Iv. Environmental Impact Analysis F

IV. ENVIRONMENTAL IMPACT ANALYSIS F. PUBLIC SERVICES 3. SCHOOLS

1. INTRODUCTION

This section evaluates potential project impacts on existing school facilities operated by the Los Angeles Unified School District (LAUSD) that would serve the site with the exception of the Los Angeles Tech Center. Impacts on the Los Angeles Tech Center are not included in this analysis because it is a vocational school, and enrollment cannot be assumed for all project residents. The analysis is based, in part, on information provided by the LAUSD Facilities Services Division. Additional information was gathered through the LAUSD website, the LAUSD Facilities Services Division website, and from the LAUSD Developer Fee Program Office. Potential air, noise, and traffic impacts during construction and operation of the proposed project to Arlington Heights Elementary School and Cochran Middle School, which are located north/northeast of the project site, are analyzed in detail in other sections of the Draft EIR including Section IV.B, Air Quality, Section IV.E, Noise, and Section IV.G, Transportation and Circulation of this Draft EIR.

2. ENVIRONMENTAL SETTING

a. Existing Conditions

LAUSD is one of the largest public school districts in the nation encompassing approximately 710 square miles and serving the City of Los Angeles, all or portions of 32 other cities, as well as several unincorporated areas of Los Angeles County. LAUSD provides kindergarten through high school (K–12) education to a total of 688,138 students enrolled throughout 885 schools and centers including: 520 elementary schools, 119 middle schools, 123 high schools, and 123 other schools and centers. 1,2

LAUSD has experienced an increase in enrollment over the last decade, from 636,000 students in the 1994–1995 school year to over 688,000 students in the 2008–2009

1 Excludes Independent Charters. 2 Los Angeles Unified School District, Office of Communications. Fingertip Facts 2008-2009. Website: http://notebook.lausd.net/pls/ptl/docs/PAGE/CA_LAUSD/LAUSDNET/OFFICES/COMMUNICATIONS/08- 09ENGFINGERTIPFACTS.PDF, accessed March 2009.

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school year. Further, LAUSD has recently implemented a class size reduction program. As part of an effort to create the needed additional space, LAUSD has implemented multi-track year- round school calendars at many school sites. Currently, more than 141 schools are on multi- track year-round schedules to accommodate the heavy enrollment at these facilities.3 Other options utilized by LAUSD to address increased enrollment and reduce class size include open enrollment and providing portable classrooms and new permanent facilities. Transportation of students from overcrowded schools to less crowded schools is also a possible method to address overcrowding, though it is not a favored solution.

In addition to utilizing SB 50 fees, other major statewide funding sources for school facilities are Proposition 47, a $13.2 billion bond approved in November 2002 containing $11.4 billion for K–12 public school facilities, and Proposition 55, a $12.3 billion bond approved in March 2004 containing $10 billion to address overcrowding and accommodate future growth in K-12 schools. Local measures provide additional funding for existing and new school construction projects.

Utilizing the funding sources described above, LAUSD has implemented the New School Construction Program, a multi-year capital improvement program valued at over $20.3 billion.4 The New School Construction Program is the major component of LAUSD’s plan to relieve overcrowding in its schools by returning students to a single-track calendar, reducing class sizes to agreed limits at all grade levels, providing special education facilities, providing pre- kindergarten facilities, and reducing the reliance on portable classrooms. By the end of 2008, LAUSD had completed 288 projects totaling 97,991 seats through the New School Construction Program, including 76 new K-12 schools and 59 classroom additions. The program is expected to add approximately 167,000 new seats by the end of 2013.5

LAUSD is currently divided into eight Local Districts. The project site is located within LAUSD Local District 3 and is currently served by Arlington Heights Elementary School, Cochran Middle School, and Los Angeles Senior High School. Table IV.F-7 on page IV.F-34 lists these schools, as well as their location, distance from the project site, current capacity and calendar, resident and actual enrollment, and current seating capacity. Figure IV.F-3 on page

3 Los Angeles Unified School District, Office of the Chief Operating Officer. 2008-2009 New and Continuing Multitrack Year-Round Schools (Alphabetical), May 14, 2008. Website: http://www.lausd.k12.ca.us/district_calendars.html, accessed March 2009. 4 Los Angeles Unified School District, Office of Communications. Fingertip Facts 2008-2009. Website: http://notebook.lausd.net/pls/ptl/docs/PAGE/CA_LAUSD/LAUSDNET/OFFICES/COMMUNICATIONS/08- 09ENGFINGERTIPFACTS.PDF, accessed March 2009. 5 Los Angeles Unified School District. Executive Summary of 2009 Strategic Execution Plan. Website: http://www.laschools.org/sep/pdf/executive-summary.pdf, accessed March 2008.

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Table IV.F-7

2008-2009 Capacity and Enrollment of LAUSD Schools Serving the Project Site

Current Distance Current Seating From Capacity/ Resident Actual Overage/ School Project Site Calendar Enrollment a Enrollment b (Shortage) c Overcrowded d Arlington Heights Elementary 0.3 mile 778/ 779 669 (1) Yes School 1 track 1717 Seventh Avenue Cochran Middle School 0.4 mile 2,035/ 1,790 1,648 245 No 4066 West 17th Street 1 track Los Angeles Senior High School 1.9 miles 4,475/ 4,192 3,334 283 Yes 4650 West Olympic Boulevard 3 track a Resident enrollment is the total number of students living in the schools’ attendance area and who are eligible to attend the school. b Actual enrollment is the number of students actually attending the school now. c Per LAUSD, current seating overage/(shortage) is equal to current capacity minus resident enrollment. d Per LAUSD, a school is considered to be overcrowded if (1) it currently operates on a multi-track calendar, (2) there is currently a seating shortage, or (3) there is currently a seating overage of less than or equal to a ‘safety margin’ of 30 seats.

Source: LAUSD Facilities Services Division, LAUSD Schools Enrollments and Capacities Report, March 2009.

IV.F-35 depicts the location of these schools in relation to the project site. A more detailed description for each school is discussed below.

LAUSD assesses school capacity based on resident enrollment (i.e., the number of students living in the school’s attendance area and who are eligible to attend the school) and not actual enrollment. Furthermore, LAUSD considers a school to be overcrowded if any one of the following occurs: (1) it currently operates on a multi-track calendar, (2) there is currently a seating shortage, or (3) there is currently a seating overage of less than or equal to a “safety margin” of 30 seats. As shown in Table IV.F-7, Arlington Heights Elementary School and Los Angeles Senior High School are currently overcrowded. To date, there are no plans by LAUSD to expand Arlington Heights Elementary School or Los Angeles Senior High School.

(1) Arlington Heights Elementary School

Arlington Heights Elementary School is located at 1717 Seventh Avenue in the City of Los Angeles, approximately 0.3 mile northeast of the project site. Arlington Heights Elementary School operates on a single-track calendar in which the school year begins in early September and ends in mid-June. The school has a current capacity of 778 students. Based on the school’s

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current capacity for 778 students and a resident enrollment of 779 students, Arlington Heights Elementary School has a shortage of one seat and is thus considered to be overcrowded.

(2) Cochran Middle School

Cochran Middle School is located at 4066 West 17th Street in the City of Los Angeles, approximately 0.4 mile north of the project site. Cochran Middle School operates on a single- track calendar in which the school year begins in early September and ends in mid-June. The school has a current capacity of 2,035 students. Based on the school’s current capacity for 2,035 students and a resident enrollment of 1,790 students, the school has an overage of 213 seats and is thus operating within capacity.

(3) Los Angeles Senior High School

Los Angeles Senior High School is located at 4650 West Olympic Boulevard in the City of Los Angeles, approximately 1.9 miles northwest of the project site. Los Angeles Senior High School operates on a three-track calendar in which the school year begins in either July or September (depending on the track) and ends in April or June. The school has a current capacity of 4,475 students. Based on the school’s current capacity for 4,475 students and a resident enrollment of 4,192 students, the school has an overage of 283 seats. However, because the school is operating on a multi-track calendar, it is considered to be overcrowded.

To relieve overcrowding in the area, LAUSD proposes to develop the Central Los Angeles New Learning Center #1 through the New School Construction Program. The Central Los Angeles New Learning Center #1 will be located at 3400 Wilshire Boulevard, approximately 3.1 miles northeast of the project site. The location of this new learning center is depicted in Figure IV.F-3. According to LAUSD, the learning center will open in fall 2009 with grades K-5. However, the learning center is planned to accommodate 1,800 students in grades K-8 (approximately 200 per grade), and 2,440 students in grades 9-12. Eight-hundred students are to be housed in the K-3 section of campus, and 1,000 students in grades 4-8 section.6

b. Regulatory Framework

(1) State of California

School services for the project are subject to the rules and regulations of the California Education Code and governance of the State Board of Education. The State also provides funding through a combination of sales and income taxes and a State lottery. In addition, due to

6 Langan, Grant, LAUSD staff, via email communication, April 1, 2009.

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Proposition 13, the State is also responsible for the allocation of education funds that are acquired from property taxes.

Senate Bill 50 (SB 50), enacted in 1998, is a program for funding school facilities largely based on matching funds. The approval of Proposition 1A authorized funds for SB 50 in the amount of $9.2 billion, including grants for new school construction and modernization of existing schools. The new construction grant provides funding on a 50/50 State and local match basis. The modernization grant provides funding on a 60/40 basis. Districts that are unable to provide some, or all, of the local match requirement and are able to meet the financial hardship provisions may be eligible for additional State funding.7

SB 50 allows LAUSD to levy a fee, charge, dedication, or other requirement against any development project within its boundaries, for the purpose of funding the construction or reconstruction of school facilities. LAUSD currently collects development fees at a rate of $3.87 per square foot of new residential construction, $0.47 per square foot of commercial/industrial construction, and $0.09 per square foot for parking structures.8 Pursuant to Government Code Section 65995, the payment of these fees by a developer serves to mitigate all potential impacts on school facilities that may result from implementation of a project to a less than significant level.

3. ENVIRONMENTAL IMPACTS

a. Methodology

The analysis of operational impacts to schools is based in part on the ability of LAUSD school facilities to accommodate the potential increase in students generated from development of the project. The analysis estimates the number of students that would be generated by the proposed project using LAUSD student generation rates, and focuses on whether LAUSD school facilities expected to serve the project would have sufficient available capacity to accommodate these students. The analysis addresses all levels of education facilities operated by LAUSD (i.e., elementary, middle, and high schools).

The anticipated number of new students was calculated using student generation rates issued by the LAUSD Developer Fee Program Office. Generation rates have been established for a variety of uses including residential (single-family detached and multi-family attached),

7 State of California, Office of Public School Construction, School Facility Program Handbook, May 2008. 8 Los Angeles Unified School District, Office of Chief Financial Officer, December 2009. Developer rates effective through October 22, 2010.

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Page IV.F-37 PRELIMINARY WORKING DRAFT – Work in Progress IV.F.3 Public Services-Schools retail and services, offices, research and development, industrial/warehouse/manufacturing, hospitals, hotels/motels, and parking structures. LAUSD student generation rates for the proposed uses are shown in Table IV.F-8 on page IV.F-39. Once calculated, the number of project-generated students was compared to LAUSD’s projected available capacity at each school that serves the project site to identify the extent to which students could be accommodated within these facilities. This analysis is focused on LAUSD Local District 3 facilities, as impacts to surrounding districts are not anticipated to occur. This conclusion is supported by the general practice that students attending public schools attend the schools in the district where their residence is located, which is LAUSD Local District 3 for future residents of the proposed project. Project-generated students that attend public schools in other school districts (e.g., Culver City Unified School District) would be required to obtain an inter-district transfer permit issued by both the school within which the student is enrolled, as well as the school of interest. Furthermore, approvals for inter-district transfers are subject to a determination that the incoming transfer students could be accommodated without creating an impact on its existing facilities.

b. Significance Thresholds

(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 schools if a project would 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.

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

The City of L.A. CEQA Thresholds Guide (2006) provides specific guidance for measuring a project's actual impacts. The following factors are set forth in the City of L.A. CEQA Thresholds Guide (2006) for determining on a case-by-case basis whether the proposed project would have a significant impact:

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

• The demand for school services anticipated at the time of project build-out compared to the expected level of service available. Consider, as applicable, scheduled improvements to LAUSD services (facilities, equipment, and personnel) and the project’s proportional contribution to the demand;

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Table IV.F-8

LAUSD Student Generation Rates

Multi-Family Attacheda Retail and Services Parking School Level (per unit) (per 1, 000 sf) (per 1,000 sf) Elementary School (K-5) 0.1266 0.0234 0.0009 Middle School (6-8) 0.0692 0.0123 0.0005 High School (9-12) 0.0659 0.0123 0.0005

a LAUSD’s multi-family attached student generation rate was used, which combines both the single-family attached units (e.g., condos, townhomes) and multi-family attached units (e.g., apartments, duplexes, triplexes).

Source: LAUSD, Commercial/Industrial Development School Fee Justification Study, February 2008.

• Whether (and the degree to which) accommodation of the increased demand would require construction of new facilities, a major reorganization of students or classrooms, major revisions to the school calendar (such as year-round sessions), or other actions which would create a temporary or permanent impact on the school(s); and

• Whether the project includes features that would reduce the demand for school services (e.g., on-site school facilities or direct support to LAUSD).

Based on these factors, according to the City of L.A. CEQA Thresholds Guide (2006), a significant impact to schools would occur if the proposed project would:

• Exceed the seating capacity of elementary, middle and high schools serving the project site.

c. Analysis of Project Impacts

(1) Construction

Option A and Option B

Arlington Heights Elementary School and Cochran Middle School are located on the north side of Washington Boulevard across from the project site. More specifically, Arlington Heights Elementary School is located approximately 600 feet to the northeast of the project site and Cochran Middle School is located approximately 600 feet to the north of the site. Given the

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proximity of these schools to the site, the schools could experience some disturbances during construction of the proposed project.

Project-related construction traffic and activities including worker travel, hauling activities, and the delivery of construction materials would affect existing school traffic, pedestrian routes, bus routes, and transportation safety in the project vicinity. As discussed in Section IV.G, Transportation and Circulation, construction vehicles traveling to and from the project site would generally travel along Washington Boulevard, Crenshaw Boulevard, and the 10 Freeway. The anticipated route for construction vehicles arriving at the project site if traveling east or west on the 10 Freeway would be to exit the 10 Freeway at Crenshaw Boulevard and go north to Washington Boulevard and east to the site. The anticipated route for construction vehicles leaving the site would be to exit the site at Washington Boulevard and go west towards Crenshaw Boulevard. Construction vehicles would then travel south on Crenshaw Boulevard to the 10 Freeway. While this route would not pass directly in front of any schools, based upon LAUSD Pedestrian Route Maps, haul routes would interfere with school pedestrian routes at Arlington Heights Elementary School and Cochran Middle School.9 Subsequently, construction vehicles could also potentially result in impacts to school bus routes, and traffic safety and access. Therefore, mitigation measures are recommended in Section IV.G, Transportation and Circulation of this Draft EIR, to ensure that school bus and pedestrian routes, and traffic and safety access would not be negatively affected. Furthermore, construction staging and construction worker-related vehicle parking would be provided on-site and would not occur on or near school property throughout the duration of the construction period. Safety and security would be maintained throughout construction, and construction activities would adhere to all applicable construction regulations and guidelines including those discussed in the California Vehicle Code, and the Construction Staging and Traffic Management Plan discussed in Section IV.G, Transportation and Circulation of this Draft EIR. With implementation of the mitigation measures presented in Section IV.G, of this Draft EIR, project-related construction would not alter existing traffic patterns or result in any significant traffic impacts to schools.

For a more detailed discussion of construction-related traffic impacts, please refer to Section IV.G, Transportation and Circulation, of this Draft EIR.

(2) Operation

As discussed above, the project site is served by Arlington Heights Elementary School, Cochran Middle School, and Los Angeles Senior High School. Therefore, students generated by the project would likely attend these schools. As buildout of the proposed project is expected

9 No LAUSD pedestrian maps are available for Los Angeles Senior High School; City of Los Angeles- Department of Transportation. http://ladot.lacity.org/tf_safe_routes_school.htm, accessed May 4, 2009.

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to occur in 2013, students generated by Option A or Option B would likely enroll in these LAUSD schools in the 2013-2014 school year. LAUSD limits forecasts to five-year projections, thus only forecasts for the 2013-2014 school year are available. As shown in Table IV.F-9 on page IV.F-42, based on LAUSD criteria, Arlington Heights Elementary School and Los Angeles Senior High School are anticipated to be overcrowded during the 2013-2014 school year without the project. Although Arlington Heights Elementary School is projected to have an overage of 27 seats, it is less than the “safety margin” of 30 seats. Los Angeles Senior High School is anticipated to have a shortage of approximately 1,573 seats.

As described in Section II, Project Description, the project proposes two development options, Option A and Option B. Project impacts on schools under both development options are discussed in detail below.

Option A

Option A would include the development of 547 residential units, approximately 106,869 square feet of commercial uses, and 444,918 square feet of parking. As shown in Table IV.F-10 on page IV.F-43, based on the generation rates provided by the LAUSD Developer Fee Program Office, Option A would generate a total of 72 elementary school students, 39 middle school students, and 37 high school students When students generated by Option A are added to the enrollment projections forecasted for each school listed above (72 elementary school students, 39 middle school students, and 37 high school students), as shown in Table IV.F-9, both Arlington Heights Elementary School and Los Angeles Senior High School would be overcrowded. With the addition of students to be generated under Option A, Arlington Heights Elementary School would result in a shortage of 45 seats and Los Angeles Senior High School would result in a shortage of 1,610 seats. However, Cochran Middle School would be able to accommodate the new middle school students. Cochran Middle School would still have an excess of 174 seats. Thus, the project under Option A would result in potentially significant impacts to both Arlington Heights Elementary School and Los Angeles Senior High School.

Option B

Option B would include the development of 342 residential units, approximately 237,125 square feet of commercial and other service uses, 35,900 square feet of office uses, and 503,000 square feet of parking. As shown in Table IV.F-11 on page IV.F-44, based on the generation rates provided by the LAUSD Developer Fee Program Office, Option B would generate 50 elementary school students, 28 middle school students, and 27 high school students. When students generated by Option B are added to the enrollment projections for each school listed above, as shown in Table IV.F-12 on page IV.F-45, Arlington Heights Elementary School and Los Angeles Senior High School would be overcrowded. With the addition of Option B, Arlington Heights Elementary School would result in a shortage of 23 seats and Los Angeles

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Table IV.F-9

Projected 2013-2014 Capacity and Enrollment of LAUSD Schools Serving the Project Site with Option A

Projected Projected Projected Seating Seating Project Enrollment Overage/ Projected Projected Overage/ Generated With Option (Shortage) Option A School Capacity a Enrollment b (Shortage) c Students A With Project Impact? Arlington Heights 736 709 27 72 781 (45) Yes Elementary School Cochran Middle School 1,579 1,366 213 39 1,405 174 No Los Angeles Senior 2,315 3,888 (1,573) 37 3,925 (1,610) Yes High School a The capacity the school will have after shifting to a two-semester (1 track) calendar and implementing operational goals such as full-day kindergarten and class-size reduction. b Projected five-year total number of students living in the school’s attendance area and who are eligible to attend the school. Includes secondary-grades magnet students. c Per LAUSD, projected seating overage/(shortage) equal to projected capacity minus projected enrollment.

Source: LAUSD Facilities Services Division, LAUSD Schools Enrollments and Capacities Report, March 2009.

Senior High School would result in a shortage of 1,600 seats. However, Cochran Middle School would be able to accommodate the new middle school students. With the addition of Option B, Cochran Middle School would still have an excess of 185 seats. Thus, as with Option A, the project under Option B would result in potentially significant impacts to both Arlington Heights Elementary School and Los Angeles Senior High School.

As discussed above, although there are no plans by LAUSD to expand Arlington Heights Elementary School or Los Angeles Senior High School, a new learning center that includes an elementary, middle, and high school is proposed through the New School Construction Program to relieve overcrowding in the area. The Central Los Angeles New Learning Center #1 is planned to accommodate 1,800 students in grades K-8 (approximately 200 per grade), and 2,440 students in grades 9-12. Eight-hundred students are to be housed in the K-3 section of campus, and 1,000 students in grades 4-8 section.10 However, it should be noted that while these new seats will help offset projected overcrowding at the existing schools serving the project site, there may be other overcrowded schools in the area that are also targeted to be relieved by this new school. Therefore, it should not be assumed that all the seats at this new school would be allocated solely towards offsetting overcrowding at Arlington Heights Elementary School or Los Angeles Senior High School.

10 Ibid (8).

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Table IV.F-10

Estimated Number of Students Generated by Option A

No. of Students Generated a Proposed Units/ Elementary School Middle School High School Land Use Square Footage (K-5) (6-8) (9-12) Multi-Family Attached b 547 units 69 38 36 Retail and Services 106,869 sf 3 1 1 Parking 444,918 sf 0 0 0 Total 72 39 37

a Rounded to the nearest whole number. b LAUSD’s multi-family attached student generation rate was used, which combines both the single-family attached units (e.g., condos, townhomes) and multi-family attached units (e.g., apartments, duplexes, triplexes).

Source: PCR Services Corporation, 2009.

In addition, the number of students generated by Option A or Option B that would actually attend the LAUSD schools serving the project site may be less than the students calculated since the analysis does not take into account options to allow students to receive education elsewhere. These options include the following:

• Private schools (such as the St. Paul’s Catholic School immediately adjacent to the west of the project site, the La Onnuri Mission Church School across the project site to the east, the King Learning Academy to the southwest of the project site, and others);

• Home-schooling;

• Open enrollment enables students anywhere within the district to apply to any regular, grade-appropriate LAUSD school with designated “open enrollment” seats;

• Magnet schools and magnet centers are open to all students in the LAUSD. Transportation is provided to students who participate in magnet programs who live outside a two-mile radius or outside the magnet school attendance boundary;

• The Permits With Transportation (PWT) program provides transportation for students seeking a more integrated experience to schools outside their home attendance area;

• Intra-district parent employment-related transfer permits allow students to enroll in a school that serves the attendance area in which the student’s parent is regularly employed;

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Table IV.F-11

Estimated Number of Students Generated by Option B

No. of Students Generated a Proposed Units/ Elementary School Middle School High School Land Use Square Footage (K-5) (6-8) (9-12) Multi-Family Attached b 342 units 43 24 23 Retail and Other Servicesc 237,125 sf 6 3 3 Office 35,900 sf 1 1 1 Parking 503,000 sf 0 0 0 Total 50 28 27

Source: PCR Services Corporation, 2009.

• Sibling permits enable students to enroll in a school where a sibling is already enrolled; and

• Child care permits allow students to enroll in a school that serves the attendance area in which a younger sibling is cared for daily during after school hours by a known child care agency, private organization, or verifiable child care provider.

Furthermore, it should be noted that the majority of units provided under both development options would include a large percentage of studio/loft-type and one-bedroom units. Therefore, it is anticipated that these units would be occupied mostly by first-time homebuyers (e.g. younger working singles and couples) and older empty nesters. Therefore, the projected student generation may be overstating the actual number of students to be generated by the project and the discussion provided herein presents a conservative analysis of the project’s potential impacts on LAUSD facilities. Furthermore, pursuant to Section 65995 of the California Government Code, with the payment of developer fees in accordance with SB 50, project-related impacts on LAUSD school facilities (i.e., Arlington Heights Elementary School and Los Angeles Senior High School) would be reduced to a less than significant level. Compliance with SB 50 is considered full and complete mitigation.

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Table IV.F-12

Projected 2013-2014 Capacity and Enrollment of LAUSD Schools Serving the Project Site with Option B

Projected Projected Projected Seating Seating Project Enrollment Overage/ Projected Projected Overage/ Generated With Option (Shortage) Option B School Capacity a Enrollment b (Shortage) c Students B With Project Impact? Arlington Heights 736 709 27 50 758 (23) Yes Elementary School Cochran Middle School 1,579 1,366 213 28 1,393 185 No Los Angeles Senior 2,315 3,888 (1,573) 27 3,914 (1,600) Yes High School a The capacity the school will have after shifting to a two-semester (1 track) calendar and implementing operational goals such as full-day kindergarten and class-size reduction. b Projected five-year total number of students living in the school’s attendance area and who are eligible to attend the school. Includes secondary-grades magnet students. c Per LAUSD, projected seating overage/(shortage) equal to projected capacity minus projected enrollment.

Source: LAUSD Facilities Services Division, LAUSD Schools Enrollments and Capacities Report, March 2009.

(3) Consistency with Regulatory Framework

Option A and Option B

The proposed project would be required to comply with SB 50, which requires payment of developer fees to LAUSD prior to issuance of building permits to mitigate the project’s impacts on public school facilities. The Project Applicant would pay the developer fees that are in effect at the time of building permits. Payment of the SB 50 fees would ensure consistency of the project with applicable regulations.

4. MITIGATION MEASURES

a. Construction

Option A and Option B

As discussed above, construction of the project could potentially impact school bus routes, pedestrian routes, and traffic and safety access. Therefore, mitigation measures have been recommended in Section IV.G, Transportation and Circulation of this Draft EIR. With the incorporation of the mitigation measures presented therein, construction-related impacts

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b. Operation

Option A and Option B

Operation of the proposed project would result in potentially significant impacts to both the Arlington Heights Elementary School and the Los Angeles Senior High School. Subsequently, the project would also contribute to a cumulative impact to both of these schools with related projects under both Option A and B. However, as discussed above, payment of developer fees under the provisions of SB 50 would constitute full mitigation for significant impacts associated with the project and for cumulative development. Therefore, with payment of these fees, no mitigation measures would be required.

5. CUMULATIVE IMPACTS

Section III of this Draft EIR identifies 31 related projects that are anticipated to be developed within the vicinity of the project site. For purposes of this cumulative impact analysis on schools, only those related projects located within the attendance boundaries of the schools serving the project site (Arlington Heights Elementary School, Cochran Middle School, and Los Angeles Senior High School) have been considered. Moreover, related projects that are located within the attendance boundaries but do not constitute uses that typically generate students (i.e., theaters, private schools, or senior housing) were also excluded from the analysis, as such uses would not be expected to generate students within a public school. This belief is further supported by the fact that LAUSD does not employ generation rates for such uses.

Of the 31 related projects identified in Section III, Environmental Setting, six are located within the attendance boundaries of the schools serving the project site and are included in this cumulative analysis as listed in Table IV.F-13 on page IV.F-47. These related projects would cumulatively generate, in conjunction with the proposed project, new students at Arlington Heights Elementary School, Cochran Middle School, and Los Angeles Senior High School. The related projects include various residential, commercial/retail, and office uses. Similar to the proposed project, the number of students anticipated to be generated by related projects was estimated using the generation rates provided by the LAUSD Developer Fee Program Office and the type of development proposed. Table IV.F-13 provides a calculation of the number of students to be generated by the related projects. As shown therein, the six related projects would generate no elementary school students, one middle school student, and 46 high schools students.

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Table IV.F-13

Related Projects Within Attendance Boundaries of LAUSD Schools Serving the Project Site

No. of Students Generated b Arlington Cochran Los Angeles Heights Middle Senior High Map Elementary School School No.a Project Location School (K-5) c,d,e (6-8) c,d,e (9-12) c,d,e 1 Coffee Shop 4177 W Washington Boulevard 0 0 0 21 Retail, Office, Bank 3060 Crenshaw Boulevard N/A 1 N/A 24 Wilshire La Brea High Rise; 5200 W. Wilshire Boulevard N/A N/A 38 Apartment, Retail, Restaurant 26 Condominium, Specialty Retail 600 Hobart Boulevard -N/A N/A 5 27 Condominium 844 S. Fedora Street N/A N/A 3 28 Restaurant 3267 W. Olympic Boulevard N/A N/A 0 (6) Related Projects Total 0 1 46 Proposed Project Option A 72 39 37 Proposed Project Option B 50 28 27 Cumulative with Option A 72 40 83 Cumulative with Option B 50 29 73

Notes: N/A= Not applicable; The number of students generated by the related project are not included in this analysis as the students would be served by a different school in the district; a Corresponds with Figure III-1 on page III-14 in Section III of this EIR. b Students generated were rounded to the nearest whole number. c Calculated by multiplying each of the proposed uses by its respective student generation rate issued by LAUSD. LAUSD has established student generation rates for residential (single-family detached and multi-family), retail and services, offices, research and development, industrial/warehouse/manufacturing, hospitals, hotels/motels, and parking structures. d Please note that the attendance boundaries are not the same for all three levels of schools. A related project may be located within the attendance boundaries of the elementary school (Arlington Elementary School) but not within the attendance boundaries of the middle school (Cochran Middle School) or high school (Los Angeles High School). This was taken into consideration when conducting the calculations presented and is indicated by dashes. e In some instances the number of students generated is <1 and therefore shown as 0.

Source: PCR Service Corporation, 2009.

Option A

As discussed above, the project under Option A would generate 72 elementary school students, 39 middle school students, and 37 high school students. Therefore, Option A in conjunction with related projects would generate 72 elementary school students (72+0), 40 middle school students (39+1), and 83 high school students (37+46).

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When compared with the projected enrollment and capacity availability in 2013-2014 for each school that would serve the project site, the project in conjunction with the addition of the students generated by the related projects would result in a potentially significant impact to both Arlington Heights Elementary School and Los Angeles Senior High School. The school facilities with the exception of Cochran Middle School would not be able to accommodate the cumulatively projected number of students. As shown in Table IV.F-14 on page IV.F-49, given the anticipated new students from both related projects and Option A, Arlington Heights Elementary School would have a shortage of 45 seats (27-72). Cochran Middle School would have an excess of 173 seats (213-40). Los Angeles Senior High School would have a shortage of 1,656 seats (-1573-83). Therefore, Option A would contribute to a cumulative impact to schools.

However, as with the proposed project, the analysis presented herein does not take into account the availability of seats that would be provided by the proposed Central Los Angeles New Learning Center #1 anticipated to open in Fall 2009. The analysis also does not take into account that the number of students that would actually attend the LAUSD schools serving the project site may be less than the number of students projected due to other schooling options available for students, including private schools, home schooling programs, magnet schools, permits with transportation programs, and those other schooling options previously discussed above. Thus, the analysis presented herein is conservative. Furthermore, pursuant to Government Code Section 65995, the payment of developer fees under the provisions of SB 50 would constitute full mitigation for all impacts to school facilities. As related projects would be required to pay developer fees to mitigate potential impacts on school facilities, cumulative impacts to LAUSD schools serving the project site would be reduced to a less than significant level.

Option B

As discussed above, Table IV.F-13, indicates that the related projects would generate 0 elementary school students, one middle school student, and 46 high school students. Option B would generate 50 elementary school students, 28 middle school students, and 27 high school students. Therefore, Option B in conjunction with related projects would generate 50 elementary school students (50+0), 29 middle school students (28 +1), and 73 high school students (27+46).

The school facilities with the exception of Cochran Middle School would not be able to accommodate the cumulatively projected number of students. As shown in Table IV.F-15 on page IV.F-50, given the anticipated new students from both related projects and Option B, Arlington Heights Elementary School would have a shortage of 23 seats (27-50). Cochran Middle School would have an excess of 184 seats (213-29). Los Angeles Senior High School would have a shortage of 1,646 seats (-1573-73). Therefore, Option B would contribute to a cumulative impact to schools.

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Table IV.F-14

Projected 2013-2014 Capacity and Enrollment of LAUSD Schools Serving the Project Site with Cumulative Projects- Option A

Total Projected Projected Related Cumulative Seating Overage/ Seating Project Projects Projects (Shortage) Cumulative Overage/ Generated Generated Generated With Cumulative Project School (Shortage) a Students Students Students Projects Impact? Arlington Heights 27 72 0 72 (45) Yes Elementary School Cochran Middle School 213 39 1 40 173 No Los Angeles Senior (1,573) 37 46 83 (1,656) Yes High School a Per LAUSD, projected seating overage/(shortage) equal to projected capacity minus projected enrollment.

Source: LAUSD Facilities Services Division, LAUSD Schools Enrollments and Capacities Report, March 2009.

However, as discussed above, the analysis presented herein is conservative as it does not take into account the availability of seats that would be provided by the proposed Central Los Angeles New Learning Center #1 nor that the number of students that would actually attend the LAUSD schools serving the project site may be less than the number of students projected due to other schooling options available for students. As with the proposed project, some of the related projects may be occupied by first-time homebuyers (e.g., younger working singles and couples) and older empty nesters. Furthermore, as discussed above, related projects would be required to pay developer fees to mitigate potential impacts on school facilities.

Pursuant to Government Code Section 65995, payment of developer fees under the provisions of SB 50 would constitute full mitigation for all impacts to school facilities. Thus, as with Option A, with payment of these fees, cumulative impacts to LAUSD schools serving the project site under Option B would be reduced to a less than significant level.

6. LEVEL OF SIGNIFICANCE AFTER MITIGATION

Option A and Option B

As discussed above, with the incorporation of the mitigation measures provided in Section IV.G, potential construction-related impacts associated with school bus access, pedestrian routes, and traffic and safety access, would be reduced to less than significant levels. Option A and Option B would result in a potentially significant impact to schools since the students generated by both options would result in an exceedance of the available capacity at Arlington Elementary and Los Angeles Senior High School. In addition, Option A and Option B

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Table IV.F-15

Projected 2013-2014 Capacity and Enrollment of LAUSD Schools Serving the Project Site with Cumulative Projects- Option B

Total Projected Seating Projected Related Cumulative Overage/ Seating Project Projects Projects (Shortage) With Cumulative Overage/ Generated Generated Generated Cumulative Project School (Shortage) a Students Students Students Projects Impact? Arlington Heights 27 50 0 50 (23) Yes Elementary School Cochran Middle School 213 28 1 29 184 No Los Angeles Senior High (1,573) 27 46 73 (1,646) Yes School a Per LAUSD, projected seating overage/(shortage) equal to projected capacity minus projected enrollment.

Source: LAUSD Facilities Services Division, LAUSD Schools Enrollments and Capacities Report, March 2009.

would contribute to a cumulative impact to schools since Arlington Elementary and Los Angeles Senior High School would operate over capacity with the proposed project in conjunction with the related projects. However, the payment of the developer fees under the provisions of SB 50 would constitute full mitigation for impacts to school facilities. Therefore, through payment of fees, project and cumulative impacts to LAUSD schools serving the project site would be mitigated to a less than significant level.

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