III. RESPONSES TO COMMENTS INTRODUCTION This section contains written responses to each of the comments on the Draft EIR received during the public review period. The responses to comments are arranged by: (1) Responses to Public Agency Comments; and (2) Responses to Public Comments. All the comment letters are included in Appendix A to this document and are shown in alphabetical order. Each letter is identified by the last name of the commenter, and each comment is delineated and numbered. The text of the individual comments is included below and is followed by a response to the comments. Corrections and additions resulting from comments on the Draft EIR are presented in Section IV, Corrections and Additions. City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-1 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments This page intentionally blank. City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-2 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments LETTER NO. 1 Scott Morgan, Acting Director Governor's Office of Planning and Research State Clearinghouse 1400 10th Street, P.O. Box 3044 Sacramento, CA 95812-3044 COMMENT NO. 1-1 The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on February 22, 2010, and the comments from the responding agency (ies) is (are) enclosed. If this comment package is not in order, please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly. Please note that Section 21104(c) of the California Public Resources Code states that: "A responsible or other public agency shall only make substantive comments regarding those activities involved in a project which are within. an area of expertise of the agency or which are, required to be carried out or approved by the agency. Those comments shall be supported by specific documentation." These comments are forwarded for use in preparing your final environmental document. Should you need more information or clarification of the enclosed comments, we recommend that you contact the commenting agency directly. This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process, RESPONSE NO. 1-1 The letter indicates that the Draft EIR was sent to various state agencies. The letter attaches two comment letters from state agencies that were received, one from Caltrans and the other from the Native American Heritage Commission. Please see Comment Letters Nos. 2 and 3, respectively, City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-3 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments for these letters and the associated responses. In addition, the letter indicates that the City has complied with the State Clearinghouse requirements. The letter does not include a specific comment regarding the contents of the Draft EIR and, thus, no further response is necessary. City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-4 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments LETTER NO. 2 Elmer Alvarez Caltrans- District 7 IGR / CEQA Coordinator Planning Division/CEQA MS 16 100 S. Main Street Los Angeles, CA 90012 COMMENT NO. 2-1 Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the above referenced project. The proposed project is to develop a mixed-use project with residential and retail-commercial uses within the West Adams-Baldwin Hills-Leimert Community in the City of Los Angeles. RESPONSE NO. 2-1 The comment provides a description of the proposed project and is introductory in nature and briefly summarizes the project. The comment does not include a specific comment regarding the contents of the Draft EIR. However, the letter will be forwarded to the decision-making bodies as part of the Final EIR for their consideration in reviewing the proposed project. COMMENT NO. 2-2 On page IV.G-3, Arlington Avenue, our records indicate that Arlington Ave. at the 1-10 westbound ramps provide two through lanes plus a left turn lane instead of three through lanes in the southbound direction. RESPONSE NO. 2-2 The description of Arlington Avenue provided on page IV.G-3 of the Draft EIR has been revised to the following: Arlington Avenue is designated a north-south Secondary Highway. It is a continuation of Wilton Place at Olympic Boulevard that extends southerly and becomes Van Ness Avenue at 54th Street. In the project vicinity, Arlington Avenue generally provides two through lanes in each direction. However, immediately north of the Santa Monica Freeway westbound ramps, the roadway widens to provide three lanes in the southbound direction. City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-5 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments Although a Type I arrow pavement marking is present in the innermost southbound travel lane north of the Santa Monica Freeway westbound ramps, this lane becomes an exclusive left-turn lane for vehicles accessing the Santa Monica Freeway eastbound on-ramp south of the westbound ramps. Left-turns are prohibited during the weekday A.M. and P.M. peak commute periods (7:00 A.M. to 9:00 A.M. and 4:00 P.M. to 7:00 P.M.) at Venice Boulevard, Washington Boulevard and Adams Boulevard. On-street parking is generally provided, except at some portions of the roadway where parking is prohibited from 7:00 A.M. to 9:00 A.M. and from 4:00 P.M. to 7:00 P.M. Approximately one mile southeast of the project site, Arlington Avenue provides full ramp access with the Santa Monica Freeway. Since approximately one-quarter to one-half of the southbound vehicles on Arlington Avenue approaching the I-10 Freeway interchange are destined for the I-10 Freeway eastbound on-ramp during the peak hours, no lane utilization imbalances are expected to occur among the three southbound travel lanes at the intersection with the I-10 Freeway westbound ramps. Therefore, the volumes and capacities for all three southbound lanes which provide for through movements at this intersection have appropriately been included and analyzed as either through or shared through/right-turn lanes. COMMENT NO. 2-3 On Table IV.G-3 and Table IV.G-4, the project is using as high as 40% of the trip volume for trip credit reduction when calculating project trip volume. The assumption of trip reduction seem unreasonably high, please justify. RESPONSE NO. 2-3 Tables IV.G-3 and IV.G-4 of the Draft EIR summarize the trip generation estimates for Options A and B, respectively. Under either option, the proposed project would consist of a mix of residential and commercial uses. Vehicle trip reductions are expected to occur due to the presence of multi-use or internal trips within the site, as well as site person trips being made through the use of public transportation, walk-in trips, and pass-by trips. The Traffic Study, which is provided in Appendix E of the Draft EIR, was prepared under the direction of the City of Los Angeles Department of Transportation (LADOT) for the City of Los Angeles, the lead agency under CEQA for the proposed project. As lead agency, the City must decide upon rational and reasonable methods in order to determine the scope and methodology of each portion of the environmental analysis. The person-trip mode split rates and corresponding vehicle trip adjustment factors used for the analysis were selected based on the project’s mix of uses, site layout, and proximity to alternative transportation modes. For example, several Los City of Los Angeles Washington Square Mixed-Use Development State Clearinghouse No. 2009021035 July 2010 Page III-6 PRELIMINARY WORKING DRAFT – Work in Progress III. Responses to Comments Angeles County Metropolitan Authority (Metro) and LADOT bus routes have stops within approximately one-quarter mile of the project site; the Metro Purple Line subway runs within two miles of the project site; the Exposition Light Rail Transit (LRT) Line and Bike Path is under construction and will run approximately one mile south of the project site; and Metro has proposed the Crenshaw Transit Corridor project to provide either bus rapid transit (BRT) or LRT along a general north-south alignment within approximately one-half mile of the project site. The pass-by trip reductions were based on standard pass-by trip rates defined in the LADOT Traffic Study Policies and Procedures (Attachment “G” – LADOT Policy on Pass-by Trips), which are based on data published by the Institute of Transportation Engineers (ITE). More specifically, the trip reduction factors are, generally, the same for the same uses proposed in both Options A and B. However, Option B does not include rental live/work units or restaurant space, but includes a greater shopping center component (approximately 237,000 sf) than Option A (approximately 82,500 sf). Because of the relative sizes of the shopping center components proposed, it is expected that customers under Option B would be drawn from a larger region than those under Option A.