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Page 1: 1639 9 Street Infill Environmental Checklist · 11/6/2019  · 1639, 1643, and 1649 9th Street Santa Monica, CA 90401 See Figure 1 for proposed location and vicinity map. The project
Page 2: 1639 9 Street Infill Environmental Checklist · 11/6/2019  · 1639, 1643, and 1649 9th Street Santa Monica, CA 90401 See Figure 1 for proposed location and vicinity map. The project

1639 9th Street

Happy Dog Project

Infill Environmental Checklist

November 2019

City of Santa Monica

Planning and Community Development 1685 Main Street Santa Monica, CA 90401

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Table of Contents

Introduction ...................................................................................................................................... 1

Purpose and Legal Authority ......................................................................................................... 1

Infill environmental checklist .......................................................................................................... 3

Environmental Factors Potentially Affected: ............................................................................ 18

I. Aesthetics ............................................................................................................................ 21

II. Agriculture and Forestry Resources ................................................................................. 27

III. Air Quality ............................................................................................................................ 29

IV. Biological Resources ...................................................................................................... 32

V. Cultural Resources ............................................................................................................. 36

VI. Energy ............................................................................................................................... 39

VII. Geology and Soils .......................................................................................................... 41

VIII. Greenhouse Gas Emissions ........................................................................................... 49

IX. Hazards and Hazardous Materials ............................................................................... 51

X. Hydrology and Water Quality .......................................................................................... 55

XI. Land Use and Planning ................................................................................................. 59

XIII. Mineral Resources .......................................................................................................... 69

XIV. Noise ................................................................................................................................. 69

XV. Population and Housing ................................................................................................ 72

XVI. Public Services................................................................................................................. 74

XVII. Recreation ....................................................................................................................... 76

XVIII. Transportation .............................................................................................................. 76

XIX. Tribal Cultural Resources ............................................................................................... 84

XX. Utilities and Service Systems .......................................................................................... 85

XXI. Mandatory Findings of Significance ........................................................................... 89

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Appendices Appendix A. Total Housing Units within 1800 feet of Project Site

Appendix B. Phase I and Phase II Environmental Site Assessment Documentation

Figures Figure 1. Regional Project Location ........................................................................................................... 8 Figure 2. Aerial Photo of Existing Project Site ............................................................................................ 9 Figure 3. Existing Project Site ...................................................................................................................... 10 Figure 4. Conceptual Rendering of Project ............................................................................................ 11 Figure 5. Ground Floor Plan ....................................................................................................................... 12 Figure 6. Second Floor Plan ....................................................................................................................... 13 Figure 7. Geological Hazards Map .......................................................................................................... 45 Figure 8. Zoning Designation for the Project Site ................................................................................... 62

Tables Table 1 Project Consistency with Scenic Quality Policies of LUCE ....................................................... 22 Table 2 Project Consistency with Zoning Standards .............................................................................. 60 Table 3 Project Consistency with the Land Use Goals and Policies of SCAG and LUCE ................. 63 Table 4 Project Consistency with Transportation Policies of SCAG’s RTP/SCS ................................... 78 Table 5 Project Consistency with Transportation Policies of LUCE ....................................................... 79 Table 6 Project Estimated Trip Generation .............................................................................................. 83

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INTRODUCTION

This document is an Infill Environmental Checklist to evaluate potential environmental

effects resulting from implementation of the proposed 1639 9th Street Happy Dog Project

(also referenced herein as the “project” or project”). The project is subject to the

guidelines and regulations of the California Environmental Quality Act (CEQA). Therefore,

this document has been prepared in compliance with the relevant provisions of CEQA

and the 2019 State CEQA Guidelines as implemented by the City of Santa Monica. This

Infill Environmental Checklist evaluates the potential direct, indirect, and cumulative

environmental effects associated with the project and demonstrates that such effects

have been previously and adequately analyzed in the LUCE EIR and/or impacts would

be less than significant.

PURPOSE AND LEGAL AUTHORITY

Guidelines, the City of Santa Monica as lead agency is required to analyze the potential

environmental impacts of a project. Senate Bill 226 (SB 226) signed into law in 2011, made

changes to the CEQA review process for infill projects. Specifically, SB 226 called for

establishing streamlined CEQA provisions for infill projects. These provisions are

implemented through CEQA Guidelines Section 15183.3, which states that to be eligible

for streamlining procedures, an infill project must:

1) Be located in an urban area on a site that either has been previously developed

or that adjoins existing qualified urban uses on at least 75% of the site’s perimeter;

2) Satisfy performance standards in Appendix M of the CEQA Guidelines; and

3) Be consistent with the general use designation, density, building intensity, and

applicable policies specified for the project area in either a sustainable communities

strategy or an alternative planning strategy.

For eligible infill projects, CEQA Guidelines Section 15183.3 state that:

“CEQA does not apply to the effects of an eligible infill project under two circumstances.

First, if an effect was addressed as a significant effect in a prior EIR for a planning level

decision,1 then, with some exceptions, that effect need not be analyzed again for an

individual infill project even when that effect was not reduced to a less than significant

level in the prior EIR.2 Second, an effect need not be analyzed, even if it was not analyzed

in a prior EIR or is more significant than previously analyzed, if the lead agency makes a

finding that uniformly applicable development policies or standards, adopted by the

lead agency or a city or county, apply to the infill project and would substantially mitigate

1 “Planning level decision” mean the enactment or amendment of a general plan or any general plan element,

community plan, specific plan, or zoning code.

2 “Prior EIR” means the environmental impact report certified for a planning level decision.

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that effect. Depending on the effects addressed in the prior EIR and the availability of

uniformly applicable development policies or standards that apply to the eligible infill

project, streamlining under this section will range from a complete exemption to an

obligation to prepare a narrowed, project-specific environmental document.”

Section 15183.3 is consistent with the directive in SB 226 that CEQA analysis of infill projects

“shall be limited” to effects that were not analyzed in a prior EIR or are more significant

than previously analyzed.

As demonstrated in this document, the project is an infill project that qualifies for the

CEQA streamlining provisions set forth in Section 15158.3 of the CEQA Guidelines.

Therefore, pursuant to CEQA, and these streamlining provisions as well as Appendix N of

the CEQA Guidelines, the City of Santa Monica has prepared this Infill Environmental

Checklist which demonstrates that the project’s environmental effects would be less than

significant and its effects were analyzed in the City’s previously certified Land Use and

Circulation Element Environmental Impact Report (LUCE EIR SCH #2009041117).

This Infill Environmental Checklist addresses all environmental issues listed in Appendix N

of the CEQA Guidelines. Based on the analysis provided within this checklist, the City has

concluded that the project would not result in new significant impacts on the

environment.

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CITY OF SANTA MONICA

INFILL ENVIRONMENTAL CHECKLIST

Project title:

1639 9th Street Happy Dog Project

Lead agency name and address:

City of Santa Monica

1685 Main Street

Santa Monica, CA 90401

Contact person and phone number:

Rachel Kwok, Environmental Planner

City Planning Division, Planning & Community Development Department

(310) 458-8341

Project location:

1639, 1643, and 1649 9th Street

Santa Monica, CA 90401

See Figure 1 for proposed location and vicinity map.

The project site is located at 1639, 1643, and 1649 9th Street in the Industrial Conservation

District of the City. The 29,034-square-foot project site is located at the eastern end of 9th

Street. The site consists of three parcels: Assessor’s Parcel Numbers:4283004010,

4283004011, and 4283004012.

Project sponsor’s name and address:

1639 9th Street LLC

1639, 1643, and 1649 9th Street

Santa Monica, CA 90404

General plan designation:

Industrial Conservation

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The Industrial Conservation District conserves Santa Monica’s small light industrial, and

service and commercial uses that have traditionally populated the industrial zone. Land

use restrictions in this district allow small workshop, warehouse, supply stores and

maintenance facilities that provide important community services and employment.

These uses assure that the City is able to maintain land where existing and new small

businesses can be incubated and supported. West of Euclid Court no housing is

permitted and only limited affordable housing may be allowed east of 17th Street.

Zoning:

Industrial Conservation District

Surrounding Land Use and Settings:

Existing development in the project vicinity consists of a mix of commercial and industrial

buildings of one to two stories in height. The properties along 9th Street to the immediate

north, south, and west of the project site support a variety of creative office and light

industrial cuses, including an animal shelter. The buildings are generally one to two stories

(see Figure 2, Aerial Photograph). The site is surrounded by the following land uses:

Southeast: buildings with creative office/post production uses

Southwest/West: one story City of Santa Monica animal shelter; and one-story

buildings with creative office/light industrial uses

North: One-story automobile service buildings

East: One-story light industrial buildings and light industrial buildings across 9th

Court

Other Public Agencies Whose Approval is Required:

None

Have California Native American tribes traditionally and culturally affiliated with the

project area requested consultation pursuant to Public Resources Code section

21080.3.1? If so, has consultation begun? ___________________________________

None. The project is considered CEQA exempt and therefore, tribal consultation is not

necessary.

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PROJECT DESCRIPTION

The project applicant proposes to construct a new two story building to house a dog

kennel with ancillary cafe at 1639 9th Street.

Existing Site

The project site encompasses the properties addressed as 1639, 1643, and 1649 9th Street

in the Industrial Conservation District of the City. The 23,094 square-foot (100 feet by 150.26

feet) project site is located at the end of 9th Street, which ends in a cul-de-sac (see

Chapter 3 for detailed description of project location). The site consists of three parcels:

Assessor’s Parcel Numbers 4283004010, 4283004011, and 4283004012. The site is generally

bordered by industrial use to the north, the City of Santa Monica Animal Shelter to the

west, alley to the east, and industrial use to the south. The project site is currently

developed with industrial buildings that are vacant:

• a 6,055 square foot one-story, metal-framed industrial building on the 1639 9th

Street portion of the site;

• a one-story, 5,500 square foot concrete block industrial building on the 1643 9th

Street portion; and,

• three, one-story concrete industrial buildings, totaling 2,225 square feet, on the

1649 9th Street portion of the site.

Automobile and pedestrian access to this segment of 9th Street is only available via

Olympic Boulevard, which functions as a one-way street heading in a westward direction

in this location. 9th Street is further cut-off from extending south of Olympic by the I-10

Freeway and the Lincoln Boulevard freeway off-ramp.

Surrounding Land Uses and Setting:

The project site is located on 9th Street within an

industrial area north of the I-10 freeway. Where

the project site is, 9th Street ends as a cul-de-

sac. Existing development in the project vicinity

consists of a mix of commercial and industrial

buildings of one to two stories in height (see

Figure 2, Aerial Photograph). The site is

surrounded by the following land uses:

Southeast: one story buildings with

creative office/post production uses

Southwest/West: one story City of Santa

Monica animal shelter; and one-story

buildings with creative office/light

industrial uses

North: One- to two story automobile

service buildings

Project at a Glance

Site Area: 23,094 sf

Proposed New Building Size (Gross): 13,413 sf

Proposed Height: 2 stories/32 feet

Parking:

Surface lot – with 20 spaces

Distance to light rail station

0.4 mile (8 minute walk)

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East: One-story light industrial buildings and light industrial buildings across 9th

Court

Currently, the project area is light industrial in character, and there are very few existing

pedestrian oriented uses along this stretch of 9th Street. The I-10 freeway to the south

separates the project area from residential neighborhoods in the Pico Neighborhood.

Existing Land Use Designation

The project site is located within the Industrial Conservation district as designated by the

City of Santa Monica General Plan Land Use and Circulation Element (LUCE).

Project Building and Uses

The project would demolish the existing buildings at 1639 and 1649 9th Street. An

approximately 13,413 sf 2-story building with a height of up to 32 feet would be

constructed at 1639 9th Street and at 1649 9th Street, a surface parking lot with 20 spaces

would be developed. The existing building at 1643 9th Street to remain – no plans have

been developed regarding the use of this building at this time).

The proposed building would be utilized for dog kennel uses with a lobby, meet and greet

areas for dogs, social areas, offices, and an ancillary café. Enclosed outdoor areas would

be located in the rear (east side) of the new building. The building would include terraces

and be designed with materials such as wood slat/siding system, glass, brick, and steel

frames.

Happy Dog would primarily receive dogs from City and County shelters and provide

canine housing, medical care, socialization, and training to facilitate their future

adoption. The facility would not keep more than 30 dogs at the facility at any given time.

Although certain staff would have 24-hour access to the facility, Happy Dog would not

be open to the public until 9 a.m. at the earliest allowing for time to feed, exercise, and

train the dogs. The facility would remain open to the public until 9 p.m., Sunday through

Thursday. Extended hours until 10 p.m. on Fridays and Saturdays would be intended to

allow Happy Dog to hold events and provide community outreach in order to further

facilitate dog rescue. These may include workshops and training services to potential and

current dog owners and partnership events or fundraisers with local businesses.

Access/Circulation/Parking

Pedestrian access to the project would be provided on the ground floor along the

building’s west facing 9th Street frontage. Parking for the proposed Happy Dog Project

and its ancillary café use would be accommodated in two surface parking lots with

space to accommodate 20 vehicles. Both lots are accessible from 9th Court service alley.

Sustainability Features

The project would, at a minimum, comply with the green building requirements included

in the City’s Green Building Standards and Energy Code. The City’s Energy Code (the

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latest update will become effective January 1, 2020) will require that non-residential

buildings such as the project have a solar photovoltaic system with a minimum rating of

2 watts per square foot of the building’s footprint. Additionally, depending on the type of

building:

• All-Electric Building: shall be designed to code established by the 2019 CEC.

• Mixed-Fuel Building: shall be designed to be 10 percent more efficient than the

code established by the 2019 CEC.

As required by the City’s TDM Ordinance, a TDM plan designed to achieve the City’s AVR

target for the project site would be prepared, and the project applicant must agree to

yearly monitoring, reporting and enforcement if needed. The TDM plan for the project

would establish trip reduction strategies, including on-site transportation information, and

transit pass subsidies.

Construction

The precise construction timeline for the project depends on the timing of entitlements

and permit processing, but is anticipated to begin in mid-late 2020. Demolition and

construction work would be conducted in accordance with the City’s permitted hours of

construction as set forth in the City’s Noise Ordinance, except as authorized by City-

issued After Hours Construction Permit(s) pursuant to SMMC § 4.12.110(e). Construction

would include the demolition of the existing industrial buildings at 1639 and 1649 9th Street

and construction of the new 2-story building. Construction of the building would require

grading and minor excavation to accommodate building foundations and support.

Project approvals:

Approvals required for implementation of the project or which may be sought for the

project include, but are not limited to, the following:

Approval of a Conditional Use Permit by the Planning Commission;

Approval by the Architectural Review Board of building design, colors and

materials, as well as landscaping, lighting and signage;

Any other incidental discretionary or administrative approvals needed for the

construction and operation of the project, including a construction haul route, building

permits, and Certificate of Occupancy.

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Figure 1. Regional Project Location

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Figure 2. Aerial Photo of Existing Project Site

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Figure 3. Existing Project Site

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Figure 4. Conceptual Rendering of Project

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Figure 5. Ground Floor Plan

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Figure 6. Second Floor Plan

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Section 15183.3 of the CEQA Guidelines provides streamlining provisions for qualified infill

projects. Infill projects that meet certain criteria may not require further environmental

review or may undergo a streamlined CEQA process.

I. INFILL PROJECT DEFINITION CRITERIA

Infill project includes the whole of an action consists of residential, commercial, retail,

transit station, school, or public office building uses, or any combination of such uses

that meet the eligibility requirements set forth in subdivision (b) [see below]. For retail

and commercial projects, no more than one half of the project area may be used for

parking. “Major Transit Station” means a site containing an existing rail transit station, a

ferry terminal served by either a bus or rail transit service, or the intersection of two or

more major bus routes with frequencies of service interval of 15 minutes or less during

the morning and afternoon peak commute periods. For the purposes of this section,

an “existing major transit stop” may include a planned and funded stop that is

included in an adopted regional transportation improvement program.

Subdivision B Requirements YES NO

Is the project located in an urban area on a site that either has

been previously developed or that adjoins existing qualified urban

uses on at least 75% of the site’s perimeter?

Does the project satisfy the standards in Appendix M of the CEQA

guidelines?

Is the project consistent with the general land use designation,

density, building intensity, and policies in SCAG’s adopted

Sustainable Communities Strategy?

Explain: The project would be supportive of SCAG’s Regional Transportation Plan/

Sustainable Communities Strategies (RTP/SCS), which emphasizes new land uses

within existing urbanized areas to reduce vehicle miles traveled (VMT),

congestion, and greenhouse gas (GHG) emissions. The project would provide a

dog kennel and ancillary café within walking distance of the Expo LRT Downtown

Santa Monica station. As a result, the project would be easily accessible by

public transit (Refer to Initial Study Section XI, Land Use and Planning).

If you answered “No” to the above question, the project does not qualify for CEQA Exemption or Streamlining as an

Infill Project pursuant to Section 15183.3.

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SATISFACTION OF APPENDIX M PERFORMANCE STANDARDS Provide the information

demonstrating that the infill project satisfies the performance standards in Appendix M:

1. Does the infill project include a renewable energy feature? If so, describe below. If not,

explain below why it is not feasible to do so.

The project would, at a minimum, comply with the green building requirements

included in the City’s Green Building Standards and Energy Code. The City’s Energy

Code (the latest update will become effective January 1, 2020) will require that non-

residential buildings such as the project have a solar photovoltaic system with a

minimum rating of 2 watts per square 18 mon of the building’s footprint. Additionally,

depending on the type of building:

• All-Electric Building: shall be designed to code established by the 2019 CEC.

• Mixed-Fuel Building: shall be designed to be 10 percent more efficient than the

code established by the 2019 CEC.

2. If the project site is included on any list compiled pursuant to Section 65962.5 of the

Government Code, either provide documentation of remediation or describe the

recommendations provided in a preliminary endangerment assessment or comparable

document that will be implemented as part of the project.

A Phase I and Phase II environmental site assessment was performed for the project site.

The property building at 1649 9th Street was occupied by a dry cleaning business from

as early as 1927 to as late as the 1930s. Dry cleaning operations typically use

chlorinated solvents, particularly tetrachloroethylene (PCE), during the dry cleaning

process. These solvents, even when properly stored and disposed of, can be released

from these facilities in small, frequent releases through floor drains, cracked

concrete, and sewer systems. Chlorinated solvents are highly mobile chemicals that

can easily accumulate in the soil and migrate to the groundwater beneath a facility.

Based on the timeline of operations, the facility operated at a time when the use,

storage, generation, treatment and disposal of hazardous substances and waste was

not regulated.

A Phase II environmental site assessment was conducted to further assess potential

contamination at the site due to the former dry cleaner business. On January 27, 2017,

four borings (B1 through B4) were drilled at the site. Soil samples were collected from

each boring at two, five, 10, and 15 feet below ground surface for a total of 16

samples. Based on the laboratory results for the soil samples, there is evidence that the

subsurface environment has been impacted by chlorinated solvents, specifically TCE.

However, the TC concentrations in soil gas were below the Department of Toxic

Substances Control’s commercial/industrial Soil Gas Screening Levels. Because the site

is being utilized for commercial uses, the detected concentrations in soil and soil gas do

not appear to represent a vapor intrusion concern or a threat to human health for the

current occupants of the property.

3. If the infill project includes residential units located within 500 feet, or such distance

that the local agency or local air district has determined is appropriate based on local

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conditions, a high volume roadway or other significant source of air pollution, as defined

in Appendix M, describe the measures that the project will implement to protect public

health. Such measures may include policies and standards identified in the local general

plan, specific plans, zoning code or community risk reduction plan, or measures

recommended in a health risk assessment, to promote the protection of public health.

Identify the policies or standards or refer to the site specific analysis, below.

Not Applicable. The project does not propose the siting of residential units located within

500 feet of a high volume roadway or other significant source of air pollution.

4. For residential projects, the project satisfies which of the following?

Located within a low vehicle travel area, as defined in Appendix M.

Located within ½ mile of an existing major transit stop or an existing stop along a

high quality transit corridor (attach map illustrating proximity to transit).

Consists of 300 or fewer units that are each affordable to low income households

(attach evidence of legal commitment to ensure the continued availability and use of

the housing units for lower income households for a period of at least 30 years, at monthly

housing costs, as determined pursuant to Section 50053 of the Health and Safety Code).

5. For commercial projects with a single building floor-plate below 50,000 square feet, the

project satisfies which of the following?

Located within a low vehicle travel area, as defined in Appendix M. (Attach VMT

map)

The project is within one-half mile of 1800 dwelling units. (Attach map illustrating

proximity to households) – See Figure below and Appendix A

Based on a review of 2010 Census data, there are approximately 6,273 housing units

located within 0.5 mile of the project site.

6. For office building projects, the project satisfies which of the following?

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Located within a low vehicle travel area, as defined in Appendix M. (Attach VMT

map)

Located within ¼ mile of an existing major transit stop

7. For school projects, the project does all of the following:

The project complies with the requirements in Sections 17213, 17213.1 and 17213.2

of the California Education Code.

The project is an elementary school and is within one mile of 50% of the student

population, or is a middle school or high school and is within two miles of 50% of the

student population. Alternatively, the school is within ½ mile of an existing major transit

stop or an existing stop along a high quality transit corridor (Attach map and

methodology).

The project provides parking and storage for bicycles and scooters.

8. For small walkable community projects, the project must be a residential project that

has a density of at least eight units to the acre or a commercial project with a floor area

ratio of at least 0.5, or both.

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ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project,

involving at least one impact that is a "Potentially Significant Impact" as indicated by the

checklist on the following pages.

Aesthetics/Shadows Agriculture and

Forestry Resources Air Quality

Biological Resources Cultural Resources Energy

Geology/Soils Greenhouse Gas

Emissions

Hazards &

Hazardous

Materials

Hydrology/Water Quality Land Use/Planning Mineral Resources

Noise Population/Housing Public Services

Recreation Transportation Tribal Cultural

Resources

Utilities/Service Systems Wildfire

Mandatory

Findings of

Significance

DETERMINATION: (To be completed by the Lead Agency)

On the basis of this initial evaluation:

I find that the infill project WOULD NOT have a significant effect on the environment

that either have not already been analyzed in a prior EIR or that are more significant

than previously analyzed, or that uniformly applicable development policies would

not substantially mitigate. Pursuant to Public Resources Code Section 21094.5,

CEQA does not apply to such effects. A Notice of Determination (Section 15094) will

be filed.

I find that the proposed infill project will have effects that either have not been

analyzed in a prior EIR, or are more significant than described in the prior EIR, and

that no uniformly applicable development policies would substantially mitigate

such effects. With respect to those effects that are subject to CEQA, I find that such

effects WOULD NOT be significant and a NEGATIVE DECLARATION, or if the project

is a Transit Priority Project a SUSTAINABLE COMMUNITIES ENVIRONMENTAL

ASSESSMENT, will be prepared.

I find that the proposed infill project will have effects that either have not been

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analyzed in a prior EIR, or are more significant than described in the prior EIR, and

that no uniformly applicable development policies would substantially mitigate

such effects. I find that although those effects could be significant, there will not be

a significant effect in this case because revisions in the infill project have been

made by or agreed to by the project proponent. A MITIGATED NEGATIVE

DECLARATION, or if the project is a Transit Priority Project, a SUSTAINABLE

COMMUNITIES ENVIRONMENTAL ASSESSMENT, will be prepared.

I find that the proposed infill project would have effects that either have not been

analyzed in a prior EIR, or are more significant than described in the prior EIR, and

that no uniformly applicable development policies would substantially mitigate

such effects. I find that those effects WOULD be significant, and an infill

ENVIRONMENTAL IMPACT REPORT is required to analyze those effects that are

subject to CEQA.

_______________________________________________________

Rachel Kwok

Environmental Planner

___________________

Date

EVALUATION OF THE ENVIRONMENTAL IMPACTS OF INFILL PROJECTS:

1) A brief explanation is required for all answers except “No Impact” answers that are adequately

supported by the information sources a lead agency cites in the parentheses following each question.

A “No Impact” answer is adequately supported if the referenced information sources show that the

impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault

rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors

as well as general standards (e.g., the project will not expose sensitive receptors to pollutants based a

project-specific screening analysis).

2) All answers must take into account of the whole action involved, including offsite as well as onsite,

cumulative as well as project-level, indirect as well as direct, and construction as well as operational

impacts.

3) For the purposes of this checklist, “prior EIR” means the environmental impact report certified for a

planning level decision, as supplemented by any subsequent or supplemental environmental impact

reports, negative declarations, or addenda to those documents. “Planning level decision” means the

enactment or amendment of a general plan, community plan, specific plan, or zoning code.

4) Once the lead agency has determined that a particular physical impact may occur as a result of an

infill project, then the checklist answers must indicate whether the nature and magnitude of that

impact has already been analyzed in a prior EIR. If the effect of the infill project is not more significant

than what has already been analyzed, that effect of the infill project is not subject to CEQA. The brief

explanation accompanying this determination should include page and section references to the

portions of the prior EIR containing the analysis of that effect. The brief explanation shall also indicate

whether the prior EIR included any mitigation measures to substantially lessen that effect and whether

those measures have been incorporated into the infill project.

5) If the infill project would cause an effect that either was not analyzed in a prior EIR, or is more significant

than what was analyzed in a prior EIR, the lead agency must determine whether uniformly applicable

development policies or standards that have been adopted by the lead agency, or city or county,

would substantially mitigate that effect. If so, the checklist shall explain how the infill project’s

implementation of the uniformly applicable development policies will substantially mitigate that effect.

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That effect of the infill project is not subject to CEQA if the lead agency makes a finding, based upon

substantial evidence, that the development policies or standards will substantially mitigate that effect.

6) If all effects of an infill project were either analyzed in a prior EIR or are substantially mitigated by

uniformly applicable development policies or standards, CEQA does not apply to the project, and the

lead agency may prepare a Notice of Determination.

7) Effects of an infill project that either have not been analyzed in a prior EIR, or that uniformly applicable

development policies or standards do not substantially mitigate, are subject to CEQA. With respect to

those effects of the infill project that are subject to CEQA, the checklist shall indicate whether those

effects are potentially significant, less than significant with mitigation, or less than significant. The lead

agency should indicate that an effect is "Potentially Significant" if there is substantial evidence that the

effect may be significant. If there are one or more "Potentially Significant Impact" entries when the

determination is made, an infill EIR is required. The infill EIR should be limited to analysis of those effects

determined to be potentially significant. (Sections 15128, 15183.3(d).)

8) "Less Than Significant With Mitigation Incorporated" applies where the incorporation of mitigation

measures will reduce an effect of an infill project that is subject to CEQA from "Potentially Significant

Impact" to a "Less Than Significant Impact." The lead agency must describe the mitigation measures,

and briefly explain how those measures reduce the effect to a less than significant level. If the effects

of an infill project that are subject to CEQA are less than significant with mitigation incorporated, the

lead agency may prepare a Mitigated Negative Declaration. If all of the effects of the infill project

that are subject to CEQA are less than significant, the lead agency may prepare a Negative

Declaration.

9) This is only a suggested form, and lead agencies are free to use different formats; however, lead

agencies should normally address the questions from this checklist that are relevant to an infill project's

environmental effects in whatever format is selected.

10) The explanation of each issue should identify:

a. the significance criteria or threshold, if any, used to evaluate each question; and

b. the mitigation measure identified, if any, to reduce the impact to less than significance.

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I. AESTHETICS

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Except as provided in Public Resources Code Section 21099, would the project:

a) Have a substantial

adverse effect on a

scenic vista?

b) Substantially damage

scenic resources,

including, but not limited

to, trees, rock

outcroppings, and historic

buildings within a state

scenic highway?

c) In non-urbanized area,

substantially degrade the

existing visual character

or quality of the site and

its surroundings? (Public

views are those that are

experienced from

publicly accessible

vantage point). If the

project is in an urbanized

area, would the project

conflict with applicable

zoning and other

regulations governing

scenic quality?

d) Create a new source of

substantial light or glare

that would adversely

affect day or nighttime

views in the area?

e) Produce extensive

shadows affecting

adjacent uses or

property?

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a) No Impact. The project area is urbanized and there are no scenic vistas available from

within and near the project site. Due to existing development and flat topography, off-site

scenic resources and scenic public views are not visible from the project site or area. As

such, the project would not have a substantial adverse effect on a scenic vista. No

impacts would occur.

b) No Impact. The project site and area is highly industrial in character. The site itself is

developed with vacant industrial buildings with low scenic quality. No scenic resources,

including scenic trees, rock outcroppings, or historic buildings within a state scenic

highway, are located on the project site or in the project area. There are no scenic

highways officially designated by the State in the City of Santa Monica. Furthermore, the

existing on-site trees do not possess any scenic value. The project would not damage

scenic resources. No impacts would occur.

c) No Impact. The project site is developed with several industrial buildings. The project

would demolish the industrial buildings at 1643 and 1649 9th Street and construct a new

two story 13,413 sf building. The project would have a maximum height of 32 feet with a

contemporary design. Although the project would represent an increase in height from

existing site conditions, this height would be consistent with the maximum height and FAR

allowed by the Zoning Ordinance for this site. Furthermore, the proposed building would

be designed with wood slats, bricks, glass, and other materials to create a more updated

modern appearance. Additionally, the building’s terraces, would create a more attractive

and interesting streetscape. Furthermore, final design review by the Architectural Review

Board would ensure that the City’s development and design standards and policies

addressing aesthetics would be met prior to final project approval. Therefore, the project

would not conflict with applicable zoning and other regulations governing scenic quality.

No Impact would occur.

Table 1 Project Consistency with Scenic Quality Policies of LUCE

Policy Relationship to Project

LUCE

LU4.3 Pedestrian-Oriented

Design. Engage pedestrians

with ground floor uses, building

design, site planning, massing

and signage that promote

vibrant street life and

emphasize transit and bicycle

access.

Consistent. The project would develop a new

contemporary building on an existing property

with low visual quality. The project’s building

would have wood slats, siding system and glass

facades and the building would be designed

with appropriate articulation in the form of

terraces to create a pedestrian scale.

Landscaped planters adjacent to the 9th Street

frontage will create an inviting pedestrian

environment and more attractive interface with

the sidewalk.

LU15.1 Create Pedestrian-

Oriented Boulevards. Orient the

City’s auto-dependent

boulevards to be inviting

Consistent. See discussion for LU4.3.

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Policy Relationship to Project

avenues with wider sidewalks,

improved transit, distinctive

architecture, landscaping,

trees, planted medians and

neighborhood–friendly

services—defining a new sense

of place where local residents

will be attracted to shop, work,

live and play.

LU15.3 Context-Sensitive

Design. Require site and

building design that is context

sensitive and contributes to the

City’s rich urban character.

Consistent. The proposed massing and 32-foot

height of the building would not be substantially

greater than the nearby one and two story

industrial and creative office uses. The project

would comply with the building envelope

requirements in the Zoning Ordinance. Building

mass, elevations, and façade materials would

be varied to promote visual interest.

Furthermore, final project design review by the

City’s Architectural Review Board would ensure

that the project would contribute to the

character of the area.

LU15.4 Open and Inviting

Development. Encourage new

development to be open and

inviting with visual and physical

permeability, connections to

the existing street and

pedestrian network, and

connections to the

neighborhoods and the

broader community.

Consistent. The project’s façade facing 9th

Street would be designed to include wood slats,

siding system, and glass creating the

appearance of permeability. Street frontage

planters will create an inviting pedestrian

environment and more attractive interface with

the sidewalk. As compared to the existing

industrial buildings on the site, the project would

represent an improvement, creating and open

and inviting environment.

LU15.7 Street–Level Pedestrian-

Oriented Design. Buildings in the

mixed-use and commercial

areas should generally be

located at the back of the

sidewalk or the property line

(street front) and include active

commercial uses on the ground

floor. Where a residential use

occupies the ground floor, it

should be set back from the

property line, be located one

half level above the street or

Consistent. See discussion for LU4.3.

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Policy Relationship to Project

incorporate design features to

provide privacy for the unit.

Front doors, porches and stoops

are encouraged as part of

orienting residential units to the

street.

LU15.8 Building Articulation.

Building façades should be well

designed with appropriate

articulation in the form of

setbacks, offsets, projections

and a mix of architectural

materials and elements to

establish an aesthetically

pleasing pattern. Large areas of

glass above the ground floor

require special design

consideration. Highly reflective

materials are to be avoided,

and dark or reflective glass is

prohibited.

Consistent. The building façades would be

designed with appropriate articulation in the

form of planters, terraces, and a mix of

architectural materials and elements to create

a pedestrian scale. Highly reflective materials

that could produce glare would not be utilized.

Project design including building materials

would be subject to Architectural Review Board

approval to ensure that the project would be

aesthetically pleasing and would not utilize

inappropriate reflective materials.

LU15.9 Pedestrian-Oriented

Design. Buildings should

incorporate pedestrian-scaled

elements with durable, quality

materials and detailing located

on the lower stories adjacent to

the pedestrian.

Consistent. See discussion for LU4.3.

LU15.10 Roofline Variation.

Buildings should be designed

with a variety of heights and

shapes to create visual interest

while maintaining a generally

consistent overall street front. To

achieve this goal, development

standards should provide

flexibility to encourage

buildings with interesting

silhouettes and skylines, and the

primary building façade shall

not be lower than the

designated minimum street

façade height.

Consistent. The roofline of the proposed building

would be varied, creating a visually interesting

appearance along the 9th Street frontage. The

building would feature slanted rooflines with

terraces and a mix of architectural materials to

promote visual interest and to improve the

existing visual appearance of the surrounding

area. Furthermore, final project design review

by the City’s Architectural Review Board would

ensure that the project would contribute to the

character of the area.

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Policy Relationship to Project

LU15.11 Building Façades and

Step Backs. Buildings should

generally conform to the

minimum and maximum

requirements for the street

façade height established for

their designated area. Portions

of a building façade higher

than the street frontage, 45 feet

for most mixed-use areas, shall

step back from the façade of

the floor below in a manner

that will minimize the visual bulk

of the overall building as

viewed from the public

sidewalks and roadway and

ensure maximum light, air and

sense of openness for the

general public.

Guidelines or standards for the

building mass above the

streetwall shall be established in

the zoning ordinance.

Consistent. The building façades would be

designed with appropriate articulation in the

form of terraces, and a mix of architectural

materials and elements to create a pedestrian

scale. The roofline of the proposed building

would be sloped in the front with a terrace at

the rear southern end, creating a visually

interesting appearance along the 9th Street

frontage. The project would comply with the

specified setback and building envelope

requirements in the Zoning Ordinance.

Furthermore, final project design review by the

City’s Architectural Review Board would ensure

that the project would improve the character of

the area.

LU16.1. Design Buildings with

Consideration of Solar Patterns.

In designing new buildings,

consider the pattern of the sun

and the potential impact of

building mass on habitable

outdoor spaces and adjacent

structures in order to minimize

shadows on public spaces at

times of the day and year when

warmth is desired, and provide

shade at times when cooling is

appropriate, and minimize solar

disruption on adjacent

properties.

Consistent. See discussion for Policy 15.2.

D27.10 Utilizing a variety of

heights, forms and materials to

create visual interest while

maintaining the traditional

character of the area are

encouraged. Building design

Consistent. See discussion for Policy LU15.10

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Policy Relationship to Project

should avoid uniformly flat roofs

or cornices in order to create

an interesting skyline.

D27.11 Ground floor uses along

the street are encouraged to

place pedestrian entrances,

storefronts and offices along

the front face of the building to

create pedestrian interest.

Consistent. See discussion for LU4.3.

d-e) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. Existing light and glare sources in the project area include vehicle

headlights from cars on the roadways, exterior and interior lighting from existing buildings,

street lights, and lighting from signage. The nearest light-sensitive land uses are the

residential uses on 9th Street (north of Colorado Avenue), which are located more than

650 feet to the north – these uses are at a considerable distance from the site and

separated by intervening development including Colorado Avenue.

The project would include new lighting sources such as interior lighting that would

emanate from the building and exterior lighting for safety. Lighting on the project site

would be similar to other development in the surrounding area, and would not substantially

increase nighttime lighting levels. Additionally, because of the lack of light sensitive uses in

the area, project-related lighting would not substantially degrade nighttime views near the

project site. Furthermore, all new lighting would be installed in accordance with applicable

regulations, including the Santa Monica Municipal Code (SMMC) Section 9.21.120

(Lighting) to ensure that lighting would not adversely affect views. The exterior of the

building would be maintained and would not incorporate highly reflective materials that

could produce glare. Therefore, impacts related to light and glare would be less than

significant.

The project’s 32 foot building would introduce shade/shadow effects that would be

greater than existing on-site. However, there are no nearby sensitive receptors including

residential uses near the project site. Impacts would be less than significant.

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II. AGRICULTURE AND FORESTRY RESOURCES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

In determining whether impacts to agricultural resources are significant

environmental effects, lead agencies may refer to the California Agricultural Land

Evaluation and Site Assessment Model (1997), prepared by the California Department

of Conservation as an optional model to use in assessing impacts on agriculture and

farmland. In determining whether impacts to forest resources, including timberland,

are significant environmental effects, lead agencies may refer to information

compiled by the California Department of Forestry and Fire Protection regarding the

state’s inventory of forest land, including the Forest and Range Assessment Project

and the Forest Legacy Assessment project; and forest carbon measurement

methodology provided in Forest Protocols adopted by the California Air Resources

Board (ARB). Would the project:

a) Convert Prime Farmland,

Unique Farmland, or

Farmland of Statewide

Importance (Farmland),

as shown on the maps

prepared pursuant to the

Farmland Mapping and

Monitoring Program of

the California Resources

Agency, to non-

agricultural use?

b) Conflict with existing

zoning for agricultural

use, or a Williamson Act

contract?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

c) Conflict with existing

zoning for, or cause

rezoning of, forest land

(as defined in Public

Resources Code section

12220(g)), timberland (as

defined by Public

Resources Code section

4526), or timberland

zoned Timberland

Production (as defined

by Government Code

section 51104(g))?

d) Result in the loss of forest

land or conversion of

forest land to non-forest

use?

e) Involve other changes in

the existing environment

which, due to their

location or nature, could

result in conversion of

Farmland to non-

agricultural use?

a-e) No Impact. The Land Use and Circulation Element (LUCE) and Zoning Ordinance

designates the project site as Industrial Conservation, which permits commercial uses

including dog kennel uses. No forest land or timberland zoning is present in the

surrounding area. The project site is fully developed with existing industrial buildings. The

project vicinity is fully urbanized with a mix of commercial and industrial buildings. No

existing agricultural land, forest land, or timberland zoning is present on the site or near

the project vicinity. The project would demolish the industrial buildings at 1639 and 1649

9th Street to construct a new 2 story building for a dog kennel and an ancillary cafe. The

project would not involve the conversion of farmland to non-agricultural use or

conversion of forest land to non-forest use either directly or indirectly. As a result, the

project would not conflict with any existing zoning for agricultural use, or a Williamson Act

contract with existing zoning for forest land or timberland. Therefore, the project would

not impact agricultural or forestry resources. No impacts would occur.

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III. AIR QUALITY

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Where available, the significance criteria established by the applicable air quality

management or air pollution control district may be relied upon to make the following

determinations. Would the project:

a) Conflict with or obstruct

implementation of the

applicable air quality plan?

b) Result in a cumulatively

considerable net increase of

any criteria pollutant for

which the project region is in

non-attainment under an

applicable federal or state

ambient air quality standard

(including releasing emissions

that exceed quantitative

thresholds for ozone

precursors)?

c) Expose sensitive receptors to

substantial pollutant

concentrations?

d) Result in other emissions

(such as those leading to

odors) adversely affecting a

substantial number of

people?

a) No Impact. The project site is located in the South Coast Air Basin (Basin), which

includes Orange County and the non-desert portions of Los Angeles, San Bernardino, and

Riverside Counties. The South Coast Air Quality Management District (SCAQMD) monitors

and regulates the Air Quality Management Plan (AQMP) for the Basin. A project is

deemed inconsistent with the air quality plan if its implementation would result in

population and/or employment growth that exceeds growth estimates in the applicable

air quality plan. Generally, the project would conflict with or potentially obstruct

implementation of an air quality plan if the project would contribute to population and/or

employment growth in excess of that forecasted in the SCAQMD’s adopted 2016 AQMP.

In turn, the AQMP relies upon growth projections developed and adopted by Southern

California Association of Governments (SCAG) Regional Transportation Plan (RTP), which

in turn, rely upon cities’ adopted general plan growth projections. Consequently,

compliance with the City’s General Plan typically results in compliance with the AQMP.

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In addition, the SCAQMD’s Air Quality Handbook states that a consistency finding should

be based on identifying whether a project would increase the frequency or severity of

existing air quality violations or cause or contribute to new air quality violations.

The project would demolish the existing industrial buildings at 1639 and 1649 9th Street and

construct a new building for dog kennel and ancillary café uses. Construction of the

building and operation generate air pollutants during construction and operation;

however, as discussed in Checklist Question XV Population and Housing, the project

would not induce or result in unplanned substantial population growth that would

substantially increase air quality violation as all employees (for construction and

operation) are anticipated to be drawn from the local area or within Los Angeles County.

Therefore, the project would be in compliance with growth projections used in the 2016

AQMP and no conflicts with the AQMP would occur. No impacts would occur.

b-c) Less than Significant Impact/ Within the Scope of Analysis in the Prior EIR/

Substantially Mitigated by Uniformly Applicable Development Policies. The project site is

located within the South Coast Air Basin, which is currently designated as a

nonattainment area for state and/or federal standards for O3, PM10, and PM2.5. The

project would generate air pollutants during construction, as a result of

grading/demolition and the use of equipment and trucks. Additionally, during operation,

the project would generate air pollutants in the form of vehicle emissions associated with

new visitor and employee vehicle trips as well as building energy demand.

Construction Emissions

Construction activity for the project would include demolition of all existing on-site uses,

excavation/grading, building construction, and architectural coatings. The use of heavy-

duty construction equipment and vehicle trips would generate emissions such as NOx

and PM10. The amount of air pollution generated from construction would vary

substantially from day to day, depending on the level of construction activity and

weather conditions. However, a number of state and local regulations would

substantially limit the generation of construction emissions related to the project. As

required by the U.S. EPA, California ARB, and as specified on the California Code of

Regulations (CCR) Title Division 3, Chapter 9, Article 4, Sec. 2423(b)(1), all off-road diesel

engines are required to meet at a minimum Tier 3 Emission Standards for off-road

compression-ignition engines (with proper diesel particulate control). Compliance with

this requirement would reduce the potential generation of NOx and PM10 emissions

Additionally, construction activity would occur in compliance with SCAQMD Rule 403

which would requires preventative measures such as covering up haul trucks carrying dirt

and properly cleaning streets in the vicinity. Compliance with this SCAQMD rule and other

best management practices as required by the SCAQMD would minimize fugitive dust

and NOx emissions. Based on the relative small size of the project (13,413 sf of new

construction) and the fact that the project site is located at a considerable distance from

sensitive receptors, the project would not exceed thresholds established by SCAQMD

and would not adversely affect sensitive receptors.

Furthermore, construction of the project is consistent with the LUCE and would be

consistent with the density and land use type permitted under the LUCE. Therefore, there

would be no construction air quality impacts that have not been previously examined or

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adequately addressed in the LUCE Program EIR (pg. 4.2- 20 through 4.2-21). Impacts

would be within the scope of those identified in the LUCE EIR, and would be less than

significant.

Operational Emissions

Operation of the dog kennel and ancillary café would generate air pollutant emissions

from the occasional use of landscaping equipment and natural gas consumption for

heating. Additionally, the proposed dog kennel uses would result in vehicle trips that

would contribute to air pollutant emissions from vehicles. However, based on the minimal

trip generation, its emissions would not be of a magnitude that have the potential to

generate substantial amounts of emissions or toxic air contaminants onto nearby sensitive

receptors. The café is ancillary to the dog kennel and would not be expected to

generate vehicle trips – rather the café would serve on-site and a small number of nearby

visitors and employees who would walk to the site.

Furthermore, the project is consistent with the LUCE and would be consistent with the

density and land use type permitted under the LUCE. Therefore, there would be no

operational air quality impacts that have not been previously examined or adequately

addressed in the LUCE Program EIR (pg. 4.2- 20 through 4.2-21). Impacts would be within

the scope of the analysis in the LUCE EIR, and would be less than significant.

d) Less than Significant Impact. The proposed dog kennel would not generate other

emissions such as those leading to odors that could adversely affect substantial numbers

of people. As part of the project’s conditions of approval, dog waste in outdoor

enclosures must be removed periodically throughout the day. Outdoor enclosure areas

must also be hosed down and cleaned at least 2 times per day. As such, impacts

associated with other emissions such as odors would be less than significant.

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IV. BIOLOGICAL RESOURCES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Have a substantial adverse

effect, either directly or

through habitat

modifications, on any

species identified as a

candidate, sensitive, or

special status species in local

or regional plans, policies or

regulations, or by the

California Department of Fish

and Game or U.S. Fish and

Wildlife Service?

b) Have a substantial adverse

effect on any riparian

habitat or other sensitive

natural community identified

in local or regional plans,

policies or regulations, or by

the California Department of

Fish and Game or U.S. Fish

and Wildlife Service?

c) Have a substantial adverse

effect on federally protected

wetlands (including, but not

limited to, marsh, vernal pool,

coastal wetlands, etc.),

through direct removal,

filling, hydrological

interruption or other means?

d) Interfere substantially with

the movement of any native

resident or migratory fish or

wildlife species or with

established native resident or

migratory wildlife corridors, or

impede the use of native

wildlife nursery sites?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

e) Conflict with any local

policies or ordinances

protecting biological

resources, such as a tree

preservation policy or

ordinance?

f) Conflict with the provisions of

an adopted Habitat

Conservation Plan, Natural

Community Conservation

Plan, or other approved

local, regional or state

habitat conservation plan?

a-d) No Impact /Within the Scope of Analysis in the Prior EIR. The City of Santa Monica is

generally urbanized, with few areas of native wildlife habitat occurring in the City or

immediate vicinity. The nearest wildlife habitat in the region occur along the coast at the

Santa Monica State Beach and substantial forested open space occurs in the Santa

Monica Mountains, located approximately 3.5 miles to the north. The project site is fully

developed with existing industrial buildings, and located in the highly urbanized Industrial

Conservation District of Santa Monica. No special status/sensitive species are known to

occur on the project site or the surrounding area. Additionally, given the urbanized

nature of the project area and considering that the project site has already been

disturbed, the likelihood presence of any sensitive or special status species is unlikely. No

riparian habitat or other sensitive natural community exists at the project site.

Furthermore, no wildlife corridors, native wildlife nursery sites, or bodies of water in which

fish are present exist near the project site. Due to the highly urbanized character of the

area, the potential for native resident or migratory wildlife species movement to occur

through the site is highly unlikely.

Therefore, the project would not have an adverse effect on any sensitive or special status

species or habitats and no impacts would occur. Additionally, the project would not

have a substantial adverse effect on federally protected wetlands nor would it interfere

with any native resident or migratory wildlife corridors and no impacts would occur.

This issue was analyzed in the LUCE Program EIR (pg. 4.3-20) which determined that there

are no riparian or sensitive habitats known to occur in the City of Santa Monica. The City

has little undisturbed native vegetation. In addition, there are no blueline streams or

wetland habitat. The LUCE Program EIR also found that the City is not recognized as an

existing or proposed, or Significant Ecological Area (SEA) that links wildlife populations. As

such, the project would not result in new biological impacts that have not been already

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analyzed in the LUCE Program EIR. Impacts would be within the scope of the analysis in

the LUCE EIR, and would not occur.

e) Less Than Significant Impact/Within the Scope of Analysis in the Prior EIR. The project

site is fully developed and located in an urbanized area in the City. There are no

biological resources, including native trees, existing on the project site. There are several

small public street trees adjacent to the project site within the right-of-way on 9th Street.

These trees are protected by the City’s Tree Ordinance and the City’s Urban Forest Master

Plan. As required by City regulations and guidelines, these street trees would be

protected in place during construction. No street trees would be removed by the project.

However, because construction and excavation work would occur near these trees

damage may occur to tree canopy or root zones and may cause the death of these

valuable trees. The City’s Urban Forest Master Plan requires the implementation of

measures for the protection of existing City trees during adjacent construction activities.

As required by the Urban Forest Master Plan and Section 7.14,110 of the Santa Monica

Municipal Code, during the construction phase of a project, a Tree Protection Zone (TPZ)

must be established around all City trees prior to the commencement of construction

activities. A TPZ is an area that will be delineated, either through fencing or another

mechanism, with the tree(s) posted to alert contractors and others on the site that no

equipment, materials, debris, supplies, or fill soil shall be located within the TPZ. All projects

must comply with this City requirement. Therefore, impacts would be less than significant.

This issue was analyzed in the LUCE Program EIR (pg. 4.3-24) which concluded that

implementation of the LUCE would be subject to all applicable federal, state, regional,

and local policies and regulations related to the protection of important biological

resources. These policies and regulations include: Federal Endangered Species Act,

Federal Migratory Bird Treaty Act, California Endangered Species Act, California Fish and

Game Code, and City of Santa Monica Tree Code. As such, the project would not result

in new biological impacts that have not been already analyzed in the LUCE Program EIR.

Impacts would be within the scope of the analysis in the LUCE EIR, and would be less

than significant.

f) No Impact/ Within the Scope of Analysis in the Prior EIR. As previously mentioned, no

habitat for any special status or sensitive biological species exists at the project site or in

the vicinity. The project site and surrounding area is urbanized with no natural habitat.

Accordingly, no Habitat Conservation Plan, Natural Community Conservation Plan, or

other approved habitat conservation plan applies to the project site. Therefore, no

impacts would occur.

This issue was analyzed in the LUCE Program EIR (pg. 4.3-20) which determined that no

habitat conservation plans, natural community conservation plans, or other approved

local, regional, or state habitat conservation plans apply to the City. Therefore, the LUCE

Program EIR determined that implementation of the LUCE and development occurring

under the LUCE would not result in impacts related to this issue. Since the project is

consistent with the LUCE and would be consistent with the density and land use type

permitted under the LUCE, there would be no land use impacts that have not been

previously examined or adequately addressed in the LUCE Program EIR. As such, the

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project would not result in new impacts that have not been already analyzed in the LUCE

Program EIR. No impacts would occur, consistent with the analysis in the LUCE EIR.

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V. CULTURAL RESOURCES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Cause a substantial adverse

change in the significance of

a historical resource pursuant

to §15064.5?

b) Cause a substantial adverse

change in the significance of

an archaeological resource

pursuant to §15064.5?

c) Disturb any human remains,

including those interred

outside of dedicated

cemeteries?

a) No Impact. A historical resource is defined in Section 15064.5(a)(3) of the CEQA

Guidelines as any object, building, structure, site, area, place, record, or manuscript

determined to be historically significant or significant in the architectural, engineering,

scientific, economic, agricultural, educational, social, political, military, or cultural annals

of California. Historical resources are further defined as being associated with significant

events, important persons, or distinctive characteristics of a type, period or method of

construction; representing the work of an important creative individual; or possessing high

artistic values. Resources listed in or determined eligible for inclusion in the California

Register, included in a local register, or identified as significant in a historic resource survey

are also considered historical resources under CEQA.

The project site is not listed on the City’s 2017 Historic Resources Inventory.3 The project

site is developed with a total of five industrial buildings, four of which would be

demolished. The first to be removed is at 1639 9th Street parcel is approximately 6,055

square feet and is a one-story, metal-framed industrial building built in 1956. Additionally,

on 1649 9th Street, the three attached one-story concrete industrial buildings, totaling

2,225 square feet (built in 1924, 1927, and 1950) would be removed. Demolition Permit

applications (19BLD-0116 and 119BLD-0445) were received and reviewed by the

3 City of Santa Monica Historic Resources Inventory; available online at https://www.smgov.net/Departments/PCD/Programs/Historic-Preservation/Historic-Resources-Inventory-Update-(2017)/; accessed April 25, 2019.

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Landmarks Commission on March 11, 2019.4 No action to designate and/or study the

property was taken. The one-story, 5,500 square foot concrete block industrial building

on the 1643 9th Street portion of the site would remain.

In addition to the buildings not being on the HRI, the project site and existing buildings

are not known to be associated with significant events or persons important in the past

and has no architectural significance. Therefore, the project site does not contain any

historic resources. Therefore, demolition of the industrial buildings as part of the project

would not result in a significant impact on a historic resource.

b) Less Than Significant Impact/ Within the Scope of Analysis of the Prior EIR/ Substantially

Mitigated by Uniformly Applicable Policies. There are no documented archaeological

resources in the project vicinity, based on historic aerial photography and property

records. No archaeological resources have been identified onsite or within the

immediate project area. Additionally, the site is considered to have low sensitivity for

archaeological resources. Multiple phases of development have occurred onsite, dating

to the 1920s. Project development would result in grading and minor excavations of the

ground surface for building foundations and support. Given prior development that has

occurred on the site and the minimal depth of excavation, the project is not anticipated

to encounter and adversely affect archaeological resources.

This issue was also analyzed in the LUCE Program EIR (pg. 4.4-45-46). As concluded in the

LUCE Program EIR, policy HP 1.10 requires avoidance or impact minimization would be

required in the event of discovery of archaeological resources. Therefore impacts would

be less than significant and is within the scope of the analysis in the LUCE Program EIR.

c) Less than Significant Impact/ Within the Scope of Analysis of the Prior EIR/ Substantially

Mitigated by Uniformly Applicable Policies: A prior cultural resources assessment for the

project site did not identify any human remains or known human burial sites on the project

site or in its vicinity. The project site has been heavily disturbed in the past and is currently

developed with industrial buildings, so it is unlikely that any human remains exist on the

site. However, the excavation and grading activities of the project could result in impacts

to previously undiscovered human remains.

California Health and Safety Code Section 7050.5, CEQA Section 15064.5, and Public

Resources Code Section 5097.98 mandate the process to be followed in the event of an

inadvertent or unanticipated discovery of any human remains in a location other than a

dedicated cemetery. Specifically, California Health and Safety Code Section 7050.5

requires that in the event human remains are discovered within a project site, disturbance

of the site shall be immediately halted. A qualified professional archaeologist must

inspect the remains and confirm that they are human, and if so shall immediately notify

the coroner in accordance with Public Resources Code Section 5097.98 and Health and

Safety Code Section 7050.5. If the coroner determines the remains are Native American,

the coroner shall contact the Native American Heritage Commission (NAHC). As

provided in Public Resources Code Section 5097.98, the NAHC shall identify the person or

persons believed to be most likely descended from the deceased Native American. The

4 City of Santa Monica Landmarks Commission meeting minutes, March 11, 2019; https://www.smgov.net/departments/pcd/agendas/Landmarks-Commission/2019/20190311/a20190311.htm

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most likely descendent makes recommendations for means of treating or disposing of,

with appropriate dignity, the human remains and any associated grave goods as

provided in Public Resources Code Section 5097.98. With compliance with existing

regulations prescribed in California Health and Safety Code Section 7050.5, CEQA

Section 15064.5, and Public Resources Code Section 5097.98, impacts to human remains

would be less than significant.

This issue was also analyzed in the LUCE Program EIR (pg. 4.4-47). As concluded in the

LUCE Program EIR, there is the possibility that human remains could be found in the

subsurface of the City. The LUCE Program EIR states that earth-disturbing development

activities associated with the LUCE could uncover buried human remains. However, State

CEQA Guidelines Section 15064.5 enumerates specific requirements for the evaluation

and treatment, in the event of an accidental discovery, of human remains. As

determined in the LUCE Program EIR, future development within the City would be

required to comply with CEQA, including Section 15064.5, and therefore, impacts would

be less than significant. As such, since the project is consistent with the LUCE and would

be required to comply with State requirements, there would be no impacts to human

remains that have not been previously examined or adequately addressed in the LUCE

Program EIR. Implementation of the project would not result in new impacts related to

human remains that have not been already analyzed in the LUCE Program EIR. Impacts

would be within the scope of the analysis in the LUCE EIR, and would be less than

significant.

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VI. ENERGY

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation

No

Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Result in potentially

significant environmental

impact due to wasteful,

inefficient or unnecessary

consumption of energy

resources during project

construction or

operation?.

b) Conflict with or obstruct

a state or local plan for

renewable energy or

energy efficiency?

a) Less Than Significant/Substantially Mitigated by Uniformly Applicable

Development Policies

Construction

Energy consumed during construction of the project would include electricity and

natural gas. The amount of electricity used during project construction would be minimal

because typical electricity demand would be limited to electrically powered hand tools

and/or small equipment, as-necessary nighttime lighting, and potentially, for a small

construction trailer that could be located on-site. Natural gas could be utilized to power

vehicles and equipment but would not be considered wasteful or inefficient since

construction would occur for a limited time. Therefore, impacts would be less than

significant.

Operation

After the completion of building construction, the dog kennel and ancillary cafe uses

would require electricity and natural gas for operation (electronic equipment, lighting,

heating, etc.). The City’s default electricity service provider is Clean Power Alliance,

which provides electricity consisting of renewable resources. Santa Monica customers

served by Clean Power Alliance (which include the project) are defaulted to receive its

electricity consisting of 100% renewables.

Additionally, the project would be required to comply with the City’s Energy Code

standards or the most recent standards at the time of building issuance The City’s Energy

Code (the latest update will become effective January 1, 2020) will require that non-

residential buildings such as the project have a solar photovoltaic system with a minimum

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rating of 2 watts per square foot of the building’s footprint. Additionally, depending on

the type of building:

• All-Electric Building: shall be designed to code established by the 2019 CEC.

• Mixed-Fuel Building: shall be designed to be 10 percent more efficient than the

code established by the 2019 CEC.

Therefore, because the project would implement sustainability features and would meet

the City’s Energy Code (which establishes more energy efficient standards than current

State standards), the project’s electricity consumption would not result in a wasteful and

inefficient use of energy resources. Therefore, it is likely that the project’s electricity

demand would be met by renewable resources.

Lastly, as an infill project located near transit opportunities, the project would not result in

the wasteful and inefficient consumption of transportation fuels. Employees would be

able to travel to the project site via transit provided by Expo LRT as well as bus service

provided by Big Blue Bus. Due to its urban location, the project site is also accessible via

walking/biking location for employees living in the area. A TDM plan would also be

implemented by the project applicant as required by the City’s TDM ordinance to reduce

vehicle trips and fuel usage.

Based on the above, the project would not result in a potentially significant

environmental impact due to wasteful, inefficient or unnecessary consumption of energy

resources. Impacts would be less than significant.

b) Less Than Significant Impact. The project would be required to comply with the

City’s Energy Code standards or the most recent standards at the time of building

issuance. The City’s Energy Code (the latest update will become effective January 1,

2020) will require that non-residential buildings such as the project have a solar

photovoltaic system with a minimum rating of 2 watts per square foot of the building’s

footprint. Additionally, depending on the type of building:

All-Electric Building: shall be designed to code established by the 2019 CEC.

Mixed-Fuel Building: shall be designed to be 10 percent more efficient than

the code established by the 2019 CEC.

Therefore, the project would not conflict with or obstruct a state or local plan for

renewable energy or energy efficiency. Impacts would be less than significant.

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VII. GEOLOGY AND SOILS

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Directly or indirectly cause potential substantial adverse effects,

including the risk of loss, injury or death, involving:

i) Rupture of a known

earthquake fault, as

delineated on the

most recent Alquist-

Priolo Earthquake

Fault Zoning Map

issued by the State

Geologist for the area

or based on other

substantial evidence

of a known fault?

Refer to Division of

Mines and Geology

Special Publication 42.

ii) Strong seismic ground

shaking?

iii) Seismic-related

ground failure,

including

liquefaction?

iv) Landslides?

b) Result in substantial soil

erosion or the loss of

topsoil?

c) Be located on a geologic

unit or soil that is unstable,

or that would become

unstable as a result of the

project, and potentially

result in on- or offsite

landslide, lateral

spreading, subsidence,

liquefaction or collapse?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

d) Be located on expansive

soil, as defined in Table

18-1-B of the Uniform

Building Code (1994),

creating substantial direct

or indirect risks to life or

property?

e) Have soils incapable of

adequately supporting

the use of septic tanks or

alternative wastewater

disposal systems where

sewers are not available

for the disposal of

wastewater?

f) Directly or indirectly

destroy a unique

paleontological resource

or site or unique

geological feature?

a-i) No Impact. The California Geological Survey (CGS) designates Alquist-Priolo

Earthquake Fault Zones, which are regulatory zones around active faults.5 These zones,

which extend from 200 to 500 feet on each side of known active faults, identify areas

where potential surface ruptures along active faults could prove hazardous and identify

where special studies are required to characterize hazards to habitable structures. CGS’

Alquist-Priolo zones update map does not indicate the project site as being located

across the Santa Monica Fault (CGS 2018). The project would not directly or indirectly

cause loss, injury, or death involving rupture of a known active or potentially active fault.

Therefore, no impacts related to fault rupture would occur.

a-ii) Less Than Significant Impact/Within the Scope of Analysis of the Prior EIR/Substantially

Mitigated by Uniformly Applicable Development Policies. The project site is located in the

seismically active region of southern California and as such, the project would be

potentially subject to strong ground shaking in the event of an earthquake on the Santa

Monica fault or any other fault in the region. The ground shaking that an area is subject

to experience is primarily a function of the distance between an area and the seismic

source, the type of material underlying a property, and the motion of fault displacement.

5 Active faults are those having historically produced earthquakes or shown evidence of movement within the past

11,000 years.

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The nearest fault to the project site is the Santa Monica Fault located approximately 0.77

mile north.

As with all development within the City, the project is required to comply with the

California Building Code (CBC) and Santa Monica Building Code (SMBC). The SMBC

includes requirements to ensure that new development does not cause or exacerbate

geological and soil hazards including seismic ground shaking and seismically-related

ground failure. Measures to minimize the risk of loss, injury, and death from the

construction of new buildings are included within the SMBC, with specific provisions for

seismic design. Additionally, the project would be required to meet the most recent

seismic-safety building criteria and construction design recommendations of a final

project-specific geotechnical report (as required by the City during the plan check

process). Required compliance with the seismic design and construction parameters of

the SMBC as well as the final geotechnical report would ensure that the project would

not directly or indirectly cause loss, injury or death to building employees and visitors from

seismic ground shaking. Therefore, impacts would be less than significant.

This issue was also analyzed in the LUCE Program EIR (pg. 4.5-23). As concluded in the

LUCE Program EIR, all new construction in the City would be required to comply with the

building design standards of the CBC and SMBC and would be required to incorporate

structural features, foundation modifications and improved materials and construction

methods that reflect current and future updated seismic and geologic safety standards

to mitigate adverse seismic impacts upon structures. The LUCE Program EIR concludes

that impacts would be less than significant. As such, since the project is consistent with

the LUCE and would be required to comply with State requirements, there would be no

impacts related to seismic groundshaking that have not been previously examined or

adequately addressed in the LUCE Program EIR. Implementation of the project would not

result in new impacts related to seismic ground shaking that have not been already

analyzed in the LUCE Program EIR. Impacts would be within the scope of the analysis in

the LUCE EIR, and would be less than significant

a-iii) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR/

Substantially Mitigated by Uniformly Development Policies. Soil liquefaction occurs when

loose, saturated, granular soils lose their inherent shear strength due to excess water

pressure that builds up during repeated movement from seismic activity. Factors that

contribute to the potential for liquefaction include a low relative density of granular

materials, a shallow groundwater table, and a long duration and high acceleration of

seismic shaking. Liquefaction usually results in horizontal and vertical movements from

lateral spreading of liquefied materials and post-earthquake settlement of liquefied

materials. Liquefaction potential is greatest where the groundwater level is less than 50

feet from the surface, and where the soils are composed of poorly consolidated, fine to

medium grained sand.

The project site is not mapped by the CGS as a liquefaction zone. In addition, according

to the City of Santa Monica’s Geologic Hazards Map, the project site is not located in an

area susceptible to liquefaction. Given the types of soils and the groundwater levels likely

to be present on the site, the project site does not appear to be susceptible to

liquefaction risk. Furthermore, the project would be required to meet the most recent

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building safety criteria and construction design recommendations of a final project-

specific geotechnical report (as required by the City during the plan check process).

Required compliance with the design and construction parameters of the SMBC as well

as the final geotechnical report would ensure that the project would not directly or

indirectly cause loss, injury or death to building employees and visitors from liquefaction.

Based on the above considerations, the potential for liquefaction occurring at the site is

considered low.

This issue was also analyzed in the LUCE Program EIR (pg. 4.5-22). As concluded in the

LUCE Program EIR, all new construction in the City would be required to first assess the

potential for liquefaction at the building site and to provide design recommendations to

mitigate the site’s liquefaction potential to the satisfaction of the City’s building official

prior to issuance of building permits and impacts would be less than significant. As such,

since the project is consistent with the LUCE and would be required to comply with State

requirements, there would be no impacts related to liquefaction that have not been

previously examined or adequately addressed in the LUCE Program EIR. Implementation

of the project would not result in new impacts related to seismic ground failure or

liquefaction that have not been already analyzed in the LUCE Program EIR. Impacts

would be within the scope of the analysis in the LUCE EIR, and would be less than

significant.

a-iv) No Impact/ Within the Scope of Analysis in the Prior EIR. Landslides occur when

slopes become unstable and masses of earth material move downslope. Landslides are

generally considered to be rapid events, often triggered during periods of rainfall or by

earthquakes. The project site and surrounding area has a flat topography with no

distinguishable slopes and is developed with industrial buildings. The probability of

seismically induced landslides affecting the project site is considered remote, due to the

lack of significant slopes on the site and surrounding area. Further, the project site is not

mapped by the City as being located in a Landslide Risk Area or mapped by the CGS as

an Earthquake-Induced was Area. Therefore, no impacts related to landslides would

occur.

This issue was also analyzed in the LUCE Program EIR (pg 4.5-20). As concluded in the

LUCE Program EIR, only the areas along the coastline and the northern edge of the City

would have the potential for landslides. The project area is characterized by a relative

flat terrain; no steep slopes exist in the area. Therefore, the potential for landslides is low

and there would be no geological impacts that have not been previously examined or

adequately addressed in the LUCE Program EIR. Implementation of the project would not

result in new impacts related to landslides that have not been already analyzed in the

LUCE Program EIR. Impacts would be within the scope of the analysis in the LUCE EIR, and

would be less than significant.

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Figure 7. Geological Hazards Map

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b) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR/ Substantially

Mitigated by Uniformly Applicable Development Policies. The project would require

grading and minor excavation of soils for the installation of building foundations and

support. Construction activity for the project would be conducted in accordance with

applicable requirements, including the City’s Urban Runoff Pollution Control Ordinance

to minimize soil erosion impacts. In addition, the project site is almost entirely

covered/developed with the existing buildings/surface parking lot and impervious

materials and is characterized by a flat topography. Construction of the project’s

building would result in minimal soil exposure, and as such, the potential for erosion

hazards is extremely low. Therefore, impacts with respect to soil erosion or the loss of soil

would be less than significant.

This issue was also analyzed in the LUCE Program EIR (pg. 4.5-23). As concluded in the

LUCE Program EIR, since land in the City is largely developed, the potential for large areas

of exposed topsoil that could be subject to erosion is considered minimal. However,

demolition and construction activities for new land uses within the City would be required

to comply with the erosion and sediment controls mandated by the National Pollution

Discharge Elimination System (NPDES) program and/or Section 7.10 of the Santa Monica

Municipal Code (Urban Runoff Pollution Control Ordinance). Therefore, compliance with

existing regulatory requirements would ensure that new land uses allowed under the

LUCE do not increase the level of soil erosion and loss of topsoil within the City. As such,

since the project is consistent with the LUCE and would be required to comply with NPDES

and SMMC requirements, there would be no soil erosion impacts that have not been

previously examined or adequately addressed in the LUCE Program EIR. Implementation

of the project would not result in new impacts related to soil erosion that have not been

already analyzed in the LUCE Program EIR. Impacts would be within the scope of the

analysis in the LUCE EIR, and would be less than significant.

c) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR / Substantially

Mitigated by Uniformly Applicable Development Policies. As discussed above, the

project site is not subject to landslides, lateral spreading, or liquefaction. The SMBC

includes requirements to ensure that new development does not cause or exacerbate

geological and soil hazards including collapse of soils. Measures to minimize the risk of

loss, injury, and death from the construction of new buildings are included within the

SMBC, with specific provisions for shoring. Additionally, the project would be required to

meet the most recent building safety criteria and construction design recommendations

of a final project-specific geotechnical report (as required by the City during the plan

check process). Required compliance with the design and construction parameters of

the SMBC as well as the final geotechnical report would ensure that the project would

not directly or indirectly cause loss, injury or death to building employees and visitors from

collapsible soils. Impacts resulting from collapsible soil would be less than significant.

Subsidence: The major cause of ground subsidence is withdrawal of groundwater.

According to the Phase I ESA, subsurface investigations performed at the nearby 1661

Lincoln Boulevard (File Number 904040034) property, the depth to groundwater is

identified as being between 40 and 60 feet below ground surface (bgs) with the direction

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of groundwater flow identified to flow towards the southwest. Soil borings advanced to

15 feet below ground surface for the Phase II ESA did not encounter groundwater. Project

construction would require minimal excavation and grading (no subterranean levels are

proposed). Therefore, groundwater would not be encountered by the project – and

groundwater withdrawals would not be require. Impact would be less than significant.

These issues were also analyzed in the LUCE Program EIR (pg 4.5-24 to 4.5-25). As

concluded in the LUCE Program EIR, new development projects occurring in the City must

submit a site specific geotechnical investigation that includes standards and

requirements for addressing expansive soils. The geotechnical investigation must be

submitted to the City for review and approval before a grading or building permit can

be issued by the City for a project. As concluded in the LUCE EIR, adherence to the

building code requirements as well as the geotechnical investigation requirements,

would reduce impacts related to expansive soils. As such, since the project is consistent

with the LUCE and would be required to comply with building code requirements and

the final geotechnical report, there would be no geological impacts that have not been

previously examined or adequately addressed in the LUCE Program EIR (pg. 4.2- 20

through 4.2-21). Implementation of the project would not result in new impacts related to

expansive soils that have not been already analyzed in the LUCE Program EIR. Impacts

would be within the scope of the analysis in the LUCE EIR and would be less than

significant.

d) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR / Substantially

Mitigated by Uniformly Applicable Development Policies. Expansive soils are soils that are

generally clayey, swell when wetted and shrink when dried. Wetting can occur in a

number of ways (i.e., absorption from the air, rainfall, groundwater fluctuations, lawn

watering, broken water or sewer lines, etc.). Expansive soils located beneath structures

can result in cracks in foundations, walls, and ceilings. Expansive soils located on slopes

can cause slope failure.

During the Phase II investigation conducted for the site, soil borings performed indicate

that the underlying subsurface consists predominantly of very fine-grained, loose, damp,

dark grayish brown silty sand (SM) from the ground surface to approximately two feet

below ground surface (bgs), underlain by olive brown, soft, moist, silty clay and silt (ML)

to 15 feet bgs. The SMBC includes requirements to ensure that new development does

not cause or exacerbate geological and soil hazards including collapse of soils. Measures

to minimize the risk of loss, injury, and death from the construction of new buildings are

included within the SMBC, with specific provisions for shoring. Additionally, the project

would be required to meet the most recent building safety criteria and construction

design recommendations of a final project-specific geotechnical report (as required by

the City during the plan check process). Required compliance with the design and

construction parameters of the SMBC as well as the final geotechnical report would

ensure that the project would not directly or indirectly cause loss, injury or death to

building employees and visitors from expansive soils.

This issue was also analyzed in the LUCE Program EIR (pg 4.5-24 to 4.5-25). As concluded

in the LUCE Program EIR, new development projects occurring in the City must submit a

site specific geotechnical investigation that includes standards and requirements for

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addressing expansive soils. The geotechnical investigation must be submitted to the City

for review and approval before a grading or building permit can be issued by the City

for a project. As concluded in the LUCE EIR, adherence to the building code requirements

as well as the geotechnical investigation requirements, would reduce impacts related to

expansive soils. As such, the project would not result in new impacts related to expansive

soils that have not been already analyzed in the LUCE Program EIR. Impacts would be

within the scope of the analysis in the LUCE EIR and would be less than significant.

e) No Impact. The project site is currently served by the City of Santa Monica’s

wastewater (sewer) system. Septic tanks and other alternative wastewater disposal

systems are not required or necessary for the project. Therefore, no impacts would occur.

f) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR. The project

would include excavation of the entire site to depths of up to 34 feet for construction of

the proposed subterranean parking garage. There are no unique geological features on

the project site as it is currently developed with industrial buildings. However, surface

deposits in the entire vicinity of the project site consist of older Quaternary Alluvium, and

are considered highly sensitive for paleontological deposits. Due to the high sensitivity of

paleontological resources in the area, excavation as shallow as six feet has the potential

to uncover fossils that may be buried in site soils. This issue was also analyzed in the LUCE

Program EIR (pg. 4.4-45-46). Consistent with LUCE Policy HP 1.10 which requires avoidance

or impact minimization, the project applicant will retain a professional paleontologist to

monitor ground-disturbing activities at the project site. If paleontological resources are

discovered, any discovered resources would be protected and curated if encountered

during project construction. Therefore, impacts would be less than significant.

This issue was also analyzed in the LUCE Program EIR (pg. 4.4-46). As concluded in the

LUCE EIR, policy HP1.10 of the LUCE requires that proposed developments for potential

impacts on paleontological resources or unique geological feature, and incorporate

appropriate mitigation measures to protect the resource. As such, since the project is

consistent with the LUCE and would comply with LUCE policy regarding paleontological

monitoring, there would be no impacts that have not been previously examined or

adequately addressed in the LUCE Program EIR. Implementation of the project would not

result in new impacts related to paleontological resources that have not been already

analyzed in the LUCE Program EIR. Impacts would be within the scope of the analysis in

the LUCE EIR and would be less than significant.

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VIII. GREENHOUSE GAS EMISSIONS

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Generate greenhouse gas

emissions, either directly or

indirectly, that may have a

significant impact on the

environment?

b) Conflict with an applicable

plan, policy or regulation

adopted for the purpose of

reducing the emissions of

greenhouse gases?

a) Less than Significant Impact/ Within the Scope of Analysis in the Prior EIR. GHG

emissions would occur from construction and operation activities associated with the

project. GHG emissions resulting from construction would be generated by heavy-haul

trucks and other construction equipment. Operation of the project would generate GHG

emissions from mainly mobile sources. However, the project would incorporate

sustainable features, including implementation of TDM measures (in accordance with the

City’s TDM) and solar photovoltaic panels that would reduce the amount of GHGs

generated by the operation of the project. The project site’s location near the Expo LRT

Downtown Santa Monica Station would also provide transit opportunities, thus promoting

a reduction in vehicle trips traveled and associated GHG. As an urban infill development

located near a variety of uses, the project is consistent with the LUCE and SCAG policies

to place new uses near transit and other uses. As such, the project would not emit

considerable amounts of GHG to cause extensive impacts to the environment.

Furthermore, development of the project is consistent with the LUCE and would be

consistent with the density and land use type permitted under the LUCE. Therefore, there

would be no greenhouse gas impacts that have not been previously examined or

adequately addressed in the LUCE Program EIR (pg. 4.14-28 through 4.14-33). Impacts

would be within the scope of the analysis in the LUCE EIR and would be less than

significant.

b) Less than Significant Impact/ Substantially Mitigated by Uniformly Applicable

Development Policies. The project would be consistent with the City’s GHG reduction

goals and policies established in the LUCE, Sustainable City Plan, and Climate Action

Plan. The project includes a number of characteristics and sustainable design features

intended to reduce overall GHG impacts. For example, it would be built in compliance

with the most recent updated Green Building Ordinance and Energy Reach Code

standards and include energy reduction features such as solar photovoltaic cells.

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Therefore, impacts to applicable plan, policy, or regulations addressing GHG emissions

would be less than significant.

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IX. HAZARDS AND HAZARDOUS MATERIALS

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Create a significant hazard

to the public or the

environment through the

routine transport, use or

disposal of hazardous

materials?

b) Create a significant hazard

to the public or the

environment through

reasonably foreseeable

upset and accident

conditions involving the

release of hazardous

materials into the

environment?

c) Emit hazardous emissions or

handle hazardous or acutely

hazardous materials,

substances or waste within

one-quarter mile of an

existing or proposed school?

d) Be located on a site which is

included on a list of

hazardous materials sites

compiled pursuant to

Government Code §65962.5

and, as a result, would it

create a significant hazard

to the public or the

environment?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

e) For a project located within

an airport land use plan area

or, where such a plan has

not been adopted, within

two miles of a public airport

or a public use airport, would

the project result in a safety

hazard for people residing or

working in the project area?

f) Impair implementation of, or

physically interfere with, an

adopted emergency

response plan or emergency

evacuation plan?

g) Expose people or structures

to a significant risk of loss,

injury or death involving

wildland fires?

a) Less Than Significant Impact. Operation of the project’s dog kennel and ancillary cafe

uses would involve the routine transport, use or disposal of commercially available

hazardous materials in small amounts for maintenance (e.g., cleaning solvents, paints)

and/or cleaning purposes. Hazardous materials would be contained, stored, and used in

accordance with manufacturers’ instructions and handled in compliance with

applicable standards and regulations. Large amounts of hazardous materials would not

be utilized or stored on-site. Therefore, impacts related to the routine transport, use, and

storage of these materials would be less than significant.

b) Less Than Significant Impact. A Phase I and Phase II environmental site assessment was

performed for the project site. The property building at 1649 9th Street was previously

occupied by a dry cleaning business from as early as 1927 to as late as the 1930s. Dry

cleaning operations typically use chlorinated solvents, particularly tetrachloroethylene

(PCE), during the dry cleaning process. These solvents, even when properly stored and

disposed of, can be released from these facilities in small, frequent releases through floor

drains, cracked concrete, and sewer systems. Chlorinated solvents are highly mobile

chemicals that can easily accumulate in the soil and migrate to the groundwater

beneath a facility. Based on the timeline of operations, the facility operated at a time

when the use, storage, generation, treatment and disposal of hazardous substances and

waste was not regulated.

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A Phase II environmental site assessment was conducted to further assess potential

contamination at the site due to the former dry cleaner business. On January 27, 2017,

four borings (B1 through B4) were drilled at the site. Soil samples were collected from each

boring at two, five, 10, and 15 feet below ground surface for a total of 16 samples. Based

on the laboratory results for the soil samples, there is evidence that the subsurface

environment has been impacted by chlorinated solvents, specifically TCE. However, the

TC concentrations in soil gas were below the Department of Toxic Substances Control’s

commercial/industrial Soil Gas Screening Levels. Because the site is being utilized for

commercial uses, the detected concentrations in soil and soil gas do not appear to

represent a vapor intrusion concern or a threat to human health for the current

occupants of the property.

Minor excavation for grading/building foundation would remove top soils with residual

levels of contaminants of concern and a soils management plan would be implemented

to properly manage and dispose of potentially contaminated soils and to ensure no

hazardous impacts would occur to construction workers.

Furthermore, demolition of the existing industrial buildings would be subject to state

regulations protecting construction workers from any asbestos materials or lead based

paint on-site. If ACMs are found present, the findings of ACMs testing must be

documented in a report that shall be submitted to the SCAQMD for review and approval

pursuant to SCAQMD Rule 1403. In addition, the City of Santa Monica Building and Safety

Division requires lead based paint testing and remediation prior to the issuance of any

demolition permits. Therefore, construction of the project would not create a significant

hazard to the public or the environment through reasonably foreseeable upset and

accident conditions involving the release of hazardous materials into the environment

impacts would be less than significant. As stated above in Question a, operation of the

dog kennel and ancillary cafe uses would involve the routine transport, use or disposal of

commercially available hazardous materials in small amounts for maintenance (e.g.,

cleaning solvents, paints) and/or cleaning purposes. Hazardous materials would be

contained, stored, and used in accordance with manufacturers’ instructions and

handled in compliance with applicable standards and regulations. The limited

use/storage of common hazardous materials would not create adverse risk to the public

or the environment. Therefore, operation of the project would not create a significant

hazard to the public or the environment through reasonably foreseeable upset and

accident conditions involving the release of hazardous materials into the environment

impacts would be less than significant.

c) Less Than Significant Impact. The nearest school to the project site is PS1 Pluralistic

School located at 1225 Broadway, approximately 1,200 feet (0.25 mile) to the north of

the project site. Intervening development, including Colorado Avenue, separates this

school from the project site. As discussed above, construction and operation of the dog

kennel and ancillary cafe uses would not create a hazard through the release of

hazardous materials, or routinely use, transport, or handle of notable quantities of

hazardous materials. Therefore, potential impacts associated with the emission of

hazardous materials near an existing or proposed school would be less than significant.

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d) Less Than Significant Impact. Based on the Phase I ESA, the subject property is

identified as a federal Facility Index System (FINDS)/ECHO (U.S. EPA's Enforcement and

Compliance History Online database) site, a federal Superfund Enterprise Management

System (SEMS) Archive (formerly Comprehensive Environmental Compensation and

Liability Act Information System (CERCLIS) No Further Remedial Action Planned (NFRAP))

site, a federal Emergency Response Notification System (ERNS) site, a California Facility

and Manifest Data (HAZNET) site, a California Hazardous Material Incident Report System

(CHMIRS).

The property building at 1649 9th Street was previously occupied by a dry cleaning

business from as early as 1927 to as late as the 1930s. Dry cleaning operations typically

use chlorinated solvents, particularly tetrachloroethylene (PCE), during the dry cleaning

process. These solvents, even when properly stored and disposed of, can be released

from these facilities in small, frequent releases through floor drains, cracked concrete,

and sewer systems. Chlorinated solvents are highly mobile chemicals that can easily

accumulate in the soil and migrate to the groundwater beneath a facility. Based on the

timeline of operations, the facility operated at a time when the use, storage, generation,

treatment and disposal of hazardous substances and waste was not regulated.

A Phase II environmental site assessment was conducted to further assess potential

contamination at the site due to the former dry cleaner business. On January 27, 2017,

four borings (B1 through B4) were drilled at the site. Soil samples were collected from each

boring at two, five, 10, and 15 feet below ground surface for a total of 16 samples. Based

on the laboratory results for the soil samples, there is evidence that the subsurface

environment has been impacted by chlorinated solvents, specifically TCE. However, the

TC concentrations in soil gas were below the Department of Toxic Substances Control’s

commercial/industrial Soil Gas Screening Levels. Because the site is being utilized for

commercial uses, the detected concentrations in soil and soil gas do not appear to

represent a vapor intrusion concern or a threat to human health for the current

occupants of the property.

Minor excavation for grading/building foundation would remove top soils with residual

levels of contaminants of concern and a soils management plan would be implemented

to properly manage and dispose of potentially contaminated soils and to ensure no

hazardous impacts would occur to construction workers. As such, the project would not

create a significant hazard to the public or the environment, and impacts would be less

than significant.

e) No Impact. As stated above, the project site is approximately 1.6 miles northwest of

the Santa Monica Municipal Airport. However, the project site is not located within the

Santa Monica Airport Influence Area. The project would not result in a safety hazard for

people residing or working in the project area. Therefore, no impacts would occur.

f) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable Policies.

The project would not impair or physically interfere with an adopted emergency response

plan or a local, state, or federal agency’s emergency evacuation plan. Operationally,

the project would not materially change the characteristics of the project site in a way

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that would alter emergency response or evacuation plans. Emergency access to the

project site is currently provided to emergency vehicles on 9th Street. After project

implementation, emergency access would continue to be available along this street. The

site plan for the project would be reviewed prior to issuance of a building permit to ensure

that all Santa Monica Fire Department fire safety requirements (including those related

to emergency access) would be met. The project would not result in inadequate

emergency access. Therefore, impacts would be less than significant.

g) No Impact. The project site is located in an urbanized area of Santa Monica

surrounded by commercial and light industrial uses. The project site is not located

adjacent to or intermixed with wildlands. As such, the project would not subject people

or structures to a significant risk of loss, injury, or as a result of exposure to wildland fires.

No impact would occur.

X. HYDROLOGY AND WATER QUALITY

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Violate any water quality

standards or waste

discharge requirements or

otherwise substantially

degrade surface or

groundwater quality?

b) Substantially decrease

groundwater supplies or

interfere substantially with

groundwater recharge such

that the project may impede

sustainable groundwater

management of the basin)?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

c) Substantially alter the existing

drainage pattern of the site

or area, including through

the alteration of the course

of a stream or river, o

through the addition of

impervious surfaces, in a

manner which would (i) result

in substantial erosion or

siltation on or off-site; (ii)

substantially increase the

rate or amount of surface

runoff in a manner which

would result in flooding on- or

offsite; (iii) create or

contribute runoff water

which would exceed the

capacity of existing or

planned stormwater

drainage system or provide

substantial additional sources

of polluted runoff; or (iv)

impede or redirect flood

flows?

d) In flood hazard, tsunami, or

seiche zones, risk release of

pollutants due to project

inundation?

e) Conflict with or obstruct

implementation of a water

quality control plan or

sustainable groundwater

management plan?

a) Less than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. Construction and operation of the project would comply with

applicable regulations and requirements that address water quality, including the City’s

Runoff Conservation and Sustainable Management Ordinance (Section 7.10 of the

SMMC). Therefore, the project would not violate any water quality standards or waste

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discharge requirements; or otherwise substantially degrade surface or ground water

quality. Impacts would be less than significant:

Construction: Project construction would require excavation of soils for the extension of

the basement floor area. In accordance with the City’s Runoff Conservation and

Sustainable Management Ordinance (Section 7.10 of the SMMC), Best Management

Practices (BMPs) and pollutant control measures would be employed during project

construction to minimize pollutants and reduce runoff to levels that comply with

applicable water quality standards. The following urban runoff reduction requirements

would be implemented during construction:

Any sediment or other materials that are tracked off the project or parcel

by vehicles or equipment shall be removed the same day. Where

determined to be necessary by the Director of Public Works, a temporary

sediment control BMP(s) shall be installed.

For any paint removal, paint preparation, pressure-washing or

sandblasting activities that will result in particles entering the air or landing

on the ground, BMP steps shall be implemented to prevent or minimize to

the maximum extent practicable such particle releases into the

environment. Discharge of wastes from such activities to the MS4 is

prohibited.

Plastic covering or equivalent shall be utilized to prevent erosion of an

otherwise unprotected area (e.g., stockpiles or materials stored adjacent

to the public right-of-way), along with treatment control BMPs to intercept

and safely convey the runoff to the municipal storm drains

Erosion drainage controls shall be utilized depending on the extent of

proposed grading and topography of the parcel to prevent runoff

Therefore, compliance with standards and regulations would ensure that project

construction impacts related to violation of water quality standards and waste discharge

requirements would be less than significant.

Operation: For operation, good housekeeping practices and BMPs would be

implemented to minimize polluted runoff in accordance with the City’s Runoff

Conservation and Sustainable Management Ordinance (Section 7.10 of the SMMC). This

ordinance requires onsite rainwater collection and non-potable water use for properties

15,000 square feet or greater. Throughout operation, new developments are required to

implement good housekeeping practices to minimize polluted runoff and prepare a

Runoff Mitigation Plan.

SMMC Section 7.10.090 requires that that the applicants for development projects in the

City submit a Runoff Mitigation Plan to the Department of Public Works for review and

approval at the time of building permit application submittal. The Runoff Mitigation Plan

must demonstrate that the project would be able to store and use for non-potable

and/or potable purposes, infiltrate, or evapotranspire the calculated SWQDv (e.g., the

water volume generated by a 0.75-inch twenty-four-hour storm event) through

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incorporation of low impact development design element(s) and Green Infrastructure

(e.g., rainwater or stormwater harvesting for non-potable uses, temporary storage and

infiltration into the ground, bio-retention-infiltration, bioswales, bio-infiltration pervious

pavement), or alternatively, pay a Runoff Reduction Fee unless payment of such a fee is

precluded by subsection (v) of Section 7.10.090. The BMP provisions set forth in the Runoff

Mitigation Plan would be implemented throughout the operational life of the project to

reduce the discharge of polluted runoff from the project site. Furthermore, as part of the

project’s conditions of approval, all outdoor dog areas shall have separate sewer

drainage that waste can be washed down in order to minimize pet waste from remaining

on ground surfaces for an extended period of time. Therefore, compliance with

standards and regulations would ensure that project operational impacts related to

violation of water quality standards and waste discharge requirements would be less

than significant.

b) No Impact. The project site is currently developed with industrial buildings. The project

would demolish the existing industrial buildings at 1639 and 1649 9th Street and develop

a new dog kennel and ancillary care. The existing site is completely impervious to

groundwater infiltration, and thus, the project’s construction of a new building and

surface parking lot would not decrease the amount of groundwater infiltration that would

occur at the project site when compared to existing conditions. Furthermore, the project

site does not overlie a groundwater recharge basin and no groundwater wells are

located within the vicinity. Development of the project would not interfere with

groundwater recharge or infiltration. Therefore, no impacts would occur.

c) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. Upon completion of the project, drainage patterns of stormwater

runoff from the project site would be similar to existing conditions. Storm water runoff

would flow from the roof of the new building/and site to the existing municipal storm

water system. As a result, the existing drainage patterns and volume of runoff would be

similar to existing conditions. The municipal storm water conveyance infrastructure

currently has adequate capacity to accommodate runoff from the project site, and no

downstream flooding is known to occur. Further, the City’s Department of Public Works

would have final review and approval of the Runoff Mitigation Plan to demonstrate that

the project would be able to store and use for non-potable and/or potable purposes,

infiltrate, or evapotranspire the calculated SWQDv (e.g., the water volume generated by

a 0.75-inch twenty-four-hour storm event). The project would not result in substantial

erosion or siltation on or off-site; result in flooding on- or offsite; exceed the capacity of

existing or planned stormwater drainage system or provide substantial additional sources

of polluted runoff; or impede or redirect flood flows. Therefore, the project would result

in a less than significant impact due to alteration of drainage patterns.

d) No Impact. The project site is not located in an area at risk of flooding such as a FEMA

flood zone or downstream of dams, levees, or flood control channels or a tsunami zone.

Areas susceptible to a tsunami in the City include areas below the Palisades Bluff, within

approximately 0.25 miles from the ocean and area susceptible to inundation from a

seiche are enclosed bodies of water. The project site is approximately 1.2 miles east of

the Pacific Ocean. As such, the project site and its vicinity are not in any tsunami hazard

zone. Furthermore, the potential for inundation by a seiche is considered non-existent,

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since there are currently no lakes of significant size or bays of the correct size depth and

geometry in the vicinity of the project site. Therefore, the project would not risk the release

of pollutants in an inundation zone. No impacts would occur.

e) No Impact. As previously stated, during project operation, good housekeeping

practices and BMPs would be implemented to minimize polluted runoff in accordance

with the City’s Runoff Conservation and Sustainable Management Ordinance (Section

7.10 of the SMMC). This ordinance requires onsite rainwater collection and non-potable

water use for properties 15,000 square feet or greater. Throughout operation, new

developments are required to implement good housekeeping practices to minimize

polluted runoff and prepare a Runoff Mitigation Plan. Furthermore, as part of the project’s

conditions of approval, all outdoor dog areas shall have separate sewer drainage that

waste can be washed down in order to minimize pet waste from remaining on ground

surfaces for an extended period of time. Therefore, the project would not conflict with a

water quality control plan.

Additionally, the project would not conflict with a groundwater management plan. The

project would develop a new dog kennel and ancillary café on an existing site that is

already completely impervious to groundwater infiltration, and thus would not decrease

the amount of groundwater infiltration that would occur at the project site when

compared to existing conditions. Furthermore, the project site does not overlie a

groundwater recharge basin and no groundwater wells are located within the vicinity.

Development of the project would not result in adverse effects on groundwater.

Therefore, no impacts would occur.

XI. LAND USE AND PLANNING

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Physically divide an

established community?

b) Cause a significant

environmental impact due to

a conflict with land use plan,

policy or regulation adopted

for the purpose of avoiding or

mitigating an environmental

effect?

a) No Impact/ Within the Scope of Analysis in the Prior EIR. The project site is located in

the Industrial Conservation District. Surrounding land uses in the area consist of a mix of

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animal shelter, creative office, and industrial uses within one story buildings. The project

site is located at the end of 9th Street north of Olympic Boulevard, is an existing urban

infill site, and developed with industrial buildings. The project would demolish the existing

industrial buildings at 1639 and 1649 9th Street and develop a new dog kennel and

ancillary cafe. Development of the project would be a continuation of compatible and

similar land uses that already exist in the project area.

The project would be developed within the boundaries of the existing parcels and would

not introduce roadways or other infrastructure improvements that would bisect or

transect the adjacent residential or commercial community. The project would not

create land use barriers or otherwise divide or disrupt the physical or visual arrangement

of the surrounding established community. Additionally, since all construction work would

be contained onsite, the project would not disrupt surrounding land uses. Therefore,

impacts related to the division of an established community would not occur.

This issue was also analyzed in the LUCE Program EIR (page 4.8-115). As concluded in the

LUCE Program EIR, development occurring under the LUCE would not physically divide

an established community. While some parts of the City are expected to undergo

change over time, the LUCE seeks to buffer existing residential neighborhoods are

buffered from the potential adverse impacts of changes elsewhere. Therefore, the LUCE

Program EIR concluded that no impact to established communities would occur. Since

the project is consistent with the LUCE and would be consistent with the density and land

use type permitted under the LUCE, there would be no land use impacts that have not

been previously examined or adequately addressed in the LUCE Program EIR (pg. 4.2- 20

through 4.2-21). Impacts would be within the scope of the analysis in the LUCE EIR and

would be less than significant.

b) Less Than Significant Impact. The following provides an analysis of the project’s

consistency with the applicable plans and development standards, particularly the City’s

Zoning Ordinance, LUCE, and SCAG’s Regional Transportation Plan and Sustainable

Communities Strategy. The analysis shows that the project would not result in physical

environmental impact as a result of an inconsistency with plan, policy, or regulation:

Zoning Ordinance

The project site is zoned Industrial Conservation (IC) – see Figure 8. Per the Zoning

Ordinance (Section 9.11.020), dog kennels uses in the IC district are allowed with a

Conditional Use Permit. Within the Industrial Conservation designation, Tier 1

development standards are 2 stories/32 feet with a FAR 1.0 and Tier 2 development

standards are 3 stories/45 feet with a FAR of 1.75. As shown in Table 2, the project is

consistent with the Tier 1 development standards set forth in the Zoning Ordinance.

Table 2 Project Consistency with Zoning Standards

Zoning Standard Project Consistent?

Tier 1 Projects

FAR of 1.0 0.46 (13,413 sf

proposed/29,034

sf site)

Yes

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Maximum stories/Height of 2/32’ 2/32’ Yes

Parking Requirement of 19 spaces 20 spaces Yes

Land Use and Circulation Element (LUCE)

The project site is located on 9th Street, specifically designated in the LUCE as Industrial

Conservation. This designation conserves small light industrial, and service and

commercial uses that have traditionally populated the industrial zone. Land use

restrictions in this district allow small workshop, warehouse, supply stores and

maintenance facilities that provide important community services and employment.

Therefore, the project’s development of the proposed dog kennel and cafe uses would

be consistent with the City’s LUCE.

The project would also be consistent with LUCE policies that encourage pedestrian- and

transit oriented development; provide community benefits; and contribute to the

creation of a complete, sustainable neighborhood that would reduce the amount of

vehicle trips in the City. The project site is located near transit in the Industrial Conservation

District, and is consistent with relevant land use goals and policies in the applicable

regional and local plans. As shown in Table 3, the project would not result in land use

impacts related to relevant LUCE policies, and impacts would be less than significant.

Southern California Association of Governments (SCAG)

The project would be supportive of SCAG’s 2016-2040 Regional Transportation Plan/

Sustainable Communities Strategies (RTP/SCS), which emphasizes new land uses within

existing urbanized areas to reduce vehicle miles traveled (VMT), congestion, and

greenhouse gas (GHG) emissions. The project is a proposed infill development that would

redevelop an existing urbanized site for new dog kennel and ancillary café uses. As a

result, the project would be easily accessible to/from the Expo LRT Downtown Santa

Monica station (0.5 mile away), as well as via bus routes provided by Big Blue Bus. The

project site is also within close proximity to the City’s bicycle lanes on 14th Street. Refer to

Table 3, Project Consistency with the Land Use Goals and Policies of SCAG.

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Figure 8. Zoning Designation for the Project Site

R2 (multi-unit residential)

IC (industrial conservation)

MUBL (mixed use boulevard low)

LT (Lincoln Transition)

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Table 3, Project Consistency with the Goals and Policies of SCAG and LUCE, below

outlines the project’s consistency with the applicable goals and policies of the LUCE. As

shown in Table 3, the project is consistent with the goals and policies of the LUCE as the

project would develop a low-scale,2 -story dog kennel and ancillary cafe in the Industrial

Conservation District. The proposed uses would be consistent with existing surrounding

land uses and the 9th Street façade of the building would activate the street and

contribute to a more pedestrian-friendly area.

Table 3 Project Consistency with the Land Use Goals and Policies of SCAG and LUCE

Policy Relationship to Project

SCAG Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS)

RTP Goal: Maximize the

productivity of our

transportation system.

Consistent. The project would support and

maximize the productivity of the transportation

system by locating a new dog kennel and

ancillary café in the City of Santa Monica,

within walking distance (0.5 mile) of the Expo

LRT Downtown Santa Monica station. Employees

of the project would have the opportunity to

use the Expo LRT for their commute.

Additionally, per the City’s Transportation

Demand Ordinance, the project would

implement a Transportation Demand

Management (TDM) plan to increase

alternative transportation usage and to further

improve the productivity of the regional

transportation system.

RTP Goal: Encourage land use

and growth patterns that

facilitate transit and non-

motorized transportation.

Consistent. The project site is near existing public

transit opportunities provided by the Expo LRT.

Specifically the site is within walking distance

(0.5 mile) of the Expo LRT Downtown Santa

Monica station. Additionally, the project is easily

accessible via bike on the Broadway bicycle

lanes. Therefore, project employees would have

easy access to alternative transportation

options.

SCS Goal 1. Better

Placemaking: The strategies

outlined in the 2016-2040

RTP/SCS promote the

development of better places

to live and work through

measures that encourage more

compact development, varied

housing options, bike and

pedestrian improvements, and

Consistent. The project is a compact, infill

project that would provide a new dog kennel

and ancillary cafe near the Expo LRT Downtown

Santa Monica station.

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Policy Relationship to Project

efficient transportation

infrastructure.

SCS Goal 5: Improved Access

and Mobility: Strategies

contained within the 2016–2035

RTP/SCS will help the region

confront congestion and

mobility issues in a variety of

ways, including improvements

to bicycle and pedestrian

facilities. Land use strategies in

the 2016–2040 RTP/SCS will

improve mobility and access by

placing destinations closer

together and decreasing the

time and cost of traveling

between them.

Consistent. The project would support improved

access and mobility by providing a new dog

kennel and ancillary café within walking

distance (0.5 mile) of the Expo LRT Downtown

Santa Monica station and in close proximity to

bicycle lanes on Broadway.

SCAG Compass/ Growth Visioning Principles

To realize the Growth Vision Principles, the Growth Vision encourages:

(1) Focusing growth in existing

and emerging centers and

along major transportation

corridors.

Consistent. The project site is located in the

Industrial Conservation District, near other

employment uses. The project site is within

walking distance (0.5 mile) of the Expo LRT

Downtown Santa Monica station.

(2) Creating significant areas of

mixed use development and

walkable communities.

Consistent. The project would develop a dog

kennel and ancillary cafe in a heavily industrial

area. The project site is within walking distance

to a variety of commercial uses and residential

uses.

(3) Targeting growth around

existing and planned transit

stations.

Consistent. The project site is located within

walking distance (0.5 mile) of the Expo LRT

Downtown Santa Monica Station.

(4) Preserving existing open

space and stable residential

areas.

Consistent. The project would not develop or

encroach onto existing open space and stable

residential areas.

LUCE

Policy LU3.1 Reduce Regional-

serving Commercial Uses:

Reduce regional office and

commercial uses and

encourage smaller floor plate

Consistent. The project would not develop large

floor plate regional office uses. The project

would develop a new dog kennel and ancillary

café that would be approximately 13,413 sf in

size.

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Policy Relationship to Project

office uses, housing and local

serving retail and services

LU4.2 Uses to Meet Daily needs.

Encourage uses that meet daily

needs such as grocery stores,

local-serving restaurants and

other businesses and activities

within walking distance of

residences to reduce the

frequency and length of

vehicle trips.

Consistent. The project would provide a new

dog kennel and ancillary cafe that would be

within walking distance to many nearby

residences.

LU4.3 Pedestrian-Oriented

Design. Engage pedestrians

with ground floor uses, building

design, site planning, massing

and signage that promote

vibrant street life and

emphasize transit and bicycle

access.

Consistent. The project would develop a

pedestrian oriented building on an existing

property with low visual quality. The project’s

building would have transparent facades and

the building would be designed with

appropriate articulation in the form of terraced

planters to distinguish each story and a mix of

architectural materials and elements to create

a pedestrian scale. Landscaped planters

adjacent to the 9th Street frontage will create

an inviting pedestrian environment and more

attractive interface with the sidewalk.

LU10.2 Benefits Tied to

Community Values. Require

new development that requests

height above the base to

provide measurable benefits to

foster complete neighborhoods

and support the goals of the

LUCE, including reducing

vehicle trips and GHG

emissions, maintaining diversity,

and promoting affordable and

workforce housing.

Consistent. The project is a Tier 1 project and as

such, the project would not be required to

provide community benefits.

Policy LU12.1 Maintain

Character: Rehabilitation of

Historic Resources – Promote

adaptive reuse of historic

structures and sensitive

alterations where changes are

proposed. New construction or

additions to historic structures

Not applicable. The existing industrial buildings

are not historic resources. Therefore, this policy is

not applicable to the project.

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Policy Relationship to Project

shall be respectful of the

existing historic resource.

LU15.1 Create Pedestrian-

Oriented Boulevards. Orient the

City’s auto-dependent

boulevards to be inviting

avenues with wider sidewalks,

improved transit, distinctive

architecture, landscaping,

trees, planted medians and

neighborhood–friendly

services—defining a new sense

of place where local residents

will be attracted to shop, work,

live and play.

Consistent. The proposed building would be

designed to engage and invite pedestrians. The

building would be pedestrian-scale with a mix

of interesting architectural materials, a terrace,

and landscaped planters, all oriented toward

9th Street.

LU15.4 Open and Inviting

Development. Encourage new

development to be open and

inviting with visual and physical

permeability, connections to

the existing street and

pedestrian network, and

connections to the

neighborhoods and the

broader community.

Consistent. The wood slat and wood siding

façade of the new building adjacent to the

sidewalk would provide visual and physical

permeability and connections to the existing

street and pedestrian network. Additionally,

street frontage landscaping will create an

inviting pedestrian environment and more

attractive interface with the sidewalk.

Policy HP1.8: Encourage the

preservation and regular

maintenance of mature trees

and landscaping that

contribute to the unique

character of a neighborhood.

Consistent. The project would preserve and

protect existing street trees. All existing street

trees would remain in place, and project

construction activities would not impact or

damage existing street trees.

Industrial Conservation District Policies

GOAL D27: Preserve and

protect an industrial area,

where traditional light industrial

uses may prosper and new

small businesses can be

incubated and supported.

Consistent. The project would develop a new

dog kennel and ancillary cafe in the Industrial

Conservation District. The project would thus

support small businesses.

D27.1 Preserve and protect the

existing industrial uses and allow

for new light industrial uses to

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Policy Relationship to Project

locate in the Industrial

Conservation District.

Policy T15.7: Monitor and

coordinate construction activity

to minimize disruption on the

transportation system.

Consistent. A Construction Impact Mitigation

Plan would be prepared to address traffic

impacts from demolition, site preparation, and

ongoing construction activities. Components of

the plan would include measures to address

vehicular and pedestrian safety, notification of

local business, identification of construction

parking, construction traffic and route design,

and construction scheduling. The Construction

Impact Mitigation Plan would be subject to

approval by the City prior to issuance of a

building permit. The approved mitigation plan

would be posted and available at the project

site for the duration of construction and would

be produced upon request.

Policy T19.2: Impose

appropriate Transportation

Demand Management (TDM)

requirements for new

development.

Consistent. In accordance with the City’s TDM

Ordinance (Chapter 9.53 of the SMMC), the

project’s applicant would implement a TDM

plan designed to achieve the City’s AVR target

is a requirement for project approval, and the

project applicant must agree to yearly

monitoring, reporting and enforcement if

needed. The TDM plan for the project would

establish trip reduction strategies, including on-

site transportation information and transit pass

subsidies.

Policy T21.3: TDM program

requirements shall be triggered

for new development

consistent with the LUCE

performance standards.

Consistent. See discussion for Policy T19.2.

Policy T25.2: Require that

parking be accessed only from

alleys, where alley access is

available.

Consistent. Consistent with City policies,

vehicular site access would be provided off 9th

Court alley. A loading area and trash enclosure

is also provided off the rear alley also.

Policy T25.3: Minimize the width

and number of driveways at

individual development

projects.

Consistent. The project would not increase the

number of driveways. Rather, the project would

remove existing curb cuts on 9th Street. Access

to the parking lot would be from 9th Court alley.

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Policy Relationship to Project

Policy T25.7: Encourage

installation of electrical outlets

in loading zones, including

signage, to reduce vehicle

idling associated with operating

refrigeration for delivery trucks.

Consistent. A loading area is provided at the

rear, off of 9th Court alley. Electrical outlets

would be provided for the loading area.

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XII. MINERAL RESOURCES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Result in the loss of

availability of a known

mineral resource that would

be of value to the region

and the residents of the

state?

b) Result in the loss of

availability of a locally

important mineral resource

recovery site delineated on

a local general plan, specific

plan or other land use plan?

a-b) No Impact. There are no known mineral resources within the project site. In addition,

no State of California designated operational mineral resource recovery sites are present

in the project vicinity (CA Dept. of Conservation 2014). The project would not occur in an

area known to contain mineral resources. Further, given that the project site is located

within a highly urbanized area of the City and has been previously disturbed by

development, the potential for mineral resources to occur onsite is low. Therefore, the

project would not result in the loss of availability of a mineral resource or a mineral

resource recovery site and no impacts would occur.

XIII. NOISE

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project result in:

a) Generation of a substantial

temporary or permanent

increase in ambient noise

levels in excess of standards

established in the local

general plan or noise

ordinance or of applicable

standards of other agencies?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

b) Exposure of persons to or

generation of excessive

groundborne vibration or

groundborne noise levels?

c) For a project located within

the vicinity of a private

airstrip or an airport land use

plan area or, where such a

plan has not been adopted,

within two miles of a public

airport or a public use airport,

would the project expose

people residing or working in

the project area to excessive

noise levels?

a) Less Than Significant/Substantially Mitigated by Uniformly Applicable Development

Policies. In accordance with Section 4.12.110 of Article 4 of the City’s Noise Ordinance,

construction activities would be restricted to the hours of 8:00 AM to 6:00 PM on

weekdays, 9:00 AM to 5:00 PM on Saturdays, and no construction activities would be

allowed on Sundays or public holidays except as authorized by City-issued After Hours

Construction Permit(s) pursuant to SMMC § 4.12.110(e). Given the project site’s location

in the Industrial Conservation District, there are no nearby residential uses that would be

adversely affected by project construction noise.

All construction activity would involve the use of heavy equipment as well as smaller

power tools and equipment that would produce noise. Haul trucks traveling on the streets

would generate increased noise as well. Construction would involve a different mix of

operating equipment, and noise levels would vary based on the amount and types of

equipment in operation and the location of the activity. The project construction

techniques would involve excavation and the use of typical “drill and pour” cast-in-place

concrete. No pile driving would be necessary for construction.

According to the City’s Noise Ordinance, noise from construction activities shall not

exceed 20 dBA over the exterior noise standards specified for the noise zone. The exterior

noise standard for Noise Zone III (industrial zone for the project site) is set at 70 dBA

anytime, thereby allowing for a maximum noise level of 90 dBA during these hours. As

shown in the table below, the use of certain equipment during project construction

activities could generate noise levels that may exceed the established exterior noise limit

of 90 dBA in an industrial zone. However Section 4.12.110(d) of the City’s Noise Ordinance

states that construction noise levels can exceed those standards during the hours of 10:00

AM and 3:00 PM since these hours are typically outside of normal sleeping hours. The

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project would be required to comply with the City’s Noise Ordinance and therefore, the

project would have less than significant construction impacts related to noise.

Furthermore, there are no nearby noise sensitive uses that would be adversely affected

by the project’s construction noise.

Table xx

Typical Construction Equipment Noise Emission Levels

Equipment Typical Sound Level (dBA) 50 Feet from Source

Air compressor 81

Backhoe 80

Compactor 82

Concrete mixer 85

Concrete pump 82

Concrete vibrator 76

Crane, mobile 83

Dozer 85

Generator 81

Grader 85

Impact wrench 85

Jackhammer 88

Loader 85

Paver 89

Pneumatic tool 85

Pump 76

Roller 74

Saw 76

Truck 88

During operation of the project, noise could be generated from barking dogs. As part of

the conditions of approval, the property owner will be required to limit excessive dog

barking in the outdoor areas. Indoor areas of the facility where dogs are kept will be

acoustically treated, as necessary, to mitigate excessive noise levels that are audible

outside the property boundaries. Additionally, no dogs will be allowed to be kept outside

between the hours of 9 p.m. and 7 a.m.

With regard to vehicle noise, the project would generate minimal employee and

customer vehicle trips. It would take a doubling of traffic volumes on the street to result

in a noticeable increase in noise (3 dBA). Additionally, mechanical equipment such as

HVAC equipment would also be screened in accordance with Section 4.12.130 of the

SMMC which requires that all mechanical equipment be designed with appropriate

noise control devices, such as sound attenuators, acoustic louvers, and/or sound

screens/parapet walls to comply with noise limitation requirements provided in Section

4.12.060 of the SMMC, which limits the exterior noise level to 60 dBA during the daytime

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hours and 50 dBA during the nighttime hours at the source. The project’s mechanical

equipment would be designed and installed in accordance with Sections 4.12.060 and

4.12.130 of the SMMC. Therefore, mechanical noise would be screened to minimize noise

levels on nearby uses. Operation of the project would not cause a substantial increase in

noise. Therefore, operational noise impacts would be less than significant.

b) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. As discussed above in Checklist Question XIV (a), the construction

would be limited and short-term. During construction, groundborne vibration would

occasionally occur during ground disturbance and foundation/pile installation activities.

However, impact pile driving (which could produce significant groundborne vibration)

would not occur during construction. Piles would be installed using less impactful

methods (such as cast-in-place, or drilling). Furthermore, noise and vibration from

construction would occur in conformance with the City’s Noise Ordinance. The City’s

Noise Ordinance exempts vibration levels during construction. Additionally, there are no

nearby historic resources that could be adversely impacted by construction vibration.

The operation of the project would also not generate a substantial temporary or periodic

increase in ambient noise levels in the project vicinity above existing levels. Dog kennel

and ancillary café uses are not uses that would result in groundborne vibration. Therefore,

groundborne vibration impacts would be less than significant.

b) No Impact. The project site is located approximately 1.6 miles northwest of the Santa

Monica Airport, but it is not within the airport land use plan. As a result, the project site is

located outside of the 65 and 75 CNEL Airport Land Use Plan Noise Contour. The project

would not expose people residing or working in the project area to excessive noise levels

from an airport or airstrip. Therefore, this project would have no impact.

XIV. POPULATION AND HOUSING

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Induce substantial

unplanned population

growth in an area, either

directly (e.g., for example by

proposing new homes and

businesses) or indirectly (e.g.,

through extension of roads or

other infrastructure)?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

b) Displace substantial numbers

of existing people or housing,

necessitating the

construction of replacement

housing elsewhere?

a) Less Than Significant Impact/ Within the Scope of Analysis in the Prior EIR. The project

would construct a new two story building for a dog kennel and ancillary cafe. The project

would not include construction of any housing units, and thus, would not directly induce

unplanned population growth. Construction employment opportunities provided by the

project, would not result in household relocation by construction workers due to the

relatively small project scale. During operation, it is anticipated that the project would

generate a moderate number of employment opportunities. These project employees

could indirectly increase the population of the City of Santa Monica; however, these

employees are anticipated to be drawn largely from the local area or within the region

and would not exceed the planned LUCE projections. As a result, employment for the

construction and operational of the project would not substantially induce population

growth. Therefore, the project would result in a less than significant impact.

This issue was analyzed in the LUCE Program EIR (pg. 4.10-20) which estimated the

population, housing, and employment growth anticipated to occur in the City of Santa

Monica through 2030. Since the project is consistent with the LUCE land use designation,

the project would not result in new population growth impacts that have not been

already analyzed in the LUCE Program EIR. Impacts would be within the scope of the

analysis in the LUCE EIR and would not occur.

b) Less Than Significant Impact. The project site is currently developed with industrial

buildings. As such, the project’s demolition of the existing industrial buildings at 1639 and

1649 9th Street would not displace existing housing units or people. Therefore, no impacts

would occur.

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XV. PUBLIC SERVICES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

With

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project result in substantial adverse physical impacts associated with the

provision of new or physically altered governmental facilities, need for new or physically

altered governmental facilities, the construction of which could cause significant

environmental impacts, in order to maintain acceptable service ratios, response times or

other performance objectives for any of the public services:

a) Fire protection?

b) Police protection?

c) Schools?

d) Parks?

e) Other public facilities?

a) Less Than Significant Impact. The project would develop a new dog kennel with

ancillary cafe. These uses would not create an unusually high fire risk, nor would they

increase the potential for emergency medical situations. Additionally, the project would

be designed in accordance with the applicable regulations of the Santa Monica Fire

Code pertaining to fire protection, such as the provision of adequate fire connections to

ensure adequate water flows, the installation of fire sprinklers, portable fire extinguishers,

smoke detection systems with fire alarms, and egress lighting and exit signage.

The project would result in a negligible demand for fire protection services (i.e., similar to

existing conditions) since the project would not generate a nighttime, permanent

residential population. Dog kennel and cafe uses are not uses that would generate a

high fire service demand. Expansion of existing SMFD facilities or personnel would not be

necessary to accommodate demand associated with the project. Therefore, impacts to

fire protection services would be less than significant.

b) Less Than Significant Impact. The dog kennel and ancillary cafe are not anticipated

to result in significant security risk or unusual high demand for SMPD services. As a result,

the demand for police protection services would be negligible (i.e., similar to existing

conditions) and the SMPD would not need to construct a new facility or alter an existing

facility to accommodate the project. Therefore, the project would result in a less than

significant impact.

c) Less than Significant Impact. The project would construct a new dog kennel and

ancillary cafe. No residential uses are proposed; and as such, the project would not

generate demand for school facilities. The project would not materially change

employment such that direct or indirect increases in demand for housing and school

facilities would result. Therefore, impacts to school facilities would be less than significant.

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d) Less than Significant Impact. As discussed in Section XV(a), Population and Housing,

the project would not introduce a new population that would create additional

demands on existing or planned park facilities. Further, the project would not displace or

directly impact existing parks or recreational facilities. Therefore, impacts to park facilities

or recreational facilities would be less than significant.

e) Less than Significant Impact. As previously the project’s moderate increase of

employees would not generate a residential population that would substantially increase

the demand for libraries or other public facilities. Therefore, impacts to other public

facilities would be less than significant.

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XVI. RECREATION

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

With

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

a) Would the project increase

the use of existing

neighborhood and regional

parks or other recreational

facilities such that substantial

physical deterioration of the

facility would occur or be

accelerated?

b) Does the project include

recreational facilities, or

require the construction or

expansion of recreational

facilities, which might have

an adverse physical effect

on the environment?

a) No Impact. As discussed in Section XV(a), Population and Housing, the project would

develop a new dog kennel with an ancillary cafe. The addition of new employees on the

project site would not create a substantial increase in demands on existing or planned

recreational facilities. The current parks and recreational facilities would not be

substantially affected by the potential increase in employment. Therefore, no impacts to

recreational parks or other recreational facilities would occur.

b) No Impact. The project would not include the development of or require the

construction of recreational facilities that would physically affect the environment.

Therefore, the project would not result in an increased demand for parks or recreational

services and no impacts would occur.

XVII. TRANSPORTATION

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation

No

Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation

No

Impact

Within the

Scope of

Analysis in

the Prior

EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

a) Conflict with a program, plan,

ordinance or policy

addressing the circulation

system, including transit,

roadway, bicycle and

pedestrian facilities?

b) For a land use project, would

the project conflict or be

inconsistent with CEQA

Guidelines Section 15064.3

subdivision (b)?

c) Substantially increase hazards

due to a geometric design

feature (e.g., sharp curves or

dangerous intersections) or

incompatible uses (e.g., farm

equipment)?

d) Result in inadequate

emergency access?

a) Less Than Significant Impact. The project would not conflict with a program, plan,

ordinance or policy addressing the circulation system, including transit, roadway, bicycle

and pedestrian facilities. SCAG’s RTP/SCS and the City’s LUCE, Sustainable Action Plan,

Bike Action Plan, and Pedestrian Action Plan provide guiding goals and policies for the

City’s circulation system, including transit, roadway, bicycle, and pedestrian facilities.

SCAG RTP/SCS

The 2016 RTP/SCS presents the transportation vision for the region through the year 2040

and provides a long-term investment framework for addressing the region’s

transportation and related challenges. The 2016 RTP/SCS includes nine goals that pertain

to economic development, mobility, accessibility, travel safety, productivity of the

transportation system, protection of the environment and health through improved air

quality, energy efficiency, and land use and growth patterns that complement the state

and region’s transportation investments, and security of the regional transportation

system.

The RTP/SCS provides goals and policies to minimize increases in regional traffic

congestion by focusing growth, density, and land use intensity within existing urbanized

area. The RTP/SCS encourages local jurisdictions to accommodate future growth near

high quality transit areas (HQTA) to reduce VMT, congestion, and greenhouse gas (GHG)

emissions. As indicated in the table below, the project would not conflict with SCAG’s

RTP/SCS.

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Table 4 Project Consistency with Transportation Policies of SCAG’s RTP/SCS

Policy Relationship to Project

SCAG Regional Transportation Plan/ Sustainable Communities Strategy (RTP/SCS)

RTP Goal: Maximize the

productivity of our

transportation system.

Consistent. The project would support and

maximize the productivity of the transportation

system by locating a new dog kennel and

ancillary cafe in the City of Santa Monica,

within walking distance of the Expo LRT

Downtown Santa Monica station. Employees of

the project would have the opportunity to use

the Expo LRT for their commute. Additionally,

per the City’s Transportation Demand

Ordinance, the project would implement a

Transportation Demand Management (TDM)

plan to increase alternative transportation

usage and to further improve the productivity of

the regional transportation system.

RTP Goal: Encourage land use

and growth patterns that

facilitate transit and non-

motorized transportation.

Consistent. The project site is located in an

urban infill area in the Industrial Conservation

district, near existing public transit opportunities

provided by the Expo LRT. Therefore, project

employees would have easy access to

alternative transportation options. Project

development would promote a land use

pattern that would facilitate transit and non-

motorized transportation.

SCS Goal 1. Better

Placemaking: The strategies

outlined in the 2016– 2040

RTP/SCS promote the

development of better places

to live and work through

measures that encourage more

compact development, varied

housing options, bike and

pedestrian improvements, and

efficient transportation

infrastructure.

Consistent. The project is a compact, infill

project that would provide a new dog kennel

and ancillary cafe within walking distance (0.5

mile) of the Expo LRT Downtown Santa Monica

station.

SCS Goal 5: Improved Access

and Mobility: Strategies

contained within the 2016–2040

RTP/SCS will help the region

confront congestion and

Consistent. The project would support improved

access and mobility by redeveloping an existing

underutilized site within walking distance of the

Expo LRT Downtown Santa Monica station and

in close proximity to bicycle lanes on 14th Street.

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Policy Relationship to Project

mobility issues in a variety of

ways, including improvements

to bicycle and pedestrian

facilities. Land use strategies in

the 2016-2040 RTP/SCS will

improve mobility and access by

placing destinations closer

together and decreasing the

time and cost of traveling

between them.

Additionally, bus lines that service the project

site are Big Blue Bus Lines 1, 4, 10, and Metro

Lines 1 and 704. The majority of these lines have

service frequency or headways of 30 minutes or

less, with peak-hour headways of 8 to 15

minutes.

SCAG Compass/ Growth Visioning Principles

To realize the Growth Vision Principles, the Growth Vision encourages:

(1) Focusing growth in existing

and emerging centers and

along major transportation

corridors.

Consistent. The project site is located in the

Industrial Conservation District on an urban infill

site near other employment uses. The project

site is within walking distance of the Expo LRT

Downtown Santa Monica station.

(2) Creating significant areas of

mixed use development and

walkable communities.

Consistent. The project would develop on a

new dog kennel in an area with a variety of

industrial and commercial uses nearby,

including an animal shelter and creative office

uses.

(3) Targeting growth around

existing and planned transit

stations.

Consistent. The project site is located within

walking distance (0.5 mile) of the Expo LRT

Downtown Santa Monica Station.

(4) Preserving existing open

space and stable residential

areas.

Consistent. The project would not develop or

encroach onto existing open space and stable

residential areas.

LUCE

The LUCE of the City’s General Plan integrates the City’s land use and transportation

planning functions; and governs existing and future land uses in the City. The LUCE has a

number of goals and policies addressing the circulation system, including transit, biking

and walking facilities. As indicated in Table 5 below, the project would not conflict with

the LUCE transportation policies.

Table 5 Project Consistency with Transportation Policies of LUCE

LUCE

Policy LU2.5: Vehicle Trip

Reduction. Achieve vehicle trip

reduction through

comprehensive strategies that

Consistent. The project would support a

reduction in vehicle trips by providing a new

dog kennel and ancillary cafe within walking

distance of the Expo LRT Downtown Santa

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designate land uses, establish

development and street design

standards, implement sidewalk,

bicycle, and roadway

improvements, expand transit

service, manage parking, and

strengthen TDM programs that

support accessibility by transit,

bicycle, and foot, and

discourage vehicle trips at a

district-wide level. Monitor

progress using tools that

integrate land use and

transportation factors. Increase

bicycle and pedestrian

connectivity in transit districts

and adjust bus and shuttle

services to ensure success of

the transit system.

Monica station and in close proximity to bicycle

lanes on 14th Street. Additionally, per the City’s

Transportation Demand Ordinance, the project

would implement a Transportation Demand

Management (TDM) plan to increase

alternative transportation usage and minimize

vehicle trips.

Policy LU8.1: Transportation

Demand Management. Require

participation in TDM programs

for projects above the base to

encourage walking, biking, and

transit, and to reduce vehicle

trips. Engage existing

development in TDM Districts

and programs to encourage

reduction of existing vehicle

trips.

Consistent. In accordance with the City’s TDM

Ordinance, the project’s applicant would

implement a TDM plan designed to achieve the

required AVR target and the project applicant

must agree to yearly monitoring, reporting and

enforcement if needed. The TDM plan for the

project would establish trip reduction strategies,

including on-site transportation information, and

transit pass subsidies.

Circulation Element

Policy T8.4: Design buildings to

prioritize pedestrian access

from the street, rather than from

a parking lot.

Consistent. The project would remove the

existing industrial buildings at 1639 and 1649 9th

Street and develop a dog kennel and ancillary

cafe. Pedestrian access to the project would be

provided on the along the building’s west

facing 9th Street frontage.

Policy T15.1 Reduce

automobile trips starting or

ending in Santa Monica,

especially during congested

periods, with the goal of

keeping peak period trips at or

below 2009 levels.

Consistent. See Policy LU2.5

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Policy T15.7: Monitor and

coordinate construction activity

to minimize disruption on the

transportation system.

Consistent. A Construction Impact Mitigation

Plan would be prepared to address traffic

impacts from demolition, site preparation, and

ongoing construction activities. Components of

the plan would include measures to address

vehicular and pedestrian safety, notification of

local business, identification of construction

parking, construction traffic and route design,

and construction scheduling. The Construction

Impact Mitigation Plan would be subject to

approval by the City prior to issuance of a

building permit. The approved mitigation plan

would be posted and available at the project

site for the duration of construction and would

be produced upon request.

Policy T19.2: Impose

appropriate Transportation

Demand Management (TDM)

requirements for new

development.

Consistent. See discussion for Policy LU8.1

Policy T21.3: TDM program

requirements shall be triggered

for new development

consistent with the LUCE

performance standards.

Consistent. See discussion for Policy LU8.1

Policy T25.2: Require that

parking be accessed only from

alleys, where alley access is

available.

Consistent. Consistent with this City policy,

vehicular site access to surface parking would

be provided off 9th Court alley. A loading area

and trash enclosure is also provided off the

alley.

Policy T25.3: Minimize the width

and number of driveways at

individual development

projects.

Consistent. The project would not increase the

number of driveways. Rather the project would

remove existing curb cuts on 9th Street. Access

to the parking would be from 9th Court alley.

Policy T25.7: Encourage

installation of electrical outlets

in loading zones, including

signage, to reduce vehicle

idling associated with operating

refrigeration for delivery trucks.

Consistent. A loading area is provided along 9th

Court alley. Electrical outlets would be provided

within the loading area.

Bike Action Plan: The Bike Action Plan, adopted in November 2011, guides the City's

efforts to promote an increase in safe bicycling consistent with the LUCE. The Bike Action

Plan includes a 5-year Implementation Plan to improve 75 percent of the City's bicycle

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network as well as a long term 20-year Vision Plan. The implementation priorities include

both bikeway and program investments. Recommended programs include efforts in all

program areas: events, awareness, information, education, encouragement,

enforcement and supporting facilities such as development of a bicycle wayfinding

system and bicycle parking improvements.

The project would not conflict with the actions or existing/future projects in the Bike Action

Plan. The project would develop a new dog kennel and ancillary cafe within the existing

site boundaries. There are no planned or existing bike facilities on 9th Street adjacent to

the project site. The project would not physically impede, conflict with, or remove existing

and future bike facilities identified in the Bike Action Plan. The project would also not

conflict with the City’s goals/policies to increase bicycling in the City. Rather, the project

would encourage employees to bike through implementation of a TDM plan.

Pedestrian Action Plan: The City of Santa Monica also adopted a Pedestrian Action Plan

in 2016. The plan provides a comprehensive approach to pedestrian policy in Santa

Monica using a multi-disciplined approach to making physical, operational and

educational improvements that prioritize pedestrians. The Plan introduces a Vision Zero

program which envisions zero fatalities from pedestrian crashes. The project would not

conflict with the actions or existing/future projects in the Bike Action Plan. The project

would develop a new dog kennel and ancillary cafe within the existing site boundaries.

The project would not physically impede, conflict with, or remove existing and future

pedestrian facilities identified in the Pedestrian Action Plan. The project would also not

conflict with the City’s goals/policies to increase bicycling in the City. Rather, the project

would encourage employees to walk to the site through implementation of a TDM plan

and would improve the existing sidewalk/pedestrian environment along 9th Street in the

project area. Additionally, as compared to the existing conditions, the project would

contribute to a more pedestrian friendly site.

b) Less Than Significant Impact. Section 15064.3 of the CEQA Guidelines was

adopted by the Office of Planning and Research in December 2018, and states that

vehicles miles traveled is the appropriate measure of transportation impacts. Cities and

jurisdictions must utilize VMT starting in July 1, 2020. Section 15064.3(c) also states that the

provisions of this section shall apply prospectively (i.e., only applicable to new projects

after date of adoption). The City of Santa Monica has not yet adopted significance

thresholds for vehicle miles traveled (VMT or a methodology for determining impacts

based on VMT. Therefore, this project’s transportation impacts is reviewed against the

City’s current methodology for analyzing transportation impacts, which is consistent with

the LUCE EIR.

The project consists of the development of a 13,413 sf new dog kennel and ancillary cafe.

Given the project’s size and minimal trip generation of 43 AM peak hour trips and 35 PM

peak hour trips as shown in Table 6, the project would not result in new traffic impacts on

intersections. The dog kennel would be limited to only 30 dogs. Based on empirical trip

data collection conducted for a dog training/boarding facility in 2017 in Santa Clara, the

project is anticipated to result in minimal trips of 2 AM peak hour trips and 3 PM peak hour

trips. These small amount of trips would not affect the operations of the transportation

system.

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Furthermore, the LUCE EIR had analyzed traffic impacts associated with future potential

growth occurring in the City, which included 566,803 net new sf of retail uses (pg 3-19 of

LUCE EIR). Since the project is consistent with the LUCE land use designation and would

be consistent with LUCE growth projections, there would be no new traffic impacts that

have not been previously examined or adequately addressed in the LUCE Program EIR

(pg 4.12-56 through 4.12-71). Implementation of the project would not result in new

impacts related to traffic that have not been already analyzed in the LUCE Program EIR.

Impacts would be within the scope of the analysis in the LUCE EIR and would be less than

significant.

Table 6 Project Estimated Trip Generation

#dogs AM Trip Rate

(per dog)

AM Peak

Hour Trips

PM Trip Rate

(per dog)

PM Peak

Hour Trips

Dog Kennel a 30 0.07 2.1 0.09 2.7

Trip generation rates from Operation Freedom Dogs Project Focused Traffic Study,

https://www.sccgov.org/sites/dpd/DocsForms/Documents/9413_SMPAC_20170524_Item4_Staffreport.pdf

Furthermore, in consideration of VMT impacts, the project site is located approximately

0.5 mile from the Expo LRT Downtown Santa Monica Station and is accessible via at least

5 bus lines with stops within ¼ mile. VMT impacts are not anticipated to be significant.

c) No Impact. The project would involve the construction of a new dog kennel and

ancillary cafe on an existing urban infill site. The project would not introduce any

hazardous design features such as dead ends, sharp curves, or dangerous intersections,

nor would the project involve any hazardous or incompatible uses. Therefore, no impacts

would occur.

d) Less Than Significant Impact. The project site is accessible to emergency vehicles

and evacuation routes are available via existing streets, including 9th Street. Emergency

access on 9th Street and to the project site would be maintained at all times during

construction as required. Therefore, impacts would be less than significant.

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XVIII. TRIBAL CULTURAL RESOURCES

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project cause a substantial adverse change in the significance of a tribal cultural

resource, defined in Public Resources Code section 21074 as either a site, feature, place,

cultural landscape that is geographically defined in terms of the size and scope of the

landscape, sacred place, or object with cultural value to a California Native American tribe,

and that is:

a) Listed or eligible for listing in

the California Register of

Historical Resources, or in a

local register of historical

resources as defined in Public

Resources Code section

5020.1(k), or?

b) A resource determined by

the lead agency, in its

discretion and supported by

substantial evidence, to be

significant pursuant to criteria

set forth in subdivision (c) of

Public Resources Code Section

5024.1. In applying the criteria

set forth in subdivision (c) of

Public Resources Code Section

5024.1, the lead agency shall

consider the significance of

the resource to a California

Native American tribe.

a and b) Less than Significant. Based on a review of City available resources, the Project

site is not listed or eligible for listing in the California Register of Historical Resources, or in a

local register of historical resources as defined in Public Resources Code section 5020.1(k).

Assembly Bill 52 (AB 52) requires lead agencies to conduct a formal consultation process

with California Native American Tribes to identify potential significant impacts to Tribal

Cultural Resources, as defined in Public Resources Code §21074, as part of CEQA. The

project is exempt from CEQA as documented in this Infill Checklist. Furthermore, there are

no previously documented prehistoric archaeological sites or ethnographically

documented camps within or near the Project site – indicating a low probability for Tribal

Cultural Resources to exist. Past development that have occurred on the Project site and

surrounding area, including grading and export of soil, further decrease the probability of

any tribal resources. Information has not identified substantial evidence that Tribal Cultural

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Resources exist on the project site or within a 0.25-mile radius of the project site. Therefore,

impacts are anticipated to be less than significant.

XIX. UTILITIES AND SERVICE SYSTEMS

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

Would the project:

a) Require or result in

the relocation or

construction of new or

expanded water,

wastewater treatment or

stormwater drainage,

electric power, natural gas,

or telecommunications

facilities, the construction or

relocation of which would

cause significant

environmental effects?

b) Have sufficient water

supplies available to serve

the project and reasonably

foreseeable future

development during

normal, dry and multiple

dry years?

c) Result in a

determination by the

wastewater treatment

provider that serves or may

serve the project that it has

adequate capacity to

serve the project’s

projected demand, in

addition to the provider’s

existing commitments?

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Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

with

Mitigation No Impact

Within the

Scope of

Analysis in

the Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

d) Generate solid

waste in excess of State or

local standards , or in

excess of the capacity of

local infrastructure or

otherwise impair the

attainment of solid waste

reduction goals?

e) Comply with federal,

state and local

management and

reduction statutes and

regulations related to solid

waste?

a) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. The project would develop a new dog kennel and ancillary cafe

within the boundaries of an existing urban infill site served by existing utilities. The project

is not anticipated to result in the relocation or construction of new utility lines. The

construction of new expanded sewer and water lines are not anticipated since the

project would be required to comply with the City’s Water Neutrality Ordinance, and as

such would off-set the net increase in water usage on the project site or contribute in-lieu

fees towards off-setting water demand at another location.

Furthermore, as part of the conditions of approval for the project’s Development Review

Permit, a flow capacity report would be required in order to determine if existing water

and sewer lines are necessary to adequately serve the project. Prior to the issuance of

the building permit, the applicant will be required to submit a sewer study to the City of

Santa Monica Public Works Department that shows that the City’s sewer system can

accommodate the project’s wastewater flows. The applicant will be responsible to

upgrade any downstream deficiencies, to the satisfaction of the Public Works

Department, if calculations show that the project will cause such mains to receive greater

demand than can be accommodated. Improvement plans will be submitted to the

Engineering Division. All reports and plans will also be approved by the Public Works

Department Civil Engineer. Furthermore, pursuant to Chapter 7.04 of the SMMC, the

project Applicant would be assessed a sewer service charge for the receiving,

transportation, pumping, treatment and disposal of sewage through the sewer system.

The sewer service charge money collected would be placed and deposited into a fund

for the purposes of the construction, operation and maintenance of the City’s

wastewater system and wastewater treatment facilities. Therefore, the project would not

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require the relocation of construction of new water and wastewater treatment facilities

or expansion of existing facilities. Impacts would be less than significant.

b) Less Than Significant Impact/Substantially Mitigated by Uniformly Applicable

Development Policies. As stated above, the project would be required to comply with

the City’s Water Neutrality Ordinance, and as such would off-set the net increase in water

usage on the project site or contribute in-lieu fees towards off-setting water demand at

another location. Therefore, impacts would be less than significant.

c) Less Than Significant Impact. Wastewater produced by the project would meet NPDES

requirements through treatment at the Hyperion Treatment Plant. This treatment plant

uses full secondary treatment and has recently been upgraded to reduce the amount

of wastewater solids going into Santa Monica Bay by 95 percent. In addition, this increase

in wastewater would also be within the City’s contractual entitlement for flows to the HTP.

Therefore, the project would not exceed RWQCB wastewater treatment capacity and

impacts would be less than significant.

d) Less Than Significant Impact/Within the Scope of the Analysis in the Prior EIR.

Construction and operation of the project would result in the need for solid waste disposal

at the County’s landfills. Project construction would generate construction and

demolition (C&D) waste such as asphalt, concrete, glass, and wood. SMMC Section

8.108.010, Subpart B, requires that demolition and/or construction projects greater than

$50,000 or 1,000 sf divert at least 70 percent of C&D material from landfills. With

approximately 36,783 sf of new floor space being constructed, the project would be

subject to this diversion requirement. The applicant shall complete a waste management

plan (WMP) to ensure the management of C&D waste, as required and approved by the

City as part of the application for the construction and demolition permit. Therefore, the

project’s C&D waste disposal would be reduced by at least 70 percent and the impacts

on landfills would be less than significant.

Throughout the operational life of the project, recyclable containers or bins would be

provided onsite to ensure that project-generated solid waste would be recycled or

reused to the greatest extent possible The project would not impact the ability of these

landfills to accommodate solid waste generated in Santa Monica. Furthermore, the dog

waste and other solid waste generated by the project falls within the waste generation

that was analyzed in the LUCE EIR. Since the project is consistent with the LUCE land use

designation and would be consistent with LUCE growth projections, there would be no

new solid waste impacts that have not been previously examined or adequately

addressed in the LUCE Program EIR. Implementation of the project would not result in

new impacts related to solid waste that have not been already analyzed in the LUCE

Program EIR. Impacts would be within the scope of the analysis in the LUCE EIR and would

be less than significant.

e) Less than significant. The project would not conflict with the goals of the City’s

Sustainable City Plan, AB341, or the Zero Waste Strategic Plan. As mentioned above,

during project construction, the City would comply with SMMC Section 8.108.010, Subpart

B, to divert at least 70 percent of C&D material from landfills. In accordance with the

SMMC, a Waste Management Plan (WMP) would be prepared prior to commencement

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of construction work. Additionally, throughout the operational life of the project,

recyclable containers or bins would be provided onsite to ensure that project-generated

solid waste would be recycled or reused to the greatest extent possible. Therefore, the

project would comply with federal, state, and local regulations related to solid waste and

would result in less than significant impacts.

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XX. WILDFIRE

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

With

Mitigation No Impact

Within the

Scope of

Analysis in the

Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

If located in or near state responsibility area or lands classified as very high fire hazard severity

zones, would the project:

a) Substantially impair an

adopted emergency response

plan or emergency

evacuation plan?

b) Due to slope, prevailing

winds, and other factors,

exacerbate wildfire risks, and

thereby expose project

occupants to, pollutant

concentrations from a wildfire

or the uncontrolled spread of a

wildfire?

c) Require the installation

or maintenance of associated

infrastructure (such as roads,

fuel breaks, emergency water

sources, power lines or other

utilities) that may exacerbate

fire risk or that may result in

temporary or ongoing impacts

to the environment?

d) Expose people or structures

to significant risks, including

downslope or downstream

flooding or landslides, as a

result of runoff, post-fire slope

instability, or drainage

changes?

a-d) No Impact. The project site is located in an urbanized area of Santa Monica

surrounded by commercial and residential uses. The project site is not located adjacent

to areas or lands classified as Very High Fire Hazard Severity Zone and is not intermixed

with wildlands. As such, the project would not subject people or structures to a significant

risk of loss, injury, or death as a result of exposure to wildfires. No impacts would occur.

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XXI. MANDATORY FINDINGS OF SIGNIFICANCE

Potentially

Significant

Impact

Less Than

Significant

(LTS) or LTS

With

Mitigation No Impact

Within the

Scope of

Analysis in the

Prior EIR

Substantially

Mitigated by

Uniformly

Applicable

Development

Policies

a) Does the project have

the potential to degrade the

quality of the environment,

substantially reduce the

habitat of a fish or wildlife

species, cause a fish or wild-life

population to drop below self-

sustaining levels, threaten to

eliminate a plant or animal

community, substantially

reduce the number or restrict

the range of rare or

endangered plants or animals,

or eliminate important

examples of the major periods

of California history or

prehistory?

b) Does the project have

impacts that are individually

limited, but cumulatively

considerable? "Cumulatively

considerable" means that the

incremental effects of a

project are considerable when

viewed in connection with the

effects of past projects, the

effects of other current

projects, and the effects of

probable future projects.

c) Does the project have

environmental effects that will

cause substantial adverse

effects on human beings,

either directly or indirectly?

Discussion

a) Less than Significant Impact. The project would develop a new dog kennel and

ancillary cafe. The project has been determined to have no impacts, less than significant

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impacts, and its impacts are within the scope of the LUCE EIR. As discussed in Section IV,

Biological Resources, because the project site is completely developed and located in

an urbanized area within the City, there are no rare or endangered habitats or protected

plant or animal species. In addition, the project would not cause a fish or wild-life

population to drop below self-sustaining levels or threaten to eliminate a plant or animal

community.

As discussed in Section V, Cultural Resources, no known examples of major periods of

California history or prehistory would be eliminated as a result of the project. Therefore,

the project would result in less than significant impacts.

b-c) Less than Significant Impact. Based on the analysis provided in this document, the

project would not result in any significant impacts on an individual or cumulative level

and would not result in any significant adverse effects on human beings. The project is

consistent with applicable zoning and LUCE land use standards. All impacts would be

within the scope of analysis in the LUCE EIR. Therefore, the project would result in less than

significant impacts.