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Planning Commission Staff Report 140 South Lasky Drive November 14, 2019 ATTACHMENT F Class 32 Environmental Exemption Report w/appendices 170

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November 14, 2019
170
Community Development Department 455 North Rexford Drive, First Floor
Beverly Hills, California 90210
prepared by
Rincon Consultants, Inc. 250 East 1st Street, Suite 1400 Los Angeles, California 90012
October 2019
Community Development Department 455 North Rexford Drive, First Floor
Beverly Hills, California 90210
250 East 1st Street, Suite 1400 Los Angeles, California 90012
October 2019
172
This report prepared on 50% recycled paper with 50% post-consumer content.
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4. Consistency Analysis .................................................................................................... 15
Table 2 Consistency with Zoning Ordinance Requirements ........................................... 17
Table 4 Trip Generation .................................................................................................. 20
Table 5 Significant Impact Threshold Signalized Intersections ....................................... 21
Table 7 Future (2020) + Project Intersection Level of Service Analysis .......................... 22
Table 8 Neighborhood Street Impact Analysis Existing Conditions ................................ 24
Table 9 Neighborhood Street Impact Analysis Opening Year ......................................... 25
Table 10 Onsite Noise Measurement Results ................................................................... 30
Table 11 Typical Noise Levels at Construction Sites ......................................................... 32
Table 12 Vibration Source Levels for Construction Equipment ........................................ 33
Table 13 Estimated Operational Emissions ....................................................................... 36
Table 14 Estimated Construction Emissions ..................................................................... 37
Table 15 Consistency with 2016-2040 RTP/SCS ................................................................ 39
Table 16 Estimated Construction Emissions of Greenhouse Gases .................................. 42
Table 17 Combined Annual Emissions of Greenhouse Gases ........................................... 43
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Figure 2 First Level Plan ...................................................................................................... 5
Figure 3 Roof Level Plan ..................................................................................................... 6
Figure 4 Building Section 1 ................................................................................................. 7
Figure 5 Building Section 2 ................................................................................................. 8
Figure 6 Building Elevations: North and South................................................................... 9
Figure 7 Building Elevations: East and West .................................................................... 10
Figure 8 Proposed Building Rendering – Aerial View looking Northeast ......................... 11
Figure 9 Proposed Building Rendering - Street View on South Lasky Drive looking Northeast ............................................................................................................ 12
Figure 10 Photographs of the Project Site ......................................................................... 14
Figure 11 Noise Measurement Locations ........................................................................... 31
Appendices
Appendix B Historic Resources Assessment
Appendix C Historic Resources Assessment Peer Review
Appendix D Noise Measurement and Analyses Data
Appendix E Parking Impact Analysis
Appendix F Traffic Impact Analysis
Appendix G Traffic and Parking Impact Analysis Peer Review
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Categorical Exemption Report
This report serves as the technical documentation of an environmental analysis performed by Rincon Consultants, Inc. for The Lasky Hotel Project (the “Project”) in the City of Beverly Hills. The intent of the analysis is to document whether the project is eligible for a Class 32 Categorical Exemption (CE). The report provides an introduction, project description, and evaluation of the project’s consistency with the requirements for a Class 32 exemption. This includes an analysis of the project’s potential impacts in the areas of biological resources, traffic, air quality, noise, water quality, and historic resources. The report concludes that the project is eligible for a Class 32 CE.
1. Introduction
The City of Beverly Hills proposes to adopt a Class 32 CE for a proposed project at 140 South Lasky Drive. The State CEQA Guidelines Section 15332 states that a CE is allowed when:
a. The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
b. The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses.
c. The project site has no value as habitat for endangered, rare, or threatened species.
d. Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
e. The site can be adequately served by all required utilities and public services.
State CEQA Guidelines Section 15300.2 also states that a categorical exemption “shall not be used for a project which may cause a substantial adverse change in the significance of a historical resource.”
Rincon Consultants, Inc. evaluated the project’s consistency with the above requirements, including its potential impacts in the areas of biological resources, traffic, noise, air quality, water quality, and historic resources to confirm the project’s eligibility for the Class 32 exemption.
2. Project Description
The project site is located at 140 South Lasky Drive in the City of Beverly Hills, California. The site includes three parcels identified as Assessor Parcel No. (APN) 4328-008-011, -012 and -013 that totals 18,380 square feet (sf) (0.422 acres). The site is occupied by an existing three-story, 44 room boutique hotel (Maison 140 Hotel, or “Existing Hotel”) and associated surface parking lot.
The proposed project would involve demolition of the Existing Hotel (14,625 sf) and construction of a new boutique hotel. The proposed hotel would be four stories above ground (45 feet in height) and would consist of 66 guestrooms, a restaurant at ground-level, unenclosed rooftop terrace with a pool, gymnasium and restrooms, and three levels of underground parking. Table 1 shows the characteristics of the proposed new building. Figure 1 shows the location of the project site. Figure 2 and Figure 3 show the proposed first and roof level plans, respectively. The proposed four-story hotel building would have a net floor area of 36,760 sf, not including parking and rooftop areas. The hotel building
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would have a total of 66 guestrooms and 1,845 sf of restaurant space. Parking would be provided in three subterranean levels that would include 94 spaces. Common open space would be provided within a 2,033 sf first floor courtyard and a 6,355 sf rooftop pool and terrace area, totaling 8,388 sf of open space. The project would also include an approximately 1,905-sf enclosed gymnasium and restroom area on the rooftop of the hotel building. Building sections, elevations and renderings are depicted in Figure 4 through Figure 9, respectively.
Vehicular access to the subterranean garage would be provided from South Lasky Drive. Access to the loading area located in the rear of the hotel would be provided from the rear alley. Loading trucks would enter the alley from Charleville Boulevard, located to the south of the project site, and would exit the alley from South Lasky Drive. One loading truck space and one van loading space would be provided.
Table 1 Project Characteristics
Assessor’s Parcel Number (APN) 4328-008-011, -012, -013
Lot Area 18,380 sf (0.42 acres)
Existing uses
46 spaces
2,033 sf
6,355 sf
Vehicle Parking
Bicycle Parking
sf = square feet
1 The total floor area is calculated pursuant to Beverly Hills Municipal Code (BHMC) §10-3-100 and does not include underground levels for parking, parking spaces at or above the first story and associated access routes -- see 10-3-100 “Floor Area” 6A (provided that in commercial zones not less than the front 40’ of the ground floor shall be devoted to retail, office, or financial uses and at least one full level of parking below grade is provided), rooftop areas, elevator and escalator shafts and elevator lobbies located in parking areas or on rooftop, stair shafts, courts, mall areas, machinery rooms, or space used or provided for publicly owned off street parking facilities. 2 The applicant is requesting a 15% reduction as part of the Conditional Use Permit (CUP) approvals pursuant to BHMC § 10-3-2866 I.
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Source: Kollin Altomare Architects, 2019
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Source: Kollin Altomare Architects, 2019
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Source: Kollin Altomare Architects, 2019
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12
Figure 9 Proposed Building Rendering - Street View on South Lasky Drive looking Northeast
Source: Kollin Altomare Architects, 2019
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Categorical Exemption Report 13
Construction would occur over approximately 24 months, occurring between about June 2020 and June 2022. The project would require 20,480 cubic yards (CY) of excavated soil material for construction of the subterranean parking garage. Of this soil, 505 CY would be used as fill on-site and 19,975 CY would be exported to construction and demolition (C&D) landfills. In addition, the project would require 133 CY of import soil. Assuming a 10 CY capacity per hauling truck for imported and exported soil, the proposed project would involve approximately 2,011 round-trip hauling truck trips.
3. Existing Site Conditions
The project site is a generally flat, rectangular lot located along the east side of South Lasky Drive between Charleville Boulevard to the south and South Santa Monica Boulevard to the north (see Figure 10 for photos of the project site). Vegetation on the project site consists of ornamental landscaping, including ground cover and shrubs, in small planter areas. Two ornamental trees are located on the project site fronting South Lasky Drive. Additionally, two ornamental street trees are located along the public right-of-way fronting the project site. The project site is currently occupied by the Maison 140 Hotel, a 3-story (33 feet in height) boutique hotel that includes 14,625 gross sf of building area and 44 guest rooms. As described in detail in the Historic Resources Assessment, the hotel includes a brick veneer façade at its primary west elevation and incorporates an American Colonial Revival style of architecture (see Appendix B).
The project site also includes a surface parking with 46 parking spaces. Vehicular access to the project site is currently provided from two driveways located off South Lasky Drive, which includes one ingress driveway and one ingress/egress driveway. Additionally, an egress driveway is located at the rear of the project site that provides access to the alley.
As shown in Figure 1, the project site is bordered by South Lasky Drive to the west, an alley to the east, a one-story commercial building with associated surface parking lot to the north, and a three- story commercial building with associated surface parking to the south. Land uses to the west of the project site (to the west of South Lasky Drive) include the four-story Peninsula Beverly Hills hotel and multi-family residential and commercial buildings. Land uses to the east of the project site (to the east of the alley) include multi-family and single-family residential buildings and commercial and office buildings. Land uses north of the project site (to the north of South Santa Monica and Wilshire Boulevards) include commercial and office buildings. Land uses to the south (south of Charleville Boulevard) include multi-family and single-family residential buildings.
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Figure 10 Photographs of the Project Site
View A: Looking east at the existing Maison 140 Hotel, from the west side of South Lasky Drive.
View B: Looking northwest at the Maison 140 Hotel from the alleyway.
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Criterion (a)
The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
Consistency with the applicable requirements of the City of Beverly Hills Municipal Code (BHMC) for the C-3, Commercial Zone is analyzed below and shown in Table 2.
Permitted Uses
According to the City of Beverly Hills General Plan Land Use Map, the project site is designated for low density general commercial uses. The project site is located with the C-3, Commercial zone. Pursuant to BHMC Section 10-3-1604, the C-3 zone allows hotel uses with approval of a Conditional Use Permit (CUP). The proposed hotel would thus be consistent with the allowable uses of the project site. The project applicant is requesting a CUP, pursuant to BHMC Section 10-3-2862, to allow for a hotel development consistent with a code-compliant project.
FAR and Height
The allowed FAR in the C-3 zone is 2.0:1. The proposed project would have a floor area of 36,760 net sf at a total FAR of 2.0:1. The allowable height for hotel uses in the C-3 Zone is 45’ (four stories). The proposed project would be constructed at a height of 45’to the top of the roof deck (four stories). The additional rooftop features consisting of the gymnasium and restrooms would be constructed at a height of 13’, as measured from the roof deck. Pursuant to BHMC Section 10-3-3107 A.1.b., these rooftop features are allowed with a maximum height of 15’ from roof deck and are exempt from the maximum 45’ building height requirement.
Setbacks
Pursuant to BHMC Section 10-3-1952 A, a six-foot building setback is required when a non- residentially-zoned property abuts a residentially-zoned property across from an alley. Additionally, the City’s Street Master Plan requires the dedication of 2’-6” of the rear of the property for future widening of the alley. The site plan for the project shows that required 2’-6” alley dedication will be provided to accommodate future widening of the alley. Additionally, the new hotel building will provide the required 6’ setback at the rear of the property. This required rear setback is measured from the adjusted rear property line, accounting for the required alley dedication. No front or side yard setbacks are required for the property. However, the proposed hotel building will be constructed with a setback of 1’-6” along the north and south sides of the property.
The eastern border to the rear of the project site abuts residentially-zoned property across an alley that is developed with multi-family residential housing. When a non-residentially-zoned property abuts a residentially-zoned property across from an alley, BHMC Section 10-3-1953 A requires the construction of a property line wall that is 3’ in height to provide a buffer and transition between uses. Openings to accommodate access to parking or loading areas are allowable in the required property line wall.
The site plan for the Project shows the construction of the required 3’ tall wall at the adjusted rear property line. The proposed masonry wall will provide for two 25’ openings providing access to the
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loading area located to the rear of the property and one 5’ opening providing site egress from the building. The proposed project would be constructed to conform to the required building setbacks and provide for the required property line wall to provide a transition between residential and nonresidential uses.
Parking and Loading
Pursuant to BHMC Sections 10-3-2730, 10-3-2866, and 10-3-3107 A.1.f., hotel, hotel restaurant dining, and rooftop gymnasium uses are required to comply with the following parking standards:
Hotel Uses:
Hotel Restaurant Dining:
1 parking space per 45 sf of dining and bar floor area for the first 9,000 sf, and 1 space per 65 sf of dining and bar floor area in excess of 9,000 sf.
Rooftop Gymnasium:
2 parking spaces for a rooftop gymnasium.
Additionally, pursuant to BHMC Section 10-3-2866 I, the number of parking spaces required may be reduced by not more than fifteen percent (15%) where a finding is made in approval of the conditional use permit that the hotel use will not generate a need for the number of parking spaces required because of one or more of the following: (a) the location of the hotel; (b) availability of public transportation; or (c) proximity and concentration of shopping to the hotel site.
Based on the parking standards provide in BHMC Sections 10-3-2730, 10-3-2866, and and 10-3-3107 A.1.f., the proposed project would be required to provide a total of 109 parking spaces. As part of the applicant’s request, the project is requesting a 15% reduction in the amount of parking required for the project, pursuant to the provisions in BHMC Section 10-3-2866 I, to reduce the amount of required parking to 91 spacing spaces. However, a total of 94 parking spaces will be provided within a three- level subterranean parking structure. Additionally, the proposed project would also provide five - bicycle racks and lockers.
As discussed under Criterion D, Parking, and in the Parking Study (see Appendix E), the proposed project meets the requirements of the BHMC for a reduction in parking. Pursuant to the BHMC Section 10-3-2866.1, the project applicant is also requesting a reduction of required loading spaces from three loading truck spaces to one loading truck space and one loading van space.
Design and Landscaping
As shown in Figure 8 and Figure 9, the proposed project would feature a stone facade with metal work accents, large windows, and modern straight lines. Landscaping would be provided in the rear setback to buffer the loading area and trash enclosure from the alleyway. Landscaping would include drought tolerant plants. As such, the proposed project would be consistent with BHMC Section 10-3-1954, which requires landscaping of setbacks for commercial uses. Open space would total 8,388 sf, which would include 6,355 sf of common open space on the rooftop terrace and pool deck and 2,033 sf within the first floor courtyard.
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BHMC Requirements Proposed Project
Height Lesser of 45 feet or 4 stories 45 feet at 4 stories
Floor Area Ratio
Side: 1’-6” (South Side)
Rear: 6’-0”
Parking 109 spaces 94 spaces1
1 As discussed under Criterion D, Parking, and in the Parking Study (see Appendix E), the proposed project meets the requirements of the BHMC for a reduction in parking.
Source: BHMC 2018
General Plan Consistency
The General Plan has several land-use policies that are relevant to the proposed project, including those related to community character and quality. Table 3 presents an evaluation of the project’s consistency with applicable Beverly Hills General Plan policies. As shown in Table 3 the proposed project would be consistent with applicable General Plan policies.
Table 3 Consistency with Beverly Hills General Plan Policies
Policy Consistency
Maintain and enhance the character, distribution, built form, scale, and aesthetic qualities of the City’s distinctive residential neighborhoods, business districts, corridors, and open spaces.
Consistency with General Plan:
Surrounding development consists of one- to four- story multi-family residential buildings and one- to four-story hotel and commercial buildings. The proposed four-story hotel building would be similar in scale to surrounding development to the four-story Peninsula Beverly Hills hotel, located west of the project site across South Lasky Drive. The building would undergo architectural review to ensure the facade is compatible with the surrounding development. Building renderings, which are depicted in Figure 8 and Figure 9, show the architectural style of the proposed project. The project would feature a stone façade, modern, clean lines, and landscaping that would enhance the character of the project site and would be compatible with the architectural style of the area.
LU 2.4 – Architectural and Site Design.
Require that new construction and renovation of existing buildings and properties exhibit a high level of excellence in site planning, architectural design, building materials, use of sustainable design and construction practices, landscaping, and
Consistency with General Plan:
The proposed project would exhibit a facade consisting of glass and stone, as shown in Figure 8 and Figure 9. The project design is required to undergo architectural review to ensure that the design complements the
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Policy Consistency
amenities that contribute to the City’s distinctive image and complement existing development.
existing development and exhibits excellence in planning, building materials and sustainable design.
LU 2.10 – Development Transitions and Compatibility.
Require that sites and buildings be planned, located, and designed to assure functional and visual transitions between areas of differing uses and densities by addressing property and height setbacks, window and entry placement, lighting, landscape buffers, and service access.
Consistency with General Plan:
The building height of four stories above grade, architectural treatment, and landscape buffers would complement the surrounding development that consists of one- to four-story multi-family residential buildings and one- to four-story hotel and commercial buildings. The eastern elevation would feature landscaping and a three-foot-high wall to ease the transition from residential uses to the proposed hotel.
LU 9.1 – Uses for Diverse Customers.
Accommodate retail, office, entertainment, dining, hotel, and visitor serving uses that support the needs of local residents, attract customers from the region, and provide a quality experience for national and international tourists.
Consistency with General Plan:
The proposed project involves a hotel and restaurant that support the needs of local residents and attract customers from the region.
LU 11.2 – Site Planning and Architectural Design.
Require that commercial and office properties and buildings are planned and designed to exhibit a high level of site and architectural design quality and excellence.
Consistency with General Plan:
The proposed project would exhibit quality site and architectural design. The exterior of the building would consist of landscaping, a stone façade with glass windows. The rear of the building would have landscaping and a wall to ease the transition to the adjacent residential uses.
LU 12.2 – Building, Parking Structure, and Site Design.
Require that buildings, parking structures, and properties in commercial and office districts be designed to assure compatibility with abutting residential neighborhoods, incorporating such elements as setbacks, transitional building heights and bulk, architectural treatment of all elevations, landscape buffers, enclosure of storage facilities, air conditioning, and other utilities, walls and fences, and non- glare external lighting.
Consistency with General Plan:
The proposed building, subterranean parking, and site design would be compatible with abutting one- to four- story residential buildings in the project vicinity. The building height of four stories above grade, architectural treatment, and landscape buffers would complement the surrounding development. The eastern elevation would feature landscaping and a three-foot high wall to ease the transition from residential uses to the proposed hotel.
LU 12.3 – Alleys Between Commercial and Residential Uses.
Encourage that alleys be attractively designed as a transition between retail and office districts and residential neighborhoods, using features such as quality paving materials, landscaping, low voltage lighting and high-quality maintenance to assure that such alleys are attractive, and kept free of trash and debris.
Consistency with General Plan:
The project site has an alley on the east end separating commercial and residential uses. The project would enhance the transition between the commercial use and the adjacent residential area with landscaping on the project site along the alley frontage separating the loading zone. A three-foot-high block wall would further enhance the transition between the loading zone and building and the alley.
The proposed project would be consistent with applicable General Plan land use designation, General Plan policies, zoning designation, and regulations, including the CUP required for the requested reduction in parking.
Criterion (b)
The proposed development occurs within the city limits on a project site of no more than five acres substantially surrounded by urban uses.
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The proposed development would occur within the City limits of Beverly Hills on a project site of less than five acres substantially surrounded by urban uses. As shown in Figure 1 the project site is located on a 0.42-acre parcel in a developed urban neighborhood. It is immediately surrounded by urban uses on all sides, including multi-family residences and commercial uses. Photos documenting the urban character of the project site and surrounding area are provided in Figure 10. Refer also to Section 2, Project Description, subheading Existing Site Conditions.
Criterion (c)
The project site has no value as habitat for endangered, rare, or threatened species.
The project site is located in a developed urban area that lacks habitat that would be suitable for sensitive animal or plant species. In addition, the project site itself is occupied by an existing boutique hotel and surface parking. As previously discussed, under Existing Site Conditions, the project site contains ornamental vegetation in planter areas and two ornamental trees. This vegetation does not provide habitat for sensitive species due to its small size, lack of native vegetation, and highly urban context. However, trees on or bordering the project site could provide nesting habitat for a variety of bird species that are afforded protection under the federal Migratory Bird Treaty Act (MBTA – 16 United State Code Section 703-711) and Section 3503 of the California Fish and Game Code (CFGC). The proposed project has the potential to impact migratory and other bird species if construction activities occur during the nesting season, which is typically February 15 through September 15. Construction-related disturbances could result in nest abandonment or premature fledging of the young. To avoid disturbance of protected species, the construction team will engage with a certified avian biologist to observe activity during the nesting season that may impact vegetation in the vicinity. If active nests are to be discovered a buffer area would be indicated and maintained to not disturb within this dedicated boundary area.
Criterion (d)
Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
The following discussion provides an analysis of the project’s potential effects with respect to traffic, noise, air quality and greenhouse gas emissions, and water quality.
A. Traffic
Trip Generation
Kimley Horn prepared the Traffic Impact Analysis (TIA) (March 2019) and Parking Study (March 2019) for the proposed project (see Appendix E and F). Additionally, Fehr and Peers performed a Peer Review of both the TIA and Parking Study (See Appendix G).
Daily, morning peak hour, evening peak hour, and Saturday peak hour trips for the proposed project were calculated using the trip generation rates published in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition (2017). Trip rates are based on ITE Land Use Category 310 –Hotel. The project takes into consideration trip credit for the Existing Hotel land use. As shown in Table 4, the project is estimated to generate a net total of 184 daily trips, including 11 morning peak hour trips and 13 evening peak hour trips, and 16 peak hour Saturday trips.
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AM Trip Rate Per
Proposed Hotel
Total Net New Trips 184 11 13 16
1 Trip generation for restaurant uses is reflected in the typical ITE hotel rate.
Source: Kimley Horn, 2019 (See Appendix F).
Analysis Methodology
Analysis Scenarios
The TIA provides an evaluation of morning and evening peak hour operations during the morning (7:00 to 9:00 AM) and evening (4:00 to 6:00 PM) peak periods. Additionally, a Saturday peak period hour condition was included. The following scenarios were evaluated:
Existing Conditions
The following study intersections have been included in the analysis:
1. South Santa Monica Boulevard at Charleville Boulevard
2. Charleville Boulevard at Durant Drive
3. Charleville Boulevard at South Lasky Drive
Intersection Analysis Methodology
SIGNALIZED INTERSECTIONS
In accordance with the City of Beverly Hills requirements, signalized intersection operation is evaluated using the Intersection Capacity Utilization (ICU) methodology, which provides a comparison of the theoretical hourly vehicular capacity of an intersection to the number of vehicles actually passing through that intersection during the peak hour. The results of the evaluation are reported in terms of a volume-to-capacity (V/C) ratio, which corresponds to a Level of Service (LOS). Level of Service is represented by letter grades A through F, with LOS A representing free-flow conditions, and LOS F representing congested, over-capacity conditions.
UNSIGNALIZED INTERSECTIONS
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Categorical Exemption Report 21
seconds per vehicle) for each approach. Just as with the Intersection Capacity Utilization (ICU) methodology, the HCM delay forecast translates to a Level of Service designation, ranging from LOS A to LOS F. The descriptions of operating conditions for each LOS are very similar to the LOS descriptions for signalized intersections.
SIGNIFICANCE THRESHOLDS
A project impact would be significant at a signalized study intersection if the project-related increase in the V/C ratio equals or exceeds the thresholds shown in Table 5.
Table 5 Significant Impact Threshold Signalized Intersections
Final LOS Project V/C Increase
F 0.02 or more
E 0.02 or more
LOS = Level of Service
V/C = Volume to Capacity
Additionally, a project impact would be significant at an unsignalized study intersection as follows:
At intersections operating at LOS F, an increase in critical approach delay of 3.0 seconds or more. At intersections operating at LOS E, an increase in critical approach delay of 3.0 seconds or more. At intersections operating at LOS D, an increase in critical approach delay of 4.0 seconds or more.
EXISTING PLUS PROJECT CONDITIONS
Project-related trips were added to existing traffic volumes to forecast Existing Plus Project Conditions. Traffic volumes for this scenario are shown in Figure 5 of the TIA (see Appendix F). A summary of the resulting intersection LOS is provided on Table 6.
FUTURE PLUS PROJECT CONDITIONS
As shown in Table 6, all study intersections would operate at LOS B or better in Existing Plus Project Conditions. Ambient traffic growth at a rate of 1% per year and traffic from Cumulative Projects were added to Existing Conditions to establish Opening Year 2020 Without Project Conditions. Under Opening Year 2020 Without Project Conditions, all study intersections would operate at acceptable LOS. Project traffic was added to Opening Year 2020 Without Project Conditions to establish Opening Year 2020 With Project Conditions. Under Opening Year 2020 With Project Conditions, all study intersections would continue to operate at acceptable LOS.
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Table 6 Existing (2018) + Project Intersection Level of Service Analysis
No. Intersection Peak Hour
Existing (2018) Existing (2018)
AM 0.691 B 0.692 B 0.001 No
PM 0.650 B 0.654 B 0.004 No
Saturday 0.501 A 0.502 A 0.001 No
2 Charleville Boulevard at Durant Drive
AM 10.8 B 10.9 B 0.1 No
PM 9.3 A 9.4 A 0.1 No
Saturday 7.9 A 8.0 A 0.1 No
3 Charleville Boulevard at South Lasky Drive
AM 10.8 B 10.9 B 0.1 No
PM 11.3 B 11.4 B 0.1 No
Saturday 8.6 A 8.7 A 0.1 No
Notes:
- For signalized intersections, intersection operation is expressed in V/C ratio using the ICU methodology.
- For all-way stop control intersections, LOS is expressed in average seconds of delay per peak hour vehicle, based on the methodology outlined in the 2010 Highway Capacity Manual.
Source: Kimley Horn, 2019 (See Appendix F).
Table 7 Future (2020) + Project Intersection Level of Service Analysis
No. Intersection Peak Hour
Future (2020) Future (2020)
AM 0.807 D 0.809 D 0.002 No
PM 0.865 D 0.869 D 0.004 No
Saturday 0.708 C 0.712 C 0.004 No
2 Charleville Boulevard at Durant Drive
AM 11.0 B 11.1 B 0.1 No
PM 9.4 A 9.5 A 0.1 No
Saturday 8.0 A 8.0 A 0.0 No
3 Charleville Boulevard at South Lasky Drive
AM 11.1 B 11.2 B 0.1 No
PM 11.6 B 11.7 B 0.1 No
Saturday 8.7 A 8.7 A 0.0 No
Notes:
- For signalized intersections, intersection operation is expressed in V/C ratio using the ICU methodology.
- For all-way stop control intersections, LOS is expressed in average seconds of delay per peak hour vehicle, based on the methodology outlined in the 2010 Highway Capacity Manual.
Source: Kimley Horn, 2019 (See Appendix F).
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NEIGHBORHOOD STREET IMPACT ANALYSIS
The following street segments were included in the neighborhood street impact analysis:
1. South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
2. Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
3. Charleville Boulevard between Durant Drive and South Lasky Drive
4. Durant Drive between South Lasky Drive and Charleville Boulevard
As indicated by the City of Beverly Hills, the project would cause a significant impact on a local street if the following thresholds are exceeded:
For a street segment with an Average Daily Traffic (ADT) of less than 2,000 vehicles per day, a significant impact is defined when the project increases the ADT by 16%, or if the project increases peak hour volumes by 16%, or both.
For a street segment with an ADT of greater than 2,001 vehicles per day, but less than 4,000 vehicles per day, a significant impact is defined when the project increases the ADT by 12%, or if the project increases peak hour volumes by 12%, or both.
For a street segment with an ADT of greater than 4,001 vehicles per day, but less than 6,750 vehicles per day, a significant impact is defined when the project increases the ADT by 8%, or if the project increases peak hour volumes by 8%, or both.
For a street segment with an ADT of greater than 6,750 vehicles per day, a significant impact is defined when the project increases the ADT by 6.25%, or if the project increases peak hour volumes by 6.25%, or both.
Daily and peak hour traffic volumes for the existing and future conditions are summarized in Table 8 and Table 9. As shown, there are no significant impacts to the neighborhood streets in any study scenario.
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Intersection #
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
2,554 133 2,687 4.9% 12% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
4,324 133 4,457 3.0% 8% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
5,356 133 5,489 2.4% 8% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
695 0 695 0.0% 16% No
Daily Saturday
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
1,823 106 1,929 5.5% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
2,523 106 2,629 4.0% 12% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
2,548 106 2,654 4.0% 12% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
436 0 436 0.0% 16% No
Peak Hour Weekday
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
227 11 238 4.6% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
375 11 386 2.8% 16% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
510 11 521 2.1% 16% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
79 0 79 0.0% 16% No
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1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
171 13 184 7.1% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
231 13 244 5.3% 16% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
225 13 238 5.5% 16% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
41 0 41 0.0% 16% No
Source: Kimley Horn, 2019 (See Appendix F).
Table 9 Neighborhood Street Impact Analysis Opening Year
Int. #
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
2,631 133 2,764 4.8% 12% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
4,455 133 4,588 2.9% 8% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
5,518 133 5,651 2.4% 8% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
716 0 716 0.0% 16% No
Daily Saturday
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
1,878 106 1,984 5.3% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
2,599 106 2,705 3.9% 12% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
2,625 106 2,731 3.9% 12% No
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4 Durant Drive between South Lasky Drive and Charleville Boulevard
449 0 449 0.0% 16% No
Peak Hour Weekday
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
234 11 245 4.5% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
386 11 397 2.8% 16% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
525 11 536 2.1% 16% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
81 0 81 0.0% 16% No
Peak Hour Saturday
1
South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard
176 13 189 6.9% 16% No
2
Charleville Boulevard between South Santa Monica Boulevard and Durant Drive
238 13 251 5.2% 16% No
3 Charleville Boulevard between Durant Drive and South Lasky Drive
232 13 245 5.3% 16% No
4 Durant Drive between South Lasky Drive and Charleville Boulevard
42 0 42 0.0% 16% No
Source: Kimley Horn, 2019 (See Appendix F).
Parking
A parking Study was conducted to determine the project site’s compliance with City parking standards (Parking Study) (Kimley Horn 2019a, see also Appendix E). The City’s parking standards, pursuant to BHMC Section 10-3-2730, require hotel and hotel restaurant dining uses to comply with the following:
Hotel Uses:
Hotel Restaurant Dining:
1 parking space per 45 sf of dining and bar floor area for the first 9,000 sf, and 1 space per 65 sf of dining and bar floor area in excess of 9,000 sf.
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2 parking spaces for a rooftop gymnasium.
As discussed in the Parking Study, the proposed project would have a parking requirement of 107 parking spaces per the City’s requirements. Additionally, the proposed rooftop gymnasium would increase the required parking by 2 spaces, for a total of 109 spaces. The project site plan shows a parking supply of 94 spaces, resulting in a parking deficiency of 15 parking spaces, which represents a reduction of 13.7% from the parking requirement. However, pursuant to BHMC Section 10-3-2866 I, the number of parking spaces required by the City’s parking standards may be reduced by not more than 15% where a finding is made in approval of the conditional use permit that the hotel use will not generate a need for the number of parking spaces required because of one or more of the following: (a) the location of the hotel; (b) availability of public transportation; or (c) proximity and concentration of shopping to the hotel site.
As discussed in the Parking Study, parking observations at two similar hotel locations in Beverly Hills indicate that the actual peak parking demands are much lower than the parking required by the BHMC. In reviewing data collected at the two sample hotel locations, and determining parking occupancy rates based on each respective hotel’s building characteristics, a parking rate that is more indicative of real world conditions can be calculated and applied to the proposed project. By applying this rate to the proposed project, a total of 80 parking spaces would be required. This would be 14 fewer spaces than the 94 proposed spaces. As such, a 15% reduction from the 109 required parking spaces (or 91 parking spaces) would still be less than actual parking demand experienced at similar locations.
Furthermore, the project site is located within half a mile from large retail areas to the northeast of the project site. Downtown Beverly Hills is walking distance from The Lasky Hotel. As concluded in the Parking Study, synergies in parking demand from hotel patrons and from shopping in the nearby areas would be expected and would contribute to a lowered need for parking on site. With adequate parking on site, there is no potential for impacts in the surrounding neighborhoods from spill-over parking or cars circulating while seeking parking.
Site Access
The proposed project would include two driveways off South Lasky Drive. Both driveways would be located under the porte-cochere, immediately in front of the proposed hotel building. The southern driveway would only allow inbound movements, while the northern driveway would only allow egress movements. Therefore, vehicles would circulate in and out of the project site in a counter-clockwise manner. Once on-site, parking would be provided via an underground parking facility, which would be exclusive to valet. A separate access would also be provided via an alley behind the hotel. Service trucks would utilize this entrance and access the alley by turning off Charleville Boulevard. Moreover, the alley could be accessed via South Lasky Drive. The proposed project would not result in inadequate emergency access or introduce any design features or incompatible uses, such as sharp curves or dangerous intersections, which would substantially increase hazards at the site.
Construction Traffic
Construction traffic impacts could be significant if the project would create a prolonged impact due to lane closure; impede emergency vehicle access; create traffic hazards to bicycles and/or pedestrians; or result in similar substantial impediments to circulation or safety.
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It is anticipated that the construction vehicles, haul trucks, and construction workers would travel north along South Lasky Drive to Santa Monica Boulevard or Wilshire Boulevard, which are approved heavy haul routes (Beverly Hills 2019). As stated in the Project Description, construction of the project would involve approximately 2,011 round-trip hauling trips during the grading phase. According to the applicant-provided construction schedule, the proposed 24-month construction schedule would be roughly as follows: one and a half months for demolition, two and a half months for site preparation, one month for grading, 17 months of building construction, and two months for paving and architectural coating. Thus, over approximately 108 days during the site preparation and grading phase, there would be approximately 19 round-trip haul trips per day. Assuming that haul trips are spread out over a 10-hour construction day (8:00 AM to 6:00 PM in accordance with the BHMC), an estimated two trips would generally occur per hour. If only two trucks traveled to or from the project site in any given hour, construction trucks would not significantly disrupt the flow of traffic on surrounding roadways, including Santa Monica Boulevard and South Lasky Drive.
The proposed project would not involve road closures that would significantly affect emergency vehicle access or create significant hazards to bicycles and pedestrians.
The total number of construction trips would generally be staggered throughout the day, with most trips occurring during off-peak hours.
To reduce temporary disruptions on the adjacent roadway network due to construction activities, the project would be subject to the standard City of Beverly Hills condition of approval requiring preparation and approval of a Construction Management Plan prior to the initiation of construction activities. This plan would address the following items:
Maintain existing access for land uses in proximity of the project site during project construction
Schedule deliveries and hauling of construction materials to non-peak travel periods, including night hours and weekends
Coordinate deliveries and hauling to reduce the potential of trucks waiting to load or unload for extended periods of time
Minimize obstruction of through traffic lanes
Meet the requirements of the Community Development and Public Works Departments with respect to construction scheduling and coordination with other construction near the project site, heavy hauling and material delivery routing, types of trucks, use limitations per hour, hours of operations, traffic plan submission for different stages, pedestrian and vehicular access, street use permit process, daily street cleanliness and maintenance and safety after work, and parking management for construction workers.
In order to comply with BHMC 9-1-109(c), on-street parking of construction-related vehicles shall not be permitted, unless otherwise approved by the building official as part of the review of a construction management plan. Similarly, on-street construction parking shall not extend beyond the street width of the property. The maximum number of construction parking spaces would be identified, and the applicant would be required to accommodate any additional parking either at the project site or at a nearby site from which workers would be transported to the site. With the provision of such parking, it is anticipated that for workers traveling to the project site there would be sufficient on-site access.
Based on the above and the fact that construction traffic impacts are temporary in nature and would have no effect on traffic and circulation beyond the construction period, construction-related traffic impacts would not be significant.
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Conclusion
Based on the assessment of traffic impacts and site access above, there would be no significant impacts related to traffic.
B. Noise
Noise Characteristics and Measurement
Noise level (or volume) is generally measured in decibels (dB) using the A-weighted sound pressure level (dBA). The A-weighting scale is an adjustment to the actual sound power levels to be consistent with that of human hearing response, which is most sensitive to frequencies around 4,000 Hertz (about the highest note on a piano) and less sensitive to low frequencies (below 100 Hertz).
One of the most frequently used noise metrics that considers duration as well as sound power level is the equivalent noise level (Leq). The Leq is defined as the steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual varying levels over a period of time (essentially, Leq is the average sound level).
Noise Standards
The City of Beverly Hills’ General Plan incorporates comprehensive goals, policies, and actions related to noise and acceptable noise levels. These policies address unnecessary, excessive, and annoying noise levels and sources, such as vehicles, construction, special sources (e.g., radios, musical instrument, animals) and stationary sources (e.g., heating and cooling systems, mechanical rooms).
For noise, impacts would be significant if project-generated noise levels that result in the exposure of sensitive receptors to a substantial increase in noise. Noise level increases of 3 dBA or more are considered barely perceptible, a 5-dBA increase would be considered a readily noticeable increase, and a 10-dBA increase would be a doubling of the noise level. It would require a doubling of traffic volume to generate a 3-dBA increase in roadway traffic noise. For purposes of assessment, the following thresholds are utilized to determine the significance of noise impacts:
A substantial increase in long-term noise levels is a 3 dBA increase if noise levels at an affected land use exceed the City’s clearly compatible noise level standard, or
A 5 dBA increase if the existing and future noise levels would be below the City’s clearly compatible noise level standard.
A substantial short-term increase in noise levels would be a 10-dBA increase.
Impacts relating to on-site activities are significant when project-related activities create noise exceeding the previously listed standards as identified for the project. The proposed hotel would replace an Existing Hotel building on a site that is zoned for commercial use and designated for low density general commercial use. The nearest sensitive receptors to the project site are the multi- family residences located 15 feet east of the project site across an alley, and the Peninsula Beverly Hills hotel located approximately 75 feet west of the project site across South Lasky Drive.
Existing Ambient Noise Levels
The primary source of noise in the vicinity of the project site is motor vehicle traffic, including automobiles, trucks, buses, and motorcycles. Among area roadways, South Lasky Drive, Santa Monica Boulevard, and Charleville Boulevard produce traffic noise at the site. While typical conversation noise
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may occur at nearby hotel and residential properties, it would be sporadic and limited in volume, thus, traffic is the main contributor to existing ambient noise levels.
To determine existing noise levels on the project site, two 15-minute noise measurements were taken on the project site during evening peak traffic hours between 4:00 PM and 5:00 PM on January 23, 2019, using an Extech 407780A ANSI Type 2, A-weighted integrating sound level meter five feet above ground level.
The first noise measurement was located along the eastern boundary of the site by an alley. The second noise measurement was located along the western boundary of the project site on South Lasky Drive. Figure 11 shows the on-site noise measurement locations, and Table 10 identifies the measured noise levels. As shown in Table 10, noise levels were measured at 56.5 dBA Leq by the alley and 60.7 dBA Leq along South Lasky Drive.
Table 10 Onsite Noise Measurement Results
Measurement Number Measurement Location Primary Noise Sources Sample Time Leq (dBA)
1 Alley behind project site Traffic on South Lasky Drive
4:15 PM – 4:30 PM
Traffic on South Lasky Drive
4:36 PM – 4:51 PM
60.7
Source: Field visit on January 23, 2019, using an Extech 407780A ANSI Type II Integrating sound level meter.
Refer to Appendix D for noise monitoring data sheets.
Construction Noise
Temporary noise levels caused by construction activity would be a function of the noise generated by construction equipment, the location and sensitivity of nearby land uses, and the timing and duration of noise-generating activities. The demolition, site preparation, and grading phases of construction tend to create the highest noise levels because of the operation of heavy equipment. Typical heavy construction equipment would include tractors, bulldozers, excavators, front-end loaders, graders, and stationary equipment, such as compressors and generators.
Construction noise was estimated using the Federal Highway Administration (FHWA) Roadway Construction Noise Model (RCNM) Version 1.1. To determine construction noise impacts, noise was modeled at the nearest noise-sensitive receptors, which include multi-family residences adjacent to the eastern boundary of the site, and the Peninsula Beverly Hills hotel and additional multi-family residences across South Lasky Drive to the east. For assessment purposes and to be conservative, the loudest phases have been used for this assessment, which are demolition and grading. Noise levels are based on a dozer, an excavator, and a loader operating simultaneously. It is assumed that diesel engines would power all construction equipment. Table 11 shows the pieces of equipment assumed to generate the highest noise levels (dBA, Leq) during construction at a distance of 75 feet from the center of the construction activity.
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Construction Equipment Leq, dBA
See Appendix D for RCNM data sheets and assumptions.
A significant impact would occur if construction activities occurring on the project site would result in a temporary increase of 10 dBA above the ambient level outside the hours permitted by the City’s noise ordinance (i.e., between the hours of 6:00 PM and 8:00 AM on weekdays, or at any time on Saturday, Sunday, or a public holiday), pursuant to BHMC Section 5-1-205. Further, construction work within 500 feet of a residential zone is prohibited on Saturdays. While construction noise may cause short-term annoyance to adjacent residences, it would be temporary and restricted to the hours permitted by the city’s noise ordinance. Therefore, impacts due to construction noise would be less than significant.
Construction Vibration
Groundborne vibration consists of oscillatory waves that propagate from the source through the ground to adjacent structures. The frequency of a vibrating object describes how rapidly it is oscillating. The number of cycles per second of oscillation is the vibration frequency, which is described in terms of hertz (Hz). The normal frequency range of most groundborne vibration that can be felt generally starts from a low frequency of less than 1 Hz to a high of about 200 Hz (Crocker 2007). While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings from construction activities may cause rattling of windows, items on shelves, and pictures hanging on walls. Vibration of building components can also take the form of an audible low-frequency rumbling noise, which is referred to as groundborne noise (FTA 2018). Although groundborne vibration is sometimes noticeable in outdoor environments, it is almost never annoying to people who are outdoors (FTA 2018). The ground motion caused by vibration in this analysis is measured as root mean squared velocity in inches per second and is referenced as vibration decibels (VdB).
The vibration velocity level threshold of perception for humans is approximately 65 VdB. A vibration velocity of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels for many people. Most perceptible indoor vibration is caused by sources within buildings such as operation of mechanical equipment, movement of people, or the slamming of doors. Typical outdoor sources of perceptible groundborne vibration are construction equipment, steel wheeled trains, and traffic on rough roads. If a roadway is smooth, the groundborne vibration from traffic is barely perceptible. Based on the vibration criteria in the FTA Transit Noise and Vibration Assessment (2018), construction vibration impacts would be significant if vibration levels exceed 100 VdB and cause structural damage to typical buildings, 75 VdB at institutional land uses with primary daytime use (e.g., churches and schools), or 72 VdB at residences during nighttime hours.
Construction activities that would occur on the project site have the potential to generate groundborne vibration. Construction activities would occur as close as 25 feet from multi-family residences to the east and 75 feet from the Peninsula Beverly Hills hotel. Table 12 identifies various vibration velocity levels at 25 feet and 75 feet for the types of equipment that are likely to operate at the project site during construction.
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Equipment
Small Bulldozer 58 43
Source: Federal Transit Administration (FTA), 2018. Transit Noise and Vibration Impact Assessment Manual Table 7-4.1 See Appendix D for vibration calculations at a distance of 75 feet using FTA reference vibration levels at 25 feet.
Based on the information presented in Table 12, vibration levels could be up to about 87 VdB at the existing multi-residences located east of the site. Therefore, construction vibration would not exceed the 100 VdB threshold for structural damage to off-site receptors. Though vibration levels may exceed 72 VdB at nearby sensitive receptors, construction activities would be limited to daytime hours between 8:00 AM to 6:00 PM Monday through Friday per BHMC Section 5-1-205. Therefore, vibration levels would not affect residents during sleep hours. Because construction vibration would be temporary and limited to daytime hours, impacts would be less than significant.
Operational Noise
Existing uses near the project site may periodically be subject to noise associated with operation of the proposed project, including noise that is typical of hotel development such as conversations, music, trash hauling, deliveries, rooftop pool and gymnasium use, and noise associated with rooftop ventilation and heating systems. However, noise from the proposed project would be comparable to noise currently generated by the existing on-site hotel. The proposed project’s rooftop uses, including the roof terrace pool deck would be new noise-generating sources at the site and may potentially be heard at adjacent residences. However, as shown in Figure 3 and Figure 8, direct line-of-sight between the rooftop pool deck and the nearest multi-family residences east of the alley would be obstructed by the enclosed stairwell, elevator shaft, mechanical equipment, and rooftop gymnasium which would serve as barriers to reduce noise from conversations and pool use. Although the project would also include a rooftop gymnasium, all fitness activities would occur indoors and noise generated from gymnasium use would be contained within the building.
Furthermore, BHMC Section 10-3-2703 prohibits the playing amplified sound and prerecorded music outdoors, outside of the Business Triangle area. The Business Triangle is comprised of that area of the City of Beverly Hills that is bounded by the centerline of Wilshire Boulevard to the south, the centerline of Santa Monica Boulevard (south roadway) to the north and west, and the centerline of the alley between Canon Drive and Crescent Drive to the east. The subject property at 140 South Lasky Drive is not located with the Business Triangle and any music or similar amplified sound is restricted to occurring within the building. Therefore, outdoor noise at the rooftop, such as from conversations, fitness activities, and pool use, would not substantially contribute to average ambient noise levels and would be similar to noise from nearby multi-family residences and the Peninsula Beverly Hills hotel, which also has a rooftop pool.
The proposed project would also generate traffic noise from vehicles traveling to and from the project site. As shown in Table 4, the proposed project would generate approximately 552 daily trips, with 31 AM peak hour trips, 39 PM peak hour trips, and 48 Saturday PM peak hour trips. However, in comparison with the Existing Hotel, the project would generate 184 net new daily trips. South Lasky
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Drive has an existing volume of 2,554 vehicles (Kimley Horn 2019b; See Appendix F). Vehicular access to the subterranean garage would be provided from South Lasky Drive. Assuming that all vehicle trips associated with the proposed project would occur on South Lasky Drive between South Santa Monica Boulevard and Charleville Boulevard, the estimated net gain of 184 daily trips would represent an increase of less than 1 dBA over the existing noise levels. Therefore, the minimal amount of traffic generated by the proposed project relative to existing traffic volumes on local roadways would not result in a 3-dBA perceptible increase in roadway noise.
Based on the preceding analysis, potential impacts associated with operational noise would be less than significant.
Conclusion
The proposed project would not result in a significant long-term increase in traffic noise levels; and based on required compliance with the City’s time restrictions on construction activities contained in the BHMC, temporary construction noise would be less than significant. The project does not include any operational changes that would be expected to have an effect on daily on-site operational noise generated by the Existing Hotel and surrounding properties. Therefore, noise-related impacts resulting from implementation of the proposed project would be less than significant.
C. Air Quality
A significant adverse air quality impact may occur when a project individually or cumulatively interferes with progress toward the attainment of the ozone standard by releasing emissions that equal or exceed the established long-term quantitative thresholds for pollutants or causes an exceedance of a state or federal ambient air quality standard for any criteria pollutant. Primary criteria pollutants are emitted directly from a source (e.g., vehicle tailpipe, an exhaust stack of a factory, etc.) into the atmosphere. Commonly found primary criteria pollutants include reactive organic gases (ROG), nitric oxides (NOx), carbon monoxide (CO), and particulate matter (PM10 and PM2.5). PM 10 is particulate matter measuring no more than 10 microns in diameter, while PM2.5 is fine particulate matter measuring no more than 2.5 microns in diameter. Because the project site is located within the South Coast Air Basin and falls under the jurisdiction of the South Coast Air Quality Management District (SCAQMD), this air quality analysis conforms to the methodologies recommended in SCAQMD’s CEQA Air Quality Handbook (1993). The following significance thresholds have been recommended by the SCAQMD for project operations in the South Coast Air Basin:
55 pounds per day of ROG
55 pounds per day of NOX
550 pounds per day of CO
150 pounds per day of PM10
55 pounds per day of PM2.5
Construction-related air quality impacts are considered significant if emissions associated with construction activity would exceed adopted SCAQMD thresholds. Temporary construction emission thresholds have been recommended by the SCAQMD on a daily basis as follows:
75 pounds per day of ROG
100 pounds per day of NOX
550 pounds per day of CO
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150 pounds per day of PM10
55 pounds per day of PM2.5
In addition to the regional air quality thresholds shown above, SCAQMD has developed Localized Significance Thresholds (LSTs) in response to the Governing Board’s Environmental Justice Enhancement Initiative (1-4), which was prepared to update the SCAQMD’s CEQA Air Quality Handbook. LSTs were devised in response to concern regarding exposure of individuals to criteria pollutants in local communities. LSTs represent the maximum emissions from a project that will not cause or contribute to an air quality exceedance of the most stringent applicable federal or state ambient air quality standard at the nearest sensitive receptor, taking into account factors such as ambient concentrations in each source receptor area (SRA), project size, and distance to the sensitive receptor. However, LSTs only apply to emissions within a fixed stationary location, including idling emissions during both project construction and operation, and are not applicable to mobile sources such as cars on a roadway (SCAQMD 2003). LSTs have been developed for NOX, CO, PM10, and PM2.5. Since the majority of emissions from a hotel project would be generated by vehicle trips on roadways, LSTs for operational emissions would not apply to the proposed project. However, LSTs would apply for construction emissions. Localized LSTs for the 0.422-acre project site were derived through a regression analysis based on the SCAQMD’s LSTs for one-acre project sites in SRA 2 for Northwest Coastal LA County.
Operational Emissions
Long-term operational emissions associated with the proposed project are those associated with vehicle trips (mobile emissions) and the use of natural gas, consumer products, and architectural coatings (area source emissions) upon buildout of the project. Heavily congested intersections can lead to long-term mobile emissions that exceed carbon monoxide (CO) standards and lead to CO hotspots. CO hotspots are locations where the federal or state ambient air quality standards could be exceeded because of the concentration of motor vehicles that are idling. Other factors contributing to a CO hotspot include the configuration of the intersection, distance to sensitive receptors, and patterns of air circulation. However, as discussed under Criterion D, the proposed project would not result in significant increases in traffic at intersections and would not require analysis for CO hotspots, based on Caltrans’ Transportation Project CO Protocol Manual.
Pollutant emissions associated with the proposed project (shown in Table 13) were quantified using CalEEMod, version 2016.3.2, based on the proposed use and the number of associated vehicle trips generated by the project as discussed above.
As shown in Table 13, the emissions generated by the proposed project would not exceed the SCAQMD’s daily operational thresholds for any pollutant and would not significantly affect regional air quality. Therefore, the project would have a less than significant impact on air quality from operational emissions.
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Emissions (lbs/day)
Emissions from the Proposed Hotel 1.7 3.5 9.4 2.8 0.8
Emissions from the Existing Hotel 1.0 2.9 7.3 1.9 0.5
Net New Emissions 0.7 0.6 2.1 0.9 0.3
SCAQMD Thresholds 55 55 550 150 50
Exceed Thresholds? No No No No No
Source: CalEEMod v. 2016.3.2
Note: Please see Appendix A for complete modeling results. For a conservative estimate of project emissions, construction and operational emissions were modeled and reported for the maximum day during the winter, since emission estimates are typically higher in the winter months compared to the summer months. Winter emission estimates are then compared to the SCAQMD thresholds measured in pounds-per-day. The annual emissions listed in the tables in Appendix A show the average annual emissions in terms of metric tons per year. These estimates are used for analysis of greenhouse gas emissions impacts, since the greenhouse gas emission thresholds are based on metric tons per year.
Construction Emissions
Development of the proposed project would involve site grading, excavation, new building construction, and other construction-related activities that have the potential to generate substantial air pollutant emissions. Temporary construction emissions from these activities were estimated using CalEEMod, based on the gross amount of proposed new hotel space. Table 14 shows the maximum daily construction emissions.
As indicated in Table 14, emissions from construction activities would not exceed SCAQMD daily significance thresholds and would not result in any significant air quality impacts. Moreover, SCAQMD Rule 403 requires the following measures to reduce fugitive dust; these are required to be implemented at all construction sites located within the South Coast Air Basin:
Minimization of Disturbance. Construction contractors should minimize the area disturbed by clearing, grading, earth moving, or excavation operations to prevent excessive amounts of dust.
Soil Treatment. Construction contractors should treat all graded and excavated material, exposed soil areas, and active portions of the construction site, including unpaved on-site roadways to minimize fugitive dust. Treatment shall include, but not necessarily be limited to, periodic watering, application of environmentally safe soil stabilization materials, and/or roll compaction as appropriate. Watering shall be done as often as necessary, and at least twice daily, preferably in the late morning and after work is done for the day.
Soil Stabilization. Construction contractors should monitor all graded and/or excavated inactive areas of the construction site at least weekly for dust stabilization. Soil stabilization methods, such as water and roll compaction and environmentally safe dust control materials, shall be applied to portions of the construction site that are inactive for over four days. If no further grading or excavation operations are planned for the area, the area shall be seeded and watered until landscape growth is evident, or periodically treated with environmentally safe dust suppressants, to prevent excessive fugitive dust.
No Grading During High Winds. Construction contractors should stop all clearing, grading, earth moving, and excavation operations during periods of high winds (20 miles per hour or greater, as measured continuously over a one-hour period).
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Street Sweeping. Construction contractors should sweep all on-site driveways and adjacent streets and roads at least once per day, preferably at the end of the day, if visible soil material is carried over to adjacent streets and roads.
Table 14 Estimated Construction Emissions
Emissions (lbs/day)
Maximum Daily Emissions 7.3 18.4 9.5 1.1 0.9
SCAQMD Threshold 75 100 550 150 55
Exceed SCAQMD Threshold? No No No No No
Maximum On-site Emissions 7.3 8.9 7.6 0.8 0.6
Localized Significance Thresholds1 N/A 103 562 4 3
Exceed LST? No No No No No
Source: CalEEMod v. 2016.3.2 1 Allowable emissions (lbs/day) as a function of receptor distance (25 meters) from site boundary. LST for Source Receptor Area 2: Northwest Coastal LA County.
Source: http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/localized-significance-thresholds
Note: Please see Appendix A for complete modeling results. For a conservative estimate of project emissions, construction and operational emissions were modeled and reported for the maximum day during the winter, since emission estimates are typically higher in the winter months compared to the summer months. Winter emission estimates are then compared to the SCAQMD thresholds measured in pounds- per-day.
Conclusion
The operation and construction emissions associated with the proposed project would not generate significant air quality impacts. Additionally, as discussed under Criterion D, this project would not result in significant increases in traffic at intersections. Thus, the project would not require analysis for CO hotspots, based on the recommendations contained in Caltrans’ Transportation Project CO Protocol Manual.
D. Greenhouse Gas Emissions
Climate Change and Greenhouse Gases
Climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period of time. Climate change is the result of numerous, cumulative sources of greenhouse gases (GHGs). GHGs contribute to the “greenhouse effect,” which is a natural occurrence that helps regulate the temperature of the planet. The majority of radiation from the Sun hits the Earth’s surface and warms it. The surface in turn radiates heat back towards the atmosphere, known as infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping back into space and re-radiate it in all directions. This process is essential to supporting life on Earth because it warms the planet by approximately 60° Fahrenheit. Emissions from human activities since the beginning of the industrial revolution (approximately 250 years ago) are adding to the natural greenhouse effect by increasing the gases in the atmosphere that trap heat, thereby contributing to an average increase in the Earth’s temperature.
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GHGs occur naturally and from human activities. Human activities that produce GHGs include the burning of fossil fuels (coal, oil and natural gas for heating and electricity, gasoline and diesel for transportation); methane from landfill wastes and raising livestock, deforestation activities; and some agricultural practices. GHGs produced by human activities include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), and sulfur hexafluoride (SF6). Since 1750, it is estimated that the concentrations of carbon dioxide, methane, and nitrous oxide in the atmosphere have increased over 36%, 148%, and 18%, respectively, primarily due to human activity. Emissions of GHGs affect the atmosphere directly by changing its chemical composition while changes to the land surface indirectly affect the atmosphere by changing the way in which the Earth absorbs gases from the atmosphere. Potential impacts in California of global warming may include loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years (CEC 2009).
Significance Thresholds
Section 15064.4 of the CEQA Guidelines recommends that lead agencies quantify GHG emissions of projects and consider several other factors that may be used in the determination of significance of GHG emissions from a project, including: the extent to which the project may increase or reduce GHG emissions; whether a project exceeds an applicable significance threshold; and the extent to which the project complies with regulations or requirements adopted to implement a plan for the reduction or mitigation of GHG emissions.
CEQA Guidelines Section 15064.4 does not establish a threshold of significance. Lead agencies have the discretion to establish significance thresholds for their respective jurisdictions, and in establishing those thresholds, a lead agency may appropriately look to thresholds developed by other public agencies, or suggested by other experts, as long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7[c]). The CEQA Guidelines also clarify that the effects of GHG emissions are cumulative and should be analyzed in the context of CEQA’s requirements for cumulative impact analysis (see CEQA Guidelines Section 15130[f]). As a note, the CEQA Guidelines were amended in response to SB 97. In particular, the CEQA Guidelines were amended to specify that compliance with a GHG emissions reduction plan renders a cumulative impact insignificant.
Per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements that would avoid or substantially lessen the cumulative problem in the geographic area of the project. To qualify, such plans or programs must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency. Examples of such programs include a “water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plans [and] plans or regulations for the reduction of greenhouse gas emissions.” Put another way, CEQA Guidelines Section 15064(h)(3) allows a lead agency to make a finding of less than significant for GHG emissions if a project complies with adopted programs, plans, policies and/or other regulatory strategies to reduce GHG emissions.
In the absence of any adopted numeric threshold, the significance of the project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b) by considering whether the project complies with applicable plans, policies, regulations and requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. For this Project, the most directly applicable adopted regulatory plan to reduce GHG emissions is the 2016–2040
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RTP/SCS, which is designed to achieve regional GHG reductions from the land use and transportation sectors as required by SB 375 and the state’s long-term climate goals. This analysis also considers consistency with the City’s Sustainable City Plan (2009).
Consistency with Applicable Plans and Policies
The SCAG 2016–2040 RTP/SCS is expected to help California reach its GHG reduction goals by reducing transportation-related GHG emissions by eight percent by 2020 and 19 percent by 2035. The reduction strategies contained in the 2016-2040 RTP/SCS are primarily land use and transportation- oriented; however, because the proposed project involves an eldercare facility and a church preschool, most of the reduction strategies do not directly apply. Nevertheless, the project’s consistency with the 2016-2040 RTP/SCS is summarized in
Table 15. As discussed therein, the project would be consistent with the applicable reduction strategies of the 2016-2040 RTP/SCS.
Table 15 Consistency with 2016-2040 RTP/SCS
Reduction Strategy Project Consistency
Reflect the Changing Population and Demands
The SCAG region, home to about 18.3 million people in 2012, currently features 5.9 million households and 7.4 million jobs. By 2040, the Plan projects that these figures will increase by 3.8 million people, with nearly 1.5 million more homes and 2.4 million more jobs. High Quality Transit Areas (HQTA) will account for three percent of regional total land, but will accommodate 46 percent and 55 percent of future household and employment growth respectively between 2012 and 2040. The 2016 RTP/SCS land use pattern contains sufficient residential capacity to accommodate the region’s future growth, including the eight-year regional housing need. The land use pattern accommodates about 530,000 additional households in the SCAG region by 2020 and 1.5 million more households by 2040. The land use pattern also encourages improvement in the jobs-housing balance by accommodating 1.1 million more jobs by 2020 and about 2.4 million more jobs by 2040.
Consistency with 2016-2040 RTP/SCS:
The proposed project would establish a boutique hotel within walking and biking distance of the Wilshire Boulevard commercial corridor, including the Rodeo Drive shopping strip. Existing public transit facilities are located along Wilshire Boulevard, consisting of Metro Bus Lines 20 and 720, and the future Metro Purple Line rail project. The project would accommodate visitors to the City and provide jobs. The proposed project would also provide five bicycle racks and lockers. Implementation of the proposed project would place future visitors in proximity to businesses as well as facilitate use of active transportation to these uses.
Focus New Growth Around Transit
The 2016 RTP/SCS land use pattern reinforces the trend of focusing growth in the region’s HQTAs. Concentrating housing and transit in conjunction concentrates roadway repair investments, leverages transit and active transportation investments, reduces regional life cycle infrastructure costs, improves accessibility, avoids greenfield development, and has the potential to improve public health and housing affordability. HQTAs provide households with alternative modes of transport that can reduce VMT and GHG emissions.
Consistency with 2016-2040 RTP/SCS:
The proposed project would establish a boutique hotel within walking and biking distance of the Wilshire Boulevard commercial corridor, including the Rodeo Drive shopping strip. Existing public transit facilities are located along Wilshire Boulevard, consisting of Metro Bus Lines 20 and 720, and the future Metro Purple Line rail project. The project would be walkable, and pedestrian access to the existing transit would be available.
Provide More Options for Short Trips
Thirty eight percent (38%) of all trips in the SCAG region are less than three miles. The 2016 RTP/SCS provides two strategies to promote the use of active transport for short
Consistency with 2016-2040 RTP/SCS:
The proposed project would establish a boutique hotel within walking and biking distance of the Wilshire Boulevard commercial corridor, including the Rodeo Drive shopping
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Reduction Strategy Project Consistency
trips. Neighborhood Mobility Areas are meant to reduce short trips in a suburban setting, while “complete communities” support the creation of mixed-use districts in strategic growth areas and are applicable to an urban setting.
strip. Implementation of the proposed project would place future City visitors in proximity to these businesses as well as facilitate use of active transportation to these uses. Therefore, this project would support efforts to reduce short trips.
Transportation Strategies
Transit
Since 1991, the SCAG region has spent more than $50 billion dollars on public transportation. This includes high profile investments in rail transit and lower profile, vital investments in operations and maintenance. Looking toward to 2040, the 2016 RTP/SCS maintains a significant investment in public transportation across all transit modes and also calls for new household and employment growth to be targeted in areas that are well-served by public transportation to maximize the improvements called for in the Plan.
Consistency with 2016-2040 RTP/SCS:
The proposed project would establish a boutique hotel within walking and biking distance of the Wilshire Boulevard commercial corridor, including the Rodeo Drive shopping strip. Existing public transit facilities are located along Wilshire Boulevard, consisting of Metro Bus Lines 20 and 720, and the future Metro Purple Line rail project. Implementation of the proposed project would place future City visitors in proximity to these businesses as well as facilitate use of active transportation to these uses. The project would be walkable, and pedestrian access to the existing transit would be available.
Active Transportation
The 2016 RTP/SCS includes $12.9 billion for active transportation improvements, including $8.1 billion in capital projects and $4.8 billion as part of the operations and maintenance expenditures on regionally significant local streets and roads. The Active Transportation portion of the 2016 Plan updates the Active Transportation portion of the 2012 Plan, which has goals for improving safety, increasing active transportation usage and friendliness, and encouraging local active transportation plans. It proposes strategies to further develop the regional bikeway network, assumes that all local active transportation plans will be implemented, and dedicates resources to maintain and repair thousands of miles of dilapidated sidewalks. To accommodate the growth in walking, biking, and other forms of active transportation regionally, the 2016 Active Transportation Plan also considers new strategies and approaches beyond those proposed in 2012.
Consistency with 2016-2040 RTP/SCS:
The proposed project would establish a boutique hotel within walking and biking distance of the Wilshire Boulevard commercial corridor, including the Rodeo Drive shopping strip. Existing public transit facilities are located along Wilshire Boulevard, consisting of Metro Bus Lines 20 and 720, and the future Metro Purple Line rail project. Implementation of the proposed project would place future City visitors in proximity to these businesses as well as facilitate use of active transportation to these uses. The proposed project would also provide five bicycle racks and lockers. Therefore, walking or bicycling would be viable modes of transportation to reach numerous destinations or public transit.
Zero-Emissions Vehicles
While SCAG’s policies are technology neutral with regard to supporting zero and/or near zero-emissions vehicles, this section will focus on zero-emissions vehicles. Since SCAG adopted the 2012 RTP/SCS, the Governor’s Office released the Zero Emissions Vehicle (ZEV) Action Plan for 2013 and 2015. These plans identified state level funding to support the implementation of Plug-in Electric Vehicle (PEV) and Hydrogen Fuel Cell refueling networks. As part of the 2016 RTP/SCS, SCAG modeled PEV growth specific to Plug-in Hybrid Electric Vehicles (PHEV) in the SCAG region. These are electric vehicles that are powered by a gasoline engine when their battery is depleted. The 2016 RTP/SCS proposes a regional charging network that will increase the number of PHEV miles driven on electric power. In many instances, these chargers may double the electric range of PHEVs. A fully funded regional charging
Consistency with 2016-2040 RTP/SCS:
Of the 94 parking spaces, the project would designate nine spaces for electric vehicles, including two American with Disabilities Act (ADA)-designated spaces for a vehicle and a van.
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Reduction Strategy Project Consistency
network program would result in a reduction of one percent per capita GHG emissions.
Source: SCAG 2016-2040 RTP/SCS
Beverly Hills adopted the Sustainable City Plan, which contains goals intended to support sustainable development within the City. Implementation of this plan would contribute to a reduction in the City’s overall GHG emissions. The proposed project is particularly consistent with the Goal 3 Energy, which encourages “the use of energy in a clean and efficient manner and the use of renewable resources.” All light fixtures will be high-efficiency LED’s and controls will include occupancy sensors and daylight setting to reduce power consumption to maximize use of daylighting throughout the building. In addition, Low-E (low emissivity) glass will be used on the exterior of the building to reduce heat gain in the guestrooms and public areas. The project would also be consistent with Goal 4 Water, which states “Reduce water use while maintaining a garden-like quality in the City.” The project would implement a Contech Filterra System for processing of storm water, which will be used conjunction with drip-irrigation throughout the property to reduce water consumption. In addition, all plumbing fixtures will be low-flow to meet current code requirements set forth in the California Building Code.
Proposed Project GHG Emissions
As described above, compliance with plans, policies, and regulations adopted for the purpose of reducing GHG emissions indicates that project-related GHG emissions are less than significant. Quantitative calculations are provided below in support of the consistency analysis that