greater than 100 acres in size and serves recreation users within a radius of 25 miles or more to provide users with an experience of the natural environment.14 The nearest regional parks are Venice City Beach (138.5 acres) in the City of Los Angeles, located approximately 1.7 miles southwest of Mark Twain Middle School; Santa Monica State Beach (207.2 acres) in the City of Santa Monica, located approximately 1.9 miles west of Mark Twain Middle School; Dockweiler State Beach (316.9 acres) in the Community of Playa Del Rey in the City of Los Angeles, located approximately 2.1 miles south-southwest of Mark Twain Middle School; Kenneth Hahn State Recreation Area (340.4 acres) in the Community of Ladera Heights in unincorporated Los Angeles County and the City of Los Angeles, located approximately 4.1 mile east of Mark Twain Middle School; Will Rogers State Historic Park (187.8 acres), located approximately 4.9 miles northwest of Mark Twain Middle School; and Santa Monica Mountains National Recreation Area (including Topanga State Park) (153,075 acres), located approximately 5.1 miles northwest of Mark Twain Middle School (see Figure 3P.2-1).
14 County of Los Angeles Department of Regional Planning. Accessed 31 October 2014. 2014 Draft General Plan 2035. Chapter 10: Parks and Recreation Element. Available at: http://planning.lacounty.gov/assets/upl/project/gp_2035_Chapter10_2014.pdf Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-4 Draft EIR Q:\1498\MarkTwain_MS\ArcProjects\ParksandRec.mxd
0 0.5 1 2 Miles Santa Monica Mountains o 1:95,000 National Recreation Area SOURCE: SEI, ESRI, LA Co.
Will Rogers State Historic Park
Stoner Recreation Center
Woodbine Park
Virginia Avenue Park Mar Vista Recreation Center
Santa Monica Clover Park State Beach Airport Park Penmar Culver City Park Kenneth Hahn Recreation Center State Recreation Area Marine Park !( Ocean View Culver Slauson Park Park Oakwood Recreation Center Mar Vista Gardens Yvonne B. Burke Park Glen Alla Park Venice City Beach
Burton W. Chace Park
Westchester Recreation Center
LEGEND Dockweiler State Beach !( Project Site Pocket Park (0-5 acres) Neighborhood Park (5-15 acres) Community Park (15-100 acres) Regional Park (100+ acres) Recreation Center County Boundaries
FIGURE 3P.2-1 Parks and Recreation Subchapter 3P. Recreation
3P.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of two questions when addressing the potential for significant impact to recreation. Would the proposed project: a. Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
3P.4 IMPACT ANALYSIS
Impact 3P-a: Would the proposed project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less than Significant Impact
The proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities that would cause or accelerate substantial deterioration of the facilities. The proposed project would not induce population growth in the project area, which would be the principal cause of such an impact. Implementation of the proposed project would include students relocated from the existing Mandarin Immersion program at Broadway Elementary School, as well as new students who would enroll in the program. Students who participate in the Mandarin Immersion program are considered to be traveling or “non-resident,” meaning that they can participate in the program even if it is not their LAUSD-designated resident school, which is based on the student’s home address. As the proposed project would not be limited to a student pool from the immediate neighborhood, it would not be growth-inducing. Thus, the proposed project would not result in the creation of housing that would induce or accelerate population or household growth that would exceed SCAG Year 2020 projections for the LAUSD.15 As such, the proposed project would not stimulate population growth beyond that already projected to occur, and would therefore not increase the use of existing neighborhood and regional parks or other recreational facilities that would cause or accelerate substantial deterioration of the facilities.
Recreation facilities required to support school programs would be provided on-site; therefore, there would be no impact on existing recreation facilities and programs within the adjacent communities of Mar Vista and Venice. Implementation of the proposed project would provide the new Mandarin and English Dual-Language Immersion Elementary School with elementary and kindergarten play areas, potentially resulting in no net loss of recreational facilities after the removal of a portion of an athletic field (1.9 acres) and an oval track (1.0 acre). Approximately 2 acres of the turf athletic field would remain as part of the middle school campus, as well as approximately 3.06 acres of asphalt recreation area, including nine tennis courts, 12 full-sized basketball courts, six half-sized basketball courts, 11 four-square courts, multiple handball courts, and a straight track for short-distance running. The oval track would be redrawn around the
15 LAUSD OEHS. California Environmental Quality Act Specification Manual. Revised June 2007.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-5 Draft EIR Subchapter 3P. Recreation remaining asphalt recreation area. Additionally, the 3.6-acre community school park at the adjacent Beethoven Elementary School campus, which is intended for public use including AYSO soccer practice, would remain open as a public park.
However, the proposed project would result in the reduction of recreational facilities available for organizations such as FC Los Angeles that have a contract with LAUSD under the Civic Center Act to use the soccer field, thereby potentially increasing the use of existing recreational facilities in the project area. The proposed project site encompasses an existing painted track on asphalt and the northern half of a turf multiuse athletic field with four baseball backstops. Approximately 700 students at Mark Twain Middle School and the organizations that have been permitted by LAUSD to use the school’s recreational facilities pursuant to the Civic Center Act would be affected by the loss of the proposed site’s existing recreational facilities, which has the potential to increase use at the nearest recreation centers: Penmar Recreation Center (12.7 acres), located approximately 0.5 mile northwest of Mark Twain Middle School; Mar Vista Recreation Center (19.7 acres), located approximately 1.2 mile northeast of Mark Twain Middle School; Oakwood Recreation Center (3.6 acres), located approximately 0.9 mile southwest of Mark Twain Middle School; Mar Vista Recreation Center (19.7 acres), located approximately 1.2 mile northeast of Mark Twain Middle School; and Stoner Recreation Center (8.7 acres), located approximately 2.4 miles north of Mark Twain Middle School (see Figure 3P.2-1). The impact on neighborhood recreation facilities would be expected to be below the level of significance because the Mark Twain Middle School campus would continue to provide approximately 5 acres of outdoor recreational facilities for the students, and the new athletic field would continue to be available during off-school hours for permitted use by public organizations. Therefore, the proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities that would cause or accelerate substantial deterioration of the facilities. No further study of this issue is required.
Impact 3P-b: Would the proposed project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
No Impact
The proposed project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. The proposed project would include the construction of recreational facilities to provide designated elementary school and kindergarten play areas to serve students within the Mandarin and English Dual-Language Program on the Mark Twain Middle School campus. The proposed recreational facilities for the play areas would be constructed at the location of an existing oval asphalt track and an existing athletic field, which would be expected to result in no expansion of recreational facilities. The proposed project site is not home to a listed species, does not involve a significant cultural resource, and does not affect any wetlands. Therefore, the proposed project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. No further study of this issue is required.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-6 Draft EIR Subchapter 3P. Recreation
3P.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to recreation. Therefore, there would be no cumulative impacts.
3P.6 MITIGATION MEASURES
The proposed project would not result in significant impacts to recreation. Therefore, the consideration of mitigation measures is not required.
3P.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact 3P-a: Less than significant impact.
Impact 3P-b: No impact.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3P-7 Draft EIR SUBCHAPTER 3Q Transportation/Traffic
This analysis is undertaken to determine if the proposed project may have a significant impact on Transportation/Traffic, which would require the consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines. This section evaluates the potential impacts of the proposed project on transportation and traffic through a consideration and evaluation of the results of the Traffic Study (Appendix H, Traffic Study) and other relevant data.1 Terminology
Level of Service. Traffic operations of roadway facilities are described as “Level of Service” (LOS). LOS is a qualitative description of traffic flow based on such factors as speed, travel time, delay, and freedom to maneuver. Six levels are defined—from LOS “A,” representing completely free-flow conditions, to LOS “F,” representing breakdown in flow resulting in stop-and-go conditions. LOS “E” represents operations at or near capacity, an unstable level where vehicles are operating with the minimum spacing for maintaining uniform flow. Table 3Q-1, Volume/Capacity and Corresponding Level of Service, summarizes the volume/capacity (V/C) ranges for LOS “A” through “F”. The V/C ranges are designated in the Los Angeles County Congestion Management Program, (CMP) as well as the General Plans for the City of Los Angeles and County of Los Angeles for signalized intersections.
1 KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H). Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-1 Draft EIR Subchapter 3Q. Transportation/Traffic
Table 3Q-1: Volume/Capacity and Corresponding Level of Service Volume to LOS Interpretation Capacity Ratio There are no stables that are fully loaded, and few are close to loaded. No approach phase is fully utilized by traffic and no vehicle waits longer than one red indication. Typically, the approach A 0.00–0.60 appears quite open, turning movements are easily made, and nearly all drivers find freedom of operation Represents stable operation. An occasional approach phase is fully utilized and a substantial B number are approaching full use. Many drivers begin to feel somewhat restricted within platoons 0.61–0.70 of vehicles. Stable operation continues. Full signal cycle loading is still intermittent, but more frequent. C Occasional drivers may have to wait through more than one red signal intersection, and backups 0.71–0.80 may develop behind turning vehicles. Encompasses a zone of increasing restriction approaching instability. Delays to approaching vehicles may be substantial during short peaks with the peak period, but enough cycles with D 0.81–0.90 lower demand occur to permit periodic clearance of developing queues, thus preventing excessive backups. Represents the most vehicles that any particular intersection approach can accommodate. At E capacity (V/C = 1.00), there may be long queues of vehicles waiting upstream of the intersection 0.90–1.00 and delays may be great (up to several signal cycles). Represents jammed conditions. Backups from locations downstream or on the cross street may restrict or prevent movement of vehicles out of the approach under consideration; hence, F >1.00 volumes carried are not predictable. V/C values are highly variable because full utilization of the approach may be prevented by outside conditions. SOURCE: Transportation Research Board. 2000. Highway Capacity Manual, 2000.
3Q.1 REGULATORY FRAMEWORK Federal
There are no applicable federal regulations. State
Complete Streets Act (Assembly Bill 1358)
Assembly Bill 1358, the Complete Streets Act (Government Code Sections 65040.2 and 65302), was signed into law by Governor Arnold Schwarzenegger in September 2008. The law requires cities and counties, when updating the part of a local general plan that addresses roadways and traffic flows, to ensure that those plans account for the needs of all roadway users. The goal of the legislation is to improve safety, access, and mobility for all travelers in California; and recognize bicycle, pedestrian, and transit modes as integral elements of the transportation system. Specifically, the legislation requires cities and counties to ensure that local roads and streets adequately accommodate the needs of bicyclists, pedestrians and transit riders, as well as motorists. At the same time, the California Department of Transportation (Caltrans) unveiled a revised version of Deputy Directive 64, an internal policy document that now explicitly embraces Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-2 Draft EIR Subchapter 3Q. Transportation/Traffic
Complete Streets as the policy covering all phases of state highway projects, from planning to construction to maintenance and repair. Local
The California legislature granted school districts the power to exempt school property from local zoning requirements, provided the school district complies with the terms of Government Code Section 53094.2 As lead agency for the proposed project, it is anticipated that LAUSD will comply with Government Code Section 53094 to render the local City of Los Angeles Zoning Ordinance inapplicable to the proposed project. Nevertheless, the LAUSD has considered local plans and policies for the communities surrounding its facilities. The boundaries of the LAUSD encompass most of the County of Los Angeles, along with all or portions of 31 cities and unincorporated areas of the county. For the purpose of this analysis, the City of Los Angeles and the County of Los Angeles traffic regulations are described.
Transportation Improvement Plan
The Los Angeles County Metropolitan Transportation Authority (Metro) serves as transportation planner and coordinator, designer, builder, and operator for Los Angeles County. Metro funds improvements to all modes of transportation through several programs, including the Transportation Improvement Program (TIP), the CMP, and Bicycle Transportation Strategic Plan. Metro operates rail and bus transit services throughout Los Angeles County.
Los Angeles County Congestion Management Program
The CMP involves monitoring traffic conditions and performance measures on the designated transportation network, analyzing the impact of land use decisions on the transportation network, and implementing mitigation measures to reduce impacts on the network. The CMP for Los Angeles County requires that the traffic impact of individual development projects of potentially regional significance be analyzed. A specific system of arterial roadways plus all freeways compose the CMP system. All new projects within the County of Los Angeles must comply with the CMP, which was adopted by the Metro pursuant to state law.3
Based on the CMP Transportation Impact Analysis (TIA) Guidelines, the following locations must be analyzed:
2 Government Code Section 53094. (a) Notwithstanding any other provision of this article, this article does not require a school district to comply with the zoning ordinances of a county or city unless the zoning ordinance makes provision for the location of public schools and unless the city or county has adopted a general plan. (b) Notwithstanding subdivision (a), the governing board of a school district, that has complied with the requirements of Section 65352.2 of this code and Section 21151.2 of the Public Resources Code, by a vote of two-thirds of its members, may render a city or county zoning ordinance inapplicable to a proposed use of property by the school district. The governing board of the school district may not take this action when the proposed use of the property by the school district is for non-classroom facilities, including, but not limited to, warehouses, administrative buildings, and automotive storage and repair buildings. (c) The governing board of the school district shall, within 10 days, notify the city or county concerned of any action taken pursuant to subdivision (b). 3 Los Angeles County Metropolitan Transportation Authority. 2010. Congestion Management Program for Los Angeles County. Available at: http://www.metro.net/projects/congestion_mgmt_pgm/ Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-3 Draft EIR Subchapter 3Q. Transportation/Traffic
Mainline freeway monitoring locations where a project will add 150 or more trips, in either direction, during either a.m. or p.m. weekday peak hours.
All CMP arterial monitoring intersections, including freeway on- and off-ramp intersections, where a proposed project will add 50 or more trips during either the a.m. or p.m. weekday peak hours (of adjacent street traffic).
Appendix D of the CMP includes Transportation Impact Assessment (TIA) guidelines. It requires a TIA for any project that impacts CMP highways and intersections. If a project does not add, but merely shifts trips at a given monitoring location, a CMP analysis is not required.
A significant impact occurs when a project increases traffic demand on a CMP facility by 2 percent of capacity (V/C ≥ 0.02), causing LOS F (V/C > 1.00); if the facility is already at LOS F, a significant impact occurs when a project increases traffic demand on a CMP facility by 2 percent of capacity (V/C ≥ 0.02).
County of Los Angeles General Plan
V/C ranges for LOS “A” through “F” are designated in the Los Angeles County general plans for signalized intersections. The Intersection Capacity Utilization (ICU) methodology is the preferred method to calculate the existing and future level of service at intersection, per the Los Angeles County guidelines.4 According to the county, a project would cause an increase in traffic on a highway that is substantial in relation to the existing traffic load and capacity of the street system if the project would:
Increase the V/C ratio or ICU by at least one percentage point (0.01) at any location where the final V/C ratio or ICU is 0.91 or greater (LOS E or F).
Increase the V/C ratio or ICU by at least two percentage points (0.02) at any location where the final V/C ratio or ICU is between 0.81 and 0.90 (LOS D).
Increase the V/C ratio or ICU by at least four percentage points (0.04) at any location where the final V/C ratio or ICU is between 0.71 and 0.80 (LOS C).
City of Los Angeles General Plan – Transportation Element
The City of Los Angeles Department of Transportation (LADOT) sets long-term goals for the city’s transportation needs. LADOT is the main agency responsible for the planning, design, construction, and operations of transportation systems in the City of Los Angeles. The LADOT works in conjunction with the city’s planning department to set long-term polices related to the city’s future transportation needs.
The City of Los Angeles General Plan contains definitions, goals and objectives, and regulatory requirements for a variety of roadway classifications that make up the city’s roadway system. The City of Los Angeles General Plan implements citywide development standards which require the following:
4 County of Los Angeles Department of Public Works. 1997. County of Los Angeles Traffic Impact Analysis Report Guidelines, p. 5 and 6. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-4 Draft EIR Subchapter 3Q. Transportation/Traffic
a. Whenever practicable, driveway access to buildings from side streets or alleys in order to minimize interference with pedestrian access and vehicular movement (for properties with frontage along major or secondary highways).
b. Whenever possible, off-street loading/dock facilities for all non-residential buildings, sufficient to accommodate the shipping and receiving needs of such buildings.
1. Expanded truck loading and turning areas on-site in industrial areas and for large shopping centers.
2. Revise geometric design standards for street intersections in and around industrial areas with high truck volumes.
c. Encourage transit friendly site design, where appropriate. This includes management of curb areas adjacent to transit centers to facilitate smart shuttles and taxi queuing.
d. Protect lower density residential areas from the intrusion of “through traffic” by implementing neighborhood traffic management programs. These programs shall include measures to reduce/control speeding and measures (including partial street closures) to reduce traffic volumes on neighborhood local streets. Any proposed partial street closure shall be subject to approval by LADOT and the Los Angeles Fire Department.
It should be noted that the City of Los Angeles does not have threshold criteria for stop-controlled intersections. Significant impacts at the unsignalized intersections are generally defined by changes in LOS to D or worse due to project-related traffic, plus the results of peak-hour signal warrant analyses.
Coastal Transportation Corridor Specific Plan (CTCSP)
The Coastal Transportation Corridor Specific Plan (CTCSP) was originally adopted in 1985 and was updated by the City of Los Angeles in 1993. The CTCSP was the first trip fee program implemented by the City of Los Angeles. The intent of the plan was to provide a funding mechanism for transportation improvements within the Specific Plan area that were determined to be necessary to accommodate and mitigate projected future development. While some of the improvements contained in the CTCSP have subsequently been implemented, others have not. The passage of time and changes in both development and traffic patterns and broader issues affecting transportation planning (e.g., greenhouse gases, increased emphasis on non-traditional means) have affected transportation priorities in the Westside. The key purposes included as part of the Coastal Transportation Corridor Specific Plan that are relevant to the proposed project are included below:
1. Promote or increase work-related ridesharing and bicycling to reduce peak-hour Trips and to keep critical intersections from severe overload; and
2. Avoid Peak Hour Level of Service (LOS) on streets and interchanges from reaching LOS F or, if presently at LOS F, preclude further deterioration in the Level of Service; and
3. Promote the development of coordinated and comprehensive transportation plans and programs with other jurisdictions and public agencies;
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-5 Draft EIR Subchapter 3Q. Transportation/Traffic
3Q.2 EXISTING CONDITIONS
The proposed project site is located on the existing Mark Twain Middle School campus. Mark Twain Middle School was selected as the proposed project location due to its proximity to Venice High School and its ability to feed into the World Languages Magnet program at Mark Twain Middle School.
Although the proposed project is not regionally significant as defined by the County of Los Angeles and the City of Los Angeles, a traffic impact study was completed to address the concerns voiced by the community during the scoping process. The proposed project does not meet the criteria for projects of statewide, regional or area wide significance. The project site is located within the City of Los Angeles and therefore the local area falls within the jurisdiction of the City of Los Angeles Department of Transportation (LADOT), but as the study area overlapped neighboring jurisdictions as well, the scoping effort for this project technical study also included coordination with the City of Santa Monica, the City of Culver City, and the County of Los Angeles Department of Public Works.
Fieldwork was undertaken to identify the condition of major roadways, to identify traffic control and approach lane configuration at each study intersection, and to identify the locations of on- street parking and transit stops (see Appendix H).
The proposed project study area is defined by the following intersections:
1. Lincoln Boulevard & Marine Avenue (City of Santa Monica)
2. 23rd Street & Ocean Park Boulevard (City of Santa Monica)
3. Bundy Drive & Airport Avenue (City of Santa Monica)
4. Walgrove Avenue & Rose Avenue (City of Los Angeles)
5. Walgrove Avenue & Morningside Way (City of Los Angeles)
6. Walgrove Avenue & Palms Boulevard (City of Los Angeles)
7. Beethoven Street & Palms Boulevard (City of Los Angeles)
8. Centinela Avenue & Palms Boulevard (City of Los Angeles)
9. Walgrove Avenue & Victoria Avenue, West-Leg (City of Los Angeles)
10. Beethoven Street & Victoria Avenue, East-Leg (City of Los Angeles)
11. Centinela Avenue & Charnock Avenue (City of Los Angeles)
12. Lincoln Boulevard & Venice Boulevard (City of Los Angeles)
13. Walgrove Avenue & Venice Boulevard (City of Los Angeles)
14. Beethoven Street & Venice Boulevard (City of Los Angeles)
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-6 Draft EIR Subchapter 3Q. Transportation/Traffic
15. Centinela Avenue & Venice Boulevard (City of Los Angeles)
16. Beethoven Street & Zanja Street-Caswell Avenue (City of Los Angeles)
17. Lincoln Boulevard & Washington Boulevard (City of Los Angeles)
18. Glencoe Avenue & Washington Boulevard (City of Culver City)
19. Walgrove Avenue & Washington Boulevard (City of Culver City)
20. Beethoven Street & Washington Boulevard (City of Culver City)
21. Centinela Avenue & Washington Place (City of Los Angeles/City of Culver City)
22. Centinela Avenue & Washington Boulevard (City of Los Angeles/City of Culver City)
23. Lincoln Boulevard & Bali Way (Los Angeles County/City of Los Angeles)
24. Lincoln Boulevard & Mindanao Way (Los Angeles County/City of Los Angeles)
25. Lincoln Boulevard & Fiji Way (Los Angeles County/City of Los Angeles)
Figure 3Q.2-1, Traffic Study Area Map, illustrates the locations of the study intersections and the proposed project site. Key roadways within the study area are shown in Table 3Q.2-1, Study Area Roadway Descriptions.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-7 Draft EIR (!2 Santa Monica (! (!1 3
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(! (!5 (!3 4
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(!9 (!10 (!11 (!12
(!13 (! (!14 (!1 (!2 (!15 3 Culver City (!4
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Sources: Esri, HERE, DeLorme, TomTom, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), swisstopo, MapmyIndia, © OpenStreetMap contributors, and the GIS User Community
LEGEND
Project Site
(! Study Intersection N
SOURCE: KOA Corporation Not to Scale
FIGURE 3Q.2-1 Traffic Study Area Map Subchapter 3Q. Transportation/Traffic
Table 3Q.2-1: Study Area Roadway Descriptions #Lanes Median Parking Restrictions Posted Segment From To NB/EB SB/WB Type NB/WB SB/EB General Land Use Speed Limit Rose Avenue Penmar Avenue Morningside Way 1 1 2LT/ST Permitted Permitted Recreational / Residential 25 Maplewood Morningside Way Penmar Avenue 1 1 DY Permitted Permitted / No Stopping 7 a.m. – 5 p.m. (School Days) Institutional / Residential Not Posted Avenue Maplewood Palms Boulevard Penmar Avenue 1 1 NS Permitted/NPAT Permitted Residential 25 / 35 Avenue Penmar Avenue Walgrove Avenue 1 1 NS Permitted Permitted Institutional / Residential Not Posted Victoria Avenue Walgrove Avenue Beethoven Street 1 1 NS Permitted No Stopping 7 a.m. – 5 p.m. (School Days) Institutional / Residential Not Posted Penmar Avenue Walgrove Avenue 1 1 NS Permitted / Handicap Parking Only Permitted Institutional / Residential Not Posted Lucille Avenue Walgrove Avenue Beethoven Street 1 1 NS Permitted / Handicap Parking Only Permitted Institutional / Residential Not Posted Lincoln Boulevard Walgrove Avenue 3 3 RM Permitted / 1-Hour Parking 8 a.m. – 6 p.m. Permitted Handicap Parking Only Commercial / Residential 40 15-Min. Parking 7 a.m. – 5 p.m. (School Days) / No Parking 7 a.m. – 5 Walgrove Avenue Beethoven Street 3 3 RM No Parking Commercial / Residential / Institutional 40 Venice Boulevard p.m. (School Days) / 2-Hour Parking 8 a.m. – 6 p.m. 15-Min Parking 8 a.m. – 6 p.m. / 1-Hour Parking 8 a.m. – 6 p.m. / Beethoven Street Wade Street 3 3 RM 1-Hour Parking 8 a.m. – 6 p.m. / Permitted Commercial / Residential 40 Permitted Rose Avenue Morningside Way 1 1 DY NSAT / Permitted Permitted Residential Not Posted No Parking 7 a.m. – 5 p.m. (School Days) / No Stopping 7 a.m. – 5 Morningside Way Palms Boulevard 1 1 DY Permitted p.m. (School Days) / Passenger Loading 6:30 – 9 a.m. & 1:30 – 4 p.m. Institutional / Residential 25 (School Days) / 2-Hour Parking 9 a.m. – 1:30 p.m. (School Days) Walgrove Avenue Palms Boulevard Victoria Avenue 1 1 DY Permitted Permitted Institutional / Residential 25 Victoria Avenue Lucille Avenue 1 1 DY Permitted Permitted Institutional / Residential 25
Lucille Avenue Venice Boulevard 1 1 DY Permitted Permitted Residential 25
Morningside Way Palms Boulevard 1 1 ST Permitted Permitted Commercial / Residential 30
Palms Boulevard Victoria Avenue 1 1 ST 15-Min. Parking 7 a.m. – 5 p.m. (School Days) / Permitted Permitted Institutional / Residential 30 Beethoven Street Passenger Loading 6:30 – 9 a.m. & 1:30 – 4 p.m. (School Victoria Avenue Lucille Avenue 1 1 ST Days) / 2-Hour Parking 9 a.m. – 1:30 p.m. (School Days) / No Permitted Institutional / Residential Not Posted Stopping 7 a.m. – 5 p.m. (School Days) Lucille Avenue Venice Boulevard 1 1 ST Permitted Permitted Commercial / Residential 30 KEY: NS = no striping ST = striped DY = double yellow RM = raised median NSAT = no stopping anytime NPAT = no parking anytime 2LT = dual left turn
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-8 Draft EIR Subchapter 3Q. Transportation/Traffic
Intersection-turn movement counts were conducted at the study intersections on:
Wednesday, May 14, 2014 during the timeframes of 7:00 a.m. to 9:00 a.m. and 3:00 p.m. to 5:00 p.m.
Wednesday, December 10, 2014 during the timeframes of 7:00 a.m. to 10:00 a.m. and 3:00 p.m. to 6:00 p.m.
Thursday, January 22, 2015 during the timeframes of 7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.
The results of the counts were used to determine existing weekday a.m. and p.m. peak-hour conditions. Traffic counts conducted during the year 2014 were factored to existing year-2015 conditions.
Forecast Project trip generation was based on private school rates defined within Trip Generation (9th edition), published by the Institute of Transportation Engineers (ITE). The trip generation used the ITE assumptions for Private school that reflect the potential for students to travel longer distances, and a higher frequency of students to travel to and from school via automobile— consistent with the student populations for other schools where dual language immersion programs exist.
For analysis of LOS at signalized intersections, LADOT has designated the Circular 212 Planning methodology as the desired tool. The concept of roadway level of service under the Circular 212 method is calculated as the volume of vehicles that pass through the facility divided by the capacity of that facility. A facility is “at capacity” (V/C of 1.00 or greater) whereby extreme congestion occurs. This volume/capacity ratio value is a function of hourly volumes signal phasing, and approach lane configuration on each leg of the intersection.
For analysis of level of service (LOS) at signalized intersections and stop-controlled intersections, the City of Santa Monica has designated the operational analysis method from Highway Capacity Manual (HCM) published by the Transportation Research Board (TRB). The HCM expresses levels of service in terms of "delay" and in terms of "average seconds per vehicle" for the study intersections. This delay value is based upon volumes by lane, signal phasing, and approach lane configuration.
SB 743 requires that the State Office of Planning and Research (OPR) change State CEQA guidelines for traffic significance thresholds to utilize new metrics, including vehicle miles traveled (VMT), in addition to LOS values. At the time of the Notice of Preparation for this EIR, OPR has not issued guidance upon these thresholds; therefore, VMTs were not used as the basis for assessing significance of impacts.
For analysis of level of service at signalized intersections within Culver City, the Intersection Capacity Utilization (ICU) methodology was utilized. The concept of roadway level of service under the ICU methodology is calculated as the critical volume of vehicles that pass through the facility divided by the capacity of that facility. A facility is “at capacity” (volume-to-capacity of 1.00 or greater) when extreme congestion occurs. This volume-to-capacity (V/C) ratio value is based upon volumes by lane and approach lane configuration. For this analysis, a lane capacity of 1,600
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-9 Draft EIR Subchapter 3Q. Transportation/Traffic vehicles per hour per lane (vphpl) for all through and single turn lanes, 2,880 vphpl for dual left- turn lanes and a total loss time of 10% were used.
For the unsignalized study intersections of Walgrove Avenue/Washington Boulevard and Beethoven Street/Zanja Street/Caswell Street, LOS values were evaluated by using the Highway Capacity Manual unsignalized methodology. LADOT does not define impact thresholds for un- signalized intersections, but these locations were included in the analysis to provide a review of operations at intersections in close proximity to the Project site. The analysis of these locations focused on LOS values only and specific impact thresholds were not applied. Where LOS values would worsen to, or within, LOS E or F with the proposed Project; traffic signal warrants were evaluated.
The applied traffic signal warrants were based on a peak-hour period analysis defined by the California Edition of the Manual of Uniform Traffic Control Devices (MUTCD).
Traffic count summaries are provided in Appendix B of the Traffic Study, which is Appendix H to the EIR. Existing level of service values at each of the study intersections are shown in Table 3Q.2- 2, Existing Peak-Hour Level of Service Summary.
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Table 3Q.2-2: Existing Peak-Hour Level of Service Summary Existing AM Peak Hour PM Peak Hour Study Intersections Jurisdiction V/C or Delay LOS V/C or Delay LOS 1 Lincoln Boulevard & Marine Avenue Santa Monica 8.5 A 16.6 B 2 23rd Street & Ocean Park Boulevard Santa Monica 22.8 C 19.3 B Santa Monica 5.9 A 14.9 B 3 Bundy Drive & Airport Avenue Los Angeles 0.667 B 0.791 C 4 Walgrove Avenue & Rose Avenue Los Angeles 1.082 F 0.900 D 5 Walgrove Avenue & Morningside Way Los Angeles 0.543 A 0.567 A 6 Walgrove Avenue & Palms Boulevard Los Angeles 0.622 B 0.591 A 7 Beethoven Street & Palms Boulevard Los Angeles 0.559 A 0.741 C 8 Centinela Avenue & Palms Boulevard Los Angeles 0.909 E 0.963 E 9 Walgrove Avenue & Victoria Avenue, West-Leg Los Angeles 0.534 A 0.477 A 10 Beethoven Street & Victoria Avenue, East-Leg Los Angeles 0.393 A 0.381 A 11 Centinela Avenue & Charnock Avenue Los Angeles 0.675 B 0.583 A 12 Lincoln Boulevard & Venice Boulevard Los Angeles 0.788 C 0.824 D 13 Walgrove Avenue & Venice Boulevard Los Angeles 0.784 C 0.807 D 14 Beethoven Street & Venice Boulevard Los Angeles 0.769 C 0.769 C 15 Centinela Avenue & Venice Boulevard Los Angeles 0.937 E 1.002 F 16 Beethoven Street & Zanja Street * Los Angeles 14.8 B 21.5 C 17 Lincoln Boulevard & Washington Boulevard Los Angeles 0.827 D 0.789 C 18 Glencoe Avenue & Washington Boulevard Culver City 0.748 C 0.844 D 19 Walgrove Avenue & Washington Boulevard * Culver City 87.7 F >100 sec F 20 Beethoven Street & Washington Boulevard Culver City 0.673 B 0.774 C Culver City 0.899 D 0.951 E 21 Centinela Avenue & Washington Place Los Angeles 0.798 C 0.856 D Culver City 0.868 D 0.948 E 22 Centinela Avenue & Washington Boulevard Los Angeles 0.719 C 0.805 D L.A. County 0.440 A 0.563 A 23 Lincoln Boulevard & Bali Way Los Angeles 0.440 A 0.563 A L.A. County 0.664 B 0.872 D 24 Lincoln Boulevard & Mindanao Way Los Angeles 0.664 B 0.872 D L.A. County 0.572 A 0.770 C 25 Lincoln Boulevard & Fiji Way Los Angeles 0.572 A 0.770 C NOTE: *Un-signalized intersection. SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
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Table 3Q.2-3, Proposed Project Trip Generation, summarizes the number of trips generated as a result of the proposed project.
Table 3Q.2-3: Proposed Project Trip Generation A.M. Peak P.M. Peak Total In Out Total In Out 510 281 230 340 160 180 Source: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
The project design features outlined in Section 2.0, Project Description, describe the existing street widths, and proposed street widening as part of the project construction, and in order to make Walgrove Avenue and Victoria Avenue compliant with the definition of a collector street.
Existing public transportation servicing the proposed project area is summarized below in Table 3Q.2-4, Transit Service Summary.
Table 3Q.2-4: Transit Service Summary Peak Agency Line From To Via Frequency Metro 33 Santa Monica Downtown Los Venice Boulevard 6–15 Minutes Angeles Metro Rapid 733 Santa Monica Downtown Los Venice Boulevard 7–15 Minutes Angeles Santa Monica Big 1 Westwood Venice Victoria Avenue / Walgrove 10–30 Minutes Blue Bus Avenue / Venice Boulevard / Lincoln Boulevard Santa Monica Big 3 Westwood LAX Lincoln Boulevard 15–30 Minutes Blue Bus Santa Monica Big 6 Santa Monica Palms Centinela Boulevard 25–60 Minutes Blue Bus Santa Monica Big 14 Brentwood Culver City Centinela Boulevard 13–30 Minutes Blue Bus Santa Monica Big Rapid 3 Santa Monica LAX Lincoln Boulevard 12–30 Minutes Blue Bus Culver City 2 Venice Culver City Lincoln Boulevard / Venice 60 Minutes Boulevard / Centinela Boulevard Culver City 5 Venice Culver City Venice Boulevard / Centinela Boulevard SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
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3Q.3 THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines recommend the consideration of six questions when addressing the potential for significant impact to transportation/traffic. Would the proposed project: a. Conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system; taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to, intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit?
LADOT has established specific thresholds for project related increases in the V/C of study intersections, shown in Table 3Q.3-1, LADOT Intersection Significance Threshold.
Table 3Q.3-1: LADOT Intersection Significance Thresholds Level of Service Final V/C Ratio Project-Related Increase in V/C C > 0.701–0.800 Equal to or greater than 0.040 D > 0.801–0.900 Equal to or greater than 0.020 E > 0.901–1.000 Equal to or greater than 0.010 F Greater than 1.000 Equal to or greater than 0.010 SOURCE: City of Los Angeles, Department of Transportation. June 2013. Traffic Study Policies & Procedures. Available at: http://ladot.lacity.org/stellent/groups/departments/@ladot_contributor/documents/contributor_web_content/lacit yp_026875.pdf
b. Conflict with an applicable congestion management program, including, but not limited to, level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c. Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d. Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e. Result in inadequate emergency access? f. Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities; or otherwise decrease the performance or safety of such facilities?
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3Q.4 IMPACT ANALYSIS
Impact 3Q-a: Conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including, but not limited to intersections streets, highways and freeways, pedestrian and bicycle paths, and mass transit?
Potentially Significant Impact
The Traffic Study identifies significant impacts, in relation to the thresholds of significance established by the LADOT, to LOS in the existing peak traffic conditions at six intersections in the study area: (1) Walgrove Avenue/Rose Avenue, (2) Centinela Avenue/Palms Boulevard, (3) Walgrove Avenue/Venice Boulevard, (4) Beethoven Street/Venice Boulevard, (5) Centinela Avenue/Venice Boulevard, and (6) Walgrove Avenue/Washington Boulevard. The public transportation that services the proposed project site, as shown in Table 3Q.2-4, utilizes all of these affected streets. Therefore, the proposed project would be anticipated to result in a significant impact on the effectiveness of the transportation system, requiring the consideration of mitigation measures.
Impact 3Q-b: Conflict with an applicable congestion management program, including, but not limited to, level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways?
Potentially Significant Impact
As documented above for Impact 3Q-a, and as demonstrated in Table 3Q.4-2, the proposed project would be expected to result in significant impacts to the following six intersections: (1) Walgrove Avenue/Rose Avenue, (2) Centinela Avenue/Palms Boulevard, (3) Walgrove Avenue/Venice Boulevard, (4) Beethoven Street/Venice Boulevard, (5) Centinela Avenue/Venice Boulevard, and (6) Walgrove Avenue/Washington Boulevard. There would be substantial changes to V/C and a decrease in LOS in these intersections as a result of the proposed project, requiring the consideration of mitigation measures.
Impact 3Q-c: Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks?
No Impact
The proposed project site is within a 2-mile radius of the Santa Monica Municipal Airport. However, the proposed project site is outside of the area of impact as defined by the Airport Planning and Land Use Commission. The proposed project would be developed on the existing Mark Twain Middle School campus. Therefore, the proposed project would not result in significant impacts to air traffic patterns or result in substantial safety risks, and the consideration of mitigation measures is not warranted.
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Impact 3Q-d: Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
No Impact
The proposed project would not substantially increase hazards due to a design feature or incompatible use. Proposed project design features include a setback along Victoria Avenue of 12 feet, and a widening of the east portion of Walgrove Avenue. These features would enhance existing drop-off zones for students and partially alleviate traffic congestion on Walgrove Avenue and Victoria Avenue. The proposed project would not result in incompatible uses. Therefore, there would be no impact, and the consideration of mitigation measures is not warranted.
Impact 3Q-e: Result in inadequate emergency access?
Less than Significant Impact
The proposed project would result in less than significant impacts to emergency access. The proposed project would be developed on the existing Mark Twain Middle School campus, which has a Safe School Plan, consisting of the school’s Coordinated Safe and Healthy School Plan (CSHS Plan), Prevention Programs, Emergency Procedures, and Recovery Procedures. The adjacent Beethoven Elementary School has a Safe School Plan, and the Mandarin and English Dual- Language Immersion Program would have a Safe School Plan as well. Although there would be an increase in the number of vehicle trips as a result of the proposed project, the ability of emergency vehicles to access the proposed project site would not change. The Safe School Plans have taken into account a wide range of possible planning scenarios to provide for the access, safety, and functional needs of the whole school community during school days as well as on and off campus, including coordination with surrounding neighborhoods to communicate about anticipated traffic patterns. With advanced planning, it is anticipated that there would be less than significant impacts with regards to emergency access, and the consideration of mitigation measures is not warranted.
Impact 3Q-f: Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities?
Less than Significant Impact
The Traffic Study considers potential pedestrian crossing locations as part of the Project Design Features to accommodate an increased number of pedestrians in the vicinity of the proposed project. As demonstrated above, the proposed project would be anticipated to result in increased congestion generally in the vicinity of the project. However, the proposed project would not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. Therefore, the proposed project would result in less than significant impacts, and the consideration of mitigation measures is not warranted.
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3Q.5 CUMULATIVE IMPACTS
As described in Impacts 3Q-a and 3Q-b above, the proposed project would be expected to result in a significant impact to transportation and traffic in relation to conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including, but not limited to intersections streets, highways and freeways, pedestrian and bicycle paths, and mass transit; and in relation to conflict with an applicable congestion management program, including, but not limited to, level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways. The anticipated impacts of the proposed projects would combine with the impacts of related past, present, or reasonably foreseeable, probable future projects listed in Table 2.5-1, List of Related Projects, resulting in a decrease in LOS in the proposed project vicinity to values of E or F. The intersections identified below have significant impacts regarding future baseline conditions, as shown in Table 3Q.5-1, Projected Impact Summary for Future Baseline Conditions. As indicated in Table 3Q.5-2, Change in V/C for Future Conditions, the Traffic Study identifies significant impacts, in relation to the thresholds of significance established by the LADOT, to V/C ratio in the peak traffic conditions at eight intersections in the study area. Additionally, the two intersections within Los Angeles County would experience significant impacts in future baseline conditions related to change in V/C during peak traffic hours, based on County significant impact guidelines. Significant impacts are anticipated at ten of the intersections:
Walgrove Avenue/Rose Avenue – During the a.m. and p.m. peak hours.
Centinela Avenue/Palms Boulevard – During the a.m. peak hour.
Lincoln Boulevard/Venice Boulevard – During the a.m. and p.m. peak hours.
Walgrove Avenue/Venice Boulevard – During the a.m. and p.m. peak hours.
Beethoven Street/Venice Boulevard – During the a.m. and p.m. peak hours.
Centinela Avenue/Venice Boulevard – During the a.m. and p.m. peak hours.
Walgrove Avenue/Washington Boulevard – During the a.m. and p.m. peak hours.
Beethoven Street/Washington Boulevard – During the p.m. peak hour.
Lincoln Boulevard/Mindanao Way – During the a.m. and p.m. peak hours.
Lincoln Boulevard/Fiji Way – During the a.m. and p.m. peak hours.
Therefore, the proposed project would be expected to result in significant cumulative impacts to transportation and traffic, requiring the consideration of mitigation measures.
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Table 3Q.5-1: Projected Impact Summary for Future Baseline Conditions Future without Project Future with Project A.M. Peak Hour P.M. Peak Hour A.M. Peak Hour P.M. Peak Hour Study Intersections Jurisdiction V/C or Delay LOS V/C or Delay LOS V/C or Delay LOS V/C or Delay LOS 1 Lincoln Boulevard & Marine Avenue Santa Monica 8.4 A 16.9 B 8.5 A 16.9 B 2 23rd Street & Ocean Park Boulevard Santa Monica 24.2 C 20.1 C 25.3 C 20.6 C Santa Monica 6.1 A 15.5 B 6.1 A 15.5 B 3 Bundy Drive & Airport Avenue Los Angeles 0.691 B 0.814 D 0.697 B 0.818 D 4 Walgrove Avenue & Rose Avenue Los Angeles 1.115 F 0.928 E 1.149 F 0.969 E 5 Walgrove Avenue & Morningside Way Los Angeles 0.564 A 0.588 A 0.567 A 0.612 B 6 Walgrove Avenue & Palms Boulevard Los Angeles 0.645 B 0.613 B 0.674 B 0.655 B 7 Beethoven Street & Palms Boulevard Los Angeles 0.573 A 0.759 C 0.610 B 0.765 C 8 Centinela Avenue & Palms Boulevard Los Angeles 0.937 E 0.990 E 0.954 E 0.999 E 9 Walgrove Avenue & Victoria Avenue, West-Leg Los Angeles 0.555 A 0.497 A 0.677 B 0.502 A 10 Beethoven Avenue & Victoria Avenue, East-Leg Los Angeles 0.403 A 0.391 A 0.406 A 0.469 A 11 Centinela Avenue & Charnock Avenue Los Angeles 0.697 B 0.600 A 0.702 C 0.603 B 12 Lincoln Boulevard & Venice Boulevard Los Angeles 0.990 E 1.110 F 1.005 F 1.122 F 13 Walgrove Avenue & Venice Boulevard Los Angeles 0.834 D 0.869 D 0.909 E 0.890 D 14 Beethoven Street & Venice Boulevard Los Angeles 0.828 D 0.835 D 0.899 D 0.917 E 15 Centinela Avenue & Venice Boulevard Los Angeles 0.991 E 1.096 F 1.005 F 1.113 F 16 Beethoven Street & Zanja Street * Los Angeles 16.5 C 25.5 D 19.0 C 33.0 D 17 Lincoln Boulevard & Washington Boulevard Los Angeles 0.902 E 0.888 D 0.910 E 0.893 D 18 Glencoe Avenue & Washington Boulevard Culver City 0.800 C 0.913 E 0.808 D 0.918 E 19 Walgrove Avenue & Washington Boulevard * Culver City >100 sec F >100 sec F >100 sec F >100 sec F 20 Beethoven Street & Washington Boulevard Culver City 0.716 C 0.820 D 0.741 C 0.841 D Culver City 0.931 E 0.986 E 0.938 E 0.990 E 21 Centinela Avenue & Washington Place Los Angeles 0.833 D 0.896 D 0.841 D 0.901 E Culver City 0.896 D 0.994 E 0.904 E 1.004 F 22 Centinela Avenue & Washington Boulevard Los Angeles 0.749 C 0.854 D 0.758 C 0.865 D L.A. County 0.466 A 0.596 A 23 Lincoln Boulevard & Bali Way Los Angeles 0.463 A 0.594 A 0.466 A 0.596 A L.A. County 0.691 B 0.912 E 24 Lincoln Boulevard & Mindanao Way Los Angeles 0.687 B 0.910 E 0.691 B 0.912 E L.A. County 0.600 A 0.808 D 25 Lincoln Boulevard & Fiji Way Los Angeles 0.597 A 0.806 D 0.600 A 0.808 D NOTE: *Un-signalized intersection. SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
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Table 3Q.5-2: Change in V/C for Future Conditions Change in V/C Significant Study Intersections A.M. Peak Hour P.M. Peak Hour Impact? 1 Lincoln Boulevard & Marine Avenue 0.1 0.0 No 2 23rd Street & Ocean Park Boulevard 1.1 0.5 No 0.0 0.0 No 3 Bundy Drive & Airport Avenue 0.006 0.004 No 4 Walgrove Avenue & Rose Avenue 0.034 0.041 Yes 5 Walgrove Avenue & Morningside Way 0.003 0.024 No 6 Walgrove Avenue & Palms Boulevard 0.029 0.042 No 7 Beethoven Street & Palms Boulevard 0.037 0.006 No 8 Centinela Avenue & Palms Boulevard 0.017 0.009 Yes 9 Walgrove Avenue & Victoria Avenue, West-Leg 0.122 0.005 No 10 Beethoven Avenue & Victoria Avenue, East-Leg 0.003 0.078 No 11 Centinela Avenue & Charnock Avenue 0.005 0.003 No 12 Lincoln Boulevard & Venice Boulevard 0.015 0.012 Yes 13 Walgrove Avenue & Venice Boulevard 0.075 0.021 Yes 14 Beethoven Street & Venice Boulevard 0.071 0.082 Yes 15 Centinela Avenue & Venice Boulevard 0.014 0.017 Yes 16 Beethoven Street & Zanja Street * 2.5 7.5 No 17 Lincoln Boulevard & Washington Boulevard 0.008 0.005 No 18 Glencoe Avenue & Washington Boulevard 0.008 0.005 No 19 Walgrove Avenue & Washington Boulevard * - - Yes 20 Beethoven Street & Washington Boulevard 0.025 0.021 Yes 0.007 0.004 No 21 Centinela Avenue & Washington Place 0.008 0.005 No 0.008 0.010 No 22 Centinela Avenue & Washington Boulevard 0.009 0.011 No 23 Lincoln Boulevard & Bali Way 0.003 0.002 No 24 Lincoln Boulevard & Mindanao Way 0.004 0.002 No 25 Lincoln Boulevard & Fiji Way 0.003 0.002 No NOTE: *Un-signalized intersection. SOURCE: KOA Corporation. 17 March 2015. Traffic Study for LAUSD Mandarin Immersion Elementary School. Prepared for: LAUSD, OEHS. Prepared by: KOA Corporation, Monterey, CA. (Appendix H).
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As described in Impacts 3Q-c through 3Q-f, above, the proposed project would not result in significant impacts related to a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks; substantially increase hazards due to a design feature or incompatible uses; result in inadequate emergency access; or conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities. Therefore, the proposed project would not result in significant cumulative impacts to these issue areas, and the consideration of mitigation measures is not warranted.
3Q.6 MITIGATION MEASURES
The Traffic Study identified four feasible mitigation measures to reduce the transportation and traffic impacts associated with the proposed project.
MM Trans/Traffic 1: Restriping of the westbound approach at the intersection of Walgrove Avenue and Rose Avenue to provide a left/through lane and right-turn lane, including prohibition of on-street parking within vicinity of approach.
MM Trans/Traffic 2: Restriping of the northbound and southbound approach at the intersection of Beethoven Street and Venice Boulevard to provide a left-turn lane and shared-through/right lane, including prohibition of on-street parking within vicinity of approach.
MM Trans/Traffic 3: Install a new traffic signal at the intersection of Walgrove Avenue and Washington Boulevard with protected permissive. or a left turn signal with five lights (red, yellow, green, yellow arrow, green arrow) that allows left turns to be made as protected movements (opposite movement receives a red indication) with the green arrow indication and through gaps in traffic as permitted movements during the “green ball” indication portion of the cycle, at the eastbound approach.
MM Trans/Traffic 4: Restriping of the northbound approach at the intersection of Beethoven Street and Washington Boulevard to provide a left-turn lane and right/through lane, including prohibition of on-street parking within vicinity of approach.
In addition to the four feasible mitigation measures that have been identified, other measures were evaluated that required additional rights-of-way such as road widening, but it was determined that there was insufficient public right-of-way to accomplish such measures. Therefore, such solutions were determined to be infeasible.
3Q.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impact 3Q-a and 3Q-b: Significant and unavoidable. Implementation of Mitigation Measures Trans/Traffic 1–4 would reduce the impacts at four of the studied intersections to below the level of significance. However, the impacts would remain significant and unavoidable at six intersections. Because the impacts of the proposed project on transportation and traffic would remain significant
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3Q-19 Draft EIR Subchapter 3Q. Transportation/Traffic and unavoidable after the application of feasible mitigation measures, a Statement of Overriding Considerations would be required.
Impacts 3Q-c and 3Q-d: No impact.
Impacts 3Q-e and 3Q-f: Less than significant impact.
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This analysis is undertaken to determine if the proposed project may have a significant impact to utilities and service systems, which would require consideration of mitigation measures or alternatives in accordance with Section 15063 of the State CEQA Guidelines.1 The potential for impacts to utilities and service systems was evaluated with regard to the Federal CWA,2 the Los Angeles RWQCB Basin Plan, California Integrated Waste Management Plan, and the LAUSD SWMP. Definitions
Acre-Foot: An acre-foot represents the amount of water it would take to cover an acre of land 12 inches deep. The term is commonly used in irrigation and water resource management to allocate water resources and to calculate the volume of water in reservoirs and other bodies of water.
General Construction Activity Storm Water Permit: Where the U.S. EPA is the permitting authority, or in California acting through the SWRCB and RWQCBs, construction stormwater discharges are almost all regulated under the General Construction Activity Storm Water Permit, which requires compliance with effluent limits and other permit requirements, such as the development of an SWPPP. Construction operators intending to seek coverage under General Construction Activity Storm Water Permit must submit a Notice of Intent (NOI) certifying that they have met the permit’s eligibility conditions and that they will comply with the permit’s effluent limits and other requirements.
Los Angeles Regional Water Quality Control Board: The Los Angeles RWQCB is one of nine statewide regional boards. The Los Angeles RWQCB protects ground and surface water quality in the Los Angeles Region, including the coastal watersheds of Los Angeles and Ventura Counties, along with very small portions of Kern and Santa Barbara Counties. In order to carry out its mission “to preserve and enhance water quality in the Los Angeles Region for the benefit of present and future generations,” the Los Angeles RWQCB conducts a broad range of activities to protect ground and surface waters under its jurisdiction.
State Water Resources Control Board: The federal CWA is administered and enforced by the SWRCB, which develops regulations to implement water-quality control programs mandated at the federal and state levels. To implement these programs, California has nine RWQCBs.
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000–15387, Appendix G. 2 U.S. Environmental Protection Agency. 16 March 2014. Laws and Regulations: Summary of the Clean Water Act. Available at http://www2.epa.gov/laws-regulations/summary-clean-water-act Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-1 Draft EIR Subchapter 3R. Utilities and Service Systems
Storm Water and Stormwater: In layman’s terms, stormwater is defined as an abnormal amount of surface water due to a heavy rain or snowstorm. The term storm water is used when employed by the cited source of information. In all other instances, stormwater is used, consistent with the provision of Appendix G of the State CEQA Guidelines and as defined by the U.S. EPA. Stormwater runoff is generated when precipitation from rain and snowmelt events flows over land or impervious surfaces and does not percolate into the ground. As the runoff flows over the land or impervious surfaces (e.g., paved streets, parking lots, and building rooftops), it accumulates debris, chemicals, sediment, or other pollutants that could adversely affect water quality if the runoff is discharged untreated.
Stormwater Best Management Practices: As defined by CASQA, Stormwater BMPs include schedules of activities, prohibitions of practices; maintenance procedures, and other management practices to prevent, eliminate, or reduce the pollution of the receiving waters. BMPs also include treatment requirements, operating procedures, and practices to control plant site runoff spillage or leaks, sludge or waste disposal, or drainage from raw material storage.
Stormwater Pollution Prevention Plan: A plan created by developers to show their plans for sediment and erosion control. Typically these plans are part of an overall design that details procedures to be followed during various phases of construction. This is required by a federal regulation governing stormwater runoff from active construction sites that are more than one acre in area.
Urban Water Management Plan: As defined by the SWRCB, UWMPs are prepared by California’s urban water suppliers to support their long-term resource planning and ensure adequate water supplies are available to meet existing and future water demands. Every urban water supplier that either provides over 3,000 acre-feet of water annually or serves more than 3,000 or more connections is required to assess the reliability of its water sources over a 38-year planning horizon considering normal, dry, and multiple dry years. This assessment is to be included in its UWMP, which is to be prepared every 5 years and submitted to the DWR. DWR then reviews the submitted plans to make sure they have completed the requirements identified in the Urban Water Management Planning Act (Division 6 Part 2.6 of the Water Code §10610–10656).
Wastewater:3 The spent or used water of a community or industry that contains dissolved and suspended matter.
Waters of the United States: Surface waters such as navigable waters and their tributaries, all interstate waters and their tributaries, natural lakes, all wetlands adjacent to other waters, and all impoundments of these waters.
Water Resources Plans: A WRP provides a comprehensive overview of water resources and demands in the region; an overview of the water resources portfolio, or available resources; the approach used for forecasting water demand; and recommendations for demand management and strategy for meeting long-term resources needs, including a plan of action for times of declared shortages. A WRP will normally include a discussion of the environmental issues that will influence future supply and demand.
3 California Association of Sanitation Agencies. n.d. Definition of Terms – S. Available at: http://www.casaweb.org/definition-of-terms/s Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-2 Draft EIR Subchapter 3R. Utilities and Service Systems
3R.1 REGULATORY FRAMEWORK Federal
Clean Water Act, Section 401
The CWA established the basic structure for regulating discharges of pollutants into the waters of the U.S. and regulating quality standards for surface waters.4 Under the CWA, the U.S. EPA has implemented pollution control programs such as setting wastewater standards for industries and surface waters. Section 401 of the CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained. The U.S. EPA’s NPDES permit program controls discharges. Point sources are discrete conveyances, such as pipes or manmade ditches. Individual homes that are connected to a municipal system, use a septic system, or do not have a surface discharge do not need an NPDES permit; however, industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters. State
California Integrated Waste Management Act of 1989
The California Integrated Waste Management Act of 1989 (Assembly Bill [AB] 939) was enacted to reduce, recycle, and reuse solid waste generated in the State to the maximum extent feasible. Specifically, the Act requires city and county jurisdictions to identify an implementation schedule to divert 50 percent of the total waste stream from landfill disposal by the year 2000. The Act also requires each city and county to promote source reduction, recycling, and safe disposal or transformation. Cities and counties are required to maintain the 50 percent diversion specified by AB 939 by the year 2000.
For Los Angeles County, the County’s Department of Public Works (Public Works) is responsible for preparing and administering the Summary Plan and the Countywide Siting Element (CSE). These documents were approved by the County, a majority of the cities within the County containing a majority of the cities’ population, the County Board of Supervisors, and the California Department of Resources Recycling and Recovery (CalRecycle). The Summary Plan, approved by CalRecycle on June 23, 1999, describes the steps to be taken by local agencies, acting independently and in concert, to achieve the mandated State diversion rate by integrating strategies aimed toward reducing, reusing, recycling, diverting, and marketing solid waste generated within the County. The CSE, approved by CalRecycle on June 24, 1998, identifies how, for a 15-year planning period, the County and the cities within it would meet their long-term disposal capacity needs to safely handle solid waste generated in the County that cannot be reduced, recycled, or composted.
4 California Water Boards Fact Sheet. n.d. Water Quality Control Policy for Siting, Design, Operation and Maintenance of Onsite Wastewater Treatment Systems (OWTS Policy). Available at: http://www.waterboards.ca.gov/water_issues/programs/owts/index.shtml Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-3 Draft EIR Subchapter 3R. Utilities and Service Systems
California Solid Waste Reuse and Recycling Act
The California Solid Waste Reuse and Recycling Act of 1991 (AB 2176) was enacted to assist local jurisdictions with accomplishing the goals of AB 939.5 In accordance with AB 2176, any development project that has submitted an application for a building permit must include adequate, accessible areas for the collection and loading of recyclable materials. Furthermore, the areas to be utilized must be adequate in capacity, number, and distribution to serve the proposed project. Moreover, the collection areas are to be located as close to existing exterior refuse collection areas as possible. Regional
Water Quality Control Plan for the Los Angeles Region
The CWA is administered and enforced by the SWRCB, which develops regulations to implement water-quality control programs mandated at the federal and state levels. To implement these programs, California has nine RWQCBs.
The RWQCB has prepared a Water Quality Control Plan for the Los Angeles Region (Basin Plan), which includes the Coastal Watersheds of Los Angeles and Ventura Counties. The first essentially complete Basin Plan, which was established under the requirements of California’s 1969 Porter- Cologne Water Quality Control Act (Section 13000 [Water Quality] et seq. of the California Water Code), was adopted in 1975 and revised in 1984. The latest version was adopted in 1994.
The Basin Plan assigned beneficial uses to surface and groundwater such as municipal water supply and water-contact recreation to all waters in the basin. It also set water quality objectives, subject to approval by the EPA, intended to protect designated beneficial uses. These objectives apply to specific parameters (numeric objectives) and general characteristics of the water body (narrative objectives). An example of a narrative objective is the requirement that all waters must remain free of toxic substances in concentrations producing detrimental effects upon aquatic organisms. Numeric objectives specify concentrations of pollutants that are not to be exceeded in ambient waters of the basin.
The Los Angeles RWQCB is one of nine statewide regional boards. The Los Angeles RWQCB protects ground and surface water quality in the Los Angeles region, including the coastal watersheds of Los Angeles and Ventura Counties, along with very small portions of Kern and Santa Barbara Counties. In order to carry out its mission “to preserve and enhance water quality in the Los Angeles Region for the benefit of present and future generations,” the Los Angeles RWQCB conducts the following broad range of activities to protect ground and surface waters under its jurisdictions:
Addresses region-wide and specific water quality concerns through updates of the Water Quality Control Plan for the Los Angeles Region
Prepares, monitors compliance with, and enforces Waste Discharge Requirements, including NPDES Permits
5 CalRecycle Model Ordinance on Recycling Space Allocation - AB 1327. 11 October 1991. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-4 Draft EIR Subchapter 3R. Utilities and Service Systems
Implements and enforces local stormwater control efforts
Regulates the cleanup of contaminated sites, which have already polluted or have the potential to pollute ground or surface water
Enforces water quality laws, regulations, and waste discharge requirements
Coordinates with other public agencies and groups that are concerned with water quality
Informs and involves the public on water quality issues
General Construction Activity Stormwater Discharges
Stormwater discharges that are composed entirely of runoff from qualifying construction activities may require regulation under the General Construction Activity Storm Water Permit issued by the SWRCB. Construction activities that qualify include clearing, grading, excavation, reconstruction, and dredge-and-fill activities that result in the disturbance of at least 1 acre and less than 5 acres of total land area. The proposed project would be required to conform to the Standard Urban Stormwater Management Plan (SUSMP) as part of compliance with the NPDES General Construction Activity Storm Water Permit to reduce water quality impacts to the maximum extent practicable. A SUSMP is a report that includes one or more site maps, an identification of construction activities that could cause pollutants to enter the stormwater, and a description of measures or BMPs to control these pollutants to the maximum extent practicable. A BMP is defined by the Stormwater Quality Task Force as any program, technology, process, siting criteria, operating method, measure, or device that controls, prevents, removes, or reduces stormwater pollution. Local
Los Angeles Bureau of Sanitation
The Bureau of Sanitation carries out its responsibility by the management of these primary programs related to water quality:
Wastewater Program: Safely and efficiently convey and treat 550 million gallons of wastewater per day and beneficially reuse 700 wet tons per day of biosolids.
Watershed protection program: protect the beneficial uses of receiving waters, while complying with all stormwater pollution abatement regulations.
Los Angeles Department of Water and Power
The proposed project site is served by the LADWP for water and power. LADWP, a municipal water and power provider, prepares a UWMP to forecast the future water demands and water supplies under average and dry year conditions, identify future water supply projects such as recycled water, provide a summary of water conservation BMPs, and provide a single- and multi- dry-year management strategy. The most recent UWMP was adopted in 2010 and serves two purposes: (1) to achieve full compliance with requirements of the California Urban Water Management Planning Act and (2) to serve as a master plan for water supply and resources management consistent with the City’s goals and policy objectives. Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-5 Draft EIR Subchapter 3R. Utilities and Service Systems
3R.2 EXISTING CONDITIONS Wastewater
The Hyperion Treatment Plant serves the project area.6 The plant has a capacity to handle a daily flow of 362 million gal/day (mgd), and 450 mgd capacity Treatment - Full secondary, solids handling. Stormwater Drainage
There are existing stormwater drainage facilities in the proposed project area. Stormwater drainage facilities and surface runoff from the campus is conveyed by a non-erosive storm drain system consisting of area drains, catch basins, gutters, roof drains, and storm drain piping. From the proposed project site, runoff would flow west-southwest along the surface topography to storm drains maintained by the LACFCD through catch basins at the intersection of Victoria Avenue and Walgrove Avenue (Figure 3I.2-1, Storm Drains in the Vicinity of the Proposed Project). These systems convey runoff from the campus to the Santa Monica Bay. Water Supply
The LADWP has plans for increasing water supply for the increasing demand of its service area in its 2010 UWMP. LADWP obtains its current water supply from the Los Angeles Aqueduct, the Metropolitan Water District of Southern California (MWD) (California State Water Project and Colorado River), local groundwater, and recycled water. By 2035, LADWP estimates that it will receive additional water supply from water transfers, stormwater capture, and conservation. LADWP’s supply projections are expected to exactly meet the increased demands of its service area, which includes the project area, between 2010 and 2035. LADWP accounted for an annual population growth rate of 0.4 percent within its service area over the next 25 years. Solid Waste
The proposed project site is served by the City of Los Angeles Bureau of Sanitation for solid waste collection. As the five landfills maintained by the City of Los Angeles Bureau of Sanitation have been closed, the City uses Sunshine Canyon Landfill, which is located at 14747 San Fernando Rd, Sylmar, California 91342 and operated by the Los Angeles County Sanitation District, to dispose of approximately 3,691 tons of refuse per day in fiscal year 2004–2005,7 or approximately 527 tons per day within the Western Wasteshed (the City of Los Angeles disposes of approximately 860,000 tons of refuse per year at Sunshine Canyon Landfill).8 In 2011, the maximum daily capacity of the landfill was 12,100 tons per day, and a total of approximately 7,801 tons of refuse was disposed per day (36 percent less than daily permitted capacity), or approximately 2,434,000 tons per
6 City of Los Angeles Department of Public Works. Accessed 11 December 2014. Treatment Plants: About the Treatment Plants. Available at: http://www.lasewers.org/treatment_plants/about/index.htm 7 City of Los Angeles Bureau of Sanitation. Accessed 11 December 2014. About Solid Resources: Facts and Figures. Available at: http://www.lacitysan.org/solid_resources/factsfigures.htm 8 City of Los Angeles Bureau of Sanitation. 14 November 2005. City of Los Angeles Wasteshed. Available at: http://www.lacitysan.org/solid_resources/pop_wasteshed.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-6 Draft EIR Subchapter 3R. Utilities and Service Systems year.9,10 As of December 31, 2011, the estimated remaining permitted capacity of Sunshine Landfill was approximately 82,390,000 tons, and the remaining life of the landfill was estimated to be approximately 25 years from 2012 (anticipated closure in 2037).11,12
The City of Los Angeles is one of the 18 member cities of the Los Angeles Regional Agency (LARA), a joint powers authority promoting solid waste diversion.13 The Bureau of Sanitation has established a goal of 70 percent diversion of refuse from landfills by 2020.14
3R.3 THRESHOLDS OF SIGNIFICANCE
The potential for the proposed project to result in impacts related to utilities and service systems was analyzed in relation to the seven questions contained in Appendix G of the State CEQA Guidelines. Would the proposed project: a. Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b. Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c. Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d. Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? f. Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs? g. Comply with federal, state, and local statutes and regulations related to solid waste?
9 Los Angeles Department of Public Works. 2001. Los Angeles County Integrated Waste Management Plan, 2000 Annual Report on the Countywide Summary Plan and Countywide Siting Element. Alhambra, CA 10 Disposal quantities are based on actual tonnages reported by owners/operators of permitted solid waste disposal facilities to the Los Angeles County Department of Public Works' Solid Waste Information Management System (www.LACountySWIMS.org.) 11 Remaining Life is based on either the 2011 average daily disposal tonnage or the facility's permit expiration date, whichever is later. 12 County of Los Angeles Department of Public Works. August 2012. County of Los Angeles Countywide Integrated Waste Management Plan: 2011 Annual Report. 13 Los Angeles Regional Agency (LARA). Accessed 11 December 2014.Members Directory. Available at: http://www.laregionalagency.us/?page_id=73 14 City of Los Angeles Bureau of Sanitation. Accessed 11 December 2014. Solid Resources: Strategic Programs. Available at: http://www.lacitysan.org/solid_resources/strategic_programs/index.htm Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-7 Draft EIR Subchapter 3R. Utilities and Service Systems
3R.4 IMPACT ANALYSIS
Impact 3R-a: Would the proposed project exceed wastewater treatment requirements of the applicable regional water quality control board?
No Impact
The proposed project is not expected to result in significant impacts associated with utilities and service systems in relation to exceeding wastewater treatment requirements pursuant to the Los Angeles Basin Plan (Los Angeles RWQCB). As discussed above, the wastewater from the proposed project would be serviced by the Hyperion Treatment Plant, which is located approximately 5 miles south of the proposed project site at 12000 Vista Del Mar, Los Angeles, California 90293. The Hyperion Plant has a design capacity of 450 mgd and currently treats an average of 362 mgd to primary and secondary treatment standards, using three levels of filtration treatment before discharging the treated wastewater 5 miles offshore. The remaining capacity of the Hyperion Treatment Plant is, therefore, approximately 88 mgd or 19.5 percent of its total capacity. Most of the effluent from the Hyperion Treatment Plant is discharged into the Santa Monica Bay through a 5-mile ocean outfall, while approximately 50 mgd of secondary effluent is recycled on-site or transported to the West Basin Municipal Water District Water Recycling Plant for use by local industries. The proposed project would relocate up to 336 students to the existing Mark Twain Middle School campus and would not result in a significant net increase in LAUSD enrollment. Thus, the proposed project would not generate sewer flows that would contain constituents that would jeopardize the ability of the Hyperion Treatment Plant to operate within its established wastewater requirements. As with all wastewater treated by the Hyperion Treatment Plant, wastewater from the proposed project would be treated according to the treatment requirements enforced by the NPDES permit authorized by the Los Angeles RWQCB. The proposed project would adhere to the California Building Standards Code (the 2010 Plumbing Code, California Code of Regulations, Title 24, Part 5).15 Therefore, there is no potential for the proposed project activities to be inconsistent with the established wastewater treatment requirements and permits regulated by the Los Angeles RWQCBs, and no further evaluation is warranted.
Impact 3R-b: Would the proposed project require or result in the construction of new water or wastewater treatment facilities, the construction of which could cause significant environmental effects?
No Impact
The proposed project would not result in significant impact in relation to the construction of new water or wastewater treatment facilities or expansion of facilities. The project is serviced by the Hyperion Treatment plant, which has a remaining capacity of approximately 88 mgd or 19.5 percent of its total capacity beyond current operation levels, and will be able to handle any additional wastewater activities produced by the proposed project. The proposed project would not result in a significant net increase in LAUSD enrollment. Implementation of the proposed project, which would accommodate up to 336 students, would include students relocated from the
15 California Building Standards Commission. Effective 1 January 2011. 2010 California Plumbing Code. “California Code of Regulations, Title 24, Part 5.” Available at: https://law.resource.org/pub/us/code/bsc.ca.gov/gov.ca.bsc.2010.05.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-8 Draft EIR Subchapter 3R. Utilities and Service Systems existing Mandarin Immersion program at Broadway Elementary School, as well as new students who would enroll in the program. Students who participate in the Mandarin Immersion program are considered to be traveling or “non-resident,” meaning that they can participate in the program even if it is not their LAUSD-designated resident school, which is based on the student’s home address. As the proposed project would not be limited to a student pool from the immediate neighborhood, it would not be growth-inducing and would not create the need for additional housing. The proposed project site would continue to be served by existing City water and wastewater utility lines, and the proposed project would not exceed the capacity of Hyperion Treatment Plant. Therefore, there is no potential to overload the current capacity levels of the wastewater treatment facilities, and the construction of new water or wastewater treatment facilities would not be required. Therefore, the proposed project would not result in a significant impact to utilities and service systems in regard to requiring or resulting in the construction of new water or wastewater treatment facilities, the construction of which could cause significant environmental effects, and no further evaluation is warranted.
Impact 3R-c: Would the proposed project require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental impacts?
Less than Significant Impact
The proposed project would result in less than significant impacts in relation to the construction of new stormwater drainage facilities or expansion of existing facilities. The proposed construction would add additional stormwater drainage facilities; however, the construction is not anticipated to cause significant environmental impacts. From the proposed project site, runoff would flow west- southwest along the surface topography to storm drains maintained by the Los Angeles County Flood Control District (LACFCD) through catch basins at the intersection of Victoria Avenue and Walgrove Avenue (see Figure 3I.2-1, Storm Drains in the Vicinity of the Proposed Project). Site drainage is directed to adjacent streets following the natural topography of the existing land, and sheet flow is directed to existing storm drains. The proposed project would be designed to maintain a similar pattern of drainage, thereby providing a less than significant change in the existing storm runoff. As currently conceived, site improvements from implementation of the proposed project may potentially change the amount of pervious area. During construction and normal operation, the proposed project, as currently conceived, would be required to incorporate BMPs consistent with the guidelines provided in the California Storm Water Best Management Practices Handbook for Construction Activities and in the LAUSD SWMP for substantiated erosion or siltation. These BMPs shall be designed in coordination with the existing project area in order to prevent any substantial alteration of the existing drainage pattern of the proposed project area.
Therefore, the proposed project would result in less than significant impacts to utilities and service systems in regard to requiring or resulting in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental impacts, and no further evaluation is warranted.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-9 Draft EIR Subchapter 3R. Utilities and Service Systems
Impact 3R-d: Would the proposed project have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed?
No Impact
The proposed project would not result in significant impacts to utilities and service systems in relation to having sufficient water supplies available to serve the project from existing entitlements and resources. The LADWP has plans for increasing water supply for the increasing demand of its service area in its 2010 UWMP. According to the LADWP’s 2010 UWMP, LADWP obtains its current water supply from the Los Angeles Aqueduct, MWD (California State Water Project and Colorado River), local groundwater, and recycled water. By 2035, LADWP estimates that it will receive additional water supply from water transfers, stormwater capture, and conservation. LADWP’s supply projections are expected to exactly meet the increased demands of its service area, which includes the proposed project area, between 2010 and 2035. LADWP accounted for an annual population growth rate of 0.4 percent within its service area over the next 25 years. Therefore, the proposed project would not result in significant impacts to utilities and service systems in regard to having sufficient water supplies available to serve the project from existing entitlements and resources, or new or expanded entitlements needed, and no further evaluation is warranted.
Impact 3R-e: Would the proposed project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
No Impact
The proposed project would not result in significant impacts to the capacity of the Hyperion Treatment Plant to serve existing commitments. The proposed project site will be served by the Hyperion wastewater treatment facility which has a capacity to handle a daily flow of 362 million gal/day (mgd), and 450 mgd capacity Treatment - Full secondary, solids handling. The proposed project does not facilitate a significant net increase in LAUSD enrollment. The proposed project would relocate up to 336 students from Broadway Elementary School, and allow for additional program enrollment, to a total capacity of 567 students in a newly constructed building and modifications to eight existing portable classroom buildings on the existing Mark Twain Middle School Campus, which is served by the Hyperion Treatment Plant. As discussed above in Impact 3R-b, the proposed project site would continue to be served by existing City water and wastewater utility lines and the proposed project would not exceed the capacity of Hyperion Treatment Plant. In addition, in order to comply with the City’s water conservation ordinances, the proposed project would be equipped with water conservation devices (i.e., toilets, faucets, etc.) that would reduce the on-site wastewater generation. The Hyperion Treatment Plant is currently serving this program at its existing location at Broadway Elementary School and has sufficient capacity to serve the new location. Therefore, there is no significant potential to overload the current capacity levels of the Hyperion Treatment Plant’s wastewater treatment facilities that would result in the requirement to the construct new water or wastewater treatment facilities. No further evaluation is warranted.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-10 Draft EIR Subchapter 3R. Utilities and Service Systems
Impact 3R-f: Would the proposed project be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?
No Impact
The proposed project would not result in significant impacts in relation to being served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs. Solid waste from the existing Mandarin Immersion program at Broadway Elementary School is disposed of at Sunshine Canyon Landfill. The proposed project would relocate students from one campus to a new campus from which solid waste is also disposed at Sunshine Canyon Landfill. As Sunshine Canyon Landfill accepted approximately 36 percent less refuse than its permitted daily capacity in 2011 and the City and County are implementing waste diversion policies and programs to reduce refuse disposal further, it is expected that Sunshine Canyon Landfill has sufficient capacity to accept the additional solid waste produced by the expansion of the program. Therefore, there is no potential to overload the current permitted capacity levels of the landfill facilities. No further evaluation is warranted.
Impact 3R-g: Would the proposed project comply with Federal, State, and Local statutes and regulations related to solid waste?
No Impact
The proposed project would not result in significant impacts in relation to complying with federal, state, and local statutes and regulation related to solid waste. Solid waste management in the state is primarily guided by the California Integrated Waste Management Act of 1989 (AB 939), which emphasizes resource conservation through reduction, recycling, and reuse of solid waste. AB 939 establishes an integrated waste management hierarchy consisting of (in order of priority): (1) source reduction, (2) recycling and composting, and (3) environmentally safe transformation and land disposal. Additionally, in March 2006, the City Council adopted RENEW LA, a 20-year plan with the primary goal of shifting from waste disposal to resource recovery within the City, resulting in “zero waste” and an overall diversion level of 90 percent. The “blueprint” of the plan builds on the key elements of existing reduction and recycling programs and infrastructure, and combines them with new systems and conversion technologies to achieve resource recovery (without combustion) in the form of traditional recyclables, soil amendments, renewable fuels, chemicals, and energy. The plan also calls for reductions in the quantity and environmental impacts of residue material disposed in landfills. The proposed project would be consistent with the applicable regulations associated with solid waste. LAUSD has solid waste diversion at the existing home of the Mandarin Immersion program that will continue to the new site. Specifically, the proposed project would promote compliance with AB 939 and City waste diversion goals by providing clearly marked, source-sorted receptacles to facilitate recycling. Additionally, as there would be no building demolition associated with the proposed project, the proposed project would not generate demolition solid waste during construction. Pursuant to the construction and demolition waste recycling/reuse requirement in the California Green Building Standards Code Section 5.408, construction contractors are required to divert 75 percent of solid waste during construction. The proposed project would also comply with LAUSD School Design Guide & Specification 01340, Construction & Demolition Waste Management, which requires the collection and separation of all construction and demolition waste materials generated on-site, reuse or recycling on-site,
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-11 Draft EIR Subchapter 3R. Utilities and Service Systems transportation to approved recyclers or reuse organizations, or transportation to legally designated landfills, for the purpose of recycling, salvaging, and/or reusing a minimum of 75 percent of the construction and demolition waste generated.16,17 Since the proposed project would comply with federal, state, and local statutes and regulations related to solid waste, the proposed project would not result in significant impacts to utilities and service systems, and no further analysis is warranted.
3R.5 CUMULATIVE IMPACTS
The proposed project would not result in significant impacts to utilities and public services. Therefore, there would be no cumulative impacts.
3R.6 MITIGATION MEASURES
The proposed project would not result in significant impacts related to utilities and public services. Therefore, the consideration of mitigation measures is not required.
3R.7 LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts 3R-a, 3R-b, 3R-d, 3R-e, 3R-f, and 3R-g: No impact.
Impact 3R-c: Less than significant impact.
16 Los Angeles Unified School District, Design Standards Department. January 2014. “School Design Guide: Los Angeles Unified School District.” Available at: http://www.laschools.org/documents/download/asset_management/school_design_guide/School_Design_Guide _Jan_2014.pdf?version_id=310708755. Book Two, Section 2.4.f, Construction Waste Management. Page 103- 104. 17 LAUSD. 7 July 2003. Specifications – Division 01.“Section 01340: Construction & Demolition Waste Management.” Available at: http://www.laschools.org/fcs/cc/lausd- bidding/file?file_id=2228510&show_all_versions_p=t Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 3R-12 Draft EIR CHAPTER 4.0 ALTERNATIVES ANALYSIS
4.1 INTRODUCTION AND OVERVIEW
This section of the EIR describes alternatives to the proposed project. Alternatives have been analyzed consistent with the recommendations of Section 15126.6 of the State CEQA Guidelines, which requires the evaluation of a range of reasonable alternatives to the proposed project, or to the location of the project, which would feasibly attain most of the basic objectives of the proposed project but would avoid or substantially lessen any of the significant effects of the proposed project, and an evaluation of the comparative merits of the alternatives. The discussion of alternatives focused on four criteria:
Alternatives to the project or its location that may be capable of avoiding or substantially reducing any significant effects that a project may have on the environment
Alternatives capable of accomplishing most of the basic objectives of the project and potentially avoid or substantially lessen one or more of the significant effects
The provision of sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with the proposed project
The no project analysis of what would be reasonably expected to occur in the foreseeable future if the project were not approved
Pursuant to Section 15126.6(e)(2) of the State CEQA Guidelines, if the environmentally superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative among the feasible action alternatives. The analysis of alternatives should be limited to those that LAUSD determines could feasibly attain most of the basic objectives of the project. Section of 15364 of the State CEQA Guidelines defines feasibility as capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.1
Alternatives addressed in this EIR reflect comments received during scoping, and opportunities to avoid or reduce significant impacts on volume to capacity ratios and level of service for traffic. One alternative that was identified during public outreach undertaken by LAUSD, an expanded program at Broadway Elementary School, was determined to be infeasible because it would require the relocation of the resident student population for the traditional school program and the Spanish Immersion program to other schools, such as the nearby Westminster Avenue Elementary School. The forced relocation of resident neighborhood students off of Broadway Elementary School is not
1 California Code of Regulations, 2006. Title 14, Division 6, Chapter 3, Section 15064.
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-1 Draft EIR Chapter 4. Alternatives Analysis feasible because it does not meet the objective to comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school. The use of existing facilities was determined to be infeasible because the Program needs to be located within the Venice High School Complex to achieve the objective of providing a continuous educational program from kindergarten to Grade 12. There is insufficient capacity within the existing facilities to support a consolidated K–5 Program on a single campus within the Venice High School complex.
As a result of the public outreach process, LAUSD was asked to consider an alternative whereby funds allocated for the facilities for the immersion program would be used to improve facilities at other neighborhood schools. The proposed project, as defined in this EIR, is funded by bond funds, which were approved by the Board of Education. The LAUSD budget has provisions for ongoing operations and maintenance of all active school campus, improvements to neighborhood schools are considered as part of the annual budgeting process. Operation and maintenance of existing campuses is funded through general funds, and would not be an authorized use for the bond funds that have been allocated to this project. The No Project Scenario reflects the consequences of not using the bond funds for the proposed project.
The use of existing facilities was determined to be infeasible because the Program does not currently have adequate facilities at Broadway Elementary School to provide enough classroom space for all students of the Program. A full list of alternatives that were considered, but determined to be infeasible, can be found in Section 4.3 below.
There are five types of information considered in the evaluation of each alternative:
Description of the alternative
Analysis of the comparative level of impact of the alternative versus the proposed project
Identification of the impacts of the project that would be avoided or lessened by the alternatives
Assessment of whether the alternative would meet most of the basic project objectives
Evaluation of the comparative merits of the alternative and the project.
Per the CEQA Guidelines Section 15126.6(d), additional significant effects of the alternatives are discussed in less detail than the significant effects of the proposed project. 4.2 ALTERNATIVES TO THE PROPOSED PROJECT
The alternatives identified below, with the exception of the mandatory No Project Alternative, were selected due to their potential to attain most of the basic project objectives, and to lessen or avoid significant environmental effects resulting from implementation of the proposed project. Alternatives considered in this EIR include:
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-2 Draft EIR Chapter 4. Alternatives Analysis
No Project Alternative
Alternative Location at Marina Del Rey Middle School
Reduced Project Alternative
Redistricting Alternative
As discussed in Section 2.1.2, Project Objectives, LAUSD has identified eight project objectives to support achievement of the overarching goal of serving students in the Program through the provision of up to 336 new two-semester seats in 15 new classrooms, dedicated to Mandarin and English dual-language instruction. This section of the EIR provides a comparative analysis of the ability of the proposed project and project alternatives to attain most of the basic objectives of the project (Table 4.2-1, Summary of Ability of Proposed Project and Alternatives to Attain Project Objectives). The proposed project would meet all the basic objectives of LAUSD (Table 4.2-1). Although the No Project Alternative is not capable of meeting most of the basic objectives of the proposed project, it has been analyzed, as required by CEQA.
Table 4.2-1: Summary of Ability of Proposed Project and Alternatives to Attain Project Objectives Alternative Location at Reduced Proposed No Marina Del Rey Project Redistricting Objective Project Project Middle School Alternatives Alternative
1. Provide educational facilities dedicated to the Program Yes No Yes Yes Yes for kindergarten through fifth grade.
2. Consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective Yes No Yes No Yes use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program. 3. Build and maintain a school that reflects the wise and efficient use of limited District Bond Funds and General Yes No No Yes No Funds. 4. Build and maintain a school that reflects the wise and Yes No No Yes Yes efficient use of limited land and public resources. 5. Maintain the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since Yes Yes Yes Yes Yes 2010, thus minimizing the disruption for families, students, and educators engaged in the Program. 6. Enable the alignment of the Program with the world language instructional pathways initiative that includes Yes No No No Yes matriculation to Mark Twain Middle School and Venice High School.
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-3 Draft EIR Chapter 4. Alternatives Analysis
Table 4.2-1: Summary of Ability of Proposed Project and Alternatives to Attain Project Objectives Alternative Location at Reduced Proposed No Marina Del Rey Project Redistricting Objective Project Project Middle School Alternatives Alternative 7. Comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood Yes Yes Yes Yes No school. 8. Provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting Yes Yes Yes No Yes up to four classes of kindergarten students every year.
4.2.1 NO PROJECT ALTERNATIVE Alternative Components
There are no components to the No Project Alternative. Under the No Project Alternative, the proposed project would not be constructed. The Program would remain on a split campus between Broadway Elementary School and Mark Twain Middle School and/or the District would have to restrict the Program’s enrollment. The existing capacity and facilities at both campuses would remain the same. The project site would remain as athletic facilities parking, and portable classrooms, as described in Section 2.2.1, Project Components. Objectives and Feasibility
Under the No Project Alternative, five of the eight objectives of the project would not be met:
This alternative would not provide educational facilities dedicated to the Program for kindergarten through fifth grade;
It would not consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program;
It would not result in the building and maintaining of a school that reflects the wise and efficient use of limited District Bond Funds and General Funds;
It would not result in the building of a school that reflects the wise and efficient use of limited land and public resources; and
It would not enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School.
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-4 Draft EIR Chapter 4. Alternatives Analysis
Under the No Project Alternative, the existing Program would not be allowed to grow on a single consolidated campus. The Program would remain split between two campuses and thus not meet the project objectives. One of the primary objectives of the Program is to provide an intellectually challenging and standards-based curriculum in both English and Mandarin Chinese for Grades K–5 on a single campus, with the eventual goal of spanning through Grade 8. A consolidated campus for the Program would more readily support collaboration between teachers in designing curriculum and assessments; facilitate teacher collaboration in instructional planning within and across grade levels to ensure that instruction is coherent within the program; create an immersive language community that allows students to use the language outside the classroom and practice their language skills by teaching younger students on the playground and at lunch; and provide for shared resources for K–8, such as Mandarin books and multimedia for the students and a collection of resources for teachers. This is also true for tutoring and afterschool programs in Mandarin; the paucity of such programs for Mandarin means that organizing them is a challenge and it is far easier to manage in a single location. By keeping the Program split across two campuses, the No Project Alternative would not meet this key objective.
This alternative would meet three of the eight objectives of the project: maintaining the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators, engaged in the Program; complying with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school; and providing sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year. Construction Scenario
Under the No Project Alternative, no construction would occur. Therefore, no environmental impacts would occur. Comparative Impacts
Unlike the proposed project (which would result in no impacts to 5 environmental issue areas, less than significant impacts to 9 issue areas, and potentially significant impacts to 4 issue areas), this alternative would result in no significant impacts for 17 environmental issue areas, less than significant impacts for 1 issue area (public services – schools), and potentially significant impacts for 0 issue areas. The comparative level of impacts from this alternative in regard to the 4 environmental issue areas for which potentially significant impacts have been identified for the proposed project is evaluated below.
Cultural Resources
The No Project Alternative avoids potential impacts associated with the unanticipated discovery of archeological resources, paleontological resources, or human remains during grading and earth- moving during the construction phase of the proposed project. The No Project Alternative would not entail any grading (excavation and fill), modification of existing structures, or construction of new structures and therefore would not impact historic, archaeological, or paleontological resources. As a result, the No Project Alternative would not require implementation of Mitigation Measure Cultural-1 and Mitigation Measure Cultural-2 described in Section 3E, Cultural Resources.
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The No Project Alternative avoids the potential for impacts to cultural resources that may occur during the construction phase of the proposed project.
Noise
The No Project Alternative would avoid the significant impact on ambient noise levels generated by construction of the proposed project. The No Project Alternative would avoid noise impacts, because there would be no construction on the Mark Twain Middle School campus. Therefore, Mitigation Measures Noise-1 through -5 described in Section 3L, Noise, to reduce noise impact to below the level of significance, and Noise-6 and -7, required for the proposed project, would not be required for the No Project Alternative. As with the proposed project, continued operation of the Program at Broadway Elementary School would generate comparable levels to that anticipated for the proposed project site during the operational phase of the project. The No Project scenario would be expected to have the same ambient noise levels at Broadway Elementary, as that at the proposed project for the operational phase of the project during the 2015 to 2035 planning horizon.
Pedestrian Safety
There would be no significant impacts related to pedestrian safety with the No Project Alternative. Therefore, the No Project Alternative would not require implementation of Mitigation Measures Trans/Traffic 1-4, as described in Section 3Q, Transportation and Traffic. As with the proposed project, continued operation of the Program at Broadway Elementary School would require compliance with the same LAUSD safety standards that apply to the proposed project. Impacts associated with the No Project Alternative would be similar to those of the proposed project, except for Vehicle Access, which would have a lesser impact.
Transportation and Traffic
The No Project Alternative avoids significant impacts to transportation and traffic that would be expected to result from the implementation of the proposed project. Therefore, the No Project Alternative would not require implementation of Mitigation Measures Trans/Traffic-1 through MM Trans/Traffic-4 described in Section 3Q, Transportation and Traffic. Section 3Q proposes mitigation for short- and long-term construction and operation impacts that would occur as a result of the proposed project. Unlike the proposed project, the No Project Alternative would create no additional transportation or traffic components and implementation of the mitigation measures would not be required. In addition, there would be no significant or unavoidable impacts. Conclusion and Relationship to Project Objectives
The No Project Alternative fails to meet most of the basic objectives of the project and fails to support the goals set by LAUSD for making the opportunity for Program and the corresponding dual language competency and preparedness for college entrance exams (Table 4.2-1). The No- Project alternative would fail to resolve the existing space constraints and inability of Broadway Elementary to adequately house the traditional educational instructional program and the two dual- language immersion programs for Mandarin and Spanish. The No Project Alternative would result in the continuation of existing conditions at the proposed project site. The proposed project site would remain as athletic facilities, parking, and portable classrooms, as described in Chapter 2.0,
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-6 Draft EIR Chapter 4. Alternatives Analysis
Project Description and Environmental Setting, and the Mandarin Immersion Program would remain as a split campus. The No Project Alternative avoids the significant and unavoidable impacts to traffic associated with the proposed project. As with the proposed project, which reduces impacts to cultural resources, noise and pedestrian safety through the application measures; the No Project Alternative avoids these impacts by foregoing construction or operation of new classroom facilities. Compared to the proposed project, the No Project Alternative is preferable and environmentally superior in relation to traffic.
4.2.2 ALTERNATIVE LOCATION AT MARINA DEL REY MIDDLE SCHOOL Alternative Components
Unlike the displacement of the Charter School at Marina Del Rey Middle School that was determined to be infeasible for legal reasons, construction of new classrooms at Marina Del Rey Middle School was carried forward for detailed evaluation to assess it potential to avoid significant impacts to cultural resources, noise, pedestrian safety and traffic. Marina Del Rey Middle School is located within the Venice High School complex of schools and has space available for construction of new classroomst Under this alternative (Marina Del Rey Alternative), the Program would move to the Marina Del Rey Middle School campus and utilize 23 new classrooms that would need to be constructed on land currently occupied by outdoor recreation facilities. Marina Del Rey Middle School campus does not have any available classrooms that could be modified to support the Program; therefore this alternative would require constructing 23 new classrooms instead, 8 more than the 15 classrooms under consideration for the proposed project. This alternative requires constructing the same support and core facilities as proposed project. No existing buildings would be demolished as a result of this alternative. Unlike the alternative at Marina Del Rey Middle School described in Section 4.3, Alternatives Eliminated from Further Consideration, this alternative retains the Goethe International Charter School that is co-located on the Marina Del Rey Middle School campus. Objectives and Feasibility
The Marina Del Rey Alternative would not meet three of the proposed project’s eight objectives of building and maintaining a school that reflects the wise and efficient use of limited District Bond Funds and General Funds, building and maintaining a school that reflects the wise and efficient use of limited land and public resources; or enabling the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School. This alternative would not connect to an existing language program, which exists at Mark Twain Middle School. The World Languages Magnet program at Mark Twain Middle School readily feeds into the World Languages and Global Studies Magnet program at Venice High School. Marina Del Rey Middle School has a Performing Arts Magnet program and a Marine Science Academy but no existing world languages program. Additionally, while Mark Twain Middle School has 8 existing classrooms which the Program can utilize, Marina Del Rey Middle School does not have available classrooms because the Goethe International Charter School occupies all spaces not utilized by Marina Del Rey Middle School. Therefore, this alternative would require the construction of a total of 23 classrooms, which is 8 more new classrooms than the proposed project, in order to consolidate the Program on a single contiguous campus. The net effect of the requirement to build more classrooms is that there would be a
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-7 Draft EIR Chapter 4. Alternatives Analysis conversion of approximately 30 percent more open space than that required at Mark Twain Middle School, and increased cost and duration of construction.
This alternative would meet five of the eight objectives of the project: providing educational facilities dedicated to the Program for kindergarten through fifth grade; consolidating the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program; maintaining the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program; complying with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school, and providing sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year. Construction Scenario
Under the Marina Del Rey Alternative, an approximately 25 percent increase in the footprint of new buildings would require a larger area of construction-related activities that would occur as those activities required for the proposed project, as more buildings would be required for operation of the Program than required for the proposed project. As with the proposed project, this alternative would require the displacement of existing turf and asphalt athletic facilities on the existing Marina Del Rey Middle School campus. Comparative Impacts
Compare to the proposed project, this alternative would result in no significant impacts for 7 environmental issue areas, less than significant impacts for 7 issue areas, and potentially significant impacts for 4 issue areas. The baseline conditions for this alternative location in relation to 18 environmental issue areas have been characterized to facilitate a comparative impact analysis (Appendix I, Impact Analysis for Marina Del Rey Project Alternative at Marina Del Rey Middle School).
As with the proposed project the Marina Del Rey Middle School Alternative Location would be expected to result in potentially significant impacts to cultural resources, noise, pedestrian safety and transportation and traffic.
Cultural Resources
As with the proposed project, the Marina Del Rey Alternative would potentially entail the unanticipated encounter of archaeological resources or human remains during construction that would be mitigated to below the level of significance with the implementation of Mitigation Measures Cultural-1 and Cultural-2 described in Section 3E, Cultural Resources. According to the SCCIC, there are no known prehistoric resources within the Marina Del Rey Alternative area.2 An individual listed by the NAHC as someone who may have knowledge of cultural resources in the
2 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 9 March 2015. Email: “RE: Records Search for the LAUSD Mandarin and English Dual-Language Immersion Elementary School Project.”
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Marina Del Rey Alternative area identified the general area (Marina Del Rey Middle School is less than 2 miles away from Mark Twain Middle School) as an area of high sensitivity to Native American resources. A request has been sent to the NAHC regarding this alternative and inquiring about knowledge of Native American sacred lands and traditional places. The Marina Del Rey Alternative site would be located less than 200 feet from Ballona Creek, a well-documented area of Native American use and sensitivity.3 However, due to the level of disturbance that has occurred within the Marina Del Rey Alternative area with historical development and construction, it is unlikely that such resources are present.
As with the proposed project, although the likelihood of encountering human remains is low, the Marina Del Rey Alternative has the potential to directly or indirectly disturb human remains, including those interred outside of formal cemeteries. The results of the archaeological record search indicate that no historic period or Native American burial grounds are located within or in proximity to the Marina Del Rey Alternative area.4 An individual listed by the NAHC as someone who may have knowledge of cultural resources in the Marina Del Rey Alternative area identified the area as an area of high sensitive to Native American resources. Sensitive Native American resources may contain human remains. However, due to the level of disturbance that has occurred within the Marina Del Rey Alternative area with historical development and construction, it is unlikely that such resources are present. It is the recommendation of Sapphos Environmental, Inc. that Native American consultation continues; however, any additional action, such as Native American monitoring, shall be done under the discretion of LAUSD. The potential disruption associated with an unanticipated discovery of human remains constitutes a significant impact requiring the consideration of mitigation measures. Therefore, although the likelihood of encountering human remains is low, as with the proposed project, the Marina Del Rey Alternative has the potential to disturb human remains, including those interred outside of formal cemeteries.
The construction-related activities of the Marina Del Rey Alternative, including the construction of a new building, would encompass a larger footprint for excavation and construction, which may have the potential to increase the chance of discovery of paleontological resources or human remains.
Noise
The Marina Del Rey Alternative would result in the same impacts as the proposed project related to ambient noise levels resulting from construction-related activities. The construction duration is anticipated to be the same for the Marina Del Rey Alternative as the proposed project. However, the construction of this alternative would require approximately 30 percent more ground disturbance due to an increase in the construction required for the school facilities. Therefore, the Marina Del Rey Alternative would result in greater impacts regarding a substantial temporary increase in ambient noise levels in the Marina Del Rey Alternative site vicinity when compared to the proposed project. As with the proposed project, implementation of Mitigation Measures Noise- 1 through Noise-5 described in Section 3L, Noise, would reduce construction impacts on ambient
3 Altschul, Jeffrey H., et. al., Statistical Research, Inc., Tucson, AZ, Redlands, CA "Playa Vista Archaeological and Historical Project, At the Base of the Bluff, Archaeological Inventory and Evaluation along Lower Centinela Creek, Marina Del Rey, California", April 2003 4 Galaz, Michelle, South Central Coastal Information Center, California State University, Fullerton. 16 March 2015. Email: “RE: Records Search for the Marina Del Rey Alternative.”
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-9 Draft EIR Chapter 4. Alternatives Analysis noise levels to below the level of significance. As with the proposed project, implementation of Mitigation Measures Noise-6 and -7 would reduce construction impacts related to ground-borne vibration to below the level of significance. Operational impacts would also be comparable to the proposed project. The Marina Del Rey Alternative would have no difference in the proposed project when considering the potential impacts of these activities to ambient noise and vibration levels.
Pedestrian Safety
Under the Marina Del Rey Alternative, an equivalent number of pedestrians would travel to and from the proposed alternative location school site during peak-hour traffic conditions. Consequently, the potential pedestrian safety impact or concerns resulting from the number of students would be the same as the proposed project. However, there would still be short-term construction impacts. As with the proposed project, the Marina Del Rey Alternative would require implementation of Mitigation Measures Trans/Traffic-1 through Trans/Traffic-4 described in Section 3Q, Transportation and Traffic. The Marina Del Rey Alternative would result in comparable impacts related to pedestrian safety as the proposed project that would be reduced to below the level of significance with the implementation of Mitigation Measures Trans/Traffic-1 through Trans/Traffic-4.
Transportation and Traffic
Under the Marina Del Rey Alternative, potential impacts related to transportation and traffic at the six intersections identified in Section 3Q, Transportation and Traffic would be redistributed to intersections in the vicinity of the Marina Del Rey Alternative site. The Marina Del Rey Alternative site does not require traffic to traverse neighborhood intersections to reach regional arterial routes. There is sufficient width in the neighboring roadway segments that collector designations for roadway classifications apply, rather than local designations. Although some of the surrounding roadways are wider, the trip generation associated with adding 23 new classrooms at Marina Del Rey would be expected to generate sufficient new trips to result in significant impacts to a comparable number of intersections. As with the proposed project, the application of mitigation measures, such as those specified in Mitigation Measures Tran/Traffic-1 through -4 would be required. The streets in the vicinity of Marina Del Rey Middle School also lack sufficient rights-of- way to accommodate road widening. As with the proposed project, it is anticipated that there would be significant and unavoidable impacts to a comparable number of intersections. However, after implementation of mitigation measures, impacts to transportation and traffic would still be significant. Conclusion and Relationship to Project Objectives
The Marina Del Rey Alternative meets most of the basic objectives of the project (Table 4.2-1). However, this alternative would not achieve the following LAUSD project objectives:
Build and maintain a school that reflects the wise and efficient use of limited District General Funds. In this alternative, 50 percent, eight, more classrooms would need to be constructed with corresponding increases in the cost and duration of construction.
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Build and maintain a school that reflects the wise and efficient use of limited land and public resources. In this alternative, 50 percent, eight, more classrooms would need to be constructed with corresponding increases in the loss of open space on the campus which is more severely constrained than the recreation facilities and open space at the Mark Twain Middle School campus.
Enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School. In this alternative, the K–5 Program would be relocated to Marina Del Rey Middle School, a middle school that does not currently have a world languages program, which would require students who continue the Program after fifth grade to relocate to Mark Twain Middle School or another world language instructional pathway in the area.
This alternative would result in no significant impacts for 6 environmental issue areas (agriculture and forestry resources, biological resources, hazards and hazardous materials, land use and planning, mineral resources, population and housing), less than significant impacts for 8 issue areas (aesthetics, air quality, geology and soils, greenhouse gas emissions, hydrology and water quality, public services, recreation, and utilities and service systems), and potentially significant impacts for 4 issue areas (cultural resources, noise, pedestrian safety, and transportation and traffic) that would be reduced to below the level of significance with mitigation measures. Compared to the proposed project, the Marina Del Rey Middle School Alternative would be expected to have lesser impacts on traffic, in that it would not result in a significant impact, related to reduction in LOS and substantial reduction in V/C ratio during the AM or PM peak hour. The Marina Del Rey Middle School Alternative would be expected to result in similar impact levels for aesthetics, agriculture and forestry resources, air quality, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, pedestrian safety, population and housing, public services, and utilities and service systems to the impact levels of the proposed project. The Marina Del Rey Alternative would be expected to result in lesser impacts to biological resources and transportation and traffic than the proposed project because there are no trees that would have the potential to support nesting of migratory birds that would be removed and the Marina Del Rey Alternative site is located in a less congested area. The Marina Del Rey Alternative would be expected to result in greater impact levels for cultural resources, noise, and recreation because the new buildings would occupy a 25 percent larger building footprint, requiring more excavation than the proposed project with a greater potential for discovery of paleontological resources or human remains, require more ground disturbance that would increase ambient noise levels during construction, and, as the existing recreational facilities at Marina Del Rey Middle School occupy approximately 0.8 acre less than the Mark Twain Middle School campus, result in a greater impact to school recreation facilities than the proposed project due to its smaller existing recreational facilities.
As with the proposed project, impacts related to reduced level of service would remain significant and unavoidable.
Implementation of this alternative would not create new impacts that are not associated with the proposed project. However, this alternative would not reduce impacts to transportation and traffic to below the level of significance.
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4.2.3 REDUCED PROJECT ALTERNATIVE Alternative Components
This alternative would involve providing less classroom space at Mark Twain Middle School for the Program by reducing the enrollment of the Program to accept only two classes in kindergarten every school year. This alternative would require constructing five new classrooms, modernizing eight existing classrooms in portables, and constructing all of the same support and core facilities as proposed in the Project. The total projected enrollment for the Program would be reduced by approximately 50 percent from 567 to 283. Objectives and Feasibility
Reducing the capacity of the program would reduce traffic impacts from additional students commuting to the campus during peak school traffic hours. However, this alternative would not meet three of the project’s eight objectives: to consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program; enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School; and provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year. The Reduced Project Alternative would not provide a critical mass for a 50/50 Model of Mandarin dual-language instruction that requires collaboration among instructors within and across grade levels; where older students and younger students benefit from mentoring; resources are shared for K–5 and 6–8 programs, such as books, recorded material, tutoring, and after school programs; and the world language instructional pathways initiative is aligned in the Venice High School Complex. The proposed project accommodates a four-class unit model, with 4 classes per grade for grades K–3 (total 16 classes) and 3 classes per grade for grades 4 and 5 (total 6 classes), to create the critical mass needed to make the Program work, as the Program thins out in the fourth and fifth grades. An additional set aside classroom for alternative use is customary to an elementary school, such as for a parent center or break out instruction, for a total of 23 classrooms needed to support the Program.
This alternative would meet five of the eight objectives of the project: providing educational facilities dedicated to the Program for kindergarten through fifth grade, building and maintaining a school that reflects the wise and efficient use of limited District Bond Funds and General Funds, building and maintaining a school that reflects the wise and efficient use of limited land and public resources, maintaining the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program, and complying with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school. However, the Reduced Project Alternative would not meet the first objective, providing educational facilities dedicated to the Program for kindergarten through fifth grade, as fully as the proposed project.
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Construction Scenario
Under the Reduced Project Alternative, the same amount of construction-related activities would occur as those activities required for the proposed project, for an approximately 33 percent reduction in the footprint of new buildings. Comparative Impacts
As with the proposed project, this alternative would result in no significant impacts for 5 environmental issue areas, less than significant impacts for 9 issue areas, and potentially significant impacts for 4 issue areas. The comparative level of impacts from this alternative in regard to the four environmental issue areas for which significant impacts have been identified for the proposed project is evaluated below.
Cultural Resources
As with the proposed project, the Reduced Project Alternative would potentially entail the unanticipated encounter of archaeological resources or human remains during construction that would be mitigated to below the level of significance with the implementation of Mitigation Measures Cultural-1 and Cultural-2 described in Section 3E, Cultural Resources. The construction- related activities of the proposed project, including the construction of a new building, are the same construction-related activities for this alternative. The Reduced Project would require less construction and excavation; therefore, it would reduce the area subject to significant impacts of the proposed project to cultural resources.
Noise
The Reduced Project Alternative would result in lesser impacts as the proposed project related to ambient noise levels and ground-borne vibration resulting from construction-related activities. As with the proposed project, implementation of Mitigation Measures Noise-1 through Noise-5 described in Section 3L, Noise, would reduce construction impacts on ambient noise levels to below the level of significance. As with the proposed project, implementation of Mitigation Measures Noise-6 and -7 would reduce construction impacts related to ground-borne vibration to below the level of significance. Operational impacts would also be comparable to the proposed project. The Reduced Project Alternative would have no difference in the proposed project when considering the potential impacts of these activities to ambient noise and vibration levels.
Pedestrian Safety
Under the Reduced Project Alternative, fewer student pedestrians would travel to and from the proposed school site. Consequently, the potential pedestrian safety impact or concerns resulting from the number of students would be reduced. However, there would still be short-term construction impacts. As with the proposed project, the Reduced Project Alternative would require implementation of Mitigation Measures Trans/Traffic-1 through Trans/Traffic-4, as described in Section 3Q, Transportation and Traffic. The Reduced Project Alternative would result in comparable impacts related to pedestrian safety as the proposed project, but they would be reduced to below the level of significance with the implementation of Mitigation Measures Trans/Traffic-1 through Trans/Traffic-4.
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Transportation and Traffic
Under the Reduced Project Alternative, potential impacts related to transportation and traffic would be less than those of the proposed project. The number of vehicles and amount of congestion would be reduced below that of the proposed project, resulting in a less than significant impact regarding decrease in LOS and V/C for the six intersections identified in Section 3Q, Transportation and Traffic. This alternative would reduce the number of trips to the school site and would help reduce the significant impacts associated with traffic congestion below the level of significance. As with the proposed project, the Reduced Project Alternative would require implementation of Mitigation Measures Trans/Traffic-1 through Trans/Traffic-4, as described in Section 3Q, Transportation and Traffic. The Reduced Project Alternative would result in lesser impacts compared to the proposed project, but it would still result in significant and unavoidable impacts related to traffic congestion after implementation of these Mitigation Measures. Conclusion and Relationship to Project Objectives
This alternative would not provide sufficient capacity for the Program to be successful. Furthermore, this alternative would not achieve the following three LAUSD project objectives:
Enable the alignment of the Program with the world language instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School. The Reduced Project Alternative would not have enough students to fully support the Program as designed to enable the K–5 Program to align with the middle school and high school level language instructional pathways initiative.
Consolidate the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program. This alternative would not provide a critical mass for a 50/50 Model of Mandarin dual-language instruction that requires collaboration among instructors within and across grade levels.
Provide sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year. This program would create the critical mass of students needed to make the Mandarin Immersion Program work.
As with the proposed project, this alternative would result in no significant impacts for 5 environmental issue areas (agriculture and forestry resources, hazards and hazardous materials, land use and planning, mineral resources, population and housing), less than significant impacts for 9 issue areas (aesthetics, air quality, biological resources, geology and soils, greenhouse gas emissions, hydrology and water quality, public services, recreation, and utilities and service systems), and potentially significant impacts for 4 issue areas (cultural resources, noise, pedestrian safety, and transportation and traffic), 3 of which would be reduced to below the level of significance with the incorporation of mitigation measures. Impacts to transportation and traffic would remain significant after mitigation. The Reduced Project Alternative would be expected to result in similar impact levels for aesthetics, agriculture and forestry resources, biological resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-14 Draft EIR Chapter 4. Alternatives Analysis planning, mineral resources, noise, pedestrian safety, population and housing, public services, and recreation to the impact levels of the proposed project. The Reduced Project Alternative would be expected to result in lesser impacts to air quality, cultural resources, greenhouse gas emissions, transportation and traffic, and utilities and service systems than the proposed project because this alternative would involve a 33 percent reduction in the building footprint at the same location as the proposed project and reduce traffic congestion during school operations in comparison to the proposed project. The Reduced Project Alternative would not be expected to result in greater impact levels for any of the environmental issue areas because this alternative would reduce the construction impacts of the proposed project at the same site and reduce traffic congestion during operations.
Implementation of this alternative would not create new impacts that are not associated with the proposed project. This alternative would not reduce impacts to transportation and traffic to below the level of significance.
4.2.4 REDISTRICTING ALTERNATIVE Alternative Components
The Redistricting Alternative would involve redrawing the LAUSD boundaries so that resident students in traditional instructional programs at LAUSD elementary schools would be relocated from their neighborhood school and redistricted to other campuses. Currently, there is intermittent classroom capacity sprinkled in various campuses in the general area where the Program operates. This alternative proposes that by redistricting students to fill capacity across various campuses, the Program can be consolidated and allowed to operate on a single site. The eight portables at Mark Twain Middle School would be vacated and the proposed project site would remain as athletic facilities, parking, and portable classrooms, as described in Chapter 2.2.1, Project Components. Objectives and Feasibility
This alternative would make space for the Program at Broadway Elementary School, but it would require resident students to move to other schools. This alternative would only meet seven of the eight objectives for the project. This alternative would be inconsistent with LAUSD’s commitment to provide every student with the opportunity to attend their neighborhood school. It would also be inconsistent with the primary goal of LAUSD’s bond program to provide students with the opportunity to attend a neighborhood school operating on a traditional, two-semester calendar.
This alternative would meet seven of the eight objectives of the project: providing educational facilities dedicated to the Program for kindergarten through fifth grade; consolidating the Program on a single contiguous campus with the necessary facilities to support the Program that allows educators, students, and families to collaborate and that enables the efficient and effective use of educational and operational resources that facilitates a learning environment that is conducive to an immersion program; building and maintaining a school that reflects the wise and efficient use of limited District Bond Funds and General Funds; building and maintaining a school that reflects the wise and efficient use of limited land and public resources; maintaining the Program within close proximity to Broadway Elementary School where the Program has been housed and has served the surrounding area, since 2010, thus minimizing the disruption for families, students, and educators engaged in the Program; enabling the alignment of the Program with the world language
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-15 Draft EIR Chapter 4. Alternatives Analysis instructional pathways initiative that includes matriculation to Mark Twain Middle School and Venice High School; and providing sufficient classroom and appurtenant facilities to maintain a critical mass for the Program by accepting up to four classes of kindergarten students every year. Construction Scenario
Under the Redistricting Alternative, no construction-related activities would occur. Comparative Impacts
Unlike the proposed project, this alternative would result in no significant impacts for 12 environmental issue areas, less than significant impacts for 4 issue areas, and potentially significant impacts for 2 issue areas. The comparative level of impacts from this alternative in regard to the four environmental issue areas for which significant impacts have been identified for the proposed project is evaluated below.
Cultural Resources
The Redistricting Alternative would not require any construction, excavation, or grading, therefore resulting in no impacts to cultural resources.
Noise
The Redistricting Alternative would result in lower impacts compared to the proposed project related to ambient noise levels and ground-borne vibration resulting from construction-related activities. The Redistricting Alternative would not require construction, meaning that the associated construction noise and vibration impacts would not exist. Operational impacts would be comparable to the proposed project.
Pedestrian Safety
Under the Redistricting Alternative, longer pedestrian trips would be generated in the LAUSD area. Consequently, the potential pedestrian safety impact or concerns resulting from the number of students would be increased. This alternative would result in a comparatively lower impact to pedestrian safety than the proposed project because students would be displaced from their nearest geographic school, and might instead be driven to school outside their neighborhood.
Transportation and Traffic
Under the Redistricting Alternative, potential impacts related to transportation and traffic would be reduced in the vicinity of the proposed project site, but increased over the area serviced by LAUSD. Under the Redistricting Alternative, up to 567 students who currently live within walking distance of their school may instead be driven to school outside their neighborhood, if they are no longer assigned to the most proximal school. The LOS at the six identified intersections that are subject to significant and unavoidable impacts from the proposed project would be reduced as the students would not be concentrated at the Mark Twain Middle School campus. However, students would be displaced from their nearest geographic school, resulting in a potential increase in the number of trips to sites in the area that ultimately accommodates the immersion program, and adversely affecting congestion in the vicinity of the schools where students are reassigned. There
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-16 Draft EIR Chapter 4. Alternatives Analysis may be sufficient width in the neighboring roadway segments that collector designations for roadway classifications apply, rather than local designations. Although some of the surrounding roadways for the redistricted students may be wider, the trip generation associated with displacement of up to 567 students would be expected to generate sufficient new trips to result in significant impacts to a comparable number of intersections. As with the proposed project, the incorporation of mitigation measures, such as those specified in Tran/Traffic 1 through 4, would be required. The streets in the vicinity of the redistricted schools may also lack sufficient rights-of-way to accommodate road widening. As with the proposed project, it is anticipated that there would be significant and unavoidable impacts to a comparable number of intersections. Conclusion and Relationship to Project Objectives
Unlike the proposed project, this alternative would result in no significant impacts for 12 environmental issue areas (aesthetics, agriculture and forestry resources, biological resources cultural resources, geology and soils, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, recreation, and utilities and service systems), less than significant impacts for 4 issue areas (air quality, greenhouse gas emissions, noise, and public services), and potentially significant impacts for 2 issue areas, pedestrian safety and transportation/traffic, neither of which would be reduced to below the level of significance with the incorporation of mitigation measures. The Redistricting Alternative would be expected to result in similar impact levels for agriculture and forestry resources, greenhouse gas emissions, hazards and hazardous materials, land use and planning, mineral resources, population and housing, and public services to the impact levels of the proposed project. The Redistricting Alternative would be expected to result in lesser impacts to aesthetics, air quality, biological resources, cultural resources, geology and soils, hydrology and water quality, noise, recreation, and utilities and service systems than the proposed project because this alternative would not require the construction of any new facilities to support the Program. The Redistricting Alternative would be expected to result in greater impact levels for pedestrian safety and transportation and traffic because implementation of this alternative would create new regional impacts to transportation and traffic and pedestrian safety as a result of increased commute distance from current resident students that are not associated with the proposed project.
Furthermore, this alternative would not achieve the following LAUSD project objective:
Comply with LAUSD’s commitment to providing every student with the opportunity to attend their neighborhood school. Redistricting would require resident students to move to other schools instead of attending the nearest school to their residences, which would also require students to have farther commutes to school.
This alternative would not reduce impacts to transportation and traffic to below the level of significance. 4.3 ALTERNATIVES ELIMINATED FROM FURTHER CONSIDERATION
This section describes the rationale for selection and rejection of alternatives. The State CEQA Guidelines allow the lead agency to make an initial determination as to which alternatives are feasible and which are infeasible, therefore providing merit to in-depth consideration for those
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-17 Draft EIR Chapter 4. Alternatives Analysis selected for additional analysis. Alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered. As the lead agency, LAUSD evaluated initial alternatives that were identified as infeasible. This section presents the alternatives considered by the LAUSD that were identified as infeasible and provides a brief explanation of the reasons for their exclusion. Fund Other Neighborhood School Improvements Instead of Project
Another alternative to the proposed project, which was identified during public outreach undertaken by LAUSD, would be to dismiss the proposed project and use the funding for other neighborhood school improvements. This alternative would not allow the Mandarin and English Dual-Language Immersion Program to grow on the Broadway Elementary School campus. This alternative would reduce potential traffic impacts at Mark Twain Middle School because no change would be made to the Mark Twain Middle School campus, and no additional students would be commuting to the campus during peak school traffic hours. However, this alternative has been determined by LAUSD to be infeasible because it would not attain most of the basic objectives of the project. As a result, this alternative was not evaluated in the EIR. Alternative Site Exploration
Throughout 2012 and 2013, LAUSD conducted a comprehensive planning process to identify opportunities and options to support the growth of the Mandarin Immersion Program. During this time, District staff focused on analyzing existing school sites and their potential to accommodate the Program by maximizing underutilized space. It was found that no existing school sites had enough available capacity to support the Program’s entire projected enrollment. Therefore, staff explored adding capacity to various school sites in the general geographic area of Broadway Elementary School where the Program was initiated Table 4.3-1, Alternative Sites Considered but Determined to Be Infeasible).
Table 4.3-1: Alternative Sites Considered but Determined to Be Infeasible Grandview ES / McBride Grandview ES / McBride Special Ed center is an existing school site in the Venice HS Complex. The campus has an elementary school and adjacent facility built for special education. This alternative would require the construction of approximately 19 new classrooms and major modernizations to existing buildings in order to provide enough capacity to support the Program on top of the existing occupants of the site. The food services, multi-purpose, play space, parking, library and administrative facilities would all be inadequately sized to support the population if the Program was added to the site. There is limited contiguous land area available to provide larger and more costly core facilities. Westminster ES Westminster ES is an existing elementary school in the Venice HS Complex. This alternative considered the relocation or removal of the EEC program and up to 8 set aside classrooms utilized by Westminster ES for special programs. In addition to these displacements, providing enough space for the Program would require the construction of approximately 11 classrooms. The food services, multi-purpose, play space, parking, library and administrative facilities would all be inadequately sized to support the population if the Program was added to the site. There is limited contiguous land area available to provide larger and more costly core facilities.
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Table 4.3-1: Alternative Sites Considered but Determined to Be Infeasible Broadway ES Broadway ES is an existing elementary school in the Venice HS Complex and is where the Program was initiated. It is also home to a Spanish Immersion program. Broadway ES has 20 permanent classrooms and 5 portable classrooms that were added to temporarily accommodate enrollment growth until a permanent solution to meet this need is available. The Broadway campus does not have sufficient land to add permanent classroom space and maintain minimum play and parking area standards required by CDE. Additionally, the food services, multi-purpose, play space, parking library and administrative facilities would all be inadequately sized to support additional capacity beyond the existing permanent classrooms. There is limited contiguous land area available to provide larger and more costly core facilities. Oso ES Oso ES is a former elementary school in the West San Fernando Valley, outside of the Venice HS Complex. It has been closed and vacant for many years. The site would require extensive modernization work, including new buildings, to serve the Program. The site was not considered feasible due to its location, which is over 13 miles “as the crow flies” from the Program’s current home. Stoner ES Stoner ES is an existing school in the Venice HS Complex. This alternative would require the construction of approximately 23 new classrooms and major modernizations to existing buildings in order to provide enough capacity to support the Program in addition to existing site uses. The food services, multi-purpose, play space, parking, library and administrative facilities would all be inadequately sized to support the population if the Program was added to the site. There is limited contiguous land area available to provide larger and more costly core facilities.
Marina Del Rey MS Marina Del Rey MS is an existing school in the Venice HS Complex. Under this alternative, the Program would move to the Marina Del Rey MS campus. Marina Del Rey MS has approximately 17 classrooms currently utilized by a Charter School. Under this alternative, the Charter School would need to be relocated to another site (site not identified) and the Program would move to the Marina Del Rey MS campus and utilize the classrooms currently housing the Charter School. This alternative would require relocating the Charter School, constructing six new classrooms, modernizing seventeen existing classrooms and constructing all of the same support and core facilities as proposed in the Project.
Under Section 47614(b) of the California Education Code, the District is prohibited from either terminating or otherwise relocating a charter school unnecessarily. The District’s desire to move the Program into Marina Del Rey Middle School would be interpreted as being “unnecessary” under Section 47614(b) and would thereby make this alternative infeasible. Webster MS Webster MS is an existing school in the Venice HS Complex. Under this alternative, the Program would move to the Webster Middle School campus. As the Webster MS campus does not have any available classrooms that could be modified to support the Program, this alternative would require constructing 23 new classrooms. This is 8 more than the 15 classrooms in the proposed project and would also require constructing all of the same support and core facilities as proposed in the project.
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Table 4.3-1: Alternative Sites Considered but Determined to Be Infeasible Wright MS Wright MS is an existing school in the Venice HS Complex. Under this alternative, the Program would move to the Wright Middle School campus. Wright MS has approximately 20 classrooms currently utilized by a Charter School. Under this alternative, the Charter School would need to be relocated to another site (site not identified) and the Program would move to the Wright MS campus and utilize the classrooms currently housing the Charter School. This alternative would require relocating the Charter School, constructing 23 new classrooms, existing classrooms and constructing all of the same support and core facilities as proposed in the Project.
Venice HS Under this alternative, the Program would move to the Venice High School campus. Existing facilities on the Venice HS campus are inadequately sized and therefore incompatible for elementary school-aged children and there is no contiguous space available to build an elementary school on the Venice HS campus.
To date, staff has evaluated elementary, middle and high school sites in the Venice High School complex of schools as well as a former (now closed) elementary school site in the San Fernando Valley. Venice High School was found not to have the available space to accommodate a consolidated Program. It was also found that existing elementary school sites in the vicinity, including Grandview, Westminster, Broadway, Oso and Stoner, generally lack the physical space necessary to support the addition of the Program to the enrollment already at the existing school sites. The elementary sites are generally small plots of land where the addition of buildings would take up valuable playground space, parking and/or other outdoor elements, further reducing those spaces well below sizes required by the California Department of Education. Additionally, elementary school core facilities such as food services and multi-purpose rooms were initially designed to support only the amount of students housed in their original buildings. As a result, the core facilities would be inadequately sized if the Program were relocated to any elementary school that was evaluated.
Middle school sites that have been evaluated during the planning process include Mark Twain Middle School, Marina Del Rey Middle School, Wright Middle School, and Webster Middle School. Of these campuses, only Mark Twain Middle School has the available space to accommodate the addition of a full, consolidated Program. Webster Middle School has no available space, and both Marina Del Rey Middle School and Wright Middle School have co- located Charter Schools that occupy all of the space not utilized for the home school’s curriculum. During the planning process, staff explored the option of relocating the charter school from the Marina Del Rey Middle School, thus making up to 15 existing classrooms available for utilization by the Program. The evaluation of this option included stakeholder engagement with school staff and the community; however, it was ultimately concluded that the curricula of Marina Del Rey Middle School and the Program were not complimentary to one another, and the relocation of the Program to this campus would not be instructionally or operationally successful. Furthermore, under Section 47614(b) of the California Education Code, the District is prohibited from either terminating or otherwise relocating a charter school unnecessarily. The District’s desire to move the Program into Marina Del Rey Middle School would be interpreted as being “unnecessary” under Section 47614(b) and would thereby make this alternative infeasible.
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As the planning process has progressed, the parameters for the project have evolved. The preliminary options that were evaluated relied on the assumption the Program would share core facilities, share administrative areas and the District would add portable buildings to school sites. As the course of the planning process has progressed, it has become apparent that the Program will require its own administrative space. If relocated to a middle school campus, it would require its own core facilities as well. In keeping with the goals and objectives of the School Upgrade Program, which includes replacing temporary relocatable housing with permanent structures, the District also determined that it would not use the addition of portable buildings to house the Program as a long-term solution.
The educational and operational objectives have also been refined as a result of the evolution of the planning process, finding that co-locating the Program with another school would be less likely to succeed unless the home school offered a complimentary learning model. The Program is intended to grow from a K–5th grade Program to a K–12th grade Program, and Mark Twain Middle School and Venice High School are the planned locations to receive the Mandarin Immersion students in middle and high school grade levels, respectively. Therefore, Mark Twain Middle School offers the best opportunity for the expansion of the Program and successful transition of its students from kindergarten all the way through 12th grade.
In addition to the significance of the Mark Twain campus for fostering K–8 instructional continuity, it is critical that all K–5th grade Mandarin Immersion classes stay on one campus in order to support collaboration between teachers in designing curriculum and assessments; facilitate teacher collaboration in instructional planning within and across grade levels to ensure that instruction is coherent within the program; create an immersive language community that allows students to use the language outside the classroom and practice their language skills by teaching younger students on the playground and at lunch; and provide for shared resources for K–8, such as Mandarin books and multimedia for the students and a collection of resources for teachers. In the past 5 years, teacher collaboration and developing growth together have proven to be a tremendous asset to Broadway’s Mandarin Immersion program, resulting in rigorous instruction and strong student learning. This is also true for tutoring and afterschool programs in Mandarin, as the paucity of such programs means that organizing them is a challenge and it is far easier to manage in a single location. 4.4 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
This section summarizes the environmental advantages and disadvantages associated with the proposed project and the alternatives. According to State CEQA Guidelines Section 15126.6(d), Evaluation of Alternatives, an EIR shall include sufficient information about each alternative. Each alternative must be evaluated for the impacts that are most important, depending on setting and impact classification. An alternative would be considered superior to the proposed project if there is a reduction in environmental impact. CEQA also requires that the No Project Alternative to be evaluated. Of the alternatives analyzed in the EIR, the No Project Alternative is the environmentally superior alternative due to the fact that it would avoid or reduce most of the potential impacts associated with construction and operation of the proposed project. However, the No Project Alternative would not meet the objectives of the proposed project, as discussed earlier in this chapter.
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The State CEQA Guidelines require that if the No Project Alternative is determined to be the environmentally superior alternative, an environmentally superior alternative must also be identified among the action alternatives.5 Therefore, the Redistricting Alternative would be the superior alternative since it would result in less overall impacts in comparison to the proposed project and the Marina Del Rey Alternative. The Redistricting Alternative is considered environmentally superior to all other alternatives for a number of reasons including:
The Redistricting Alternative would not entail construction of new structures and classrooms, therefore reducing impacts associated with construction emissions, noise, and traffic.
The Redistricting Alternative would fulfill the greatest decrease in disturbances to the physical footprints. There are no excavation or physical disturbances anticipated; therefore, this alternative has no environmental impacts associated with grading, excavation, or earth- moving activities.
The Redistricting Alternative would meet most of the project objectives and result in the least amount of environmental impacts compared to the proposed project and Marina Del Rey alternatives.
Summaries of impacts are provided in Table 4.4-1, Summary of Impacts, and Table 4.4-2, Comparison of Alternatives to the Proposed Project.
Table 4.4-1: Summary of Impacts Alternatives Proposed Project Marina Del Rey No Project Redistricting No Impact 5 7 17 12 Less Than Significant 9 7 1 4 Potentially Significant 4 4 0 2
5 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15126.6.
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative I. AESTHETICS - Would the project: Have a substantial adverse effect on a scenic vista? No impact Similar Similar Similar Similar Damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No impact Similar Similar Similar Similar
Substantially degrade the existing visual character or quality of the site and its surroundings? No impact Similar Similar Similar Similar
Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Less than significant impact Less Similar Similar Less
II. AGRICULTURAL RESOURCES - In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agricultural farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Program and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project: Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program No impact Similar Similar Similar Similar in the California Resources Agency, to non-agricultural use?
Conflict with existing zoning for agricultural use, or a Williamson Act contract? No impact Similar Similar Similar Similar
Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), No impact Similar Similar Similar Similar or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
Result in the loss of forest land or conversion of forest land to non-forest use? No impact Similar Similar Similar Similar
Involve other changes in the existing environment, which, due to their location or nature, could individually or cumulatively result in loss of Farmland, to non-agricultural use or conversion of No impact Similar Similar Similar Similar forest land to non-forest use?
III. AIR QUALITY - Where available, the significance criteria established by the applicable air quality management or pollution control district may be relied upon to make the following determinations. Would the project: Conflict with or obstruct implementation of the applicable air quality plan? No impact Similar Similar Similar Similar
Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Less than significant impact Less Similar Less Similar
Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard Less than significant impact Less Similar Less Similar (including releasing emission, which exceed quantitative thresholds for ozone precursors)?
Expose sensitive receptors to substantial pollutant concentrations? Less than significant impact Less Similar Less Similar
Create objectionable odors affecting a substantial number of people? Less than significant impact Less Similar Less Less
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative IV. BIOLOGICAL RESOURCES – Would the project: Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, No impact Similar Similar Similar Similar policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of No impact Similar Similar Similar Similar Fish and Wildlife or U.S. Fish and Wildlife Service?
Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through No impact Similar Similar Similar Similar direct removal, filling, hydrological interruption, or other means?
Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of Less than significant impact Less Less Similar Less native wildlife nursery sites?
Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? No impact Similar Similar Similar Similar
Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state Habitat Conservation Plan? No impact Similar Similar Similar Similar
V. CULTURAL RESOURCES – Would the project: Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5? No impact Similar Similar Similar Similar
Cause a substantial adverse change in the significance of an archaeological resource as defined in Section 15064.5? No impact Similar Similar Similar Similar
Directly or indirectly, destroy a unique paleontological resource or site or unique geologic feature? Less than significant impact Less Greater Less Less
Disturb any human remains, including those interred outside of formal cemeteries? Less than significant impact Less Greater Less Less VI. GEOLOGY AND SOILS – Would the project: Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other No impact Similar Similar Similar Similar substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative Strong seismic ground shaking? No impact Similar Similar Similar Similar
Seismic-related ground failure, including liquefaction? No impact Similar Similar Similar Similar
Landslides? No impact Similar Similar Similar Similar Result in substantial soil erosion or the loss of topsoil? No impact Similar Similar Similar Similar
Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, No impact Similar Similar Similar Similar liquefaction, or collapse?
Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994) creating substantial risks to life or property? Less than significant impact Less Similar Similar Less
Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems, where sewers are not available for the disposal of wastewater? No impact Similar Similar Similar Similar
VII. GREENHOUSE GAS EMISSIONS - Would the project:
Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Less than significant impact Less Similar Less Similar
Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? No impact Similar Similar Similar Similar
VIII. HAZARDS AND HAZARDOUS MATERIALS - Would the project: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? No impact Similar Similar Similar Similar
Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the No impact Similar Similar Similar Similar environment?
Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No impact Similar Similar Similar Similar
Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to No impact Similar Similar Similar Similar the public or the environment?
For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety No impact Similar Similar Similar Similar hazard for people residing or working in the project area?
For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? No impact Similar Similar Similar Similar
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? No impact Similar Similar Similar Similar
Expose people or structures to a significant risk of loss, injury, or death involving wild land fires, including where wild lands are adjacent to urbanized areas or where residences are No impact Similar Similar Similar Similar intermixed with wildlands?
IX. HYDROLOGY AND WATER QUALITY – Would the project: Violate any water quality standards or waste discharge requirements? Less than significant impact Less Similar Similar Less
Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local Less than significant impact Less Similar Similar Less groundwater table level (i.e., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted).
Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner, which would result in substantial erosion or Less than significant impact Less Similar Similar Less siltation on- or off-site?
Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface Less than significant impact Less Similar Similar Less runoff in a manner, which would result in flooding on- or off-site?
Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Less than significant impact Less Similar Similar Less
Otherwise, substantially degrade water quality? Less than significant impact Less Similar Similar Less Place housing within a 100-year floodplain, as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? No impact Similar Similar Similar Similar
Place within a 100-year floodplain structures, which would impede or redirect flood flows? No impact Similar Similar Similar Similar
Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? No impact Similar Similar Similar Similar
Inundation by seiche, tsunami, or mudflow? No impact Similar Similar Similar Similar X. LAND USE AND PLANNING – Would the project: Physically divide an established community? No impact Similar Similar Similar Similar Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal No impact Similar Similar Similar Similar program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative Conflict with any applicable habitat conservation plan or natural community conservation plan? No impact Similar Similar Similar Similar
XI. MINERAL RESOURCES – Would the project: Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? No impact Similar Similar Similar Similar
Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No impact Similar Similar Similar Similar
XII. NOISE – Would the project result in: Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, or a Less than significant impact Less Similar Similar Less substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project?
Exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels? Less than significant impact Less Similar Similar Less
A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Less than significant impact Less Similar Similar Less
A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Less than significant impact Less Greater Similar Less
For a project is located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, or within the vicinity of a private No impact Similar Similar Similar Similar airstrip, would the project expose people residing or working in the project area to excessive noise levels?
For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? No impact Similar Similar Similar Similar
XIII. PEDESTRIAN SAFETY – Would the project: Vehicle Access: Substantially increase vehicular and/or pedestrian safety hazards due to a design feature or incompatible uses? Less Than Significant Less Similar Similar Similar
Pedestrian Routes to School: Create unsafe routes to schools for students walking from local neighborhoods? No Impact Similar Similar Similar Greater
Roadways in the Project Vicinity: Be located on a site that is adjacent to or near a major arterial roadway or freeway that may pose a safety hazard? No impact Similar Similar Similar Similar
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Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative XIV. POPULATION AND HOUSING – Would the project: Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other No impact Similar Similar Similar Similar infrastructure)?
Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? No impact Similar Similar Similar Similar
Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? No impact Similar Similar Similar Similar
XV. PUBLIC SERVICES – Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: Fire protection? No impact Similar Similar Similar Similar Police protection? No impact Similar Similar Similar Similar Schools? Less than significant impact Similar Similar Similar Similar Parks? No impact Similar Similar Similar Similar Other public facilities? No impact Similar Similar Similar Similar XVI. RECREATION – Would the project: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be Less than significant impact Less Greater Similar Less accelerated?
Does the project include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment? No impact Similar Similar Similar Similar
XVII. TRANSPORTATION/TRAFFIC – Would the project: Conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation Significant and unavoidable Less Similar Less Greater including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and impact bicycle paths, and mass transit?
Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the Significant and unavoidable Less Less Similar Greater county congestion management agency for designated roads or highways? impact
Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? No impact Similar Similar Similar Similar
Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? No Impact Similar Similar Similar Similar
Result in inadequate emergency access? Less than significant impact Less Less Similar Similar
Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? Less than significant impact Less Less Similar Similar
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-28 Draft EIR Chapter 4. Alternatives Analysis
Table 4.4-2: Comparison of Alternatives to the Proposed Project Alternative Location at Reduced Proposed Project No Project Marina Del Rey Middle Project Redistricting Environmental Issue Area (After Mitigation) Alternative School Alternative Alternative XVIII. UTILITIES AND SERVICE SYSTEMS – Would the project: Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? No impact Similar Similar Similar Similar
Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental No impact Similar Similar Similar Similar effects?
Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Less than significant impact Less Similar Less Less
Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? No impact Similar Similar Similar Similar
Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to No impact Similar Similar Similar Similar the provider’s existing commitments?
Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs? No impact Similar Similar Similar Similar
Comply with federal, state, and local statues and regulations related to solid waste? No impact Similar Similar Similar Similar
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 4-29 Draft EIR CHAPTER 5.0 OTHER CEQA CONSIDERATIONS
This chapter presents the evaluation of other types of environmental impacts required by the State CEQA Guidelines that are not covered within the other chapters of this EIR. The other CEQA considerations include environmental effects that were found not to be significant, growth-inducing impacts, and significant and unavoidable adverse impacts. 5.1 ENVIRONMENTAL EFFECTS FOUND NOT TO BE SIGNIFICANT
LAUSD has determined that the proposed project would result in either no impact or a less than significant impact to 14 of 18 environmental issue areas. Chapter 3, Environmental Analysis, discusses why the proposed project would have no impact or a less than significant impact for these issue areas. The issue areas determined to have no impact or a less than significant impact in the environmental analysis include the following:
Aesthetics Hydrology and Water Quality
Agriculture and Forestry Resources Land Use and Planning
Air Quality Mineral Resources
Biological Resources Population and Housing
Geology and Soils Public Services
Greenhouse Gas Emissions Recreation
Hazards and Hazardous Materials Utilities and Service Systems
5.2 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES
According to Section 15126.2(c) of the CEQA Guidelines, “Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely.” Primary impacts and, particularly, secondary impacts (such as a highway improvement that provides access to a previously inaccessible area), generally commit future generations to similar uses. Though unlikely for this proposed project, irreversible damage can result from environmental accidents associated with a
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 5-1 Draft EIR Chapter 5.0 Other CEQA Considerations project. Irretrievable commitments of resources should be evaluated to ensure that such current consumption is justified. Therefore, the purpose of this analysis is to identify any significant irreversible environmental effects of project implementation that cannot be avoided.
Both construction and operation of the proposed project would lead to the consumption of limited, slowly renewable, and nonrenewable resources, committing such resources to uses that future generations would be unable to reverse. The new development would require the commitment of resources that include (1) building and construction materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the proposed project site.
Construction of the proposed project would consume certain types of lumber and other forest products including the raw materials in steel, metals such as copper and lead, aggregate materials used in concrete and asphalt such as sand and stone, water, petrochemical construction materials such as plastic, petroleum-based construction materials, and other similar slowly renewable or nonrenewable resources. In addition, fossil fuels for construction vehicles and equipment would also be consumed. In terms of the proposed project operations, the following slowly renewable and nonrenewable resources would be required: natural gas and electricity, petroleum-based fuels, fossil fuels, and water. Part 6, 2013 California Energy Code of the California Code of Regulations, Title 24 (California Building Standards Code) of the California Administrative Code regulates energy use in California buildings, including the amount of energy consumed by new development for heating, cooling, ventilation, and lighting purposes.1 Nevertheless, the consumption of such resources would represent a long-term commitment of those resources.
The commitment of resources required for the construction and operation of the proposed project would limit the availability of such resources for future generations or for other uses during the life of the proposed project. However, continued use of such resources is consistent with the anticipated growth and planned changes on the proposed project site and within the general vicinity. Furthermore, impacts to the energy supply would be less than significant given the existing levels of development within the City of Los Angeles and the County of Los Angeles.
The proposed project would result in commitment of the already developed school campus to other school uses, eliminating other options for its use. The middle school athletic facilities and portable classrooms on the site would be replaced with new elementary school components. Along with the long-term commitment of land uses is an increased commitment of certain public services to the proposed land uses. This includes the provision of water supply services, wastewater treatment services, and solid waste disposal. However, as indicated in Section 5.1, impacts associated with these utilities would be less than significant.
1 California Building Standards Commission. 2013. 2013 California Energy Code. California Code of Regulations, Title 24, Part 6. Available at: http://www.ecodes.biz/ecodes_support/Free_Resources/2013California/13Energy/13Energy_main.html Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 5-2 Draft EIR Chapter 5.0 Other CEQA Considerations
5.3 GROWTH-INDUCING IMPACTS
Pursuant to Sections 15126(d) and 15126.2(d) of the State CEQA Guidelines, an EIR must address whether a proposed project would directly or indirectly foster growth as follows:
[An EIR shall] discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Included in this are projects which would remove obstacles to population growth (a major expansion of wastewater treatment plant, might, for example, allow for more construction in service areas). Increases in the population may further tax existing community service facilities so consideration must be given to this impact. Also discuss the characteristic of some projects, which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively. It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.
This section of the analysis evaluates whether the proposed project would directly, or indirectly, induce economic, population, or housing growth in the surrounding environment. Such impacts normally occur when the proposed project fosters economic or population growth, or the construction of additional housing, either directly or indirectly in the surrounding environment. The types of projects that are normally considered to result in growth-inducing impacts are those that provide infrastructure that would be suitable to support additional growth or remove an existing barrier to growth. Direct Growth-Inducing Impacts in the Surrounding Environment
A project would directly induce growth if it would remove barriers to population growth such as the development of new residences or a change to a jurisdiction’s general plan and zoning ordinance that allowed new residential development to occur. As indicated in Section 5.1, the relocation of the Mandarin Immersion Program to the Mark Twain Middle School campus would not be expected to induce growth.
LAUSD is mandated by state law to educate those students residing in the school district. The proposed project will enable the world language instructional pathways initiative in the Venice High School Complex to align; the associated Spanish and English Dual-Language Immersion Program at Broadway Elementary School to grow; and the associated Mandarin and English Dual- Language Immersion Program to continue to grow and operate on a single site, Mark Twain Middle School. The proposed project will also allow Broadway Elementary School to continue to offer a traditional instructional program for the long-term.
LAUSD staff has analyzed the facilities on the Mark Twain Middle School campus. Educational Service Center West administrators and staff have met with and solicited input from the principals of the Mandarin and English Dual-Language Immersion Program and Mark Twain Middle School. With the cooperation of the respective programs/schools, staff developed the proposed project, a mutually acceptable facilities solution that would provide sufficient capacity on the Mark Twain Middle School campus to support the growth of the Mandarin and English Dual-Language
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 5-3 Draft EIR Chapter 5.0 Other CEQA Considerations
Immersion Program without negatively impacting the capacity or operations of Mark Twain Middle School. Indirect Growth-Inducing Impacts in the Surrounding Environment
A project would indirectly induce growth if it would increase the capacity of infrastructure in an area in which the public service currently met demand. Examples would be increasing the capacity of a sewer treatment plant, other utilities, or a roadway beyond the amount needed to meet the existing demand. As stated above, the construction of the proposed project would not induce more growth, but would meet the current and future demand of a student population enrolled in the Program. 5.4 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS
This section of the EIR includes discussion of the potential for the proposed project to result in significant environmental effects that cannot be avoided. The potentially adverse effects of the proposed project are discussed in Chapter 3. Consistent with the requirements of Section 15126.2(b) of the State CEQA Guidelines, significant impacts, including those that can be mitigated, but not reduced to below the level of significance, are described in this section of the EIR. The potential for the construction, operation, and maintenance of the proposed project to result in significant environmental impacts has been analyzed in Chapter 3.
Based on the analysis contained in Chapter 3, the proposed project would not be expected to result in significant impacts related to aesthetics, agriculture and forestry resources, air quality, biological resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, public services, recreation, and utilities and service systems, based on each set of significance criteria.
The proposed project would result in potentially significant impacts related to cultural resources, noise, and pedestrian safety, but these impacts would be reduced to below the level of significance with the incorporation of mitigation measures. While temporary construction-related impacts to transportation and traffic would be reduced to below the level of significance with the incorporation of mitigation measures, significant and unavoidable impacts related to transportation and traffic would result from the operation of the proposed project, requiring a Statement of Overriding Considerations.
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 5-4 Draft EIR CHAPTER 6.0 ACRONYMS AND ABBREVIATIONS
AAQS Ambient Air Quality Standards
AB Assembly Bill
ACHP Advisory Council on Historic Preservation
ADA Americans with Disabilities Act
ALUC Airport Land Use Commission
APEFZ Alquist-Priolo Earthquake Fault Zone
APN Assessor’s Parcel Number
AQMP Air Quality Management Plan
ASHA American Speech-Language-Hearing Association
ASHRAE American Society of Heating, Refrigeration, and Air-Conditioning Engineers
B.P. Before Present
BLM Bureau of Land Management
BMPs Best Management Practices
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
C&D Construction and Demolition
CalEMA California Emergency Management Agency
CAL FIRE California Department of Forestry and Fire Prevention
CalRecycle California Department of Resources Recycling and Recovery
Caltrans California Department of Transportation
CASQA California Stormwater Quality Association
CBC California Building Code
CCC California Coastal Commission
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-1 Draft EIR Chapter 6.0 Acronyms and Abbreviations
CCR California Code of Regulations
CDC California Department of Conservation
CDE California Department of Education
CDP Coastal Development Permit
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFCs Chlorofluorocarbons
CFP California Fully Protected Species.
CFR Code of Federal Regulations
CGS California Geologic Survey
CH4 Methane
CHL California Historical Landmarks
CHPS Collaborative for High Performance Schools
CHRIS California Historical Resources Information System
CIWMB California Integrated Waste Management Board
CMP Congestion Management Program
CNDDB California Native Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO Carbon Monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent
CPA Community Plan Area
CPHI California Points of Historical Interest
CRHR California Register of Historical Resources
CSA California Special Animal
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-2 Draft EIR Chapter 6.0 Acronyms and Abbreviations
CSC California Species of Special Concern
CSE Countywide Siting Element
CTCSP Coastal Transportation Corridor Specific Plan
CWA Clean Water Act dB Decibel dBA A-weighted Decibel
DOGGR Division of Oil, Gas, and Geothermal Resources
DRS Disposal Reporting System
DSA Division of State Architect
DTSC Department of Toxic Substances Control
DWR Department of Water Resources
EDR Environmental Data Resources
EIR Environmental Impact Report
EOC Emergency Operations Center
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ESA Endangered Species Act
FAR Floor Area Ratio
FEMA Federal Emergency Management Agency
FHWA Federal Highway Administration
FIRMs Flood Insurance Rate Maps
FMMP Farmland Mapping and Monitoring Program
GHG Greenhouse Gas
GWP Global Warming Potential
HCD California Department of Housing and Community Development
HCFCs Hydrochlorofluorocarbons
HCP Habitat Conservation Plan
HFCs Hydrofluorocarbons
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-3 Draft EIR Chapter 6.0 Acronyms and Abbreviations
HUD U.S. Department of Housing and Urban Development
Hz Hertz
ICU Intersection Capacity Utilization
KOP Key Observation Point
LACFCD Los Angeles County Flood Control District
LADOT Los Angeles Department of Transportation
LADWP Los Angeles Department of Water and Power
LAFD Los Angeles Fire Department
LARA Los Angeles Regional Agency
LASPD Los Angeles School Police Department
LAUSD Los Angeles Unified School District
LAX Los Angeles International Airport
LCP Local Coastal Plans
Ldn Day-Night Level
Leq Equivalent Continuous Noise Level
LOS Level of Service
MBTA Migratory Bird Treaty Act
Metro Los Angeles County Metropolitan Transportation Authority mgd Millions of Gallons per Day
MMTCO2e Million Metric Tons of CO2e.
MOU Memoranda of Understanding mph Miles per Hour
MPO Metropolitan Planning Organization
MRZ Mineral Resource Zones
MSL Mean Sea Level
MTCO2e Metric Ton of CO2e.
Mw Moment Magnitude
MWD Metropolitan Water District of Southern California
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-4 Draft EIR Chapter 6.0 Acronyms and Abbreviations
N2O Nitrous Oxide
NAGPRA Native American Graves Protection and Repatriation Act
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NHPA National Historic Preservation Act
NO2 Nitrogen Dioxide
NOI Notice of Intent
NOP Notice of Preparation
NPDES National Pollution Discharge Elimination System
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
O&M Operation and Maintenance
O3 Ozone
OEHS Office of Environmental Health and Safety
ONAC Office of Noise Abatement and Control
OPR Office of Planning and Research
OSHA Occupational Safety and Health Administration
OWTS Onsite Wastewater Treatment System
Pb Lead pCi/L Picocuries per Liter
PF Public Facilities
PFCs Perfluorocarbons
PM10 Coarse Particulate Matter
PM2.5 Fine Particulate Matter
PRC Public Resources Code
PTA Parent-Teacher Associations
RCPG Regional Comprehensive Plan and Guide
RCRA Resource Conservation and Recovery Act
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-5 Draft EIR Chapter 6.0 Acronyms and Abbreviations
REC Recognized Environmental Conditions
ROWD Report of Waste Discharge
RWQCB Regional Water Quality Control Board
SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users
SARA Superfund Amendment and Reauthorization Act
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCCIC South Central Coastal Information Center at California State University, Fullerton
SF6 Sulfur Hexafluoride
SFPD School Facilities Planning Division
SHCB State Historical Building Code
SHPO State Historic Preservation Officer
SIP State Implementation Plan
SMARA Surface Mining and Reclamation Act
SO2 Sulfur Dioxide
SoCAB South Coast Air Basin
SUSMP Standard Urban Stormwater Management Plan
SWMP Storm Water Management Plan
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC Toxic Air Contaminant
TIP Transportation Improvement Program
TMDL Total Maximum Daily Load
TMZ Timberland Production Zone
TSCA Toxic Substances Control Act
TSS Total Suspended Solids
UBC Uniform Building Code
USACE U.S. Army Corps of Engineers
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-6 Draft EIR Chapter 6.0 Acronyms and Abbreviations
USC United States Code
USDA United States Department of Agriculture
USFS U.S. Forest Service
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
UST Underground Storage Tank
UWMP Urban Water Management Plan
V/C Volume/Capacity
WDR Waste Discharge Requirements
WRP Water Resources Plan
ZIMAS Zone Information and Map System
Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 6-7 Draft EIR CHAPTER 7.0 REFERENCES
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United States Code, Title 42, Chapter 116 et. seq: “Emergency Planning and Community Right-to- Know Act.” Available at: http://www.law.cornell.edu/uscode/html/uscode42/usc_sup_01_42_10_116.html
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and Reconstruction Historic Buildings. Washington, DC: U.S. Department of the Interior, National Park Service.
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Los Angeles Unified School District March 26, 2015 Proposed Mandarin and English Dual-Language Immersion Elementary School Project Page 7-18 Draft EIR CHAPTER 8.0 REPORT PREPARATION
8.1 REPORT PREPARERS
Table 8-1: List of Preparers and Reviewers Name Project Role / EIR Chapter Lead Agency / Reviewers Mr. Edward Paek LAUSD CEQA Project Manager/Contract Professional Ms. Gwenn Godek LAUSD CEQA Project Manager/Contract Professional Mr. Scott Singletary LAUSD Facilities Development Manager Ms. Julia Hawkinson LAUSD Senior Project Development Manager/Contract Professional Mr. Jay Golida, Esq. LAUSD Office of General Counsel Mr. Fernando Villa, Esq. Allen Matkins Leck Gamble Mallory & Natsis LLP/Legal Council CEQA Consultant: Sapphos Environmental, Inc. Ms. Marie C. Campbell Principal Ms. Lucy Lin Senior Manager Ms. Laura Male Project Manager Executive Summary, Introduction, Project Description, Alternatives Analysis, Other CEQA Considerations, Aesthetics, Agriculture and Forestry Resources, Population and Housing, Public Services, Recreation Mr. John Eggers Assistant Project Manager Air Quality, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Mineral
Resources, Noise, Pedestrian Safety, Transportation/Traffic, Alternatives Analysis Ms. Lauren Dorough Biological Resources Mr. AJ White Cultural Resources, Geology and Soils, Alternatives Analysis Ms. Marilyn Novell Cultural Resoures, Historic Resources Assessment (Appendix D) Mr. Eric Charlton Land Use and Planning Mr. Jeffrey Rex Hydrology and Water Quality, Utilities and Service Systems Ms. Ann Espejo GIS Analyst Mr. Eugene Ng Graphics Traffic / Pedestrian Impact Consultant: KOA Corporation Mr. Brian Marchetti Traffic Impact Analysis (Appendix H)
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 8-1 Draft EIR Chapter 8.0 Report Preparation
8.2 ORGANIZATIONS AND PERSONS CONSULTED
Geology and Soils Gorian & Associates, Inc. (Geotechnical Investigation)
Hazards and Hazardous Materials Parsons (Phase I Environmental Site Assessment, Phase I Environmental Site Assessment Addendum)
Pedestrian Safety KOA Corporation, Mr. Brian Marchetti, Senior Transportation Planner (Pedestrian Safety Analysis)
Transportation and Traffic KOA Corporation, Mr. Brian Marchetti, Senior Transportation Planner (Traffic Impact Analysis)
Los Angeles Unified School District March 26, 2015 Mandarin and English Dual-Language Immersion Elementary School Project Page 8-2 Draft EIR