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PRELIMINARY WORKING DRAFT – Work in Progress IV.F.2

PRELIMINARY WORKING DRAFT – Work in Progress IV.F.2

IV. ENVIRONMENTAL IMPACT ANALYSIS F. PUBLIC SERVICES 2. POLICE PROTECTION

1. INTRODUCTION

This section addresses impacts on police protection services that would occur due to increased population, traffic, and construction activities associated with the proposed project. The analysis is based in part on information provided by the Police Department (LAPD) regarding police protection facilities, services, and response times.

2. ENVIRONMENTAL SETTING

a. Existing Conditions

(1) Police Protection Facilities and Services

The LAPD currently comprises 19 community police areas operated by four geographically located bureaus: the Central, South, West, and Valley Bureaus. The project site is located in the West Bureau of the LAPD, which covers approximately 124 square miles encompassing the neighborhoods of Pacific Palisades, Westwood, , Venice, Hancock Park, and the Miracle Mile. The West Bureau oversees operations at four community police stations including the Community Police Station, the Wilshire Community Police Station, the Pacific Community Police Station, and the Community Police Station. The West Bureau also oversees operations at the West Traffic Division, which is responsible for investigating traffic collisions and traffic-related crimes for all operations in the West Bureau.

The project site is located in the Wilshire Area, which covers 13.77 square miles and is served by the Wilshire Community Police Station located at 4861 West Venice Boulevard (approximately 2.4 miles southwest of the project site). The cities of Beverly Hills and West Hollywood and the police stations at Hollywood, Rampart, Southwest, and West Los Angeles border Wilshire’s community boundaries. The Wilshire Community Police Station provides police protection service to a residential population of approximately 272,903 people within the

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service area.1 In the event additional staffing is required, additional officers can be called in from other LAPD areas. The Wilshire Area is further divided into several reporting districts. The project site is located within Reporting District (RD) 788, which is bounded by Washington Boulevard to the north, Crenshaw Boulevard to the west, the I-10 freeway (Santa Monica freeway) to the south, and 10th Avenue to the east. Figure IV.F-2 on page IV.F-23 illustrates the location of the Wilshire Area Community Police Station in relation to the project site.

Table IV.F-4 on page IV.F-24 provides statistics for the Wilshire Area and Citywide service areas in terms of population served, sworn personnel, crime rates, officers per 1,000 persons, and the average response times for emergency calls. As shown in Table IV.F-4, the Wilshire Area Community Police Station has 230 sworn officers and 25 civilian support staff. Based on this station’s service population of 272,903, the ratio of officer per resident is approximately one officer per 1,187 persons. In comparison, the Citywide ratio is approximately one officer per 406 persons.

Officers responding to calls for police service do not respond from the Wilshire Community Police Station but are dispatched from the field. The average response time to emergency calls for the Wilshire Area and particularly to the project vicinity is approximately 7 minutes, which is the same amount of time as the average Citywide response time of 7 minutes.

Table IV.F-5 on page IV.F-25 summarizes the 2008 crime statistics for RD 788, the Wilshire Area, and the City. As shown in Table IV.F-5, there are approximately 48 crimes per 1,000 persons in the Wilshire Area and 52 crimes per 1,000 persons Citywide.

The most common type of crime in RD 788, the Wilshire Area, and Citywide is aggravated and theft which constitutes approximately 20 to 30 percent of the total crimes reported.

b. Regulatory Environment

(1) Los Angeles General Plan Framework

The City of Los Angeles General Plan Framework, adopted in December 1996 and again in August 2001, sets forth general guidance regarding long-term growth issues for the entire City of Los Angeles and defines Citywide policies regarding land use, infrastructure, and public services. Goal 9I of the Infrastructure and Public Services Chapter of the Citywide General Plan Framework

1 LAPD. Website: http://www.lapdonline.org/wilshire_community_police_station/content_basic_view/1723, accessed February 2009.

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HAUSER BLVD

VENICE BLVD

W 6TH ST

SAN VICENTE BLVD VICENTE SAN S REDONDO BLVD BLVD VICENTE SAN

S LA BREA AV W OLYMPIC BLVD W OLYMPIC BLVD

W WASHINGTON BLVD PROJECT SITE Source: PCR Services Corporation, 2009; Thomas Brothers, Inc. 2008. 0 Los Angeles, CA 90019 4861 West Venice Police Station Wilshire Community

WILSHIRE BLVD WILSHIRE BLVD

W PICO BLVD PICO W W PICO BLVD PICO W 0.5

N

CRENSHAW BLVD

W ADAMS BLVD 1 Miles

ARLINGTON AV

S WILSTON PL Location of Wilshire Community S WESTERN AV S WESTERN AV

WILSHIRE BLVD

W WASHINGTON BLVD

W PICO BLVD

W OLYMPIC BLVD Police Station Figure IV.F-2

W 8TH ST Washington Square IV.F.2. Police Protection

Table IV.F-4

Population, Officer, Crime, and Response Time Comparison for 2008 a

Square Sworn Officer/Population Average Response Service Area Miles Population Officers Ratio Crimes Time Wilshire Area 13.77 272,903 230 1/1,187 13,109 7 minutes Citywide 485 4,000,226 9,830 1/406 207,503 7 minutes a Statistical information is based on 2008 LAPD Consolidated Crime Analysis Database and Management Information Development Allocation System.

Source: Davis, Eric T., Captain, Wilshire Area Commanding Officer, LAPD, August 25, 2009; LAPD Website, Citywide Crime Statistics: http://www.lapdonline.org/crime_maps_and_compstat/pdf_view/40460, accessed August 20, 2009.

is to ensure that every neighborhood has the necessary level of police services, facilities, equipment, and manpower required to provide for the public safety needs of that neighborhood.2

Objective 9.13 and Policy 9.13.1 requires the monitoring and reporting of police statistics and population projections for the purpose of evaluating existing and future needs. Objective 9.14 requires that adequate police services, facilities, equipment, and personnel are available to meet existing and future public needs. Additionally, Objective 9.15 requires police services to provide adequate public safety in emergency situations by maintaining relationships with local law enforcement agencies, State law enforcement agencies, and the National Guard.

Presently, the LAPD Computer Statistics Unit (COMPSTAT) implements the General Plan Framework goal of assembling statistical population and crime data to determine necessary crime prevention actions. COMPSTAT was created in 1994 by then Police Commissioner of the New York Police Department and current Chief of the Los Angeles Police Department, William J. Bratton. This system implements a multilayer approach to police protection services through statistical and geographical information system (GIS) analysis of growing trends in crime through its specialized crime control model. As such, COMPSTAT has effectively and significantly reduced the occurrence of crime in Los Angeles communities through accurate and timely intelligence regarding emerging crime trends or patterns.3

(2) City of Los Angeles Charter and Administrative and Municipal Codes

The law enforcement regulations and the powers and duties of the LAPD are outlined in the City of Los Angeles Charter Article V, Section 570; the City of Los Angeles Administrative

2 City of Los Angeles General Plan Framework, page 9-5. 3. LAPD “COMPSTAT.” http://www.lapdonline.org/crime_maps_and_compstat (accessed February 2009).

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Table IV.F-5

Crime Statistics by Reporting District of Occurrence

RD 788 Wilshire Citywide Crime Number Percent a Number Percent a Number Percent a 14 11 1,240 9 19,327 9 12 10 1,069 8 13,302 6 Weapon 2 2 92 1 1,506 1 Murder 0 0 22 2 384 0 Rape 0 0 37 0 774 0 Aggravated Assault/Other Assault 30 24 2,517 19 45,142 22 Against Family/Child 1 1 49 0 935 0 Disorderly Conduct 0 0 32 0 448 0 Vagrancy 1 1 87 1 1,560 0 Other Sex Offense 2 2 180 1 2,831 1 Pimping/Panhandling 0 0 4 0 46 0 Theft from Person/Vehicle/Other 23 18 3,692 28 57,011 27 Vehicle Theft 11 9 1,364 10 22,908 11 Forgery/Counterfeit 1 1 173 1 2419 1 Fraud/ Embezzlement 0 0 130 1 1,636 1 Vandalism 14 11 1,366 10 22,474 11 Other Violations 14 11 1,055 8 14,800 7 Total Crimes 125 13,109 207,503

Crimes per 1,000 persons 48 52 a Totals rounded up to the nearest whole number, therefore, values may not add to exactly 100 percent.

Source: Davis, Eric T., Captain, Wilshire Area Commanding Officer, Los Angeles Police Department, August 25, 2009. 2008 Los Angeles Police Department Consolidated Criminal Analysis Database and Management Information Development Allocation System.

Code Chapter 11, Section 22.240; and the Los Angeles Municipal Code (LAMC) Chapter 5 (Public Safety and Protection), Article 2 (Police and Special Officers).

City of Los Angeles Charter Article V, Section 570 gives power and duty to the Police Department to enforce the penal provisions of the Charter, City ordinances and state and federal law. The charter also provides that the responsibility of the LAPD is to act as peace officers and to protect lives and property in times of disaster or public calamity. Chapter 11, Section 22.240 of the Los Angeles Administrative Code requires the LAPD to adhere to the State of California standards described in Section 13522 of the California Penal Code, which charges the LAPD with the responsibility of enforcing all LAMC Chapter 5 regulations related to fire arms, illegal hazardous waste disposal, and nuisances, such as excessive noise, and providing support to the Department of Building and Safety Code Enforcement inspectors and the Fire Department in the enforcement of the City’s Fire, Building, and Health Codes. The LAPD is given the power and

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the duty to protect residents and property, and to review and enforce specific security related mitigation measures in regards to new development.

3. ENVIRONMENTAL IMPACTS

a. Methodology

The determination of significance relative to impacts on police protection services is based on the ability of police personnel to adequately serve the existing and future population, including the proposed project, as well as consideration of the project’s proposed security and/or design features that would reduce the demand for police protection services.

According to the City of Los Angeles’ 2006 CEQA Thresholds Guide, police service demand relates to the size and characteristics of the community, population, the geographic area served, and the number and the type of calls for service. Changes in these factors resulting from a project may affect the demand for services. As such, the determination of significance relative to impacts on police services is based on the evaluation of existing police services in the division serving the project site, including the availability of police personnel to serve the existing and future population. The project’s estimated population is based on the West Adams Community Plan average household size.4 The analysis presents COMPSTAT statistical averages associated with the police division serving the project site, the regional bureau, and Citywide services. Data include the ratio of officer per residents, major crimes per resident, and crimes per officer in the local Wilshire area. The determination of impact on the capability of existing police project services and personnel is based on the potential for the annual crimes per officer in the Wilshire area to exceed current area averages before the addition of the proposed project. Project design features and additional mitigation measures that would reduce the impact of the project on police services are also described as mitigating factors in the determination of any unavoidable impact.

b. Thresholds of Significance

(1) Appendix G to the State CEQA Guidelines

In accordance with Appendix G to the State CEQA Guidelines, a project could have a significant impact on the environment with regard to police protection if a project would result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or need for new or physically altered police protection facilities, the

4 The average household size of 2.79 persons per unit for owner-occupied housing within the West Adams Community Plan Area is utilized.

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construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives of the police department.

(2) City of Los Angeles’ 2006 CEQA Thresholds Guide

According to the City of L.A. CEQA Thresholds Guide (2006), the determination of significance is made on a case-by-case basis, considering the following factors:

• The population increase resulting from the proposed project, based on the net increase of residential units or square footage of non-residential floor area.

• The demand for police services anticipated at the time of project buildout compared to the expected level of service available. Consider, as applicable, scheduled improvements to LAPD services (facilities, equipment, and officers) and the project’s proportional contribution to the demand.

• Whether the project includes security and/or design features that would reduce the demand for police services.

c. Project Design Features

(1) Option A

Option A would contain 547 residential units (328 rental and 219 for sale) and approximately 106,800 square feet of commercial floor area. Additionally, Option A would provide an approximately 1,200 square foot substation for the Los Angeles Police Department. Option A would also include the provision of private security personnel, as well as security lighting, cameras, and secured entries to the parking structures (i.e., gated and controlled). The project design features would serve to create a safe environment for residents and patrons of the commercial uses.

(2) Option B

Option B would provide 342 residential units (125 rental and 217 for sale) and approximately 237,100 square feet of commercial/office floor area. Similar to Option A, Option B would also provide an approximately 1,200 square foot substation for the Los Angeles Police Department, as well as the inclusion of private security personnel, security lighting, cameras, and secured entries to the parking structures (i.e., gated and controlled) to create a safe environment for residents and patrons of the commercial uses.

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d. Analysis of Project Impacts

(1) Construction

Construction-related traffic on adjacent streets could potentially affect emergency access to the project site and neighboring uses. Construction activities may involve temporary lane closures for utility construction, crane erection, or the foundation mat slab pour (generally, only one lane would be temporarily closed so through access on all roadways serving the project site would be maintained). Other implications of construction-related traffic include increased travel time due to flagging or stopping of traffic to accommodate trucks entering and exiting the project site during construction (i.e., for the movement of construction equipment and hauling of excavated materials). As such, construction activities could increase response time for emergency vehicles to local businesses and/or residences, due to travel time delays to through traffic. However, the LAPD would be notified of the times of day and locations of all temporary lane closures, and such closures would be coordinated so that they do not occur during peak traffic periods, to the extent feasible. For a discussion of construction-related traffic, please refer to Section IV.G, Transportation and Circulation, of this EIR. With implementation of the recommended mitigation measures described in Section IV.G of this EIR, traffic impacts from construction activity would be reduced to a less than significant level. Therefore, construction- related traffic impacts to emergency access would be less than significant.

During construction, equipment and building materials would be temporarily stored on- site, that could result in theft and/or potentially necessitate police involvement unless adequate safety and security measures are implemented to secure the site. Therefore, the project would incorporate security design features, such as controlled access by construction personnel, security guards and guard dogs during non-construction hours, and secured perimeter fencing to deter potential crime-related activity on-site during construction.

(2) Operation

Option A

As discussed above, the project site is served by the Wilshire Area Community Police Station, which consists of approximately 230 sworn officers and 25 civilians within the Wilshire Area. As shown in Table IV.F-4, the Wilshire Area Community Police Station provides police protection services to a population of approximately 272,903 people and reported 13,109 crimes in 2008. By dividing the number of annual crimes by the population serviced by the Wilshire Area, a generation factor of 0.05 annual crimes per capita was derived.

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Option A would generate approximately 1,526 new residents and approximately 321 patrons and employees for a total temporary and permanent residential population of 1,847 persons.5 Based on the generation factor of 0.05 crimes per capita, the residential component of the proposed project could potentially result in 76 crimes per year. Based on the generation factor of 0.05 annual crimes per capita, the non-residential component of the proposed project could potentially generate 16 crimes per year. Combined, the residential and non-residential portions of the project could potentially generate 92 crimes per year, which is an increase of 0.7 percent of the crimes reported in the Wilshire Area in 2008. This increase would be offset by the project’s provision of a 1,200 square foot substation for the LAPD. The police substation would increase the amount of police protection available to the site. Additionally, as discussed above, Option A would also include the provision of private security personnel, as well as security lighting, cameras, and secured entries to the parking structures (i.e., gated and controlled). LAPD has also requested that the project take into consideration the placement of monitors within the police substation so that on-site police personnel can work in concert with the private security services. As such, with the development of the LAPD substation and with incorporation of the project design features, impacts to police protection services would be less than significant.

Option B

As discussed above, the project site is served by the Wilshire Community Police Station, which consists of approximately 230 sworn officers and 25 civilians within the Wilshire Area. As shown in Table IV.F-4, the Wilshire Area Community Police Station provides police protection services to a residential population of approximately 251,000 people and reported 13,109 crimes in 2008. By dividing the number of annual crimes by the residential population of the Wilshire Area, a generation factor of 0.05 annual crimes per capita was derived.

Option B would generate approximately 954 new residents and approximately 603 employees and patrons for a total temporary and permanent population of 1,557 persons. Based on the generation factor of 0.05 crimes per capita, the residential component of the proposed project could potentially result in 48 additional crimes per year. Based on the generation factor of 0.05 annual crimes per capita, the non-residential component of the proposed project could potentially generate 30 additional crimes per year.6 Combined, the residential and non-

5 The West Adams-Baldwin Hills-Leimert Community Plan estimates that in 2010, the population in the Community Plan Area would increase to 200,981 residents and the number of households would grow to 71,896, which would represent an average household size of 2.79 persons. For the proposed non-residential uses, the non-residential population was determined based on the following generation factors as indicated in the City of L.A. CEQA Thresholds Guide (2006): 4 persons per 1,000 square feet of office space and 3 persons per 1,000 square feet of retail space. 6 Ibid (6).

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Page IV.F-29 PRELIMINARY WORKING DRAFT – Work in Progress IV.F.2. Police Protection residential portions of the project could potentially generate 78 crimes per year, which is an increase of 0.6 percent of the crimes reported in the Wilshire Area in 2008. However, as with Option A, this increase would be offset by the project’s provision of a 1,200 square foot substation for the LAPD. The police substation would increase the amount of police protection available to the project. Additionally, as with Option A, development of the project under Option B would include private security personnel, security lighting, cameras, and secured entries to the parking structures (i.e., gated and controlled) to create a safe environment for residents and patrons of the commercial uses. As such, with the creation of the LAPD substation and the project design features mentioned above, potential impacts to police protection services would be less than significant.

4. MITIGATION MEASURES

With incorporation of LAMC requirements and project design features, impacts to police protection services during construction of the proposed project would be less than significant. Regarding operation, with incorporation of the project’s design features and development of the police substation, project operation under Option A or Option B would not result in impacts that would significantly affect the capacity of the LAPD to serve the project. Although not necessary to reduce impacts to a less than significant level, the mitigation measures below are recommended to ensure that potential impacts remain less than significant:

Mitigation Measure F.2-1: The Applicant shall consult with the Los Angeles Police Department Crime Prevention Unit on crime prevention features appropriate for the design of the project. The plans shall incorporate the design guidelines relative to security, semi-public and private spaces, which may include but not be limited to access control to building, secured parking facilities, well- illuminated public and semi-public space designed with a minimum of dead space to eliminate areas of concealment, location of toilet facilities or building entrances in high-foot traffic areas These measures shall be approved by the Police Department prior to the issuance of building permits.

Mitigation Measure F.2-2: Upon project completion, the Applicant shall provide the Wilshire Community Police Station Commanding Officer with a diagram of each portion of the property, including access routes, and provide additional information that might facilitate police response.

5. CUMULATIVE IMPACTS

Section III of this Draft EIR identifies approximately 31 related projects that are anticipated to be developed within the vicinity of the project site. For purposes of this

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cumulative analysis on police protection services, only those related projects located within the Wilshire Community Police Station service area are considered, as related projects located in other jurisdictions would be served by their respective police departments (e.g., Beverly Hills Police Department, Santa Monica Police Department, Los Angeles County Sheriffs Department). Of the 31 related projects identified in Section III, eight are located within the City of Los Angeles and in the Wilshire Community Police Station service area as listed in Table IV.F-6 on page IV.F-32.

These related projects would cumulatively generate, in conjunction with the proposed project, the need for additional police protection services. The related projects include various residential, commercial/retail, and office uses. Similar to the proposed project, the number of annual crimes anticipated to be generated by related projects is estimated based on residential and non-residential increases in population. As shown in Table IV.F-6, related projects could potentially generate 131 additional crimes per year than that which would occur if no development were to take place. The proposed project in conjunction with related projects could therefore generate 223 or 209 additional crimes per year under Option A and Option B, respectively. This represents an approximate 1.7 or 1.6 percent increase in annual crimes. However, related projects (particularly those of a larger nature) would likely be subject to discretionary review on a case-by-case basis by the LAPD to ensure that sufficient security measures are implemented to reduce potential impacts to police protection services. Therefore, cumulative impacts to the existing police protection services would be less than significant.

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION

The project would result in less than significant impacts to police protection services with the implementation of LAMC requirements and project design features.

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Table IV.F-6

Cumulative Projects within Wilshire Community Police Station Service Area

Residential and Non- Approximate Map Residential No. of Crimes No.a Project Location Population b, c per capita d 1 Coffee Shop 4177 W Washington Boulevard 5 0 2 Private Elementary School e 1932 10th Avenue - ___ 3 Elementary School e 3rd Avenue and Washington - ___ Boulevard 4 Day Care Center 2240 Crenshaw Boulevard 15 1 5 Office 936 Crenshaw Boulevard 71 4 22 Apartment 5500 275 14 23 Apartment, Restaurant, Retail 5600 Wilshire Boulevard 490 25 24 Wilshire La Brea High Rise; Apartment, 5200 W. Wilshire Boulevard 1,765 88 Retail, Restaurant Related Projects Total 2,621 131

Proposed Project Option A Total 1,847 92 Proposed Project Option B Total 1,557 78

Cumulative with Option A Total 4,468 223 Cumulative with Option B Total 4,178 209

Note: Calculations accounted for proposed net changes in building square footages (i.e., Projected populations for projects that propose to reduce overall building square footage will be recorded as negative). a Corresponds with Map Nos. on Figure III-1 in Section III of this Draft EIR. b For related projects with residential uses, the residential population was determined by multiplying the number of residential units by the average household size as indicated by the population data obtained for the census tract where each project is located. c For related projects with non-residential uses, the non-residential population was determined based on the following generation factors as indicated in the City of L.A. CEQA Thresholds Guide (2006): 4 persons per 1,000 square feet of office space and 3 persons per 1,000 square feet of retail space. d Totals rounded to the nearest whole number. The residential and non-residential population was multiplied by the generation factor of 0.05 crimes per capita to estimate the number of crimes generated by related projects. e No population was calculated for school uses since the increase in population for such uses would generally be accounted for in new residential uses within the area and would result in double counting.

Source: PCR Services Corporation, 2009.

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