The Lorenzo Project - LA City Planning · 2010. 12. 28. · Environmental Review Section City Hall...

Environmental Review Section

City Hall • 200 N. Spring Street, Room 750 • Los Angeles, CA 90012

SUPPLEMENTAL CEQA ANALYSIS OF REDUCED

DENSITY PROPOSAL SOUTHEAST LOS ANGELES COMMUNITY PLAN AREA

The Lorenzo Project

Case No. ENV-2006-9471-EIR SCH No. 2008061060

Council District No. 9 THIS DOCUMENT COMPRISES ANALYSIS AS REQUIRED UNDER THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT

Project Address: 2300 & 2327 South Flower Street

Original Project Description (not reflecting Reduced Density Proposal): The Project as originally proposed would have involved the development of a mixed-use project with a total of approximately 1,400 multi-family residential units (approximately 1,663,061 square feet of residential floor area) and ancillary common area and recreation amenities and proposed retail uses resulting in a total project floor area of approximately 1,762,531 square feet. The Project as originally proposed provided approximately 34,000 square feet of retail uses, including approximately 6,000 square feet of restaurant use. More specifically, the Project as originally proposed would have consisted of two structures, a six-story building on the eastern side of Flower Street (Site A) and a 44-story building directly across from it, on the western side of Flower Street (Site B). Site A would have contained approximately 34,000 square feet of retail uses and 919 multi-family units; Site B would have contained approximately 481 multi-family units. Parking for the Project as originally proposed would have consisted of approximately 3,204 spaces provided in three subterranean levels and one ground level located beneath Site A and five subterranean parking levels located beneath Site B.

Reduced Density Proposal: The Applicant’s Reduced Density Proposal (referred to herein as the Reduced Lorenzo Project) would not change the proposed height, unit count and retail square footage on Site A, but would reduce the proposed structure on Site B from 44 stories to 12 stories and from 481 multi-family units to 132 multi-family units. This Proposal would also result in a reduction in total project parking from 3,204 spaces to 2,447 spaces, which would be provided in two subterranean levels and one ground level located at Site A and four subterranean levels and one ground level located at Site B.

APPLICANT: Palmer/Flower Street Properties

December 2010

Lorenzo Project Table of Contents Supplemental CEQA Analysis of Reduced Density Proposal

TABLE OF CONTENTS

Sections

I. INTRODUCTION/SUMMARY

II. ENVIRONMENTAL IMPACT ANALYSIS

III. PREPARERS OF SUPPLEMENTAL CEQA ANALYSIS OF REDUCED DENSITY PROPOSAL

Exhibits

A UPDATED TRIP GENERATION CALCULATIONS – LORENZO PROJECT (KOA Corporation, November 9, 2010)

B UPDATED PARKING CALCULATIONS FOR REDUCED LORENZO PROJECT

C PREPARER CURRICULUM VITAE

Lorenzo Project I. Introduction/Summary Supplemental CEQA Analysis of Reduced Density Proposal Page I-1

I. INTRODUCTION/SUMMARY

PROJECT BACKGROUND AND CEQA

The Lorenzo Project (Draft EIR Project)

On June 11, 2008, the City issued a Notice of Preparation (NOP) for the proposed Lorenzo Project. The NOP described, and the EIR analyzed, a proposed project that would consist of two structures, a six-story building (approximately 75 feet in height) on the east side of Flower Street (Site A) and a 44-story building (approximately 527 feet in height) directly across from it, on the west side of Flower Street (Site B). Site A would contain approximately 34,000 square feet of retail and restaurant uses and 919 dwelling units; Site B would contain approximately 481 dwelling units. Parking for the Lorenzo Project would consist of approximately 3,204 spaces provided in three subterranean levels and one ground level located on Site A and five subterranean levels located beneath Site B. A pedestrian bridge over South Flower Street would connect the two buildings.

The Lorenzo Project would provide a total of approximately 50,000 square feet of recreational amenities including a pool/spa area, gym, indoor basketball court, as well as amenities such as a lounge, library, a study room with internet access and bookshelves, computer stations, virtual gaming, and business center/conference room uses. Approximately 200 bike racks would also be provided.

Additionally, it is expected that the Lorenzo Project would provide pedestrian access between the proposed commercial and residential uses and the proposed 23rd Street Station of the Expo light rail line currently being constructed on Flower Street directly in front of the Lorenzo Project. The design of the ground floor commercial space would provide functional connections for pedestrians, shoppers and residents to access the Lorenzo Project and the future transit station.

The project would include landscaped common areas and pedestrian walkways. All pedestrian areas, residential walkways, parking areas, and common areas would include lighting systems to enhance security on-site. Lighting would be designed to minimize light spillover onto surrounding properties.

The Lorenzo Project would be designed to meet the requirements of the City of Los Angeles’ Green Building Ordinance, which includes Leadership in Energy and Environmental Design (LEED) equivalency. The LEED Green Building Rating System was developed by the U.S. Green Building Council to provide standards for design, construction, and operation of environmentally-responsible buildings. The project is currently planning to install solar panels to provide power to heat the project’s swimming pool. Other specific energy-saving features to reach LEED equivalency will be determined as project planning and design continues.

Vehicle access to Site A would be via two access points on 23rd Street and one access point on Adams Boulevard at vacated Hope Street, to be shared with the Orthopaedic Hospital. Vehicle access to Site B would be via one access point on South Flower Street.

City of Los Angeles December 2010


The NOP for a draft EIR (the “Draft EIR”) was circulated for a 30-day review period starting on June 11, 2008, ending on July 11, 2008. Based on public comments in response to the NOP and a review of environmental issues by the City, the Draft EIR analyzed the following environmental impact areas:

• Aesthetics • Air Quality • Cultural Resources • Geology and Soils • Hazards and Hazardous Materials • Hydrology and Water Quality • Land Use and Planning • Noise • Population and Housing • Public Services • Traffic, Transportation and Parking • Utilities

On November 19, 2009, the City of Los Angeles (“City”) released the Draft EIR for public comment. The comment period was 45 calendar days, ending on January 4, 2010. The lead agency received 76 written comments on the Draft EIR from public agencies, groups and individuals. Responses to all comments received between November 19, 2009 and January 4, 2010 are included in the Final EIR. The City issued a Notice of Completion and Availability of the Final EIR on August 25, 2010.

The Reduced Lorenzo Project

On October 26, 2010, the applicant submitted a revised reduced project (the “Reduced Lorenzo Project”) to reduce the proposed 44-story tower on Site B to a 12-story structure with a maximum height of approximately 125 feet. The reduced 12-story structure would include 132 dwelling units. Under the Reduced Lorenzo Project, Site A would continue to be developed as proposed in the EIR, with a six-story building containing approximately 34,000 square feet of retail and restaurant uses and 919 dwelling units. Thus, the Reduced Lorenzo Project would result in a total dwelling unit count of 1,051, which represents a net reduction of 349 units across the project site. The total floor area on Site A would be approximately 1,260,068 square feet, which results in a Floor Area Ratio (“FAR”) for Site A of 3.22:1. The total floor area on Site B would be approximately 123,000 square feet, which results in an FAR for Site B of 6:1. The original Lorenzo Project analyzed in the Draft EIR would have had a combined FAR of 4.3:1 and included a pedestrian bridge over South Flower Street to connect the two proposed buildings and a Conditional Use Permit request to average the floor area across the entire project site. The Reduced Lorenzo Project would include neither a pedestrian bridge to connect the two buildings nor a Conditional Use Permit request to average floor area, and FAR for the Reduced Lorenzo Project has been calculated independently for Site A and Site B.

Parking for the Reduced Lorenzo Project would consist of approximately 2,447 spaces provided in two subterranean levels and one ground level located at Site A and four subterranean parking levels and one ground level located at Site B. Approximately 2,255 parking spaces would be provided in the Site A



parking structure, which would include 1,737 parking spaces for the 919 dwelling units located on Site A, 151 spaces for restaurant and retail uses, and 367 replacement parking spaces for the Orthopaedic Hospital. Approximately 192 parking spaces would be provided in the building on Site B for the 132 dwelling units located on Site B.

The Reduced Lorenzo Project would provide a total of approximately 140,650 square feet of recreational amenities including open space, a pool/spa area, gym, indoor basketball court, as well as amenities such as a lounge, library, a study room with internet access and bookshelves, computer stations, virtual gaming, and business center/conference room uses. Of this total, approximately 125,950 square feet of private and common open space would be provided at Site A, and approximately 14,700 square feet of private and common open space would be provided at Site B. In addition, approximately 200 bike racks would continue to be provided in the Reduced Lorenzo Project.

Additionally, the Reduced Lorenzo Project, like the Lorenzo Project, would provide pedestrian access between the proposed commercial and residential uses to the proposed 23rd Street Expo line station currently being constructed on Flower Street directly in front of the Project Site. The design of the ground floor commercial space would provide functional connections for pedestrians, shoppers and residents to access the Proposed Project and the future transit station.

The Reduced Lorenzo Project would include landscaped common areas and pedestrian walkways. All pedestrian areas, residential walkways, parking areas, and common areas would include lighting systems to enhance security on-site. Lighting would be designed to minimize light spillover onto surrounding properties.

The Reduced Lorenzo Project would also be designed to meet the requirements of the City of Los Angeles’ Green Building Ordinance, which includes Leadership in Energy and Environmental Design (LEED) equivalency, as under the Lorenzo I. The LEED Green Building Rating System was developed by the U.S. Green Building Council to provide standards for design, construction, and operation of environmentally-responsible buildings. The project is currently planning to install solar panels to provide power to heat the project’s swimming pool. Other specific energy-saving features to reach LEED equivalency will be determined as project planning and design continues.

Vehicle access under the Reduced Lorenzo Project would not change as compared to the Lorenzo Project. Vehicle access to Site A would be via two access points on 23rd Street and one access point on Adams Boulevard at vacated Hope Street, to be shared with the Orthopaedic Hospital. Vehicle access to Site B would be via one access point on South Flower Street.

The following pages of this section provide updated images and diagrams depicting the Reduced Lorenzo Project.



Revised Draft EIR Exhibit IV.B-1

Reduced Lorenzo Project Main Entrance



Revised Draft EIR Exhibit IV.B-2

Reduced Lorenzo Project Flower Street Elevation



Reduced Lorenzo Project Elevations



Reduced Lorenzo Project Second Floor Plan

Lorenzo Project II. Environmental Impact Analysis Supplemental CEQA Analysis of Reduced Density Proposal Page II-1

II. ENVIRONMENTAL IMPACT ANALYSIS

The purpose of this California Environmental Quality Act (CEQA) analysis is to address the potential environmental impacts of the proposed reductions to the Lorenzo Project by evaluating how those reductions affect the analysis in the Draft and Final EIRs. The Reduced Lorenzo Project, as described in Section I of this document, involves reductions in height and unit count to the Lorenzo Project’s proposed structure for Site B.

Section 15088.5 of the State CEQA Guidelines (Guidelines) requires a lead agency to recirculate an EIR when significant new information is added to the EIR after notice is given as to the availability of the Draft EIR for public review, but before certification. This section of the CEQA Guidelines provides that new information added to an EIR is not significant unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. Significant new information requiring recirculation includes, for example, a disclosure showing that:

• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;

• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;

• A feasible project alternative considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it;

• The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.

The analysis presented in this document demonstrates that no new significant environmental impacts have been identified as a result of the Reduced Lorenzo Project. In addition, the revised project does not substantially increase the severity of an environmental impact identified in Draft EIR for the Lorenzo Project. As such, recirculation of this analysis would not be required under the criteria listed in State CEQA Guidelines Section 15088.5.

SIGNIFICANT AND UNAVOIDABLE IMPACTS

The Draft EIR, dated June 2008, found that the original Lorenzo Project would result in significant impacts in the following categories:

• Aesthetics (Visual Character)



• Air Quality (Construction NOx, Operational VOC (Project and Cumulative), and Greenhouse Gas Emissions (Cumulative))

• Noise (Construction (Project and Cumulative))

• Public Services (Police)

Compared to the Lorenzo Project, the Reduced Lorenzo Project would not increase the severity of these identified impacts, as discussed below.

Aesthetics (Draft EIR § IV.B)

Environmental Analysis of Reduced Lorenzo Project

The original Lorenzo Project would have consisted of two structures: a six-story, 1,208,538-square-foot building located on Site A containing 919 multi-family residential units and ancillary common area and recreational amenities as well as commercial retail and restaurant uses and a 44-story, 553,993-square-foot building located on Site B containing 481 multi-family residential units and ancillary common area. The Draft EIR concluded that because the immediate surrounding buildings vary from one to six stories in height, with 10- and 13-story structures located within 0.35 and 0.3 miles of the site, respectively, development on Site A would be compatible and complementary to the visual character of the project area. However, the Draft EIR concluded that the 44-story building would represent the tallest building in the immediate project area, would present a substantial contrast between the surrounding uses and the proposed building, and would represent a substantial change with respect to massing in comparison to current site conditions that would be inconsistent with immediate surrounding uses. As such, the Draft EIR concluded that impacts related to the height and massing of the 44-story building would be significant and unavoidable.

The Reduced Lorenzo Project has revised the building on Site B by reducing the building’s height from 44 stories (approximately 527 feet above grade) to 12 stories (approximately 125 feet above grade), and reducing the building’s dwelling units from 481 units to 132 units. The height and unit count of the revised building would be over 70 percent smaller than the building analyzed in the Draft EIR.

A 12-story structure on Site B would be consistent with the height of structures in the vicinity of the project site, specifically with the 13-story LA Mart building located approximately 0.3 miles northeast of the project site and the 10-story Bob Hope Patriotic Hall located 0.35 miles north of the project site. The proposed structure would still be taller than the uses immediately surrounding the properties, which include the four-story residential building located on the west side of South Flower Street, a five-story hotel located on West Adams Boulevard just south of the project site, the six-story Orthopedic medical office building directly adjacent to the project site, and a six-story commercial building located on the corner of West Adams Boulevard and Grand Avenue just south of the project site.

The Draft EIR specifically evaluated a reduced density alternative (Alternative B) as part of the Draft



EIR’s Alternatives analysis (see Draft EIR § VI.B), the primary purpose of which was to address the significant and unavoidable visual character impacts that result from developing a 44-story structure on Site B. A 44-story structure would be more than three times taller than the tallest building in the vicinity of the project site, and as the Draft EIR concluded, the intensity and height of such a building would be inconsistent with immediate and surrounding uses. Alternative B in the Draft EIR evaluated a six-story building on Site B, which is the same height as the portion of the project proposed for Site A, and reflects the height of several nearby buildings. The Draft EIR concluded that the height and massing impacts of the six-story structure proposed in Alternative B would be less than significant.

However, and as discussed above, there are buildings that are taller than six stories in the surrounding project vicinity, including the LA Mart building and the Bob Hope Patriotic Hall. Accordingly, a building that is taller than six stories but substantially shorter than 44 stories could be consistent with the visual character of the surrounding neighborhood and could be found to have less-than-significant impacts with respect to height and massing.

The Applicant’s proposal to reduce the building height on Site B from 44 stories to 12 stories under the Reduced Lorenzo Project would be more compatible with the height and massing of existing uses and the surrounding neighborhood than the original Lorenzo Project. Unlike the Lorenzo Project, the Reduced Lorenzo Project would not create a significant contrast between the proposed features and existing features in the area that represent the area’s aesthetic image. Specifically, the height, scale, and mass of the Reduced Lorenzo Project would be more compatible with surrounding uses than the taller and more intense project evaluated in the Draft EIR, and would be generally consistent with the character of the surrounding community that includes 10- and 13-story structures. As a result, the Reduced Lorenzo Project would not result in a building that would detract from the existing style or image of the surrounding area due to density or height.

Thus, the considerable reductions to the height and scale of the building on Site B under the Reduced Lorenzo Project would result in a project that does not exceed the aesthetics thresholds related to height, scale and massing provided in the City’s CEQA Thresholds Guide and would serve to reduce potential impacts to visual character to a less than significant level. The Applicant’s concession to reduce building height to 12 stories on Site B also would promote the key purpose of Alternative B in the Draft EIR to reduce building height on Site B to a level that avoids significant visual character impacts.

With regard to other aesthetics impacts analyzed in the Draft EIR, the proposed changes in the Reduced Lorenzo Project would not change any of the EIR’s conclusions with respect to each of those impact areas. Impacts would remain less than significant, and in several areas (including views of and through the project site and shade and shadow) the substantially reduced height and massing of the Reduced Lorenzo Project would further reduce the already less-than-significant impacts. Impacts related to scenic resources, views of and toward the project site, signage, light, glare and shade and shadow would remain less than significant. Cumulative aesthetic impacts would also remain less than significant.



Level of Significance After Mitigation

All aesthetic mitigation measures set forth in the Draft EIR shall also be incorporated in the Mitigation Monitoring and Reporting Program (MMRP) for the Reduced Lorenzo Project.

With the implementation of mitigation measures B-1, B-2, B-3, and B-4 identified in the Draft EIR, potential impacts related to light, glare and signage would remain less than significant. Impacts of the Reduced Lorenzo Project related to views of and through the project site, shade and shadow and cumulative impacts would remain less than significant. The substantial reduction in height and massing of the Reduced Lorenzo Project would significantly reduce the contrast between the proposed project and the existing features in the area when compared to the original Lorenzo Project evaluated in the Draft EIR, and accordingly would make the project compatible with surrounding uses and consistent with the character of the immediate community. Accordingly, impacts of the Reduced Lorenzo Project related to visual character would be reduced to less-than-significant levels and no mitigation measures are required. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project in combination with the related projects would not result in a significant cumulative impact with regard to aesthetics.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the Reduced Lorenzo Project would not create new significant aesthetics impacts or result in a substantial increase in the severity of those impacts as previously identified in the Draft EIR for the Lorenzo Project. Therefore, recirculation of the EIR is not warranted.

Air Quality (Draft EIR § IV.C)


Construction of the Reduced Lorenzo Project would develop fewer residential units in a smaller structure on Site B compared to the Lorenzo Project, and would accordingly require fewer construction traffic trips that would result in slightly lower NOx emissions associated with those trips. However, the Reduced Lorenzo Project would use similar equipment for construction. Although the Reduced Lorenzo Project involves less floor area than the Lorenzo Project, this reduction in floor area would not result in a substantial reduction in construction intensity or duration. Therefore, the Draft EIR’s analysis for construction and operational air quality would not change considerably based on the Reduced Lorenzo Project.


All construction and operational air quality mitigation measures set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project.

Implementation of Mitigation Measure C-14 in the Draft EIR would slightly reduce regional air quality impacts associated with NOx emissions during project construction, however, emissions would continue to



exceed the SCQAMD threshold and would result in a significant and unavoidable impact. Operational emissions would exceed the established SCAQMD threshold levels for VOCs during both the summertime (smog season) and wintertime (non-smog season). The exceedance of the SCAQMD thresholds for VOCs is primarily due to the use of consumer products such as lighter fluid and hairspray within the residential uses. Currently there is no feasible mitigation available to reduce the use of consumer products associated with the Reduced Lorenzo Project. Therefore, this impact would be significant and unavoidable. The contribution of daily operational emissions of VOCs by the Reduced Lorenzo Project would also be cumulatively considerable. In addition, while the Reduced Lorenzo Project is an infill project that results in fewer emissions than a similar project in an outlying area and the project would not result in an unplanned level of development or a substantial new source of Greenhouse Gas (GHG) emissions, and implementation of Mitigation Measure C-10 in the Draft EIR would reduce GHG emissions associated with the Reduced Lorenzo Project to the extent feasible, any increased accumulation of GHGs in the atmosphere may result in adverse environmental effects. Accordingly, the Reduced Lorenzo Project would combine with the local related project to result in increased emissions of GHGs that would be cumulatively considerable.

All other potential project-level and cumulative air quality impacts evaluated in the Draft EIR would remain less than significant after mitigation.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant air quality impacts or result in a substantial increase in the severity of those impacts as previously identified. Therefore, recirculation of the EIR related to air quality impacts is not warranted.

Noise (Draft EIR § IV.I)


Construction of the Reduced Lorenzo Project would result in fewer residential units in a smaller structure on Site B compared to the Lorenzo Project evaluated in the Draft EIR, and would accordingly require fewer construction and operational traffic trips, but would use similar equipment for construction. Although the Reduced Lorenzo Project involves less floor area than the Lorenzo Project, this reduction in floor area would not result in a substantial reduction in construction intensity or duration, or in operational noise. Therefore, the Draft EIR’s analysis of construction and operational noise would not change based on the Reduced Lorenzo Project.


All construction and operational noise mitigation measures set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. While Mitigation Measures I-1 through I-10 would reduce construction-related noise impacts to the greatest extent feasible, construction noise impacts would remain significant and unavoidable. Due to the close proximity of the project site to



Related Project No. 12, which is just north of the project site across West 23rd Street, a potentially significant cumulative impact associated with temporary or periodic increase in ambient noise levels could occur if construction of the Reduced Lorenzo Project and Related Project No. 12 occur at the same time. Although it is unknown whether construction would overlap at these development sites, this analysis conservatively assumes this potential scenario and concludes that cumulative noise impacts from construction could be potentially significant. Implementation of Mitigation Measures I-11 and I-3 would continue to reduce vibration impacts associated with the proposed project to less than significant levels. Implementation of Mitigation Measures I-13 to I-15 would continue to ensure that the project’s operational noise impacts would be less than significant. Consistent with the Draft EIR’s analysis roadway noise impacts due to cumulative traffic volumes would remain less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant noise impacts or result in a substantial increase in the severity of those impacts as previously identified in the Draft EIR. Therefore, recirculation of the EIR is not warranted.

Public Services – Police Protection (Draft EIR § IV.K.2)


The Draft EIR found that the Lorenzo Project would result in a significant and unavoidable impact to police services because the project would potentially increase response times, and decrease the officer-to-civilian ratio. With the population increase caused by the Lorenzo Project, eight additional police officers would be required in order to maintain the current officer-to-civilian ratio in the Newton Area.1 This may result in the need for new or physically altered police protection facilities in order to maintain acceptable service ratios. Although any potential new or expanding police stations would be subject to CEQA, their construction could cause significant environmental impacts. While the Los Angeles Police Department (LAPD) has not stated whether a new or expanded police station would be needed as a result of the Lorenzo Project, LAPD has indicated that the Lorenzo Project would have a significant impact on police services in the Newton Area. Thus, the Draft EIR concluded that impacts on police services would be significant and unavoidable.

The Reduced Lorenzo Project would construct fewer residential units and generate fewer residents than the Lorenzo Project evaluated in the Draft EIR and by LAPD. The reduction in residential units from

1 As provided in the Draft EIR, the project site is served by the Newton Community Police Station, and the Newton Area has a population of approximately 169,527 and encompasses 9.78 square miles and is roughly defined by the following boundaries: 7th Street and Washington Boulevard to the north, Florence Avenue to the south, Alameda Street to the east, and the Harbor Freeway (I-110 Freeway) to the west. (Draft EIR, p. IV.K-11.) There are approximately 312 sworn officers and 21 civilian support staff deployed throughout the Newton Area, which represents an officer to population ratio of approximately one officer to every 509 residents. (Id.)



1,400 units under the Lorenzo Project to 1,051 units proposed under the Reduced Lorenzo Project would result in a reduction of the on-site residential population from 4,154 residents to 3,118 residents. The 76 employee population would remain the same. The Reduced Lorenzo Project would therefore introduce approximately 3,194 individuals to the project site. In order to maintain the current officer-to-population ratio in the Newton Area (1:509), approximately six additional police officers would be needed to maintain the ratio under the Reduced Lorenzo Project. Thus, while the Reduced Lorenzo Project could require two fewer police officers to maintain current ratios than the Lorenzo Project evaluated in the Draft EIR, it would still be an increase above existing conditions. In addition, like the Lorenzo Project, the Reduced Lorenzo Project would potentially increase response times.

Therefore, while the development of the project site would achieve the benefit of eliminating a vacant site that could be a potential venue for crime to occur and thus be a demand on police services, as the Draft EIR concluded adding residents to the project site could also result in additional demand on police services. While reducing the residential population on Site B under the Reduced Lorenzo Project would reduce the demand on police services, it does not fully eliminate the potential impact to police services that would result from a population increase on the site. Accordingly, the Reduced Lorenzo Project does not change the Draft EIR’s conclusion that development of the project may result in the need for additional police officers that may result in the need to construct new police stations that could cause a significant environmental impact. As a result, while the mitigation measures identified in the Draft EIR would continue to be implemented to minimize the potential impacts of the Reduced Lorenzo Project on police protection services to the maximum extent feasible, the impacts would remain significant and unavoidable.


All police services mitigation measures set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project.

Implementation of Mitigation Measures K-2 to K-5 in the Draft EIR would reduce the Reduced Lorenzo Project’s impacts on police services to the maximum extent feasible, and cumulative impacts would remain less than significant. Nevertheless, the Reduced Lorenzo Project would potentially increase response times and decrease the officer-to-civilian ratio. Six additional police officers would be required in order to maintain the current officer-to-civilian ratio in the Newton Area, which could result in the need for new or physically altered police protection facilities in order to maintain acceptable service ratios. Although any potential new or expanding police stations would be subject to CEQA review, their construction could cause significant environmental impacts. Therefore, potential impacts of the Reduced Lorenzo Project on police services would remain significant and unavoidable.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant police protection impacts or result in a



substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

LESS-THAN-SIGNIFICANT IMPACTS

Furthermore, the Draft EIR found that the Lorenzo Project would result in less-than-significant impacts, with or without mitigation, in the following categories:

• Cultural Resources

• Geology and Soils

• Hazards and Hazardous Materials

• Hydrology and Water Quality

• Land Use and Planning

• Population and Housing

• Public Services (except Police Services)

• Traffic, Transportation and Parking

• Utilities

The Reduced Lorenzo Project would not increase the severity of these identified impacts, or result in any new significant impacts, as discussed below.

Cultural Resources (Draft EIR § IV.D)


The Reduced Lorenzo Project would involve the same demolition and excavation activities as the Lorenzo Project as analyzed in the Draft EIR. The Reduced Lorenzo Project would be required to implement the same mitigation measures as the Lorenzo Project to reduce potential impacts to historical, archaeological, and paleontological resources and human remains that are currently unknown but may be encountered during project construction to less than significant levels.


The Reduced Lorenzo Project would continue to have a less-than-significant impact to historical resources, and as explained in the Draft EIR, no mitigation is required. All mitigation measures set forth in the Draft EIR regarding archaeological and paleontological resources and human remains shall also be incorporated in the MMRP for the Reduced Lorenzo Project. With the implementation of those measures, the Reduced Lorenzo Project would continue to have a less-than-significant impact with respect to archaeological and paleontological resources, as well as human remains. Consistent with the Draft EIR’s analysis, if subsurface cultural resources are protected upon discovery as required by law, impacts to



those resources would be cumulatively less than significant and would not be cumulatively considerable.

With regard to the criteria set forth in CEQA Guidelines 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant cultural resource impacts or result in a substantial increase in the severity of those effects as previously identified. Impacts from the Reduced Lorenzo Project would remain the same as the Lorenzo Project and would remain less than significant. Therefore, recirculation of the EIR is not warranted.

Geology and Soils (Draft EIR § IV.E)


The Reduced Lorenzo Project would construct a reduced number of residential units on the same project site compared to the Lorenzo Project analyzed in the Draft EIR. However, the project site and its geological setting would not change, and thus the Reduced Lorenzo Project would not change the Draft EIR’s analysis with respect to geology and soils. The Reduced Lorenzo Project would be required to implement Mitigation Measure E-1 from the Draft EIR, which would ensure that the project would comply with applicable grading and building permit requirements, Best Management Practices (“BMPs”), and would comply with the recommendations of the Geotechnical Report contained in Draft EIR Appendix C. With the implementation of this measure, the Reduced Lorenzo Project’s impacts with regard to geology and soils would be less than significant.


The geology and soils mitigation measure set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. The implementation of this measure would ensure that project impacts related to geology and soils would be less than significant. Consistent with the Draft EIR’s analysis, no cumulatively considerable geological impacts are anticipated.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant geology and soils impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, the recirculation of the EIR is not warranted.

Hazards and Hazardous Materials (Draft EIR § IV.F)


The Reduced Lorenzo Project would be constructed on the same project site, would involve the same uses as the Lorenzo Project analyzed in the Draft EIR and would not involve the routine transport, use, or disposal of substantial amounts of hazardous materials. Therefore, the Draft EIR’s analysis of the Lorenzo Project’s potential hazards and hazardous materials impacts would not change based on the



Reduced Lorenzo Project. The Reduced Lorenzo Project would be required to implement the same mitigation measures provided in the Draft EIR for the Lorenzo Project to reduce potential impacts to less than significant levels.


The hazards and hazardous materials mitigation measures set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. With implementation of Mitigation Measures F-1 through F-6 as identified in the Draft EIR, impacts with respect to hazards and hazardous materials would be less than significant. Consistent with the Draft EIR’s analysis, potential cumulative impacts pertaining to hazards and hazardous materials would be less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant hazards or hazardous materials impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Hydrology and Water Quality (Draft EIR § IV.G)


The Reduced Lorenzo Project’s construction activities, including excavation and grading would be generally the same as the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis of the Lorenzo Project’s potential impacts to hydrology and water quality would not change based on the Reduced Lorenzo Project. The Reduced Lorenzo Project would be required to implement the same mitigation measures as the Lorenzo Project to reduce potential construction and operational impacts to hydrology and water quality to less than significant levels.


Mitigation Measures G-1 through G-3 set forth in the Draft EIR shall be incorporated in the MMRP for the Reduced Lorenzo Project and implementation of those measures would ensure that the Reduced Lorenzo Project’s potential impacts related to hydrology and water quality would be less than significant. Consistent with the Draft EIR’s analysis, the Reduced Lorenzo Project would not contribute to a significant cumulative impact, and therefore potential cumulative impacts pertaining to hydrology and water quality would not occur.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant hydrology or water quality impacts or result in a substantial increase in the severity of those impacts as previously identified. Therefore, recirculation of the EIR is not warranted.



Land Use Planning (Draft EIR § IV.H)


The Reduced Lorenzo Project’s potential impacts to land use would be similar to those of the Lorenzo Project analyzed in the Draft EIR. The Reduced Lorenzo Project would reduce the Lorenzo Project’s 4.3:1 FAR across both sites to 3.36:1 (providing a 3.22:1 FAR on Site A and a 6:1 FAR on Site B), and would contain approximately 1,051 residential units, 349 fewer than the Lorenzo Project. Unlike the Lorenzo Project analyzed in the Draft EIR, the Reduced Lorenzo Project would not include a Conditional Use Permit request to average floor area across both sites and would not contain a pedestrian bridge to connect the two buildings on Site A and Site B.

The Reduced Lorenzo Project’s height on Site B would be 12 stories and approximately 125 feet tall, reduced by 32 stories and approximately 402 feet in height compared to the Lorenzo Project. The Reduced Lorenzo Project would provide approximately 2,447 parking spaces, which would meet Los Angeles Municipal Code requirements. Approximately 2,255 parking spaces would be provided on Site A in two subterranean levels (a reduction from three subterranean levels originally proposed for the Lorenzo Project) and one ground level, and approximately 192 parking spaces would be provided on Site B in four subterranean levels (a reduction from five subterranean levels originally proposed for the Lorenzo Project) and one ground level. The Draft EIR concluded that Lorenzo Project would be consistent with a large majority of the applicable plans, goals, objectives and policies of the related plans, and that potential impacts to land use would be less than significant.

The Draft EIR concluded that the original, larger 1,400-unit Lorenzo Project would be inconsistent with Southeast Los Angeles Community Plan Policy 1-6.4 to “Require that any proposed development be designed to enhance and be compatible with adjacent development” because while the Lorenzo Project would be generally consistent with the architectural style of the surrounding area, the proposed 44-story tower on Site B would be largely out of scale with the surrounding uses.

The Reduced Lorenzo Project would reduce the height of the proposed structure on Site B to 12 stories rather than 44. A 12-story structure on Site B would be more consistent with the height of structures in the vicinity of the project site, specifically with the 13-story LA Mart building located approximately 0.3 miles northeast of the project site and the 10-story Bob Hope Patriotic Hall located 0.35 miles north of the project site. Thus, and as discussed in the Aesthetics analysis above, overall the Reduced Lorenzo Project would be more compatible with the height and massing of existing uses and the surrounding neighborhood than the original Lorenzo Project. This would reduce the visual character impact associated with height and massing to a less than significant level. Based on these substantial reductions in height and size of the structure on Site B, the Reduced Lorenzo Project would be consistent with Policy 1-6.4.

The original Lorenzo Project included a pedestrian bridge linking the buildings on Site A with Site B, which the Reduced Lorenzo Project does not include. The Draft EIR concludes that the original Lorenzo



Project would be consistent with Southeast Los Angeles Community Plan Policy 2-4.9 to: “Require that mixed use projects, where residential and commercial uses are in separate structures, provide adequate access between the residential and commercial uses so that residents can walk conveniently and safely,” partly due to the inclusion of the bridge linking Sites A and B. The Reduced Lorenzo Project would not include the bridge but would remain consistent with this policy due to the existing crosswalk on West 23rd Street crossing South Flower Street linking the two sites, as well as the fact that most of the residences in the Reduced Lorenzo Project will be in the same building as the commercial uses.

The Draft EIR also concluded that the original Lorenzo Project would be inconsistent with Southeast Los Angeles Community Plan Policy 5-1.3 to: “Require development in major opportunity sites to provide public open space.” Like the Lorenzo Project, the Reduced Lorenzo Project proposes open space for project residents, but would not provide public open space. For this reason, the Reduced Lorenzo Project would continue to be inconsistent with Policy 5-1.3

In addition, the Draft EIR provided a list of discretionary approvals that would be required to develop the Lorenzo Project. Although not required as mitigation under CEQA, the Draft EIR explained that if the Lorenzo Project were to be developed as proposed without obtaining the discretionary approvals, the development would be inconsistent with the land use plans, policies and zoning affecting all or a portion of the project site. Since the Lorenzo Project could not be developed as proposed without obtaining the listed discretionary approvals, obtaining those approvals would ensure that the Lorenzo Project is consistent with applicable land use plans, policies and zoning. As a result of the changes and reductions in the Reduced Lorenzo Project, the list of discretionary approvals provided in the Draft EIR has changed. In order to develop the Reduced Lorenzo Project, the following discretionary approvals would be needed to ensure that the Reduced Lorenzo Project is consistent with land use plans, policies and zoning:

• Pursuant to Section 11.5.6 of the Los Angeles Municipal Code, a General Plan Amendment to the Southeast Los Angeles Community Plan to amend Footnote Number 1 to specifically exclude the project site from the Height District 1 (1.5:1 Floor Area Ratio) limitation imposed by Footnote Number 1 in order to permit the site to be developed consistent with the existing Height District 2 (6:1 Floor Area Ratio) Zone designation.

• Pursuant to Section 12.32 of the Los Angeles Municipal Code, a Zone/Height District Change from [Q]C2-2-O (Commercial Zone with conditions that restricted the site to educational, hospital, medical office, parking and related uses), to C2-2-O, to permit all uses allowed in the C2 (Commercial) Zone.

• Pursuant to Section 12.24.W.1 of the Los Angeles Municipal Code, a Conditional Use Permit to permit the sale and dispensing of a full line of alcoholic beverages off-site in conjunction with a market or drugstore use and sale and dispensing of a full line of alcoholic beverages for consumption on-site in conjunction with a restaurant use.



• Pursuant to Section 12.24.Y of the Los Angeles Municipal Code, a Determination to permit a 10% reduction in the number of commercial-parking spaces by Finding that the commercial building is located on a lot not more than 1,500 feet distant from the portal of a fixed rail transit station, or bus station, or other similar facility.

• Pursuant to Section 16.05 of the Los Angeles Municipal Code, Site Plan Review for a project which creates, or results in an increase, of 50 or more dwelling units.

• Pursuant to Section 12.22.A.25 of the Los Angeles Municipal Code, in consideration of restricting 5% of the dwelling units for Very Low Income Housing, permitting the utilization of Parking Option Number 1 which permits a reduction in the otherwise required parking for residential units of a Housing Development Project.

• Haul route review.

• Pursuant to Section 11.5.6 of the Los Angeles Municipal Code, General Plan Amendment(s) necessary to permit the development of the Reduced Lorenzo Project on Site B as proposed in Section I of this analysis (132 residential dwelling units, in a 12-story structure with a maximum height of approximately 125 feet and 6:1 Floor Area Ratio).

• Community Redevelopment Agency (CRA) Plan consistency review and Community Redevelopment Plan approval(s) to allow on the project site commercial and residential uses in order to permit the site to be developed consistent with the existing C2-2-O zoning designation.

• Pursuant to Section 21082.1(c)(3) of the California Public Resources Code, certification of an Environmental Impact Report and Adoption of a proposed mitigation monitoring program, required findings and the Statement of Overriding Considerations for the adoption of the EIR.

• All other approvals as necessary to permit the development of the Reduced Lorenzo Project as described in Section I of this analysis.

This revised list of discretionary approvals removes certain approvals listed in the Draft EIR that are no longer needed due to the substantial reductions in height, density and residential population in the Reduced Lorenzo Project as compared to the Lorenzo Project analyzed in the Draft EIR. In addition, the revised list clarifies several of the approvals that would be needed to develop the Reduced Lorenzo Project, and provides only those approvals that would be needed to develop a smaller project that has greater consistency with applicable land use plans and policies than the project described in the Draft EIR and reviewed by the public. The Lorenzo Project analyzed in the Draft EIR was substantially denser and taller than the Reduced Lorenzo Project and would have contained 349 more residential units. Thus, the Draft EIR provided the public with the opportunity to review and comment on a larger project with potentially greater inconsistencies with land use planning than the Reduced Lorenzo Project that is now being proposed.



Among the list of discretionary approvals discussed in the Draft EIR, the Draft EIR notes that Community Redevelopment Agency (CRA) Plan consistency review would be required. As discussed in the Draft EIR, the project site is located within the CRA’s Council District 9 Redevelopment Project area, and is therefore subject to CRA approval. As part of the CRA’s consistency review, it would need to address the Redevelopment Plan’s erroneous designation of Site A as “Open Space; Public & Quasi-Public.” This designation reflects the Southeast Los Angeles Community Plan’s prior erroneous designation of this site as Public/Quasi-Public Open Space and erroneous zoning of Public Facility (PF-1), which were incorrectly applied to the site despite its private uses. The Plan also designates Site B as Industrial, which is inconsistent with its commercial zoning designation. As discussed in the Draft EIR, in August 2002 the City Council adopted Ordinance No. 174772 to correct the Site A’s erroneous zoning designation to a qualified commercial zone. It also changed the Community Plan’s land use designation for Site A from Public Facility to Community Commercial. Despite these corrections, the CRA’s Redevelopment Plan has not been corrected to conform to Site A’s current zoning and Community Plan designations, or to Site B’s current zoning, both of which allow private commercial uses. To correct these errors and to provide for a consistent designation across the project site, approval of the project by the CRA may require a Redevelopment Plan approval to allow on the project site commercial and residential uses. This approval would ensure Redevelopment Plan consistency with the underlying C2 Commercial zone applicable to both Sites A and B and with the proposed amendments to the Community Plan Land Use Map. With this approval, the Reduced Lorenzo Project would be consistent with the Redevelopment Plan, and therefore impacts would be less than significant.

In addition to the Applicant’s request to amend the Southeast Los Angeles Community Plan to exempt the project site from Footnote 1/Height District 1 to be consistent with the site’s underlying zoning that provides for Height District 2 and a maximum FAR of 6:1, the Community Plan contains other density limitations for commercially designated properties which, if not amended, could restrict the utilization of the 6:1 FAR limitation allowed by the underlying C2-2-O zoning designation on Site B. Any such limitations would be inconsistent with the property’s underlying zoning that provides for Height District 2, uses allowed in the C2 zone, and the Applicant’s requests to provide for uniform land use and zoning designations across the project site. As discussed in the Draft EIR, the allowance for Height District 2 reflects a vision to intensify the residential development on the subject property to provide new residential housing units needed to meet the City’s growing population in addition to being strategically located near transit opportunities. Accordingly, providing for Height District 2 and a maximum FAR of 6:1 on Site B fulfills an important City goal set forth in the Framework Element. With the approval of any such Community Plan amendment, the Reduced Lorenzo Project would be consistent with the Community Plan, and therefore impacts would be less than significant.

The remaining analysis in the Draft EIR concerning potential impacts to land use planning would not change based on the Reduced Lorenzo Project and land use planning impacts would remain less than significant.




As with the original Lorenzo Project, the Reduced Lorenzo Project would be consistent with the substantial majority of the applicable goals, objectives, and policies of the related plans described in the Draft EIR. Therefore, impacts related to land use planning would be less than significant and no mitigation is required. Consistent with the analysis in the Draft EIR, potential cumulative impacts to land use planning would remain less than significant with the Reduced Lorenzo Project.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the Reduced Lorenzo Project would not result in any new significant land use impacts or result in a substantial increase in the severity of those impacts as previously identified. Further, the clarifications and modifications contained in the land use analysis for the Reduced Lorenzo Project are insignificant and necessary to clarify and elaborate upon certain aspects of the analysis contained in the Draft EIR. These clarifications and modifications do not add significant new information to the Draft EIR, as they would permit the development of a reduced project with fewer significant unavoidable impacts compared to the Lorenzo Project evaluated in the Draft EIR released for public review, and thus public review and comment were not precluded. Therefore, recirculation of the EIR is not warranted.

Population and Housing (Draft EIR § IV.J)


The Reduced Lorenzo Project would construct fewer residential units and therefore would generate fewer residents on-site compared to the Lorenzo Project analyzed in the Draft EIR. The reduction in residential units from 1,400 units under the Lorenzo Project to 1,051 units under the Reduced Lorenzo Project would result in a reduction of the on-site residential population from 4,154 residents to 3,118 residents. Employment would be the same under either project scenario, and thus the Draft EIR’s analysis of employment would be the same for the Reduced Lorenzo Project. Although like the Lorenzo Project, the Reduced Lorenzo Project would exceed housing and population projections for Census Tract 2240.20, which contains the project site, it would be consistent with projections for the immediate project area as well as the City. As explained in Response to Comment Ross-175 in the Final EIR, determining ways to accommodate a housing demand within a larger area (such as at the community and city level) is not best assessed by focusing on the ability to accommodate that demand on individual census tracts. Developing housing on a Census tract in excess of what has previously been considered for that tract to meet a demand for housing that occurs within an area beyond the boundaries of the Census tract does not necessarily constitute “unplanned growth,” as is the case with the Reduced Lorenzo Project. The Southern California Association of Governments forecasts 98,168 persons and 27,943 households in the immediate one-mile radius around the project site by the year 2020. While the Lorenzo Project analyzed in the Draft EIR would have accounted for 34 percent of the projected area population growth and 30 percent of the projected area housing growth from 2000 to 2020, the Draft EIR concluded that this growth would be within area growth projections and City-wide growth projections and therefore appropriately concluded that the Lorenzo Project would have a less-than-significant impact on housing and population. The Reduced Lorenzo Project’s 3,118 residents and 1,051 units would account for smaller percentages of



area and City-wide growth projections during the same period (approximately 25 percent of the projected area population growth and approximately 23 percent of the projected area housing growth), and therefore would have smaller potential impacts to population and housing than the Lorenzo Project that would also be less than significant.

Since employment in the Reduced Lorenzo Project would be the same as the Lorenzo Project analyzed in the Draft EIR and population and housing would be smaller, consistent with the Draft EIR’s conclusion that the Lorenzo Project would not have cumulative impacts to those areas, the Reduced Lorenzo Project’s potential cumulative impacts with respect to employment, population and housing would be less than significant.


Impacts related to population and housing would be less than significant and no mitigation is required. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project’s and the related projects’ potential cumulative impacts with respect to employment, population and housing would be less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant population or housing impacts or result in a substantial increase in the severity of those impacts as previously identified. Therefore, recirculation of the EIR is not warranted.

Public Services – Fire Protection (Draft EIR § IV.K.1)


The Reduced Lorenzo Project would construct fewer residential units and generate fewer residents on-site than the Lorenzo Project analyzed in the Draft EIR. As discussed in the Draft EIR, the Water Operations Division of LADWP would perform a fire flow study during the permitting process in order to ascertain whether water system or site-specific improvements would be necessary. Although no improvements to the existing water system that serves the project site are anticipated, any such improvements would be designed based on LADWP and statutory standards that account for LAFD fire flow and pressure requirements. This impact would be mitigated to a less than significant level with implementation of Mitigation Measure K-1, which requires the Project Applicant to upgrade water infrastructure in the project vicinity sufficiently to serve the project.


Mitigation Measure K-1 set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project, and implementation of this measure would ensure that the Reduced Lorenzo Project would have less than a significant impact related to fire protection. Consistent with the analysis in



the Draft EIR, the Reduced Lorenzo Project would not contribute to a cumulatively considerable incremental effect on fire protection services and thus cumulative impacts to fire protection services would remain less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant fire protection impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Public Services – Schools (Draft EIR § IV.K.3)


The Reduced Lorenzo Project would generate fewer students than the Lorenzo Project analyzed in the Draft EIR as fewer residential units are proposed. Therefore, the Draft EIR analysis regarding potential school impacts would not change based on the Reduced Lorenzo Project and with the payment of required school fees pursuant to SB 50, all potential impacts would be fully mitigated to a less than significant level. Similarly, the payment of mandatory school fees pursuant to SB 50 would reduce potential cumulative impacts upon school services to a less than significant level.


Impacts to schools would be less than significant for the Reduced Lorenzo Project with the payment of school fees pursuant to SB 50, and all potential project-level and cumulative impacts would be fully mitigated.

With regard to the criteria set forth in CEQA Guidelines Section 15588.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant school impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Public Services – Parks and Recreation (Draft EIR § IV.K.4)


Like the Lorenzo Project analyzed in the Draft EIR, the Reduced Lorenzo Project would provide open space in an amount that exceeds Los Angeles Municipal Code (“LAMC”) requirements. Specifically, the Reduced Lorenzo Project would provide approximately 140,650 square feet of open space (approximately 125,950 square feet of private and common open space would be provided at Site A, and approximately 14,700 square feet of private and common open space would be provided at Site B). The open space provided exceeds the required amount of open space pursuant to the LAMC by approximately 6,350 square feet. Therefore, the Draft EIR’s analysis for public services-parks and recreation would not



change based on the Reduced Lorenzo Project and impacts related to parks and recreation would remain less than significant. The Reduced Lorenzo Project would also be required to comply with all parks and recreation fee requirements.


The Reduced Lorenzo Project would have less-than-significant impacts on parks and recreation and no mitigation measures are recommended. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project would provide more than the required on-site open space and would not contribute to potential cumulative impacts on parks and recreation generated by the related projects.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5 (a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant parks and recreation impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Public Services – Libraries (Draft EIR § IV.K.5)


The Reduced Lorenzo Project would construct fewer residential units and generate fewer residents on-site than the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis of public services-libraries would not change based on the Reduced Lorenzo Project. With the payment of mitigation fees required by Mitigation Measure K-6 in the Draft EIR, the Reduced Lorenzo Project’s potential impacts to library facilities would be reduced to less than significant levels.


The public services-libraries mitigation measure set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. Impacts to library services would be less than significant for the Reduced Lorenzo Project with implementation of Mitigation Measure K-6. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project would provide Los Angeles Public Library recommended per capita mitigation fees and would not significantly contribute to potential cumulative impacts on library services generated by the related projects.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant library impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.



Traffic, Transportation, and Parking (Draft EIR § IV.L)


The Reduced Lorenzo Project would provide 349 fewer residential units than the Lorenzo Project analyzed in the Draft EIR. The Draft EIR concluded that with the incorporation of required mitigation measures, potential traffic and transportation impacts would be reduced to less than significant levels. The Final EIR included in Section III (Responses to Comments) an updated traffic analysis to address public comments that raised potential concerns about the Draft EIR’s analysis, which also concluded that no new significant impacts beyond what was identified in the Draft EIR would occur. Since the Reduced Lorenzo Project would contain fewer residential units, and thus would generate fewer traffic trips than the Lorenzo Project, a revised trip generation table has been prepared by KOA, dated November 9, 2010, and is attached as Exhibit A to this analysis. As demonstrated in the revised table from KOA, no new significant impacts beyond what was identified in the Draft EIR would occur based on the Reduced Lorenzo Project.2 Thus, the Draft EIR’s conclusions with regard to potential traffic impacts would not change with the Reduced Lorenzo Project and with implementation of the required mitigation measures, impacts would remain less than significant.

Due to the reduction in residential uses in the Reduced Lorenzo Project, parking spaces would also be reduced from the number of spaces identified in the Draft EIR for the larger Lorenzo Project. The Reduced Lorenzo Project would provide a total of approximately 2,447 spaces. Approximately 2,255 parking spaces would be provided on Site A in two subterranean levels (a reduction from three subterranean levels originally proposed for the Lorenzo Project) and one ground level, which would include 1,737 parking spaces for the 919 residential units located on Site A, 151 spaces for restaurant and retail uses, and 367 replacement parking spaces for the Orthopedic Hospital. Approximately 192 parking spaces would be provided on Site B in four subterranean levels (a reduction from five subterranean levels originally proposed for the Lorenzo Project) and one ground level, which would provide parking for the 132 residential units located on Site B. As demonstrated in the table attached as Exhibit B, the Reduced Lorenzo Project’s parking would meet Los Angeles Municipal Code requirements, and impacts would remain less than significant.

2 For purposes of analyzing traffic impacts, the Draft EIR conservatively assumed a project of 100 more dwelling units and 6,000 square feet of additional commercial floor area than what was contained in the original Lorenzo Project proposed by the Applicant. In its November 9, 2010, Technical Memorandum, KOA analyzed the trip generation difference between the Reduced Lorenzo Project and the conservative traffic analysis contained in the Draft EIR and does not specifically break-out the trip reductions that would already occur as a result of the reductions to residential units and commercial floor area in the Lorenzo Project proposed by the Applicant.. Accordingly, the trip generation difference shown in the KOA memorandum accounts for both the reductions to residential units and commercial floor area resulting from the proposed Lorenzo Project, as well as the additional reductions to residential units on Site B resulting from the Reduced Lorenzo Project.




The Reduced Lorenzo Project would have a less-than-significant impact on traffic and transportation after implementation of Mitigation Measures L-1 through L-4. These mitigation measures shall also be incorporated in the MMRP for the Reduced Lorenzo Project. Parking impacts for the Reduced Lorenzo Project would remain less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by The Current Project would not result in any new significant traffic, transportation, and parking impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Utilities – Sewer (Draft EIR § IV.M.1)


The Reduced Lorenzo Project would contain fewer residential units and would therefore generate less wastewater than the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis for utilities-wastewater would not change based on the Reduced Lorenzo Project. The Reduced Lorenzo Project would be required to implement the same mitigation measures as the Lorenzo Project to reduce potential impacts to wastewater conveyance infrastructure to less than significant levels. All other utilities-wastewater impacts would remain less than significant consistent with the analysis in the Draft EIR.


Mitigation Measure M-1 set forth in the Draft EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. With implementation of Mitigation Measure M-1, the Reduced Lorenzo Project would have less than a significant impact on wastewater conveyance infrastructure. Impacts to wastewater treatment facilities would remain less than significant. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project’s and the related projects potential cumulative impacts to wastewater treatment capacity and wastewater treatment facilities would be less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant wastewater impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.



Utilities – Water (Draft EIR § IV.M.2.)


The Reduced Lorenzo Project would contain fewer residential units and would therefore consume less water than the Lorenzo Project analyzed in the Draft EIR. As with the Lorenzo Project, with the approval of the Reduced Lorenzo Project’s discretionary requests the project would be consistent with applicable land use and zoning designations, and with the incorporation of water conservation measures required by the Los Angeles Department of Water and Power (“LADWP”), the Reduced Lorenzo Project would not consume water in excess of water supplies available to the City of Los Angeles. The Reduced Lorenzo Project would implement Mitigation Measures M-2 through M-13 as set forth in the MMRP in the Final EIR in order to reduce water consumption. Therefore, the EIR’s analysis for water supplies would not change based on the Reduced Lorenzo Project and impacts would remain less than significant.

Because the Reduced Lorenzo Project would consume less water than the Lorenzo Project analyzed in the Draft EIR, the Draft EIR’s analysis of water infrastructure, water treatment, fire flow and cumulative impacts would not change for the Reduced Lorenzo Project. The Reduced Lorenzo Project would be required to implement the same mitigation measures as the Lorenzo Project to reduce potential impacts to water infrastructure and fire flow to less than significant levels. All other utilities-water impacts would remain less than significant consistent with the analysis in the Draft EIR.


All water services mitigation measures set forth in the MMRP in the Final EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. With the implementation of those measures, the Reduced Lorenzo Project would have less than a significant impact on water services. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project’s and the related projects’ potential cumulative impacts on water services would be less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant water services impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Utilities – Solid Waste (Draft EIR § IV.M.3)


Construction waste generated by the Reduced Lorenzo Project would be similar to the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis for construction utilities-solid waste would not change based on the Reduced Lorenzo Project and potential impacts would remain less than significant. Implementation of Mitigation Measures M-15 and M-16 set forth in the MMRP of the Final



EIR would further ensure recycling of demolition and construction related solid waste.

The Reduced Lorenzo Project would contain fewer residential units and would therefore generate less solid waste than the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis for operational utilities-solid waste would not change based on the Reduced Lorenzo Project and potential impacts would remain less than significant. Implementation of Mitigation Measure M-17 set forth in the MMRP of the Final EIR would promote on-site recycling during operation.


The Reduced Lorenzo Project’s impacts on solid waste disposal facilities would be less than significant without mitigation. However, implementation of the recommended Mitigation Measures M-15 through M-17 would further reduce the Reduced Lorenzo Project’s potential impacts. Those measures shall also be incorporated in the MMRP for the Reduced Lorenzo Project. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project’s and the related projects’ potential cumulative impacts on solid waste services would remain less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant solid waste impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Utilities – Electricity (Draft EIR § IV.M.4)


The Reduced Lorenzo Project would contain fewer residential units and would therefore consume less electricity than the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis for electricity services would not change based on the Reduced Lorenzo Project and potential impacts would remain less than significant. The Reduced Lorenzo Project would be required to implement the same mitigation measures as the Lorenzo Project to further reduce potential impacts to electricity supplies.


The Reduced Lorenzo Project would have a less-than-significant impact with respect to electricity services. All electricity services mitigation measures set forth in the MMRP in the Final EIR shall also be incorporated in the MMRP for the Reduced Lorenzo Project. The implementation of those measures would ensure that the Reduced Lorenzo Project would reduce electricity consumption to the extent feasible, meet the intent of LEED certification level and be served by adequate infrastructure. Consistent with the analysis in the Draft EIR, the Reduced Lorenzo Project in combination with the related projects would have a less than significant cumulative impact on energy services.



With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant electricity impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Utilities – Natural Gas (Draft EIR § IV.M.5)


The Reduced Lorenzo Project would contain fewer residential units and would therefore consume less natural gas than the Lorenzo Project analyzed in the Draft EIR. Therefore, the Draft EIR’s analysis of natural gas services would not change based on the Reduced Lorenzo Project and impacts would remain less than significant. The Reduced Lorenzo Project would be required to implement energy conservation measures identified in Mitigation Measures M-25 and M-26 (as renumbered in the MMRP in the Final EIR) to further reduce potential impacts.


The Reduced Lorenzo Project’s potential impacts to natural gas supplies and infrastructure would be less than significant; nevertheless, Mitigation Measures M-25 and M-26 would further reduce impacts related to natural gas services. Those Mitigation Measures shall also be incorporated in the MMRP for the Reduced Lorenzo Project. Consistent with the analysis in the Draft EIR, the Lorenzo Project’s and the related project’s potential cumulative impacts on natural gas services would remain less than significant.

With regard to the criteria set forth in CEQA Guidelines Section 15088.5(a), the changes proposed by the Reduced Lorenzo Project would not result in any new significant natural gas services impacts or result in a substantial increase in the severity of those effects as previously identified. Therefore, recirculation of the EIR is not warranted.

Lorenzo Project III. Preparers Supplemental CEQA Analysis of Reduced Density Proposal Page III-1

III. PREPARERS OF SUPPLEMENTAL CEQA ANALYSIS OF REDUCED DENSITY PROPOSAL

Lead Agency

City of Los Angeles Department of City Planning, 200 North Spring Street, Room 750 Los Angeles, California 90012 Adam Villani, Project Coordinator

Project Applicant

Palmer/Flower Street Properties 11740 San Vicente Blvd., Suite 208 Los Angeles, California 90049

Environmental Consultant

Ms. Lainie Herrera 1838 S Orange Drive Los Angeles, CA 90019

*Ms. Herrera was the Project Manager for preparation of the Lorenzo Project’s EIR, and her Curriculum Vitae is attached as Exhibit C to this document.

Architects

Nelson/Bovin-Architects 21066 Colina Drive, Suite 101 Topanga, California 90290

Traffic Consultant

KOA Corporation 1100 Corporate Center Dr., Suite 201 Monterey Park, CA 91754

Brian A. Marchetti

Exhibit A: UPDATED TRIP GENERATION CALCULATIONS – LORENZO PROJECT

(KOA Corporation, November 9, 2010)

1100 Corporate Center Dr., Suite 201 Monterey Park, CA 91754

t: 323-260-4703 f: 323-260-4705 www.koacorporation.com

TECHNICAL MEMORANDUM Date: November 9, 2010 To: Greg Smith – G.H. Palmer Associates From: Brian A. Marchetti, AICP Subject: Updated Trip Generation Calculations – Lorenzo Project (KOA Corporation Project JA6199X) The proposed Lorenzo Project would be constructed at the intersection of Flower Street & 23rd Street. This memorandum provides an update on project trip generation totals, based on a planned project unit reduction that has been defined by G.H. Palmer Associates. It is our understanding that G.H. Palmer has recently decided to reduce the number of apartment on the western portion of the site (west side of Flower Street) to 132 dwelling units. The total height of the revised western portion of the project would be 12 stories, based on this unit number reduction. Table 1 provides the updated project trip generation summary, based on unit reductions for the high-rise portion of the project. In order to provide a conservative estimate of project trip generation, pass-by trip reductions for the commercial uses and transit-based reductions for the residential uses were all reduced to values of 15 percent. The bottom row of the table indicates that the project, as revised by the applicant, would generate 302 daily trips, seven a.m. peak-hour trips (-129 inbound trips and 137 outbound trips), and 76 p.m. peak-hour trips (152 inbound trips and -76 outbound trips). The project trip generation analyzed for the 2006 project traffic study totaled 1,598 daily trips, 126 a.m. peak-hour trips (-116 inbound trips and 242 outbound trips), and 152 p.m. peak-hour trips (209 inbound trips and -57 outbound trips). Some of the inbound or outbound trip totals within these numbers are negative, due to the existing land use credits applied to the numbers.

Updated Trip Generation Calculations – Lorenzo Project Page 2 Prepared for G.H. Palmer Associates JA6199X November 9, 2010

Table 1 – Project Trip Generation Update

Land Use Intensity Units Daily

Weekday

AM Total

Weekday

AM IN

Weekday

AM OUT

Weekday

PM Total

Weekday PM

IN

Weekday PM

OUT

Mid-Rise Apartments (Land Use 223) ** - D.U. 4.20 0.30 0.09 0.21 0.39 0.23 0.16High Rise Apartments (Land Use 222) - D.U. 4.20 0.30 0.08 0.23 0.35 0.21 0.14Hospital (Land Use 610) - KSF 17.57 1.20 0.80 0.40 1.18 0.39 0.79General Office (Land Use 710) - KSF 11.01 1.55 1.36 0.19 1.49 0.25 1.24Medical Office (Land Use 720) - KSF 36.13 2.48 1.96 0.52 3.72 1.00 2.72Sit-Down Restaurant (Land Use 931) KSF 89.95 0.81 0.41 0.41 7.49 5.02 2.47Shopping Center (Land Use 820) - KSF 42.94 3.75 1.80 1.95 3.75 1.80 1.95

Land Use Intensity Units Daily

Weekday

AM Total

Weekday

AM IN

Weekday

AM OUT

Weekday

PM Total

Weekday PM

IN

Weekday PM

OUTHospital (Land Use 610) 190.380 KSF 3,345 228 153 75 225 74 151General Office (Land Use 710) 21.000 KSF 231 33 29 4 31 5 26Medical Office (Land Use 720) 37.500 KSF 1,355 93 73 20 140 38 102

4,931 354 255 99 395 117 278

Mid-Rise Apartments (Land Use 223) -

Main Site 919.000 D.U. 3,860 276 85 190 358 208 151High Rise Apartments (Land Use 222) -

Adjacent to the Freeway 132.000 D.U. 554 40 10 30 46 28 18

Sit-Down Restaurant (Land Use 932) * 6.000 KSF 459 4 2 2 38 26 13Shopping Center (Land Use 820) * 28.000 KSF 1,022 89 43 46 89 43 46

-662 -47 -14 -33 -61 -35 -25

5,233 361 126 235 471 269 2024,931 354 255 99 395 117 278302 7 -129 137 76 152 -76

Note: Hospital intensity (for existing use calcs) includes the main hospital, engineering, and rehab buildings. PM rate used for the AM peak for transit center retail with 50-50 inbound/outbound split* Sit-down restaurant trips reduced by 15% and shopping center retail trips reduced by 15% due to orientation to rail transit station.** Assumes high-rise apartment daily rate due to negeligible daily rate for mid-rise apartment.

TRIP GENERATION RATES

FORECAST TRIP GENERATION

TOTAL NET TRIP GENERATION

Existing Use

Proposed UseTotal Existing Use

Total Proposed Use

Transit Commuter Credit - Future Exposition Line (15%) -

Residential Uses Only

Total Existing Use

The revised trip generation totals provided for this update represent an 81% reduction in net daily trips, a near-removal of all net a.m. peak-hour trips, and a 50% reduction in net p.m. peak-hour trips.

Exhibit B: UPDATED PARKING CALCULATIONS FOR

REDUCED LORENZO PROJECT

UPDATED PARKING CALCULATIONS FOR REDUCED LORENZO PROJECT

Site A Required Parking

Use Number of Units Ratio Parking Required Residential

One Bedroom 101 units 1.5 spaces/unit 152 Two Bedroom 673 units 2 spaces/unit 1,346 Three Bedroom 145 units 2 spaces/unit 290

Total Residential Parking 1,788 Parking Reduction (SB1818)1 -51 Total Residential Parking Required/Provided

1,737

Commercial Total Commercial Parking Required/Provided

151

Replacement Hospital Total Replacement Hospital Parking Required/Provided

367

Total Parking Required/Provided for Site A

2,255

Site B Required Parking Use Number of Units Ratio:

Spaces/Unit Parking Required

Residential One Bedroom 72 1.5 108 Two Bedroom 60 2 120

Total Residential Parking 228 Parking Reduction (SB1818)2 -36 Total Parking Required/Provided for Site B

192

Site A and Site B Required Parking Total Parking for Site A 2,255 Total Parking for Site B 192 Total Parking Required/Provided 2,447 1 101 one bedroom units x 0.5 spaces/unit = 50.5 2 72 one bedroom units x 0.5 spaces/unit = 36

Exhibit C: PREPARER CURRICULUM VITAE

Page 1 of 1

EDUCATION University of Southern California

BS, Public Policy, Management, and Planning, 2003

Lainie Herrera

Lainie Herrera is a project manager with over seven years’ professional experience as a CEQA/NEPA planner and manager specializing in preparation of environmental review documents pursuant to CEQA, NEPA, and regional project approval process.

She has managed and written numerous CEQA analyses, coordinating daily with agency staff, subconsultants, and applicants. Ms. Herrera’s experience includes Initial Studies, Environmental Assessments, Negative Declarations, Mitigated Negative Declarations, Environmental Impact Reports, and Mitigation Monitoring Programs. She has served as project manager and primary author of many documents in and around the City of Los Angeles, including the Los Angeles Community Redevelopment areas. Her diverse project experience includes commercial/retail, mixed-use, single and multi-family residential, public works, medical facilities, sports entertainment, recreation, historic structures, and specific plans. Ms. Herrera also has experience with public scoping meetings and hearings, planning commission and city council hearings, and public workshops.

PROJECT EXPERIENCE

Wilshire Grand Redevelopment Project Environmental Impact Report (EIR), City of Los Angeles, California.

1601 & 1605 Vine Street Project Environmental Impact Report (EIR), City of Los Angeles, California.

Bradley Landfill and Recycling Center Master Plan Environmental Impact Report (EIR), City of Los Angeles, California.

Wetherly Project Environmental Impact Report (EIR), City of Los Angeles, California.

Plaza Pacoima Project Mitigated Negative Declaration (MND), City of Los Angeles, California.

Casden Sepulveda Project Environmental Impact Report (EIR), City of Los Angeles, California.

Casden Ross Project Environmental Impact Report (MND), City of Los Angeles, California.

SeaGlass Townhome Project Environmental Impact Report (EIR), City of Los Angeles, California.

LAAFB Land Conveyance, Construction and Development Project Environmental Impact Report (EIR) and Environmental Impact Statement (EIS), City of El Segundo, and City of Hawthorne.

Sun Valley Health Center Project Mitigated Negative Declaration (MND), County of Los Angeles, California.

Del Amo Fashion Center Phase II Mixed-Use Development Project (EIR), City of Torrance.

Los Angeles Memorial Coliseum (EIR), City of Los Angeles.

Malibu Civic Center - La Paz Development Project (EIR), City of Malibu.

Sepulveda/Rosecrans Site Rezoning and Plaza El Segundo Development (EIR), City of El Segundo

Summerwind Ranch at Oak Valley (EIR), City of Calimesa.

Beverly Connection (IS/MND), City of Los Angeles.

City of Los Angeles Housing Department Section 151.28 Ellis Act Provisions – Rental of Replacement Units (IS/ND), City of Los Angeles.

First Street Trunk Line Project, Los Angeles Department of Water and Power (MND), City of Los Angeles

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The Lorenzo Project - LA City Planning · 2010. 12. 28. · Environmental Review Section City Hall...

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