Loyola Marymount University Master Plan Project Final EIRJuly 2010

City of Los AngelesENV-2008-1342-EIR

Letter No. 1

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Loyola Marymount University Master Plan Project Final EIRJuly 2010

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II. List of Commenters and Responses to Comments

City of Los Angeles Loyola Marymount University Master Plan Project Final EIRENV-2008-1342-EIR July 2010

LETTER NO. 1

State of California, Department of Transportation

Division of Aeronautics

Response 1-1

The comment notes that LMU has a heliport on campus that operates in accordance with a state permit

issued by the California Department of Transportation (Caltrans), Division of Aeronautics (Division), and

requests that any development on campus that would result in a change in the heliport-operating permit

should be communicated to the Division. The commenter further states that any structure that exceeds

200 feet in height, or any other notification criteria of FAR Part 77, would require notification of the

Federal Aviation Administration (FAA). The final siting and height of specific Master Plan components

has not yet been determined; however, the proposed Specific Plan for the campus would limit buildings

on Hughes Campus, the location of the existing heliport, to the existing height limit of 139 feet above

mean sea level, which is the current approximate height of the residential neighborhood to the east of the

campus. The Specific Plan would also limit new buildings to a maximum of 75 feet above grade, with

lower height limits proposed for much of the campus. Please refer to Topical Response No. 5, Building

Heights, Building Setbacks, and Views, for a discussion of the height limits proposed for the campus.

Nonetheless, compliance with the regulatory guidelines cited by the commenter will be followed as

buildings and structures are sited and designed on LMU’s campus.

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Loyola Marymount University Master Plan Project Final EIRJuly 2010

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Letter No. 2

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II. List of Commenters and Responses to Comments

City of Los Angeles Loyola Marymount University Master Plan Project Final EIRENV-2008-1342-EIR July 2010

LETTER NO. 2

State of California

Governor's Office of Planning and Research

Response 2-1

The comment confirms receipt from the City of Los Angeles of the revised Notice of Completion (NOC)

extending the Draft EIR public review period until March 15, 2010. Since this comment is not directed at

the environmental analysis or conclusions contained in the Draft EIR, no further response is required.

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Loyola Marymount University Master Plan Project Final EIRJuly 2010

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Letter No. 3

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II. List of Commenters and Responses to Comments

City of Los Angeles Loyola Marymount University Master Plan Project Final EIRENV-2008-1342-EIR July 2010

LETTER NO. 3

State of California

Native American Heritage Commission

Response 3-1

The Draft EIR complies with the described provisions of CEQA, and adequately assesses whether the

Proposed Master Plan Project would have an adverse impact on archaeological resources within the

project area.

Response 3-2

In letters provided in May and June 2008 in response to consultation by the City of Los Angeles with the

Native American Heritage Commission, the Native American Heritage Commission concluded that the

Sacred Lands File did not contain information on any archaeological sites within the immediate project

area. These letters are included in Appendix I, Notice of Preparation (NOP)/Initial Study (IS)/Public

Comments on the Notice of Preparation (NOP)/Initial Study IS, of the Draft EIR. Therefore, this comment,

provided in January 2010 by the Native American Heritage Commission, stating that the Sacred Lands

File contains information on Native American cultural resources within 0.5 mile of the Proposed Project

area, is apparently based on a recent addition to that file. The Native American Heritage Commission

does not raise any issues in their January 2010 letter pertaining to the Proposed Project site, or

archaeological resources therein, that are not already disclosed and mitigated to a less than significant

level in the Draft EIR. The Native American Heritage Commission has been given, and responded to,

three opportunities to comment on the Draft EIR scope and the subsequent completed Draft EIR. A

Notice of Preparation (NOP) for the Draft EIR was sent to the Native American Heritage Commission in

May 2008 and they responded on May 30, 2008 and June 4, 2008. The Notice of Availability of the

completed Draft EIR, a Tribal Consultation Request, and a copy of the Draft EIR on CD was sent to the

Native American Heritage Commission in January 2010 and they responded with a comment letter on

January 26, 2010. Additionally, all of the Native American groups that the Native American Heritage

Commission recommended be contacted were notified of the availability of the Draft EIR in January 2010

(no comments were received).

As outlined in the Draft EIR, the South Central Coastal Information Center, located at California State

University Fullerton, has been contacted as part of Draft EIR preparation and a thorough record search

was conducted. This information, in addition to a detailed review and analysis of all major archaeological

work in the area, is presented in the Draft EIR.

The federal statutes listed by the Native American Heritage Commission are not applicable to the

Proposed Project, since it is not a federal undertaking.

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II. List of Commenters and Responses to Comments

City of Los Angeles Loyola Marymount University Master Plan Project Final EIRENV-2008-1342-EIR July 2010

Response 3-3

Potential Proposed Project impacts on archaeological resources on LMU’s campus, and mitigation

measures to reduce those impacts to a less than significant level, are discussed in Section IV.D.2,

Archaeological Resources, of the Draft EIR, and in the accompanying Archaeological Resource Inventory

and Impact Assessment Technical Report, provided in Appendix IV.D.1 of the Draft EIR. Mitigation

measure MM-ARCH-1 states that archaeological resources shall be avoided, and further states that, if

avoidance is not possible, disturbance shall be mitigated through data recovery, documentation, analysis,

and curation. Additional mitigation measures MM-ARCH-2 through MM-ARCH-12 define the protocols

to be followed during Proposed Project construction to determine the potential presence of archaeological

resources on a given site of proposed development on LMU’s campus, as well as procedures to be

followed for data recovery, documentation, analysis and curation of any resources discovered.

The proposed mitigation measures also provide for specific protocols if human remains are discovered

during work on campus, following Public Resources Code 5097.98 and Health and Safety Code 7050.5.

Response 3-4

The presence of a Native American cultural resource listed in the Native American Heritage Commission

Sacred Lands File within 0.5 mile of the project area does not raise any issues not already identified and

mitigated in the Draft EIR.

Response 3-5

The Draft EIR did not identify the presence of, or the probable likelihood, of Native American human

remains within the Proposed Project area (i.e., the LMU campus), as described in State CEQA Guidelines

15064.5(d). The proposed mitigations in the Draft EIR provide for specific protocols if human remains are

discovered during future work on campus, following Public Resources Code 5097.98 and Health and

Safety Code 7050.5.

As stated in the Archaeological Resource Inventory and Impact Assessment Technical Report, provided

in Appendix IV.D.1 of the Draft EIR, as specific Proposed Project components are finalized and

implemented, avoidance of soil areas with a higher likelihood of containing archaeological resources to

facilitate preservation in place shall be the preferred manner for the development of the campus.

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