Final Environmental Impact Report Transit Oriented Development Plan for Downtown Inglewood and Fairview Heights

Transcription

1 Final Environmental Impact Report Transit Oriented Development Plan for Downtown Inglewood and Fairview Heights Prepared for: City of Inglewood One Manchester Boulevard, Fourth Floor Inglewood, CA Prepared by: Metis Environmental Group 437 Alcatraz Avenue Oakland, CA September 2016

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3 Table of Contents TABLE OF CONTENTS 1. Introduction Project Location Project Overview Format of the Final EIR Use of the Final EIR in Agency Decision Making Consultation with Other Agencies CEQA Requirements Regarding EIR Comments and Responses Availability of Reference Materials Page 2. Response to Comments List of Agencies that Received the Draft EIR of Notice of Availability List of Comment Letters Received on the Draft EIR Response to Comments California Highway Patrol Caltrans District Office of Planning and Research: August 22, Office of Planning and Research: August 26, County Sanitation Districts of Los Angeles County Los Angeles County Fire Department East Beach Inglewood LLC Diane Sambrano Revisions to the Draft EIR Environmental Setting, Impacts, and Mitigation Mitigation Monitoring and Reporting Program Introduction List of Figures 1.1 TOD Plan Area List of Tables 1-1 Summary of Proposed Development Mitigation Monitoring and Reporting Requirements Downtown Inglewood and Fairview Heights i Metis Environmental Group

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5 1.0 Introduction CHAPTER 1 INTRODUCTION This Final Environmental Impact Report (FEIR) has been prepared by the City of Inglewood ( City or Inglewood ) as the Lead Agency in conformance with the California Environmental Quality Act (CEQA) (Pub. Resources Code et seq.) and the CEQA Guidelines (14 Cal. Code Regs, tit. 14 ch. 3, et seq.) to identify, analyze, and mitigate the significant environmental effects of a proposed Transit Oriented Development (TOD) Plan, including a General Plan Amendment, Concept Plans, Transit Oriented Development Zoning, and Design Guidelines for the Downtown Inglewood and Fairview Heights planning areas within the City of Inglewood. According to CEQA Guidelines, Section 15132, the Final EIR shall consist of: (a) The Draft EIR or a revision of the Draft; (b) Comments and recommendations received on the Draft EIR, either verbatim or in summary; (c) A list of persons, organizations, and public agencies commenting on the Draft EIR; (d) The responses of the lead agency to significant environmental points raised in the review and consultation process; (e) Any other information added by the lead agency. The City of Inglewood has determined that none of the additional material included in the Final EIR constitutes significant new information requiring recirculation of the Draft EIR under CEQA Guidelines Section The additional material presented in the Final EIR clarifies and amplifies existing information prepared in the Draft EIR. It does not indicate that proposed development subject to the TOD Plan would result in a new significant environmental impact or impacts not previously disclosed in the Draft EIR, nor that there would be a substantial increase in the severity of an environmental impact that will not be mitigated, or that any of the other circumstances requiring recirculation described in CEQA Guidelines Section would result. 1.1 PROJECT LOCATION Figure 1.1 indicates the location of the Downtown Inglewood and Fairview Heights planning areas. The Downtown Inglewood planning area consists of approximately 585 acres located in the center of Inglewood along the new Crenshaw/LAX Metro line just east of the Florence Avenue/La Brea Avenue intersection. The Downtown planning area generally encompasses the area within approximately half-mile radius of the Downtown Inglewood Metro Station. The Fairview Heights planning area consists of approximately 328 acres located near the intersection of Florence Avenue and West Boulevard. This planning area generally encompasses Downtown Inglewood and Fairview Heights 1-1 Metis Environmental Group

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7 1.0 Introduction the portion of the half-mile radius area extending from the Fairview Heights Metro Station along the Crenshaw/LAX Metro line that is within the City of Inglewood. As shown in Figure 1.1, the westerly portion of the half-mile radius from the Metro station generally lies within the City of Inglewood; the easterly portion of this half-mile radius lies within the City of Los Angeles, and is not part of the proposed project. 1.2 PROJECT OVERVIEW The consists of an amendment to the Inglewood General Plan to recognize the changes that completion of the Metro Crenshaw/LAX Line will have on the community s accessibility, and to capture the land use and economic development opportunities such accessibility will bring. Included in the General Plan Amendment are revisions to proposed land uses to take advantage of higher density mixed use development opportunities adjacent to the two Metro stations that will be opened within Inglewood along the Metro Crenshaw/LAX Line. Concept plans for the two planning areas provide a detailed land use plan and policy direction for appropriate uses and development intensity, along with improved access to the two Metro stations that are at the center of the planning areas and enhanced pedestrian and bicycle mobility. The Concept Plans also provide for new and enhanced public spaces within the Downtown and Fairview Heights areas. Overall, the TOD Plan would provide for the types and amount of development described in Table 1-1, Summary of Proposed Development. TABLE 1-1 SUMMARY OF PROPOSED DEVELOPMENT RESIDENTIAL (units) RETAIL (s.f.) OFFICE (s.f.) HOTEL (rooms) INSTITUTIONAL (s.f.) INDUSTRIAL & INDUSTRIAL/ CREATIVE OFFICE (s.f.) Existing Development 5,781 1,031, , , ,479 Future Demolition , , , ,927 Future Development 2, , , ,977 1,248,476 Development at Buildout 8,474 1,230,872 1,120, ,752,029 Source: The Arroyo Group, The proposed Transit Oriented Development Plan will involve modifications to existing zoning designations to provide form-based development regulations aimed at maximizing use of transit, bicycling, and walking. These regulations set forth opportunities for increased development intensity in mixed use settings, along with expansion of employment-generating uses, particularly in the Downtown area. Form-based development regulations include design guidelines for new development and rehabilitation of existing historic structures. Recognizing the intended transit orientation of new development within the Downtown and Fairview Downtown Inglewood and Fairview Heights 1-3 Metis Environmental Group

8 1.0 Introduction Heights areas, proposed zoning regulations include reductions in minimum parking requirements for uses and locations most amenable to transit use. 1.3 FORMAT OF THE FINAL EIR The following chapters are contained within this document: Chapter 1, Introduction, describes CEQA requirements and the content of the Final EIR. Chapter 2, Response to Comments, provides a list of agencies, organizations, and interested individuals who commented on the Draft EIR, copies of all comment letters received during the public review period for the Draft EIR, and responses to each of the comments contained in those comment letters. Chapter 3, Revisions to the Draft EIR. This chapter sets forth revisions made to the Draft EIR as a result of the comments received by agencies, organizations and individuals as described in Chapter 2, and/or errors and omissions discovered subsequent to release of the Draft EIR for public review. Chapter 4, Mitigation, Monitoring, and Reporting Program. This chapter includes the Mitigation Monitoring and Reporting Program (MMRP) prepared based on the mitigation measures included in this Final EIR. CEQA requires lead agencies to adopt a reporting and mitigation monitoring program for the changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment (CEQA , CEQA Guidelines 15097). 1.4 USE OF THE FINAL EIR IN AGENCY DECISION MAKING In conformance with CEQA and the CEQA Guidelines, the Final EIR provides detailed and objective information regarding the environmental consequences of the proposed TOD Plan and resulting development within the Downtown Inglewood and Fairview Heights areas. The Final EIR also examines mitigation measures and alternatives to the project intended to reduce or avoid significant environmental impacts. The Final EIR will be considered by the City and Responsible Agencies prior to engaging in discretionary decisions regarding development within the Downtown Inglewood and Fairview Heights areas. Should the City decide to certify the Final EIR, it must make the findings set forth in CEQA Guidelines 15090(a). Namely, the City would have to certify that the EIR: Complies with CEQA; Reflects the lead agency s independent judgment and analysis; and Was presented to the decision-making body, which reviewed and considered the information in the Final EIR before approving or approving with modifications any component of the proposed project. Downtown Inglewood and Fairview Heights 1-4 Metis Environmental Group

9 1.0 Introduction After considering and certifying the EIR, the lead agency may then decide whether or how to approve the proposed project. Under CEQA, an agency may not approve or carry out a project for which an EIR was prepared unless it makes written findings to the effect that: The project as approved will not have a significant effect on the environment; or The agency has eliminated or substantially lessened all significant effects on the environment when feasible, and has determined that any remaining significant effects are acceptable when balanced again the project s benefits. (Pub. Res. Code 21081; CEQA Guidelines 15092(b).) CEQA requires an agency to avoid or reduce a project s significant effects when it is feasible to do so. When deciding whether a project should be approved, an agency then has an obligation to balance various public objectives, including economic, environmental, legal, technological, and social factors, and determine whether overriding considerations justify approval of the project despite its significant environmental effects. The agency then must adopt a statement of overriding considerations, setting forth specific reasons in support of project approval. In accordance with CEQA and the CEQA Guidelines, the Final EIR will be made available prior to the City s consideration of EIR certification. All documents referenced in this Final EIR are also available for public review. See Section 1.6, below, for information regarding reference availability. 1.5 CONSULTATION WITH OTHER AGENCIES Section of the CEQA Guidelines sets forth a list of entities with which a lead agency must consult with and request comments on the Draft EIR. These include responsible agencies (public agencies that have discretionary approval authority over some aspect of the project); trustee agencies (state agencies with jurisdiction by law over natural resources that are held in trust for the people of the state of California and that may be affected by a project); any other state, federal and local agencies that have jurisdiction by law with respect to the project or which exercise authority over resources which may be affected by the project, including water agencies consulted pursuant to Guidelines Section ; adjacent cities and counties; and transportation planning agencies. Chapter 2 of this document lists all of the recipients of the Draft EIR or Notice of Availability. 1.6 CEQA REQUIREMENTS REGARDING EIR COMMENTS AND RESPONSES The lead agency must evaluate comments on the Draft EIR and prepare written responses for inclusion in the Final EIR. The written responses must describe the disposition of any significant environmental issues raised by commenters. (Pub. Res. Code 21091(d); CEQA Guidelines ) Written responses must be detailed and provide a reasoned, good faith Downtown Inglewood and Fairview Heights 1-5 Metis Environmental Group

10 1.0 Introduction response. Responses to comments that do not raise a significant environmental question are not required. (Citizens for E. Shore Parks v. State Lands Comm n (2011) 202 Cal.App.4th 549.) CEQA Guidelines Section 15204(a) outlines parameters for submitting comments, and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be on the sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commentors. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR. CEQA Guidelines Section 15204(c) further advises, Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence. Section (d) also states, Each responsible agency and trustee agency shall focus its comments on environmental information germane to that agency s statutory responsibility. Section (e) states, This section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section. In accordance with CEQA, Public Resources Code (PRC) Section , copies of the written responses to public agencies are required to be forwarded to those agencies at least 10 days prior to certification of the environmental impact report. Thus, responses to public agency comments will be forwarded with copies of this Final EIR document, as permitted by CEQA, and will conform to the legal standards established for response to comments on the Draft EIR. In addition, the full set of comments and responses to comments will be made available to the public on the City s website prior to the comencement of public hearings on the proposed project. 1.7 AVAILABILITY OF REFERENCE MATERIALS Copies of documents referred to in this EIR are available for review during normal business hours at: City of Inglewood Planning Division One Manchester Boulevard, Fourth Floor Inglewood, CA Downtown Inglewood and Fairview Heights 1-6 Metis Environmental Group

11 2.0 Response to Comments CHAPTER 2 RESPONSE TO COMMENTS 2.1 LIST OF AGENCIES THAT RECEIVED THE DRAFT EIR OR NOTICE OF AVAILABILITY State Agencies Governor s Office of Planning & Research (copies of Draft EIR distributed by OPR to state agencies). Regional Agencies Los Angeles County Metropolitan Transportation Authority (Metro) South Coast Air Quality Management District Southern California Association of Governments (SCAG) Gabrieleno Band of Mission Indians-Kizh Nation Local Agencies City of Los Angeles City of Gardena City of Hawthorne County of Los Angeles Inglewood Unified School District Los Angeles County Fire Department Los Angeles World Airports Sanitation Districts of Los Angeles County 2.2 LIST OF COMMENT LETTERS RECEIVED ON THE DRAFT EIR State Agencies California Highway Patrol Caltrans District 7 Governor s Office of Planning & Research: August 22, 2016 Governor s Office of Planning & Research: August 26, 2016 Local Agencies County Sanitation Districts of Los Angeles County Downtown Inglewood and Fairview Heights 2-1 Metis Environmental Group

12 2.0 Response to Comments Los Angeles County Fire Department Individuals and Organizations East Beach Inglewood LLC Diane Sambrano 2.3 RESPONSE TO COMMENTS Each comment letter has been assigned a letter code based on the initials of the commenter or agency/organization acronym. Individual comments within each letter have been assigned an alphanumeric comment identification code based on the letter code and comment number; for example, the first comment in the letter from Caltrans is Caltrans-1. Each comment letter is presented in full, and is followed by the City s response to the comments contained in the letter. Some comments received on the Draft EIR raised planning issues or provided background information, and did not address the adequacy of the Draft EIR or its analyses and conclusions. While the City, as the CEQA Lead Agency, acknowledges their receipt, as permitted by CEQA and CEQA Guidelines, only limited responses are provided to comments that do not address the adequacy of the Draft EIR, its analyses and conclusions, or that do not identify any significant environmental issue. Where a response to a comment requires revisions to the text of the Draft EIR, such revisions are shown in underline for additions and strikethrough for deletions. Chapter 3 of the Final EIR contains a consolidated set of all changes made to the Draft EIR that resulted from: (1) changes made in response to the comments received on the Draft EIR; or (2) City staff-initiated changes to correct errors or to clarify information presented in the Draft EIR. Downtown Inglewood and Fairview Heights 2-2 Metis Environmental Group

13 2.0 Response to Comments Comment Letters and Responses to Comments Downtown Inglewood and Fairview Heights 2-3 Metis Environmental Group

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15 2.0 Response to Comments CALIFORNIA HIGHWAY PATROL CHP-1 Caltrans District 7 did, in fact, review the Traffic Impact Analysis (TIA) and EIR prepared for the proposed TOD Plan for Downtown Inglewood and Fairview Heights. Included in the TIA was an analysis of queueing on freeway off-ramps. The Caltrans comment letter raised no concerns with the queueing analysis prepared for the TOD Plan other than to note that one of the intersections that was studied to determine whether project-related traffic could queue back up onto the feeeway mainline was not actually under Caltrans control. No issues were raised regarding the adequacy or conclusions of the queueing analysis. Downtown Inglewood and Fairview Heights 2-5 Metis Environmental Group

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17 2.0 Response to Comments CALTRANS DISTRICT 7 Caltrans-1 Caltrans-2 Caltrans-3 Although this intersection is not under Caltrans jurisdiction, it was analyzed per Caltrans guidelines, including a ramp queuing analysis. The values shown in Tables 8 and 9 are taken directly from SCAG regional population and employment projections model, and are values developed by SCAG in coordination with each jurisdiction. The methodology employed in the Traffic Impact Analysis uses the SCAG 2012 model as the basis for socioeconomic growth, as well as for multi-modal trip interchanges and travel assignment. Within the study area, the SCAG model forecasts a reduction in both population and employment within Inglewood, which reduces the overall trips that are forecast on the network. The land use data from SCAG projections was modified in the Traffic Impact Analysis to include significant known development projects, such as the redevelopment of Hollywood Park. Comment Caltrans-3 does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-7 Metis Environmental Group

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19 2.0 Response to Comments OFFICE OF PLANNING AND RESEARCH: AUGUST 22, 2016 OPR 1-1 This letter transmits comments from the California Highway Patrol (CHP), which was the only State Agency to provide comments during the public review period. Specific responses to the comments raised in the CHP letter can be found in Section of this Final EIR. The OPR letter does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-9 Metis Environmental Group

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21 2.0 Response to Comments OFFICE OF PLANNING AND RESEARCH: AUGUST 26, 2016 OPR 2-1 This letter transmits comments from Caltrans District 7, which was received after close of the public review period. Specific responses to the comments raised in the Caltrans letter can be found in Section of this Final EIR. The OPR letter does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-12 Metis Environmental Group

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24 2.0 Response to Comments COUNTY SANITATION DISTRICTS OF LOS ANGELES COUNTY LACSD-1 LACSD-2 Table 4.N-3 identifies City of Inglewood wastewater generation factors, which are slightly higher than the factors used by the Sanitation Districts. Thus, as shown in Draft EIR Table 4.N-4, the City anticipates that wastewater generation within the TOD Plan areas will increase by 1.26 million gallons per day, which represents a worst case impact in comparison to the 1.1 million gallon per day increase cited in Comment LACSD-1. The third paragraph on page 4.N-12 is revised to read as follows: There are approximately 203 connections to the LACSD system throughout the City, which convey City s wastewater to the LACSD Joint Water Pollution Control Plant located in the City of Carson for treatment and disposal (SSMP, 2015). The JWPCP facility processes both primary and secondary treatment for an average flow of mgd with a design capacity of 400 mgd (LACSD 2016). Prior to discharge, the treated wastewater is disinfected with sodium hypochlorite and sent to the Pacific Ocean through a network of outfalls. These outfalls extend 2 1-½ miles off the coast of Southern California into the Palos Verdes Peninsula to a depth of 200 feet. LACSD-3 LACSD-4 LACSD-5 LACSD-6 See Response LACSD-1. Will Serve Requests will be submitted for site-specific development projects within the TOD Plan areas. See Response LACSD-2. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-15 Metis Environmental Group

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27 2.0 Response to Comments COUNTY OF LOS ANGELES FIRE DEPARTMENT LACFD-1 The first paragraph under Existing Setting Fire Protection Services on page 4.M-4 of the Draft EIR is revised to read: The City of Inglewood receives fire protection and paramedic services from Los Angeles County Fire Department (LACFD). Services provided by the Fire Department include fire suppression, hazardous materials protection, emergency medical treatment, including basic and advanced life support transportation, earthquake and fire safety planning, fire inspections, and building plan reviews. LACFD-2 The second full paragraph on page 4.M-6 is revised to read: As described above, there is one fire station (Station 171) within the TOD Plan areas, another fire station (Station 172) located within one mile of the of the TOD Plan areas, and 10 more fire stations located within three miles of the City boundary. The proposed TOD Plan would result in infill development, increased residents and employees; and therefore, an increased number of calls for fire services that would increase needs for fire department staffing and equipment,. tthis increase would occur gradually over the incremental implementation of the proposed 20-year plan and the fire department would add staff and equipment to the existing stations on an as-needed basis in order to accommodate these increased demands identify the need for any additional staff or equipment on a project-by-project basis in order to accommodate the incremental increase in service demands. Due to the large number of existing fire stations within the area, and the infill nature of the development that would occur within the already served TOD Plan areas, the increase in fire department staffing and equipment required to serve the build out of the proposed TOD would be accommodated by the existing fire stations, and new or physically altered fire protection facilities would not be required. Thus, physical impacts to the environment related to the development of or expansion of fire department facilities would not occur. LACFD-3 LACFD-4 The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-18 Metis Environmental Group

28 2.0 Response to Comments LACFD-5 The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-19 Metis Environmental Group

29 EAST BEACH INGLEWOOD, LLC c/o Lee Ventures Realty, Inc. 111 N. La Brea Ave., Suite 101 Inglewood, California August 22, 2016 VIA OVERNIGHT COURIER AND ELECTRONIC MAIL Mindy Wilcox, Planning Manager Fred Jackson, Senior Planner City of Inglewood, Planning Division One Manchester Boulevard, 4th Floor Inglewood, California RE: Draft Environmental Impact Report for Transit Oriented Development Plan for Downtown Inglewood and Fairview Heights (SCH No ) Dear Ms. Wilcox and Mr. Jackson, Thank you for the opportunity to comment upon the draft Environmental Impact Report ( DEIR ) prepared for the City of Inglewood s Transit Oriented Development Plan for Downtown Inglewood and Fairview Heights. On November 3, 2014, East Beach Inglewood, LLC, a California limited liability company ( Property Owner ), acquired that certain real property located at 338 East Beach Avenue / 355 La Colina Drive [Assessor s Parcel Numbers and -025] (the Property ), and remains the current owner of record of the Property. As shown on Figure 4.A-1 ( Existing Land Uses Downtown ) on page 4.A-8 of the DEIR, the Property is currently vacant. However, as previously discussed with City staff, the Property Owner intends to bring forward an application to the City at a future date for a multi-family residential development compatible with the City s vision for transit-oriented development around the new Downtown Inglewood Metro Station. As discussed in more detail below, we write today on behalf of the Property Owner to highlight a critical error in both the DEIR and the February 25, 2016 public review draft of the Form Based Concept Plans and TOD Zoning: The New Downtown Inglewood and Fairview Heights (the Inglewood TOD Plan ) regarding the proposed new General Plan land use designation for the Property. Left uncorrected, this error would represent a significant and unavoidable impact of the Inglewood TOD Plan which was neither properly disclosed nor analyzed in the DEIR, and which would require the DEIR analysis to be revised and recirculated. Each of DEIR Figure 3.7 ( Downtown Urban Design Framework, page 3-13) and Figure 3.13 ( Downtown Preferred Land Use Plan (Zoning and Public Uses), page 3-25) designates the Property as Open Space, and DEIR Figure 3.9 ( Downtown Complete Streets and Parking, page 3-20) labels the Property as Parks. Each of Inglewood TOD Plan Figures 2.5, 2.11, 2.16, and 3.2 (on pages 11, 17, 21, and 33, respectively) similarly labels the property as Open Space

30 Notably, the Property is the only privately-held parcel in the Downtown Inglewood area that is targeted for such redesignation as Open Space. This proposed General Plan land use designation of Open Space would be fundamentally incompatible with the Property s current zoning as Light Manufacturing (M-1) (general commercial uses) and Residential Limited Multi Family (R-2) (two dwelling units per lot). The use of the Property as Open Space is not analyzed or discussed in the DEIR, and is only shown on the figures referenced above. Moreover, the DEIR contains no discussion of how the restriction to Open Space uses would preclude the Property from being redeveloped for any economicallyviable use and foreclose the opportunity for the Property to be redeveloped for much-needed housing. In discussions with the Property Owner, City staff has expressed that this new Open Space or Park designation represents the City s vision for the site, but does not in and of itself represent a sub-designation of the single TOD designation that is proposed to replace all existing General Plan land use designations for the Downtown Inglewood and Fairview Heights planning areas. However, there is nothing in the text of the DEIR or the Inglewood TOD Plan indicating that such Open Space or Parks designation is descriptive of the City s policy vision, as opposed to being regulatory in nature. In fact, Section 3.3 of the Inglewood TOD Plan adds to the confusion with the following statement: 3 cont'd 4 5 Figure 3.2 gives the Preferred Land Use Plan, which locates the recommended future locations for public open space and public parking structures as well as the zoning map. The Preferred Land Use Plan implements the zoning district shown in Figure 3.1. (Emphasis added). The Preferred Land Use Plan both recommends open space locations and implements the City s zoning. As such, it is unclear how to reconcile the inconsistency between Figures 3.1 and 3.2. Figure 3.2 labels the Property as Open Space (O-S), which is described on page 32 of the Inglewood TOD Plan as applying to City-owned parks or plazas (emphasis added). However, Figure 3.1 proposes to retain the Property s split M-1/R-2 zoning. Left uncorrected, a future General Plan amendment would be needed to resolve such ambiguity in connection with any future entitlement application for the Property. Were the Property to be designated as Open Space in the General Plan, such restriction would create an undevelopable island in an area adjacent to public transit with substantially less restrictive General Plan designations. Such an approach would have a dramatic economic effect, depriving the owner of an economically viable use of the property and undermining the investment-backed expectations of the Property Owner that were expressed to City staff prior to the Property Owner s acquisition of the Property. While City staff have recently expressed to the Property Owner that a pocket park on the Property would be in the public benefit, singling out the Property from all other privately-held parcels in the area does not seem rational, particularly given that Edward Vincent Junior Park is located a short 3-minute walk northeast of the Property, and is described in the DEIR as one of the most significant City Parks in Southern California (DEIR p. 3-7). Furthermore, the Open Space restriction would be fundamentally inconsistent with the City s stated goal to take advantage of higher density mixed use development opportunities 6 7 2

31 adjacent to the Downtown Inglewood Metro Station (DEIR p. 3-2), as well as the goals articulated in the Land Use element of the existing General Plan to facilitate development of new housing to meet community needs and in the Housing element to Encourage the Production and Preservation of Housing for All Income Categories, particularly around high quality transit. Rather than redesignate the Property as Open Space, either purposefully or as an unintended consequence of the drafting ambiguities described above, the Property Owner strongly encourages the City to select a General Plan and zoning designation for the Property that recognizes the Property s development potential for much-needed modern, transit-oriented, higher-density housing stock in Downtown Inglewood. We welcome the opportunity to re-engage with City staff on the Property Owner s vision for this site, and in the interim appreciate the City s prompt attention to correcting this error in the DEIR and the Inglewood TOD Plan. 7 cont'd 8 Sincerely, Terri Riker Authorized Agent for Property Owner, East Beach Inglewood, LLC 3

32 2.0 Response to Comments EAST BEACH INGLEWOOD LLC East Beach-1 East Beach-2 East Beach-3 East Beach-4 East Beach-5 East Beach-6 The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The Draft EIR is not in error in relation to the proposed land use for the property addressed in this comment, and accurately reflects the proposals set forth in the TOD Plan for Downtown Inglewood and Fairview Heights. Comment East Beach-2 does not identify any physical environmental changes to the environment that would occur as the result of the proposed TOD Plan, but were not addressed in the Draft EIR, and refers only to an unspecified significant and unavoidable impact. The Draft EIR for the proposed TOD Plan is a programmatic document. As such, the Draft EIR addresses the overall physical changes to the environment that would occur should the proposed TOD Plan be approved, rather than the site-specific impacts of development on individual properties within the Downtown Inglewood and Fairview Heights areas. As discussed in Response East Beach-3, the EIR accurately reflects the provisions of the proposed TOD Plan. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. No change to the General Plan designation or zoning of the property being discussed in this comment letter is actually proposed. The comment letter refers to a figure entitled Preferred Land Use Plan, which is an aspirational depiction of potential land use within the Downtown Inglewood and Fairview Heights planning areas. Until such time as the property being discussed in this comment letter might be acquired on a willing buyer willing seller basis and the site s General Plan and zoning designations are actually changed, development would be permitted based on the site s current M-1 and R-2 zoning. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. As discussed in Response East Beach-3, the EIR accurately reflects the provisions of the proposed TOD Plan. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. As discussed in Response East Beach-3, the EIR accurately reflects the provisions of the proposed TOD Plan. The comment does not raise any Downtown Inglewood and Fairview Heights 2-23 Metis Environmental Group

33 2.0 Response to Comments significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. East Beach-7 East Beach-8 As discussed in Response East Beach-3, the EIR accurately reflects the provisions of the proposed TOD Plan. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. As discussed in Response East Beach-3, the EIR accurately reflects the provisions of the proposed TOD Plan. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Downtown Inglewood and Fairview Heights 2-24 Metis Environmental Group

34 Diane Sambrano 3640 W 111 th Place Inglewood Ca August 22, 2016 Fred Jackson, Senior Planner City of Inglewood Planning Division One Manchester Boulevard 4 th Floor Inglewood, Ca fjacksoncityofinglewood.org Response to Environmental Impact Report for Downtown Inglewood It is has been most annoying that a document as significant as this is has not been made easily available to the public for review. When I called even last Thursday city staff was not able to locate the document on the City Website It is absolutely unrealistic for anyone to expect that residents would know the name of the consultant and that the document impacting our neighborhood for the rest of our lives would only be found by accessing by the consultants name. That the notices re community meetings were only sent to those within 500 feet of those parcels to be rezoned is an insult to every member of the Inglewood Constituency. Each one of us will be impacted in one way or another by the development changes suggested. This feels like another in the long list of backroom deals that meet just barely the letter rather than the spirit of the law. 1 2 That the community which is already established must undergo the realignment suggested seems more of an attack on Community focused on displacing current residents and long term businesses to enrich campaign contributors rather than meeting the needs of those who live here. 3 In all the sixty years of residency I have NEVER heard a single neighbor yearn to go to Santa Monica or mourn that there is a lack of public transit to Santa Monica. That there are 9000 residents surrounding the light rail does not mean they want to go where it is proposed nor that others will want to spend their dollars in our community. 4 The desire to build multistory is not a community desire but a gift for developers. It is ironic that the reason given for the demolition of the apartments along 104 th and 102nd was that High Density was the main reason for increased crime and therefore should be bulldozed. Now that those homes have become parking lots for The Forum it will be an even greater insult to those displaced should even Higher Density be part of the new plan. 5

35 That Green Boulevards are proposed is humorous since it is the current city council and the current Public Works director who have yanked out and killed healthy trees and left barren medians and sidewalks on the majority of our main corridors. The once Beautiful Trees were not sick nor poorly placed but suffered just another attempt to create a slummish appearance ripe for developers to avoid costly purchases. 6 Oh look how nice that without a public hearing to discuss public -private partnership of the Fox is anticipated. 7 With regard to the history 4.D.6 is sadly mistaken - original source documents should have been utilized to avoid misconceptions being repeated. This lack of concern for truth, which is easily documentable leaves all other parts of this report as questionable. 8 Noteworthy by its absence is reference to the Michael Stern Googie built prior to his many designs in Las Vegas oops. And so many others are missing as well. 9 Re Traffic even a third grader would tell you that adding 3000 homes will generate more traffic and the excuse that it is already bad does not make it okay to make it worse. 10 Well I wish I didn t have to be snarkey but hey without access to the document earlier you can t expect anything more gracious or precise. When the non-select community is treated so disrespectfully that shows us how you want us to treat you in like fashion! 11 Diane Sambrano i

36 2.0 Response to Comments DIANE SAMBRANO Sambrano-1 Sambrano-2 Sambrano-3 Sambrano-4 Sambrano-5 Sambrano-6 Sambrano-7 Sambrano-8 Sambrano-9 The Draft EIR was available for inspection at the City of Inglewood Planning Division and at the Inglewood public library for the entirety of the 45-day public review period. In addition, a Google search for Inglewood TOD Plan or Inglewood TOD Plan EIR provides a link to the TOD Plan and the Draft EIR, both of which can be reviewed on the internet. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. Draft EIR Section 4.D.6, which is referenced in Comment Sambrano-8, provides the reference documents used for analysis of project-related Cultural Resources impacts. These include the City s General Plan Technical Report and previously approved environmental studies. Comment Sambrano-8 does not identify a specific misconceptions, and it is therefore not possible to provide a more specific response to this comment. The list of historic resources within the Downtown Inglewood and Fairview Heights TOD Plan areas is based on the City s General Plan Technical Report and previously approved environmental studies. Downtown Inglewood and Fairview Heights 2-27 Metis Environmental Group

37 2.0 Response to Comments In addition to the historic resources listed on Page 4.D-8 of the Draft EIR, the following paragraph is added. The Los Angeles Conservancy identifies Sheri's Coffee Shop (now Cafetales) at 115 South La Brea Avenue as historically significant. Completed in 1958, the coffee shop was designed by architect Martin Stern, Jr., who was better known for his casino-hotel-resort designs on the Las Vegas Strip. Sherri s was among his earlier and smaller-scale works, but it is important as an example of the playful Googie style. The TOD Plan proposes that the 1950s structure and sign remain in place. Sambrano-10 Sambrano-11 Section 4.E.6 of the Draft EIR provides detailed information on the increases in traffic that would result from approval of the proposed TOD Plan. As noted in that section, a total of 11 intersections will not meet established performance criteria under Cumulative with Project conditions. With mitigation, impacts would remain significant at 7 intersections. Such impacts are considered to be unavoidable should the City approve the proposed TOD Plan. The comment does not raise any significant environmental issues regarding the analyses, conclusions, or adequacy of the Draft EIR and therefore no further response is required. See Response Sambrano-1 for discussion of the availability of the Draft EIR. Downtown Inglewood and Fairview Heights 2-28 Metis Environmental Group

38 3.0 Revisions to the Draft EIR CHAPTER 3 REVISIONS TO THE DRAFT EIR This chapter contains revisions to the text of the Transit Oriented Development Plan Draft EIR contained in the responses to comments set forth in Chapter 2 of the Final EIR. For each revision to the Draft EIR, the following information is presented: Draft EIR page number where the revision occurs; The specific response to comment where the revision to the Draft EIR is discussed; A description of the revision (e.g., add, revise, or delete text); and The text of the Draft revision. Added text is underlined, while deletions are shown in strikethrough text. 3.1 ENVIRONMENTAL SETTING, IMPACTS, AND MITIGATION Cultural Resources Page 4.D-8 Response Sambrano-9. ADD a new paragraph at the end of the Section entitled, Downtown Inglewood Historic Resources to read: The Los Angeles Conservancy identifies Sheri's Coffee Shop (now Cafetales) at 115 South La Brea Avenue as historically significant. Completed in 1958, the coffee shop was designed by architect Martin Stern, Jr., who was better known for his casino-hotel-resort designs on the Las Vegas Strip. Sherri s was among his earlier and smaller-scale works, but it is important as an example of the playful Googie style. Public Services Page 4.M-4 Response LAFD-1. REVISE the first paragraph under Existing Setting Fire Protection Services to read: The City of Inglewood receives fire protection and paramedic services from Los Angeles County Fire Department (LACFD). Services provided by the Fire Department include fire suppression, hazardous materials protection, emergency medical treatment, including basic and advanced life support transportation, earthquake and fire safety planning, fire inspections, and building plan reviews. Page 4.M-6 Response LAFD-2. REVISE the second full paragraph to read: As described above, there is one fire station (Station 171) within the TOD Plan areas, another fire station (Station 172) located within one mile of the of the TOD Downtown Inglewood and Fairview Heights 3-1 Metis Environmental Group

39 3.0 Revisions to the Draft EIR Plan areas, and 10 more fire stations located within three miles of the City boundary. The proposed TOD Plan would result in infill development, increased residents and employees; and therefore, an increased number of calls for fire services that would increase needs for fire department staffing and equipment,. tthis increase would occur gradually over the incremental implementation of the proposed 20-year plan and the fire department would add staff and equipment to the existing stations on an as-needed basis in order to accommodate these increased demands identify the need for any additional staff or equipment on a project-by-project basis in order to accommodate the incremental increase in service demands. Due to the large number of existing fire stations within the area, and the infill nature of the development that would occur within the already served TOD Plan areas, the increase in fire department staffing and equipment required to serve the build out of the proposed TOD would be accommodated by the existing fire stations, and new or physically altered fire protection facilities would not be required. Thus, physical impacts to the environment related to the development of or expansion of fire department facilities would not occur. UTILITIES, SERVICE SYSTEMS, AND WATER SUPPLY Page 4.N-12 Response LACSD-2. REVISE the third paragraph to read as follows: There are approximately 203 connections to the LACSD system throughout the City, which convey City s wastewater to the LACSD Joint Water Pollution Control Plant located in the City of Carson for treatment and disposal (SSMP, 2015). The JWPCP facility processes both primary and secondary treatment for an average flow of mgd with a design capacity of 400 mgd (LACSD 2016). Prior to discharge, the treated wastewater is disinfected with sodium hypochlorite and sent to the Pacific Ocean through a network of outfalls. These outfalls extend 2 1-½ miles off the coast of Southern California into the Palos Verdes Peninsula to a depth of 200 feet Downtown Inglewood and Fairview Heights 3-2 Metis Environmental Group

40 4.0 Mitigation Monitoring and Reporting Program CHAPTER 4 MITIGATION MONITORING AND REPORTING PROGRAM 4.1 INTRODUCTION Section of the California Public Resources Code and Sections 15091(d) and of the State CEQA Guidelines require public agencies to adopt a reporting or monitoring program for changes to the project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment. The following Mitigation Monitoring and Reporting Program (MMRP) is based on the mitigation measures presented in the Final Environmental Impact Report (EIR) prepared by the City of Inglewood to analyze impacts of proposed development associated with the TOD Plan for Downtown Inglewood and Fairview Heights. As lead agency for the proposed development within the TOD Plan areas, and pursuant to AB 3180, the City of Inglewood is responsible for implementation of this MMRP. Pursuant to the State CEQA Guidelines, a Mitigation Monitoring and Reporting Program must: Identify the entity that is responsible for each monitoring and reporting task, be it the City of Inglewood (as lead agency), other agency (responsible or trustee agency), or a private entity (i.e., the project sponsor); Be based on the project description and the required mitigation measures presented in the environmental document prepared for the project and certified by the lead agency (Downtown Inglewood and Fairview Heights Transit Oriented Development Final EIR); and Be approved by the lead agency at the same time as project entitlement action or approvals. An Environmental Impact Report (EIR) has been prepared for the proposed Transit Oriented Development Plan for Downtown Inglewood and Fairview Heights that addresses the anticipated environmental impacts of development pursuant to that plan. Where significant impacts are identified, the EIR set forth measures to mitigate these impacts. It is the purpose of this MMRP to identify the implementation strategy for each mitigation measure to ensure that adopted mitigation measures are successfully implemented. Following adoption of the MMRP by the Inglewood City Council, the City will incorporate the mitigation monitoring/reporting requirements in the appropriate site-specific development project approvals and permits. Therefore, in accordance with the aforementioned requirements, this Chapter of the Final EIR lists each mitigation measure, describes the methods for implementation and verification for each measure, and identifies the responsible party or parties as detailed below in the MMRP Implementation section. Downtown Inglewood and Fairview Heights 4-1 Metis Environmental Group