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DEPARTMENT OF CITY PLANNING R ECOMMENDATION R EPORT City Planning Commission Case No.: CPC-2009-598-SP CEQA No.: ENV-2009-599-EIR Incidental Cases: None Related Cases: None Council No.: 1-Reyes Plan Area: Central City North Northeast Los Angeles Silverlake/Echo Park/Elysian Valley Specific Plan: None Certified NC: Lincoln Heights Historic/Cultural GPLU: Various Zone: Various Applicant: City of Los Angeles Representative: City of Los Angeles Date: October 11, 2012 Time: After 8:30 am Place: City Hall 200 N. Spring Street, Room 350 Los Angeles, CA 90012 Public Hearing: Limited Hearing Required. Public Hearing held August 30, 2012. Appeal Status: Not applicable PROJECT LOCATION: The project area is located in portions of the Central City North, Northeast Los Angeles, and Silverlake/Echo Park/Elysian Valley Community Plans. The project is bounded by the intersection of San Fernando Boulevard and Avenue 26 on the north; Pasadena Avenue and the Golden State Freeway (I-5) on the east; Main Street for the portion of the project east of the Los Angeles River (River) and the railroad right of way for the portion of the project west of the River on the south; and Broadway Boulevard on the west. The project area includes portions of the Chinatown and Lincoln Heights communities. The River and the Golden State Freeway bisect the project area north to south and the Arroyo Seco and Arroyo Seco Parkway run east to west through the northeastern section of the project area. The project area includes the Lincoln Heights/Cypress Park Goldline Station and immediately abuts the Chinatown Station and the Heritage Square Station in the southwest and northeast corners of the project area respectively. PROPOSED PROJECT: Cornfield Arroyo Seco Specific Plan: The Cornfield Arroyo Seco Specific Plan (Proposed Plan) revises land use and zoning, and introduces new building form, urban design, open space, parking, conservation, performance, and street standards to reflect recent shifts in existing conditions such as the opening of the Gold Line, the completion of the Los Angeles River Revitalization Master Plan (LARRMP), and the pending development of the Los Angeles State Historic Park (LASHP). The Proposed Plan includes revisions to the Citywide General Plan Framework Element, Transportation Element, and General Plan Land Use designations; Zone changes; and Street Reclassifications. REQUESTED ACTIONS: 1. Pursuant to procedures set forth in Section 11.5.6 of the Municipal Code and City Charter Sections 555 and 558, amend the Central City North, Northeast Los Angeles, and Silverlake/Echo Park/Elysian Valley Community Plans as part of the General Plan of the City of Los Angeles, as modified in the attached Plan

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DEPARTMENT OF CITY PLANNING

RECOMMENDATION REPORT

City Planning Commission Case No.: CPC-2009-598-SP

CEQA No.: ENV-2009-599-EIR

Incidental Cases: None

Related Cases: None

Council No.: 1-Reyes

Plan Area: Central City North Northeast Los Angeles Silverlake/Echo Park/Elysian Valley

Specific Plan: None

Certified NC: Lincoln Heights Historic/Cultural

GPLU: Various

Zone: Various

Applicant: City of Los Angeles

Representative: City of Los Angeles

Date: October 11, 2012

Time: After 8:30 am

Place: City Hall

200 N. Spring Street, Room 350 Los Angeles, CA 90012 Public Hearing: Limited Hearing

Required. Public Hearing held August 30, 2012.

Appeal Status: Not applicable

PROJECT LOCATION:

The project area is located in portions of the Central City North, Northeast Los Angeles, and Silverlake/Echo Park/Elysian Valley Community Plans. The project is bounded by the intersection of San Fernando Boulevard and Avenue 26 on the north; Pasadena Avenue and the Golden State Freeway (I-5) on the east; Main Street for the portion of the project east of the Los Angeles River (River) and the railroad right of way for the portion of the project west of the River on the south; and Broadway Boulevard on the west. The project area includes portions of the Chinatown and Lincoln Heights communities. The River and the Golden State Freeway bisect the project area north to south and the Arroyo Seco and Arroyo Seco Parkway run east to west through the northeastern section of the project area. The project area includes the Lincoln Heights/Cypress Park Goldline Station and immediately abuts the Chinatown Station and the Heritage Square Station in the southwest and northeast corners of the project area respectively.

PROPOSED PROJECT:

Cornfield Arroyo Seco Specific Plan: The Cornfield Arroyo Seco Specific Plan (Proposed Plan) revises land use and zoning, and introduces new building form, urban design, open space, parking, conservation, performance, and street standards to reflect recent shifts in existing conditions such as the opening of the Gold Line, the completion of the Los Angeles River Revitalization Master Plan (LARRMP), and the pending development of the Los Angeles State Historic Park (LASHP). The Proposed Plan includes revisions to the Citywide General Plan Framework Element, Transportation Element, and General Plan Land Use designations; Zone changes; and Street Reclassifications.

REQUESTED ACTIONS:

1. Pursuant to procedures set forth in Section 11.5.6 of the Municipal Code and City Charter Sections 555 and 558, amend the Central City North, Northeast Los Angeles, and Silverlake/Echo Park/Elysian Valley Community Plans as part of the General Plan of the City of Los Angeles, as modified in the attached Plan

CPC-2009-598-SP Page 2

Resolution (Exhibit A), the Cornfield Arroyo Seco Specific Plan, (Exhibit B) and Corresponding Zone and Land Use Changes (Exhibits C, F)

2. Pursuant to Section 12.32 of the Municipal Code, rezoning actions to effect

changes of zone as identified on the Land Use Designation Map (Exhibit F) and Zone Change Map (Exhibit C).

3. Pursuant to procedures set forth in Section 11.5.6 of the Municipal Code and City

Charter Sections 555 and 558, amend the Highways and Freeways Map of the Transportation Element of the General plan to reclassify selected streets within the Central City North, Northeast Los Angeles, and Silverlake/Echo Park/Elysian Valley Community Plans as shown on the Street Redesignation Matrix (Exhibit D-A2).

RECOMMENDED ACTIONS:

1. Conduct a limited public hearing on the Proposed Plan, as modified in this staff report. 2. Approve the Staff Report as the Commission Report. 3. Approve and Recommend that the Mayor approve and the City Council adopt the

attached Cornfield Arroyo Seco Specific Plan (Exhibit B), Land Use Change Maps (Exhibit C) amending the Central City North, Northeast Los Angeles, Silverlake/Echo Park/Elysian Valley Community Plans as part of the General Plan of the City of Los Angeles, as modified.

4. Approve and Recommend that the City Council adopt the requested zoning actions to

effect the changes of zone as identified in the Zone Change Ordinance and Map (Exhibit D). 5. Instruct the Department of City Planning to finalize the necessary zone change ordinances

to be presented to City Council, and make other technical corrections as necessary. 6. Authorize the Director of Planning to present the resolution (Appendix A) and Plan (Exhibit

B) to the Mayor and City Council, in accordance with Sections 555 and 558 of the City Charter.

7. Amend the Highways and Freeways Map of the Transportation Element of the General Plan

to reclassify selected streets within the Central City North, Northeast Los Angeles, Silverlake/Echo Park/Elysian Valley Community Plans as shown in the Street Modification Table in the Cornfield Arroyo Seco Specific Plan and the Modified Street Cross-Sections A2. in the Plan’s Appendices (Exhibit B).

8. Approve and Recommend that the City Council adopt the Administrative Code

Amendment establishing the Cornfield Arroyo Seco Floor Area Trust Fund (Exhibit F). 9. Find that the City Planning Commission has reviewed and considered the Environmental

Impact Report ENV-2009-599-EIR (Appendix E) in its determination approving the Proposed Plan, and transmit the EIR to the City Council for certification.

10. Approve and Recommend that the City Council Adopt the Statement of Overriding

Considerations. 11. Approve and Recommend that the City Council Adopt the Findings, including the

Environmental Findings.

TABLE OF CONTENTS

Proposed Plan Analysis ............................................................................................ A-1

Proposed Plan Summary………………………………………………………….A-1 Background……………………………………………………… ……………….. A-1 Discussion of Key Issues………………………………………..........................A-3 Findings ...................................................................................................................... F-1

General Plan/Charter Findings…………………………………........................F-1 CEQA Findings…………………………………………………………………….F-9 Public Hearing and Communications ...................................................................... P-1 Public Participation…………………………………………………………..…….P-1 Summary of Central and East Area Planning Commission………………..….P-11

Exhibits (Attached):

A. Draft Resolution

B. Cornfield Arroyo Seco Specific Plan + Appendices

C. Proposed Land Use Designation Change Map

D. Proposed Zone Change Ordinance and Map

E. Final Environmental Impact Report (includes DEIR, RP-DEIR and Appendices)

F. Administrative Code Amendment

CPC-2009-598-SP A-1

PROPOSED PLAN ANALYSIS

Proposed Plan Summary The Proposed Plan includes changes in land use designations and zones along with the establishment of new design and performance standards and revised street classifications that are intended to achieve the following:

• Transform an underserved and neglected vehicular-oriented industrial and public facility area into a cluster of mixed-use, pedestrian oriented and aesthetically pleasing neighborhoods

• Maintain and enhance the concentration of jobs

• Provide a range of housing choices

• Provide shops and services for everyday needs

• Increase access to open space

• Reduce per capita water and energy use

• Lessen dependence on the automobile by facilitating pedestrian and transit mobility and encouraging bicycle use

Over the past 10 years, investments in transit infrastructure, the Los Angeles River Revitalization Master Plan (LARRM) and Los Angeles State Historic Park (LASHP) have increased redevelopment pressures in this area. To facilitate the realization of the goals above, the Plan includes the designation of new mixed-use zoning districts that will expand the range and intensities of permitted uses, establish building height, massing, façade, open space and conservation standards, while also requiring the provision of unbundled parking, reducing parking requirements, expanding bicycle parking standards, establishing transportation demand management strategies, implementing new street and urban design standards, and providing access to a variety of transit options including frequent light rail and bus connections, shared vehicles and bicycles, and taxis.

Background The Cornfield Arroyo Seco Specific Plan (Proposed Plan) is a regulatory land use ordinance as permitted by Section 11.5.7 of Volume 1 of the City’s Municipal Code. The City establishes specific plans to address area specific land use needs and concerns. The Plan is the result of several years of planning and community engagement that involved community workshops, meetings and conversations with residents, employers, property owners, and community business, and environmental organizations as well as staff input from numerous City, County, State, and federal departments. The need for, and initial vision of the Proposed Plan arose from a variety of planning and infrastructure activities that occurred within the Proposed Plan area between 2004 and 2007. The primary activity that set the stage for the Proposed Plan was the LARRMP that was adopted by the City Council in 2007. The LARRMP re-imagined thirty-two miles of the Los Angeles River as a public amenity complete with continuous pedestrian and bicycle trails, mixed-use projects, parks and watershed management features. The LARRMP also identified much of the Plan area as an ideal location to showcase land use, watershed, open space and multi-modal connectivity innovations. While the LARRMP established an early vision for the area, two major infrastructure projects were beginning to encourage unplanned redevelopment in the Proposed Plan area. The opening of the light rail Gold Line in 2004 and the promise of the new Los Angeles State Historic

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Park, on the parcel commonly known as the “Cornfield,” spurred the entitlement of approximately 900 residential units on what had been industrially zoned properties. While residential uses are not an unwelcome attribute adjacent to either transit or park land, the area had not been previously planned to accommodate residential uses and many community amenities and support services were lacking. The City had also recently completed an industrial land use study that highlighted the negative economic impacts of industrial land conversions to residential uses and was therefore particularly sensitive to the impact of potentially losing additional industrially zoned properties. The zone changes did however highlight the area’s vulnerability to change and illustrated the need for a comprehensive development plan to leverage the transit and park infrastructure improvements, while also keeping in mind the multiple needs of residents and employees. Fortunately, the City’s Framework Element, adopted in 1995 and the Transportation Element, adopted in 1995, which comprise part of the City’s General Plan, set forth a variety of policies to encourage the very mix of uses that was beginning to occur in an ad-hoc fashion within the Plan area. In particular the General Plan encouraged the development of transit-oriented districts (TODs) in and around transit stations. These TODs were often envisioned as higher density places with a mix of land uses designed to accommodate pedestrians and bicyclists. The General Plan policies, combined with the vision established in the LARRMP, set the stage for a model planning opportunity whereby transit oriented and multi-mobility strategies could be blended with the interests of economic development, affordable housing, watershed enhancements, open space and connectivity. From the beginning, at the first workshop in September 2007 that was led by volunteer facilitators from the Western Justice Center, the community articulated a keen interest in seeing the Plan provide for safe and accessible passageways for pedestrians and bicyclists, additional open space, and access to the Los Angeles River and Arroyo Seco. The community also stressed the importance of providing for a mix of uses, especially near the transit stations and the State Park, which included affordable housing, along with community and employment uses. Community members also identified key industrial quarters that they wanted to protect, primarily along Main Street and the area currently defined as the Lincoln Heights Industrial Business Improvement District. Due to the area’s proximity to downtown, several universities, as well as transit and freeway infrastructure, these industrial properties, along with the City’s own vehicle storage and maintenance yards, are well suited to attract and retain a portion of the existing light industrial sector as well as the burgeoning clean technology industry. While the City requires many of the yards to remain within easy access to the downtown area and surrounding communities, a number of the properties are obsolete or dysfunctional. Redevelopment of these sites could attract key industrial employers, showcase examples of public/private partnerships, increase site efficiencies, and demonstrate principles of sustainable development. It is important to note the area’s historical prominence. Of particular significance are the four historic bridges, the Figueroa/Riverside Drive Bridge, North Broadway, Buena Vista Bridge, North Spring Street Viaduct, and the North Main Street Bridge. The oldest of these bridges is the North Main Street Bridge which was designed by Henry G. Parker and Hugo Eckardt and completed in 1910. The bridge is in fact the earliest of all of the monumental bridges built across the Los Angeles River, and one of only two dating to the first decade of the twentieth century. All four of the bridges were designated as City Historic-Cultural Monuments in the Spring of 2008. The Plan area also includes such significant historic locations as the Zanja Madre (pending National Register of Historic Places), William Mead (California Register of Historic Resources, and the Lincoln Heights Jail and Albion Cottages and Milagro Market which are both Los Angeles Historic/Cultural Monuments.

CPC-2009-598-SP A-3

The Proposed Plan anticipates that by 2035 the population within the Proposed Plan could reach 31,855, that there could be a total of 8.776 units and that there could be a total of 10,546 jobs. As of 2007 the population within the Proposed Plan was 5,304 and there were 1,448 housing units and 2,908 jobs. To enable this growth and to achieve the goals of the General Plan and the LARRMP the Proposed Plan establishes four new zoning districts: Urban Village, Urban Center, Urban Innovation, and Greenway. The Plan also includes an area-specific Density Bonus Option, a Community Benefit Option, and a Transfer of Floor Area (TFAR) program which together provide incentives for affordable housing, community benefits (open space, child care, library), and the preservation of lower-density industrial and residential uses, open space, and historic resources. The Plan includes a variety of standards addressing building form and massing, urban design, park, conservation, maintenance, noise, parking and streets. These are intended to regulate the urban form, promote open space, provide for a clean environment, minimize the effects of noise and vibrations, provide pleasant, safe, non-vehicular mobility options, and reduce energy and water consumption.

Discussion of Key Issues Focusing Growth near Transit Infrastructure At its heart, the Proposed Plan is a plan for sustainable, mixed-use transit-oriented development. As State law requires that the City plan for projected growth in population, housing, and employment levels, the Proposed Plan focuses this possible growth near existing transit infrastructure, such as the Metro Gold Line and key commercial corridors such as Spring Street, Main Street, Broadway, Figueroa, and San Fernando. Focusing growth around transit helps to reduce dependency on automobiles, expands mobility choices, encourages development with less impact on our roads, promotes sufficient density to support walkable communities, and supports increased use of existing transit infrastructure. Protecting and Enhancing Industrial Employment Centers Employment, and especially light industrial employment, is a critical component to ensuring the City’s future economic viability and success. The Proposed Plan was initiated at a time when the City’s Industrial Land Use Study neared completion, and as it became apparent that the Proposed Plan’s proximity to transit was putting scarce industrial land parcels at risk. In the immediate years leading up to the Plan’s initiation, 388 units of residential units had been constructed adjacent to the Gold Line’s Lincoln Heights/Cypress Park Station on what had once been a six-acre industrial site. Another 146 units were also constructed immediately south of this new large residential campus, further eroding the quantity of industrial land in the area. Just west of the station, 102 residential loft units were being constructed in a cast in-place concrete building from the 1920’s that had once been the headquarters for the Fuller Paint Company. And on the west side of the river, a stone’s throw from the Gold Line’s Chinatown Station, 300 residential units had been entitled. While residential uses around transit is often welcome, in this case, the City recognized that residential was being built in locations where it had not been planned for; therefore, needed residential services and amenities were not on hand, and the viability of those neighborhoods for continued use as industrial areas was being eroded. In 2007, when the Plan got underway, there were 2,908 jobs in the Plan area. A full 20% of the jobs were in the wholesale trade while approximately another 10% each were allocated to retail trade, education/health care, food and metal products. The remainder of the jobs was distributed among farming, mining/utilities, wood products, transportation/warehousing, delivery services/storage, finance/information, real estate, professional/administrative functions, entertainment, and services. At the time, 57% of the land area was comprised of residential uses, 12% was used for commercial activities, and 27% was utilized for industrial and public

CPC-2009-598-SP A-4

maintenance facilities. This blend of residential, commercial, retail and industrial uses is illustrative of the area’s balance, which the Plan wanted to protect and build upon. The three mixed-use zoning districts Urban Village, Urban Center, and Urban Innovation that are included in the Proposed Plan are intended to facilitate the continued utilization and expansion of light industrial and public uses in the area while also encouraging and supporting an influx of new commercial, retail, and residential uses. Providing Housing Options From the onset, housing has been a constant theme in the discussions about the Proposed Plan. A key focus of that discussion has been the need to provide affordable housing options. The area today has a number of affordable housing developments that provide income-restricted units for low-income and very-low income families and seniors. These developments include the 412 units at William Mead Housing which is operated by the Housing Authority of the City of Los Angeles (HACLA), as well as 369 units of family and senior housing that are managed by AMCAL. The rest of the housing in the area is divided between the approximately 400 units represented by older housing stock that is primarily located in the southeast portion of the Plan area, 46 units of market rate rental live-work at the Lacy Street Studios, and two relatively new condominium projects. The two condominium projects include the 102 units at Alta Lofts and the 165 units at Puerta del Sol immediately adjacent to the Gold Line’s Lincoln Heights/Cypress Park station. Both of these projects included subsidies to assist moderate income home buyers in purchasing their units. While the Proposed Plan includes incentives to encourage the development of additional affordable units, the Plan also hopes to attract a range of residential developments to the area. In order to incentivize residential developers, both affordable and market-rate alike, to include affordable units, the Plan establishes a 2.5 Base FAR in the Urban Village District for projects that wish to be largely residential. A residential project that desires more than a 2.5 Base FAR may utilize the Density Bonus Option to obtain up to an additional 1.5 FAR, for a total 4.0 FAR, with the inclusion of affordable units. Because a 3.0 FAR is typically recognized as the “optimum” FAR for residential development by limiting the Base FAR to a 2.5 it is expected that developers will be motivated to include affordable units in order to achieve a higher FAR. The Density Bonus Option includes two pathways; one for projects that obtain public financing and one for projects that do not utilize public financing. In both cases, developers may obtain up to a 4.0 FAR, are offered an Administrative Clearance process, and may utilize both on and off-menu incentives. Publicly Funded Projects Typically, publicly financed projects are for either “80-20” deals, whereby at least 20% of the units are set-aside for low-income households, or 100% affordable projects whereby all of the units are set-aside for income-qualified households. Projects that set aside 100% of their units for income-restricted households would automatically receive a 4.0 FAR and publicly financed projects that include at least 20% of their units for low-income or 11% of their units for very-low income households automatically receive a 3.375 FAR. Not Publicly Funded Non-publicly financed projects may obtain additional floor area by including affordable units for low, very-low, or extremely low-income households. For every square foot of a low-income unit that is built, the developer could build an additional two square feet of a market rate unit. For every square foot of a very-low income unit, an additional four square feet can be built, and for every square foot of an extremely low-income unit an additional six square feet can be built. Developers who build for-sale units may build an additional three square feet of a market rate unit for every square foot of an income-restricted moderate income unit.

CPC-2009-598-SP A-5

In addition to the formal Density Bonus Option, the Plan includes two strategies that will assist in ensuring greater affordability of new housing units. It is expected that, together, these strategies will provide an array of “market rate” units that are relatively affordable for the general work force. The first strategy includes the removal of a density cap and is described in detail here. The second strategy includes the removal of parking minimums and is detailed in the parking discussion below. In most places in the City, developers are limited as to the number of units that can be built, but in the Proposed Plan there is no such restriction. The lifting of this limitation will permit developers to respond to on-going changes that reflect demographic and economic shifts. This flexibility will permit developers to build smaller units within the limitations on total square footage, when and where market demand warrants. While smaller units are typically more expensive on a per square foot basis, they are still less expensive than larger units of a comparable bedroom size. Parking Due to the proximity to three Gold Line transit stations as well as seven local, two rapid and two DASH bus lines the Proposed Plan provides the natural location for the City to reduce its vehicle parking standards. Instead of establishing parking minimums the Plan instead includes parking maximums. A project may, if it desires, include no vehicle parking. Projects that do elect to include parking will then be subject to a requirement to include 5% of their spaces for vehicle charging stations and include both a shared vehicle parking space and a scooter/moped/motorcycle stall for every 25 units and/or 25,000 square feet of non-residential square footage. The addition of a car share and non-traditional vehicle spaces will provide additional mobility options for households who do not own a car for every licensed household member and will expand the opportunity for employees to arrive at work without a car knowing that a shared vehicle would be available for meetings, errands or unexpected off-site visits. While most areas of the City require a minimum of 2 to 2.5 parking spaces for each new residential unit and anywhere from one space for every 100 square feet (health clubs/restaurants) to one space for every 500 square feet (institutions) the Proposed Plan instead includes a parking maximum of one space/residential unit and one space per 1,000 square feet of non-residential uses. The Proposed Plan further requires developers to “unbundle” their parking from the rental or sale price of the unit and/or square footage.. By unbundling the price of a vehicle parking space from the rent or sale price of a residential unit renters or home buyers who do not have a vehicle or who have less than two cars will be able to obtain a unit less expensively than in other places in the City where two parking spaces are typically included in the rent or sale price. And, likewise an employee who is not automatically provided “free” parking as part of his/ her employment may be more inclined to explore alternative mobility options for his/her commute. Applicants who feel that the maximum parking requirement is too restrictive may include additional parking above the maximum, but the additional parking must be made available to the general public at times and prices established by the owner. There is no limit on the amount of publicly available parking that a project may include as long as it adheres to the parking design standards established in the Proposed Plan. The Plan released on August 6, 2012 included parking caps on the number of publicly available parking spaces in each sub-area of the Plan but after numerous conversations with the community, property owners and potential project developers the caps have been eliminated. Regardless of whether a project includes parking, bicycle parking must be included at a ratio of one bicycle parking space or locker for every two residential units and one bicycle space or locker for every 2,000 square feet of non-residential spaces. Parks shall be required to provide two bicycle parking spaces for every 15,000 square feet of park area. Mix of Uses

CPC-2009-598-SP A-6

In order to promote the continued mix of uses in the Proposed Plan area, the three new mixed-use districts, Urban Village, Urban Center, and Urban Innovation will each permit, to varying degrees, industrial, commercial, residential, retail and other assorted supporting and related uses. All three of the mixed-use districts permit light-industrial uses along with hotels, schools, public facilities, religious institutions, and non-profit organizations but they vary in regards to the degree to which residential and other non-industrial uses are permitted. In general, the Urban Village district can be described as the most permissive with respect to housing (up to 90% of the FAR) while in the Urban Center and Urban Innovation districts residential uses are limited to 15% of the FAR. The Urban Innovation district limits new commercial office space to 10% of the allowable Base FAR while commercial office space is permitted up to 65% in the Urban Village and Urban Center districts. In all three of the districts restaurants are permitted up to 10% of the FAR and retail and personal services are permitted up to 20% of the FAR. Entertainment, exhibit and cultural facilities as well as recreation facilities and spectator sports are permitted in the Urban Village and Urban Center but are limited to 10% of the FAR in the Urban Innovation district. Hybrid Industrial Land Use To accommodate this blend of uses the City establishes a new Hybrid Industrial Land Use designation. The Urban Village, Urban Center, and Urban Innovation districts are all corresponding zones within this new designation. Use Classification Recognizing the broad range of uses that are located within this area today, and in further recognition of the changing landscape of the industrial economy, the Plan establishes use classifications as opposed to the existing list of uses that are today in place for each zone type. Each of the use classifications is described in the Definitions section of the Plan and is intended to describe the general intent or types of activities typically associated with a use without identifying specific industries or products that would be associated with the use. In this way, new products or processes, or even new industries which are today not yet contemplated, may still find they are well suited and welcome in the area of the Proposed Plan. To provide greater clarity as to the intent of some of the proposed use classifications some of the use definitions have been modified (in track changes) since the August 6, 2012 draft. Conservation, Environmental, and Social Service Organizations, Public Facilities, and Religious Institutions There are several unique land use characteristics of the Proposed Plan that need to be described in more detail. The area has a relatively high proportion of non-profit organizations, public facilities and religious institutions located within its boundaries. The non-profits include such well-recognized and highly lauded organizations as Goodwill Industries, St. Vincent du Paul, Conservation Corps, and the Mountains Recreation and Conservation Authority (MRCA). Public facilities include city maintenance yards for the Bureau of Sanitation, the Department of Transportation, and the Los Angeles Fire Department. The religious institutions include Young Nak Church (the largest Korean-American church in the United States), and the headquarters for the Self-Realization Fellowship. Originally it was thought that the wide array of job activities (ranging from educational training, publishing, distribution, wholesale, and repair and maintenance activities) that these organizations engage in would be identified as permissible under the variety of “industrial” use classifications. Later, it was determined that it would be less confusing, and would reduce any future misinterpretation as to their suitability for the Plan area, and in particular the Urban Innovation zone, if these uses were combined into a single use classification: Public Facilities, Religious Institutions and Conservation, Environmental and Social Service Organizations. But religious assembly, which is unique among these other uses, has been provided its own category, These text changes are intended for clarification purposes and do not change the analysis or assumptions of the Final EIR.

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Riverways The Los Angeles River and Arroyo Seco are predominant features in the Proposed Plan. While both rivers have been severely degraded, lined in concrete, and buffered by railroad tracks (LA River) and obscured under by a freeway (Arroyo Seco) there are on-going local, regional, and federal efforts to improve both of these important waterways as community amenities that offer walking and bicycling paths along with habitat for local species. To assist with these other efforts the Proposed Plan preserves the existing 1.5:1 FAR within 300’ of the edge of both waterways. Property owners who elect not to develop within this River Buffer area may transfer the unused FAR to another portion of their property not located within the River Buffer or sell it through the Plan’s TFAR program. To promote visual connections to these rivers, property within the River Buffer area that is developed shall limit the building footprint to 50% of the site area. Parks and Open Space The Proposed Plan includes the Downey Recreation Center, Lacy Street Park, the temporary 11- acre LASHP, the recently completed Confluence Park, and the future Albion Dairy Park. The LASHP is expected to close sometime in 2013 for a year-long construction period during which the park will be expanded to 32 acres. Efforts continue between the City, Caltrans and the County to establish a greenway along the Arroyo Seco from Avenue 26 to San Fernando Road but no plans have been finalized. In addition to the parks within the Proposed Plan area, the area benefits from proximity to Elysian Park, Debs Park, and Taylor Yards. Not including the new 1.2 acre Confluence Park or the 6-acre Albion Dairy there a total of 814.80 acres of parks within two miles of the Plan and 88%, or 716, of those acres are within one mile. Assuming a future total (existing + new) population of 31,855 residents this translates into a total of 26 acres per 1,000 persons. If the future employment figures of 10,546 are added in there will be a total of 20 acres per 1,000 persons. The City’s park acreage standard sets a minimum of 4 acres per 1,000 persons. This relative abundance, compared to other very park poor areas of the City, does not mean, of course, that additional park area is not welcome. A portion of each of the properties currently utilized by the Fire Department and the Bureau of Sanitation have been zoned as Greenway with the expectation that in the future, as these sites are redeveloped, they would include public open space and/or recreational opportunities. The Fire Department site, as it is located in the center of the new Urban Village area and is in close proximity to the Five Points and Broadway shopping districts and Lincoln Heights residents could be particularly well adapted to recreational activities. In addition, all future projects will need to provide some portion of their site for open space. Projects are provided incentives to provide the space for public use. Pedestrian-Friendly Streets and Walkability Making the area’s streets more “walkable” is an important goal of the Proposed Plan that brings many benefits to the community, including improved mobility and quality-of-life improvements for local residents and employees, a reduced need to use automobiles for short trips, increased foot traffic for retail businesses, and a better experience for visitors. Walkability is influenced by a variety of factors including sufficient sidewalk widths, the presence of alleys and paseos, a mix of nearby uses, the design and orientation of adjacent buildings, and attractive streetscapes. To facilitate the development of this new “walkable” landscape the Plan includes a host of design standards including building form and massing and urban design standards. The Plan also modifies most of the existing street designations and establishes street design standards. Building Form and Massing The building form and massing standards will require applicants to build a percentage of their building in close proximity to the street-facing property line and to break up the base of the buildings so that no building face exceeds 300’ in length. The relationship of the building height to the width of the adjacent street plays a large role in determining the comfort level a pedestrian feels while walking on the street. A wide street with short buildings along it provides

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neither shade for the passerby or a scale that is conducive to pedestrians. A similarly wide street with buildings that are at least half as tall as the street is wide, provide a sense of enclosure and comfort for the pedestrian. To assist in providing this sense of an urban, public room, the Proposed Plan establishes an average minimum and maximum height limit. The resulting building heights will, in turn, produce building to street ratios between 1:0.5 and 1:1. The length of the block also plays a large role in promoting walkability. Due to the “industrial” nature of much of the area, many of the blocks are longer than the block length typically desired to promote pedestrian activity. Shorter blocks would also help reduce traffic speeds and therefore result in increased pedestrian and bicycle safety. To induce the development of shorter blocks, blocks that are in excess of the identified optimum for each of the three zoning districts (Urban Village- 450’, Urban Center-500’ and Urban Innovation -600’) are identified on the Maximum Block Length Map and developments that meet the identified criteria will be required to include a paseo or alley through their property. Urban Design To further enhance walkability, urban design standards are established to ensure that entrances are visible and accessible from the street, and that ground floor uses include, where suited, active uses such as retail, office, residential, lobby and sales areas, or meeting rooms. Projects are also required, again to varying degrees, to design a percentage of the street wall as transparent so that habitants and users of the spaces have sight lines to the out of doors but also so that passerbys have the comfort of knowing that they are not “invisible” to their surrounding urban environment. Other urban design requirements for windows/glazing, exterior lighting, and utilitarian building components further enhance the overall aesthetic environment of the Proposed Plan while reducing building heat gain, reducing the fatality and injury of birds due to collisions, and reducing night time light pollution. Streets for Pedestrians and Bicyclists The design of a street plays a large role in deterring or supporting a walkable environment. In the Plan area today most of the streets are devoid of street trees, pedestrian street lights and street furniture of any kind with the exception of a few transit shelters and bus benches. For the most part the sidewalk width is narrow and in some places, like along Humboldt Street they are non-existent. The Plan establishes modified street and sidewalk widths along with street tree and pedestrian street light requirements. New projects will need to comply with these new requirements along the portion of the street adjacent to their property. In addition to enhancing the environment for pedestrians the new street standards will enhance the environment for bicyclists as well. The new street standards implement the City’s 2010 Bicycle Plan by allowing for the addition of bicycle lanes on Broadway (west of the Los Angeles River), Figueroa, Main Street, Pasadena, San Fernando, Spring Street, and portions of Avenues 26, 19, and 18. Bicycle sharrow markings will be included on Avenue 26 between the Arroyo Seco Parkway and the Gold line Bridge, on Avenue 20 between Broadway and Main Street, and on Broadway (east of the Los Angeles River). Signage Due to the extent of sign regulations covered in L.A.M.C. 14.4 the signage chapter has been reduced in scope, since release of the August 6, 2102 Draft Plan, to avoid duplication and focus only on additional sign prohibitions that are desired. Transfer of Floor Area In order to protect existing historical and industrial properties as well as provide financial benefit to public parks and properties within the River Buffer the Proposed Plan includes a Transfer of

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Floor Area (TFAR) program that permits unused FAR to be transferred to another property within the Proposed Plan. Non-residential projects may purchase any unused FAR from an eligible property up to their maximum permitted FAR. Residential projects may purchase any unused FAR from any an eligible property up to their maximum permitted FAR in conjunction with the Bonus FAR program. LEED-ND (Leadership in Energy and Environmental Design–Neighborhood Development) During the initial months of the Plan’s conception back in 2007, the US Green Building Council (USGBC) initiated a pilot phase of its newest LEED rating system: LEED-Neighborhood Development (ND). The goal of the USGBC in developing the LEED-ND program was to expand the benefits of green building energy and conservation strategies to the neighborhood scale. The goals of LEED-ND seemed a perfect complement to the initial concepts for the Plan. The City, with the assistance of the Department of Water and Power, the Community Redevelopment Agency, and the non-profit Global Green, applied for and were accepted into the LEED-ND pilot program. The LEED-ND program provided a useful guide throughout the development of the Plan as a means to evaluate and set implementation standards for various conservation and design strategies. Because of the many years over which a typical LEED-ND project may be developed, the LEED-ND program, unlike other LEED programs, establishes three stages at which a project can achieve certification: Optional Pre-Review (Stage 1), Certification of an Approved Plan (Stage 2), and Certification of a Completed Neighborhood Development (Stage 3). Due to the time constraints imposed by the LEED-ND pilot program the City applied for, and received, Stage 1 certification in April 2010 based on the March 2009 draft of the Plan. The Plan achieved 44 of a possible 106 points and at the time was the only public project to have achieved LEED-ND certification. Due to the preliminary nature of the Plan at the time a number of points were not yet able to be documented fully and therefore were not accepted. Subsequent to our initial application, USGBC determined that any pilot project that did not complete either their Stage 2 or Stage 3 Certification would need to re-apply for LEED-ND certification under the regular LEED-ND program. While further recognition by the LEED-ND program of the multiple environmental benefits and smart growth outcomes resulting from the implementation of the Proposed Plan would certainly be welcome there are many challenges to pursuing further certification. First, there is a substantial cost (fee based on plan size + time to assemble application) in participating in a LEED-ND program. Secondly, the LEED-ND program, due to the extent of the details required for obtaining certification, is best suited for a project that is owned or at least controlled by a single entity, Given these constraints the Proposed Plan is not going to continue as a LEED-ND project but any number of property owners of adjoining parcels within the Proposed Plan may certainly select independently to pursue a separate LEED-ND Stage 2 or Stage 3 Certification for their properties. Environmental Analysis An Environmental Impact Report (EIR) has been prepared as part of the Proposed Plan to fully analyze and identify significant impacts of the Proposed Plan, evaluate project alternatives, develop feasible mitigations, and create a mitigation monitoring plan. The EIR is a program level document that meets the requirements of CEQA. Projects that are eligible for an Administrative Clearance will not need additional environmental review. Projects that require a Project Permit Compliance and that adhere to the standards of the Plan will be able to use this programmatic EIR as their project level environmental review. Projects that are not consistent with the Proposed Plan will require additional environmental review. These future project-level environmental reviews will be able, as appropriate, to tier off this EIR in accordance with the rules governing program level EIRs and tiering (California Public Resources Code, Section 21068.5, 21093, and 21094).

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A Final EIR was released on August 17, 2012, which included detailed responses to the comments that were received on both the Original DEIR and the Recirculated Portions (RP)-DEIR. The RP-DEIR included a discussion on construction air quality and health risks due to emissions from toxic air contaminants, the cumulative impacts of green house gas emissions, construction noise impacts and an expanded discussion of transportation impacts. A copy of the Original DEIR, the RP-DEIR, and Final EIR is attached as an exhibit to this report. This report also includes Findings to support the adoption of the Proposed Plan, including environmental findings in detail. There is also a Statement of Overriding Considerations in this report that is recommended for adoption by the City Planning Commission and City Council. Section 15088 of the CEQA Guidelines requires the lead agency (DCP) to evaluate comments on environmental issues from public agencies and interested parties who review the Original DEIR and RP-DEIR and provide written responses. DCP prepared responses in writing to all the comments received. A full analysis of the environmental setting, plan impacts, project alternatives, mitigations, and unavoidable significant impacts are contained in the Final EIR, Exhibit G of this report.

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FINDINGS 1. Charter Section 556 – That in accordance with Charter Section 556, the proposed

Cornfield Arroyo Seco Specific Plan (Proposed Plan- Appendix B) is in substantial conformance with the purposes, intent, and provisions of the General Plan. The Proposed Plan is consistent with, and helps to further accomplish goals, objectives, and policies contained in portions of the General Plan, including the Citywide General Plan Framework Element, as outlined below. The General Plan Framework establishes the standards, goals, policies, objectives, programs, terms, definitions, and direction to guide the update of citywide elements, community plans and the establishment of specific plans. Specifically, with respect to land use, the General Plan Framework states the following:

Objective 3.1: Accommodate a diversity of uses that support the needs of the City’s existing and future residents, businesses, and visitors.

Objective 3.2: Provide for the spatial distribution of development that promotes an improved quality of life by facilitating a reduction of vehicular trips, vehicle miles traveled, and air pollution.

The Proposed Plan provides for a variety of different land uses to meet the diverse needs of the community, including housing, retail, commercial and industrial businesses that contribute to the economy of the community as well as the Los Angeles region. The Southern California Association of Governments (SCAG) projects an increase in population, employment, and housing in the City through the year 2035. The Proposed Plan directs future growth to areas near transit where new development can be supported by transportation infrastructure and different types of land uses can be intermingled to reduce the length and number of vehicle trips. Mixed-use development around Metro stations and transit corridors would give residents and visitors mobility choices that would enable reduction in the number and length of vehicle trips thus reducing greenhouse gas emissions associated with local trip generation, in accordance with recent legislation (Senate Bill 375). By encouraging transit oriented development and making a strong connection between transportation and land use planning, the Proposed Plan promotes several principles that are key to creating livable communities, including: improved mobility options for residents, employees, and visitors; increased access to a wide range of uses; and expanded opportunity for location-efficient housing in the city. The Proposed Plan’s reasonable expected development capacity gives a degree of flexibility to accommodate additional employment to meet the requirements of the Sustainable Communities Strategy adopted by SCAG as part of the latest update to the Regional Transportation Plan (RTP) in accordance with Assembly Bill 32, the California Global Warming Solutions Act of 2006, and Senate Bill 375. These legislative acts require that California cities lay out a vision for regional growth that considers the relationship of land use to transportation in reducing vehicle trips to achieve greenhouse gas emission reduction targets. Because of significant transit infrastructure investment with the opening of the Gold Line Metro Rail service in 2004 and the presence of a Regional Center, Community Center and Mixed-Use Boulevard within the Plan area the Proposed Plan’s land use pattern can and should support increased transit use. Since this is an area where growth is anticipated and encouraged due to the area’s investment in transit infrastructure, the Proposed Plan’s increases in capacity are growth-accommodating rather than growth-inducing, consistent with policies in the General Plan Framework.

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Aside from accommodating future growth, if and when it occurs, there are other reasons for the targeted increase of capacity in the Proposed Plan area, such as focusing growth around transportation infrastructure, maintaining the City’s jobs/housing ratio, and conserving existing residential neighborhoods. The Proposed Plan redirects growth, strategically increasing capacity in certain areas in a manner that is consistent with the General Plan and achieves General Plan Framework goals. In its discussion of economic development policies, the Framework states:

“The baseline 2010 employment and housing forecasts prepared by SCAG indicate that the City’s jobs/housing ratio will decline by 2010. This decline would be economically detrimental to the City…In order to avoid the potentially detrimental consequences of a decline in the City’s jobs/housing ratio, the City must implement a proactive economic development program which seeks to generate employment growth commensurate with projected population increases. Maintenance of the existing jobs/housing ratio of 1.46 will require that the City attract approximately 400,000 new jobs, compared to the 200,000 new jobs indicated in the SCAG forecasts” (Chapter 7 – Economic Development).

The Framework is intended to offer “a strategy for long-term growth which sets a citywide context to guide the update of the community plan and citywide elements.” The Framework is not intended to cause population or employment growth to occur but, rather, to accommodate changes in population and employment that may occur in the future. The Proposed Plan is consistent with this framework for growth in that it concentrates future growth, should it occur as forecast, around commercial centers and corridors supported by transit infrastructure while limiting development in surrounding low-density neighborhoods.

Goal 3D: Pedestrian-oriented districts that provide local identity, commercial activity, and support Los Angeles’ neighborhoods.

Goal 3E: Pedestrian-oriented, high activity, multi- and mixed-use centers that support and provide for Los Angeles’ communities.

Objective 3.9: Reinforce existing community centers, which accommodate a broad range of uses that serve the needs of adjacent residents, promote neighborhood and community activity, are compatible with adjacent neighborhoods, and are developed to be desirable places in which to live, work and visit, both in daytime and nighttime.

Goal 3F: Mixed-use centers that provide jobs, entertainment, culture, and serve the region.

Goal 3I: A network of boulevards that balance community needs and economic objectives with transportation functions and complement adjacent residential neighborhoods.

Objective 3.13: Provide opportunities for the development of mixed-use boulevards where existing or planned major transit facilities are located and which are characterized by low-intensity or marginally viable commercial uses with commercial development and structures that integrate commercial, housing, and/or public service uses.

Goal 3J: Industrial growth that provides job opportunities for the City’s residents and maintains the City’s fiscal viability.

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Objective 3.14: Provide land and supporting services for the retention of existing and attraction of new industries.

Policy 3.14.2: Provide flexible zoning to facilitate the clustering of industries and supporting uses.

Policy 3.14.4: Limit the introduction of new commercial and other non-industrial uses in existing commercial manufacturing zones to uses which support the primary industrial function of the location in which they are located.

Goal 3K: Transit stations to function as a primary focal point of the City’s development.

Objective 3.15: Focus mixed commercial/residential uses, neighborhood-oriented retail, employment opportunities, and civic and quasi-public uses around urban transit stations, while protecting and preserving surrounding low-density neighborhoods from the encroachment of incompatible land uses.

With three Metro Gold Line light rail subway stations at Chinatown, Lincoln Heights/Cypress Park, and Heritage Square, the Plan Area contains prime locations for transit-oriented development. The significant regional investment made in transit infrastructure in the Proposed Plan area provides an opportunity for integrating transportation planning with land use planning in a way that concentrates future growth in population and employment in mixed-use development in areas within walking distance of transit service. In this manner, the Proposed Plan best accommodates growth as it occurs or may not occur over the life of the plan. The Proposed Plan builds upon these opportunities to concentrate growth and limit new development in existing low-density residential neighborhoods. These strategies promote improved livability both within the Proposed Plan and for the City at large, by encouraging the use of alternative forms of transportation, improving accessibility, and providing housing opportunities near centers of employment.

Policy 3.15.4: Design and site new development to promote pedestrian activity and provide adequate transitions with adjacent residential uses.

Policy 3.15.5: Provide for the development of public streetscape improvements, where appropriate.

Goal 3L: Districts that promote pedestrian activity and provide a quality experience for the City’s residents.

Objective 3.16: Accommodate land uses, locate and design buildings, and implement streetscape amenities that enhance pedestrian activity.

Making the area’s streets more walkable is an important goal of the Proposed Plan. Wide sidewalk widths, appropriate design and orientation of adjacent ground floor uses, provisions for street trees and furniture, and the reduction of block size all addressed in the Proposed Plan. A number of street designations have been modified to require larger sidewalk widths in the future. The design and orientation of buildings adjacent to sidewalks can either encourage or discourage pedestrian activity and the Proposed Plan addresses this important element of creating walkable environments by including ground floor design standards along key boulevards.

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Objective 3.17: Maintain significant historic and architectural districts while allowing for the development of economically viable uses.

The Proposed Plan also contains standards to protect buildings and places that are considered historically and culturally significant. For identified or potential historic resources the Proposed Plan requires conformance with the Secretary of the Interior’s Standards for Rehabilitation. To further provide an incentive for the preservation of historic resources the Plan includes a TFAR program that permits historic resources to sell the portion of their unused Base FAR to a receiving party. With respect to housing, the General Plan Framework states: Housing Policy – Framework Element policies address providing additional capacity for new housing units, encouraging production of housing for households of all income levels, while at the same time preserving existing residential neighborhood stability and promoting livable neighborhoods by the following measures: (1) concentrating opportunities for new multi-family residential, retail commercial, and office development in the City’s neighborhood districts, community, regional, and downtown centers as well as along primary transit corridors/boulevards; (2) providing development opportunities along boulevards that are located near existing or planned major transit facilities and areas characterized by low-intensity or marginally viable commercial uses with structures that integrate commercial, housing, and/or public service uses; (3) focusing mixed commercial/residential uses around urban transit stations, while protecting and preserving surrounding low-density neighborhoods from the encroachment of incompatible land uses (Chapter 4 – Housing).

Policy 4.1.1: Provide sufficient land use and density to accommodate an adequate supply of housing units by type and cost within each City subregion to meet the twenty-year projections of housing needs.

Objective 4.2: Encourage the location of new multi-family housing development to occur in proximity to transit stations, along some transit corridors, and within some high activity areas with adequate transitions and buffers between higher-density developments and surrounding lower-density residential neighborhoods.

Objective 4.3: Conserve scale and character of residential neighborhoods.

Objective 4.4: Reduce regulatory and procedural barriers to increase housing production and capacity in appropriate locations.

In addition, the City’s adopted Housing Element also contains policies on meeting the City’s housing needs, including:

Policy 1.1.3: Facilitate new construction of a variety of housing types that address current and projected needs of the city’s households.

Policy 2.2.1: Provide incentives to encourage the integration of housing with other compatible land uses.

Policy 2.2.3: Provide incentives and flexibility to generate new housing and to preserve existing housing near transit.

Policy 2.4.4: Promote residential development that meets the needs of current residents as well as new residents.

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The Proposed Plan is consistent with and helps to implement the above-stated housing objectives, policies, and programs of the City in that it encourages the development of additional housing for current and future residents in designated centers, transit oriented districts, and along mixed-use boulevards. As previously discussed, the Proposed Plan includes incentives for mixed-use development, which encourages the integration of housing with other compatible land uses as called for in the Framework Element. Additionally, the Proposed Plan provides for a mix of housing types, balancing additional housing at higher densities in appropriate locations near transit with the preservation of existing, lower density single-family neighborhoods in the south east portion of the Plan Area. The Proposed Plan promotes livable neighborhoods, consistent with the adopted Housing Element, by encouraging new residential development to be located near transit options and within proximity to a mixture of compatible uses, thereby increasing mobility options and improving accessibility to employment and activity centers. The Proposed Plan also includes urban design standards which help to implement an important program identified in the Framework. With respect to urban form and neighborhood design, the General Plan Framework includes the following goals, objectives, and policies:

Goal 5A: A livable City for existing and future residents and one that is attractive to future investment. A City of interconnected, diverse neighborhoods that builds on the strengths of those neighborhoods and functions at both the neighborhood and citywide scales.

Objective 5.1: Translate the Framework Element’s intent with respect to citywide urban form and neighborhood design to the community and neighborhood levels through locally prepared plans that build on each neighborhood’s attributes, emphasize quality of development, and provide or advocate “proactive” implementation programs.

Objective 5.2: Encourage future development in centers and in nodes along corridors that are served by transit and are already functioning as centers for the surrounding neighborhoods, the community, or the region.

Policy 5.2.1: Designate centers and districts in locations where activity is already concentrated and/or where good transit service is, or will be, provided.

Objective 5.5: Enhance the livability of all neighborhoods by upgrading the quality of development and improving the quality of the public realm.

Objective 5.6: Conserve and reinforce the community character of neighborhoods and commercial districts not designated as growth areas.

Objective 5.7: Provide a transition between conservation neighborhoods and their centers.

Objective 5.8: Reinforce or encourage the establishment of a strong pedestrian orientation in designated neighborhood districts, community centers, and pedestrian-oriented subareas within regional centers, so that these districts and centers can serve as a focus of activity for the surrounding community and a focus of investment in the community.

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The Proposed Plan is consistent with the City’s goals, policies, and objectives for urban form and neighborhood design in that it concentrates new growth in designated centers and in locations with access to public transportation. The Plan also provides transitions in scale between single-family neighborhoods and adjacent multi-family and employment areas through height limitations and design standards. Topic areas covered by the urban design standards include building orientation, scale, height and massing, parking and loading, pedestrian amenities, sustainability, on-site open space, landscaping, and building façade. The City’s Transportation Element of the General Plan contains a number of important policies related to the Proposed Plan, including:

Goal A: Adequate accessibility to work opportunities and essential services, and acceptable levels of mobility for all those who live, work, travel, or move goods in Los Angeles.

Objective 2: Mitigate the impacts of traffic growth, reduce congestion, and improve air quality by implementing a comprehensive program of multimodal strategies that encompass physical and operational improvements as well as demand management.

Policy 2.27: Discourage the vacation and/or closure of public alleys which service properties fronting on major or secondary highways.

Objective 3: Support development in regional centers, community centers, major economic activity areas and along mixed-use boulevards as designated in the Community Plans.

Policy 3.11: Develop programs for new development to implement both transportation improvements and demand reduction programs which mitigate the circulation impacts attributable to new development in accordance with State nexus legislation and judicial findings.

Policy 3.13: Enhance pedestrian circulation in neighborhood districts, community centers, and appropriate locations in regional centers and along mixed-use boulevards; promote direct pedestrian linkages between transit portals/platforms and adjacent commercial development through facilities orientation and design.

Policy 3.16: Promote implementation of the Land Use/Transportation Policy as adopted by City Council and endorsed by the LACMTA Board which encourages economic development in proximity to transit centers.

Objective 4: Preserve the existing character of lower density residential areas and maintain pedestrian-oriented environments where appropriate.

Policy 4.3: Seek to provide access patterns and circulation improvements that preserve the existing character of neighborhood retail areas.

Goal C: An integrated system of pedestrian priority street segments, bikeways, and scenic highways which strengthens the City's image while also providing access to employment opportunities, essential services, and open space.

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Objective 10: Make the street system accessible, safe, and convenient for bicycle, pedestrian, and school child travel.

The Proposed Plan is consistent with the Transportation Element of the General Plan in that it concentrates future employment and housing in accessible locations near transit stations, thereby helping to minimize increases in vehicle trip generation and improve air quality. The Proposed Plan contains modified street standards which plan for wider sidewalk widths where current dimensions do not provide for adequate pedestrian circulation. Other General Plan Elements also contain policies and programs related to the Proposed Plan, including the Air Quality Element, the Open Space Element, and the Public Recreation Plan of the Service Systems Element. Some of these policies include:

Air Quality Element Policy 4.2.1: Revise the City’s General Plan/Community Plans to achieve a more compact, efficient urban form and to promote more transit-oriented development and mixed-use development.

Open Space Element Policy: Private development should be encouraged to provide ample landscaped areas, malls, fountains, and other aesthetic features which emphasize open space values through incentive zoning practice or other practicable means.

Service Systems Element – Public Recreation Plan Policies:

• Recreational facilities and services should be provided for all segments of the population on the basis of present and future projected needs, the local recreational standards, and the City's ability to finance.

• Recreational use should be considered for available open space and unused or

underused land, particularly publicly owned lands having potential for multiple uses.

The Proposed Plan is consistent with the General Plan in that it helps to implement policies contained in a number of the other Elements, including the Air Quality Element, Open Space Element, and the Service Systems Element – Public Recreation Plan. As stated previously, the Proposed Plan promotes transit-oriented development and mixed-use development for a number of reasons, one of which is to help the City to achieve regional air quality benefits over traditional, single-use sprawl development. This is consistent with the Air Quality Element which encourages the City to develop in a more compact, efficient urban form. In support of the Open Space Element, the Proposed Plan includes design standards to maximize the provision of pedestrian amenities, landscaped plazas, paseos, and other open spaces as part of new development. In addition, the Proposed Plan encourages the development of alleys and/or paseos to enhance access to private development, promote pedestrian circulation, and provide enhanced urban open space opportunities. In summary, the Proposed Plan is consistent with the City’s General Plan in that it provides for an arrangement of land use, circulation, and services which will encourage and contribute to the economic, social, and physical health, safety, welfare, and convenience of the community, within the larger framework of the City of Los Angeles. At its heart, the Proposed Plan is a plan for sustainable, transit-oriented development. As State law requires that the City plan for growth in population, housing, and employment levels and in consideration of new state requirements contained in SB 375, the Proposed Plan focuses this possible growth

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near existing transit infrastructure, such as the Metro Gold Line and commercial corridors with high levels of bus service. This approach helps to reduce dependency on automobiles, and offers mobility choices, encourages development with less impact on roads, promotes sufficient density to support walkable communities, and supports increased use of existing and planned transit infrastructure.

2. Charter Section 558- That in accordance with Charter Section 558(b)(2), the Proposed Plan will have no adverse effect upon the General Plan, or any other plans being created by the Department of City Planning in that the Proposed Plan is consistent with the City’s General Plan and directly implements the policies of the Framework Element for the reasons stated in the findings above. In addition, the Proposed Plan will be in conformity with public necessity, convenience, general welfare and good zoning practice for all of the reasons previously described. One of the objectives of the Proposed Plan is to promote economic well being and public convenience through the allocation and distribution of lands in sufficient quantities to satisfy the housing, commercial, retail, service, industrial, and open space needs of the community. The Proposed Plan accomplishes this by revising the zoning and design standards to facilitate the development of future growth in a mix of uses in proximity to public transportation and existing open space amenities while also limiting further intensification of existing low-density residential neighborhoods. The Proposed Plan follows good zoning practice in implementing building form, urban design, open space, parking, conservation, performance and street standards that promote a safe, comfortable, and inviting physical environment to encourage walking, bicycling and the use of transit.

3. California Environmental Quality Act (CEQA) – HAVING RECEIVED, REVIEWED, AND

CONSIDERED THE FOLLOWING INFORMATION AS WELL AS ALL OTHER INFORMATION IN THE RECORD OF PROCEEDINGS ON THIS MATTER, THE CITY PLANNING COMMISSION HEREBY FINDS AND RECOMMENDS THAT THE CITY COUNCIL OF THE CITY OF LOS ANGELES FIND, DETERMINE, AND DECLARE AS FOLLOWS:

I. CERTIFICATION OF THE FINAL EIR The City Council of the City of Los Angeles (the “City”) hereby finds that the Final Environmental Impact Report State Clearinghouse No. 2009031002, dated August 2012 (the “Final EIR”) for the Proposed Plan described below has been completed in compliance with the California Environmental Quality Act (CEQA), Public Resources Code Section 21000 et seq. This Final EIR is being certified in connection with all approvals required to implement the Project. The City determined an EIR was necessary to analyze the potential environmental effects of the Proposed Plan. The Notice of Preparation (NOP) for a draft EIR (the “Draft EIR”) was first circulated on March 3, 2009 for the required 30-day review period. Due to a change in the Project Description that contemplated the development of a Redevelopment Project Area for the Plan area, a second NOP was prepared and circulated November 3, 2010 through December 15, 2010. 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: Chp 3-Land Use; Chp-4 Transportation; Chp-5 Visual Resources; Chp-6 Earth Resources; Chp-7 Hydrology and Water Quality; Chp-8 Biological Resources; Chp-9 Cultural Resources; Chp-10 Hazardous Materials; Chp-11 Air Quality; Chp-12 Noise and Vibration; Chp-13 Population, Housing and Employment; Chp-14 Public Services; Chp-15 Utilities; and Chp-16 Energy and Greenhouse Gases.

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The Original DEIR was prepared and circulated for a period of 60 days (in excess of the 45-day public review period required by State Law), beginning on September 22, 2011, and ending on November 21, 2011. The lead agency also accepted a comment letter received after the comment period closed. The lead agency received 41 written comments on the Draft EIR from public agencies, groups and individuals. In response to the comments the lead agency prepared and circulated, for a period of 45 days, a Recirculated Portions (RP) DEIR that replaces several portions of the Original DEIR. The RP-DEIR included a discussion on construction air quality and health risks due to TAC (Toxic Air Contaminants) emissions (Chp 2A), cumulative Greenhouse Gas (GHG) impacts (Chp 2B), construction noise impacts (Chp 2C), and an expanded discussion of transportation impacts (Chp 2D). The comment period for the RP-DEIR began on May 31, 2012 and ended on July 16, 2012. The lead agency received another nine written comments on the RP-DEIR from public agencies, groups and individuals. Responses to all comments received during both the comment period for the Original and RP-DEIR are included in the Final EIR. II. ENVIRONMENTAL FINDINGS Section 21081 of the California Public Resources Code and Section 15091 of the State CEQA Guidelines (the “Guidelines”) require a public agency, prior to approving a project, to identify significant impacts of the project and make one or more of three possible findings for each of the significant impacts.

1. Changes or alterations have been required in , or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR (Guidelines Section 15091 (a)(1)); and

2. Such changes or alterations are within the responsibility and jurisdiction of

another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (Guidelines Section 15091 (a)(2)); and

3. Specific economic, legal, social, technological, or other considerations, including

provision of employment opportunities for highly trained workers, make infeasible, the mitigation measures or project alternatives identified in the final EIR. (Guidelines, Section 15091 (a)(3)).

For those significant effects that cannot be mitigated to a level below significance, the City is required to find that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment. All Final EIR mitigation measures, as discussed herewith and as set forth in the Proposed Plan’s Mitigation Monitoring Plan (the “MMP”- included in the Final EIR in Appendix A1, and contained herein as Exhibit F) are incorporated by reference into these findings. In addition, any revisions to the Plan that have occurred during the administrative process are incorporated by reference into these findings. In accordance with the provisions of CEQA (California Public Resources Code §§ 21000, et seq.) and the CEQA Guidelines (California Code of Regulations Title 14, Chapter 3, §§ 15000 et seq.), these findings are hereby adopted as part of the certification of the Final EIR and adoption of a Statement of Overriding Considerations for the Plan. III. ENVIRONMENTAL IMPACTS FOUND TO BE LESS THAN SIGNIFICANT WITHOUT MITIGATION

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The City of Los Angeles Planning Department prepared two Initial Studies for the Plan, the first was dated March 2009 and a second was prepared for the second Scoping Meeting in November 2010. The Studies both determined that the Proposed Plan would not have the potential to cause significant impacts in the following areas: Mineral Resources and Recreation. The Final EIR found that the following environmental impacts of the Proposed Plan will be less-than-significant without mitigation measures: A. Land Use (Chapter 3) Description of Potentially Significant Effects. As the Final EIR concluded, the implementation of the Plan would not cause significant impacts with respect to land use and mitigation measures are not required. A significant impact could occur if the Proposed Plan were to result in physically dividing an established community, conflict with any applicable land use plan, or conflict with any applicable habitat conservation or natural community plan. Development permitted by the Proposed Plan will enhance connections between established communities, including Lincoln Heights, Chinatown, and Solano Canyon through building and streetscape design standards enhancing streetscape quality and visual surveillance of streets and other public spaces. The Proposed Plan includes General Plan Amendments, where required, to ensure that land use designations are consistent with existing and proposed changes to zoning. The Proposed mixed-use zoning districts are informed by national and international best-practices and research indicating that such development reduces automobile travel and increases regional transit services as well as pedestrian activity and bicycle use. The arrangement and mix of land uses within the Proposed Plan are intended to reduce both mobile and stationary source GHG emissions through increasing transit ridership, facilitating the development of new businesses and requiring that the operation of residential, commercial, and industrial buildings is conducted in an energy and water-efficient manner. The Proposed Plan is not within any areas to which a habitat conservation plan or natural community plan applies. Therefore, the implementation of the Proposed Plan would have a less than significant impact on land use.

B. Visual Resources (Chapter 5) Description of Potentially Significant Effects. As the Final EIR concluded, the implementation of the Plan would not cause significant impacts with respect to visual resources and mitigation measures are not required. A significant impact could occur if the Proposed Plan were to conflict with plans, policies, or regulations governing scenic resources; have a substantial adverse effect on a scenic vista, resource or public viewshed, substantially damage scenic resources; substantially degrade the existing visual character or quality of the area; adversely degrade area-wide architectural character; create a new source of substantial light or glare, or cast shadows that substantially impair the function of a building or the beneficial use of any public park or open space. The Proposed Plan will include regulations that control for the overall lot development, set-backs, height, bulk, scale and form of buildings, and exterior nighttime illumination to protect viewsheds, enchance the urban form of the area, and control light pollution into the nighttime sky, adjacent properties, and/or sensitive habitat areas. Therefore, the implementation of the Proposed Plan would have a less than significant impact on visual resources. C. Population, Housing, and Employment (Chapter 13) Description of Potentially Significant Effects. As the Final EIR concluded, the implementation of the Plan would not cause significant impacts with respect to population, housing, and employment and mitigation measures are not required. A significant impact would occur if the

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Proposed Plan were to result in population, housing and/or employment growth that would induce substantial population growth in an area such that the area exceeds projected/planned levels beyond what was previously evaluated in the General Plan and that increase would, in turn, result in physical impacts to the environment; displace substantial numbers of existing housing units and/or residents and thereby necessitating construction of replacement housing elsewhere in excess of the contained in the housing element; displace substantial numbers of business and jobs in excess of that contemplated in the General Plan; or otherwise be inconsistent with adopted City and regional housing policies. The Proposed Plan encourages the production of a range of housing types to be built in proximity to the urban core and thus close to jobs, infrastructure and services, accommodates projected population and employment growth, and facilitates the development of a range of uses to encourage a jobs/housing balance and therefore would have a less than significant impact on population, housing and employment. D. Public Services (Chapter 14) Description of Potentially Significant Effects. As the Final EIR concluded, the implementation of the Plan would not cause significant impacts with respect to public services and mitigation measures are not required. A significant impact would occur if the Proposed Plan were to result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities in order to maintain acceptable service ratios response times or other performance objectives for fire and emergency medical services, police protection, public schools, parks, or other facilities such as libraries , and/or increase the use of existing parks and other recreational facilities such that substantial physical deterioration would occur or be accelerated. The Proposed Plan includes land uses and zoning that will continue to permit fire and emergency medical services, police protection services, public schools, parks and recreation, and other public and community facilities, establishes open space and paseo requirements, and provides additional floor area ration in exchange for the inclusion of branch libraries, publicly accessible open space, child care, schools, or other community amenities. Therefore, the Proposed Plan would have a less than significant impact on public services.

IV. ENVIRONMENTAL IMPACTS FOUND TO BE LESS THAN SIGNIFICANT WITH MITIGATION The Final EIR found that the following environmental impacts of the Proposed Plan will be less-than-significant with the implementation of mitigation measures. A. Earth Resources (Chapter 6) Description of Potentially Significant Effects. The Proposed Plan could have a significant earth resources impact if it would expose people or structures to potential substantial adverse effects including the risk of loss, injury or death involving rupture of a known fault, strong seismic ground shaking, seismic-related ground failure-including liquefaction and lateral spreading- or seismically induced landslides and ground cracking; result in substantial soil erosion or loss of topsoil; be located on geologic soil that is unstable; be located on expansive soil; have soils incapable of adequately supporting the use of septic tanks; or result in the loss of a known valuable mineral resource. All new projects, within the Proposed Plan will be subject to City requirements related to grading and construction, including the use of best management practices intended to prevent soil erosion and loss of topsoil. However, implementation of the Proposed Plan could subject projects to significant impacts resulting from seismic activity and liquefaction. Without measures to analyze the potential for ground shaking and a geotechnical report to asses potential consequences of any

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liquefaction and soil strength loss the potential impact is considered to be significant. However, as the Final EIR concluded, implementation of Earth Resources Measures 6.1 through 6.3 would reduce the Plan’s potential impacts on earth resources to a level of less-than-significant. Mitigation Measure 6.1: Seismic Standards. All projects shall conform to the California Building Code Seismic standards as approved by the Department of Building and Safety. Mitigation Measure 6.2: Geotechnical Report. Submit a geotechnical report that assesses potential consequences of any soil strength loss, estimation of settlement, lateral movement or reduction in foundation soil-bearing capacity, and discuss mitigation measures that may include building design consideration. Mitigation Measure 6.3: Liquefaction. Submit a geotechnical report that assesses potential consequences of any soil strength loss, estimation of settlement, lateral movement or reduction in foundation soil-bearing capacity, and discuss mitigation measures that may include building design consideration. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to seismic activity and liquefaction to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. B. Hydrology and Water Quality (Chapter 7) Description of Potentially Significant Effects. The Proposed Plan could have a significant hydrology and water quality impact if it would violate water quality standards or waste discharge requirements, substantially deplete groundwater supplies or interfere with groundwater recharge, substantially alter the existing drainage patterns of the area, create or contribute water runoff that would exceed the capacity of the stormwater drainage systems, or, expose people or structures to significant risk of loss, injury, or death involving flooding. The existing hydrologic conditions of the area have substantively deteriorated as a result of urbanization. With the exclusion of the LASHP and several small open space areas and backyards, nearly the entire area of the Proposed Plan has been paved or developed with structures. All surface drainages have been placed in culverts beneath the surface. All new projects, within the Proposed Plan will be subject to the County’s National Pollutand Discharge Eliminatin System (NPDES) permits and the City’s Stormwater and Urban Runoff Pollution Control and Stormwater Pollution Control Measures for Development Planning and Construction Activities, and Low-Impact Development (LID) requirements. Implementation of the Proposed Plan could place housing or structures in locations that could impede or redirect flood flows within a 100-year flood plain and shallow perched conditions could impact proposed developments. Without measures to protect structures located in the approximately 28 acres of the Proposed Plan that area located within the 100-year floodplain, and without an evaluation that infiltration of stormwater can be accomplished without raising groundwater conditions to such a level that they could adversely affect facilities or structures the potential impact is considered to be significant. However, as the Final EIR concluded, implementation of Hydrology and Water Quality Measures 7.1 through 7.5 would reduce the Plan’s potential impacts on hydrology and water quality to a level of less-than-significant. Mitigation Measure 7.1: Floodplain. Projects located within the 100 year flood plain shall comply with the requirements of the Flood Hazard Management Specific Plan, and shall

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obtain any required concurrence from FEMA that the new development complies with the requirements of that agency. Mitigation Measure 7.2: Stormwater Infiltration. All projects shall, as part of their compliance with the LID ordinance, demonstrate that the infiltration of stormwater on the site will not raise groundwater conditions to such a level that they would adversely affect existing facilities or structures.. Mitigation Measure 7.3: Dewatering System. Projects that impact groundwater quantity as a result of additions or withdrawals, or through interception of an aquifer by cuts or excavations, or through substantial loss of groundwater recharge capacity shall modify the structural design of a building so as not to need a permanent dewatering system. Mitigation Measure 7.4: Stormwater Pollution Prevention. Projects shall comply with the following requirements:

• Leaks, drips and spills shall be cleaned up immediately to prevent contaminated soil on paved surfaces that can be washed away into the drains.

• All vehicles/equipment maintenance, repair and washing shall be conducted away from storm drains. All major repairs shall be conducted off-site.

• Pavement shall not be hosed down at material spills.

• Dumpsters shall be covered and maintained. Mitigation Measure 7.5: Standard Urban Stormwater Mitigation Plan. All projects must comply with the Standard Urban Stormwater Mitigation Plan (SUSMP). Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to seismic activity and liquefaction to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. C. Biological Resources (Chapter 8) Description of Potentially Significant Effects. The Proposed Plan could have a significant biological resources impact if it would have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species; effect any riparian habitat or other sensitive natural community, federally protected wetlands ; interfere substantially with the movement of any resident or migratory fish or wildlife species; or, conflict with the provisions of an adopted Habitat Conservation Plan or other approved local, regional, or state habitat conservation plan. Due to the urbanization of the area there is limited native vegetation and the site is not located within any federally or State designated critical habitat and it is assumed that no sensitive plants are expected to occur due to lack of suitable habitat. However, implementation of the Proposed Plan could disturb potential nesting bird in buildings, shrubs and trees and/or result in removing oak trees that are native to the site. Without measures to protect bird species and native oak trees the potential impact is considered to be significant. However, as the Final

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EIR concluded, implementation of Biological Resources Measures 8.1 and 8.2 would reduce the Plan’s potential impacts on biological resources to a level of less-than-significant. Mitigation Measure 8.1: Habitat Modification. All projects that require a grading and/or building permit are subject to standards that require them to either avoid disturbances that take place during the breeding bird season or to comply with a set of requirements that includes, but is not limited to, bird surveys, monitoring, the establishment of a buffer zone, and/or the development of a mitigation plan. Mitigation Measure 8.2: Oak Trees. All projects that require a grading and/or building permit shall prepare a Tree Report, prepared by a Tree Expert that includes measures to ensure the protection, relocation, or replacement of any affected trees. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to birds and oak trees to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. D. Cultural Resources (Chapter 9) Description of Potentially Significant Effects. The Proposed Plan could have a significant cultural resources impact if it would cause a substantial adverse change in the significance of an archaeological resource; directly or indirectly destroy a unique paleontological site or unique geological feature; disturb any human remains; or cause a substantial adverse change in the significance of an historic resource. Although the area of the Proposed Plan has been extensively disturbed over the past 150 years or more, implementation of the Proposed Plan has the potential to affect the historic integrity of cultural resources. Without measures to halt and/or monitor sites where any prehistoric or historic subsurface cultural resources or human skeletal remains are discovered, or the ability to require that historic resources, or potential historic resources have demonstrated compliance with the Secretary of the Interior’s Standards for Historical Resources the potential impact is considered to be significant. However, as the Final EIR concluded, implementation of Cultural Resources Measures 9.1 through 9.3 would reduce the Plan’s potential impacts on cultural resources to a level of less-than-significant. Mitigation Measure 9.1a: Archaeological Resources. In the event that archaeological materials are discovered all activities shall halt and the services of an archaeologist shall be secured who shall assess the discovered material and prepare a survey, study or report evaluating the impact. Mitigation Measure 9.1b: Paleontological Resources. If any paleontological materials are encountered all activities shall halt and the services of a paleontologist shall be secured who shall assess the discovered material and prepare a survey, study or report evaluating the impact. Mitigation Measure 9.1c: Human Remains. In the event that human remains are discovered work must stop immediately and contact the County Corner. If the remains are Native American the Coroner has 24 hours to notify the Native American Heritage Commission Mitigation Measure 9.2: Historic Resources. Projects that could potentially impact an identified or eligible historic resource shall demonstrate compliance with the Secretary of the Interior’s Standards for Historic Resources.

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Mitigation Measure 9.3: Native American Gabrielino Ground Disturbance Monitor. All projects that require a grading permit which include ground disturbances 15’ or more below the surface shall retain a Native American of Gabrielino descent to observe and monitor sub-surface activities. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to archeological and paleontological resources, human remains, and historic resources to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. E. Hazardous Materials (Chapter 10) Description of Potentially Significant Effects. The Proposed Plan could have a significant hazardous materials impact if it would create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, or through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; emit hazardous emissions or wastes within ¼ mile of an existing or proposed school, be located on a site that is included on a list of sites compiled pursuant to Government Code Section 65962.5; impair implementation of a, or physically interfere with an adopted emergency response plan; or expose people or structures to a significant risk of loss, injury or death involving wild fires. All new projects, within the Proposed Plan will be subject to City requirements related to the renovation or demolition activities which could release lead from lead-based paints, asbestos from materials with insulation and piping, and other hazardous materials, the handling of methane, abandoned wells, storage tanks, and the establishment of an emergency evacuation plan. However, implementation of the Proposed Plan could subject projects to significant impacts resulting from the transport, use or disposal of hazardous materials, an upset or accident involving the release of hazardous substances and the use, storage or management of hazardous materials within ¼ mile of schools, and development of sites on the Cortese List. Without measures that approve plans for the transport, creation, use, containment, treatment and disposal of hazardous materials, require a Phase I Environmental Assessment, the establishment of a dewatering and treatment plan, and/or soil Remediation Action Plan the potential impact is considered to be significant. However, as the Final EIR concluded, implementation of Hazardous Resources Measures 10.1 through 10.4 would reduce the Plan’s potential impacts on earth resources to a level of less-than-significant. Mitigation Measure 10.1 and 10.2: Hazardous Substances. All industrial uses shall obtain a letter from the Fire Department stating that it has permitted the facility’s use, storage, transport, creation and disposal of hazardous substances. Mitigation Measure 10.3: Hazardous Materials near Schools. All commercial or industrial uses within ¼ mile of a school shall obtain a letter from the Fire Department stating that it has permitted the facility’s use, storage, transport, creation and disposal of hazardous substances. Mitigation Measure 10.4: Contaminated Soil or Groundwater. Prior to the issuance of a grading permit all projects shall conduct a Phase 1 Environmental Assessment (ESA). If the Phase I ESA determines that potential exists for contaminated soil or groundwater than the project shall conduct a Phase II ESA and follow its recommendations. Projects with an open case with the Los Angeles Regional Water Quality Board and/or the Department of Toxic

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Substance and Control and/or future uses of the Bortz Oil Company and/or the Kennington LTD will have to comply with the specific measures outlined in MM 10.4. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to the use, storage, transport, creation and disposal of hazardous substances and development of projects with contaminated soil or groundwater to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. F. Utilities (Chapter 15) Description of Potentially Significant Effects. The Proposed Plan could have a significant utilities impact if it would exceed wastewater treatment capabilities of LADWP; cause a measureable increase in wastewater flows; substantially or incrementally exceed the future scheduled capacity of any one wastewater treatment plant; require or result in the construction of new water or wastewater treatment facilities or stormwater drainage facilities; result in insufficient water supplies; or result in insufficient solid waste disposal capacity. All new projects within the Proposed Plan would be required to meet the City’s Water Management Ordinance which imposes numerous water conservation measures and the Final EIR found that impacts to solid waste disposal capacity to be less than significant without the addition of mitigations. However, implementation of the Proposed Plan could subject projects to significant impacts resulting from insufficient potable water, a wastewater conveyance system, electricity, natural gas, or access to an IT/communication system. However, as the Final EIR concluded, implementation of Utilities Mitigation Measures 15.1 to 15.5 would reduce the Plan’s potential impacts on utilities to a level of less-than-significant. Mitigation Measure 15:1 Water. All projects shall install a separate water meter for irrigation, install restroom faucets with a self-closing design, be prohibited from installing single-pass cooling equipment, install and utilize only high-efficiency clothes washers and dishwashers, and any application that includes a car wash shall incorporate a water recycling system. Mitigation Measure 15.2: Wastewater. All projects shall include a holding tank large enough to hold three times the project’s daily wastewater flow and install a grey water system to reuse wastewater from the project. Mitigation Measure 15.3: Electricity. Projects shall obtain confirmation from LADWP that the existing electrical supply infrastructure can meet the project’s potential energy demand. Mitigation Measure 15.4: Natural Gas. Projects shall obtain confirmation from the Southern California Gas Company that the existing gas supply infrastructure can meet the project’s potential natural gas demand. Mitigation Measure 15.5: IT/Communications. Projects shall obtain confirmation from the local IT/Comm provider that the existing infrastructure can meet the project’s potential IT/Communications services. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to supply, distribution and/or disposal of water, wastewater, electricity, gas or IT/Communications to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and

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included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. G. Greenhouse Gas Emissions (Chapters 16 and 2B) Description of Potentially Significant Effects. The Proposed Plan would have a significant greenhouse gas impact if the Proposed Plan would result in an increase in reliance on natural gas and oil when compared to the Unmitigated Growth (“Business as Usual”) scenario (2035), would result in less than the GHG emission reductions determined necessary to meet the state AB 32 goals for 2020 (16 percent below the “Business-as-Usual”), and would conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. All new projects, within the Proposed Plan will be subject to requirements related to the provision of infrastructure for recycled water. However, implementation of the Proposed Plan could subject projects to significant impacts without measures to reduce a project’s energy demand and implementation of the City’s Climate Action Plan the potential impact is considered to be significant. However, as the Final EIR concluded, implementation of Green House Gas Emissions 16.1 and 16.2 would reduce the Plan’s potential impacts on greenhouse gas emissions to a level of less-than-significant. Mitigation Measure 16.1: Energy Generation. All projects shall supply 20 percent of non-residential and 10 percent of residential energy demand with renewable energy generation. Mitigation Measure 16.2: Climate Action Plan. The City shall implement the Climate Action Plan. Findings. The mitigation measures are feasible and would avoid potentially significant impacts related to greenhouse gas emissions to a less than significant level for the reasons set forth in the Final EIR. The City Planning Commission hereby directs these measures be adopted. Implementation of these measures, which have been required or incorporated into the Proposed Plan, and included in the Mitigation Monitoring Plan (MMP), would substantially lessen the severity of a potentially significant effect to a less-than-significant level. V. ENVIRONMENTAL IMPACTS FOUND TO BE SIGNIFICANT AND UNAVOIDABLE

The Final EIR includes mitigation measures that will either avoid or provide substantial mitigation of the Plan’s identified potentially significant environmental effects, including potentially significant cumulative effects; however, certain environmental effects cannot be feasibly mitigated to a level of insignificance. Consequently, in accordance with CEQA Guideline 15093, a Statement of Overriding Considerations has been prepared to substantiate the City’s decision to accept these unavoidable significant effects when balanced against the significant benefits afforded by the Plan. A. Transportation (Chapters 4 and 2D) Description of Significant Effects. As the Final EIR concluded, the implementation of the Proposed Plan would result in an unavoidable significant adverse impact to transportation and traffic based on the City’s adopted thresholds of significance. In 2035 under the Proposed Plan significant changes would occur at nine of the 43 study area intersections (9 of the 29 signalized intersections studied) include six signalized study intersections outside of the Proposed Plan area. The Proposed Plan includes Transportation Demand Management (TDM) Strategies (Mitigation Measure Transportation 4.1) that will require future projects to unbundle parking,

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provide bicycle facilities, a Transportation Information Center, and rideshare or carshare parking, and include parking for scooters, mopeds, and motorcycles. In addition, projects seeking a Project Permit Compliance, or otherwise requiring additional environmental analysis may be required to include additional TDM strategies such as a Transit Pass. Subsidy Plan, parking cash out, guaranteed ride home, flexible work hours, commuter club, ridesharing services plan, and flex work trips. While the TDM strategies along with new parking maximum standards and required street enhancements (pedestrian lighting, street trees, wider sidewalks) and urban design features have been included to reduce the transportation impacts of the Proposed Plan to the extent feasible, impacts remain significant and unavoidable. Findings. The City adopts CEQA Findings 1 and 3. (see reference on page F-9) Facts in Support of Findings. The Proposed Plan would have a significant transportation impact if: (1) the “volume-weighted” average V/C ratio under the 2035 Proposed Plan for all of the analyzed signalized intersections exceeds that of existing conditions and/or (2) the number of intersections projected to operate at unsatisfactory levels of service (LOS E or F) under the Proposed Plan substantially exceeds the number for 2009 Existing Conditions. Anticipated changes in traffic operations in 2035 with implementation of the Proposed Plan are analyzed using a focused and refined version of the Southern California Association of Governments (SCAG) travel demand model, which assigns traffic to Traffic Analysis Zones TAZs). The output provided by the travel demand model was utilized to estimate and compare total vehicle miles traveled and the number of impacted intersections under the Proposed Plan for 2035. While the Proposed Plan is anticipated to result in impacts to nine intersections, as indicated above, the project would be consistent with SB 375 and the Sustainable Communities Strategy and it is expected that as a result of increased development adjacent to transit in areas such as the Proposed Plan this will correspondingly relieve development pressure in other areas further from transit. Although the Proposed Plan will generate approximately 2,506,000 vehicle miles traveled (VMT) per day, which is an increase of 637,000 VMT when compared to the existing conditions, and 159,000 VMT when compared to the No Project Alternative, the new land uses included in the Proposed Plan will influence overall regional traffic patterns and thus the Proposed Plan’s true impact on regional VMT is estimated by subtracting the total regional VMT estimated under the No Project Alternative from the total regional VMT estimated under the Proposed Plan. Once this step is taken, the Proposed Plan’s true impact on VMT on Los Angeles County Roadways is a reduction of approximately 296,000 VMT, a 0.26 percent reduction. B. Air Quality (Chapter 11 and 2A) Description of Significant Effects. As the Final EIR concluded, the implementation of the Proposed Plan would result in an unavoidable significant adverse impact on air quality due to the total vehicular emissions of ozone precursors, the proximity of sensitive receptors to identified toxic air contaminate (TAC) emissions emanating from freeway, industrial, and railyard sources, the release of reactive organic gases (ROGs), oxides of nitrogen (NOx), carbon monoxide (CO), and particulate matter (PM10) and the exposure of sensitive receptors to substantial pollution concentrations in excess of the established Localized Significant Threshold (LST) during construction activities. The inclusion of mitigation measures 11.1 to 11.12 in the Mitigation Monitoring Plan will help mitigate significant impacts on regional and local air quality to the extent feasible; however, air quality impacts due to vehicular emissions, freeway, industrial, and railyard sources and construction activities will remain significant and unavoidable.

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Findings. The City adopts CEQA Findings 1 and 3. Facts in Support of Findings. The Proposed Plan would have a significant impact on air quality if it would: (1) violate any air quality standard or contribute substantially to an existing or projected air quality violation; and/or (2) expose sensitive receptors to substantial pollutant concentrations. The following facts, together with mitigation measures, indicate that the significant effects of the Project have been reduced or avoided to the extent feasible, but that certain significant air quality impacts are unavoidable. (a) Regional Operational Emissions The City is not in attainment with the State and National ozone standard. As a part of the effort to reach compliance with this standard, the SCAQMD has established numerical emissions thresholds for the ozone precursors, reactive organic gases, and oxides of nitrogen. The CalEEMod was used to estimate the total emissions of these contaminants that would result from the Proposed Plan. The Proposed Plan would exceed the threshold values for all pollutants except sulfur dioxide. Mobile source emissions alone constitute the following total operational emissions sources: 93 percent of NOx, 81 percent of CO, 99 percent of PM10, 85 percent of PM2.5, and 38 percent of ROGs. The Proposed Plan includes project design measures such as providing a mixture of uses in close proximity to transit, and infrastructure improvements to encourage bicycling and walking that reduce vehicle trips to the extent feasible. The CalEEMod model estimates that these trip reduction features will result in the following reduction to total operational emissions: 18 percent of NOx, 27 percent of CO, 39 percent of PM10, 35 percent of PM2.5, and 12 percent of ROGs. However, due to the scale of the Proposed Plan, operational criteria air quality emissions would be considered a significant and unavoidable impact for NOx, CO, PM10, PM2.5 and ROGs. (b) TAC Emissions The Final EIR is a programmatic document and there are no specific projects proposed at this time. Methodological inputs about specific site location and orientation of TAC sources, and sensitive receptor locations, emission profiles and local meteorology are a few of the factors required for a health risk assessment (HRA) to produce a quantitative health risk impact conclusion. Performing a quantitative analysis to determine the significant health risk impact to future residents from emissions sources for much of the Project Area could only be conducted at the time of the development of a specific project. However, because sensitive receptors would potentially be permitted in proximity to TAC sources, the health risk impacts related to siting sensitive land uses in proximity to TAC sources is considered a significant and unavoidable impact. Some of the specific TAC sources are discussed in more detail below.

Freeway Sources The SR-110 and I-5 freeways transect the Project Area and are major sources of diesel particulate matter (DPM) emissions. DPM constitutes 70 percent of TAC emissions statewide. The California Air Resources Board (CARB) cites several studies that demonstrate adverse health effects of sensitive receptors when placed within 300 to 1,000 feet of a freeway. Several mitigation measures were included in the MMP that would reduce exposure to TAC emissions. There are also other regulatory and technology trends that indicate that freeway sources of DPM will be much lower in the future. However, because it is possible that the Proposed Plan would permit sensitive land uses within the proximity to the SR-110 and I-5 freeways, health risk impacts would be considered significant and unavoidable. Specific projects located within the CARB recommended siting distances of 500 feet from the freeways would be required to conduct project specific HRA and incorporate measures to reduce health risks to on site occupants to an acceptable level as defined in the MMP.

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Industrial Sources In addition to freeways, industrial sources in the Proposed Plan that are potential sources of TAC emissions include, but are not limited to: food and commercial distribution facilities, railyards, fuel dispensing activities, utility transmission facilities, forging and dye shops, chrome plating operations and other industrial uses. The Proposed Plan gives a high priority to the retention and expansion of light industrial uses, though generally prohibits the expansion of industrial TAC sources such as heavy manufacturing and trucking and transportation terminals. Since the Proposed Plan encourages a mixture of uses in an existing industrial area, it is possible sensitive land uses would be permitted within proximity to new and existing industrial TAC sources, health risk impacts would be considered significant and unavoidable. Specific projects located within the CARB recommended siting distances from industrial sources would be required to incorporate measures to reduce health risks to on-site occupants. Railyard Sources Railyards are another potential source of DPM pollution in the Proposed Plan. The Los Angeles Transportation Center (LATC) railyard directly borders the Project Area on the southeast side. An HRA conducted for the LATC demonstrated that the LATC is a substantial source of DPM emissions. The Proposed Plan designates areas adjacent to the LATC railyard as the Urban Innovation Zone, which allows 15 percent for residential uses. Since it is possible sensitive land uses would be permitted within proximity to the LATC railyard, health risk impacts would be considered significant and unavoidable. Specific projects located within the CARB recommended siting distances from the LATC railyard would be required to incorporate measures to reduce health risks to on-site occupants.

(c) Construction Implementation of the Proposed Plan will take place over a period of years spanning from the present until at least 2035. Construction activities associated with such development may result in criteria pollutant emissions from fugitive dust associated with ground disturbance during grading and exhaust emissions from construction equipment as well as worker and delivery vehicles traveling to and from the site. Without adequate construction schedules or information regarding project locations and schedules, construction emissions for individual projects allowed under the Plan cannot be quantified; however, there is sufficient data available to determine the types of construction that may occur (e.g., residential, commercial, and industrial), and associated square footage. Emissions would be anticipated to be lower during years where, economically, the area is experiencing a slow down, and higher during years where the economy is at a peak. It is anticipated that the daily average emission (between present and 2035) would exceed the SCAQMD’s recommended thresholds for construction emissions and impacts would be significant and unavoidable. However, individual years (and months and days) would vary substantially over the planning horizon. (d) Sensitive Receptors and LSTs Localized Significant Thresholds (LST) have been developed by the SCAQMD to determine the maximum allowable concentrations of criteria air pollutants during construction under the Proposed Plan. LSTs have been established only for construction of projects and do not apply to emissions during operations. Each sensitive receptor area (SRA) in the Basin has a unique LST for pollutants. Because specific construction activity under the Proposed Plan cannot be determined at this time, this impact is considered significant and unavoidable. Due to the magnitude of potential emissions from all cumulative construction activities, and the addition of sensitive receptors beyond those existing in the area of the Proposed Plan, it is

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reasonable to assume that the construction air quality emission impacts would exceed the LST levels relevant to the specific projects. C. Noise and Vibration (Chapters 12 and 2C) Description of Significant Effects. As the Final EIR concluded, the Proposed Plan would allow the development of noise-sensitive land uses in some areas with existing ambient noise levels in excess of acceptable noise levels and that construction associated with implementing the Plan would result in significant and unavoidable short-term construction noise and vibration. The Proposed Plan could expose people and/or structures to substantial ambient and ground-borne vibration levels from adjacent from busy roadways and during construction activities. The Proposed Plan would permit the addition of sensitive receptors (schools, libraries, residences, hotels, senior care facilities, religious assembly, parks) and new developments requiring construction would significantly increase noise levels at sensitive receptors along certain street segments. Mitigation Measures 12.1 (a-d) and 12.2 would help mitigate roadway and construction noise impacts associated with implementation of the Proposed Plan to the extent feasible; however, the Final EIR concluded that noise impacts would remain significant and unavoidable. Findings. The City adopts CEQA Findings 1 and 3. Facts in Support of Findings. The impacts from the Proposed Plan would be considered significant if it would: (1) expose people to or generate noise levels in excess of standards established in the General Plan or noise ordinance, or applicable standards of other agencies; (2) expose people to or generate excessive ground-borne vibration or ground-borne noise levels; (3) cause a substantial increase in ambient noise levels; or (4) cause a substantial temporary or periodic increase in ambient noise levels. City guidelines recommend analyzing noise associated with both construction and operation, with corresponding thresholds designated for each. The Proposed Plan could result in significantly increased number of sensitive receptors living and/or gathering in proximity to busy roadways and significantly increased noise levels during construction. The Proposed Plan could expose people and/or structures to substantial noise and ground-borne vibration levels as a result of construction activities that occur during the Proposed Plan. Existing and future traffic would significantly increase noise levels at sensitive receptors along certain street segments. These impacts would be considered significant and unavoidable. Mitigations will require that residences, nursing homes, commercial uses, public parks, schools, library or religious uses on identified roadways shall be required to conduct acoustical analysis as well as include specific physical mitigations intended to reduce ambient noise levels. In addition, the Proposed Plan includes a new standard, revised since the August 6, 2012 draft Plan that requires special events that include the use of an audio system, with amplifiers, or fireworks displays to obtain a special event permit and provide a noise management plan. As each project will vary in the scale of construction activities and the proximity of sensitive receptors, it is uncertain if the implementation of the mitigation measures will reduce construction activities lasting more than one day, to less than the existing ambient exterior noise levels by 10 dBA or more at a noise sensitive use, or lasting more than 10 days in a three month period, to less than the existing ambient exterior noise levels by 5 dBA or more at a noise sensitive use. Therefore, noise and vibration impacts related to construction activities would be considered significant and unavoidable, albeit temporary. However, there are many feasible construction measures that shall be implemented to reduce noise and vibrations associated with implementation of the Proposed Plan. VI. ALTERNATIVES TO THE PROJECT

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Cornfield Arroyo Seco Specific Plan Goals The Plan’s Goals, as identified in the Final EIR are:

• Transform an under-served and neglected vehicular-oriented industrial and public facility area into a cluster of mixed-use pedestrian oriented and aesthetically pleasing neighborhoods

• Increase access to open space

• Provide economic growth opportunities for emerging new technologies

• Reconnect historical communities

• Maintain and enhance the concentration of jobs in the public and private sectors

• Provide a range of housing types and price levels that offer many choices, including home ownership for people of diverse ages, ethnicity, household sizes, and incomes

• Provide shops and services for everyday needs including groceries, day care, cafes, restaurants, banks, and drug stores, within an easy walk from home or work

• Facilitate pedestrian mobility, encourage bicycle use, provide shared and unbundled parking spaces, provide access to a variety of transit options including frequent light rail and bus connections, shared vehicles and bicycles, and taxis

• Lessen dependence on automobiles, and thereby reduce vehicle emissions, while enhancing the personal health of residents, employees, and visitors

• Provide “eyes on the street” to create a safe and stable community and to encourage interaction and identity

• Respect historically significant buildings, including massing and scale, while encouraging innovative architectural design that expresses the identify of contemporary urban Los Angeles

• Reduce the use of energy and potable water, capture stormwater, improve the ecology and hydrology of the Los Angeles River Watershed and the Arroyo Seco, create connections from the community to the Los Angeles River and the Arroyo Seco, and support the Los Angeles River Revitalization Master Plan

• Provide places for people to socialize, including parks, sidewalks, courtyards, and plazas that are combined with shops and services

• Provide adequate public recreational open space within walking distance of residents and employees and to integrate public art that contributes to the civic and cultural life of the City of Los Angeles

GENERAL FINDINGS. Based on these findings, the Final EIR, and the whole of the administrative record, the City finds that the Final EIR analyzes a reasonable range of Plan alternatives that would feasibly attain most of the basic goals of the Plan. Specifically, the

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Final EIR considered the following alternatives: No Project Alternative, Modified Project Alternative, Reduced Project Standards Alternative, and No Redevelopment Plan Alternative. Having weighed and balanced the pros and cons of each of the alternatives analyzed in the Final EIR, each of these alternatives is hereby found to be infeasible based on the Final EIR’s analyses, the Plan’s Goals, these CEQA findings and economic, legal, environmental, social, technological and other considerations. These considerations include the provision of development opportunities adjacent to transit and within proximity to the Los Angeles River and the Arroyo Seco, the flexibility to address a range of land use needs and affordable housing and employment opportunities for a wide range of residents and employees, all of importance to the City, all as supported on the evidence contained in the whole of the administrative record and based on the evidence and testimony presented in this matter. ALTERNATIVE-No Project Alternative. This Alternative is required by CEQA. Under the No Project Alternative, there would be no modification to the existing land uses and zoning. Development would not exceed the levels of reasonable development anticipated to occur under the current land use and zoning. Impact Summary. This Alternative would not result in significant but unavoidable or less-than- significant impacts for: Land Use, Transportation, Visual Resources, Earth Resources, Hydrology and Water Quality, Biological Resources, Cultural Resources, Hazardous Materials, Air Quality, Noise and Vibration, Population, Housing and Employment, Public Services and Recreation Facilities, Utilities, and Energy and Greenhouse Gas Emissions. Finding. The No Project Alternative would not have the environmental impacts that are projected to occur from the development allowed under the Proposed Plan. However this Alternative does not fully meet the Proposed Plan’s objectives. It is found pursuant to Public Resources Code Section 21081(a)(3), that specific economic, legal, environmental, social, and technological or other considerations of importance to the City, including affordable housing and industrial employment opportunities and the considerations identified in Section IX of these Findings (Statement of Overriding Considerations), make infeasible the No Project Alternative described in the Final EIR. Additionally, it is anticipated that increased development adjacent to transit (as in the Proposed Plan) will allow other areas not well served by transit to maintain their existing scale of development, consistent with SB 375 and the Sustainable Communities Strategy adopted by SCAG in April 2012. Rationale for Finding. The No Project Alternative, in general, is anticipated to result in incrementally less growth as compared to the Proposed Plan and would not meet the Proposed Plan’s objectives that were established during the community planning process. It would leave the area in the same condition that it is currently in and there would be no opportunity for the environmental, physical, and/or development improvements that would result from implementation of the Proposed Plan. The No Project Alternative would not change the zoning to promote a greater range of land uses, would not add building form and urban design, open space, conservation, and performance standards along with sign prohibitions to ensure that buildings and neighborhoods are well designed, reduce water and energy consumption, and provide adequate open space, and would not modify parking and street standards to improve mobility options. ALTERNATIVE-Modified Alternative. This Alternative is the same as the Original Proposed Alternative with the exception that Block 52 is proposed to be in the Urban Innovation Zone, as in the Revised Proposed Alternative (herein referred to as the Proposed Plan). Impact summary. The following significant and unavoidable impacts would occur under the Modified Alternative: Transportation, Air Quality, and Noise and Vibration; these are the same significant and unavoidable impacts that would occur under the Proposed Plan. The following

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less than significant impacts with mitigation would occur under this Alternative: Earth Resources, Hydrology and Water Quality, Biological Resources, Cultural Resources, Hazardous Materials, Utilities and Energy and Greenhouse Gases; these are also the same less than significant impacts with mitigation that would occur under the Proposed Plan. The following less than significant impacts would occur under this Alternative: Land Use, Visual Resources, Population, Housing and Employment, and Public Services and Recreation Facilities; these are the same less than significant impacts that would occur under the Proposed Plan. Finding. With this Alternative, the environmental effects would be identical to those of the Proposed Plan and none of the significant and unavoidable impact would be avoided. As with the No Project Alternative the Modified Alternative does not fully meet the Proposed Plan’s objectives. It is found pursuant to Public Resources Code Section 21081(a)(3), that specific economic, legal, environmental, social, and technological or other considerations of importance to the City, including affordable housing and industrial employment opportunities and the considerations identified in Section IX of these Findings (Statement of Overriding Considerations), make infeasible the Modified Alternative described in the Final EIR. Additionally, it is anticipated that increased development adjacent to transit (as in the Proposed Plan) will allow other areas not well served by transit to maintain their existing scale of development, consistent with SB 375 and the Sustainable Communities Strategy adopted by SCAG in April 2012. Rationale for Finding. With this Alternative, the environmental effects would be identical to those of the Proposed Plan but benefits would be reduced as this Alternative does not facilitate the development of affordable housing or provide the desired land use options to the extent the Proposed Plan does. The Modified Project Alternative, in general, is anticipated to result in similar growth as compared to the Proposed Plan. ALTERNATIVE-Reduced Project Standards Alternative. Under this Alternative development standards would be reduced. This Alternative assumes that the land use designation and zoning would be the same but the intensities of development could be reduced and the standards with respect to density, height, bulk, FAR, and open space for example could also be reduced. Therefore, this Alternative would not help provide the density desired for a transit area nor include sufficient standards to address the impacts of anticipated growth such as the urban design, building mass and TDM measures. Impact summary The following significant and unavoidable impacts would occur under the Reduced Project Standards Alternative: Transportation, Air Quality and Noise and Vibration. The impacts for Transportation and Air Quality would potentially be at reduced levels but the impact for Noise and Vibration is potentially the same depending upon the level of development. This Alternative would potentially reduce the Plan’s less than significant with mitigation impacts associated with Hydrology, Water Quality and Utilities and Energy and Greenhouse Gases but less than significant with mitigations impacts associated with Earth Resources, Biological Resources, Cultural Resources and Hazardous Materials would be the same. The less-than-significant impact associated with Land Use is potentially the same as the Proposed Plan depending upon the level of development but the less than significant impacts associated with Visual Resources, Population, Housing, and Employment and Public Services and Recreation Facilities are potentially reduced. Finding With this Alternative, the environmental effects would be potentially reduced relative to those of the Proposed Plan. As with the No Project Alternative and the Modified Alternative, the Reduced Project Standards Alternative does not fully meet the Proposed Plan’s objectives. It is found pursuant to Public Resources Code Section 21081(a)(3), that specific economic, legal, environmental, social, and technological or other considerations of

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importance to the City, including density near transit and urban design standards and the considerations identified in Section IX of these Findings (Statement of Overriding Considerations), make infeasible the Reduced Project Standards Alternative described in the Final EIR. Additionally, it is anticipated that increased development adjacent to transit (as in the Proposed Plan) will allow other areas not well served by transit to maintain their existing scale of development, consistent with SB 375 and the Sustainable Communities Strategy adopted by SCAG in April 2012. Rationale for Finding. The Reduced Project Standards Alternative is anticipated to result in incrementally lesser growth potential and reduced physical and environmental improvements stemming from the reduced design standards than the Proposed Plan. This alternative would provide somewhat decreased levels of housing and employment capacity adjacent to transit infrastructure. This alternative would not include the same level of urban design standards to ensure that buildings and neighborhoods are well-designed and would not modify the street standards to improve mobility options. ALTERNATIVE-No Redevelopment Plan Alternative. This Alternative assumes the Original Proposed Alternative without the Redevelopment Plan. Of course, as a result of ABX 1 26 redevelopment agencies statewide, including the Community Redevelopment Agency of the City of Los Angeles (CRA/LA), were eliminated effective February 1, 2012. Therefore, it is no longer be feasible to include the Redevelopment Plan in any of the alternatives including the Revised Proposed Alternative (Proposed Plan). Impact summary The following significant and unavoidable impacts would occur under the No Redevelopment Plan Alternative: Transportation, Air Quality and Noise and Vibration. The impacts for Transportation and Air Quality would potentially be at reduced levels but the impact for Noise and Vibration is potentially the same depending upon the level of development. This Alternative would potentially reduce the Plan’s less than significant with mitigation impacts associated with Hydrology, Water Quality and Utilities and Energy and Greenhouse Gases but less than significant with mitigations impacts associated with Earth Resources, Biological Resources, Cultural Resources and Hazardous Materials would be the same. The less-than-significant impact associated with Land Use is potentially reduced as compared to the Proposed Plan but the less than significant impacts associated with Population, Housing, and Employment and Public Services and Recreation Facilities are potentially reduced. The less than significant impacts associated with Visual Resources is potentially increased to a minor degree. Finding With this Alternative, the environmental effects would be potentially reduced relative to those of the Proposed Plan. As with the No Project Alternative and the Modified Alternative, the No Redevelopment Plan Alternative does not fully meet the Proposed Plan’s objectives. It is found pursuant to Public Resources Code Section 21081(a)(3), that specific economic, legal, environmental, social, and technological or other considerations of importance to the City, including affordable housing provisions and the land use modifications to Block 52 and the considerations identified in Section IX of these Findings (Statement of Overriding Considerations), make infeasible the No Redevelopment Plan Alternative described in the Final EIR. Additionally, it is anticipated that increased development adjacent to transit (as in the Proposed Plan) will allow other areas not well served by transit to maintain their existing scale of development, consistent with SB 375 and the Sustainable Communities Strategy adopted by SCAG in April 2012. Rationale for Finding. The No Redevelopment Plan Alternative, as it represents the Original Proposed Alternative without a Redevelopment Plan would not facilitate affordable housing or the other land use modifications described in the Revised Proposed Alternative.

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ENVIRONMENTALLY SUPERIOR ALTERNATIVE The Final EIR concluded that the Revised Proposed Alternative (Proposed Plan) is environmentally superior to the others. This alternative meets community planning objectives and provides many community enhancements. While it would result in significant impacts to transportation, air quality, and noise that cannot be mitigated to a level that is less than significant it does meet the goals and objectives of the City, County, and SCAG in terms of accommodating some of the forecasted growth in population and employment in an area well served by transit and access to recreation and open space opportunities and thereby assisting the region in meeting the objectives of SB 375 and the Sustainable Communities Strategy. The Proposed Plan meets the goals and objectives of the community, prepares the community for the social and economic changes expected through the year 2035, and in the view of the Department of City Planning is the alternative that best meets the social, economic, and planning goals and objectives of the City. VII. FINDINGS REGARDING OTHER CEQA CONSIDERATIONS Short Term versus Long Term Impacts The Proposed Plan is intended to address growing pressures to redevelop this largely industrial area for residential and other non-industrial uses, to increase development activities near rail and bus transit, provide amenities for the existing residential uses, and facilitate future access to the Los Angeles State Historic Park, the Los Angeles River, and the Arroyo Seco. The action being recommended in the Proposed Plan is intended to provide additional land use carrying capacity consistent with state and regional policies encouraging densification of land uses in urban areas, especially adjacent to transit. It is important to resolve these problems in the near term to ensure that the quality of life and the quality of the environment in the Proposed Plan area are enhanced. Growth Inducing Impacts of the Proposed Plan Section 15126.2(d) of the CEQA Guidelines requires a Final EIR to discuss the ways the Proposed Plan could foster economic or population growth or the construction of additional housing, directly or indirectly, in the surrounding environment. Growth inducing impacts include the removal of obstacles to population growth (e.g., the expansion of a wastewater treatment plant allowing more development in a service area) and the development and construction of new service facilities that could significantly affect the environment individually or cumulatively. In addition, growth must not be assumed as beneficial, detrimental, or of little significance to the environment. The Proposed Plan as analyzed in the EIR allows for reasonable expected development to accommodate an estimated 31,855 persons. The adoption and implementation of the Proposed Plan would create an increase in the level of reasonable expected development to accommodate 26,343 more persons than the 5,512 persons assumed by the No Project Alternative by 2035. The Proposed Plan is designed to satisfy the projected growth forecast by SCAG and further address new policies included in SCAG’s Sustainable Communities Strategy that addresses regional land use and transportation obligations to meet SB 375 and AB 32. Since SCAG, which is the regional agency responsible for projecting growth, anticipates growth in the area, land use capacity changes and adjustments to accommodate anticipated growth would not be considered growth inducing; rather they are generally considered growth accommodating.

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Since the Proposed Plan is located in a highly urbanized setting, most of the infrastructure necessary for future development is already in place. The Proposed Plan would not extend the infrastructure beyond that required to meet the anticipated needs of future development. Therefore, while minor infrastructure improvements are likely within the area, they are not anticipated to stimulate population growth and thus would not result in growth inducing effects. Significant Irreversible Impacts CEQA Guidelines Section 15126.2(c) states that: “[u]ses of nonrenewable resources during the initial and continued phases of the Project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the Project. Irreversible commitments of resources should be evaluated to assure that such current consumption is justified.” Development of the anticipated level and type with the Proposed Plan would cause the irreversible commitment of limited resources including energy and water for project development and operation. The construction phases and subsequent occupancy of new development would require the use of non-renewable resources (notably sand and gravel) for construction as well as a commitment of energy sources for building materials, fuel, operation, and the transportation of goods and people to and from the project sites. Commitment of resources during construction of future projects within the Proposed Plan would include; construction labor, materials used in construction, and fossil fuels consume d by project generated traffic and construction equipment. Commitment of resources following construction of projects would be similar to existing conditions, including electricity and gas to operate the projects and fossil fuels used by project-related traffic. The assumed level of development within the Proposed Plan would incrementally reduce existing supplies of fuels including fuel oil, natural gas, and gasoline, since fossil fuels are currently the principal energy sources. These changes are not considered significant when compared to existing energy consumption; however, this still represents a long-term commitment of non-renewable resources. Increasing commitment to renewable technologies will help offset demand. The construction of future projects within the Proposed Plan would also require the commitment or destruction of other non-renewable and slowly renewable resources. These resources include lumber and other forest products, sand, and gravel, asphalt, petrochemical construction materials, steel, copper, lead and other metals, and water. Commitment of the Proposed Plan to the proposed level and type of future development would restrict future generations from other uses for the life of the projects, approximately 20 to 50 years or more. The commitment of resources required for the type and level of proposed development would limit the availability of these resources for future generations for other uses during the life of the Plan. However, this resource consumption would be consistent with growth and anticipated change in the City of Los Angeles, the County of Los Angeles, and the Southern California region as a whole. Further, use of such resources would be of a relatively small scale in relation to the Proposed Plan’s fulfillment of regional and local urban design and development goals for the area. These goals are intended to promote smart growth that would reduce resource consumption by reducing vehicle trips and incorporating sustainable

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design features. Therefore, the use of such resources for future projects in the Plan area would be reduced as compared to development in other locations that would not fulfill such goals as fully. Recirculation of Final EIR CEQA requires that the responses to comments in the Final EIR demonstrate good faith and a well-reasoned analysis, and not be overly conclusory. Some comments assert that the Final EIR is inadequate for not appropriately addressing impacts of the Plan. However, the information in the Final EIR demonstrates that no additional impacts beyond those already identified in the Original DEIR and the RP-DEIR have been identified by the comments, and thus, the Final EIR is not inadequate for the reasons stated in the comments. Specifically, CEQA Guidelines Section 15088.5 does not require recirculation of the Final EIR based on the following: a) No significant new information has been added that would deprive the public of a

meaningful opportunity to comment on a substantial adverse environmental effect of the Project, a feasible way to mitigate or avoid such an impact that the Applicant has declined to implement, or a feasible Project alternative;

b) The new information, including certain factual corrections, minor project modifications

that do not constitute substantial new information and minor changes, provides clarification to points and information already included in the Original DEIR and RP-DEIR;

c) There are no significant new environmental impacts resulting from the Project or from a

new mitigation measure proposed to be implemented; d) There is no substantial increase in the severity of an environmental impact that has not

been mitigated to a level of insignificance; e) The Applicant has not declined to adopt any feasible project alternatives or mitigation

measures, considerably different from others previously analyzed, that clearly would lessen the environmental impacts of the Project; and

f) The Final EIR is not so fundamentally and basically inadequate and conclusory in nature

that meaningful public review and comment are precluded. g) The City Council finds that, after considering the Final EIR, there is substantial evidence

to conclude that none of the conditions requiring recirculation of the Final EIR are present and therefore recirculation of the Final EIR is not required.

Miscellaneous The concept of “feasibility” encompasses the question of whether a particular alternative promotes the underlying goals and objectives of a Project. “Feasibility” under CEQA encompasses “desirability” to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors. CEQA requires that the lead agency exercise its independent judgment in reviewing the adequacy of a Final EIR and that the decision of a lead agency in certifying a Final EIR and approving a Project not be predetermined. The City has conducted its own review and considered the Final EIR, and is exercising its independent judgment when acting as herein provided.

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CEQA requires decision-makers to adopt a mitigation monitoring plan for those mitigation measures identified in the Final EIR that would mitigate or avoid each significant impact identified in the Final EIR and to incorporate the mitigation monitoring plan, including all mitigation measures, as conditions of Project approval. The responses to the comments on the Draft EIR, which are contained in the Final EIR, clarify and amplify the analysis in the Draft EIR. CEQA requires the Lead Agency approving a Project to adopt a Mitigation Monitoring Plan (MMP) for the changes to the Project which it has adopted or made a condition of Project approval in order to ensure compliance with the mitigation measures during Project implementation. The mitigation measures included in the Final EIR as certified by the City Council and included in the MMP as adopted by the City Council serves that function. The MMP includes all of the mitigation measures and project design features that reduce potential impacts which were identified in the Final EIR and adopted by the City Council in connection with the approval of the Proposed Plan and has been designed to ensure compliance with such measures during implementation of the Proposed Plan. In accordance with CEQA, the MMP provides the means to ensure that the mitigation measures are fully enforceable. The final mitigation measures are described in the MMP. Each of the mitigation measures identified in the MMP, and contained in the Final EIR, is incorporated into the Project. In accordance with the requirements of Public Resources Code § 21081.6, the City Council hereby adopts the MMP attached to these findings as Exhibit I and incorporated by reference into these findings. The City Council finds that the impacts of the Project have been mitigated to the extent feasible by the mitigation measures identified in the MMP, and contained in the Final EIR. In accordance with the requirements of Public Resources Code § 21081.6, the City Council hereby adopts each of the mitigation measures expressly set forth herein as conditions of approval for the Project. The City Council finds and declares that substantial evidence for each and every finding made herein is contained in the Final EIR, which is incorporated herein by this reference, or is in the record of proceedings in the matter. The City, acting through the Department of City Planning, is the “Lead Agency” for the Project evaluated in the Final EIR. The City Council finds that the Final EIR was prepared in compliance with CEQA and the CEQA Guidelines. The City Council finds that it has independently reviewed and analyzed the Final EIR for the Project, that the Draft EIR that was circulated for public review reflected its independent judgment and that the Final EIR reflects the independent judgment of the City Council. The City Council finds that the Final EIR provides objective information to assist the decision-makers and the public at large in their consideration of the environmental consequences of the Project. The public review period provided all interested jurisdictions, agencies, private organizations, and individuals the opportunity to submit comments regarding the Draft EIR and the RP-DEIR. The Final EIR was prepared after the review period and responds to comments made during the public review period. The Planning Department evaluated comments on the environmental issues received from persons who reviewed the Draft EIR and RP-DEIR. In accordance with CEQA, the Planning Department prepared written responses describing the disposition of significant environmental issues raised. The Final EIR provides adequate, good faith and reasoned responses to the comments. The Planning Department reviewed the comments received and

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the responses thereto and has determined that neither the comments received nor the responses to such comments add significant new information regarding environmental impacts to the Draft EIR and RP-DEIR. The Lead Agency has based its actions on a full evaluation of all viewpoints, including all comments received up to the date of adoption of these findings, concerning the environmental impacts identified and analyzed in the Final EIR. The significant environmental impacts of the Project and the alternatives were identified and evaluated in the Draft, RP-DEIR, and Final EIR. The City Council is approving and adopting findings for the entirety of the actions described in these Findings and in the Final EIR as comprising the Project. It is contemplated that there may be a variety of actions undertaken by other State and local agencies (who might be referred to as “responsible agencies” under CEQA). Because the City is the Lead Agency for the Project, the Final EIR is intended to be the basis for compliance with CEQA for each of the possible discretionary actions by other State and local agencies to carry out the Project. VIII. MITIGATION MONITORING The Mitigation Monitoring Plan (MMP) has been prepared in accordance with Public Resources Code Section 21081.6, which requires a Lead or Responsible Agency that approves or carries out a plan where a Final EIR has identified significant environmental effects to adopt a “reporting or monitoring program for the changes to project which it has adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment.” The City is the Lead Agency for the Plan. The MMP is designed to monitor implementation of all feasible mitigation measures as identified in the Final EIR for the Plan. All departments listed are within the City unless otherwise noted. The entity responsible for the implementation of all mitigation measures shall be the City unless otherwise noted. In accordance with the Requirements of Public Resources Code § 21081.6, the City Council hereby adopts the Mitigation Monitoring Plan, which is described in full in the Final EIR for the Proposed Plan, as Appendix A1 and is attached herein as Exhibit F. The City Council reserves the right to make amendments and/or substitutions of mitigation measures if the City Planning Department or their designee determines that the amended or substituted mitigation measure will mitigate the identified potential environmental impacts to at least the same degree as the original mitigation measure, and where the amendment or substitution would not result in a new significant impact on the environment which cannot be mitigated. IX. STATEMENT OF OVERRIDING CONSIDERATIONS The Cornfield Arroyo Seco Specific Plan Final EIR identifies unavoidable significant impacts that would result from implementation of the Proposed Plan (project). Section 21081 of the California Public Resources Code and Section 15093(b) of the CEQA Guidelines provide that when a public agency approves a project that will result in the occurrence of significant impacts that are identified in the Final EIR but are not avoided or at least substantially lessened, the agency must state in writing the reasons to support its action based on the certified Final EIR and/or other information in the record. Section 21081 of the California Public Resources Code and Section 15093(b) of the CEQA Guidelines require that the decision maker adopt a Statement of Overriding Considerations at the time of approval of a project if it finds that significant adverse environmental effects have been identified in the Final EIR which cannot be avoided or substantially mitigated to an insignificant level. These findings and the Statement of Overriding Considerations are based on substantial evidence

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in the record, including but not limited to the Final EIR, and documents, testimony, and all other materials that constitute the record of proceedings. The Cornfield Arroyo Seco Specific Plan Final EIR concluded that, despite the adoption of feasible mitigation measures, the Proposed Plan would result in the following unavoidable significant adverse impacts that are not mitigated to a less-than-significant level: Transportation; Air Quality (TAC emissions and Construction); and Noise (Sensitive Receptors and Construction). Accordingly, the City Council adopts the following Statement of Overriding Considerations. The City recognizes that significant and unavoidable impacts would result from implementation of the Plan. Having (i) adopted all feasible mitigation measures, (ii) rejected alternatives to the Plan for the reasons discussed above, (iii) recognized all significant, unavoidable impacts, and (iv) balanced the benefits of the Plan, including region-wide or statewide environmental benefits, against the Plan’s significant and unavoidable impacts, the City Council hereby finds that the benefits of the Proposed Plan outweigh and override the significant unavoidable impacts for the reasons stated below. The following reasons summarize the benefits, goals and objectives of the Plan, and provide, in addition to the adopted findings, the rationale for the City Council’s determination that the benefits of the Proposed Plan outweigh its significant and unavoidable adverse impacts. These overriding considerations of the economic, social, aesthetic, and environmental benefits justify adoption of the Proposed Plan. Many of these overriding considerations individually would be sufficient to outweigh the adverse environmental impacts of the Proposed Plan and justify its approval. In particular, achieving the underlying purposes for the Proposed Plan would be sufficient to override the significant environmental impacts of the Proposed Plan. The City Council, having considered all of the foregoing, finds that the following specific overriding economic, legal, social, technological, or other benefits of the Proposed Plan outweigh the identified unavoidable significant adverse impacts on the environment. The City Council expressly finds that the following benefits would be sufficient to reach this conclusion:

1. The Proposed Plan would protect the quality of life for existing and future residents and confer citywide benefits through new land use designations and zoning to incorporate smart growth principles, including concentrating growth in areas of the city that have transit infrastructure to support it, thereby reducing new trip generation and emissions from new development and promoting sustainable development in support of AB 32 and SB 375.

2. The Proposed Plan would guide the City in expanding the local economy, including

light industries, which provide jobs, attract and retain businesses, support diverse and vibrant commercial areas, and generate sufficient revenue to support various local programs and services.

3. The Proposed Plan promotes development that would accommodate anticipated

population growth and guide physical development towards a desired image that is consistent with the social, economic and aesthetic values of the City.

4. The Final EIR provides a programmatic mitigation framework to guide development

projects in order to reduce environmental impacts of future plans and projects.

5. The Proposed Plan supports the policies and goals of the most recent Housing Element adopted by the City in 2009, and allows the City to meet future housing

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needs for the growth in population projected for the year 2030 by the Southern California Association of Governments.

6. The Proposed Plan would improve local mobility through development of a balanced,

multi-modal transportation network, encouraging residential and workplace development near transit centers.

7. The Proposed Plan would guide the preservation and protection of historical and

cultural resources, while recognizing the need for continued investment, development, and jobs and housing growth, and would improve the quality of the built environment, and maintain the character and identity of communities.

8. The Proposed Plan is consistent with SB 375. While increasing vehicle miles traveled

and greenhouse gases in the immediate area, the Proposed Plan implements a condensed development pattern adjacent to transit, consistent with SB 375 and the Sustainable Communities Strategy, and therefore would be expected to contribute to decreasing regional vehicle miles traveled and greenhouse gas emissions.

9. The Proposed Plan would support and benefit the region by protecting and preserving

light industrial uses that sustain jobs as a major source of revenue and employment and a vital sector of the regional economy.

10. The Proposed Plan would support the policies and goals of the General Plan

Framework Element by allowing the City to grow strategically and allow for the conservation of existing low-scale residential neighborhoods throughout the City.

Independent Judgment The Draft EIR, Final EIR, and all other related materials reflect the independent judgment and analysis of the Lead Agency. Substantial Evidence The City Council finds and declares that substantial evidence for each and every finding made herein is contained in the Draft EIR and Final EIR and other related materials, each of which are incorporated herein by this reference. Moreover, the City Council finds that where more than one reason exists for any finding, the City Council finds that each reason independently supports such finding, and that any reason in support of a given finding individually constitutes a sufficient basis for that finding. Relationship of Findings to EIR These Findings are based on the most current information available. Accordingly, to the extent there are any apparent conflicts or inconsistencies between the Draft EIR, the RP-DEIR and the Final EIR, on the one hand, and these Findings, on the other, these Findings shall control and the Draft EIR, RP-DEIR and Final EIR or all, as the case may be, are hereby amended as set forth in these Findings. Custodian of Documents The custodian of the documents or other material which constitutes the record of proceedings upon which the City Planning Commission and City Council’s decision is based is the City of Los Angeles, Department of City Planning, located at 200 North Spring Street, Los Angeles, California 90012.

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PUBLIC HEARING AND COMMUNICATIONS Public Participation Initial planning efforts launched in the fall of 2007 with a series of four workshops facilitated by the Western Justice Center which provided volunteer facilitators to guide and record the comments and ideas of participants. The workshops included area residents, and property and business owners as well as environmentalists, landscape architects, and urban designers. Flyers for each of the workshops were produced in English, Chinese, and Spanish and translation services were made available in Chinese and Spanish at all of these early workshops. To maximize awareness of these early planning efforts flyers were distributed in multiple languages to students at each of the surrounding area’s public schools. Pamphlets were also displayed at each of the schools and in area libraries and businesses. Additional efforts were also made, via mail and email to contact area businesses and organizations about the meetings. In addition to the workshops, Fact Sheets were regularly produced updating the community about recent goings on about the Plan and informing them about upcoming events. These Fact Sheets were also produced in Chinese and Spanish, in addition to English. A website was also maintained at cornfieldsla.googlepages.com where community members could learn about the meetings and obtain regular updates about the Plan. In addition to the workshop series, staff met over the years with area property owners, residents, business organizations, non-profits and neighborhood councils. The first workshop in September 2007 was held at the Goodwill Job Center on San Fernando Road. Over 100 community members participated in this workshop that focused on creating a vision for the area. The community was invited to share their ideas about the strengths and weaknesses of the area. The community articulated a desire to preserve jobs, provide affordable housing and community services, improve the river, and ensure a safe and accessible environment. The second workshop was held in December 2007 at the Conservation Corps building on Spring Street across from the LASHP. This workshop, where again, approximately 100 community members joined in, the discussion focused on the Plan’s goals and its future land uses. The participants were asked to reassemble the current land uses and to add new uses in accordance with the vision they had articulated in the first workshop. The community expressed a keen interest in encouraging a mix of uses, especially near the transit stations and the State Park, while also seeking to protect the industrial areas along Main Street and in the northeast quadrant of the Plan bounded by Avenue 26, Pasadena Avenue, and the Arroyo Seco. The third workshop was held on February 23, 2008, again at the Conservation Corps. During the break-out sessions the community was asked to provide feedback on the proposed concepts for the new districts, streets, and open space areas. Several area non-profits and developers displayed their proposed street, park, and development projects to that the community could also provide feedback to them. A fourth workshop was held in early November 2008 on two separate occasions. The first meeting occurred on November 6th at the Ann Street Elementary School and the second meeting, which followed the identical format of the first meeting, was held on November 8th at the Goodwill Workforce Center. Approximately 45 people attended the meeting on the 6th and another 90 joined the meeting on Saturday, the 8th. Following these November workshops a preliminary draft of the Plan was released to the public on November 17, 2008. The Plan was made available on-line as well as at City Hall and the Lincoln Heights and Chinatown libraries. A variety of comments were received regarding this first draft and a second draft was released in March 2009 to coincide with the scoping meeting

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for the Environmental Impact Report. Initially it was expected that a draft EIR would be completed by the fall of 2010 but in the summer of 2010 the Community Redevelopment Agency and the City Council approved a recommendation to study the Proposed Plan area as a redevelopment project area. The decision to study the Plan area as a redevelopment project area did not alter the goals and vision of the Plan nor did it alter the anticipated development capacity or any of the zoning requirements or design standards included in the Plan. To explain the decision to explore the Plan area as a redevelopment project area, a community meeting was held in October 2010 which approximately 60 persons attended. At the meeting it was also explained that due to the change in the project description to include the redevelopment project area, a subsequent Initial Study would be issued and a second scoping meeting would be held. This second scoping meeting was held on November 16, 2010. A newsletter was developed, and published in several languages, that explained this new development and outlined details about the Plan and the role the redevelopment project area would play in helping implement the plan. To coincide with the launch of this second scoping meeting a revised version of the Plan, that incorporated clarifying language but no land use or major changes from the 2009 draft, was released on November 1, 2010. The Draft EIR was completed and released ten months later in September 2011. During the 60 day comment period for the DEIR a community workshop was held in early November 2011 to listen to community comments and provide information on the next steps. Due to concerns that previous efforts to reach non-English speakers had been insufficient, flyers for the workshop were produced in Thai, Korean, and Vietnamese in addition to the Chinese and Spanish language versions that had been included previously. The City worked with the Southeast Asian Community Alliance (SEACA) to increase awareness to community members that had previously not been aware of the Plan. Translation services in the five languages mentioned above were made available at the November 2011 meeting. Following the close of the DEIR comment period at the end of November 2011 the City dedicated many months to preparing the FEIR. During the review of the DEIR comments staff recognized that there were some inadequacies in the original DEIR that warranted additional analyses and/or clarification; therefore on May 2012 the City released the Recirculated Portions (RP) of the DEIR for a 45 day comment period. The RP-DEIR included discussion on Air Quality (construction and TAC emissions), GHG Emissions, Noise (construction), and Transportation (traffic). A revised Draft Proposed Plan, that included modifications to reflect many of the comments received on the DEIR, was released on August 6, 2012 and the Final Environmental Impact Report was released in mid-August. A Notice of Public Hearing was mailed to approximately 6,500 property owners and tenants announcing the Open House and Public Hearing that was held on August 30, 2012. Planning staff met with various organizations and neighborhood councils, community leaders and business groups to discuss questions and concerns prior to the hearing. The Open House and Public Hearing that was held on August 30, 2012 at the Conservation Corps across the street from the LASHP was attended by approximately 150 persons. The Open House from 4:30-6:30 p.m. provided community members the opportunity to meet with staff and discuss the Plan and air specific concerns. The Public Hearing commenced at 6:30 and 40 persons gave verbal testimony during the two-hour hearing. Four written comments were delivered that evening and three comments were received via email the following day. Summary of Public Hearing Testimony and Communications Comments were received on a range of topics addressed by the Proposed Plan but the majority of comments focused on affordable housing, development capacity and the proposed parking

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cap. In addition, one verbal and one written comment expressed frustration about the paseo requirement, the river buffer and that existing uses were insufficiently protected, another letter suggested that the property adjacent to the Chinatown Station was best suited for residential uses and two letters questioned the adequacy of the EIR analysis. Of the three emails one suggested that the FAR on the property buffered between Broadway and the LASHP (block 19 B) should be reduced to 3:1 to reduce physical impacts on the State Park, another questioned the legality of distributing TFAR funds to the River Corporation, and the third expressed support for the Plan. Affordable Housing and Residential Development Capacity Comment: Almost half of the comments received at the Public Hearing expressed concern that the Plan does not sufficiently encourage affordable housing and that increased housing costs could lead to gentrification and displacement in the surrounding communities. The majority of the affordable housing comments also expressed support for SEACA’s housing Community-Oriented Development (COD) Overlay Zone (See comment 27a-27 in Volume I of the FEIR) proposal that was submitted to the City during the DEIR comment period. Alternatively, market rate developers and many of the existing property owners and nearby business organizations expressed concern that the 2.5:1 Base FAR for residential projects would limit their ability to develop their sites. Representatives of the property immediately across the street from the Gold Line Chinatown Station (Block 9) postulated that residential uses are best suited for this location and further argued that the myriad of non-residential uses permitted by the Plan are not well-suited for this area. And lastly, one comment expressed concern about permitting the property on Block 19 B to build in excess of a 3:1 FAR. Response: Concerns about housing displacement and gentrification were addressed in the Master Response (MR-1) on Housing Displacement in Volume II of the FEIR. In the intervening months between the close of the DEIR comment period in November 2011 and the Public Hearing staff met almost a dozen times with housing advocates to discuss their concerns. Staff also met with representatives of for profit and non-profit affordable housing developers to seek their input. The resulting staff recommendation of a 2.5:1 FAR for residential projects is aimed at setting a Base FAR that would make it likely that any developer would seek to include affordable housing in order to increase the size of their project and make it more financially viable. Staff was concerned that setting the Base FAR too low would result in development, if it occurred at all, that was inappropriately scaled to facilitate the redevelopment of the Proposed Plan area as a vibrant transit-oriented district. While staff understands the prospective applicant’s interest in developing Block 9 as a primarily residential use staff proposes that the site continue to be included in the Urban Center District. Today the site is zoned M-1 which does not permit any residential uses but the Proposed Plan proposes to relax this prohibition by permitting 15% of a project for residential uses. In addition, this site is eligible to achieve up to a 6:1 FAR through participation in the TFAR program which could translate into over one million square feet of development for this approximately five-acre site. If the site were to be fully developed and were to dedicate 15% of the floor area for residential uses over 163,000 square feet of residential units could be included. Even more units could be built if the project participated in the Plan’s Density Bonus Option. Due to the sizable scale of this site, and its proximity to Chinatown station, it is well suited as a mixed-use site that includes some residential but that is predominantly a job center and/or other regional attractor. A number of residential projects, outside of the Proposed Plan but adjacent to the Chinatown station, are either planned or are under construction and the Proposed Plan itself provides for an ample supply of residential uses just north-east of this site along Spring Street across from the State Park. Therefore, with the ready potential for an abundance of residential in the area and the need to protect land for employment-generating uses, it was determined that this site was most suitable for the Urban Center zone.

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Block 19B otherwise referred to as the bluff property is admittedly a difficult one. It is a narrow, steep site that is bordered on one side by Broadway and on the other by the Gold Line which abuts the LASHP. In considering the future zoning for this site staff was challenged to provide sufficient development capacity to enable the property to be activated but to also include sufficient restraint so that viewsheds between the park and the surrounding hillsides could be preserved. Because of the dramatic topographical shift between Broadway and the LASHP, access to the park from the surrounding communities is severely limited. Ultimately, the site was included in the Urban Village zone which will permit the site to be built for a wide range of uses including residential and/or non-residential uses. While staff respects the commenter’s interest in limiting the future maximum FAR of this site to 3:1 staff would point out that the site is limited to a Base FAR of 3:1 FAR (or 2.5 if primarily residential without affordable housing). While the site does include a Max 4:1 FAR this higher level of density could only be achieved if the project were to include affordable housing and/or other community benefits. And, regardless of how the site is developed it would be subject to a height limit of 75’, would be subject to the building form and massing standards and would be required to include numerous visual connections and physical accessways between Broadway and the edge of the LASHP. Public Parking Comment: A number of comments expressed concern that the proposed public parking cap, in combination with the proposed maximum parking limit, would severely constrain future development. And another comment expressed concern that, requiring a conditional use permit (CUP) for parking, as identified in the Use Classification Table of the August 6, 2012 draft would discourage the very public parking strategies that are encouraged. Response: After careful consideration, the October 11, 2012 revised draft plan has eliminated the parking cap. Thus, while projects would still be subject to the parking maximum for their project-specific parking, they could include an unlimited amount of publicly accessible parking. This change will promote the expanded use of shared parking strategies among projects. The intent of this limitation was to require a CUP for projects that wanted to build parking as a stand-alone use - it was not intended to establish a CUP requirement for any public parking that is built as part of a project. The Use Classification Table in the October 11, Proposed Plan has been modified to clarify this. Existing Uses Comment: Concern has been expressed that the Use Classification Table in the August 6, 2012 draft inadvertently limited some of the existing uses and/or combination and/or percentage of uses that are present in the area today and that are also desired in the future. Response: The Table in the September draft has been modified to provide greater clarity as to the range of uses that are permitted. The Definitions have been updated to reflect the changes to the Use Classification Table. The clarifications do not change any of the CEQA assumptions and evaluations. TFAR Comment: The comment expresses concern about the legality of distributing a portion of the Floor Area Payment to the River Revitalization Corporation. Response: Staff is reviewing this concern. Paseo

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Comment: The comment expresses concern that the paseo requirement will limit future development opportunities. Response: The establishment of a paseo is required in only limited circumstances and yet will serve to increase mobility options throughout the project area. Large block sizes encourage higher traffic speeds and discourage pedestrian activity and therefore the addition of paseos and/or alleys to reduce block lengths and increase pedestrian mobility options will help reduce traffic speeds, increase pedestrian safety and increase levels of pedestrian activity. River Buffer Comment: The comment suggests that the River Buffer be eliminated from blocks 36 and 45. Response: The river buffer was established to provide a consistent 300’ buffer within which development intensity and lot coverage would be limited as a means of increasing visual connection between the future river greenway and the community. Properties that are within the buffer that feel constrained by the design requirements of the buffer may elect to transfer the development rights for that portion of the property to other portions of the property that are not included in the River Buffer. EIR Analyses Two letters expressed numerous concerns about the adequacy of the CEQA analysis. Their comments, and responses to the comments, are detailed in the paragraphs below. Limited Scope of Responses Comment: One letter states that CEQA does not allow a lead agency to ignore deficiencies in the EIR based on the timing of the comments sighting Section 15088(c) of the CEQA Guidelines. The City also received several written comments purporting to introduce “significant new information” necessitating recirculation of the RP-DEIR to revise various impact analyses beyond the impact analyses contained in the RP-DEIR. Response: However, as stated on Page 3-144 of the Final EIR, Guidelines Section 15088.5 (f)(2) permits the City to request that reviewers limit scope of their comments to that material which is within the text of the revised portions included in the revised portions of the recirculated EIR. Pursuant to this, the City requested that reviewers not make new comments on matters already addressed in the Original DEIR and not included in this RP-DEIR. In limited circumstances, the lead agency is required to provide additional analysis when “significant new information” is added to the EIR after public notice is given of the availability of the DEIR for public review under Section 15087 but before certification” of the EIR. The City has considered each of these comments, and recirculation of the RP-DEIR is not warranted because (1) such comments raise issues already addressed in the Original DEIR or the RP-DEIR and/or (2) the information in the comments does not constitute “significant new information" within the meaning of CEQA. Predetermined Outcomes Comment: The same letter further argues that adhering to LEED-ND criteria is overly proscriptive and indicates that it is in substitution to allowing for the mitigation impacts identified in a Final EIR, alleging that this undermines the purposes of CEQA. Response: The CASP underwent an extensive CEQA process that produced a Final EIR. The Final EIR includes a Mitigation Monitoring Plan that contained mitigation measures that were identified to reduce impacts disclosed as a result of the CEQA process, and were not a

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response to the LEED-ND criteria. The CASP relied on elements of LEED-ND in formulating part of the project description, which informed the assumptions of the environmental analysis; however, the LEED-ND criteria were not used as a substitute for the CEQA process. Traffic Comment: The letter also alleges that the Final EIR lacks any analysis of transit systems, how the sizable population increases will impacts transit operations, or the operation of streets. The letter further alleges the EIR lacks trip generation assumptions associated with the proposed land uses within the Project Area precluding the public from having a fair opportunity to assess whether the assumptions are proper. Response: The level of service impacts disclosed in the Final EIR traffic analysis would relate to transit as well as automobiles. As detailed in page 4-10 of the Original DEIR, the Project Area fosters rich transit service. Transit operators such as Metro would be responsible for adjusting transit services in response to substantial increases in ridership and would recover costs based on increases in fair collections. Such increases in ridership is anticipated and encouraged by the CASP in order to accommodate more growth at lower corresponding rates of VMT and would correspond to less, not more, traffic impacts. Increases in transit services would, in and of itself not result in environmental impacts since it is an area already well serviced by transit, and would likely replace automobile trips occurring elsewhere. Since the Final EIR is a programmatic document, traditional traffic study methodology based on trip generation characteristics of specific land use parcels was not seen as appropriate method, opting instead to develop a traffic model that was based on the Proposed Plan’s land use assumptions. See Response to Comment 27a-2 and 27a-14 of the Final EIR. Cumulative Impact Analyses Comment: The letter further alleges that the Final EIR falsely claims that the Los Angeles State Historic Park (LASHP) was included in the related project list of the Original DEIR. Response: Response to Comment 8-20 of the Final EIR states “The Los Angeles State Historic Park Master Development Plan DEIR was released on January 12, 2012 and the Original DEIR was released on September 22, 2011. Therefore, the project-related impacts of the LASHP were not known at the time of release of the Original DEIR. However, the LASHP DEIR included the Proposed Plan as a related project in the cumulative impact analysis, and therefore impacts related to the development of the LASHP and the Proposed Plan have been disclosed to the public pursuant to the requirements of CEQA Guidelines Section 15130.” The response RP8-20 did not claim the Los Angeles State Historic Park was on the related projects list in the Original DEIR for the CASP. The response RP8-20 goes on to state “[a]s part of the impact analysis, LASHP DEIR found that the LASHP would have a less than significant impact on traffic and air quality, and would therefore not contribute to a new traffic and air quality significant impact as evaluated in the Original DEIR. The LASHP DEIR found that the impacts to noise would be significant and unavoidable as a result of temporary fireworks displays. However, such impacts would be temporary, would not be a direct result of the Proposed Alternative, and would not occur within the operation hours of the significant noise impacts evaluated in the Original DEIR, and therefore would not lead to a substantial increase in the severity of an existing impact as previously evaluated in the Original DEIR.” Other Deficiencies

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Comment: The letter states that the City erred in properly deferring analysis of several impacts in contrast to the finding that such impacts were speculative due to the programmatic nature of the CASP. Response: The comment fails to provide any evidence that construction of water distribution facilities will result in potentially significant impact on air quality, greenhouse gas and noise impacts beyond what was assumed for project related construction activities already addressed in the Final EIR. Comment: The letter states that the EIR did not analyze the increase in demand on fire, police, and emergency services created by that increase in population. Response: In fact, these services are discussed throughout Chapter 14, Public Services and Recreation Facilities of the Original DEIR. In particular, fire protection is discussed in Section 14.1.2; police, in Section 14.1.1; and emergency services, in Section 14.1.3. These subjects are further discussed in Impact Public Services and Recreation Facilities 1, which was found to be less than significant on account of standard, citywide development procedure that mandates LAPD and LAFD review of all specific projects. In addition, the increased demand on public services is not considered an impact under CEQA, but rather if such demand will result in a need to construct additional buildings in response to meet the demand, and the construction of these buildings would result in a significant impact on the environment. Any construction of buildings to meet additional demand would more than likely occur on infill sites, and would not have a corresponding environmental impact. Comment: The letter states that the EIR did not sufficiently analyze cumulative air quality impacts related to new light industrial or research and development uses. Response: The health risk impacts of siting sensitive receptors in proximity to industrial sources was discussed in Section 2.A.1 of the RP-DEIR where health impacts due to proximity to TAC sources were determined to be a significant and unavoidable impact. Mitigation Measure Air Quality 3 was added to the RP-DEIR that requires air filters for sensitive uses proposed within the designated distances the TAC emitting industrial uses. Further, specific projects that include industrial uses will be required to comply with applicable environmental and health regulations, including SCAQMD permitting programs.

Comment: The letter states that the EIR did not sufficiently disclose potential odor impacts. Response: However, odor impacts were evaluated on Page 11-27 of the Original DEIR and found no existing noise violations that would warrant further consideration. Future projects would need to comply with existing regulations and standards including SCAQMD nuisance violations and the Specific Plan use restrictions on odor producing uses. Comment: The letter states that the Final EIR fails to include a sufficiently detailed description of the alternatives. Response: The project alternatives were listed and described on page 17-16 of the Original DEIR. The Modified Project Alternative was essentially the same as the Original Proposed Alternative with one change in land use designation applied to a single block. The No Redevelopment Alternative would be physically identical to the Original Proposed Alternative though would lack the CRA/LA Redevelopment Project Area designation included in the Original Proposed Alternative. The Reduced Project Standards Alternative (Proposed Plan) would be the same land use designations but at a uniformly lower development intensity. As such, since the

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document conducted a programmatic level review, no greater level of detail would be necessary to inform the environmental analysis. Comment: The letter states that the Final EIR fails to give a clear and adequate project description to enable an adequate analysis of project impacts. Response: Section 2.2.1.3 of the Original DEIR provided a general summary description of the Proposed Alternative’s new hybrid industrial land use designations (Urban Village, Urban Innovation, Urban Center), in addition to describing the Bonus FAR Incentive Program and other land use regulatory requirements. As a matter of practically, it would be redundant to include the precise detail of uses that would be permitted on any one site in the Project Area as this information was readily available prior to the release of the Original DEIR in the full Draft of the Proposed Plan. The full Proposed Plan was also included as Appendix A5 to the Final EIR. Noise Comment: The other letter states that the operation of loudspeakers or other public address systems in the Greenway Districts would exceed established maximum noise limits. Response: As discussed in Section 12.3.2.1 of the Original DEIR, the Proposed Alternative was shown to have a significant unavoidable impact that would expose noise-sensitive receptors as a result of changes in land use districts and onsite fixed noise sources associated with new development. Mitigation measures were included to require noise attenuation at fixed noise sources and proper sound insulation sufficient to meet interior noise standards in habitable rooms. The Los Angeles State Historic Park (LASHP) is a property included in the Greenway District. The LASHP Master Development Plan DEIR evaluated impacts to noise as a result of special events and found that the noise impacts would be significant and unavoidable as a result of temporary fireworks displays, though found that impacts from special events that involved amplification and loudspeakers would be mitigated. A requirement is included in the mitigation measures that event organizers submit noise management plans that would reduce amplified noise levels to less than 10 dB(A) over the ambient noise levels at the receptors. In response to this concern the October 11, 2012 Draft of the Plan includes the same noise management requirement and will require that the use of any audio system or fireworks, within any of the Proposed Plan zones will require a special event permit and noise management plan. Air Quality Comment: This second letter also states that the Final EIR failed to properly identify sensitive receptors in the Project Area for the purposes of disclosing project-related localized construction and operational impacts. The comment also states that the Final EIR generally fails to provide an analysis of localized construction impacts. Response: Cathedral High School is specifically referenced in the comment, which is located adjacent to the Project Area. The EIR is a programmatic document and there are no specific development projects proposed at this time that could be used to inform a localized impact analysis. Therefore, the quantification of peak daily construction emissions from site specific projects would be remote and speculative. However, the Final EIR disclosed that impacts due to localized construction and operational emissions would be significant and unavoidable and includes mitigation measures (Mitigation Measures Air Quality 11.11 and 11.12 in the MMP) that would apply throughout the Project Area to minimize impacts to the extent feasible. The addition of the Cathedral High School would not change the outcome of the analysis.

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Comment: The letter requests further clarification that SR-110 would be a source of diesel particulate matter (DPM) in the Project Area since all diesel trucks are not prohibited on the SR-110, but only large 5+ axle trucks. Response: The Final EIR concludes that health risks due to TAC exposure from freeway sources would be a significant and unavoidable impact. In addition Mitigation Measure Air Quality 11.2 requires all projects that propose sensitive land uses within the CARB-prescribed siting distances of at least 500 feet from either the I-5 or SR-110 freeways, to prepare a health risk assessment (HRA) and mitigate health risks to an acceptable level as defined therein. As this measure applies equally to locations near the I-5 or SR-110 freeways, no revision is necessary and the sources of TAC emissions from the SR-110 would not change the outcome of the analysis. Comment: The letter states that the RP-DEIR makes no attempt to identify the locations of the 111 facilities listed in the SCAQMD Facility INformation Detail (FINDs) list included in Appendix I of the RP-DEIR or the types of toxic air contaminates (TAC) emitted from these facilities. Response: The current locations of existing TAC sources are just one factor used to determine health risks to future sensitive receptors under the Proposed Plan. Other factors include location of future sensitive receptors and new TAC sources. As the Proposed Plan is a programmatic document, specific locations of future sensitive receptors and TAC sources are not available at this time to inform site specific analysis of health risk impacts due to TAC sources. The SCAQMD FINDs list was included to indicate to the public the types of activities that currently exist in the Project Area. The Final EIR concludes that health risk impacts due to industrial TAC sources is a significant and unavoidable impact and includes mitigation measures (Mitigation Measure Air Quality 11.3 through 11.10 in the MMP) to reduce impacts to the extent feasible. Specific locations and TAC emission of properties included in the SCAQMD FINDS list would not change the outcome of the analysis.

Comment: The letter states that sufficient information is not provided to support recommendation of proposing sensitive land uses within the CASP area. Specifically, the comment states that the TAC sources in the CASP ignores potentially substantial non-DPM sources of TACs, relies on outdated studies that do not include the entirety of the Project Area, and makes no attempt to verify whether new TAC sources were introduced in the last 12 years. Response: According to CARB, DPM constitutes approximately 70 percent of TAC sources. However, non-DPM sources in the Project Area were discussed on pages 2.A-6 to 2.A-9 of the RP-DEIR. The Los Angeles Transportation Commission (LATC) Health Risk Assessment (HRA), dated from 2007, included measurements of background TAC sources that were not due to the LATC. The scope of measurement included the entirety of the Project Area as shown in figures 2.A-2 and 2.A-3 of the RP-DEIR. The EIR is a programmatic document and there are no specific development projects proposed at this time. Methodological inputs about specific site location and orientation of TAC sources, and sensitive receptor locations, emission profiles and local meteorology are a few of the factors required to produce a quantitative health risk impact conclusion. Performing a quantitative analysis to determine the significant health risk impact to future residents could only be conducted at the time of the development of a specific project. However, as stated in the Final EIR, existing TAC emitting sources, such as freeways, industrial uses, and major railyard operations, are either in proximity or within the Project Area and could potentially result in a health risk impact to future sensitive receptors. Because sensitive receptors would potentially be permitted in proximity to TAC sources under the siting distances to industrial uses prescribed in the CARB Air Quality and Land Use Handbook, the discussion of health risk impacts related to

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TAC sources were considered significant and unavoidable. The analysis relied on existing sources such as the LATC HRA to identify existing and potential TAC sources and existing efforts underway to reduce major TAC sources in the Project Area. The information requested in the comment about new TAC sources since the LATC HRA was conducted would not change the outcome of the analysis. The LATC HRA was adequately referenced in the RP-DEIR and can be accessed at http://www.arb.ca.gov/railyard/hra/up_latc_hra.pdf. Comment: The letter states that the Final EIR should explain the increase in CO emissions after mitigation. Response: Page 2.A-26 of the RP-DEIR states that after the implementation of mitigation measures, construction air quality impacts would remain significant and unavoidable for ROG, NOx, CO and PM10 emissions satisfying Section 15126.2(b) of the Sate CEQA Guidelines. Comment: The letter states that only the CAlEEMod output files and not the input files were included in the RP-DEIR and that the validity of the analysis could not be verified. Response: Comment 27-43 also raised this issue and in response the CalEEmod input files were provided as Appendix A2 of the Final EIR. Comment: The letter requests that the SCAQMD LST for NO2 must be revised to account for the new 1-hour NO2 NAAQS. Response: As the State standard of 1.8 parts per billion is many times more stringent than the national standard of 100 parts per billion, no revision to the LST discussion is necessary. Comment: The letter states that Mitigation Measure Air Quality 12 should be required for both regional and localized impacts. Response: Mitigation Measure Air Quality 12 (Mitigation Measure Air Quality 11.12 in the MMP) is required for future construction regardless of whether the air pollutants are characterized as a local or regional impact. No further change is necessary. Comment: The letter states that since the RP-DEIR includes a new mixed use zoning area and new open spaces and parks, the operational air quality analysis should have also been recirculated to account for the changes to daily trips generated by these changes. Response: It is unclear what new mixed use zoning area and open space the letter was referring to as no new changes were introduced in the RP-DEIR from what was characterized in the Original DEIR. The Final EIR included a supplemental analysis of modifications to the Specific Plan (Revised Proposed Alternatives), which included operational air quality impacts resulting from the modifications. The Final EIR found that the modifications will not result in a new significant operational air quality impacts or result in a substantial increase in the severity of an existing impact as previously evaluated in the Original DEIR. Greenhouse Gas Impacts Comment: The letter states that construction impacts presented in the RP-DEIR cannot be verified and lacks information on the emission credits taken for operation of the project, indicating the emission credits may be excessive. Response: As stated above, CalEEmod input files which formed the basis of the analysis, were provided as Appendix A2 of the Final EIR, which provided the assumptions that informed the

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quantification of construction emissions and the emission reduction benefits resulting from the implementation of the mitigation measures. . Land Use Impacts Comment: The letter states that the EIR fails to analyze the Proposed Plan consistency with the identified goals and policies of the relevant Community Plans. Response: The evaluation of the Proposed Plan’s potential impacts to land use was provided on pages 3-26 through pages 3-28 of the Original DEIR. The letter does not provide evidence of policy conflict between the applicable community plans and the Specific Plan. Modifications Comment: The letter states that the draft of the Proposed Plan contains significant changes which have not been evaluated and will undercut the Proposed Plan goals and create significant impacts that have not been considered. Response: As stated above the Final EIR included a supplemental analysis of modifications to the Proposed Plan (Revised Proposed Alternatives). The Final EIR found that the modifications will not result in new significant impacts or result in a substantial increase in the severity of any existing impacts as previously evaluated in the Original DEIR and the RP-DEIR. All changes have been adequately addressed. Summary of Central and East Area Planning Commission Comments The Proposed Plan and accompanying changes were presented to the Central Area Planning Commission on Tuesday, September 11, 2012 for review and comment. The Plan was also presented to the East Area Planning Commission on Wednesday, September 12, 2012 for review and comment. The Plan was well received by both commissions. Commissioner Martorell with the Central APC inquired about the extent of outreach that had been conducted during the development of the Plan and Commissioner Marquez with the East APC expressed support for the Plan’s efforts to implement the LARRMP and improve connections to and awareness of the Los Angeles River. East APC Commission President Lopez inquired about the community’s response to the Proposed Plan’s parking standards.